NUREG-1 838

Vol. 2

Safety Evaluation Report

Related to the License Renewal of

the Millstone Power Station,

Units 2 and 3

Docket Nos. 50-336 and 50-423

Dominion Nuclear Connecticut, Inc.

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Washington, DC 20555-0001 .0o0
lu .1A

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NUREG-1838, Vol. 2

Safety Evaluation Report

Related to the License Renewal of

the Millstone Power Station,

Units 2 and 3

Docket Nos. 50-336 and 50-423

Dominion Nuclear Connecticut, Inc.

Manuscript Completed: August 2005

Date Published: October 2005

Prepared by

J. H. Eads

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001
ABSTRACT

This safety evaluation report (SER) documents the technical review of the Millstone Power

Station (MPS), Units 2 and 3, license renewal applications (LRAs) by the staff of the U.S.

Nuclear Regulatory Commission (NRC) (the staff). By letter dated January 20, 2004, Dominion

Nuclear Connecticut, Inc. (Dominion or the applicant) submitted the LRAs for MPS in

accordance with Title 10, Part 54, of the Code of Federal Regulations (10 CFR Part 54).

Dominion is requesting renewal of the operating licenses for MPS Units 2 and 3, (Facility

Operating License Numbers DPR-65 and NPF-49, respectively) for a period of 20 years beyond

the current expiration dates of midnight July 31, 2015, for Unit 2 and midnight November 25,

2025, for Unit 3.

The MPS units are located on an approximately 500-acre site in the town of Waterford, CT, on

the north shore of Long Island Sound. The NRC issued the construction permits for MPS Units

2 and 3 on December 12, 1970,.and August 9, 1974, respectively. The operating licenses were

issued by the NRC on September 26,1975, for Unit 2 and January 31,1986, for Unit 3. MPS

Unit 2 consists of a two-steam-generator, four-coolant-loop, pressurized-light-water-reactor,

with a nuclear steam supply system supplied by Combustion Engineering, Inc. and a turbine

generator furnished by General Electric Corporation. The balance of the plant was originally

designed and constructed by Northeast Nuclear Energy Company with the assistance of its

agent, Bechtel Corporation. Unit 2 was designed to generate 2560 megawatt thermal (MWt), or

approximately 865 megawatt electric (MWe), but in 1979, the unit was uprated to a core power

output of 2700 MWt with a gross electrical output of approximately 895 MWe. MPS Unit 3

consists of a four-steam-generator, four-coolant-loop, pressurized-light-water-reactor, with a

nuclear steam supply system supplied by Westinghouse Electric Corporation and a turbine

generator furnished by General Electric Corporation. The balance of the plant was originally

designed and constructed by Northeast Nuclear Energy Company with the assistance of its

agent, Stone and Webster Corporation. MPS Unit 3 operates at a licensed power output of

3411 MWt, with a gross electrical output of approximately 1195 MWe.

This SER presents the status of the staffs review of information submitted to the NRC through

July 22, 2005, the cutoff date for consideration In the SER. The staff identified open items and

confirmatory items that had to be resolved before the staff could make a final determination on

the application. Sections 1.5 and 1.6 of this report summarize these items and their resolutions.

Section 6 provides the staffs final conclusion on the review of the MPS LRAs.

The NRC license renewal project manager is Mr. Johnny H. Eads. Mr. Eads may be reached at

(301) 415-1471. Written correspondence should be addressed to the License Renewal and

Environmental Impacts Program, U.S. Nuclear Regulatory Commission, Washington, DC

20555-0001.

iii
TABLE OF CONTENTS

Abstract ........................ II....................................iii

Table of Contents ..............................: v

Abbreviations . xviii

1 Introduction and General Discussion 11. . . 1.1 Introduction..1-1

1.2 License Renewal Background ....................... 1-2

1.2.1 Safety Review .......... ..... - 1-3

1.2.2 Environmental Review . ........................ 1-5

1.3 Principal Review Matters ........................ 1-5

1.4 Interim Staff Guidance ............... ........ 1-6

1.5 Summary of Open Items .. 1-9

1.6 Summary of Confirmatory Items .1-14

1.7 Summary of Proposed License Conditions ............................. 1-17

2 Structures and Components Subject to Aging Management Review .... 2-1

2.1 Scoping and Screening Methodology .. 2-1

2.1.1 Introduction ........... 2-1

2.1.2 Summary of Technical Information in the Application . .2-1

2.1.2.1 Scoping Methodology .2-2

2.1.2.2 Screening Methodology ..................... 2-5

2.1.3 Staff Evaluation ................. 2-7

2.1.3.1 Scoping Methodology . 2-8

2.1.3.2 Screening Methodology . 2-16

2.1.4 Evaluation Findings .'.................. 2-21

2.2 Plant-Level Scoping Results . . ....................... ;'.'.'.2-21

2.2A Unit 2 Plant-Level Scoping Results .'.- .. 2-21

2.2A.1 Summary of Technical Information in the Application .... 2-21

2.2A.2 Staff Evaluation . . .........................2-22

2.2A.3 Conclusion . . . .2-22

2.2B Unit 3 Plant-Level Scoping Results .. 2-23

2.2B.1 Summary of Technical Information in the Application .... 2-23

2.2B.2 Staff Evaluation . . . ............ 2-23

2.2B.3 Conclusion . .... 2-24

2.3 System Scoping and Screening Results - Mechanical Systems . . 2-24

2.3A Unit 2 System Scoping'and Screening Results .. 2-30

2.3A.1 Reactor Coolant System ... . 2-30

2.3A.1.1 Reactor Vessel . 2-30

2.3A.1.2 Reactor VessellIntemals .. 2-32

2.3A.1.3 Rea6tor Coolant System .. 2-33

2.3A.1.4 Steam Generator' .. 2-35

2.3A.2 Engineered Safety Features Systems .. . . 2-37

2.3A.2.1 Containment Spray System .. 2-37

2.3A.2.2 Safety Injection'System .. 2-38

V
2.3A.2.3 Refueling Water Storage Tank and Containment Sump System ................. ; .... I.

- -A - A .-

. ....................... 2-39

.m.4.o4 onultuown 0oo1ing sysiem ........................ 2.3A.2.5 Spent Fuel Pool Cooling System ....................

2.3A.3 Auxiliary Systems .......................................

2.3A.3.1 Circulating Water System .........................

2.3A.3.2 Screen Wash System ............................

2.3A.3.3 Service Water System ............................

2.3A.3.4 Sodium Hypochlorite System ......................

2.3A.3.5 Reactor Building Closed Cooling Water System ........ 2.3A.3.6 Chilled Water System ............................

2.3A.3.7 Instrument Air System. ........................ 2.3A.3.8 Nitrogen System ................................

2.3A.3.9 Station Air System ...............................

2.3A.3.10 Hydrogen System ..............................

2.3A.3.11 Chemical and Volume Control System .............. 2.3A.3.12 Sampling System ..............................

2.3A.3.13 Primary Makeup Water System ....................

2.3A.3.14 Access Control Area Air Conditioning System ........ 2.3A.3.15 Main Condensers Evacuation System .............. 2.3A.3.16 Containment Air Recirculation and Cooling System ....

2.3A.3.17 Containment and Enclosure Building Purge System ....

2.3A.3.18 Containment Penetration Cooling System ............. 2.3A.3.19 Containment Post-Accident Hydrogen Control System

2.3A.3.20 Control Room Air Conditioning System ............. 2.3A.3.21 Control Element Drive Mechanism Cooling System ....

2.3A.3.22 Diesel Generator Ventilation System ...............

2-41

2-42

2-44

2-45

2-46

2-48

2-50

2-51

2-53

2-56

2-58

2-59

2-60

2-61

2-62

2-64

2-65

2-66

2-67

2-68

2-69

2-70

2-71

2-73

2-74

2.3A.3.23

2.3A.3.24

2.3A.3.25

2.3A.3.26

2.3A.3.27

2.3A.3.28

2.3A.3.29

2.3A.3.30

2.3A.3.31

2.3A.3.32

2.3A.3.33

2.3A.3.34

2.3A.3.35

2.3A.3.36

2.3A.3.37

2.3A.3.38

2.3A.3.39

2.3A.3.40

2.3A.3.41

2.3A.3.42

2.3A.3.43

2.3A.3.44

ESF Room Air Recirculation System ......... Enclosure Building Filtration' System .......... Fuel Handling Area Ventilation System ........ Main Exhaust Ventilation System ............ Non-Radioactive Area Ventilation System ...... Process and Area Radiation Monitoring System

Radwaste Area Ventilation System .......... Turbine Building Ventilation System .......... Vital Switchgear Ventilation System .......... Unit 2 Fire ProtectionSystem ............... Unit 3 Fire Protection System ............... Domestic Water System ................... Diesel Generator System ..................

Diesel Generator Fuel Oil System ............ Station Blackout Diesel Generator System ..... Security System .........................

Clean LiquidWaste Processing System ....... Gaseous Waste Processing System .......... Post-Accident Sampling System ............. Station Sumps and Drains System ........... Aerated Liquid Radwaste System ............ Solid Waste Processing System .............

vi

.. 2-75 .. 2-76 .. 2-78 .. 2-79 .. 2-80 .. 2-81 .. 2-83 .. 2-84 .. 2-85 .. 2-86 .. 2-89 .. 2-90 .. 2-92 .. 2-94 .. 2-96 .. 2-98 .. 2-99

.. 2-101 .. 2-102 .. 2-104 .. 2-105 .. 2-106
2.3A.3.45 Turbine Building Closed Cooling Water System ...... 2-107

2.3A.3.46 Water Box Priming System ...... ................ 2-109

2.3A.4 Steam and Power Conversion Systems ...... ............... 2-110

2.3A.4.1 Main Steam System .... ................. 2-110

2.3A.4.2 Extraction Steam System .............. .......... 2-112

2.3A.4.3 Feedwater System .............................. 2-113

2.3A.4.4 Condensate System .................... 2-114

2.3A.4.5 Condensate Storage and Transfer System ..... ...... 2-116

2.3A.4.6 Condensate Demin Mixed Bed System ..... ......... 2-118

2.3A.4.7 Auxiliary Feedwater System ...... ................ 2-119

2.3A.4.8 Feedwater Heater Vents and Drains System .......... 2-120

2.3A.4.9 Moisture Separation and Reheat System ...... ....... 2-121

2.3A.4.10 Plant Heating and Condensate Recovery System .... 2-122

2.3A.4.11 Secondary Chemical Feed System ..... ........... 2-124

2.3A.4.12 Turbine Gland Sealing System ...... ............. 2-125

2.3A.4.13 Auxiliary Steam Reboiler and Deaerating Feedwater System ................................................ 2-126

2.3A.4.14 Exciter Air Cooler System ...... ................. 2-128

2.3A.4.15 Stator Liquid Cooler System ........ .............. 2-129

2.3A.4.16 Turbine Lube Oil System ......................... 2-130

2.3A.4.17 Electro Hydraulic Control System ........ ......... 2-131

2.3B Unit 3 System Scoping and Screening Results - Mechanical Systems .... 2-132

2.3B.1 Reactor Coolant System ................................ 2-132

2.3B.1.1 Reactor Vessel ................................ 2-133

2.3B.1.2 Reactor Vessel Intemals ......... ............... 2-134

2.31B.1.3 Reactor Coolant System ......................... 2-135

2.3B.1.4 Steam Generator .................... 2-138

2.3B.2 Engineered Safety Features Systems ...................... 2-139

2.38.2.1 Containment Recirculation System ...... ........... 2-139

2.38.2.2 Quench Spray System .......................... 2-141

2.3B.2.3 Safety Injection System .......................... 2-142

2.3B.2.4 Residual Heat Removal System ....... ............ 2-143

2.38.2.5 Fuel Pool Cooling and Purification System ... ........ 2-145

2.3B.3 Auxiliary Systems ................ 2-147

2.3B.3.1 Circulating Water System . .2-148

2.3B.3.2 Service Water System .. 2-149

2.3B.3.3 Sodium Hypochlorite System . .2-152

2.3B.3.4 Reactor Plant Component Cooling System . .2-153

2.3B.3.5 Turbine Plant Component Cooling Water-System ...... 2-155

2.3B.3.6 Chilled Water System .. 2-157

2.3B.3.7 Charging Pumps Cooling System . .2-158

2.3B.3.8 Safety Injection Pumps Cooling System . . 2-159

2.3B.3.9 Neutron Shield Tank Cooling System . . . 2-161

2.3B.3.10 Containment Atmosphere Monitoring System ... 2-162

2.3B.3.11 Containment Instrument Air System . . . 2-163

2.38.3.12 Instrument Air System . . .2-164

2.38.3.13 Nitrogen System .. . 2-165

2.3B.3.14 Service Air System . . .2-165

2.38.3.15 Chemical and Volume Control System .... 2-167

vii
2.3B.3.16 Reactor Plant Sampling System ...... ............ 2-169

2.3B.3.17 Primary Grade Water System ...... .............. 2-170

2.3B.3.18 Auxiliary Building Ventilation System ..... .......... 2-172

2.3B.3.19 Circulating and Service Water Pumphouse Ventilation System

................................................ 2-173

2.3B.3.20 Containment Air Filtration System ................. 2-174

2.3B.3.21 Containment Air Recirculation System ..... ........ 2-175

2.3B.3.22 Containment Purge Air System ...... ............. 2-176

2.3B.3.23 Containment Leakage Monitoring System .... ....... 2-177

2.3B.3.24 Containment Vacuum System .................... 2-178

2.3B.3.25 Control Building Ventilation System ..... ........... 2-179

2.3B.3.26 CRDM Ventilation and Cooling System ..... ........ 2-180

2.3B.3.27 Emergency Generator Enclosure Ventilation System .. 2-181

2.3B.3.28 Engineered Safety Features Building Ventilation System

......................................... .... 2-182

2.3B.3.29 Fuel Building Ventilation System ...... ............ 2-183

2.3B.3.30 Hydrogen Recombiner and Hydrogen Recombiner Building

HVAC System ................... I................. 2-184

2.3B.3.31 Main Steam Valve Building Ventilation System ....... 2-186

2.3B.3.32 Process, Effluent, and Airborne Radiation Monitoring System

.............................................. 2-187

2.3B.3.33 Service Building Ventilation and Air-Conditioning System

.............................................. 2-187

2.3B.3.34 Station Blackout Diesel Generator Building Ventilation System

.... 2-188 2.... ................... ...................... -atr 2-189

2.38.3.35 Supplementary Leak Collection and Release System .. 2-189

2.3B.3.36 Technical Support Center HVAC and Filtration System

.............................................. 2-190

2.3B.3.37 Turbine Building Area Ventilation System .... ....... 2-191

2.3B.3.38 Waste Disposal Building Ventilation System .... ..... 2-192

2.3B.3.39 Unit 2 Fire Protection System ..... ............... 2-193

2.3B.3.40 Unit 3 Fire Protection System ...... .............. 2-195

2.3B.3.41 Domestic Water System ......................... 2-196

2.38.3.42 Emergency Diesel Generator System ..... ......... 2-198

2.3B.3.43 Emergency Diesel Generator Fuel Oil System ....... 2-199

2.3B.3.44 Station Blackout Diesel Generator System .... ...... 2-201

2.3B.3.45 Security System ........ ...................... 2-204

2.3B.3.46 Boron Recovery System ........ ................. 2-205

2.3B.3.47 Radioactive Liquid Waste Processing System ....... 2-206

2.3B.3.48 Radioactive Gaseous Waste System ..... ......... 2-207

2.3B.3.49 Post-Accident Sampling System ..... ............. 2-208

2.3B.3.50 Radioactive Solid Waste System .................. 2-209

2.3B.3.51 Reactor Plant Aerated Drains System ..... ......... 2-210

2.3B.3.52 Reactor Plant Gaseous Drains System ............. 2-212

2.3B.3.53 Sanitary Water System ....... .................. 2-214

2.3B.4 Steam and Power Conversion Systems ......... ............ 2-216

2.3B.4.1 Main Steam System ....... ..................... 2-217

2.3B.4.2 Feedwater System .......... .................... 2-218

2.3B.4.3 Condensate Make-Up and Draw-Off System .... ..... 2-219

viii
2.3B.4.4 Steam Generator Blowdown System ... ........... 2-221

2.3B.4.5 Auxiliary Feedwater System ...................... 2-223

2.3B.4.6 Auxiliary Steam System .......................... 2-224

2.3B.4.7 Auxiliary Boiler Condensate and Feedwater System .... 2-225

2.3B.4.8 Hot Water Heating System ........................ 2-227

2.3B.4.9 Hot Water Pre-heating System ..... ............... 2-228

2.3B.4.10 Steam Generator Chemical Addition System . ........ 2-230

2.36.4.11 Turbine Plant Miscellaneous Drains System .... ..... 2-231

2.4 Scoping and Screening Results - Structures ......................... 2-232

2.4A Unit 2 Scoping and Screening Results - Structures ....... ............ 2-249

2.4A.1 Containment ............. .................. X ........... 2-249

2.4A.1.1 Summary of Technical Information in the Application ... 2-249

2.4A.1.2 Staff Evaluation ................ - 2-250

2.4A.1.3 Conclusion ................ 2-251

2.4A.2 Structures and Component Supports ........ ................ 2-251

2.4A.2.1 Unit 2 Containment Enclosure Building ..... ......... 2-252

2.4A.2.2 Unit 2 Auxiliary Building ........ ................... 2-253

2.4A.2.3 Unit 2 Warehouse Building ....................... 2-255

2.4A.2.4 Unit 2 Turbine Building .......................... 2-256

2.4A.2.5 Unit I Turbine Building ........................... 2-257

2.4A.2.6 Unit 1 Control Room and Radwaste Treatment Building . 2-258

2.4A.2.7 Unit 2 Fire Pump House ....... .................. 2-260

2.4A.2.8 Unit 3 Fire Pump House ....... .................. 2-261

2.4A.2.9 SBO Diesel Generator Enclosure and Fuel Oil Tank Vault

.................. .. . .. .. .. .. .. k .. ....... .. 2-262 2.4A.2.10 Unit 2 Condensate Polishing Facility and Warehouse No. 5

~~~. . . . . . . . . .

.... . . . . . . . . . . . . . . . . 2-263 . . .......... .......................... -6 2.4A.2.11 Security Diesel Generator Enclosure ..... ........... 2-264

2.4A.2.12 Stack Monitoring Equipment Building ..... ......... 2-265

2.4A.2.13 Millstone Stack ............ ..................... 2-266

2.4A.2.14 Switchyard Control House ...... ................. 2-267

2.4A.2.15 Retaining Wall ........ ........................ 2-268

2.4A.2.16 Switchyard, 345kV ............................. 2-268

2.4A.2.17 Unit 2 Intake Structure ......................... 2-269

2.4A.2.18 Sea Walls .......... ......................... 2-272

2.4A.2.19 Unit 2 Discharge Tunnel and Discharge Structure ..... 2-274

2.4A.2.20 Unit 2 Bypass Line ........... ................... 2-275

2.4A.2.21 Tank Foundations ............ ................... 2-276

2.4A.2.22 Yard Structures .......... ...................... 2-277

2.4A.3 NSSS Equipment Supports .............................. 2-278

-2.4A.3.1 Summary of Technical Information in the Application ... 2-278

2.4A.3.2 Staff Evaluation ......................... 2-279

2.4A.3.3 Conclusion ......... ................ 2-279

2.4A.4 General Structural Supports . ........................ 2-279

2.4A.4.1 Summary of Technical Information in the Application ... 2-279

2.4A.4.2 Staff Evaluation ................... 2-280

2.4A.4.3 Conclusion .. . .................. 2-280

2.4A.5 Miscellaneous Structural Commodities ........... ........... 2-280

2.4A.5.1 Summary of Technical Information in the Application ... 2-280

ix
2.4A.5.2 Staff Evaluation ................................ 2-281

2.4A.5.3 Conclusion ......... ......................... 2-281

2.4A.6 Load Handling Cranes and Devices ........ ................. 2-282

2.4A.6.1 Summary of Technical Information in the Application ... 2-282

2.4A.6.2 Staff Evaluation ................................ 2-282

2.4A.6.3 Conclusion ................................... 2-282

2.4B Unit 3 Scoping and Screening Results - Structures ..... .............. 2-283

2.4B.1 Containment ............. -2-283

2.4B.1.1 Summary of Technical Information in the Application . . . 2-283

2.4B.1.2 Staff Evaluation ................................ 2-284

2.4B.1.3 Conclusion ......... .......................... 2-289

2.4B.2 Structures and Component Supports ....................... 2-290

2.4B.2.1 Unit 3 Containment Enclosure Building ..... ......... 2-290

2.4B.2.2 Unit 3 Auxiliary Building ................. 2-292

2.4B.2.3 Unit 3 Control Building ................. 2-294

2.4B.2.4 Unit 3 Fuel Building ................... 2-295

2.4B.2.5 Railroad Canopy .............. .................. 2-297

2.4B.2.6 Unit 3 Hydrogen Recombiner Building ..... .......... 2-298

2.4B.2.7 Unit 3 Engineered Safety Features Building .... ...... 2-299

2.46.2.8 Unit 3 Main Steam Valve Building ..... ............. 2-300

2.46.2.9 Unit 3 Emergency Generator Enclosure and Fuel Oil Tank Vault .............. .......................... ; 2-301

2.46.2.10 Unit 2 Fire Pump House ....... ................. 2-303

2.46.2.11 Unit 3 Fire Pump House ......... ................ 2-304

2.46.2.12 Unit 3 Service Building ....... .................. 2-305

2.4B.2.13 Unit 3 Turbine Building ....... .................. 2-306

2.46.2.14 Unit 3 Auxiliary Boiler Enclosure ...... ............ 2-307

2.46.2.15 Unit 3 Technical Support Center .................. 2-308

2.46.2.16 Unit 3 Maintenance Shop ........ ................ 2-309

2.46.2.17 Unit 3 Waste Disposal Building ................... 2-310

2.46.2.18 SBO Diesel Generator Enclosure and Fuel Oil Tank Vault ........................ ........................ 2-311

2.4B.2.19 Unit 3 Condensate Polishing Enclosure ..... ....... 2-312

2.46.2.20 Unit 2 Condensate Polishing Facility and Warehouse No. 5 .............................................. 2-313

2.46.2.21 Security Diesel Generator Enclosure ..... .......... 2-314

2.46.2.22 Stack Monitoring Equipment Building ..... ......... 2-315

2.46.2.23 Millstone Stack . ........................ 2-316

2.46.2.24 Switchyard Control House ........... e ........... 2-317

2.46.2.25 Switchyard, 345kV ......................... 2-318

2.46.2.26 Unit 3 Circulating and Service Water Pumphouse ..... 2-319

2.46.2.27 Unit 3 West Retaining Wall ....... ............... 2-321

2.46.2.28 Sea Wall . .................................... 2-323

2.46.2.29 Unit 3 Circulating Water Discharge Tunnel and Discharge

Structure ....................... 2-324

2.4B.2.30 Unit 3 Recirculation Tempering Line ..... .......... 2-325

2.46.2.31 Vacuum Priming Pumphouse ...... .............. 2-327

2.46.2.32 Tank Foundations .......... .................... 2-328

2.46.2.33 Yard Structures ........... .................... 2-329

x
2.4B.3 NSSS Equipment Supports ............................. 2-330

2.4B.3.1 Summary of Technical Information in the Application . . . 2-330

2.4B.3.2 Staff Evaluation ................ ............... 2-331

2.4B.3.3 Conclusion ...................................... 2-331

2.4B.4 General Structural Supports ....... ...................... 2-331

2.4B.4.1 Summary of Technical Information in the Application ... 2-331

2.41.4.2 Staff Evaluation .................................. 2-332

2.4B.4.3 Conclusion ................................... 2-332

2.4B.5 Miscellaneous Structural Commodities ...... ............... 2-332

2.4B.5.1 Summary of Technical Information in the Application ... 2-332

2.4B.5.2 Staff Evaluation ................................. 2-333

2.48.5.3 Conclusion ..... . ............................. 2-333

2.4B.6 Load Handling Cranes and Devices ...... .................. 2-334

2.4B.6.1 Summary of Technical Information in the Application ... 2-334

2.48.6.2 Staff Evaluation ................................ 2-334

2.4B.6.3 Conclusion ................................... 2-334

2.5 Scoping and Screening Results - Electrical and Instrumentation and Controls

Systems...5.................................... .. 2-335

2.5.1 Cables and Connectors 'Systems ........................... 2-336

2.5.1.1 Summary of Technical Information in the Application .... 2-336

2.5.1.2 Staff Evaluation ........ i ......................... 2-336

2.5.1.3 Conclusion..;.. 2-338

2.5.2 Electrical Penetrations Systems ............ ................ 2-338

2.5.2.1 Summary of Technical Information in the Application .... 2-338

2.5.2.2 Staff Evaluation ........................ 2-339

2.5.2.3 Conclusion ....................... 2-339

2.5.3 Bus Duct Systems ........... ............ 2-340

2.5.3.1 Summary of Technical Information in the Application .... 2-340

2.5.3.2 Staff Evaluation.- ................. 2-340

2.5.3.3 Conclusion ................. 2-341

2.6 Conclusion for Scoping and Screening ............. ................. 2-341

3 Aging Management Review Results .......................... 3-1

3.0 Applicant's Use of the Generic Aging Lessons Learned Report ..... ........ 3-1

3.0.1 Format of the License Renewal Application ...... ............... 3-2

3.0.1.1 Overview of Table I ................................... 3-3

3.0.1.2 Overview of Table 2 ............................... ; 3-3

3.0.2 Staffs Review Process .................................... 3-4

3.0.2.1 Review of AMPs . ...................... 3-5

3.0.2.2 Review of AMR Results ...................... 3-6

3.0.2.3 FSAR Supplement ...................... 3-6

3.0.2.4 Documentation and Documents Reviewed ..... ......... 3-7

3.0.3 Aging Management Programs ................... . 3-7

3.0.3.1 AMPs that are Consistent with the GALL Report .... ..... 3-10

3.0.3.2 AMPs that are Consistent with the GALL Report with Exceptions

or Enhancements .. ... 3-24

3.0.3.3 AMPs that are Not Consistent with or Not Addressed in the GALL ... 3-99 .............................. . . . . . . . . . . . . . . . . . . ............ 39

3.0.4 Quality Assurance Program Attributes Integral to Aging Management

xi
IL'

Program............................. 3-117

3.0.4.1 Summary of Technical Information in Application ....... 3-118

3.0.4.2 Staff Evaluation......... I .... 3-119

3.0.4.3 Conclusion ............... 3-119

3.1 Aging Management of Reactor Vessel, Internals, and Reactor Coolant System

... . . . . . . .3-121 .................................................

3.1 A Unit 2 Aging Management of Reactor Vessel, Internals, and Reactor Coolant

System .... ...................... 3-121

3.1A.1 Summary of Technical Information in the Application -. ........... 3-121

3.1A.2 Staff Evaluation ............ ............................ 3-121

3.1A.2.1 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Not Recommended .... ..... 3-128

3.1A.2.2 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Recommended ..... ....... 3-133

3.1 A.2.3 AMR Results That Are Not Consistent With or Not Addressed in

the GALL Report ................................. 3-145

3.1A.3 Conclusion ....... . ............. ........ 3-162

3.1 B Unit 3 Aging Management of Reactor Vessel, Internals, and Reactor Coolant

System ..................................................... 3-163

3.1 B.1 Summary of Technical Information in the Application .... ...... 3-163

3.1 B.2 Staff Evaluation ......... 3-163

3.1 B.2.1 AMR Results That Are Consistent with the GALL Report, for

-Which Further Evaluation is Not Recommended ..... .... 3-170

3.1 B.2.2 AMR Results That Are Consistent with the'GALL Report, for

Which Further Evaluation is Recommended ..... ....... 3-173

3.1 B.2.3 AMR Results That Are Not Consistent With or Not Addressed in

the GALL Report .................................. 3-187

3.1 B.3 Conclusion ............................................. 3-202

3.2 Aging Management of Engineered Safety Features Systems .... ......... 3-203

3.2A Unit 2 Aging Management of Engineered Safety Features Systems ...... 3-203

3.2A.1 Summary of Technical Information in the Application .... ...... 3-203

3.2A.2 Staff Evaluation 3-203

3.2A.2.1 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Not Recommended .......... 3-206

3.2A.2.2 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Recommended ..... ....... 3-209

3.2A.2.3 AMR Results That Are Not Consistent With or Not Addressed in

the GALL Report ......... .......................... 3-212

3.2A.3 Conclusion 3.A3Cncuin...................... .3-217.. ..................... 3-217

3.2B Unit 3 Aging Management of Engineered Safety Features Systems ...... 3-218

3.2B.1 Summary of Technical Information in the Application .... ...... 3-218

3.2B.2 Staff Evaluation ............... 3-218

3.2B.2.1 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Not Recommended ........... 3-221

3.2B.2.2' AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Recommended ..... ....... 3-224

3.26.2.3 AMR Results That are Not Consistent With or Not Addressed in

the GALL Report ........... ...................... 3-228

3.2B.3 Conclusion ........................................... 3-236

xii
3.3 Aging Management of Auxiliary ...................... Systems ........ ; 3-236

3.3A Unit 2 Aging Management of Auxiliary Systems . .............. 3-236

3.3A.1 Summary of Technical Information in the Application . . 3-237

3.3A.2 Staff Evaluation. I . 3-238

3.3A.2.1 AMR Results That are Consistent with the GALL Report, for

Which Further Evaluation is Not Recommended . . 3-243

3.3A.2.2 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Recommended . . 3-249

3.3A.2.3 AMR Results That Are Not Consistent With or Not Addressed in

- the GALL Report . . 3-260

3.3A.3 Conclusion .. 3-304

3.3B Unit 3 Aging Management of Auxiliary Systems .. 3-305

3.3B.1 Summary of Technical Information in the Application . . 3-306

3.3B.2 Staff Evaluation ............... 3-306

3.38.2.1 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Not Recommended . . 3-311

3.38.2.2 AMR Results That Are Consistent with the GALL Report, for

Which Further-Evaluation is Recommended . . 3-318

3.38.2.3 AMR Results That Are Not Consistent With or Not Addressed in

the GALL Report . . I .. 3-329

3.3B.3 Conclusion .... ........... 3-376

3.4 Aging Management of Steam and Power Conversion System . . 3-376

3.4A Unit 2 Aging Management of Steam and Power Conversion System .. 3-376

3.4A.1 Summary of Technical Information in the Application . . 3-377

3.4A.2 Staff Evaluation .. 3-377

3.4A.2.1 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Not Recommended . . 3-380

3.4A.2.2 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Recommended . . 3-386

3.4A.2.3 AMR Results That Are Not Consistent With or Not Addressed in

the GALL Report .... .................. 3-390

3.4A.3 Conclusion .. 3-402

3.4B Unit 3 Aging Management of Steam and Power Conversion System .. 3-402

3.4B.1 Summary of Technical Information in the Application . . 3-402

3.4B.2 Staff Evaluation .. 3-403

3.4B.2.1 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Not Recommended . . 3-406

3.4B.2.2 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Recommended . . 3-412

3.48.2.3 AMR Results That Are Not Consistent With or Not Addressed in

the GALL Report .. 3-416

3.4B.3 Conclusion .. 3-426

3.5 Aging Management of Containment, Structures and Component Supports . . 3-426

3.5A Unit 2 Aging Management of Containment, Structures and Component Supports

..................................... 3-426

3.5A.1 Summary of Technical Information in the Application . . 3-427

3.5A.2 Staff Evaluation .. 3-427

3.5A.2.1 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Not Recommended .. 3-432

xiii
.LII

3.5A.2.2 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Recommended ..... ....... 3-437

3.5A.2.3 AMR Results That Are Not Consistent With or Not Addressed in

the GALL Report ................................. 3-452

3.5A.3 Conclusion ............................. 3-491

3.5B Unit 3 Aging Management of Containment, Structures and Component Supports

.... 3-492

3.5B.1 Summary of Technical Information in the Application .... ...... 3-493

3.5B.2 Staff Evaluation ........... ............................. 3-493

3.5B.2.1 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Not Recommended .... ..... 3-498

3.5B.2.2 AMR Results That Are Consistent with the GALL Report, for

- Which Further Evaluation is Recommended ..... ....... 3-503

3.5B.2.3 AMR Results That Are Not Consistent With or Not Addressed in

the GALL Report ..................... - 3-522

3.5B.3 Conclusion . .......... .......... 3-568

3.6 Aging Management of Electrical and Instrumentation and Controls .. ...... 3-568

3.6.1 Summary of Technical Information in the Application ..... ....... 3-568

3.6.2 Staff Evaluation .................. ....................... 3-569

3.6.2.1 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Not Recommended ..... .... 3-571

3.6.2.2 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Recommended ..... ....... 3-573

3.6.2.3 AMR Results That Are Not Consistent With or are Not Addressed

in the GALL Report ............................... 3-574

3.6.3 Conclusion ............................................ 3-580

3.7 Conclusion for Aging Management ............... .................. 3-580

4 Time-Limited Aging Analyses .............................................. 4-1

4.1 Identification of Time-Limited Aging Analyses .......................... 4-1

4.1.1 Summary of Technical Information in the Application ..... ......... 4-1

4.1.2 Staff Evaluation .............. ............................ 4-2

4.1.3 Conclusion ...... ....................................... 4-2

4.2 Reactor Vessel Neutron Embrittlement ................................ 4-3

4.2.1 Neutron Fluence . ........................................ 4-3

4.2.1.1 Summary of Technical Information in the Application ...... 4-3

4.2.1.2 Staff Evaluation ......... .......................... 4-4

4.2.1.3 FSAR Supplement ................................. 4-6

4.2.1.4 Conclusion ....................................... 4-7

4.2.2 Upper-Shelf Energy ........... ............................ 4-7

4.2.2.1 Summary of Technical Information in the Application ...... 4-7

4.2.2.2 Staff Evaluation ......... .......................... 4-9

4.2.2.3 FSAR Supplement ................................ 4-12

4.2.2.4 Conclusion ...................................... 4-13

4.2.3 Pressurized Thermal Shock ........ ........................ 4-14

4.2.3.1 Summary of Technical Information in the Application ..... 4-14

4.2.3.2 Staff Evaluation .................................. 4-15

4.2.3.3 FSAR Supplement ................................ 4-16

4.2.3.4 Conclusion ...................................... 4-17

xiv
4.2.4 Pressure-Temperature (P-T) Limits ................. 4-18

4.2.4.1 Summary of Technical Information ini the Application . 4-18

4.2.4.2 Staff Evaluation . 4-19

4.2.4.3 FSAR Supplement . 4-19

4.2.4.4 Conclusion....... ..... I 4-20

4.3 Metal Fatigue . . . .4-20

4.3A Unit 2 Metal Fatigue.. 4-21

4.3A.1 Summary of Technical Information in the Application .... 4-21

4.3A.2 Staff Evaluation . . . ............. 4-22

4.3A.3 FSAR Supplement .4-25

4.3A.4 Conclusion ...... .. ;. ... . 4-25

4.3B Unit 3 Metal Fatigue ................. . 4-25

4.3B.1 Summary of Technical Information in the Application .... 4-25

4.3B.2 Staff Evaluation .. . . 4-26

4.3B.3 FSAR Supplement . 4-31

4.3B.4 Conclusion . . . .............. 4-31

4.4 Environmental Qualification . . . .4-31

4.4.1 Summary of Technical Information in the Application . . 4-31

4.4.2 Staff Evaluation .. 4-32

4.4.3 Conclusion .. 4-33

4.5 Concrete Containment Tendon Prestress .. . . 4-33

4.5.1 Summary of Information in the Application .. 4-33

4.5.2 Staff Evaluation .. 4-34

4.5.3 Conclusion ........... 4-39

4.6 Containment Liner Plate and Penetration Fatigue Analyses . ... 4-39

4.6A Unit 2 Containment Liner Plate and Penetration Fatigue Analyses .. 4-39

4.6A.1 Summary of Technical Information in the Application ... . 4-40

4.6A.2 Staff Evaluation .. . . 4-40

4.6A.3 FSAR Supplement . 4-41

4.6A.4 Conclusion .. . . 4-41

4.6B Unit 3 Containment Liner Plate and Penetration Fatigue Analyses . ... 4-41

4.6B.1 Summary of Technical Information in the Application .... 4-42

4.6B.2 Staff Evaluation .. . . 4-42

4.6B.3 FSAR Supplement ................. 4-43

4.6B.4 Conclusion . . . .4-43

4.7 Other Plant-Specific Time-Limited Aging Analyses .. . . 4-43

4.7A Unit 2 Other Plant-Specific Time-Limited Aging Analyses . . 4-43

4.7A.1 Crane Load Cycle Limit . ,.. 4-43

4.7A.1.1 Summary of Technical Information in the Application .... 4-43

4.7A.1.2 Staff Evaluation . 4-44

4.7A.1.3 FSAR Supplement . 4-45

4.7A.1.4 Conclusion .. 4-45

4.7A.2 Reactor Coolant Pump Flywheel . 4-46

4.7A.2.1 Summary of-Technical Information in the Application .... 4-46

4.7A.2.2 Staff Evaluation . 4-46

4.7A.2.3 FSAR Supplement . 4-47

4.7A.2.4 Conclusion . 4-47

4.7A.3 Reactor Coolant Pump Code Case N-481 . 4-47

4.7A.3.1 Summary of Technical Information in the Application .... 4-47

xv
4.7A.3.2 Staff Evaluation ...................

4.7A.3.3 FSAR Supplement ................

4.7A.3.4 Conclusion ......................

4.7A.4 Leak-Before-Break ........................

4.7A.4.1 Summary of Technical Information in the

4.7A.4.2 Staff Evaluation ...................

4.7A.4.3 FSAR Supplement ................

4.7A.4.4 Conclusion ......................

4.7B Unit 3 Other Plant-Specific Time-Limited Aging Analyses

4.7B.1 Crane Load Cycle Limit .........

4.7B.1.1 Summary of Technical Information in the

4.7B.1.2 Staff Evaluation .................

4.7B.1.3 FSAR Supplement ................

4.76.1.4 Conclusion ......................

4.76.2 Reactor Coolant Pump Flywheel .............

4.76.2.1 Summary of Technical Information in the

4.7B.2.2 Staff Evaluation ...................

4.76.2.3 FSAR Supplement ................

4.76.2.4 Conclusion ......................

4.78.3 Leak-Before-Break .......................

4.76.3.1 Summary of Technical Information in the

4.76.3.2 Staff Evaluation ...................

4.7B.3.3 FSAR Supplement ................

4.7B.3.4 Conclusion ......................

4.8 Conclusion for Time-Limited Aging Analyses ............

...........

...........

;.. .. .. .. .. .

...........

...........

...........

...........

...........

...........

...........

...........

...........

...........

...........

...........

...........

...........

...........

...........

...........

... 4-48

... 4-50

... 4-50

... 4-50

... 4-50

4-51

... 4-53

... 4-54

... 4-54

... 4-54

... 4-54

... 4-54

... 4-55

... 4-55

... 4-56

... 4-56

... 4-56

... 4-57

... 4-57

... 4-57

... 4-57

... 4-58

... 4-59

... 4-60

... 4-60

5 Review by the Advisory Committee on Reactor Safeguards ............ 5-1 

6 Conclusions ........ 6-1

Appendices

APPENDIX A: Commitments for License Renewal ........ A-1

APPENDIX B: Chronology ........ B-1

APPENDIX C: Principal Contributors ........ C-1

APPENDIX D: References ................................... .... D-1

Tables

2.3A-1 Pressurizer Components that Require Additional Scoping Status Information .... 2-34

2.36-1 Pressurizer Components that Require Additional Scoping Status Information .... 2-137

3.0.3-1 MPS's Aging Management Programs ................................ 3-7

xvi
3.1A-i Staff Evaluation for Reactor Vessel, Internals, and Reactor Coolant System

Components in the GALL Report..... ........ 3-122

3.1 B-1 Staff Evaluation for Reactor Vessel, Internals, and Reactor Coolant System

Components in the GALL Report .3-164

3.2A-1 Staff Evaluation for Engineered Safety Features System Components in the GALL

Report.............................................................. 3-204

3.2B-1 Staff Evaluation for Engineered Safety Features System Components in the GALL

Report............................................ .................. 3-219

3.3A-1 Staff Evaluation for Auxiliary System Components in the GALL Report . . 3-238

3.38-1 Staff Evaluation for Auxiliary System Components in the GALL Report .3-307

3.4A-1 Staff Evaluation for Steam and Power Conversion System in the GALL Report .. 3-378

3.4B-1 Staff Evaluation for Steam and Power Conversion System in the GALL Report .. 3-411

3.5A-1 Staff Evaluation for Containment, Structures and Component Supports in the GALL -

Report ... ; 3-428

3.5B-1 Staff Evaluation for Containment, Structures and Component Supports in the GALL

Report................................................................ 3-494

3.6-1 Staff Evaluation for Electrical and Instrumentation and Controls in the GALL

Report .3-570

xvii
ABBREVIATIONS

ARTNDT irradiation induced shift in the reference nil ductility transition temperature MC alternate alternating current

AC air conditioning'or alternating current

ACI American Concrete Institute

ACRS Advisory Committee on Reactor Safeguards.

ACSR aluminum conductor steel reinforced

AERM aging effects requiring management

AFW auxiliary feedwater

AHU' air handling' unit

AISC American Institute of Steel Construction

AMP aging management program

AMR aging management review

AMSAC ATWS mitigating system actuating circuitry ANSI American National Standards Institute

API American Petroleum Institute

ASCE American Society of Civil Engineers. ASME American Society of Mechanical Engineers

ASTM American Society for Testing and Materials

ATWS anticipated transient without scram

B&PV boiler and pressure vessel

B&W Babcock and Wilcox

BMI bottom-mounted Instrumentation

BTP branch technical position

BWR boiling-water reactor

CASS cast austenitic stainless steel

CCC computer code collection

CE Combustion Engineering

CEA control element assembly

CEDM control element drive mechanism

CEOG Combustion Engineering Owners Group

CFR Code of Federal Regulations

CFS cubic feet per second

Cl confirmatory item

CF chemistry factor

CL&P Connecticut Light & Power

CLB current licensing basis

CMAA Crane Manufacturers Association of America

CO2 carbon dioxide

CR condition report

CRD control rod drive

CRDM control rod drive mechanism

CSPE chloro-sulfonated polyethylene

CUF cumulative usage factor

CVCS chemical and volume control system CVPS Central Vermont Public Service Corporation

xviii
Cv.. charpy upper shelf energy

DBA design-basis accident

DBE design-basis earthquake

DBS design-basis summary

DC direct current

DG draft regulatory guide

DOR Division of Reactors

DOTIV discrete ordinates transport code

DSS diverse scram system

DWST demineralized water storage tank

ECT eddy current testing

EDG emergency diesel generator

EEQ electrical equipment qualification

EFPD effective full power days

EFPH effective full power hours

EFPY effective full power year

ELD electronic licensing documentation database

EOC electric overhead crane

EOL end of life

EPDM ethylene propylene diene monomer

EPR ethylene propylene rubber

EPRI Electric Power Research Institute

EQ environmental qualification

EQML equipment qualification master list

EQR environmental qualification report

ER Environmental Report (10 CFR 51)

ESF engineered safety feature

ETA ethanolamine

FAC flow accelerated corrosion

FHA fire hazards analysis

FMP fatigue monitoring program

FP fire protection

FPER fire protection evaluation report

FSAR final safety analysis report

GALL NUREG-1801, Generic Aging Lessons Leamed Report"

GDC general design criterion

GDLS guidelines

GEIS generic environmental impact statement

GL generic letter

GPM gallons per minute

GRITS generation records information tracking system

GSI generic safety issue

GTR generic technical report

HELB high-energy line break

HMWPE high molecular weight polyethylene

HVAC heating, ventilation, and air conditioning

HPSI high pressure safety injection

IASCC irradiation-assisted stress corrosion cracking

ICI incore instrumentation

xix
IEEE Institute of Electrical and Electronics Engineers

ID inner diameter

IGSCC intergranular stress corrosion cracking

ILRT integrated leak-rate test

IN information notice

INPO Institute of Nuclear Power Operations

IPA integrated plant assessment

IR insulation resistance

ISG interim staff guidance

ISI inservice inspection

l&C instrumentation and controls

IWB requirements for Class 1 components of light-water cooled power plants

IWC requirements for Class 2 components of light-water cooled power plants

IWD requirements for Class 3 components of light-water cooled power plants

kV kilovolt

LBB leak before break

LCO limiting condition for operation

LCR load center room

LER licensee event report

LLRT local leak rate testing

LOCA loss-of-coolant accident

LPSI low pressure safety injection

LR license renewal

LRA license renewal application

LRIMS license renewal information management system

LSI limited structural integrity

LTOP low temperature overpressurization protection

MAER material aging effects report

MCC motor control center

MCL main coolant line

MEAP material, environment, aging effects, and aging management program

MEPL materials and equipment parts list

MIC microbiologically induced corrosion

MMOD minor modification

MMWEC Massachusetts Municipal Wholesale Electric Company

MNSA mechanical nozzle seal assembly

MOV motor operated valve

MPS Millstone Power Station

MR Maintenance Rule

MRP materials reliability program

MRRF Millstone Radwaste Reduction Facility

MSL mean sea level

MSLB main steam line break

MSRC Management Safety Review Committee

MSVB main steam valve building

MW megawatt

MWe megawatts-electrical

MWt megawatt-thermal

NACE National Association of Corrosion Engineers

xx
NCFM nuclear component fatigue management

NDE non-destructive examination

NEI Nuclear Energy Institute

NEPA National Environmental Policy Act

NFPA National Fire Protection Association

NPRDS nuclear plant reliability data system

NRC U.S. Nuclear Regulatory Commission

NSAC Nuclear Safety Analysis Center

NSR non-safety-related

NS>SR non-safety-related affecting safety-related

NSSS nuclear steam supply system

OBE operating basis earthquake

ODSCC outside diameter stress corrosion cracking

OE operating experience

01 open item

PAID piping and instrumentation diagram

PB pressure boundary

PCM personnel contamination monitor

PDT primary drain tank

PLL predicted lower limit

PM preventive maintenance

PMMS production maintenance management system

PNNL Pacific Northwest National Laboratory

PPB parts per billion

PPM parts per million

PRA probabilistic risk assessment

P-T pressure-temperature

PTS pressurized thermal shock

PVC polyvinyl chloride

PWR pressurized water reactor

PWSCC primary water stress corrosion cracking

QA quality assurance

QAP quality assurance program

QC quality control

QDR qualification document review

RAI request for additional information

RBCCW reactor building closed cooling water system

RCCA rod cluster control assembly

RCD regulatory commitment database

RCP reactor coolant pump

RCPB reactor coolant pressure boundary

RCS reactor coolant system

RFO refueling outage

RHR residual heat removal

RPCC reactor plant component cooling

RI-ISI risk informed - inservice inspection

RG regulatory guide

RPV reactor pressure vessel

RSST reserve station service transformer

xxi
I M

RT

RTD

RTNDT

RTpTs

RV

RVHP

RVI

RVID

RVSP

RWST

SAMA

SBO

SC

SCBA

SCC

SDC

SER

SFRM

SG

SGFP

SGSIP

Si

SIAS

SPCS

SR

SRP

SRP-LR

SSC

SVI

SW

SWGR

t

TBCCW

TGSCC

TIC

TLAA

TRM

TS

TSCR

TSP

USE

UT

UV

VAC

VETIP

VT

WINCDMS

WOG

XLPE

radiography testing

resistance temperature detector

reference nil ductility transition temperature

reference temperature for pressurized thermal shock

reactor vessel

reactor vessel head penetration

reactor vessel internals

reactor vessel integrity database

reactor vessel surveillance program

refueling water storage tank

severe accident mitigation alternative

station blackout

structure and component

self contained breathing apparatus

stress corrosion cracking

shutdown cooling

safety evaluation report

safety function requirements manual

steam generator

steam generator feedwater pump

steam generator structural integrity program

safety injection

safety injection actuation signal

steam and power conversion systems

safety-related

Standard Review Plan

NUREG-1 800, 'Standard Review Plan for Review of License Renewal

Applications for Nuclear Power Plants"

structures, systems, and components

single volumetric indication

service water

switchgear

thickness

turbine building closed cooling water

transgranular stress corrosion cracking

temperature indicating controllers

time-limited aging analysis

technical requirements manual

technical specification

technical specification change request

trisodium phosphate dodecahydrate

upper shelf energy

ultrasonic testing

ultraviolet

voltage alternating current

vendor equipment technical information program

visual test

chemistry data management system

Westinghouse Owners Group

cross-linked polyethylene

)odl
- -

3.1 -Aging Management of Reactor Vessel. Internals, and Reactor Coolant System

3.1A Unit 2 Aaing Management of Reactor Vessel. Internals, and Reactor Coolant

System

This section of the SER documents the staff's review of the applicant's aging management

review (AMR) results for the reactor vessel, intemrals, and reactor coolant system components

and component groups associated with the following systems:

* -reactor vessel

* reactor vessel internals

* reactor coolant system

* steam'generator

3.1A.1 Summary of Technical Information in the Application

In LRA Section 3.1, the applicant provided AMR results for reactor vessel, internals, and reactor

coolant system components and component groups. In LRA Table 3.1.1, "Summary of Aging

Management Evaluations in Chapter IV of NUREG-1801 for Reactor Vessel, Internals, and

Reactor Coolant System," the applicant provided a summary comparison of its AMRs with the

AMRs evaluated in the GALL Report for the reactor vessel, internals, and reactor coolant

system components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

aging effects requiring management (AERMs). These reviews included evaluation of plantspecific and industry operating experience. The plant-specific evaluation included reviews of

condition reports and discussions with appropriate site personnel to identify AERMs. The

applicant's review of industry operating experience included a review of the GALL Report and

operating experience issues identified since the issuance of the GALL Report.

3.1A.2 Staff Evaluation

The staff reviewed LRA Section 3.1 to determine if the applicant provided sufficient information

to demonstrate that the effects of aging for the reactor system components that are within the

scope of license renewal and subject to an AMR will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

Also, the staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report. However, the staff did verify that the material presented

in the LRA was applicable and that the applicant had identified the appropriate GALL AMRs.

The staff's evaluations of the AMPs are documented in Section 3.0.3 of this SER. Detail of the

staff's audit evaluation are documented in the MPS audit and review report and are summarized

in Section 3.1A.2.1 of this SER.

The staff also performed an onsite audit of those selected AMRs that were consistent with the

GALL Report and for which further evaluation is recommended. The staff confirmed that the

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applicant's further evaluations were consistent with the acceptance criteria in Section 3.1.2.2 of

NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear

Power Plants," dated July 2001. The staffs audit evaluation are documented in the MPS audit

and review report and are summarized in Section 3.1A.2.2 of this SER.

The staff performed an onsite audit and conducted a technical review of the remaining AMRs

that were not consistent with or not address in the GALL Report. The audit and technical review

included evaluating whether allplausible aging effects were identified and the aging effects

listed were appropriate for the combination of materials and environments specified. The staffs

audit evaluation are documented in the MPS audit and review report and summarized in

Section 3.1A.2.3 of this SER. The staffs evaluation of its technical review is also documented in

Section 3.1A.2.3 of this SER.

Finally, the staff reviewed the AMP summary descriptions in the FSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the reactor vessel, internals, and reactor coolant system components.

Table 3.1A-1 below provides a summary of the staffs evaluation of components, aging

effects/mechanisms, and AMPs listed in LRA Section 3.1 that are addressed in the GALL

Report.

Table 3.1A-1 Staff Evaluation for Reactor Vessel, Internals, and Reactor Coolant System

Components In the GALL Report

Component Grobup, APininEffec t! 'R AMP P In GAL ( P In IRStaff Evalat n

*', - t -- 4M. A Mechani-r. i :i ; - Reporf5- -r -;-;- -s :,mC ;

Reactor coolant Cumulative fatigue TLAA, evaluated TLAA This TLAA is

pressure boundary damage in accordance with evaluated in Section

components 10 CFR 54.21(c) 4.3, Metal Fatigue (Item Number

3.1.1-01)

Steam generator Loss of material Inservice Chemistry control for Consistent with

shell assembly due to pitting and inspection; water secondary systems GALL, which

(Item Number crevice corrosion chemistry program (B2.1.6); recommends further

3.1.1- 02) Inservice inspection evaluation (See

program: systems, Section 3.1.2.2.2)

components

__ _ (B2.1.18)

Pressure vessel Loss of fracture TLAA, evaluated TLAA This TLAA is

ferritic materials toughness due to in accordance with evaluated in Section

that have a neutron neutron Irradiation Appendix G of 4.2, Reactor Vessel

fluence greater than embrittlement 10 CFR 50 and Neutron

1.0E17 n/cm2 (E>1 RG 1.99 Embrittiement.

MeV)

(Item Number

3.1.1- 04)

Reactor vessel Loss of fracture Reactor vessel Reactor vessel Consistent with

beltline shell and toughness due to surveillance surveillance (B2.1.20) GALL, which

welds neutron irradiation recommends further

(Item Number embrittiement evaluation (See

3.1.1- 05) Section 3.1.2.2.3)

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Component Group AgingEffec r .- ;-AMPi- GAL IRA Stif Eva ion

_.ic~- : Meh anism - :. ; o .*so W -

Westinghouse and Loss of fracture Plant-specific Not applicable (See

Babcock & Wilcox toughness due to Section 3.1.2.2.3)

(B&W) baffle/former neutron Irradiation

bolts embrittlement and MPS Unit 2 is of

(Item Number void swelling Combustion

3.1.1- 06) Engineering design.

Baffie/former bolts

are not used in the

reactor vessel

Internals.

Small-bore reactor Crack initiation and Inservice Chemistry control for Consistent with

coolant system and growth due to SCC, Inspection; water primary systems GALL. which

connected systems IGSCC, and thermal chemistry; program (B2.1.5); recommends further

piping and mechanical one-time Inservice Inspection evaluation (See

(Item Number loading Inspection program: systems, Section 3.1.2.2.4)

3.1.1- 07) components and

supports (B2.1.18)

Vessel shell Crack growth due to TLAA Not applicable (See

(Item Number cyclic loading Section 3.1.2.2.5)

3.1.1- 10)

Reactor Internals Changes in Plant-specific Inservice inspection Consistent with

(Item Number dimension due to program: reactor GALL, which

3.1.1-11) void swelling vessel internals recommends further

(B2.1.17) evaluation (See

Section 3.1.2.2.6)

PWR core support Crack Initiation and Plant-specific Chemistry control for Consistent with

pads, instrument growth due to SCC primary systems GALL, which

tubes (bottom head and/or PWSCC program (B2.1.5); recommends further

penetrations), Inservice inspection evaluation (See

pressurizer spray program: systems, Section 3.1.2.2.7)

heads, and nozzles components and

for the steam supports (B2.1.18);

generator Inservice inspection Instruments and program: reactor

drains vessel internals

(Item Number (B2.1.17)

3.1.1- 12)

CASS reactor Crack Initiation and Plant-specific Chemistry control for Consistent with

coolant system growth due to SCC primary systems GALL, which

piping program (B2.1.5); recommends further

(Item Number Inservice inspection evaluation (See

3.1.1- 13) program: systems, Section 3.1.2.2.7)

components and

supports (B2.1.1 8) --,

3-123
- I __ _M

*Cornpn Gnt Group~ LAMP An GALL: - Z.- in LRA : Staff Evaluation - -- -, ,: - -,- ,i_,; A-~ i. A Pi Jiu 

' - ' 'e:--! .M:echanslm r poiii .. .': 

Pressurizer Crack initiation and Inservice Chemistry control for Consistent with

instrumentation growth due to inspection; water primary systems GALL, which

penetrations and PWSCC chemistry program (B2.1.5); recommends further

heater sheaths and Inservice inspection evaluation (See sleeves made of NI program: systems, Section 3.1.2.2.7) alloys components and

(Item Number supports (B2.1.18) 3.1.1-14)

Westinghouse and Crack initiation and Plant-specific Not applicable (See B&W baffle former growth due to SCC Section 3.1.2.2.8)

bolts and irradiation-

(Item Number assisted stress MPSUnit 2 is of

3.1.1- 15) corrosion cracking Combustion

(IASCC) Engineering design. Baffle/former bolts

are not used In the

reactor vessel'

intemals.

Westinghouse and Loss of preload due Plant-specific Not applicable (See B&W baffle former to stress relaxation Section 3.1.2.2.9) bolts

(Item Number MPS Unit 2 is of

3.1.1- 16) Combustion

Engineering design. Baffle/former bolts

are not used in the

reactor vessel

internals.

Steam generator Loss of section Plant-specific Not applicable (See feedwater thickness due to Section 3.1.2.2.10) impingement plate erosion

and support (Item Number

3.1.1- 17)

(Alloy 600) Steam Crack Initiation and Steam generator Chemistry control for Consistent with

generator tubes, growth due to tubing integrity; primary systems GALL, which

repair sleeves, and PWSCC, ODSCC, water chemistry program (B2.1.5); recommends further

plugs and/or IGA, or loss Chemistry control for evaluation (See (Item Number of material due to secondary systems Section 3.1.2.2.11) 3.1.1- 18) wastage and pitting program (B2.1.6); corrosion, and Steam generator fretting and wear, or structural integrity deformation due to (B2.1.22)

corrosion at tube

support plate intersections

Tube support lattice Loss of section Plant-specific Not applicable (See bars made of thickness due to Section 3.1.2.2.12) carbon steel flow-accelerated

(Item Number corrosion (FAC)

3.1.1- 19)

3-124
Componnt Group ,AgingfEffec M iln LL : A iA MP in S:taff Evalion - :-;.; -. . Mechanism. .. RprJ ...- :-- *.- - RpA;ae'. ;_i~-L

Carbon steel tube Ugament cracking Plant-specific Not applicable (See

support plate due to corrosion Section 3.1.2.2.13) (item Number

3.1.1- 20)

Steam generator Loss of material Combustion Flow-accelerated Consistent with

feedwater inlet ring due to flow engineering (CE) corrosion program GALL, which

and supports accelerated steam generator (62.1.11) recommends further

(Item Number corrosion feedwater ring evaluation (See 3.1.1- 21) inspection Section 3.1.2.2.14)

Although the Unit 2

steam generators

are not CE System

80 steam

generators, the

feedwater inlet ring is Included in the

flow accelerated

corrosion program.

Reactor vessel Crack initiation and Reactor head Inservice inspection Consistent with

closure studs and growth due to SCC closure studs program: systems, GALL, which

stud assembly and/or IGSCC components and recommends no

(Item Number supports (B2.1.18) further evaluation

3.1.1- 22) (See Section

3.1.2.1)

CASS pump casing Loss of fracture Inservice Inservice inspection Consistent with

and valve body toughness due to Inspection program: systems, GALL, which

(Item Number thermal aging components and recommends no

3.1.1-23) embrittlement supports (B2.1.18) further evaluation

(See Section

3.1A.2.1 .1)

CASS piping (Item Loss of fracture Thermal aging Inservice inspection Consistent with

Number toughness due to embrittiement of program: systems, GALL (See Section

3.1.1-24) thermal aging CASS components and 3.1.2.1.1) embrittlement supports (82.1.18) Loss of Fracture

Toughness is

managed with

inservice Inspection

program: systems,

components and

supports, which

takes some

exception to the

GALL AMP.

BWR piping and Wall thinning due to Flow- accelerated Flow-accelerated Consistent with

fittings; steam flow- accelerated corrosion corrosion (82.1.1 1) GALL, which

generator corrosion recommends no

components (Item further evaluation

Number (See Section

3.1.1-25) . . 3.1.2.1.2)

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in:Z

Component roup -- Aging EffectI AMP in'GALL-- A In -M LR St Evaluation

,~-, , . w~w;,,_,:*; MechinmtI a -. '- .. - .; 

RCPB) valve Loss of material Bolting integrity Bolting integrity Consistent with

closure bolting, due to wear; loss of GALL, (See Section

manway and preload due to 3.1.2.1.3)

holding bolting, and stress relaxation;

closure bolting in crack initiation and

high pressure and growth due to cyclic

high temperature loading and/or SCC

systems

(Item Number

3.1.1-26)

CRD nozzle Crack initiation and Ni-alloy nozzles Chemistry control for Consistent with

(Item Number growth due to and penetrations; primary systems GALL, which

3.1.1-35) PWSCC water chemistry program (B2.1.5); recommends no

Inservice inspection further evaluation

program: systems, (See Section

components and 3.1.2.1)

supports (B2.1.18)

Reactor vessel Crack initiation and Inservice - Chemistry control for Consistent with

nozzles safe ends growth due to cyclic inspection; water primary systems GALL, which

and CRD housing; loading, and/or chemistry program (82.1.5); recommends no

reactor coolant SCC, and PWSCC Inservice inspection further evaluation

system components program: systems, (See Section

(except CASS and components and 3.1.2.1)

bolting) supports (82.1.18)

(Item Number

3.1.1-36)

Reactor vessel Loss of fracture Thermal aging Inservice inspection Consistent with

internals CASS toughness due and neutron program: reactor GALL, which

components thermal aging, irradiation vessel internals recommends no

(Item Number neutron irradiation embrittlement (82.1.17) further evaluation

3.1.1-37) embrittlement, and (See Section

void swelling 3.1.2.1)

External surfaces of Loss of material Boric acid Boric acid corrosion Consistent with

carbon steel due to boric acid corrosion (B2.1.3) GALL, which

components In corrosion recommends no

reactor coolant further evaluation

system pressure (See Section

boundary 3.1.2.1)

(Item Number

3.1.1-38)

Steam generator Loss of material Inservice Not applicable (See

secondary due to erosion inspection Section 3.1.2.3.4)

manways and The steam

handholds (carbon generators are

steel) recirculating- type

(Item Number steam generators.

3.1.1-39)

3-126
Component Group' Aging'Effe t ;' A I lGALL' - AMP in i i A S taff Evaluation- r ;;~ - ^9^Mechanlsm:;'; '.'4Report.'~ ' US*l-< .

Reactor Internals, Loss of material Inservice Inservice inspection Consistent with

reactor vessel due to wear inspection - program: reactor GALL, which

closure studs, and .. vessel internals recommends no

core support pads (B2.1.17); Inservice further evaluation

(Item Number inspection program: (See Section

3.1.1-40) systems, components 3.1.2.1)

and supports

(82.1.18)

Pressurizer Integral Crack initiation and Inservice Inservice inspection Consistent with

support growth due to cyclic Ins;ectioh, ' program: systems, GALL, which

(Item Number loading : components and recommends no

3.1.1-41) supports (82.1.18) further evaluation

(See Section

' ''' 3.1.2.1)

Upper and lower, Loss of preload due Inservice - Not applicable. Internals assembly to stress relaxation inspection; loose MPS Unit 2 reactor

(Westinghouse) part and/or vessel was

(Item Number neutron noise designed by 3.1.1-42) monitoring Combustion -___ _ _Engineering.

Reactor Vessel Loss of fracture PWR vessel Ilnservice inspection Consistent with

Internals In fuel toughness due to internals, water *' program: reactor GALL (See Section

zone region (except neutron irradiation chemistry vessel Internals 3.1.2.1 A)

Westinghouse B&W embrittlement and (82.1.17);

baffle former bolts) void swelling Chemistry control for

(Item Number primary systems

3.1.1-43) . program (B2.1.5)

Steam generator Crack Initiation and Inservice Inservice inspection Consistent with

upper and lower growth due to SCC. inspection; water program: systems, GALL, which

heads, tubesheets, PWSCC, and/or chemistry components and - recommends no

and primary nozzles IASCC ' supports (B2.1.18); further evaluation

and safe ends (Item Chemistry control for (See Section

Number primary systems .3.1.2.1)

3.1.1-44) program (82.1.5) '

Vessel internals Crack initiation and PWR vessel Inservice inspection Consistent with'

(except growth due to SCC internals; water program: reactor GALL, which

Westinghouse and and IASCC chemlistry ' vessel Internals recommends no

B&W baffle former - (82.1.17); Chemistry further evaluation

bolts) control for primary (See Section

(Item Number 3.1.1 - systems program 3.1.2.1)

45) (82.1.5).

Reactor Internals Loss of preload due Inservice Not applicable. (B&W screws and to stress relaxation Inspection; loose MPS Unit 2 reactor

bolts) part monitoring vessel was

(Item Number designed by 3.1.1-46) Combustion

_Engineering.

Reactor vessel Loss of material Reactor head Not consistent with

closure studs and due towear closure studs GALL (See Section

stud assembly .3.1.2.3) (Item Number

3.1.147)

3-127.-
ilLI

Coponett-Group: --- gMi gPEf! ct . A G- i A MP.In. LR -. ...Staff E Iationo

.... ~M6chanlsm.-. ~ -Report.~ .. ~.-*.

Reactor internals Loss of preload due Inservice Inservice inspection Not consistent with

(Westinghouse to stress relaxation Inspection; loose program: reactor GALL (See Section

upper and lower part monitoring vessel internals 3.1.2.1)

internal assemblies, (B2.1.17)

CE bolts and be

rods)

(Item Number

3.1.1-48) .

The staff's review of the MPS reactor vessel, internals, and reactor coolant system components

and associated components followed one of several approaches. One approach, documented

in Section 3.1A.2.1, involves the staffs review of the AMR results for components in the reactor

vessel, internals, and reactor coolant system components that the applicant indicated are

consistent with the GALL Report and do not require further evaluation. Another approach, -

documented in Section 3.1A.2.2, involves the staffs review of the AMR results for components

in the reactor vessel, internals, and reactor coolant system components that the applicant

indicated are consistent with the GALL Report and for which further evaluation is

recommended. A third approach, documented in Section 3.1A.2.3, involves the staffs review of

the AMR results for components in the reactor vessel, internals, and reactor coolant system

components that the applicant indicated are not consistent with the GALL Report or are not

addressed in the GALL Report. The staff's review of AMPs that are credited to manage or

monitor aging effects of the reactor coolant system components is documented in Section 3.0.3

of this SER.

3.1A.2.1 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Not Recommended

Summary of Technical Information in the Avylication. In Section 3.1.2.1 of the LRA, the

applicant identified the materials, environments, and aging effects requiring management. The

applicant identified the following programs that manage the aging effects related to the reactor

vessel, internals, reactor coolant system, and steam generator components:

* boric acid corrosion program

* chemistry control for primary systems program

* chemistry control for secondary systems program

* inservice inspection program: reactor vessel internals program

* inservice inspection program: systems, components and supports program

* reactor vessel surveillance program

* closed-cycle cooling water system program

* general condition monitoring program

* work control process program

* flow-accelerated corrosion program

* steam generator structural integrity program

Staff Evaluation. In Tables 3.1.2-1 through 3.1.24 of the LRA, the applicant provided a

summary of AMRs for the reactor vessel, internals, reactor coolant system, and steam

generator, and identified which AMRs it considered to be consistent with the GALL Report.

3-128
For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation. - ; 

The applicant provided a note for each AMR line item. The notes described how the information

in the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicated the AMR was consistent with the GALL Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the

AMP identified in the GALL Report. The staff audited these line items to verify consistency with

the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by

the applicant was consistent with the AMP identified in the GALL Report and whether the AMR

was valid for the site-specific conditions.

Note C indicated that the component for the AMR line item is different, but consistent with the

GALL Report for material, environment, and aging effect. In addition, the AMP is consistent with

the AMP identified by the GALL Report. This note indicates that the applicant was unable to find

a listing of some system components in the GALL Report. However, the applicant identified a

different component in the GALL Report that had the same material, environment, aging effect,

and AMP as the component that was under review. The staff audited these line items to verify

consistency with the GALL Report. The staff also. determined whether the AMR line item of the

different component was applicable to the component under review and whether the AMR was

valid for the site-specific conditions.

Note D indicated that the component for the AMR line item is different, but consistent with the

GALL Report for material, environment, and aging effect. In addition, the AMP takes some

exceptions to the AMP identified in the GALL Report. The staff audited these line items to verify

consistency with the GALL Report. The staff verified whether the AMR line item of the different

component was applicable to the component under review. The staff verified whether the

identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The staff

also determined whether the AMP identified by the applicant was consistent with the AMP

identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note E indicated that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified

by the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the Unit 2 LRA, as

documented in the MPS audit and review report. The staff did not repeat its review of the

3-129
!it

matters described in the GALL Report. However, the staff did verify that the material presented

in the LRA was applicable and that the applicant had identified the appropriate GALL Report

AMRs. The staffs evaluation is discussed below.

3.1A.2.1.1 Loss of Fracture Toughness Due to Thermal Aging Embrittlement

In the discussion section of Table 3.1.1, Item 24 of the LRA, the applicant stated that loss of

fracture toughness is not an aging effect requiring management for applicable CASS piping and

components. During the audit and review, the staff asked the applicant for clarification as to

why loss of fracture toughness is not an aging effect requiring management. The applicant

replied that loss of fracture toughness of the CASS piping is not an aging effect requiring

management because the results of leak-before-break (LBB) analysis demonstrated that there

was a large margin between detectable flaw size and flaw instability. The staff reviewed the

applicant's TLAA report on "leak-before-break" and found that the LBB analysis is not a flaw

tolerance evaluation as specified by the GALL Report. The applicant agreed that the LBB

analysis cannot be used to manage the loss of fracture toughness due to thermal aging

embrittlement. The applicant submitted an LRA supplement letter dated July 7, 2004, and

stated that:

Note "6" for Unit 2 Tables 3.1.2-1 through 3.1.2-4 (Pages 3-101), should state

the following:

For potentially susceptible CASS materials, either enhanced volumetric

examinations or a unit or component specific flaw tolerance evaluation

(considering reduced fracture toughness and unit specific geometry and

stress information) will be used to demonstrate that the

thermally-embrittled material has adequate fracture toughness in

accordance with NUREG-1801 Section XI.M12.

'Loss of Fracture Toughness' as an aging effect for component groups

'Pipe (Safe Ends for SI and SDC)', 'Pipe (Surge Line Piping and Fittings)',

and 'Pressurizer (Safe End for PZR Surge Nozzle)' should be added in

Unit 2 Table 3.1.2-3, (pages 3-72, 74, and 77, respectively). The 'Loss of

Fracture Toughness' is managed by the inservice inspection program:

systems, components and supports and corresponds to GALL Item

IV.C2.1-f. The Notes for these entries are "A,6" and the Table 1 Item' is

"3.1.1-24." The material for the pressurizer component (identified above)

will designate that it is CASS material. NOTE: Only the 'Loss of Fracture

Toughness' entry will have Note "6" listed for the above component

groups.

The "Discussion" column in Unit 2 Table 3.1.1, Item 24, (page 3-31) should have

been read as follows:

Consistent with NUREG-1801. Loss of Fracture Toughness is managed

with the inservice inspection program: systems, components and

supports and this program takes some exception to the NUREG-1 801

AMP.

3-130
Additionally, a new commitment, Item 27, should be added to Appendix A,

Table A6.0-1 as follows and will be implemented prior to the period of extended

operation:

For potentially susceptible CASS materials, either enhanced volumetric

examinations or a unit or component specific flaw tolerance evaluation

(considering reduced fracture toughness and unit specific geometry and

stress information) will be used to demonstrate that the

thermally-embrittled material has adequate fracture toughness in

accordance with NUREG-1801 Section XI.M12.

The applicant modified the corresponding LRA to reflect the audit findings. The staff reviewed

the applicant's LRA supplement and concluded that the applicant appropriately addressed the

aging mechanism with the above mentioned new commitment, as recommended in the GALL

Report.

3.1A.2.1.2 Wall Thinning due to Flow-Accelerated Corrosion

Steam Generator Steam Nozzle Flow Restrictor and Steam Nozzle. On page 3-95 of the LRA,

the applicant stated that wall thinning due to flow-accelerated corrosion in steam generator flow

restrictor exposed to steam is managed using MPS AMP B2.1.11, "Flow-Accelerated

Corrosion.' During the audit and review, the staff asked the applicant to clarify how the flow

restrictor is being managed using the flow-accelerated corrosion (FAC) program. The applicant

replied that FAC concerns for the flow restrictor (restricting venturi) are addressed by video

inspection and venturi ID measurements performed as part of MPS AMP B2.1.22, uSteam

Generator Structural Integrity," and not part of the FAC program. The applicant stated that it will

provide clarification in an LRA supplement. Furthermore, the applicant stated that the steam

nozzle flow restrictor is fabricated from carbon steel and is integral to the steam nozzle. The

steam nozzle itself is not subjected to direct steam flow and, therefore, does not have FAC

concerns.

By letter dated July 7, 2004, the applicant submitted its LRA supplement letter. In its response,

the applicant stated that the FAC AMP should be replaced with MPS AMP B2.1.22, "Steam

Generator Structural Integrity" for the 'Steam Nozzle Flow Restrictor' component group in Unit 2

Table 3.1.2-4 (page 3-95). Also, the Note "D" should be "E" for the same entry. In addition, the

"Discussion" column in Table 3.1.1, Item 3.1.1-25 (page 3-31), should replace

"Flow-Accelerated Corrosion program" with the following:

Flow-Accelerated Corrosion program for all items except the steam nozzle flow

restrictor which is managed by the steam generator structural integrity program

AMP.

The staff reviewed the applicant's response, as documented in the staffs MPS audit and review

report, and confirmed that inspections of the SG flow restrictors are performed. In addition, the

applicant utilizes the charged-coupled device (CCD) camera to inspect the steam nozzle

venturies and utilizes the video probe to inspect steam nozzle venturies.

For loss of material in a steam environment for the carbon steel steam nozzle and safe-end

component group, in LRA Table 3.1.2-4 (page 3-94), the applicant credited both the chemistry

control for secondary systems program and the FAC program. In its letter dated July 7, 2004,

3-131
in,

the applicant stated that the FAC program was inadvertently listed as an aging management

program for the steam nozzle and safe-end component group. The staff reviewed the

applicant's response and concluded that the chemistry control for secondary systems program

alone is adequate to manage this aging effect.

On the basis of its review, the staff concluded that the applicant appropriately addressed the

aging mechanism, as recommended by the GALL Report.

Steam Generator Feedwater Nozzle Thermal Sleeve. In LRA Table 3.1.2-4 (page 3-89), the

applicant stated that wall thinning due to FAC in steam generator feedwater thermal sleeve

exposed to treated water is managed using MPS AMP B2.1.11, "Flow-Accelerated Corrosion."

During the audit and review, the staff asked the applicant to clarify how the thermal sleeve is

being managed using the FAC program. The applicant replied that there is an inner 16-inch

diameter, Schedule 80 carbon steel thermal sleeve (shield) at the feedwater inlet nozzle.

Because of the external nozzle, UT examination is not being performed on the thermal sleeve

(shield) itself. The applicant initiated a corrective action report to address the need for

establishing proper monitoring for wall thickness as part of the FAC program. On the basis of its

review, the staff concludes that the applicant's response is acceptable.

3.1A.2.1.3 Loss of Material Due to Wear; Loss of Preload Due to Stress Relaxation; Crack

Initiation and Growth Due to Cyclic Loading and/or Stress Corrosion Cracking

In LRA Table 3.1.1, Item 26 (page 3-31), the applicant stated that cracking and loss of preload

are managed using AMP B2.1.18, Inservice Inspection Program: Systems, Components and

Supports." Also, the applicant stated that loss of material due to wear is not an aging effect

requiring management for this bolting.

The staff noted that SRP-LR Table 3.1-1 recommended GALL AMP XI.M18, "Bolting Integrity,"

for managing closure bolting in a high pressure or high temperature system for loss of material

due to wear; loss of preload due to stress relaxation; crack initiation and growth due to cyclic

loading and/or stress corrosion cracking.

The staff questioned the applicant on whether all of the resolutions of the generic safety issue

for bolting, as stated in NUREG-1339, are addressed. By letter dated December 3, 2004, the

applicant submitted its LRA supplement. In its response, the applicant stated that it has

developed a specific bolting integrity aging management program that addresses degradation

of bolting at MPS. The bolting integrity program was reviewed and is addressed in Section 3.0

of this SER.

By letter dated January 11, 2005, the applicant submitted its bolting aging management roll-up

item. In its response, the applicant replaced the existing information in the "Discussionn column

of LRA Table 3.1.1, Item 26 with "consistent with the NUREG-1801."

The staff reviewed the applicant's response and finds this acceptable since it is consistent with

the GALL Report.

3.1A.2.1.4 Loss of Fracture Toughness Due to Neutron Irradiation Embrittlement, and Void

Swelling

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In LRA, Table 3.1.1, Item 43 (page 3-35), the applicant stated that loss of fracture toughness is

managed using MPS AMP B2.1 .17,1ulnservice Inspection Program: Reactor Vessel Internals."

Also, the applicant stated that MPS AMP B2.1.5, uChemistry Control for Primary Systems

Program" is not credited to manage these aging effects, but is applied to all reactor vessel

internals components as a corrosion mitigation program.

The staff reviewed the inservice inspection program: reactor vessel internals program and the

chemistry control for primary systems program and its evaluation is documented in Section

3.0.3.2.12 and Section 3.0.3.2.2 of this SER, respectively. On the basis of its review, the staff

agreed with the applicant that the chemistry control for primary systems program is a corrosion

mitigation program and the program also applies to-all reactor vessel internal components.

Therefore, the staff concluded that the applicant's proposed program is adequate to manage

loss of fracture toughness due to neutron irradiation embrittlement and void swelling.

On the basis of its audit and review, the staff determined that for all other AMRs not requiring

further evaluation, as identified in LRA Table 3.1.1 (Table 1), the applicant's references to the

GALL Report are acceptable and no further staff review is required.

On the basis of its audit and review, the staff concludes that the applicant has demonstrated

that the effects of aging will be adequately maanaged so that the intended function(s) will be

maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21 (a)(3).

Conclusion. The staff has evaluated the applicant's claim of consistency with the GALL Report.

The staff also has reviewed information pertaining to the applicant's consideration of recent

operating experience and proposals for managing associated aging effects. On the basis of its

review, the staff finds that the AMR results, which the applicant claimed to be consistent with

the GALL Report, are consistent with the AMRs in the GALL Report. Therefore, the staff finds

that the applicant has demonstrated that the effects of aging for these components will be

adequately managed so that their intended function(s) will be maintained consistent with the

CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.1A.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation Is Recommended

Summary of Technical Information in the Application. In Section 3.1.2.2 of the LRA, the

applicant provided further evaluation of aging management as recommended by the GALL

Report for reactor vessel, internals, reactor coolant system, and steam generator components.

The applicant provided information concerning how it will manage the following aging effects:

* cumulative fatigue damage

* loss of material due to pitting and crevice-corrosion

* loss of fracture toughness due to neutron irradiation embrittlerment

* crack initiation and growth due to th6rmal and mechanical loading or stress corrosion

cracking

* crack growth due to cyclic loading

* changes in dimension due to void swelling

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* crack initiation and growth due to stress corrosion cracking or primary water stress

corrosion cracking

* crack initiation and growth due to stress corrosion cracking or irradiation-assisted stress

corrosion cracking

* loss of preload due to stress relaxation

* loss of section thickness due to erosion

* crack initiation and growth due to PWSCC, ODSCC, or intergranular attack or loss of

material due to wastage and pitting corrosion or loss of section thickness due to fretting

and wear or denting due to corrosion of carbon steel tube support plate

* loss of section thickness due to flow-accelerated corrosion

* ligament cracking due to corrosion

* loss of material due to flow-accelerated corrosion

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistenc'y with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff audited and reviewed the applicant's evaluation to determine

whether it adequately addressed the issues that were further evaluated. In addition, the staff

reviewed the applicant's further evaluations against the criteria contained in Section 3.1.3.2 of

the SRP-LR. Details of the staff's audit are documented in the staff's MPS audit and review

report. The staffs evaluation of is discuss below.

3.IA.2.2.1 Cumulative Fatigue Damage

As stated in the SRP-LR, fatigue is a TLAA, as defined in 10 CFR 54.3. Applicants must

evaluate TLAAs in accordance with 10 CFR 54.21 (c)(1). Section 4.3 of this SER documents the,

staffs review of the applicant's evaluation of this TLAA. In performing this review, the staff

followed the guidance in Section 4.3 of the SRP-LR.

3.IA.2.2.2 Loss of Material Due to Pitting and Crevice Corrosion

The staff reviewed LRA Section 3.1.2.2.2 against the criteria in SRP-LR Section 3.1.2.2.2.

In Unit 2 LRA Section 3.1.2.2.2, the applicant addressed loss of material of steam generator

assemblies due to pitting and crevice corrosion.

SRP-LR Section 3.1.2.2.2 stated that loss of material due to pitting and crevice corrosion could

occur in the steam generator shell assembly. The existing program relied on control of water

chemistry to mitigate corrosion and ISI to detect cracking due to loss of material. NRC

Information Notice (IN) 90-04, 'Cracking of the Upper Shell-to-Transition Cone Girth Welds in

Steam Generators," stated that if general corrosion pitting of the shell exists, the existing

program may not be sufficient. In that case the GALL Report recommends augmented

inspections to manage the aging effect.

The AMPs recommended by the GALL Report for managing the aging of steam generator

assemblies due to pitting and crevice corrosion are GALL AMP XL.M1, uASME Section Xl

Inservice Inspection, Subsections IWB, IWC, and IWD," to detect loss of material and

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GALL AMP Xl.M2, "Water Chemistry," to mitigate corrosion. The GALL Report also

recommends a plant-specific program to conduct augmented inspections.

In the Unit 2 LRA, the applicant credits MPS AMP B.2.18, "Inservice Inspection Program:

Systems, Components and Supports," and MPS AMP B.2.1.6, "Chemistry Control for

Secondary Systems," for managing loss of material due to pitting and crevice corrosion for the

internal surfaces of the steam generator shell. The staff evaluated these programs and its

evaluations are documented in Section 3.0.3.2.13 and Section 3.0.3.2.3 of this SER,

respectively.

The staff reviewed IN 90-04, which identified the need to augment inspections beyond the

requirements of ASME Section Xl if general corrosion pitting of the steam generator shell is

known to exist in order to differentiate isolated cracks for inherent geometric conditions. In the

Unit 2 LRA, the applicant stated that it replaced the Unit 2 steam generators in 1992. The staff

reviewed operating experience which indicated that no pitting corrosion of the steam generator

shell has been detected to date, and that water chemistry has been maintained for these new

steam generators per EPRI guidelines. The staff finds that the augmented inspections

recommended by NRC IN 90-04 and referenced in the SRP-LR do not currently apply to the

Unit 2 steam generators.

Since pitting corrosion has not been detected on the steam generator shell since installation,

the staff finds that augmented inspections are not required and that the current water chemistry

control and inservice inspection programs adequately manage this aging effect.

The staff finds that, based on the programs identified above, the applicant has demonstrated

that the effects of aging will be adequately managed so that the intended functions will be

maintained consistent with the CLB during the period of extended operation, as required by

10 CFR 54.21 (a)(3).

3.1A.2.2.3 Loss of Fracture Toughness Due to Neutron Irradiation Embrittlement

The staff reviewed Unit 2 LRA Section 3.1.2.2.3 against the criteria contained in SRP-LR

Section 3.1.2.2.3.

In LRA Section 3.1.2.2.3, the applicant addressed (1) loss of fracture toughness due to neutron

irradiation embrittlement for ferritic materials that have a neutron fluence of greater than

1017 n/cm2 at the end of the license renewal term, and (2) loss of fracture toughness due to

irradiation embrittlement of the reactor vessel beltline materials. In addition, the applicant stated

that (3) the baffle/former bolts are not used in the reactor vessel internals and the discussion in

this paragraph of NUREG-1800 is not applicable.

SRP-LR Section 3.1.2.2.3 stated that certain aspects of neutron irradiation embrittlement are

TLAAs as defined in 10 CFR 54.3 and that TLAAs are required to be evaluated in accordance

with 10 CFR 54.2.(c)(1). Second, SRP-LR Section 3.1.2.2.3 stated that loss of fracture

toughness due to neutron irradiation embrittlement could occur in the reactor vessel. A reactor

vessel materials surveillance program monitors neutron irradiation embrittlement of the reactor

vessel. Reactor vessel surveillance programs are plant-specific, depending on matters such as

the composition of limiting materials, availability of surveillance capsules, and projected fluence

levels. In accordance with 10 CFR Part 50, Appendix H, an applicant is required to submit its

proposed withdrawal schedule for approval prior to implementation. Finally, the SRP-LR

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Section 3.1.2.2.3 statement that loss of fracture toughness due to neutron irradiation

embrittlement and void swelling could occur in Westinghouse and B&W baffle/former bolts.

Baffel/former bolts are not applicable to Unit 2 because Unit 2 reactor vessel internals do not

include baffle/former bolts.

The AMP recommended by the GALL Report for managing loss of fracture toughness due to

neutron irradiation embrittlement in the reactor vessel is GALL AMP XI.M31, "Reactor Vessel

Surveillance," which complies with the requirements of 10 CFR Part 50, Appendices G and H,

and 10 CFR Part 50.61.

Certain aspects of neutron irradiation embrittlement are TLAAs as defined in 10 CFR 54.3.

TLAAs are required to be evaluated in accordance with 10 CFR 54.21 (c)(1). The staff's

evaluation of this TLAA can be found in Section 4.2 of this SER, following the guidance in

Section 4.2 of the Standard Review Plan for License Renewal (SRP-LR).

Loss of fracture toughness due to neutron irradiation embrittlement could occur in the reactor

vessel. A reactor vessel materials surveillance program monitors neutron irradiation

embrittlement of the reactor vessel. Reactor vessel surveillance programs are plant-specific,

depending on matters such as the composition of limiting materials, availability of surveillance

capsules, and projected fluence levels. In accordance with 10 CFR Part 50, Appendix H, an

applicant is required to submit its proposed withdrawal schedule for approval prior to

implementation. Thus, further staff evaluation is required for license renewal. NUREG-1 801

recommends further evaluation of the reactor vessel materials surveillance program for the

period of extended operation. The staff verifies that the applicant has proposed an adequate

reactor vessel materials surveillance program for the period of extended operation.

The limiting beltline material for upper shelf energy (USE) at Millstone Unit 2 is the intermediate

and lower shell beltline axial welds, heat no. A8746. The limiting beltline material for

pressurized thermal shock (PTS) at Millstone Unit 2 is the Lower Shell Plate C-506-1 (Heat No.

C5667-1). The Millstone Unit 2, reactor vessel surveillance program, in conjunction with TLAA

analyses, effectively manages loss of fracture toughness in the beltline materials. The reactor

vessel surveillance program provides adequate material property and neutron dosimetry data to

predict fracture toughness in beltline materials at the end of the period of extended operation.

The analyses (see TLAAs, SER Section 4.2) for USE and PTS provide assurance that beltline

material toughness values in the Millstone Unit 2 reactor vessel will remain at acceptable levels

through the period of extended operation. The reactor vessel surveillance program is reviewedin SER Section 3.0.3.1.3 (AMP B2.1.20).

The staff finds that the applicant's AMR results are consistent with the GALL Report and that

the applicant has demonstrated that the programs to manage the effects of aging will be

adequate to maintain the intended functions consistent with the CLB during the period of

extended operation, as required by 10 CFR 54.21 (a)(3).

3.1A.2.2.4 Crack Initiation and Growth Due to Thermal and Mechanical Loading or Stress

Corrosion Cracking

The staff reviewed LRA Section 3.1.2.2.4 against the criteria contained in SRP-LR

Section 3.1.2.2.4.

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In LRA Section 3.1.2.2.4, the applicant addressed the potential for crack initiation and growth

due to thermal and mechanical loading or stress corrosion cracking '(SCC), including

intergranular SCC, that could occur in small-bore RCS and connected system piping less than

4-inch nominal pipe size (NPS 4).

SRP-LR Section 3.1.2.2.4 stated that the GALL Report recommends that a plant-specific

destructive examination or a nondestructive examination (NDE) that permits inspection of the

inside surfaces of the piping be conducted to'ensure that cracking has not occurred and the

component intended function will be maintained during the period of extended operation. The

applicant should verify that service-induced weld cracking is not occurring in small-bore piping

less than NPS 4. A one-time inspection of a sample of locations is an acceptable method to

ensure that the aging effect is not occurring and that the component's intended function will be

maintained during the period of extended operation. Per ASME Section Xl, 1995 edition,

Examination Category B-J or B-F, small-bore piping, defined as piping less than NPS 4, does

not receive volumetric inspection.

The AMPs recommended by the GALL Report are GALL AMP XI.M1, "ASME Section Xl

Inservice Inspection, Subsections IWB, IWC, and IWD," to detect loss of material, and GALL

AMP XI.M2, 'Water Chemistry," to mitigate SCC.'

In the LRA, the applicant credited MPS AMP B2.1.18, "Inservice Inspection Program: Systems,

Components and Supports," and MPS AMP B2.1.5, "Chemistry Control for Primary Systems,"

to mitigate cracking of reactor coolant piping. The staff evaluated'these programs and its

evaluation is documented in Section 3.0.3.2.13 and Section 3.0.3.2.2 of this SER, respectively.

To address the GALL Report recommendation that a plant-specific destructive examination or

an NDE that permits inspection of the inside surfaces'of the piping be conducted, the applicant

stated, in the LRA, that it has implemented an RI-ISI methodology to select RCS piping welds

for inspection in lieu of the requirements specified in ASME Section Xl. To address the GALL

Report recommendation for a one-time inspection of small-bore piping less than NPS 4, the

applicant indicated in the Unit 2 LRA'that small-bore pipe butt-welded connections are included

in the final weld selection for performance of volumetric examination. The staff verified that the

applicant used the RI-ISI process to determine the most susceptible locations for performing

the volumetric examination and did not eliminate small-bore pipe welds.

The staff reviewed and verified that the applicant's RI-ISI plan will perform volumetric

examination, which is recommended to address 6racking for small-bore Class 1 piping per

ISG-12, 'One-Time Inspection of Small-Bore Piping," on elements not currently required to be

volumetrically examined. Based on the programs'identified above, the staff finds that the

applicant appropriately evaluated AMR results involving current inspection methods, as detailed

in the inservice inspection program, and as supplemented by the water chemistry control, for

managing cracking of small-bore piping systems.

The staff finds that the applicant's AMR results are consistent with the GALL Report,' and that

the applicant has demonstrated that the effects of aging will be adequately'managed so that the

intended functions will be maintained consistent with the CLB during the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.1A.2.2.5 Crack Growth Due to Cyclic Loading

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NUREG-1801 recommends further evaluation of programs to manage crack growth due to

cyclic loading in the reactor vessel shell. Crack growth due to cyclic loading in reactor vessel

shells are evaluated as a TLAA. Growth of intergranular separations (underclad cracks) in lowalloy or carbon steel heat-affected zones under austenitic stainless steel cladding is a TLAA to

be evaluated for the period of extended operation for all the SA 508-Class 2 forgings where the

cladding was deposited with a high heat input welding process. Since Millstone Unit 2 does not

use SA 508-Class 2 forgings in the beltline region, this evaluation is not applicable. In addition,

the Millstone Unit 2 LRA, Section 3.1.2.2.5 states that there are no detected underclad cracks

identified in the reactor vessel.

3.1A.2.2.6 Changes in Dimension Due to Void Swelling

In LRA Section 3.1.2.2.6, the applicant addressed changes in dimension due to void swelling

that could occur in reactor internals components.

SRP-LR Section 3.1.2.2.6 stated that the GALL Report recommends that changes in dimension

due to void swelling in reactor internals components be evaluated to ensure that this aging

effect is adequately managed. The GALL Report recommends that a plant-specific AMP be

evaluated to manage the effects of changes in dimension due to void swelling and the loss of

fracture toughness associated with swelling.

In general, the applicant has concluded that void swelling is an aging related effect for the

reactor vessel internals, but currently only credits the ASME Section Xl, Subsection IWB,

Category B-N-3 inservice inspections to manage change in dimensions due to void swelling. In

lieu of the implementation of augmented inspections, such as enhanced visual VT-1

examinations or enhanced volumetric examination, Millstone will follow industry efforts to

determine the necessary steps for managing void swelling. Currently no augmented inspection

will be performed. However, since the EPRI Materials Research Project - Reactor Internals

Issue Task Group is currently addressing this issue, the applicant will follow the industry effort

related to void swelling and will implement the appropriate recommendations resulting from this

guidance. In addition, the applicant has identified the implementation of the industry initiatives

as commitment 13 in Appendix A, Table A6.0-1 of the LRA.

The staff reviewed the inservice inspection program: reactor vessel internals program and its

evaluation is documented in Section 3.0.3.2.12 of this SER. The staff finds that this program is

consistent with GALL AMP XI.M1 3, "Thermal Aging and Neutron Embrittlement of Cast

Austenitic Stainless Steel (CASS)," and GALL AMP XI.M16, OPWR Vessel Internals."

The staff finds the applicant's approach for managing changes in dimension due to void

swelling acceptable because the approach will be based on the guidelines developed by the

ongoing industry activities related to void swelling. The applicant has committed to implement

the appropriate recommendations resulting from the industry efforts. The applicant also

committed, through an LRA supplement letter, dated July 7, 2004, that the revised program

description, including a comparison with the 10 program elements of the NUREG-1 801

program, will be submitted to the NRC for approval prior to the period of extended operation.

The staff finds that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB during the period of extended operation, as

required by 10 CFR 54.21(a)(3).

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3.1A.2.2.7 Crack Initiation and Growth Due to Stress Corrosion Cracking or Primary Water

Stress Corrosion Cracking

The staff reviewed LRA Section 3.1.2.2.7 against the criteria in SRP-LR Section 3.1.2.2.7,

which recommends plant-specific programs to address these aging mechanisms.

In LRA Section 3.1.2.2.7, the applicant addressed (1)'crack initiation an growth

edn(1)Acrackiinitiation and grvt ue to SCC

and primary water stress corrosion cracking (PWSCC) in the pressurizer (spray head

assembly/nozzle assembly). Reactor vessel items included in this grouping are the surveillance

capsule holders, core stabilizing lugs, core stop ligs, and the flow baffle and skirt. Steam

generator items included in this grouping are the tube plate cladding,-channel head divider

plate, and primary instrument nozzles; (2) crack initiation and growth due to SCC in the

pressurizer surge line piping, fittings and pipe (safe-ends for safety injection (SI) and shutdown

cooling (SDC)) fabricated of CASS; and (3) crack initiation and growth due to PWSCC in

nickel-based alloy components such as the pressurizer instrumentation nozzles, heater sheaths

and sleeves, and thermal sleeves.

SRP-LR Section 3.1.2.2.7 states that:

* Crack initiation and growth due to SCC and :PWSCC could occur in core support pads (or core guide lugs), instrument tubes (bottom head penetrations), pressurizer spray

heads, and nozzles for the steam generator instruments and drains. The GALL Report

recommends further evaluation to ensure that these aging effects are adequately

managed. The GALL Report recommends that a plant-specific AMP be evaluated

because existing programs may not be capable of mitigating or detecting crack initiation

and growth due to SCC.

Crack initiation and growth due to SCC could occur in CASS RCS piping and fittings and

pressurizer surge line nozzles. The GALL Report recommends further evaluation of

-piping that does not meet either the reactor water chemistry guidelines of EPRI

TR-105714 or material guidelines of NUREG-0313, "Technical Report on Material

Selection and Processing Guidelines for BWR Coolant Pressure'Boundary Piping,"

Revision 2, January 1988.

* Crack initiation and growth due to PWSCC could occur in pressurizer instrumentation'

penetrations and heater sheaths and sleeves made of nickel alloys. The existing

program relies on ASME Section Xl inservice inspection and on control of water

chemistry to mitigate PWSCC. However, the existing program should be augmented to

manage the effects of SCC on the intended function of nickel-alloy components. The

GALL Report recommends that the applicant provide a plant-specific AMP or participate

in industry programs to determine appropriate AMPs for PWSCC of the Alloy 182 weld.

The applicant credited the following plant-specific programs for each of the three SRP-LR

criteria: '' -'

* Cracking of nickel-based alloy components due to PWSCC is managed by the

nickel-based alloys (i.e., PWSCC in Alloy 600 base metal and Alloy 82/182 weld metals)

aging management activities, which are part of MPS AMP B2.1.18, "Inservice Inspection

Program: Systems, Components and Supports," supplemented by MPS AMP B2.1.5,

"Chemistry Control for Primary Systems Program." Additionally, EPRI, through its

material reliability program (MRP) and in conjunction with the PWR Owners Group, is

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developing a strategic plan to manage and mitigate cracking of nickel-based alloy items.

The applicant stated that the guidance developed by the MRP will be used to identify the

appropriate aging management activities and will implement the appropriate

recommendations resulting from this guidance as described in the License Renewal

Commitment, Item 14.

* Crack initiation and growth due to SCC at welded connections, including the pressurizer

surge line and fittings and pipe safe-ends for SI and SDC, is managed by MPS AMP

82.1.5, mChemistry Control for Primary Systems Program," and MPS AMP B2.1.18,

uInservice Inspection Program: Systems, Components and Supports."

* The programs credited for the management of PWSCC of these nickel-based alloy

items are the nickel-based alloys (i.e., PWSCC in Alloy 600 base metal and Alloy 82/182

weld metals) aging management activities, which are part of MPS AMP B2.1.18,

"Inservice Inspection Program: Systems, Components and Supports," and MPS AMP

B2.1.5, 'Chemistry Control for Primary Systems Program." As described above, the

applicant committed to participate in the nickel-based alloys industry programs to

identify appropriate aging management activities and will implement the appropriate

recommendations from the guidance developed by industry programs.

The GALL Report recommends that a plant-specific aging management program be evaluated

because existing programs may not be capable of mitigating or detecting crack initiation and

growth due to SCC. Acceptance criteria are described in Branch Technical Position RLSB-1

(Appendix A.1 of the SRP-LR). The staff reviewed the applicant's proposed program to ensure

that an adequate program will be in place for the management of these aging effects.

Crack initiation and growth due to SCC could occur in PWR cast austenitic stainless steel

(CASS) reactor coolant system piping and fittings and the pressurizer surge line nozzle. For

PWRs, NUREG-1 801 recommends further evaluation of 'piping that does not meet the'reactor

water chemistry guidelines'of TR-105714, UPWR' Primary Water Chemistry Guidelines, Revision

3," November 1995, or later. Since Millstone Unit 2 uses the guidelines of Revision 4 to TR105714, no further evaluation of a plant-specific AMP is required since the applicant minimizes

the potential for SCC by using the later revision of TR-105714 in accordance with NUREG1801. In addition the applicant uses AMP 82.1.18, 'Inservice Inspection Program: Systems,

Components and Supports" to manage cracking of CASS components. The applicant's AMP

B2.1.18 includes the AMP recommendations for CASS components in NUREG-1801, AMP

XI.M12, uThermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)," and AMP

XI.M1, "ASME Section Xl Inservice Inspection, Subsection IWB, IWC, and IWD."

Crack initiation and growth due to PWSCC could occur in PWR pressurizer instrumentation

penetrations and heater sheaths and sleeves made of nickel-based alloys. The existing;

program relies on ASME Section Xl Inservice Inspection (ISI) and on control of water chemistry

to mitigate PWSCC. However, the existing program should be augmented to manage the

effects of SCC on the intended function of components fabricated from nickel-based alloys.

NUREG-1 801 recommends that the applicant provide a plant-specific AMP or participate in

industry programs to determine an appropriate AMP for PWSCC of Inconel 182 weld. ,

Acceptance criteria are described in Branch Technical Position' RLSB-1 (Appendix A.1 of the

SRP-LR). The staff reviewed the applicant's proposed program to ensure that an adequate

program will be in place for the management of these aging effects. Millstone Unit 2 has nickelbased alloys (Alloy 600 and 82/182) in the pressurizer instrumentation penetrations and heater

sheaths and sleeves. Millstone Unit 2 has no reactor vessel bottom mounted instrumentation

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penetrations. Millstone Unit 2 has committed to participate in industry'programs to determine

appropriate measures to manage PWSCC. This commitment is identified in the Millstone Unit 2

LRA, Appendix A, Table A6.0-1 License Renewal Commitments, Item 14. In addition, the

applicant has committed to replace the pressurizer with PWSCC resistant material. The aging

management program for PWSCC is discussed in AMP B2.1.18. Additional assurance of crack

detection is through the boric acid corrosion program, which is described in AMP B2.1.3. In this

program leakage detection is utilized to detect cracks in Alloy 600 base metal and Alloy 82/182

weld metal components in the pressurizer, as specified in NRC Bulletin 2004-01.

The pressurizer spray head for the Millstone Unit 2 is a nickel-based alloy and not CASS. The

plant-specific aging management program for managing the aging effects associated with the

pressurizer spray head is the chemistry control for primary systems program. NUREG-1801

recommends a plant-specific AMP to be evaluated to manage PWSCC of Alloys 600 and

82/182. However, Dominion stated that it intends to replace the Unit 2 pressurizer during the fall

2006 refueling outage. The replacement pressurizer will be constructed of PWSCC-resistant

materials. Therefore, since the pressurizer will be replaced with PWSCC-resistant material, no

further evaluation is required for the pressurizer spray head.

The staffs evaluation of the chemistry control for primary systems program and the inservice

inspections programs: systems, components and supports program is documented in Section

3.0.3.2.2 and Section 3.0.3.2.13 of this SER, respectively.

The nickel-based alloys aging management activity is part of MPS AMP B2.1.18, "Inservice

Inspection Program: Systems, Components and Supports," and the staffs evaluation of the

nickel-based alloys (i.e., PWSCC in Alloy 600 base metal and Alloy 82/182 weld metals) aging

management is documented in Section 3.0.3.2.13 of the SER.

On the basis of its review, the staff finds that the applicant has adequately evaluated the

management of crack initiation and growth due to stress corrosion cracking or primary water

stress corrosion cracking for components in the reactor systems, as recommended in NUREG1801. On the basis of this finding, and the finding that the remainder of the applicant's program

is consistent with NUREG-1801, the staff concludes that the applicant has demonstrated that

the effects of aging will be adequately managed so that there is reasonable assurance that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.1A.2.2.8 Crack Initiation and Growth Due to Stress Corrosion Cracking or

Irradiation-Assisted Stress Corrosion Cracking'

The staff reviewed LRA Section 3.1 ;2.2.8 against the criteria in SRP-LR Section 3.1.2.2.8.

In LRA Section 3.1.2.2.8, the applicant addressed 'crack initiation and growth due to SCC or

irradiation-assisted stress corrosion cracking (IASCC) that could occur in baffle/former bolts in

the reactor. The applicant stated that Unit 2 reactor vessel internals do not include baffle/former

bolts and that the discussion in this paragraph of the SRP-LR is not applicable. SRP-LR Section

3.1.2.2.8 stated that crack initiation and growth due to SCC or IASCC could occur in

baffle/former bolts in the reactors. The GALL Report recommends further evaluation to ensure

that these aging effects are adequately managed. On the basis that the baffle/former bolts are

not part of the Unit 2 design of reactor vessel intemals, the staff finds that this aging effect is

not applicable to Unit 2.

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3.1A.2.2.9 Loss of Preload Due to Stress Relaxation

The staff reviewed LRA Section 3.1.2.2.9 against the criteria in SRP-LR Section 3.1.2.2.9.

In LRA Section 3.1.2.2.9, the applicant stated that baffle/former bolts are not used in the reactor

vessel internals and that the discussion in this paragraph of the SRP-LR is not applicable.

SRP-LR Section 3.1.2.2.9 stated that loss of preload due to stress relaxation could occur in

baffle/former bolts in the reactor. The GALL Report recommends a plant-specific AMP to

ensure that this aging effect is adequately managed. On the basis that the baffle/former bolts

are not part of the Unit 2 design of reactor vessel intemals, the staff finds that this aging effect

is not applicable.

3.1A.2.2.10 Loss of Section Thickness Due to Erosion

The staff reviewed LRA Section 3.1.2.2.10 against the criteria in SRP-LR Section 3.1.2.2.10. In

LRA Section 3.1.2.2.10,- the applicant stated that the Unit 2 steam generators do not have

feedwater impingement plates and that the discussion in this paragraph of the SRP-LR is not

applicable. SRP-LR Section 3.1.2.2.10 stated that loss of section thickness due to erosion could

occur in steam generator feedwater impingement plates and supports. The GALL Report

recommends further evaluation of a plant-specific AMP to ensure that this aging effect is

adequately managed. On the basis that feedwater impingement plates are not part of the Unit 2

steam generator design, the staff finds that this aging effect is not applicable to Unit 2.

3.1A.2.2.11 Crack Initiation and Growth Due to Primary Water Stress Corrosion Cracking,

Outside Diameter Stress Corrosion Cracking, or Intergranular Attack or Loss of Material Due to

Wastage and Pitting Corrosion or Loss of Section Thickness Due to Fretting and Wear or

Denting Due to Corrosion of Carbon Steel Tube Support Plate

The staff reviewed LRA Section 3.1.2.2.11 against the criteria in SRP-LR Section 3.1.2.2.11.

In LRA Section 3.1.2.2.11, the applicant addressed crack initiation and growth due to PWSCC,

outside diameter SCC, or intergranular attack (IGA) or loss of material due to wastage and

pitting corrosion or deformation due to corrosion that could occur in nickel-based alloy

components of the steam generator tube plugs.

For the tube component type of nickel-based alloy material in a treated water environment, the

plant-specific note in the LRA Table 3.1.2.4 (page 3-97), indicates that the material for this -

component is not addressed by the GALL Report. Furthermore, these tubes are fabricated from

Alloy 690. The applicant also stated that Alloy 690 is a high-chromium nickel-based alloy that is

more resistant to SCC than Alloy 600. For that reason, the applicant stated that the material

match was not made to the GALL Report items that referenced Alloy 600 material. Therefore,

the tubes discussion is addressed in Section 3.1A.2.3.4 of this SER.

SRP-LR Section 3.1.2.11 states that crack initiation and growth due to PWSCC, outside

diameter SCC, or IGA or loss of material due to wastage and pitting corrosion or deformation

due to corrosion could occur in Alloy 600 components of the steam generator tubes, repair

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sleeves, and plugs. All PWR licensees have committed voluntarily to a steam generator

degradation management program described in NEI 97-06, "Steam Generator Program

Guidelines." These guidelines are currently under NRC staff review.- The GALL Report

recommends that an AMP based on the recommendations of staff-approved NEI 97-06

guidelines, or other regulatory bases for steam generator degradation management, should be

developed to ensure that this aging effect is adequately managed.

The SRP-LR also states that crack initiation and growth due to PWSCC, outside diameter SCC,

or IGA or loss of material due to wastage and pitting corrosion or deformation due to corrosion

could occur in nickel-based alloy components of the steam generator tubes and plugs.

To manage the effects of aging, the applicant credits MPS AMP B2.1.23, "Steam Generator

Structural Integrity," supplemented by MPS AMP B2.1.5, "Chemistry Control for Primary

Systems Program," and MPS AMP B2.1.6, "Chemistry Control for Secondary Systems

Program." The staff's evaluation of the steam generator structural integrity program is

documented in Section 3.0.3.1 of this SER. The staff reviewed the chemistry control for primary

systems and chemistry control for secondary systems programs and its evaluations are

documented in Section 3.0.3.2.2 and Section 3.0.3.2.3 of this SER, respectively. For general

and pitting corrosion, assessment of tube integrity, and plugging or repair criteria of flawed

tubes, the steam generator structural integrity program acceptance criteria are in accordance

with NEI 97-06 guidelines.

On the basis of its review of the primary and secondary water chemistry control, the staff finds

that the applicant appropriately evaluated AMR results involving plant-specific programs to

address these aging mechanisms, as recommended in the GALL Report.

The staff finds that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB during the period of extended operation.

3.1A.2.2.12 Loss of Section Thickness Due to Flow-Accelerated Corrosion

The staff reviewed LRA Section 3.1.2.2.12 against the criteria in SRP-LR Section 3.1.2.2.12.

In LRA Section 3.1.2.2.12, the applicant stated that the steam generator tube support lattice

bars are constructed of stainless steel. Therefore, loss of section thickness of these bars is not

an applicable aging effect for Unit 2. SRP-LR Section 3.1.2.2.12 states the loss of section

thickness due to FAC could occur in tube support lattice bars made of carbon steel. The GALL

Report recommends that a plant-specific AMP be evaluated and, on the basis of the guidelines

of NRC GL 97-06, an inspection program for steam generator internals be developed to ensure

that this aging effect is adequately managed. On the basis that carbon steel tube support lattice

bars are not part of the Unit 2 steam generator design, the staff finds that this aging effect is

not applicable.

3.1A.2.2.13 Ligament Cracking Due to Corrosion

The staff reviewed LRA Section 3.1.2.2.13 against the criteria in SRP-LR Section 3.1.2.2.13. In

LRA Section 3.1.2.2.13, the applicant stated that tube support plates are not used in the steam

generators. Therefore, ligament cracking due to corrosion is not an applicable aging effect for

Unit 2. SRP-LR Section 3.1.2.2.13 states that ligament cracking due to corrosion could occur in

carbon steel components in the steam generator tube support plate. All PWR licensees have

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committed voluntarily to a steam generator degradation management program described in NEI

97-06; these guidelines are currently under NRC staff review. The GALL Report recommends

that an AMP based on the recommendations of'staff-approved NEI 97-06 guidelines, or other

regulatory bases for steam generator degradation management, be developed to ensure that

this aging effect is adequately managed. On the basis that tube support plates are not used in

the steam generators at Unit 2, the staff finds that this aging effect is not applicable.

3.1A.2.2.14 Loss of Material Due to Flow-Accelerated Corrosion

The staff reviewed LRA Section 3.1.2.2.14 against the criteria in SRP-LR Section 3.1.2.2.14.

SRP-LR Section 3.1.2.2.14 states that loss of material due to FAC could occur in the feedwater

inlet ring and supports. As noted in Combustion Engineering (CE) IN 90-04, NRC IN 91-19,

"Steam Generator Feedwater Distribution Piping Damage," and License Event Report (LER)

50-362/90-05-01, this form of degradation has been detected only in certain CE System 80

steam generators. The GALL Report recommends further evaluation to ensure that this aging

effect is adequately managed. The GALL Report recommends that a plant-specific AMP be

evaluated because existing programs may not be capable of mitigating or detecting loss of

material due to FAC.

The staff noted, in LRA Table 3.1.2-4 (page 3-88), that for loss of material of the feedwater inlet

ring and the support component type of carbon steel exposed internally to a treated water

environment, the applicant credited the chemistry control for secondary systems program.

During the audit, the staff asked the applicant to clarify why the FAC program is not assigned to

this component.

The applicant responded in its LRA supplement letter dated July 7, 2004, that the FAC program

should be added for the feedwater inlet ring and support component type. In addition, the GALL

Report item match for this entry should be IV.DI1.3-a with Note B. Also, the 'Table 1 Item' entry

should be 3.1.1-21. Furthermore, the applicant stated that LRA Section 3.1.2.2.14 (page 3-20)

and LRA Table 3.1.1, the discussion column for Item 3.1.1-21 (page 3-30), should state:

Although the Unit 2 steam generators are not CE System 80 steam generators,

the feedwater inlet ring is included in the Flow Accelerated Corrosion program.

The staff further requested that the applicant clarify how the FAC inspection of the steam

generator feedwater ring would be performed. The applicant responded that FAC inspection of

the feedwater inlet is performed using the program generic FAC inspection techniques for

gridding and UT.

On the basis of its review, the staff finds that the applicant has demonstrated that the effect of

aging will be adequately managed so that the intended function will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

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3.1A.2.2.15 Quality Assurance for Aging Management of Non-Safety-Related Components

Section 3.0.4 of this SER provides the staffs evaluation of the applicant's quality assurance

program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determines that (1) those attributes or features

for which the applicant claimed consistency with the GALL Report were indeed consistent, and

(2) the applicant adequately addressed the issues that were further evaluated. The staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so

that the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3)..

3. 1A.2.3 AMR Results That Are Not Consistent With or Not Addressed in the GALL

Report

Summary of Technical Information in the ApDlication. In Tables 3.1.2-1 through 3.1.2-4 of the

Unit 2 LRA, the applicant provided additional details of the results of the AMRs for material,

environment, aging effect requiring management, and AMP combinations that are not

consistent with the GALL Report or are not addressed in the GALL Report.

In Tables 3.1.2-1 through 3.1.2-4, the applicant indicated, via Notes F through J, that neither

the identified component nor the material and environment combination is evaluated in the

GALL Report and provided information concerning how the aging effect will be managed.

Staff Evaluation. For component type, material and environment combination that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine

whether the applicant had demonstrated that the effects of aging will be adequately managed

so that the intended function will be maintained consistent with the CLB during the period of

extended operation.

The staffs evaluation is discussed below in Sections 3.1A.2.3.1 through 3.1A.2.3.3

3.1A.2.3.1 Reactor Vessel Aging Management Evaluation - Table 3.1.2-1

In Section 3.1.2.1.1 of the LRA, the applicant identified the materials, environments, and aging

effects requiring management. The applicant identified the following programs that manage the

aging effects requiring management for the reactor vessel and associated pressure boundary

components:

* boric acid corrosion

* chemistry control for primary systems program

* inservice inspection program: reactor vessel internals

* inservice inspection program: systems, components and supports

* reactor vessel surveillance

In Table 3.1.2-1 of the LRA, the applicant provided a summary of AMRs for the reactor vessel

and associated pressure boundary components and identified which AMRs it considered to be

consistent with the GALL Report.

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The staff reviewed Table 3.1.2-1 of the Unit 2 LRA, which summarized the results of AMR

evaluations for the reactor vessel component groups. The staff has reviewed the information in

this table and agrees that the applicant has identified the applicable aging effects because the

aging effects are appropriate for these materials and environment and are consistent with

industry operating experience, except for the following components, which are discussed below.

NUREG-1 801, Section IVA2.8-b states that the pressure vessel skirt support, cantilever/column

support, and neutron shield tank are subject to loss of material due to boric acid corrosion. The

applicant was requested in RAI 3.1.1-1 to include this aging effect and the necessary AMPs for

these components concerning loss of material due to boric acid corrosion in Table 3.1.2-1 of

the LRA or provide justification for concluding that boric acid corrosion is not an aging effect.

In response to RAI 3.1.1-1, in a letter dated December 3, 2004,.the applicant stated that the

structural supports for major reactor coolant system components are evaluated separately from

the component and its integral parts, as NSSS Equipment Supports. There are no skirt support,

cantilever/column support, or neutron shield tank components for the Millstone Unit 2 reactor;

vessel support system. The Millstone Unit 2 reactor pressure vessel supports are included as

structural members in LRA Table 3.5.2-24. Therefore, loss of material due to boric acid

corrosion is identified for these structural members consistent with NUREG-1 801 item

1ll.B1.1.1-b, and is managed with the boric acid corrosion and general condition monitoring

AMPs. The staff agrees that this resolves RAI 3.1.1-1.

Table 3.1.2-1 of the LRA does not specify loss of material/wear for the closure head stud

assembly as identified by NUREG-1801, Section IVA.2.1-d. Therefore, the applicant was

requested in RAI 3.1.1-2 to include this aging effect and the corresponding aging management

program (AMP XL.M3 of NUREG-1801 'Reactor Head Closure Studs") in Table 3.1.2-1 of the

LRA or provide justification for concluding that loss of material/wear is not an aging effect.

In response to RAI 3.1.1-2, in a letter dated December 3, 2004, the applicant stated that the

closure head stud assembly does not experience relative motion other than normal stud

removal and installation during refueling activities. These activities are closely monitored by

procedure and any degradation is dispositioned by supplemental examination, corrective

measures or repairs, analytical evaluation of the component function, or replacement of the

component to ensure continued structural integrity and function of the component. There is no

significant continuing wear to the reactor vessel closure studs that would lead to a loss of

component function and require monitoring by an aging management program. Therefore, the

applicant did not consider loss of material due to wear as an applicable aging effect for the

closure head stud assembly. However, AMP XL.M3 of NUREG-1801 and RG 1.65 indicates that.

reactor closure studs are susceptible to loss of material due to wear. In addition, RG 1.65

recommends, and the applicant uses, coatings and lubrication which are used to reduce wear.

Therefore, the staff requested that the LRA specify loss of material due to wear as an aging

effect for the closure head stud assembly and specify the AMP to be applied.

In its response dated February 8, 2005 to supplemental RAI 3.1.1-2, the applicant stated that

although wear of the reactor closure studs is not expected to affect the intended function of the

bolting, loss of material due to wear will be considered as an aging effect consistent with

NUREG-1801, item IV.A2.1-d. The aging effect will be managed by the inservice inspection

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program: systems, components and supports AMP. The staff finds this response acceptable

since it has identified the applicable aging effect and provides an aging management program

which requires inspection of the closure studs in accordance with the ASME Code requirements

that are capable of detecting loss of material.;This resolves RAI 3.1.1-2.

Table 3.1.2-1 of the LRA does not specify loss of fracture toughness/neutron irradiation

embrittlement for the upper shell as identified by NUREG-1 801, Section IVA.2.5-c. The

applicant was requested in RAI 3.1.1-3 to include this aging effect and the corresponding aging

management program (AMP XL.M31 of NUREG-1 801 "Reactor Vessel Surveillance") in Table

3.1.2-1 of the LRA or provide justification for concluding that fracture toughness/neutron

irradiation embrittlement is not an aging effect.

In response to RAI 3.1.1-3, in a letter dated December 3, 2004, the applicant stated loss of

fracture toughness due to neutron irradiation embrittlement is an applicable aging effect for

those reactor pressure vessel subcomponents exposed to a neutron fluence greater than

lxi O'7 ncm2 (E>1 Mev). This threshold level of fluence is experienced by the beltline region

subcomponents identified in LRA Table 3.1.2-1 as susceptible to loss of fracture toughness.

Based on a supplemental evaluation performed by the applicant, the upper shell and primary

outlet nozzles are subjected to loss of fracture toughness due to neutron irradiation

embrittlement and will be managed with the reactor vessel surveillance AMP. In addition, the

applicant's response to RAI 4.2.2-1 stated that an assessment has been performed to address

an expansion of the Millstone Unit 2 reactor pressure vessel beltline region resulting from the

period of extended operation. This assessment was used to evaluate all materials that were

determined to exceed the I.017 n/cm2 (E>1.0 MeV) boundary.

The applicant provided results for the upper/intermediate circumferential welds, but not for the

upper shell and primary outlet nozzles that are subject to loss of fracture toughness due to

neutron irradiation embrittlement. Based on the information provided by the LRA and the

applicant's responses to RAls 3.1.1-3 and 4.2.2-1, the staff notes that the applicant did not

provide the USE and PTS evaluations for these reactor pressure vessel subcomponents as

required by Appendix G tol 0 CFR Part 50, and 10 CFR 50.61, respectively.

Therefore to confirm that the USE and PTS evaluations for these subcomponents meet

regulatory requirements at the end of the period of extended operation, the staff requests the

applicant to include the USE and PTS evaluation (similar to the data currently in Tables 1 and 2

of the FSAR for the other reactor vessel subcomponents) for the upper shell and primary

nozzles and their associated welds into Tables 1 -and 2 of the Millstone Unit 2 FSAR

supplement and determine the effect on the limiting materials.

In response to supplemental RAI 3.1.1-3, in a letter dated February 8,2005, the applicant

provide the USE and PTS evaluations for-the upper shell and primary nozzles, and their

associated welds. The applicant calculated the USE values for these materials in accordance

with 10 CFR Part 50, Appendix G,.and performed the PTS evaluation in accordance with

10 CFR 50.61 through the extended period of operation. The USE and PTS values for these

subcomponents were also included in Tables 3.1.1-3-1 through 3.1.1-3-4 in the applicant's

response for both units. The results of the USE and PTS evaluations on these expanded

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beltline regions had no effect on the limiting material. The staff confirmed that the limiting

material previously identified in the LRA is still valid. Therefore, since the applicant evaluated all

materials that were determined to exceed the 1.Ox10 I n/cm2 (E>1.0 MeV) boundary and

identified that the limiting material specified in sections 4.2.2 and 4.2.3 of this SER is still valid,

the staff finds this response acceptable. In addition, the level of detail described in the FSAR

supplement follows the recommendations of NUREG-1800, Table 4.2-1. This resolves RAI

3.1.1-3.

Table 3.1.2-1 of the LRA does not specify loss of materialtwear for the vessel flange and core

support ledge as identified by NUREG-1 801, Section IVA.2.5-f. Therefore, the applicant was

requested in RAI 3.1.2-1 to include the aging effect and the corresponding aging management

program described in NUREG-1 801 (AMP XI.M1, "Inservice inspection") in the LRA or provide

justification for concluding that loss of material/wear is not an aging effect.

In its response to RAI 3.1.2-1, dated December 3, 2004, the applicant stated that loss of

material due to wear was not considered an applicable aging effect for the reactor vessel flange

and core support ledge since they do not experience relative motion other than normal reactor

disassembly and reassembly during refueling activities. These activities are closely monitored

by procedure and any degradation is dispositioned by supplemental examination, corrective

measures or repairs, analytical evaluation of the component function, or replacement of the

component to ensure continued structural integrity and function of the component. The

applicant also stated that there is no significant continuing wear to the reactor vessel flange and

core support ledge that would lead to a loss of component function that would require

monitoring by an aging management program. However; the staff considers wear to be an

aging effect as identified by NUREG-1 801, Section IVA.2.5-f, because the reactor vessel flange

and support ledge do experience relative motion during reactor disassembly and reassembly

during refueling activities. This aging effect should then be monitored. Since the applicant

stated this refueling'activity is monitored by procedures, some type of inspection should be

performed to monitor wear of these components. Therefore, the staff requested that the LRA

specify loss of material due to wear as an aging effect for the reactor vessel flange and core

support ledge. In addition, the applicant was requested to discuss the inspections performed by

the refueling activity procedures that monitor wear for these components or include the -

corresponding aging management program recommended by NUREG-1801 (AMP XI.M1,

"Inservice Inspection").

In its response to supplemental RAI 3.1.2-1 dated February 8, 2005, the applicant stated that

although wear of the reactor vessel flange and core support ledge is not expected to affect the

intended function of these components, loss of material due to wear will be considered as an

aging effect consistent with NUREG-1 801, Item IV.A2.5-f. The aging effect will be managed by

the Millstone inservice inspection program: reactor vessels internals AMP. The staff finds this

response acceptable since it has identified the applicable aging effect along with an appropriate

aging management program that is consistent with NUREG-1 801 for these components. This

resolves RAI 3.1.2-1.

In Table 3.1.2-1, the applicant has identified cracking as an aging effect requiring management

for the CEDM pressure boundary components and the vessel head penetration components

manufactured from stainless steel and nickel-based alloys that are exposed to treated water.

The aging effect is managed by the inservice inspection program: systems, components and

supports, and the chemistry control for primary systems program. The aging effect, material,

and the environment is consistent with NUREG 1801, Item IV.A2.2-a and Item IV.A2.2-b and no

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further evaluation is required. The staff notes that the inservice inspe ction program: systems,

components and supports includes nickel-alloy nozzles and penetrations program. This

program is used to manage PWSCC of nickel alloys. The staff concludes the inservice

inspection program: systems, components and supports (which includes the nickel-alloy

nozzles and penetrations program) and the chemistry control for primary systems program will

be effective in managing cracking for the CEDM pressure boundary components and the vessel

head penetrations. :

Based on the above information, the staff finds the applicant's management of cracking to be

acceptable.

In Table 3.1.2-1, the applicant also identified loss of material as an aging effect requiring

management for the CEDM pressure boundary components and the vessel head penetration

components manufactured from stainless steel and nickel-based alloys that are exposed to

treated water. The applicant stated the aging effect is managed by the chemistry, control for

primary systems program. The aging effect, material, and the environment is not addressed in

NUREG 1801 for Item IV.A2.2-a and Item IV.A2.2-b. In RAI 3.1-A-1 the staff requested that the

applicant provide justification on why the chemistry control for primary systems program alone

is sufficient to manage loss of material without the need to credit an inspection-based AMP to

verify that the chemistry control program is accomplishing its mitigative aging management

function.

In response to RAI 3.1-A-1, in a letter dated December 3, 2004, the applicant stated that the

stainless steel and nickel-based alloy materials exposed internally to primary treated water are

not expected to be subject to significant loss of material as a result of corrosion. In addition,

NUREG-1801 does not identify loss of material due to corrosion as an aging effect requiring

management for these materials in the RCS. However, loss of material was conservatively

considered in the Millstone LRA for the RCS components in the primary water environment. The

chemistry control for primary systems program provides reasonable assurance that loss of

material resulting from corrosion will not prevent these components from performing their

intended functions.

Verification of the effectiveness of the chemistry control for primary systems program is

provided by the work control process as described in LRA Appendix B, Section 82.1.5. The

work control process provides the opportunity to visually inspect the internal surfaces of

components during preventive and corrective maintenance activities on an ongoing basis. The

work control process provides input to the corrective action program if aging effects are

identified. The corrective actions program evaluates the cause and extent of the condition and,

if required, recommends enhancements to ensure continued effectiveness of the chemistry

control for primary systems program.

In Unit 2 LRA Table 3.1.2-1, the applicant identified no aging effects for the following stainless

steel and nickel-based alloy reactor vessel component types exposed externally to air: CEDM

head penetration nozzle, CEDM head penetration nozzle flange, CEDM pressure housings,

head vent pipe, and instrument tubes. Air is not identified in the GALL Report as an

environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that dry air on metal will not result in aging that will be of concern during the period of extended

operation. These RCS components are exposed to high-temperature internal flow, which

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creates a dry air environment. Stainless steel and nickel-based alloy components in a dry air

environment are not susceptible to general corrosion that would affect their intended function.

Therefore, the staff concludes that there are no applicable aging effects requiring management

for metal in a dry air environment. This resolves RAI 3.1-A-1.

In Unit 2 LRA Table 3.1.2-1, the applicant proposed using MPS AMP 82.1.5, "Chemistry Control

for Primary Systems Program," to manage loss of material for the following stainless steel,

nickel-based alloy, and low-alloy steel clad with stainless steel component types of the reactor

vessel exposed internally to treated, borated water core stabilizing lugs and core stop lugs,

flow skirt flow baffle, and surveillance capsule holders; CEDM head penetration nozzle, CEDM

head penetration nozzle flange, CEDM pressure housings, CEDM head dome, CEDM head

flange, instrument tubes, instrument tube flange and studs/nuts/washers, head vent pipe,

primary inlet/outlet nozzle and safe-end, bottom head, upper shell, and vessel flange and core

support ledge. The staff accepted the chemistry control for primary systems program and its

evaluation of this program is documented in Section 3.0.3.2.2 of this SER.

In Unit 2 LRA Table 3.1.2-1, for each of these same component and material combinations, the.-

applicant is also managing cracking using MPS AMP B2.1.5, uChemistry Control for Primary

Systems Program," and MPS AMP B2.1.18, "Inservice Inspection Program: Systems,

Components and Supports." MPS AMP B2.1.18 is also credited with managing PWSCC in Alloy

600 base metal and Alloy 82/182 weld metals. The staff accepted the chemistry control for

primary systems program and the inservice inspection program: systems, components and

supports program, and its evaluation of these programs is documented in Section 3.0.3.2.2 and

Section 3.0.3.2.13 of this SER, respectively. The Alloy 600 base metal and Alloy 82/182 weld

metals PWSCC management portion of the AMP has been reviewed and the staffs evaluation

of this program is documented in Section 3 of this SER. The staff finds that the applicant

managed cracking in a manner consistent with the GALL Report.

On the basis that cracking of stainless steel, nickel-based alloy, and low-alloy steel clad with

stainless steel is being managed by the water chemistry control and inservice inspection

programs, and the effects of pitting and crevice corrosion on stainless steel and nickel-based

alloy components are not significant in chemically treated, borated water, the staff finds that

management of loss of material using water chemistry control is adequate.

The staff finds that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB during the

period of extended operation, as required by 10 CFR 54.21(a)(3).

3.1A.2.3.2 Reactor Vessel Intemals - Aging Management Evaluation - Table 3.1.2-2

In Section 3.1.2.1.2 of the LRA, the applicant identified the materials, environments, and aging

effects requiring management. The applicant identified the following programs that manage the

aging effects requiring management for the reactor vessel internals and associated pressure

boundary components:

* chemistry control for primary systems program

* inservice inspection program: reactor vessel internals

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In Table 3.1.2-2 of the LRA, the applicant provided a summary of AMRs for the reactor vessel

internals and associated pressure boundary components and identified which AMRs it

considered to be consistent with the GALL Report.

The staff reviewed Unit 2 LRA Table 3.1.2-2, which summarized the results of AMR evaluations

for the reactor vessel internals component groups.

Table 3.1.2-2 of the LRA did not specify loss of fracture toughness/neutron irradiation

embrittlement for the core support barrel upper flange as identified by Section' IVB.3.3-a.

Therefore, the applicant was requested in RAI 3.'1.2-2 to include the aging effect and the

corresponding aging management program (AMP Xl.M16 of NUREG-1 801 "PWR Vessel

Intemals") in the LRA or provide justification for concluding that fracture toughness/neutron

irradiation embrittlement is not an aging effect.

In response to RAI 3.1.2-2, in a letter dated December 3, 2004, the applicant stated that due to

the location of the stainless steel core support barrel upper flange, and the distance from the

reactor core, loss of fracture toughness due to irradiation embrittlement is not'expected to be

significant. However, as part of the aging management program for the reactor vessel internals,

Dominion has committed to follow the industry efforts related to internals aging issues, including

neutron irradiation embrittlement. This commitment is described in LRA Appendix B, Section

B2.1.17 "Inservice Inspection Program: Reactor Vessel Internals" and in LRA Appendix A,

Table A6.0-1, Item 13, in a letter to NRC,- SIN: 04-320 dated July 7, 2004. The staff finds this

acceptable since the applicant commits to follow the industry efforts for neutron irradiation

embrittlement for the applicable reactor vessel intemals. This resolves RAI 3.1.2-2.

Table 3.1.2-2 of the LRA did not specify the loose parts monitoring AMP to manage the loss of

preload/stress relaxation aging effect for the' CEA shroud bolts as identified by NUREG-1 801,

Section IVB.3.2-g. Therefore, the applicant was requested in RAI 3.1.2-3 to provide this aging

management program or provide justification for not including this AMP.

In response to RAI 3.1.2-3, in a letter dated December 3, 2004, the applicant stated that the

bolted connections in the reactor vessel internals are managed by the effects of loss of preload'

by the inservice inspection program: reactor vessel internals AMP. This AMP provides for -

inspection of the internals in accordance with examination category.B-N-3 of the ASME Code,

Section Xl, Subsection IWB.

These inspections include VT-3 examinations of the bolted connections to detect a gross loss

of preload, such as looseness and improper fit, prior to failure of the connection. Therefore, the

applicant does not rely upon the loose parts monitoring program as suggested in NUREG-1801

since this approach would require failure of the bolting in order to be effective. The staff finds

this acceptable since the applicant is using Inspections to prevent the failure of the bolted

connections, and the use of the inspection in the inservice inspection program: reactor vessel

internals AMP provides reasonable assurance that degradation would be detected prior to the

loss of the intended function. This resolves RAI 3.1.2-3.

Table 3.1.2-2 of the Millstone Unit 2 LRA specified core support barrel snubber assemblies with

the following aging effects: void swelling, loss of fracture toughness, and loss of material/wear.

Figure 3.3-12 of the FSAR shows bolts for this assembly. In RAI 3.1.2-4, the applicant was

requested to clarify if these aging effects also apply to the bolts. In addition,- the applicant was

requested to provide the associated AMPs or justification for concluding that these bolts are not

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subject to these aging effects. Also, the applicant was asked if loss of preload is an aging effect

on these bolts. The appropriate AMP or justification for concluding that these bolts are not

subject to loss of preload should be provided.

In response to RAI 3.1.2-4, in a letter dated December 3, 2004, the applicant stated the aging

effects shown in the Millstone Unit 2 LRA, Table 3.1.2-2 for the core support barrel snubber

assemblies applied to all parts of the assembly, including the bolts. The applicable aging

management programs are the inservice inspection program: reactor vessel internals AMP and

the chemistry control for primary systems program. The loss of preload aging effect was

inadvertently omitted from LRA Table 3.1.2-2 for this assembly. The inservice inspection

program: reactor vessel internals AMP manages loss of preload for this bolting through VT-3

examinations in accordance with examination category B-N-3. The staff finds this acceptable

since the applicant identified the applicable aging effects for the whole snubber assembly and

manages these aging effects in accordance with the ASME Code and NUREG-1 801.

This resolves RAI 3.1.2-4.

Table 3.1.2-2 of the Millstone Unit 2 LRA specified core shroud assembly fabricated from

stainless steel. Figure 3.3-13 of the FSAR showed the core shroud assembly consists of a

lower segment and an upper segment joined by tie rod assemblies.' Therefore, in RAI 3.1.2-5,

the applicant was requested to clarify if there are welds in the individual segments of the core

shroud. If the core shroud segments are bolted, provide the aging effects, including loss of

preload for these core shroud assembly bolts and the associated AMP. If these core shroud

segments are welded, the applicant was asked if the welds and adjacent base material

susceptible to irradiation assisted stress' corrosion cracking (IASCC). In addition, the applicant

was requested to provide the appropriate AMP for IASCC (including type of inspection,

inspection frequency and acceptance criteria) or provide justification for concluding that these

welds and adjacent base material are not susceptible to IASCC.

In response to RAI 3.1.2-5, in a letter dated December 3, 2004, the applicant stated the

Millstone Unit 2 core shroud assembly upper segment and lower segment are weldments and

do not include bolting. The welds are included as part of the core shroud assembly

subcomponent in LRA Table 3.1.2-2 and are subjected to the aging effects identified for this

subcomponent, which includes cracking (stress corrosion cracking, irradiation-assisted stress

corrosion cracking) consistent with NUREG-1 801, Item IV.B3.4'a. Cracking will be managed by

the inservice inspection program: reactor vessel internals AMP and the chemistry control for

primary systems program. The staff finds this acceptable since the applicant has identified the

applicable aging effects for its design of the core shroud assembly and is managed in

accordance with the recommendations of NUREG-1801. This resolves RAI 3.1.2-5.

Section 3.1.2.2.7.1 of the LRA stated that the reactor vessel flange leak detection line is not

within the scope of license renewal because it does not meet the criteria of 10 CFR 54.4(a) as

an intended function. However, NUREG-1 801, Section IV A.2.1-f identifies that this component

is subject to a crack initiation and growth/stress corrosion cracking aging mechanism.

Therefore, the applicant was requested in RAI 3.1.2-6 to provide a plant-specific aging

management program as identified by NUREG-1801 for cracking of this component.

In response to RAI 3.1.2-6, in a letter dated December 3, 2004, the applicant stated the reactor

vessel leak detection system; including the leak detection line, is not within the scope of license.

renewal. As stated on page 3-18 in the Millstone Unit 2 LRA, the reactor vessel closure head

and shell flanges are sealed by inner and outer hollow metallic 0-rings.

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Any leakage through this seal arrangement is directed to the leakage detection system through

a 3/16-inch hole in the vessel flange. Leakage flow past the inner reactor vessel flange O-ring is

limited in the event of seal failure by the 3/16-inch diameter hole in the reactor vessel flange

which is smaller than the inside diameter of the leak detection line. Additionally, the potential

flowrate through the 3/16-inch diameter hole in the flange is within the normal make-up

capability of the chemical and volume control system such that the leak detection system doses

not constitute the RCS pressure boundary. The failure of the leak detection system components

has been evaluated and cannot affect the function of safety-related systems, structures or

components. As such, the reactor vessel flange seal leak detection system, including the leak

detection line does not meet the criteria of 10 CFR 54.4(a) and is not within the scope of license

renewal. Therefore, the system is not subject to aging management review and there is no -

aging management program applicable to the leak detection line. The staff review to determine

if this was acceptable was identified as Open Item 3.1.2-6.

In response to Open Item 3.1.2-6, in a letter dated April 1, 2005, the applicant revised its

position and has now included the leak detection components within the scope of license

renewal. In addition, the applicant stated that the leak detection system consists of piping,

tubing, and valves that are long-lived, passive components and are consistent with the existing

component types in the reactor coolant system included in LRA Table 2.3.1-3. These stainless

steel components are exposed to a treated water environment and are managed for loss of

material and cracking aging effects by the chemistry program for primary systems AMP and the

inservice inspection program: systems, components, and supports as indicated for piping,

tubing, and valves component types in LRA Table 3.1.2-3. The applicant noted that the loss of

fracture toughness aging effect listed in Table 3.2.1-3 is not applicable to these valves since the

valves are not CASS.

Based on the applicant's inclusion of the leak detection components within the scope of license

renewal, Open Item 3.1.2-6 is closed.

Table 3.1.2-2 of the Millstone Unit 2 LRA did not specify a hold-down ring that is subject to loss

of material/wear. The applicant was requested in RAI 3.1.2-7 to include this aging effect and the

necessary aging management programs in the LRA for this component as recommended by

NUREG-1801, item IV.B.3.1.4.

In response to RAI 3.1.2-7, in a letter dated December 3, 2004, the applicant stated that it uses

the terminology "Expansion Compensating Ring" in LRA Table 3.1.2-2 in lieu of hold-down ring

for the Millstone Unit 2 reactor vessel intemals.-Since the applicant includes this subcomponent

in the LRA and manages the loss of material aging effect in accordance with NUREG-1 801,

item IV.B.3.1.4, the staff finds this response acceptable. This resolves RAI 3.1.2-7.

Table 3.1.2-2 of the Millstone Unit 2 LRA did not specify core shroud assembly bolts that are

subject to fatigue, cracking, void swelling, loss of fracture toughness, and loss of preload. The

applicant was requested in RAI 3.1.2-8 to include these aging effects and the necessary aging

management programs in the LRA for this component as recommended by NUREG-1801, item

IV.B.3.4.2.

In response to RAI 3.1.2-8, in a letter dated December 3, 2004, the applicant stated that the

core shroud assembly for the Millstone Unit 2 reactor vessel internals utilizes welded

construction and there are no core shroud assembly bolts. As discussed in RAI 3.1.2-5, the

core shroud assembly upper segment and lower segment are weldments and do not include

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fill

bolting. The two core shroud assemblies are connected using tie rod assemblies. Both of these

assemblies are included in the LRA along with the applicable aging management programs in

accordance with NUREG-1801. Therefore, since the core shroud design does not include core

shroud assembly bolts, the staff finds the applicant's response acceptable. This resolves RAI

3.1.2-8.

Table 3.1.2-2 of the Millstone Unit 2 LRA did not specify core support column bolts that are

subject to fatigue, cracking/IASCC, void swelling, and loss of fracture toughness. The applicant

was requested in RAI 3.1.2-9 to include these aging effects and the necessary aging

management programs in the LRA for this component as recommended by NUREG-1801, item

IV.B.3.5.5.

In response to RAI 3.1.2-9, in a letter dated December 3, 2004, the applicant stated that the

core support columns for the Millstone Unit 2 reactor vessel internals utilize welded construction

and there are no core support column bolts. Therefore, NUREG-1801, item IV.B.3.5.5 is not

applicable. The core support columns are identified in the LRA'along with the applicable aging

effects and aging management programs in accordance with NUREG-1 801, and therefore the

staff finds the applicant's response acceptable. This resolves RAI 3.1.2-9.

In Unit 2 LRA Table 3.1.2-2, the applicant proposed to manage loss of material for the following

stainless steel component types of the reactor vessel internals system - control element

assembly (CEA) shroud assembly components such as CEA shroud extension shaft guides,

CEA shrouds - dual, CEA shrouds - single,'core shroud assembly, core shroud tie rods, core

support barrel, core support barrel alignment keys, core support barrel snubber assemblies,

core support barrel upper flange, core support columns, core support plate, expansion

compensating ring, fuel alignment pins, fuel alignment plate, fuel alignment plate guide lugs and

guide lug inserts, incore instrumentation (ICI) support plate and guide tubes, lower support

structure beam assemblies, and upper guide structure support plate - exposed internally to

treated, borated water using MPS AMP B2.1.5, "Chemistry Control for Primary Systems

Program." The staff accepted the' chemistry control for primary systems program and its

evaluation of this program is documented in Section 3.0.3.2.2 of this SER.

In LRA Table 3.1.2-2, for each of these same component and material combinations, the

applicant stated that it is also managing cracking using MPS AMP B2.1.5, "Chemistry Control

for Primary Systems Program," and MPS AMP B2.1.17, inservice Inspection Program: Reactor

Vessel Internals." MPS AMP B2.1.17 credits the ASME Section Xl, Subsection IWB, Category

B-N-3 inservice inspections and additional examinations based on future industry

developments. The staff reviewed the embrittlement effects on the CASS portion of the

inservice inspection program: reactor vessel internal program, and its' evaluation of this part of

the program is documented in Section 3.0.3.2.12 of this SER. The evaluation of aging

management of such issues as void swelling (change in dimensions), stress corrosion cracking

(PWSCC and IGSCC) and loss of preload for the reactor vessel internals components have

been reviewed and the evaluation is documented in Section 3 of this SER. The staff finds that

the applicant managed cracking in a manner consistent with the GALL Report. In addition, the

staff reviewed the applicable part of MPS AMP B2.1.18, "Inservice Inspection Program:

Systems, Components and Supports," which discusses the ASME Section Xl, Subsection IWB,

Category B-N-3 portion of the inservice inspection program. The staff accepted the inservice

inspection program: systems, components and supports program and its evaluation of this

program is documented in Section 3.0.3.2.13 of this SER.

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On the basis that cracking of stainless steel is being managed by the water chemistry control

and inservice inspection programs, and the effects of pitting and crevice corrosion on stainless

steel components are not significant in chemically treated, borated water, the staff finds that

management of loss of material using water chemistry control is adequate.

The GALL Report recommends a loose parts monitoring program to manage loss of

mechanical closure integrity for CEA shroud extension shaft guides, cylinders, and bases;

shroud base; shroud flow channel; shroud flow channel cap; shroud shaft retention pin; shroud

retention block; spanner nuts; shroud fasteners; guide tubes; ICI thimble support plate'

assembly; ICI support plate, grid, lifting support, lifting plate, column, plates, and funnel; pad,

ring, nipple, hex bolt, and spacer; and threaded rod, hex jam nut, thimble support nut, cap

screws, and reactor vessel internals.

In the Unit 2 LRA, the applicant proposed to manage this aging effect using the

MPS AMP B2.1.17, -Inservice Inspection Program: Reactor Vessel Internals." The staff

reviewed and accepted the inservice inspection program: reactor vessel internals program and

its evaluation of this program is documented in Section 3.0.3.2.12 of this SER.

On the basis that the inservice inspection program: reactor vessel internals program detects

aging effects prior to the loss of mechanical integrity of these components, the staff finds that

the use of this program in lieu of a loose parts monitoring program is acceptable.

The staff finds that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB during the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.1A.2.3.3 Reactor Coolant - Aging Management Evaluation - Table 3.1.2-3

In Section 3.1.2.1.3 of the LRA, the applicant identified the materials, environments, and aging

effects requiring management. The applicant identified the following programs that manage the

aging effects requiring management for the reactor coolant system and associated pressure

boundary components:

* boric acid corrosion

* chemistry control for primary systems program

* closed-cycle cooling water system

* general condition monitoring

* inservice inspection program: systems, components and supports

* work control process

In Table 3.1.2-3 of the LRA, the applicant provided a summary of AMRs for the reactor coolant

system and associated pressure boundary components and identified which AMRs it

considered to be consistent with the GALL Report.

The staff reviewed the Unit 2 LRA Table 3.1.2-3; which summarized the-results of AMR

evaluations for the RCS component group.,

In Unit 2 LRA Table 3.1.2-3, the applicant identified no aging effects for the following stainless

steel, nickel-based alloy, and carbon steel component types exposed externally to air for the

RCS: flow orifices, piping, tubing, valve; pressurizer nozzles, safe-ends and instruments and

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heaters (sheaths and sleeves), manway cover and insert; quench tank, reactor coolant pump

(RCP) seal coolers, RCP thermal barriers, RCP casing, RCP rupture disks. Air is not identified

in the GALL Report as an environment for these components and materials.

In the Unit 2 LRA, the applicant stated that the RCS stainless steel components are externally

insulated. The applicant's FSAR concludes (page 5-6) that the use of external thermal

insulation on RCS components in conformance with RG 1.36, "Nonmetallic Thermal Insulation

for Austenitic Stainless Steel," dated December 1973, provided reasonable assurance that the

reactor coolant pressure boundary material will be adequately protected from conditions that

would lead to loss of integrity from stress corrosion. Based on its review of the applicant's

FSAR, the staff agreed with the applicant that the RCS stainless steel components are

adequately protected from conditions that could lead to loss of integrity from stress corrosion.

On the basis of its review of current industry research and operating experience, the staff finds

that dry air on metal will not result in aging that will be of concern during the period of extended

operation. These RCS components are exposed to high-temperature internal flow, which

creates a high-temperature dry air environment, and general corrosion is not likely to occur

under such an environment. Additionally, stainless steel and nickel-based alloy in a dry air

environment are not susceptible to general corrosion that would affect the intended function of

components. The only carbon steel component is the pressurizer manway cover and insert,

which is inspected each time the manway is opened. Therefore, the staff concluded that there

are no applicable aging effects requiring management for metal in a dry air environment.

In Unit 2 LRA Table 3.1.2-3, the applicant identified the RCP seal cooler inner tube exposed to

borated treated water as subject to cracking which is being managed by MPS AMP B2.1.5,

"Chemistry Control for Primary Systems Program." During the audit and review, the staff asked

the applicant what other means are used to manage cracking and to explain the consequence

of the inner tube cracking on safety functions. The applicant responded that in the event

cracking does occur, the radiation monitors in the reactor building closed cooling water

(RBCCW) system will detect activity and a corrective action report will be initiated to correct the

condition. The applicant also stated to the staff that a plant modification has been implemented

to address the inter-system loss-of-coolant accident (LOCA) concern of the RCP seal cooler

(inner tube) failing. Furthermore, the applicant's FSAR Section 9.4.3.2 described the relief

valves that were added to protect the RBCCW system from an inter-system LOCA from a RCP

seal cooler (inner tube) failure.

In an LRA supplement letter dated July 7, 2004, the applicant stated that for RCP seal cooler

(inner tube) exposed to treated water subject to cracking, which is being managed by

MPS AMP B2.1.5, 'Chemistry Control for Primary Systems Program," the GALL Report match

for the RCP seal cooler (inner tube) (Unit 2 LRA page 3-82) should be changed to "None." In

addition, Note E will be changed to Note H and a new plant-specific note will be added that

states the following:

Cracking of the component group "RCP Seal Cooler (Inner Tube)" is managed

by Primary Water Chemistry. However, there are additional means for detecting

cracking. The additional means consist of monitoring the radiation monitors in

the RBCCW System and chemistry sampling of the RBCCW.

On the basis that inservice inspection is not feasible, the staff reviewed the applicant's FSAR

and determined that the applicant has demonstrated that the cracking will be adequately

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managed by the primary water chemistry control program and radiation monitoring in the

RBCCW system.

In Unit 2 LRA Table 3.1.2-3 (page 3-83), the applicant stated that the CASS RCP thermal

barrier exposed to treated water with aging effect of cracking is to be managed by the chemistry

control for primary systems program and the inservice inspection program: systems,

components and supports program. The staff asked the applicant to clarify which part of the

inservice inspection program is being credited with managing the aging effect for the RCP

thermal barrier. The applicant responded that it was confirmed with the inservice inspection

coordinator that the inservice inspection program does not perform examinations associated

with the thermal barriers. The work control process program is credited for managing the

effects of aging for the RCP thermal barriers; The RCPs are refurbished, designated as spares,

and reinstalled during future outages. Examples of work orders are identified where, through

the work control process program, the thermal barriers associated with spare RCPs-are blown

down of the closed cooling water and a sample of the closed cooling water is taken. -

The applicant submitted an LRA supplement letter, dated July 7, 2004, which stated the

following in response to the staffs request for clarification:

Note 6 should be added for Unit 2 LRA Table 3.1.2-3 (page 3-83) for the RCS

component group 'RCP Thermal Barriers' and aging effect 'Loss of Fracture

Toughness.' The Note for this item is revised by Item 42-1 of this clarification

letter and is applicable to this component because it is CASS material.

The 'Inservice Inspection Program: Systems, Components and Supports" should

be replaced by the "Work Control Process" for Unit 2 LRA Table 3.1.2-3 (page

3-83), for the RCS component group 'RCP Thermal Barriers' and aging effect

'Cracking.' The Note for this item should be "E" in the Unit 2 LRA. Also, the

"Discussion" column in Unit 2 Table 3.1.1, Item 3.1.1-36 (page 3-33), should

read as follows:

Not consistent with NUREG-1 801. Cracking is managed with the

chemistry control for primary systems program and the inservice

inspection program: systems,-components and supports except

for the RCP thermal barriers, which are managed with chemistry,

and the work control process. These programs take some

exceptions to the NUREG-1801 AMPs.

The staff reviewed the work control process program and Specification SP-EE-364,

"Specification for Refurbishment of a Millstone Unit 2 Reactor Coolant Pump Motor," Revision 1,

dated July 7, 1996, and determined that the applicant has demonstrated that the effects of

aging of RCP thermal barriers will be adequately managed..,

In Unit 2 LRA Table 3.1.2-3 (page 3-79), the applicant stated that for the pressurizer spray head

assembly/nozzle assembly component type of nickel-based alloy material in a treated water and

steam environment, the applicant credits the chemistry control for primary systems program to

manage cracking. The staff asked the applicant to provide justification regarding how PWSCC

can be managed by the chemistry control for primary systems program alone. The applicant

responded that it intends to replace the Unit 2 pressurizer during the fall 2006 refueling outage.

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1

The replacement will be fabricated with PWSCC resistant materials as described in a letter

dated June 3, 2004.

The staff reviewed the letter and determined that the aging effect of PWSCC will be reduced on

the basis of a new replacement pressurizer fabricated with increased PWSCC resistant

materials.

Table 3.1.2-3 of the LRA specifies the use of AMP B2.1.18, "Inservice Inspection Program:

Systems, Components and Supports," for closure bolting in the RCP, valves and pressurizer

manways. In addition, Section B2.0 of Appendix B of the LRA states that the aging

management review did not identify the need for the uBolting Integrity" AMP. However, NUREG1801, Sections IVC2.3-e, IVC2.3-g, IVC2.4-e, IVC2.4-g, IVC2.5-n and IVC2.5-p specifies the

use of AMP XI.M18, "Bolting Integrity" for these components. AMP XI.M18 of NUREG-1 801

incorporates the requirements and guidelines of NUREG-1339, EPRI NP-5769 and EPRI TR104213 concerning material selection, bolting preload control, inservice inspections, plant

operation and maintenance, and evaluation of the structural integrity of bolted joints. Therefore,

the applicant was requested in RAI 3.1.1-1 to provide the bolting integrity AMP as identified by

NUREG-1801, or include all of the necessary information discussed above into AMP B2.1.18 of

the LRA.

In response to RAI 3.1.3-1, in a letter dated December 3, 2004, the applicant stated that it has

developed a specific bolting integrity AMP to manage the aging effects for closure bolting in the

reactor coolant pump, valves and pressurizer manway. This response is acceptable since the

applicant will manage the closure bolting of these components with a bolting integrity AMP as

specified in NUREG-1 801. The bolting integrity AMP is evaluated in Section 3.0.3.2.18 of this

SER. This resolves RAI 3.1.3-1.

For the CASS spray head assembly identified in Table 3.1.2-3 of the LRA, the applicant

specified the chemistry control AMP to manage cracking. NUREG-1 801, Section IVC2.5-j,

recommends a plant-specific AMP to be used to manage cracking. Therefore, the applicant was

requested in RAI 3.1.3-2 to provide this AMP to the NRC for evaluation as recommended by

NUREG-1801, Section IVC2.5-j.

In response to RAI 3.1.3-2, in a letter dated December 3, 2004, the applicant stated that

material for the Millstone Unit 2 pressurizer spray head is a nickel-based alloy and not CASS.

The plant-specific aging management program for managing the aging effects associated with

the pressurizer spray head is the chemistry control for primary systems program.

In addition, Dominion intends to replace the Unit 2 pressurizer during the fall 2006 refueling

outage. The replacement pressurizer will be constructed of PWSCC-resistant materials. The

replacement of the pressurizer is also discussed in the evaluation of AMP B2.1.18; In response

to RAI B2.1.18-1, also in the dated December 3, 2004, letter, the applicant stated that Dominion

intends to replace the pressurizer during the fall of 2006 refueling outage for Millstone Unit 2

using materials that are resistant to PWSCC, as documented in its letter dated June 3, 2004.

To track this commitment, the applicant is requested to revise the List of Commitments (Table'

A6.0-1 of Appendix A to the Millstone Unit 2 LRA) to include the commitment that the Millstone

Unit 2 pressurizer will be replaced in fall 2006 with material resistant to PWSCC (i.e. Alloy 690

and 52/152). This is evaluated in Section 3.0.3.2.13 of this SER. This resolves RAI 3.1.3-2.

Table 3.1.2-3 of the Millstone Unit 2 LRA does not specify the pressurizer integral support that

is subject to fatigue, cracking/lASCC, and boric acid corrosion. The applicant was requested in

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.

RAI 3.1.3-4 to include these aging effects and provide the necessary aging management

programs in the LRA for this component as recommended by NUREG-1 801, item IV.C.2.5.12.

In response to RAI 3.1.3-4, in a letter dated December 3, 2004, the applicant stated that the

integral supports identified in NUREG-1801 are considered to be the same as the component

type 'Pressurizer (Seismic and Valve Support Lugs)" and "Pressurizer (Support Skirt and

Flange)" in the Millstone Unit 2 LRA, Table 3.1.2-3. The aging effects of loss of material due to

boric acid corrosion and cracking are identified for these components consistent with NUREG1801, Item IV.C.2.5.12. Fatigue is addressed as a TLAA and is identified in LRA Table 3.1.1,

item 3.1.1-10. Since the pressurizer seismic lugs, support skirt, and flange are the integral

supports, and are identified in the LRA along with the applicable AMPs consistent with NUREG1801, the staff finds this response acceptable. This resolves RAI 3.1.3-4.

On the basis of its review, the staff concludes that the applicant has adequately identified the

aging effects, and the AMPs credited for managing the aging effects, for the pressurizer, such

that there is reasonable assurance that the component intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21 (a)(3).

3.1A.2.3.4 Steam Generators Summary of Aging Management - Table 3.1.2-4

In Section 3.1.2.1.4 of the LRA, the applicant identified the materials, environments, and aging

effects requiring management. The applicant identified the following programs that manage the

aging effects requiring management for the steam generator and associated pressure boundary

components:

* boric acid corrosion

* chemistry control for primary systems program

* chemistry control for secondary systems program

* flow-accelerated corrosion

* inservice inspection program: systems, components and supports

* steam generator structural integrity

* work control process

In Table 3.1.2-4 of the LRA, the applicant provided a summary of AMRs for the steam

generator and associated pressure boundary components and identified which AMRs it

considered to be consistent with the GALL Report.

The applicant replaced the two steam generators (SGs) at Millstone Unit 2 in 1993 with

replacement SGs fabricated by Babcock'and Wilcox Intemational. Each replacement SG

nominally contains 8,523 thermally treated Alloy 690 tubes. Thermally treated Alloy 690 tubes

have been shown in laboratory tests and operating nuclear power plants to be more resistant to

PWSCC and outside diameter stress corrosion cracking (ODSCC) than the original mill

annealed Alloy 600 tubes. Each tube has a nominal outside diameter of 0.750-inch and a

nominal wall thickness of 0.0445-inch. The tubes were hydraulically expanded at both ends for

the full length of the tubesheet and are supported by a number. of Type 410 stainless steel tube

support plates with a lattice arrangement. The' U-bends of the tubes installed in rows 1 through

8 were thermally stress-relieved after bending.

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The staff reviewed Table 3.1.2-4 of the Unit 2 LRA, which summarized the results of AMR

evaluations for the steam generator component groups.

In LRA Table 3.1.2-4, the applicant identified the inservice inspection program as the AMP to

manage the aging effect of cracking in the SG base support and flange, support brackets and

lugs for Unit 2. In RAI 3.1.2-4-1, the staff asked the applicant to provide details for some of the

AMP attributes (e.g., preventive actions, parameters monitoredrinspected, detection of aging

effects, monitoring and trending, and acceptance criteria) for these components since they are

not addressed in the GALL inservice inspection AMP.

By letter dated December 3, 2004, the applicant responded that in GALL AMP XI.M1, the

program scope of the inservice inspection AMP includes 'all pressure retaining components

and their integrally welded attachments." The integral weld attachment of the base support to

the steam generators is included under ASME Section Xl, Subsection IWB. The flange, support

brackets and lugs are included under ASME Section Xi, Subsection IWF. In LRA Appendix B

Table B2.0, the applicant lists all the GALL AMPs and the designated Millstone AMP that meets

the GALL requirements. In Table B2.0, the applicant stated that the inservice inspection AMP

will address GALL Section XI.M1, ASME Section Xl Inservice Inspections, Subsection IWB,

IWC and IWD and Section XI.S3, ASME Section Xl, Subsection IWF (for supports). Since the

program elements in NUREG-1801, XI.M1 and XI.S3 are both addressed by the Millstone

inservice inspection AMP, the applicant stated that they do not need to describe separately the

attributes mentioned above. The staff finds the applicant's response acceptable because the

applicant has clarified that the GALL inservice inspection AMP attributes for the base support

flange, support brackets and lugs are addressed in the applicant's Inservice Inspection AMP.

In LRA Table 3.1.2-4, the applicant identifies cracking as the aging effect for the primary

instrument nozzles and tube plugs under treated water. In RAI 3.1.2-4-2, the staff asked the

applicant to identify the mechanism for cracking in the primary instrument nozzles and tube

plugs (e.g., PWSCC or ODSCC).

By letter dated December 3, 2004, the applicant responded that consistent with GALL, the

cracking mechanism for the primary instrument nozzles and tube plugs subcomponents is

PWSCC. The staff finds the applicant's response acceptable because the applicant clarified

that the aging mechanism for the primary instrument nozzles and tube plugs is PWSCC,

consistent with what is stated in GALL.

In LRA Table 3.1.2-4, the applicant identified cracking as an aging effect and the inservice

inspection as the AMP for the primary manway bolting in the air environment. In RAI 3.1.2-4-3,

the staff asked the applicant to clarify the aging mechanism for cracking and to explain how the

inservice Inspection AMP is used to manage this aging effect similar to the recommended

bolting integrity AMP in the GALL.

By letter dated December 3, 2004, the applicant responded that consistent with GALL, the

aging mechanism for the primary manway bolting is stress corrosion cracking; which can result

from flaw initiation and growth. The applicant stated that it will implement a bolting integrityprogram to manage the aging effect of stress corrosion cracking as stated in GALL IV.D1.1-I.

The staff finds the applicant's response acceptable because it is consistent with GALL.

In LRA Table 3.1.2-4, the applicant identified the only aging effect as cracking and the inservice

inspection program as the AMP for the secondary manway and handhole bolting in the air

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environment. In RAI 3.1.2-4-4, the staff asked the applicant to justify why loss of preload and

stress relaxation are not applicable aging effects, as stated in GALL IV.D1.1-f.

By letter dated December 3, 2004, the applicant responded that loss of preload due to stress

relaxation is not an applicable aging effect for the ASME Class 2 secondary manway and

handhole bolting. The applicant uses SA-193,-Grade B7 bolting for these applications. The

applicant stated that, according to ASME Section II, Part D, Table 4, stress relaxation may

occur at temperatures of 700 OF or higher for Grade B7 bolting materials. The applicant's

normal operating reactor coolant system hot leg temperature, which bounds the maximum

temperature for SG secondary side components, is 600.5 *F for Unit 2 and 618 0F for Unit 3.

The applicant stated that since these temperatures are below the 700 OF, loss of preload due to

stress relaxation is not an aging effect requiring aging management. The staff reviewed the

operating thresholds and footnotes for stress relaxation in Section II of the ASME Boiler and

Pressure Vessel Code for these bolting materials and confirmed that the applicant's

determination is valid. The staff finds the applicant's response acceptable because the bolts will

not be exposed to temperatures in excess of the threshold for stress relaxation in the bolting

materials.

In LRA Table 3.1.2-4, the applicant identified loss of material as the aging effect for the tube

supports lattice rings. In RAI 3.1.2-4-5, the staff stated that cracking is also a potential aging

effect and therefore asked the applicant to justify why cracking is not considered as an aging

effect for the tube support lattice rings under treated water and steam.

By letter dated December 3, 2004, the applicant responded that only high-strength carbon

steels are susceptible to this stress corrosion cracking in this environment. Since the tube

support lattice rings are made of carbon steel and not high strength carbon steel, they are not

susceptible to stress corrosion cracking under the steam generator secondary-side

environment. The staff finds the applicant's response acceptable because based on operating

experience, carbon steel is not likely to be susceptible to stress corrosion cracking under the

steam generator secondary-side environment.

In Unit 2 LRA Table 3.1.24, the applicant identified no aging effects for the following

nickel-based alloy, low-alloy steel, and carbon steel component types of the steam generator

exposed externally to air: primary instrument nozzles, primary manway cover and diaphragm,

secondary manway and handhole covers, secondary side nozzles, safe-ends, transition cone,

upper and lower shell. Air is not identified in the GALL Report as an environment for these,

components and materials.

On the basis of its review of the current industry research and operating experience, the staff

finds that dry air on metal will not result in aging that will be of concern during the period of

extended operation. The external environments being referred to are typical of ambient air

which is reactor building air environment.-Significant corrosion of low-alloy steel requires an

electrolytic environment, and a simultaneous presence of oxygen and moisture. Without the

presence of the aggressive environment, low-alloy steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Nickel-based alloy and stainless steel are not susceptible to

significant general corrosion that would affect the intended function of components. Therefore,

the staff concluded that there are no applicable aging effects requiring management for these

metals in a dry air environment.

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I II,

In Unit 2 LRA Table 3.1.2-4, the applicant proposed to use water chemistry control programs to

manage loss of material for the following stainless steel, carbon steel, low-alloy steel, and

nickel-based alloy component types of the steam generator that are exposed to treated

waterlsteam and borated water. divider plate; feedwater inlet ring and support; feedwater

nozzle and safe-end; feedwater nozzle thermal sleeve; lower head; primary manway cover and

diaphragm; primary nozzle and safe-end (and cladding); secondary manway and handhole

covers; secondary side nozzle (except steam and feedwater); shroud; steam nozzle and safeend; steam nozzle flow restrictor, top head; tube support lattice bars; tube support lattice

support rings; tubesheet (and cladding); steam generator tube plugs; and steam generator

U-tubes. Additionally, the tubesheet, steam generator U-tubes, and tube support lattice support

rings also are managed by the steam generator structural integrity program. The staff accepted

MPS AMP B2.1.5, 'Chemistry Control for Primary Systems Program," and MPS AMP B2.1.6,

TChemistry Control for Secondary Systems Program," and its evaluation of these AMPs is

documented in Section 3.0.3.2.2 and Section 3.0.3.2.3 of this SER, respectively. The steam

generator structural integrity program has been reviewed and is evaluated in Section 3 of this

SER.

On the basis of industry operating experience with these materials and use of a water chemistry

control program consistent with the GALL Report, the staff finds this acceptable.

In the Unit 2 LRA Table 3.1.2-4, the applicant proposed to use water chemistry control

programs to manage cracking for the following stainless steel component types of the steam

generator that are exposed to borated water divider plate, primary manway cover, and

diaphragm. The applicant stated that the divider plate and primary manway are not inspected

under the inservice inspection program; however, the components are inspected each time the

manway is opened. The staff reviewed the applicant's specification SP-21172, 'InserviceInspection of SGs," and determined that the applicant adequately manages the aging effect.

The staff finds that management of cracking in low-alloy steel and carbon steel exposed to

treated water using water chemistry control verified by inservice inspection is acceptable, as

recommended by the GALL Report.

The staff finds that management of cracking in stainless steel exposed to treated water using

water chemistry control is acceptable, as recommended by the GALL Report.

All other AMRs assigned to the staff in LRA Tables 3.1.2-1 through 3.1.2-4 were evaluated. The

staff finds them to be acceptable.

Conclusion. On the basis of its review, the staff finds that the applicant appropriately evaluated

AMR results involving material, environment, aging effect requiring management, and AMP

combinations that are not evaluated in the GALL Report or not addressed in the GALL Report.

The staff finds that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.1A.3 Conclusion

The staff concluded that the applicant provided sufficient information to demonstrate that the

effects of aging for the of the reactor vessel, intemals, reactor coolant system, and steam

generator components and component types that are within the scope of license renewal and

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subject to an AMR will be adequately, managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21 (a)(3).

The staff also reviewed the applicable FSAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the reactor vessel,'

intemals, and reactor coolant system components, as required by 10 CFR 54.21(d).

3.1 B Unit 3 Aging Manaaement of Reactor Vessel. Internals, and Reactor Coolant System

This section of the SER documents the staffs review of the applicant's aging management

review (AMR) results for the reactor vessel, intemals, and reactor coolant system components

and component groups associated with the following systems:

* reactor vessel

* reactor vessel internals

* reactor coolant system

* steam generator

3.1 B.1 Summary of Technical Information In the Application

In LRA Section 3.1, the applicant provided AMR results for reactor vessel, intemals, and reactor

coolant system components and component groups. In LRA Table 3.1.1, "Summary of Aging

Management Evaluations in Chapter IV of NUREG-1801 for Reactor Vessel, Intemals, and -

Reactor Coolant System," the applicant provided a summary comparison of its AMRs with the

AMRs evaluated in the GALL Report for the reactor vessel, intemals, and reactor coolant

system components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plaht-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.1B.2 Staff Evaluation

The staff reviewed LRA Section 3.1 to determine if the applicant provided sufficient information

to demonstrate that the effects of aging for the reactor system components that are within the

scope of license renewal and subject to an AMR will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54:21 (a)(3).

Also, the staff performed an onsite audit to confirm the applicant's claim that certain identified

AMRs were consistent with the GALL Report. The staff did not repeat its review of the matters

described in the GALL Report. However, the staff did verify that the material presented in the

LRA was applicable and that the applicant had identified the appropriate GALL AMRs. The

staff's evaluations of the AMPs are documented in Section 3.0.3 of this SER. Details of the

staff's audit evaluations are documented in the staffs MPS audit and review report and are

summarized in Section 3.1B.2.1 of this SER.

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The staff also performed an onsite audit of those AMRs that were consistent with the GALL

Report and for which further evaluation is recommended. The staff confirmed that the

applicant's further evaluations were consistent with the acceptance criteria in Section 3.1.2.2 of

NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for Nuclear

Power Plants," dated July 2001. The staffs audit evaluation are documented in the MPS audit

and review report and are summarized in Section 3.1 B.2.2 of this SER.

The staff performed an onsite audit and conducted a technical review of the remaining AMRs

that were not consistent with or not addressed in the GALL Report. The audit and technical

review included evaluating whether all plausible aging effects were identified and whether the

aging effects listed were appropriate for the combination of materials and environments

specified. The staffs audit evaluation is documented in the MPS audit and review report and

summarized in Section 3.1 B.2.3 of this SER. The staffs evaluation of its technical review is also

documented in Section 3.1B.2.3 of this SER.

Finally, the staff reviewed the AMP summary descriptions in the FSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the reactor vessel, intemals, and reactor coolant system components.

Table 3.1 B-1 below provides a summary of the staffs evaluation of components, aging

effects/mechanisms, and AMPs listed in LRA Section 3.1 that are addressed in the GALL

Report.

Table 3.1B-1 Staff Evaluation for Reactor Vessel, Internals, and Reactor Coolant System

Components In the GALL Report

Component Group., Aging Effecl. -AMP In GALL - ' AMP In LRA Staff Evaiuaton . to:-..-iI:.-Mec anlsm n . - Rport -. '- - -

Reactor coolant Cumulative fatigue TLAA, evaluated TLAA This TLAA is

pressure boundary damage in accordance with evaluated In Section

components 10 CFR 54.21 (c) 4.3, Metal Fatigue (Item Number

3.1.1-01)

Steam generator Loss of material Inservice Chemistry control Consistent with

shell assembly due to pitting and inspection; water for secondary GALL, which

(Item Number crevice corrosion chemistry systems program recommends further

3.1.1-02) (B2.1.6); Inservice evaluation (See

Inspection program: Section 3.1.2.2.2)

systems,

components, and

supports (B2.1.18)

Pressure vessel Loss of fracture TLAA, evaluated TLAA This TLAA Is

ferritic materials toughness due to in accordance with evaluated in Section

that have a neutron neutron Irradiation Appendix G of 4.2, Reactor Vessel

fluence greater than embrittlement 10 CFR 50 and Neutron

1.0E17 n/cm2 (E>1 RG 1.99 Embrittlement.

MeV)

(Item Number

3.1.1-04)

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ComponentGroup Aging Effect ---- AMPlnGALL-,fi -AMPIn iLRA '--Staff Eva uation'

--. >.<-Mechanism. '-* p t - -Rep6r ;

Reactor vessel Loss of fracture Reactor vessel Reactor vessel Consistent with

beltline shell and toughness due to surveillance - surveillance GALL, which

welds neutron Irradiation (12.1.20) recommends further

(Item Number embrittlement evaluation (See

3.1.1-05) ' - Section 3.1.2.2.3)

Westinghouse and Loss of fracture Plant-specific Inservice inspection Consistent with

Babcock & Wilcox toughness due to program: reactor GALL, which

(B&W) baffle/former neutron irradiation vessel internals recommends further

bolts embrittlement and (B2.1.17) evaluation (See

(Item Number void swelling Section 3.1.2.2.3)

3.1.1-06)

Small-bore reactor Crack initiation and Inservice Chemistry control Consistent with

coolant system and growth due to SCC, inspection; water for primary systems GALL, which

connected systems IGSCC, and thermal chemistry; program (B2.1.5); recommends further

piping and mechanical - one-time - Inservice inspection evaluation (See

(Item Number loading inspection - program: systems, Section 3.1.2.2.4)

3.1.1-07) components and

supports (B2.1.18)

Vessel shell Crack growth due to TLAA Not applicable (See

(Item Number cyclic loading Section 3.1.2.2.5)

3.1.1-10)

Reactor Internals Changesin Plant-specific Inservice inspection Consistent with

(Item Number dimension due to program: reactor GALL, which

3.1.1-11) void swelling vessel internals recommends further

(B2.1.17) evaluation (See

Section 3.1.2.2.6)

PWR core support Crack Initiation and Plant-specific Chemistry control Consistent with

pads, Instrument growth due to SCC for primary systems GALL, which

tubes (bottom head and/or PWSCC program (B2.1.5); recommends further

penetrations), Inservice Inspection evaluation (See

pressurizer spray program: systems, Section 3.1.2.2.7)

heads, and nozzles components and

for the steam supports (82.1.18);

generator Inservice Inspection

instruments and program: reactor

drains vessel Internals

(Item Number (82.1.17)

3.1.1-12) .

Cast austenitic Crack Initiation and Plant-specific Chemistry control Consistent with

stainless steel growth due to SCC for primary systems GALL, which

(CASS) reactor program (B2.1.5); recommends further

coolant system Inservice Inspection evaluation (See

piping program: systems, Section 3.1.22.7)

(Item Number components and

3.1.1-13) . supports (12.1.18)

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CompontGroupn' '.;Aging Eff ct AMP-,,.:A GALL 41 ; R n ' ' StA a ff Evalu...on.''

---- Mehanism -Rport.~ i.--

Pressurizer Crack initiation and Inservice Chemistry control Consistent with

Instrumentation growth due to Inspection; water for primary systems GALL, which

penetrations and PWSCC chemistry program (B2.1.5); recommends further

heater sheaths and Inservice inspection evaluation (See

sleeves made of Ni program: systems, Section 3.1.2.2.7)

alloys components and

(Item Number supports (B2.1.18)

3.1.1-14) .

Westinghouse and Crack initiation and Plant-specific Chemistry control Consistent with

B&W baffle former growth due to SCC for primary systems GALL, which

bolts and irradiation- program (B2.1.5); recommends further

(Item Number assisted stress Inservice inspection evaluation (See

3.1.1-15) corrosion cracking program: reactor Section 3.1.2.2.8)

(IASCC) vessel Internals

._ (B2.1.17)

Westinghouse and Loss of preload due Plant-specific Inservice Inspection Consistent with

B&W baffle former to stress relaxation program: reactor GALL, which

bolts vessel internals recommends further

(Item Number (B2.1.17) evaluation (See

3.1.1-16) Section 3.1.2.2.9)

Steam generator Loss of section Plant-specific Not applicable (See

feedwater thickness due to Section 3.1.2.2.10)

Impingement plate erosion

and support

(Item Number

3.1.1-17)

(Alloy 600) Steam Crack initiation and Steam generator Chemistry control Consistent with

generator tubes, growth due to' tubing integrity, for primary systems GALL, which

repair sleeves, and PWSCC, ODSCC, water chemistry program (B2.11.5); recommends further

plugs and/or IGA or loss Chemistry control evaluation (See

(Item Number of material due to for secondary Section 3.1.2.2.11)

3.1.1-18) wastage and pitting systems program

corrosion, and (B2.1.6);

fretting and wear; or Steam generator

deformation due to structural Integrity

corrosion at tube (B2.1.22)

support plate

Intersections

Tube support lattice Loss of section Plant-specific Not applicable (See

bars made of thickness due to Section 3.1.2.2.12)

carbon steel flow-accelerated

(Item Number corrosion

3.1.1-19) ._.

Carbon steel tube Ligament cracking Plant-specific Not applicable (See

support plate due to corrosion Section 3.1.2.2.13)'

(Item Number

3.1.1-20)

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I
Comionent Group.-; AglrigEffrctI AMP in GALL , - MP inLRA ` -"Stiff Eva uation-'- -.-1*-Mechanlsm ;- >-- .Rootrt. -- ; - -:P -

Steam generator Loss of material Combustion Flow accelerated Consistent with

feedwater inlet ring due to flow Engineering corrosion (B2.1.1 1) GALL, which

and supports accelerated steam generator (for feedwater inlet recommends further

(Item Number corrosion feedwater ring ring) evaluation (See

3.1.1-21) Inspection Section 3.1.2.2.14) Although the Unit 3

steam generators are

not CE System 80

steam generators, the feedwater Inlet

ring is included in the

flow accelerated

corrosion program."."

Reactor vessel Crack Initiation and Reactor head Inservice inspection Consistent with

closure studs and growth due to SCC closure studs program: systems, GALL, whichstud assembly and/or IGSCC components and recommends no

(Item Number supports (B2.1.18) further evaluation

3.1.1-22) (See Section 3.1.2.1)

CASS pump casing Loss of fracture Inservice Inservice Inspection Consistent with

and valve body toughness due to inspection program: systems, GALL, which

(Item Number thermal aging components and recommends no

3.1.1-23) embrittlement supports (B2.1.18) further evaluation

(See Section

3.1 B.2.1.1)

CASS piping Loss of fracture Thermal aging Inservice inspection Consistent with

(Item Number toughness due to embrittlement of program: systems, GALL, which

3.1.1-24) thermal aging CASS components and recommends no

embrittlement supports (B2.1.18) further evaluation

(See Section

3.1.2.1.1)

BWR piping and Wall thinning due to Flow- accelerated Flow- accelerated Consistent with

fittings; steam flow- accelerated corrosion corrosion (B2.1.1 1) GALL, which

generator corrosion recommends no

components further evaluation

(Item Number (See Section 3.1.2.1)

3.1.1-25)

RCPB valve closure Loss of material Bolting Integrity Bolting integrity Consistent with

bolting, manway due to wear, loss of GALL, (See Section

and holding bolting, preload due to 3.1.2.1.2)

and closure bolting stress relaxation; in high pressure crack Initiation and

and high growth due to cyclic

temperature loading and/or SCC

systems

(Item Number

3.1.1-26)

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Comonent Group- Aging Effec-. AMFrGALL'i - .- AMP I LRA . . Staff Evaluation- ._____;'._____-___ _ Mechanism," . .- Repor-..XL-. 6 . -

CRD nozzle Crack initiation and Ni-alloy nozzles Chemistry control Consistent with

(Item Number growth due to and penetrations; for primary systems GALL, which

3.1.1-35) PWSCC water chemistry program (B2.1.5); recommends no

Inservice inspection further evaluation

program: systems, (See Section 3.1.2.1)

components and

supports (82.1.18)

Reactor vessel Crack initiation and Inservice Chemistry control Consistent with

nozzles safe ends growth due to cyclic inspection; water for primary systems GALL, which

and CRD housing; loading, and/or chemistry program (82.1.5); recommends no

reactor coolant SCC, and PWSCC Inservice inspection further evaluation

system components program: systems, (See Section 3.1.2.1)

(except CASS and components and

bolting) supports (82.1.18)

(Item Number

3.1.1-36)

Reactor vessel Loss of fracture Thermal aging Inservice inspection Consistent with

internals CASS toughness due and neutron program: reactor GALL, which

components thermal aging, irradiation vessel internals recommends no

(Item Number neutron irradiation embrittlement (132.1.17) further evaluation

3.1.1-37) embrittlement, and (See Section 3.1.2.1)

void swelling

External surfaces of Loss of material Boric acid Boric acid corrosion Consistent with

carbon steel due to boric acid corrosion (82.1.3) GALL, which

components In corrosion recommends no

reactor coolant further evaluation

system pressure (See Section 3.1.2.1)

boundary

(Item Number

3.1.1-38)

Steam generator Loss of material Inservice Not applicable (See - secondary due to erosion inspection Section 3.1.2.3.4)

manways and The steam

handholds (carbon generators are

steel) recirculating-type

(Item Number steam generators.

3.1.1-39)

Reactor intemals, Loss of material Inservice Inservice Inspection Consistent with

reactor vessel due to wear inspection program: reactor GALL, which

closure studs, and vessel intemals recommends no

core support pads (82.1.17); Inservice further evaluation

(Item Number inspection program: (See Section 3.1.2.1)

3.1.1-40) systems,

components and

supports (B2.1.18)

Pressurizer integral Crack initiation and Inservice Iriservice inspection Consistent with

support growth due to cyclic inspection program: systems, GALL, which

(Item Number loading components and recommends no

3.1.1-41) supports (82.1.18) further evaluation

(See Section 3.1.2.1)

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Component Gr up- Aging Effect ' - APIn GALL -, -- AMP In LRA' St ff Evaluation;

"_ _-;_.:-l- . 'Me'chanimhin - -: -.-.- . -' -:

Upper and lower Loss of preload due Inservice Inservice inspection Not consistent with

Internals assembly to stress relaxation inspection; loose program: reactor GALL (See Section

(Westinghouse) part anid/or vessel internals 3.0.3.2.12)

(Item Number neutron noise (B2.1.17)

3.1.1-42) monitoring

Reactor Vessel Loss of fracture PWR vessel Inservice inspection Consistent with GALL

Internals in fuel toughness due to internals; water program: reactor (See Section

zone region (except neutron irradiation chemistry vessel Internals 3.1.2.1.3)

Westinghouse B&W embrittlement and (B2.1.17);

baffle former bolts) void swelling Chemistry control

(Item Number for primary systems

3.1.1-43) v - program (82.1.5)

Steam generator Crack initiation and Inservice Inservice Inspection Consistent with

upper and lower growth due to SCC, Inspection; water program: systems, 'GALL, which

heads, tubesheets, PWSCC, and/or chemistry components and recommends no

and primary nozzles IASCC supports (B2.1.18); furtheir evaluation

and safe ends Chemistry control (See Section 3.1.2.1)

(Item Number for primary systems

3.1.1-44) program (B2.1.5)

Vessel internals Crack initiation and PWR vessel Inservice inspection Consistent with

(except growth due to SCC intemals; water program: reactor GALL, which

Westinghouse and and IASCC chemistry vessel intemals recommends no

B&W baffle former (B2.1.17); further evaluation

bolts) Chemistry control (See Section 3.1.2.1)

(Item Number for primary systems

3.1.1.45) program (B2.1.5)

Reactor internals Loss of preload due Inservice ' Not applicable Not applicable

(B&W screws and to stress relaxation Inspection; loose (reactor vessel

bolts) part monitoring Internals were not

(Item Number . . . designed by B&W)

3.1.1.46) . .... ; . _.. A .

Reactor vessel Loss of material Reactor head Not consistent with

closure studs and due to wear closure studs GALL (See Section

stud assembly 3.1.2.3)

(Item Number

3.1.1-47)

Reactor Intemals Loss of preload due Inservice Inservice Inspection Not consistent with

(Westinghouse to stress relaxation Inspection; loose program: reactor GALL (See Section

upper and lower part monitoring vessel internals 3.0.32.12)

internal assemblies, (B2.1.17)

CE bolts and tie . * -

rods)

(Item Number 3.1.1-48)

The staff's review of the MPS reactor vessel, Internals,' and reactor coolant system and

associated components followed one'of several approaches. One approach, documented in

Section 3.1B.2.1, involves the staff's review of the AMR results for components'in reactor

vessel, internals, and reactor coolant system that the applicant indicated are consistent with the

GALL Report and do not require further evaluation. Another approach, documented in Section

3.1 B.2.2, involves the staff's review of the AMR results for components in the reactor vessel,

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internals, and reactor coolant system that the applicant indicated are consistent with the GALL

Report and for which further evaluation is recommended. A third approach, documented in

Section 3.1 B.2.3, involves the staff's review of the AMR results for components in the reactor

vessel, internals, and reactor coolant system that the applicant indicated are not consistent with

the GALL Report or are not addressed in the GALL Report. The staffs review of AMPs that are

credited to manage or monitor aging effects of the reactor coolant system components is

documented in Section 3.0.3 of this SER.

3.1B.2.1 AMR Results ThatAre Consistent with the GALL Report, for Which Further

Evaluation is Not Recommended

In Section 3.1.2.1 of the LRA, the applicant identified the materials, environments, and aging

effects requiring management. The applicant identified the following programs that manage the

aging effects related to the reactor vessel, internals, reactor coolant system, and steam

generator components:

* boric acid corrosion program

• chemistry control for primary systems program

* chemistry control for secondary systems program

* inservice inspection program: reactor vessel internals program

* inservice inspection program: systems, components and supports program

* reactor vessel surveillance program

* closed-cycle cooling water system program

* general condition monitoring program

* work control process program

* flow-accelerated corrosion program

* steam generator structural integrity program

Staff Evaluation. In Tables 3.1.2-1 through 3.1.2-4 of the LRA, the applicant provided a

summary of AMRs for the reactor vessel, internals, reactor coolant system, and steam

generator, and identified which AMRs it considered to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific.

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes described how the information

in the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicated the AMR was consistent with the GALL Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In additiori, the AMP takes some exceptions to the

AMP identified in the GALL Report. The staff audited these line items to verify consistency with

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- -

the GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by

the applicant was consistent with the AMP identified in the GALL Report and whether the AMR

was valid for the site-specific conditions.'

Note C indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP is consistent

with the AMP identified by the GALL Report. This note indicates that the applicant was unable

to find a listing of some system components in the GALL Report. However, the applicant

identified a different component in the GALL Report that had the same material, environment,

aging effect, and AMP as the component that was under review. The staff audited these line

items to verify consistency with the GALL Report. The staff also determined whether the AMR

line item of the different component was applicable to the component under review and whether

the AMR was valid for the site-specific conditions.

Note D indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP takes some

exceptions to the AMP identified in the GALL Report. The staff audited these line items to verify

consistency with the GALL Report. The staff verified whether the AMR line item of the different

component was applicable to the component under review. The staff verified whether the

identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The staff

also determined whether the AMP identified by the applicant was consistent with the AMP

identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note E indicated that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified

by the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the LRA, as documented

in its MPS audit and review report. The staff did not repeat its review of the matters described in

the GALL Report. However, the staff did verify that the material presented in the LRA was

applicable and that the applicant had identified the appropriate GALL Report AMRs. The staffs

evaluation is discussed below.

3.1 B.2.1.1 Loss of Fracture Toughness Due to Thermal Aging Embrittlement

In the discussion section of Table 3.1.1, Item 3.1.1-24 of the LRA, the applicant stated that loss

of fracture toughness is not an aging effect requiring management for applicable CASS piping and components. During the audit and review, the staff asked the applicant for clarification as to

why loss of fracture toughness is not an aging effect requiring management. The applicant

replied that loss of fracture toughness of the CASS piping is not an aging effect requiring

management because the results of leak-before-break (LBB) analysis demonstrated that there

was a large margin between detectable flaw size and flaw instability. The staff reviewed the

applicant's TLAA report regarding LBB, and found that the LBB analysis is not a flaw tolerance

evaluation as specified by the GALL Report. The applicant agreed that the LBB analysis cannot

be used to manage the loss of fracture toughness due to thermal aging embrittlement. The

applicant submitted an LRA supplement letter, dated July 7, 2004, and stated as follows:

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- I

Note "6" for Tables 3.1.2-1 through 3.1.2-4 (page 3-106), should state the following:

For potentially susceptible CASS materials, either enhanced volumetric

examinations or a unit or component specific flaw tolerance evaluation

(considering reduced fracture toughness and unit specific geometry and stress

information) will be used to demonstrate that the thermally embrittled material

has adequate fracture toughness in accordance with NUREG-1 801 Section

XI.M12.

'Loss of Fracture Toughness' as an aging effect for component group 'Pipe (Hot

and Cold Leg Piping and Fittings)' should be added in Unit 3 Table 3.1.2-3

(page 3-80). The 'Loss of Fracture Toughness' is managed by the inservice

inspection program: systems, components and supports and corresponds to

NUREG-1801 Item IV.C2.1-f. The Note for this entry is "A,6" and the 'Table 1

Item' is 3.1.1-24." NOTE: Only the 'Loss of Fracture Toughness' entry will have

Note "60 listed for the above component group.

The 'Discussion' column in Table 3.1.1, Item 24, (page 3-32), should read as follows:

Consistent with NUREG-1 801. Loss of fracture toughness is managed with the

inservice inspection program: systems, components and supports and this

program takes some exception to the NUREG-1801 AMP.

Additionally, a new commitment, Item 28, should be added to LRA Appendix A, Table A6.0-1 as

follows and will be implemented prior to the period of extended operation:

For potentially susceptible CASS materials, either enhanced volumetric

examinations or a unit or component specific flaw tolerance evaluation

(considering reduced fracture toughness and unit specific geometry and stress

information) will be used to demonstrate that the thermally embrittled material

has adequate fracture toughness in accordance with NUREG-1 801 Section

XI.M12.

The applicant modified the corresponding LRA to reflect the audit findings. The staff reviewed

the applicant's LRA supplement and finds that the applicant appropriately addressed the aging

mechanism with the abovementioned new commitment, as recommended in the GALL Report.

3.1 B.2.1.2 Loss of Material Due to Wear; Loss of Preload Due to Stress Relaxation; Crack

Initiation and Growth Due to Cyclic Loading and/or Stress Corrosion Cracking

In LRA Table 3.1.1, Item 26 (page 3-32), the applicant stated that cracking and loss of preload

are managed using AMP B2.1.18, "Inservice Inspection Program: Systems, Components and

Supports." Also, the applicant stated that loss of material due to wear is not an aging effect

requiring management for this bolting.

The staff noted that SRP-LR Table 3.1-1 recommended GALL AMP XI.M18, "Bolting Integrity,"

for managing closure bolting in high pressure or high temperature system for loss of material

due to wear, loss of preload due to stress relaxation; crack initiation and growth due to cyclic

loading and/or SCC.

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The staff questioned the applicant on whether the resolution of all the generic safety issues for

bolting, as stated in NUREG-1339, are addressed.'By letter dated December 3, 2004, the

applicant submitted an LRA supplement. In its supplement, the applicant stated that it has

developed a specific bolting integrity aging management program that addresses degradation

of bolting at MPS. The bolting integrity program is reviewed in Section 3.0.3.2.18 of this SER.

By letter dated January 11 2005, the applicant submitted its bolting aging management roll-up

item. In its response, the applicant replaced the existing information in the Discussion" column

of LRA Table 3.1.1, Item 26 with consistent with the NUREG-1 801." The staff finds this

acceptable since it is consistent with the GALL Report.

3.1 B.2.1.3 Loss of Fracture Toughness Due to Neutron Irradiation Embrittlement, and Void

Swelling

In LRA Table 3.1.1, Item 43 (page 3-37), the applicant stated that loss of fracture toughness is

managed using MPS AMP B2.1.17, 'Inservice Inspection Program: Reactor Vessel Intemals."

Also, the applicant stated that MPS AMP B2.1.5, "Chemistry Control for Primary Systems

Program," is not credited to manage these aging effects, but is applied to all reactor vessel

internals components as a corrosion mitigation program.

The staff reviewed the inservice inspection program: reactor vessel internals program and the

chemistry control for primary systems program and its evaluation is documented in

Sections 3.0.3.2.12 and 3.0.3.2.1 of this SER, respectively. On the basis of its review, the staff

agreed with the applicant that the chemistry control for primary systems program is a corrosion

mitigation program. The staff finds that the applicant's proposed program is adequate to

manage loss of fracture toughness due to neutron irradiation embrittlement and void swelling.

On the basis of its audit and review, the staff concludes that the applicant has demonstrated

that the effects of aging will be adequately managed so that the intended function(s) will be

maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21 (a)(3).

On the basis of its audit and review, the staff determined that for all other AMRs not requiring

further evaluation, as identified in LRA Table 3.1.1 (Table 1), the applicant's references to the

GALL Report are acceptable and no further staff review is required.

Conclusion. The staff has evaluated the applicant's claim of consistency with GALL Report. The

staff also has reviewed information pertaining to the applicant's consideration of recent

operating experience and proposals for managing associated aging effects. On the basis of its

review, the staff finds that the AMR results, which the applicant claimed to be consistent with

the GALL Report, are consistent with the AMRs in the GALL Report. Therefore, the staff finds

that the applicant has demonstrated that the effects of aging for these components will be

adequately managed so that their intended function(s) will be maintained consistent with the

CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.1B.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Application. In Section 3.1.2.2 of the LRA, the

applicant provided further evaluation of aging management as recommended by the GALL

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Report for reactor vessel, internals, reactor coolant system, and steam generator components.

The applicant provided information concerning how it will manage the following aging effects:

* cumulative fatigue damage

* loss of material due to pitting and crevice corrosion

* loss of fracture toughness due to neutron irradiation embrittlement

* crack initiation and growth due to thermal and mechanical loading or stress corrosion

cracking

* crack growth due to cyclic loading

* changes in dimension due to void swelling

* crack initiation and growth due to stress corrosion cracking or primary water stress

corrosion cracking

* crack initiation and growth due to stress corrosion cracking or irradiation-assisted stress

corrosion cracking

* loss of preload due to stress relaxation

* loss of section thickness due to erosion

* crack initiation and growth due to PWSCC, ODSCC, or integranular attack or loss of

material due to wastage and pitting corrosion or loss of section thickness due to fretting

and wear or denting due to corrosion of carbon steel tube support plate

* loss of section thickness due to flow-accelerated corrosion

* ligament cracking due to corrosion

* loss of material due to flow-accelerated corrosion

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff reviewed the applicant's evaluation to determine whether it

adequately addressed the issues that were further evaluated. In addition, the staff reviewed the

applicant's further evaluations against the criteria contained in Section 3.1.3.2 of the SRP-LR.

Details of the staffs audit and review are documented in the staffs audit and review report.

The GALL Report indicates that further evaluation should be performed for the aging effects

described in the following sections of this SER.

3.1B.2.2.1 Cumulative Fatigue Damage

As stated in the SRP-LR, fatigue is a TLAA, as'defined in 10 CFR 54.3. Applicants must

evaluate TLAAs in accordance with 10 CFR 54.21(c)(1). Section 4.3 of this SER documents the

staffs review of the applicant's evaluation of this TLAA. In performing this review, the staff

followed the guidance in Section 4.3 of the SRP-LR.

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3.1 B.2.2.2 Loss of Material Due to Pitting and Crevice Corrosion

In LRA Section 3.1.2.2.2.1, the applicant addressed loss of material of steam generator

assemblies due to pitting and crevice corrosion.

SRP-LR Section 3.1.2.2.2 states that loss of material due to pitting and crevice corrosion could

occur in the steam generator shell assembly. The existing program relies on control of water

chemistry to mitigate corrosion, and inservice inspection to detect loss of material. NRC IN

90-04, "Cracking of the Upper Shell-to-Transition Cone Girth Welds in Steam Generators,"

states that if general corrosion pitting of the shell exists,-the existing program may not be

sufficient. In that case, the GALL Report recommends augmented inspections to manage the

aging effect.

The AMPs recommended by the GALL Report for managing the aging of steam generator

assemblies due to pitting and crevice corrosion are GALL AMP XI.M1, "ASME Section Xi,

Inservice Inspection, Subsections IWB, IWC,-and IWD," to detect loss of material and GALL, -

AMP XI.M2, 'Water Chemistry," to mitigate corrosion. The GALL Report recommends a

plant-specific program to conduct augmented inspections.

In the LRA, the applicant credited MPS AMP B2.1.18, 'Inservice Inspection Program: Systems,

Components and Supports," and MPS AMP. B2.1.6, 'Chemistry Control for Primary Systems,"'

for managing loss of material due to pitting and crevice corrosion for the internal surfaces of the

steam generator shell. The staff evaluated these programs and its evaluation is documented in

Section 3.0.3.2.13 and Section-3.0.3.32 of this SER, respectively. -

The staff reviewed NRC IN 90-04, which identifies the need to perform augmented inspections

beyond the requirements of ASME Section Xl, if general corrosion pitting of the steam

generator shell is known to exist, in order to differentiate isolated cracks from inherent

geometric conditions. The staff reviewed operating experience which indicated that no pitting

corrosion of the steam generator shell has been detected to date, and that'water chemistry has

been maintained for these steam generators per EPRI guidelines. The staff finds that the.

augmented inspections recommended by NRC IN 90-04 and referenced in the SRP-LR do not

currently apply to the Unit 3 steam generators.

Also, since pitting corrosion has not been detected on the steam generator shell since

installation, the staff finds that augmented inspections are not required and that the current

water chemistry control and inservice inspection programs are consistent with the

recommendations of the GALL Report and adequately manage this aging effect.

The staff finds that, based on the programs identified above, the applicant has demonstrated

that the effects of aging will be adequately managed so that the intended functions will be '-'

maintained consistent with the CLB during the period of extended operation, as required by

10 CFR 54.21 (a)(3).

3.IB.2.2.3 Loss of Fracture Toughness Due to Neutron Irradiation Embrittlement

In LRA Section 3.1.2.2.3, the applicant addressed (1) loss of fracture toughness'due to neutron

irradiation embrittlement for ferritic materials that have a neutron fluence'of greater than

1017 n/cm2 at the end of the license renewal term, (2) loss of fracture toughness due to

irradiation embrittlement of the reactor vessel beltline materials, and (3) loss of fracture

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toughness due to irradiation embrittlement and void swelling of the Westinghouse baffle/former

bolts.

SRP-LR Section 3.1.2.2.3 states that certain aspects of neutron irradiation embrittlement are

TLAAs as defined in 10 CFR 54.3 and that TLAAs are required to be evaluated in accordance

with 10 CFR 54.21 (c)(1). SRP-LR Section 3.1.2.2.3 also states that loss of fracture toughness

due to neutron irradiation embrittlement could occur in the reactor vessel. A reactor vessel

materials surveillance program monitors neutron irradiation embrittlement of the reactor vessel.

Reactor vessel surveillance programs are plant-specific, depending on matters such as the

composition of limiting materials, availability of surveillance capsules, and projected fluence

levels. In accordance with 10 CFR 50, Appendix H, an applicant is required to submit its

proposed capsule withdrawal schedule for approval prior to implementation. SRP-LR

Section 3.1.2.2.3 states that loss of fracture toughness due to neutron irradiation embrittlement

and void swelling could occur in Westinghouse baffle/former bolts.

The AMP recommended by the GALL Report for managing loss of fracture toughness due to

neutron irradiation embrittlement in the reactor vessel is GALL AMP XI.M31, "Reactor Vessel

Surveillance," which complies with the requirements of 10 CFR 50, Appendices G and H. and

10 CFR 50.61.

Certain aspects of neutron irradiation embrittlement are a TLAA as defined in 10 CFR 54.3. The

TLAA is required to be evaluated in accordance with a 10 CFR 54.21 (c)(1). The staff's

evaluation of this TLAA can'be found in Section 4.2 of this SER, following the guidance in

Section 4.2 of the Standard Review Plan for License Renewal (SRP-LR).

Loss of fracture toughness due to neutron irradiation embrittlement could occur in the reactor

vessel. A reactor vessel materials surveillance program monitors neutron irradiation

embrittlement of the reactor vessel. Reactor vessel surveillance programs are plant-specific,

depending on matters such as the composition of limiting materials, availability of surveillance

capsules, and projected fluence levels. In accordance with 10 CFR Part 50, Appendix H; an

applicant is required to submit its proposed withdrawal schedule for approval prior to

implementation. Thus,' further staff evaluation is required for license renewal. NUREG-1 801

recommends further evaluation of the reactor vessel materials surveillance program for the

period of extended operation. The staff verifies that the applicant has proposed an adequate

reactor vessel materials surveillance program for the period of extended operation. This staff

evaluation is discussed in Section 3.0.3.1.3 of this SER.

The limiting beltline material for upper shelf energy (USE) at Millstone Unit 2 is the intermediate

and lower shell beltline axial welds, heat no. A8746. The limiting beltline material for

pressurized thermal shock (PTS) at Millstone Unit 2 is the Lower Shell Plate C-506-1. (Heat No.

C5667-1). The Millstone Unit 2 reactor vessel surveillance program, in conjunction with TLAA

analyses, effectively manages loss of fracture toughness in the beltline materials. The reactor

vessel surveillance program provides adequate material property and neutron dosimetry data to

predict fracture toughness in beltline materials at the end of the period of extended operation.

The analyses (see TLAAs, SER Section 4.2) for the USE and PTS provide assurance that

beltline material toughness values in the Millstone Unit 2 reactor vessel will remain at

acceptable levels through the period of extended operation. The reactor vessel surveillance

program is reviewed in SER Section 3.0.3.1.3 (AMP B2.1.20).

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Loss of fracture toughness due to neutron irradiation embrittlement and void swelling could also

occur in control element assembly (CEA) shroud bolts, core shroud tie rods, and core support

barrel snubber assemblies. The staff reviewed the applicant's proposed program on a case-bycase basis to ensure that an adequate program will be in place for management of these aging

effects. A combination of the ASME Section Xl, Subsections IWB,; IWC, and IWD inservice

inspection program and the reactor vessel internals program (described in Appendix B) will be

used to-manage loss of fracture toughness due to neutron irradiation embrittlement and void

swelling in CEA shroud bolts, core shroud tie rods and core support barrel snubber assemblies.

Millstone will also participate in industry activities and monitor industry initiatives for the purpose

of evaluating the significance of void swelling and fracture toughness on selected PWR reactor

vessel internals components. As new information and technology becomes available, the plant-'

specific reactor vessel internals program will be modified to incorporate enhanced surveillance

techniques. In addition, the applicant has identified the implementation of the industry initiatives

as commitment 13 in Appendix A, Table A6.0-1 of the LRA. The evaluation of this program and

the commitment to updating this program is addressed in Section 3.0.3.2.12 (AMP B2.1.17) of

this SER.

The staff finds that the applicant's AMR results are consistent with the GALL Report and that

the applicant has demonstrated that the programs to manage the effects of aging will be

adequate to maintain the intended functions consistent with the CLB during the period of

extended operation, as required by 10 CFR 54.21(a)(3).

3.1B.2.2.4 Crack Initiation and Growth Due to Thermal and Mechanical Loading or Stress

Corrosion Cracking

In LRA Section 3.1.2.2.4.1, the applicant addressed the potential crack initiation and growth due

to thermal and mechanical loading or SCC (including intergranular stress corrosion cracking)

that could occur in small-bore RCS and connected system piping less than 4-inch nominal pipe

size (NPS 4).

SRP-LR Section 3.1.2.2.4.1 states that the GALL Report recommends that a plant-specific

destructive examination or a nondestructive examination (NDE) that permits inspection of the

inside surfaces of the piping be conducted to ensure that cracking has not occurred and the

component intended function will be maintained during the period of extended operation. The

applicant should verify that service-induced weld cracking is not occurring in small-bore piping

less than NPS 4. A one-time inspection of a sample of locations is an acceptable method to

ensure that the aging effect is not occurring and the component's intended function will be

maintained during the period of extended operation. Per ASME Section XI, 1995 edition,

examination category B-J or B-F, small bore piping, defined as piping less than NPS 4, does

not receive volumetric inspection.

The GALL Report recommended GALL AMP XI.M1, "ASME Section Xl Inservice Inspection,

Subsections IWB, IWC, and IWD" to detect loss of material and GALL AMP XI.M2, "Water

Chemistry" to mitigate SCC. I -

The staff reviewed LRA Section 3.1.2.2.4.1. The applicant credited MPS AMP B2.1.18,

"Inservice Inspection Program: Systems, Components and Supports," and MPS AMP B2.1.5,

"Chemistry Control for Primary Systems," to mitigate cracking of reactor coolant piping. The

staff evaluated these programs and its evaluation is documented in Sections 3.0.3.2.13 and

3.0.3.2.2 of this SER, respectively.

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'I "

To address the GALL Report recommendation that a plant-specific destructive examination or

an NDE that permits inspection of the inside surfaces of the piping be conducted, the applicant

stated in the LRA that it has implemented an RI-ISI methodology to select RCS piping welds for

inspection in lieu of the requirements specified in ASME Section Xl. To address the GALL

Report for a one-time inspection of small-bore piping less than NPS'4, the application indicated

that small-bore pipe butt-welded connections are included in the final weld selection for

performance of volumetric examination. The staff verified that the applicant used the RI-ISI

process to determine the most susceptible locations for performing the volumetric examination

and did not eliminate small-bore pipe welds from examination with the RI-ISI process.

The staff reviewed and verified that the applicant's RI-ISI plan will perform a volumetric

examination, which is required to address cracking for small-bore Class 1 piping per ISG-12,

"One-Time Inspection of Small-Bore Piping," on elements not currently required to be

volumetrically examined. Based on the programs identified above, the staff finds that the

applicant appropriately evaluated AMR results involving current inspection methods, as detailed

in the inservice inspection program, and as supplemented by water chemistry control, for

managing cracking of small-bore piping systems.

The staff finds that the applicant's AMR results are consistent with the GALL Report, and that

the applicant has demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB during the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.1 B.2.2.5 Crack Growth Due to Cyclic Loading

NUREG-1801 recommends further evaluation of programs to manage crack growth due to

cyclic loading in the reactor vessel shell. Crack growth due to cyclic loading in reactor vessel

shells are evaluated as a TLAA. Growth of intergranular separations (underclad cracks) in lowalloy or carbon steel heat-affected zones under austenitic stainless steel cladding is a TLAA to

be evaluated for the period of extended operation for all the SA 508-Class 2 forgings where the

cladding was deposited with a high heat input welding process. Since Millstone Unit 3 does not

use SA 508-Class 2 forgings in the beltline region, this evaluation is not applicable. In addition,

the Millstone Unit 3 LRA, Section 3.1.2.2.5 states that there are no detected underclad cracks

identified in the reactor vessel.

3.1B.2.2.6 Changes in Dimension Due to Void Swelling

In LRA Section 3.1.2.2.6, the applicant addressed changes in dimension due to void swelling

that could occur in reactor internal components.

SRP-LR Section 3.1.2.2.6 states that the GALL Report recommends that changes in dimension

due to void swelling in reactor internal components be evaluated to ensure that this aging effect

is adequately managed. The GALL Report recommends that a plant-specific AMP be evaluated

to manage the effects of changes in dimension due to void swelling and the loss of fracture

toughness associated with swelling.

In general, the applicant has concluded that void swelling is an aging related effect for the

reactor vessel intemals, but currently only credits the ASME Section Xl, Subsection IWB,

Category B-N-3 inservice inspections to manage change in dimensions due to void swelling. In

lieu of the implementation of augmented inspections, such as enhanced visual VT-1

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.

examinations or enhanced volumetric examination, Millstone will follow industry efforts to

determine the necessary steps for managing void swelling. Currently no augmented inspection

will be performed. However, since the EPRI Materials Research Project - Reactor Internals

Issue Task Group is currently addressing'this issue, the applicant will follow the industry effort

related to void swelling and will implement the appropriate recommendations resulting from this

guidance. In addition, the applicant has identified the implementation of the industry initiatives

as commitment 13 in Appendix A, Table A6.0-1 of the LRA. Further evaluation of this program

and the commitment to updating this program is addressed in Section 3.0.3.2.12 (AMP B2.1.17)

of this SER.

The staff finds the applicant's approach for managing changes in dimension due to void

swelling acceptable because the approach will be based on the guidelines developed by the

ongoing industry activities related to void swelling. The applicant has committed to implement

the appropriate recommendations resulting from the industry efforts. The applicant also

committed, through an LRA supplement letter dated July 7, that the revised program

description, including a comparison to the 10 program elements of the GALL Report program,

will be submitted to the NRC for approval prior to the period of extended operation.

On the basis of its review, the staff finds the applicant's approach for managing changes in

dimension due to void swelling will be maintained consistent with the CLB during the period of

extended operation, as required by 10 CFR 54.21 (a)(3).

3.1 B.2.2.7 Crack Initiation and Growth Due to Stress Corrosion Cracking or Primary Water

Stress Corrosion Cracking

In the LRA Section 3.1.2.2.7.1, the applicant addressed (1) crack initiation and growth due to

SCC and PWSCC in the pressurizer (spray head assembly/nozzle assembly), core support

pads, and instrumentation tubes (bottom head); (2) crack initiation and growth due to SCC in

the hot leg and cold leg piping and fittings fabricated ofCASS; and (3) crack initiation and

growth due to PWSCC in nickel-based alloy material such as the pressurizer (safe-end welds,

surge, spray, relief, and safety), reactor vessel (safe-end welds, primary inlet and outlet), and

steam generator primary drain nozzle weld.

SRP-LR Section 3.1.2.2.7 states that:

* Crack initiation and growth due to SCC and PWSCC could occur in core support pads

(or core guide lugs), instrument tubes (bottom head penetrations), pressurizer spray

heads, and nozzles for the steam generator instruments and drains. The GALL Report

recommends further evaluation to ensure that these aging effects are adequately

managed. -The GALL Report recommends that a plant-specific AMP be evaluated

because existing programs may not be capable of mitigating or detecting crack initiation

and growth due to SCC.

* Crack initiation and growth due to SCC could occur in CASS RCS piping and fittings and

pressurizer surge line nozzles. The GALL Report recommends further evaluation of

piping that does not meet either the reactor water chemistry guidelines of EPRI

TR-1 05714 or material guidelines of NUREG-0313, "Technical Report on Material

Selection and Processing Guidelines for BWR Coolant Pressure Boundary Piping,"

Revision 2, January 1988.

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Crack initiation and growth due to PWSCC could occur in pressurizer instrumentation

penetrations and heater sheaths and sleeves made of nickel alloys. The existing

program relies on ASME Section Xl inservice inspections and on control of water

chemistry to mitigate PWSCC. However, the existing program should be augmented to

manage the effects of SCC on the intended function of nickel-alloy components. The

GALL Report recommends that the applicant provide a plant-specific AMP or participate

in industry programs to determine appropriate AMPs for PWSCC of the Inconel 182

weld.

The applicant credited the following plant-specific programs for each of the three SRP-LR

criteria:

Cracking of nickel-based alloy components due to PWSCC is managed by the

nickel-based alloys (i.e., PWSCC in Alloy 600 base metal and Alloy 82/182 weld metals)

aging management activities, which are part of MPS AMP B2.1.18, "nservice Inspection

Program: Systems, Components and Supports," supplemented by MPS AMP B2.1.5,

"Chemistry Control for Primary Systems Program." Additionally, EPRI, through its MRP

and in conjunction with the PWR owners groups, is developing a strategic plan to

manage and mitigate cracking of nickel-based alloy items. The applicant stated that the

guidance developed by the MRP will be used to identify the appropriate aging

management activities and will implement the appropriate recommendations resulting

from this guidance as described in license renewal Commitment, Item 15. Pressurizer

spray head fabricated from stainless steel is not a reactor coolant pressure boundary

component and is managed by MPS AMP B2.1.5, "Chemistry Control for Primary

Systems Program."

* Crack initiation and growth due to SCC at weld connections, including the hot leg and

cold leg piping -and fittings, is managed by MPS AMP B2.1.5," Chemistry Control for

Primary Systems Program," and MPS AMP B2.1.18, "Inservice Inspection Program:

Systems, Components and Supports."

* The programs credited for the management of PWSCC of these nickel-based alloy

items are the nickel-based alloys (i.e., PWSCC in Alloy 600 base metal and Alloy 82/182

weld metals) aging management activities, which are part of MPS AMP B2.1.18,

uInservice Inspection Program: Systems, Components and Supports," and MPS AMP

B2.1.5, "Chemistry Control for Primary Systems Program." As described in Item 1

above, the applicant committed to participate in the nickel-based alloys industry

programs to identify appropriate aging management activities and implement the

appropriate recommendations from the guidance developed by industry programs.

The GALL Report recommends that a plant-specific aging management program be evaluated

because existing programs may not be capable of mitigating or detecting crack initiation and

growth due to SCC. Acceptance criteria are described in Branch Technical Position RLSB-1

(Appendix A.1 of the SRP-LR). The staff reviewed the applicant's proposed program to ensure

that an adequate program will be in place for the management of these aging effects.

Crack initiation and growth due to SCC could occur in PWR CASS reactor coolant system

piping and fittings and the pressurizer surge line nozzle. For PWR's, NUREG-1 801

recommends further evaluation of piping that does not meet the reactor water chemistry

guidelines of TR-1 05714, "PWR Primary Water Chemistry Guidelines, Revision 3," November

1995, or later. Since Millstone Unit 3 uses the guidelines of Revision 4 to TR-1 05714, no further

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evaluation of a plant-specific AMP is required since the applicant minimizes the potential for

SCC by using the later revision of TR-1 05714 in accordance with NUREG-1 801. In addition the

applicant uses the inservice inspection program: systems, components and supports to manage

cracking of CASS components. The applicant's AMP B2.1.18 includes the AMP

recommendations for CASS in NUREG-1801, AMP XL.M12, Thermal Aging Embrittlement of

Cast Austenitic Stainless Steel (CASS), and AMP XI.M1, ASME Section Xl Inservice Inspection,

Subsection IWB, IWC, and IWD.

Crack initiation and growth due to PWSCC could occur in reactor vessel bottom head

instrumentation penetrations, pressurizer instrumentation penetrations and heater sheaths and

sleeves, and the pressurizer safe-ends for surge line, spray, relief and safety system lines

made of nickel-based alloys. The pressurizer heater sheaths and sleeves in Millstone Unit 3 are':

made of stainless steel and therefore are not subject to PWSCC. The existing program relies

on ASME Section Xl Inservice Inspection (ISI) and on control of water chemistry to mitigate

PWSCC. However, the existing program should be augmented to manage the effects of ''

PWSCC on the intended function of components fabricated from nickel-based alloys. NUREG1801 recommends that the applicant provide a plant-specific AMP or participate in industry

programs to determine an appropriate AMP for PWSCC of Inconel 182 weld. Acceptance

criteria are described in Branch Technical Position RLSB-1 (Appendix A.1 of the SRP-LR). The

staff reviewed the applicant's proposed program to ensure that an adequate program will be in ^:

place for the management of these aging effects. Millstone Unit 3 has nickel-based alloys (Alloy

600 and 82/182) in the reactor vessel bottom head instrumentation penetrations and the welds

joining the pressurizer safe-ends to the surge, spray, relief and safety system lines. The

Millstone Unit 3 LRA (Appendix A, Table A6.0-1, commitment 15) identifies that Millstone Unit 3

will participate in industry programs to determine appropriate measures to manage PWSCC

and submit an appropriate AMP to the NRC staff for approval prior to entering the extended

period of operation. The aging management program for PWSCC is discussed in AMP B2.1.18.

Additional assurance of crack detection is through the boric acid corrosion program, which is

described in AMP B2.1.3. In this program, leakage detection is utilized to detect cracks in Alloy

600 base metal and Alloy 82/182 weld metal components in the pressurizer, as specified in

NRC Bulletin 2004-01.

The CASS pressurizer spray head assembly identified in Table 3.1.2-3 of the LRA specified the

chemistry control AMP to manage cracking. NUREG-1801, Section IVC2.5-j identifies a plantspecific AMP to be used to manage cracking. Therefore, the applicant was requested in RAI

3.1.3-2 to provide this AMP to the NRC for evaluation as recommended by NUREG-1801,.

Section IVC2.5j.-

In response to RAI 3.1.3-2, in a letter dated December 3, 2004, the applicant stated that the

plant-specific AMP specified in Millstone Unit 3 LRA, Table 3.1.2-3 for managing the aging

effects associated with the CASS pressurizerxspray head is the chemistry control for primary

systems program. The RCS stainless steel materials, including the pressurizer spray head, are

exposed internally to a high-quality primary water and/or steam environment that is not

expected to result in significant stress corrosion cracking. Therefore, the applicant stated that

the chemistry control for primary systems program AMP provides reasonable assurance that

cracking resulting from SCC will not prevent the spray head from performing its intended

function. The staff agrees that the water chemistry can be used to mitigate SCC, but an

inspection is necessary to indicate whether-the water chemistry has prevented SCC. Discussed

in Section 3.1A.3. The aging management program for SCC, including the spray head is

discussed in AMP B2.1.18 in SER Section 3.0.3.2.13.-'-

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The applicant stated in Section 4.3.1 of the Millstone Unit 3 LRA that the CASS pressurizer

spray head assembly has been evaluated for susceptibility to thermal embrittlement using the

guidance and information contained in EPRI Report TR-1 06092. In addition the applicant stated

that acceptable results employing applicable loads (e.g., thermal cycles) and material properties

have been calculated over the 60-year license renewal period. The staff notes that GALL AMP

XL.M12 recommends the CASS material to be evaluated based on the criteria set forth in the

May 19, 2000, NRC letter to determine susceptibility to thermal aging embrittlement. This letter

provided the staffs position on thermal aging embrittlement. The staff requests that the

applicant confirm that the evaluation performed meets the guidelines of the May 19, 2000, NRC

letter and NUREG-1 801. If the evaluation does not conform to these guidelines, the applicant is

requested to provide the results of an evaluation that meets the guidelines of the May 19, 2000,

NRC letter and the information (i.e., molybdenum content, casting method and percent ferrite)'

to confirm that the spray head satisfies the criteria set forth in the staffs letter dated May 19,

2000. The applicant is also requested to discuss how this evaluation meets the requirements of

10 CFR 54.21 (c)(1)(i), (ii) or (iii).

In response to supplemental RAI 3.1.3-3, in a letter dated February 8, 2005, the applicant

stated that the response to supplemental RAI 4.7.3-1 (a) addresses supplemental RAI 3.1.3-3.

The staff noted that the response to RAI 4.7.3-1 (a) provides information on the evaluation of

CASS reactor coolant pumps and not the CASS spray head assembly requested in

supplemental RAI 3.1.3-3. Therefore, the applicant was requested to provide the information

requested by supplemental RAI 3.1.3-3. This was identified as Confirmatory Item 3.1.3-3.

In a supplemental response to RAI 3.1.3-3, dated June 2, 2005, the applicant agreed that the

guidance contained in the staffs letter to NEI, dated May 19, 2000, should be used when

analyzing the pressurizer spray head through the extended period of operation. The applicant

therefore initiated an evaluation of the Millstone, Unit 3 pressurizer spray head to determine the

crack growth over the period of extended operation in accordance with NUREG-1801, Section

XI.M12 "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)," Item 6

(Acceptance Criteria) and the flaw evaluation section of the staff's letter to NEI, dated

May 19, 2000. As stated in NUREG-1801, Section XL.M12, the flaw tolerance evaluation for

CASS components with ferrite values up to 25 percent is performed according to the

methodology associated with the ASME Code Subsection IWB-3640 procedure for submerged

arc welds. The applicant, however, could not positively confirm that the ferrite content of the

Millstone, Unit 3 pressurizer spray head was less than 25 percent based on the currently

available data. Since the ferrite content could not be confirmed to be less than the 25 percent

used in the ASME Code methodology, the applicant could not utilize the flaw tolerance

evaluation to resolve this issue and decided to manage thermal aging embrittlement of the

Millstone, Unit 3 pressurizer spray head by enhanced volumetric inspections performed under

the aging management program, UInservice Inspection Program: Systems, Components and

Supports," in accordance with 10 CFR 54.21 (a)(1)(iii). The applicant also stated that this

program is consistent with NUREG-1801, Section XI.M12, which considers an enhanced

volumetric inspection (ultrasonic examination) that meets the criteria of the ASME Code,

Section Xl, Appendix VIII, 'Performance Demonstrations for Ultrasonic Examination Systems,"

acceptable. This commitment is contained in the Millstone, Unit 3 LRA, Appendix A, Section

A6.0, Table A6.0-1 "License Renewal Commitments," Item 28, and states that either an

enhanced volumetric examination or a component specific flaw tolerance evaluation

(considering reduced fracture toughness and unit specific geometry and stress information) will

be used to demonstrate that the thermally-embrittled material has adequate fracture toughness

in accordance with NUREG-1801, Section Xl.M12. The staff finds the applicant's management

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of thermal aging embrittlement through inspection in accordance with 10 CFR 54.21 (c)(1)(iii)

acceptable. The staff also finds that if the applicant can confirm the ferrite content in the future,

a flaw tolerance evaluation in accordance with the guidelines of NUREG-1 801, Section XL.M12

is an acceptable alternative to the volumetric examination in accordance with NUREG-1801.

This evaluation would have to be submitted to the NRC for approval at least two years prior to

the period of extended operation. This resolves Confirmatory Item 3.1.3-3.

The staff reviewed the chemistry control for primary systems program and the inservice

inspection program: systems, components and supports program for these aging effects and its

evaluations are in Section 3.0.3.2.2 and Section 3.0.3.2.13 of this SER, respectively.

The nickel-based alloy aging management activity is part of AMP B2.1.18, ulnservice Inspection

Program: Systems, Components and Supports," and the staffs evaluation of the nickel-based

alloys (i.e., PWSCC in Alloy 600 base metal and Alloy 82/182 weld metals) aging management

is documented in Section 3.0.3.2.13 of this SER.

On the basis of its review, the staff finds that the applicant has adequately evaluated the

management of crack initiation and growth due to stress corrosion cracking or primary water

stress corrosion cracking for components in the reactor systems, as recommended in NUREG1801. On the basis of this finding, and the finding that the remainder of the applicant's program

is consistent with NUREG-1 801, the staff concludes that the applicant has demonstrated that

the effects of aging will be adequately managed so that there is reasonable assurance that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.1 B.2.2.8 Crack Initiation and Growth Due to Stress Corrosion Cracking or

Irradiation-Assisted Stress Corrosion Cracking

Crack initiation and growth due to SCC or IASCC could occur in baffle/former bolts in

Westinghouse reactors. A combination of the water chemistry control program and the reactor

vessel internals program will be used to manage this aging effect. In addition, Millstone Unit 3

will participate in Westinghouse Owners Group (WOG) activities and monitor industry initiatives

for the purpose of evaluating the significance of cracking due to IASCC on selected PWR

reactor vessel internals components. As new information and technology becomes available,

the plant-specific reactor vessel internals program (described in Appendix B) will be modified to

incorporate enhanced surveillance techniques.

The applicant has identified the implementation of the industry initiatives as commitment 13 in

Appendix A, Table A6.0-1 of the LRA. Further evaluation of this program and the commitment

to updating this program is addressed in Sections 3.0.3.2.12 (AMP B2.1.17) of this SER.

On the basis of its review, the staff finds that the applicant has adequately evaluated the

management of crack initiation and growth due to stress corrosion cracking or irradiationassisted stress corrosion cracking for components in the reactor systems, as recommended in

NUREG-1 801. On the basis of this finding, and the finding that the remainder of the applicant's

program is consistent with NUREG-1 801, the staff concludes that the applicant has

demonstrated that the effects of aging will be -adequately managed so that there is reasonable

assurance that the intended functions will be maintained consistent with the CLB for the period

of extended operation, as required by 10 CFR 54.21 (a)(3).

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3.1B.2.2.9 Loss of Preload Due to Stress Relaxation

Loss of preload due to stress relaxation could occur in baffle/former bolts in Westinghouse

reactors. Loss of preload due to stress relaxation will be managed by the reactor vessel

internals program. In addition, Millstone Unit 3 will continue to participate in industry

investigations of aging effects applicable to reactor vessel internals as well as initiatives to.

develop advanced inspection techniques which will permit resolution and measurement of very

small features of interest. Aging management activities or surveillance techniques resulting

from these initiatives will be incorporated, as required, as enhancements to the reactor vessel

internals program. The applicant has identified the implementation of the industry initiatives as

commitment 13 in Appendix A, Table A6.0-1 of the LRA. Further evaluation of this program and

the commitment to updating this program is addressed in Section 3.0.3.2.12 (AMP B2.1.17) of

this SER.

On the basis of its review, the staff finds that the applicant has adequately evaluated the

management of the loss of preload due to stress relaxation for components in the reactor

systems, as recommended in NUREG-1801. On the basis of this finding, and the finding that

the remainder of the applicant's program is consistent with NUREG-1 801, the staff concludes

that the applicant has demonstrated that the effects of aging will be adequately managed so

that there is reasonable assurance that the intended functions will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.1B.2.2.10 Loss of Section Thickness Due to Erosion

In LRA Section 3.1.2.2.10, the applicant stated that the steam generators do not have

feedwater impingement plates and that the discussion in this paragraph of the SRP-LR is not

applicable.

SRP-LR Section 3.1.2.2.10 states that loss of section thickness due to erosion could occur in

steam generator feedwater impingement plates and supports. The GALL Report recommends

further evaluation of a plant-specific AMP to ensure that this aging effect is adequately

managed.

On the basis that feedwater impingement plates are not part of the steam generator design, the

staff finds that this aging effect is not applicable.

3.1 B.2.2.11 Crack Initiation and Growth Due to Primary Water Stress Corrosion Cracking,

Outside Diameter Stress Corrosion Cracking, or Intergranular Attack or Loss of Material Due to

Wastage and Pitting Corrosion or Loss of Section Thickness Due to Fretting and Wear or

Denting Due to Corrosion of Carbon Steel Tube Support Plate

In LRA Section 3.1.2.2.11, the applicant addressed crack initiation and growth due to PWSCC,

SCC, or IGA, or loss of material due to wastage and pitting corrosion, or deformation due to

corrosion that could occur in nickel-based alloy components of the steam generator tubes and

tube plugs.

SRP-LR Section 3.1.2.2.11 states that crack initiation and growth due to PWSCC, outside

diameter SCC, or IGA, or loss of material due to wastage and pitting corrosion, or deformation

due to corrosion could occur in Alloy 600 components of the steam generator tubes, repair

sleeves, and plugs. All PWR licensees have committed voluntarily to a steam generator

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degradation management program described in NEI 97-06; these guidelines are currently under

NRC staff review. The GALL Report recommends that an AMP based on the recommendations

of staff-approved NEI 97-06 guidelines, or other regulatory bases for steam generator

degradation management, should be developed to ensure that this aging effect is adequately

managed.

The SRP-LR also states that crack initiation and growth due to PWSCC, SCC, or IGA, or loss

of material due to wastage and pitting corrosionor'deformation due to corrosion could occur in

nickel-based alloy components of the steam generator tubes and plugs.

To manage the effects of aging, the applicant credited AMP B2.1.23, Steam Generator

Structural Integrity," supplemented by AMP B2.1;5, Chemistry Control for Primary Systems

Program," and AMP B2.1.6, 'Chemistry Control for Secondary Systems Program." The staff's

evaluation of the steam generator structural integrity program is documented in

Section 3.0.3.2.16 of this SER. The. staff reviewed the chemistry control for primary systems

and secondary systems programs, and its evaluations are documented in Sections 3.0.3.2.2

and 3.0.3.2.3 of this report, respectively. For general and pitting corrosion, assessment of tube

integrity, and plugging or repair criteria of flawed tubes, the steam generator structural integrity

program acceptance criteria are in accordance with NEI 97-06 guidelines.

On the basis of its review of the chemistry control for primary and secondary systems

programs, the staff finds that the applicant appropriately evaluated AMR results involving

plant-specific programs to address these aging mechanisms, as recommended in the GALL

Report.

3.1B.2.2.12 Loss of Section Thickness Due to Flow-Accelerated Corrosion

In LRA Section 3.1.2.2.12, the applicant stated that the steam generator tube support lattice

bars are constructed of stainless steel. Therefore, loss of section thickness of these bars is not

an applicable aging effect.

SRP-LR Section 3.1.2.2.12 states the loss of section thickness due to FAC could occur in tube

support lattice bars made of carbon steel. The GALL Report recommends that a plant-specific

AMP be evaluated and, on the basis of the guidelines of NRC GL 97-06, an inspection program

for steam generator internals be developed to ensure that this aging effect is adequately

managed.

On the basis that carbon steel tube support lattice bars are not part of the steam generator

design, the staff finds that this aging effect is not applicable.

3.1B.2.2.13 Ligament Cracking Due to Corrosion

In LRA Section 3.1.2.2.13, the applicant stated that the tube support plates are not used in the

steam generators. Therefore, ligament cracking due to corrosion is not an applicable aging

effect.

SRP-LR Section 3.1.2.2.13 states that ligament cracking due to corrosion could occur in carbon

steel components in the steam generator tube support plate. All PWR licensees have

committed voluntarily to a steam generator degradation management program described in

NEI 97-06; these guidelines are currently under NRC staff review. The GALL Report

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recommends that an AMP based on the recommendations of staff-approved NEI 97-06

guidelines, or other regulatory bases for steam generator degradation management, be

developed to ensure that this aging effect is adequately managed.

On the basis that tube support plates are not used in the steam generators, the staff finds that

this aging effect is not applicable.

3.1 B.2.2.14 Loss of Material Due to Flow-Accelerated Corrosion

In LRA Section 3.1.2.2.14, the applicant addressed loss of material due to FAC.

SRP-LR Section 3.1.2.2.14 states that loss of material due to FAC could occur in the feedwater

inlet ring and supports. As noted in Combustion Engineering (CE) IN 90-04, NRC IN 91-19 and

LER 50-362/90-05-01, this form of degradation has been detected only in certain CE System 80

SGs. The GALL Report recommends further evaluation to ensure that this aging effect is

adequately managed. The GALL Report recommends that a plant-specific AMP be evaluated

because existing programs may not be capable of mitigating or detecting loss of material due to

FAC.

The staff noted that, in LRA Table 3.1.2-4 (page 3-95), for loss of material of feedwater inlet

ring and support component type of carbon steel exposed internally to a treated water

environment, the applicant credited the chemistry control for secondary systems program.

During the audit, the staff asked the applicant to clarify why the FAC program is not assigned to

this component.

In its LRA supplement letter dated July 7, 2004, the applicant stated that the FAC program

should be added for the feedwater inlet ring and support component type. In addition, the GALL

Report item match for this entry should be WIV.D1.3-a" with uNote B." Also, the "Table I Item"

entry should be "3.1.1-21." Furthermore, the applicant stated that in LRA Section 3.1.2.2.14

(page 3-21) and LRA Table 3.1.1, the discussion column for Item 3.1.1-21 (page 3-31) should

state:

Although the Unit 3 steam generators are not CE System 80 steam generators,

the feedwater inlet ring is included in the Flow Accelerated Corrosion program.

During the audit, the staff further requested that the applicant clarify how the FAC inspection of

the steam generator feedwater ring would be performed. The applicant responded that the FAC

inspection of the feedwater inlet is performed using the program generic FAC inspection

techniques for gridding and UT.

On the basis of its review, the staff finds that the applicant has demonstrated that the effect of

aging will be adequately managed so that the intended function will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.1A.2.2.15 Quality Assurance for Aging Management of Non-Safety-Related Components

Section 3.0.4 of this SER provides the staffs evaluation of the applicant's quality assurance

program.

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Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determined that (1) those attributes or features

for which the applicant claimed consistency with the GALL Report were indeed consistent, and

(2) the applicant adequately addressed the issues that were further evaluated. The staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so

that the intended functions will be maintained consistent with the CLB for the period of extended'

operation, as required by 10 CFR 54.21 (a)(3). -

3.lB.2.3 AMR Results ThatAre Not Consistent With or NotAddressed in the GALL- '

Report

Summary of Technical Information in the ADDlication. In Tables 3.1.2-1 through 3.1.2-4 of the'

LRA, the staff reviewed additional details of the results of the AMRs for material, environment,

aging effect requiring management, and AMP combinations that are not consistent with the

GALL Report or are not addressed in the GALL Report.

In LRA Tables 3.1.2-1 through 3.1.2-4, the applicant indicated, via Notes F through J, that -

neither the identified component nor the material and environment combination is evaluated in

the GALL Report and provided information concerning how the aging effect will be managed.

Staff Evaluation. For component type, material, and environment combination that are not

evaluated in the GALL-Report, the staff reviewed the applicant's evaluation to determine

whether the applicant had demonstrated that the effects of aging will be adequately managed

so that the intended function will be maintained consistent with the CLB during the period of

extended operation..

The staffs evaluation is discussed below.

3.1 B.2.3.1 Reactor Vessel - Aging Management Evaluation - Table 3.1.2-1

In Section 3.1.2.1.1 of the LRA, the applicant identified the materials, environments, and aging

effects requiring management. The applicant identified the following programs that manage the

aging effects requiring management for the reactor vessel and associated pressure boundary

components:

* boric acid corrosion

* chemistry control for primary systems program

* inservice inspection program: reactor vessel internals

* inservice inspection program: systems, components and supports

* - reactor vessel surveillance :'

In Table 3.1.2-1 of the LRA, the applicant provided a summary of AMRs for the reactor vessel

and associated pressure boundary components and identified which AMRs it considered to'be

consistent with the GALL Report. - .

The staff reviewed Table 3.1.2-1 of the LRA, which summarizes the results of AMR evaluations

for the reactor vessel component groups. The staff has reviewed the information in this table

and agrees that the applicant has identified the applicable aging effects because the aging

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effects are appropriate for these materials and environment and are consistent with industry

operating experience, except for the following components, which are discussed below.

NUREG-1801, Section IVA2.8-b states that the pressure vessel skirt support, cantilever/column

support, and neutron shield tank-are subject to loss of material due to boric acid corrosion. The

applicant was requested in RAI. 3.1.1-1 to include this aging effect and the necessary AMPs for

these components concerning loss of material due to boric acid corrosion in Table 3.1.2-1 of

the LRA or provide justification for concluding that boric acid corrosion is not an aging effect.

In response to RAI 3.1.1-1, in a letter dated December 3, 2004, the applicant stated that the -

structural supports for major reactor coolant system components are evaluated separately from

the component and its integral parts, as NSSS equipment supports. There are no skirt support

or cantilever/column support components for the Millstone Unit 3 reactor vessel support system.

The Millstone Unit 3 reactor pressure vessel supports are included as structural members in

LRA Table 3.5.2-35. Therefore; loss of material due to boric acid corrosion is identified for these

structural members consistent with NUREG-1801 item lI.B1.1.1.1-b, and is managed with the

boric acid corrosion and general condition monitoring aging management programs.

This resolves RAI 3.1.1-1.

Table 3.1.2-1 of the LRA does not specify loss of materialwear for the closure head stud

assembly as identified by NUREG-1801, Section IVA.2.1-d. The applicant was requested in RAI

3.1.1-2 to include this aging effect and the corresponding aging management program (AMP

Xi.M3 of NUREG-1801 "Reactor Head Closure Studs") in Table 3.1.2-1 of the LRA or provide

justification for concluding that loss of material/wear is not an aging effect.

In response to RAI 3.1.1-2, in a letter dated December 3, 2004, the applicant stated that the

closure head stud assembly does not experience relative motion other than normal stud

removal and installation during refueling activities. These activities are closely monitored by

procedures and any degradation is dispositioned by supplemental examination, corrective

measures or repairs, analytical evaluation of the component function, or replacement of the

component to ensure continued structural integrity and function of the component. There is no

significant continuing wear to the reactor vessel closure studs that would lead to a loss of

component function and require monitoring by an aging management program. Therefore, the

applicant did not consider loss of material due to wear as an applicable aging effect for the

closure head stud assembly. However, AMP XL.M3 of NUREG-1801 and RG 1.65 indicates that

reactor closure studs are susceptible to loss of material due to wear. In addition, RG 1.65

recommends, and the applicant uses, coatings and lubrication which are used to reduce wear.

Therefore, the staff requested that the LRA specify loss of material due to wear as an aging

effect for the closure head stud assembly and specify the AMP to be applied.

In its response dated February 8, 2005 to supplemental RAI 3.1.1-2, the applicant stated that

although wear of the reactor closure studs is not expected to affect the intended function of the

bolting, loss of material due to wear will be considered as an aging effect-consistent with

NUREG-1801, item IV.A2.1-d. The aging effect will be managed by the inservice inspectionprogram: systems, components and supports AMP. The staff finds this response acceptable

since it has identified the applicable aging effect and provides an aging management program

which requires inspection of the closure studs in accordance with the ASME Code requirements

that are capable of detecting loss of material..This. resolves RAI, 3.1.1-2.

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Table 3.1.2-1 of the LRA does not specify loss of fracture toughness/neutron irradiation

embrittlement for the upper shell as identified by NUREG-1 801, Section IVA.2.5-c. The

applicant was requested in RAI 3.1.1-3 to include this aging effect and the corresponding aging

management program (AMP XL.M31 of NUREG-1801 "Reactor Vessel Surveillance") in Table

3.1.2-1 of the LRA or provide justification for concluding that fracture toughness/neutron

irradiation embrittlement is not an aging effect.

In response to RAI 3.1.1-3, in a letter dated December 3, 2004, the applicant stated loss of

fracture toughness due to neutron irradiation embrittlement is an applicable aging effect for

those reactor pressure vessel subcomponents exposed to a neutron fluence greater than

1xO107 n/cm2 (E>1 MeV). This threshold level of fluence is experienced by the beltline region

subcomponents identified in LRA Table 3.1.2-1 as susceptible to loss of fracture toughness.

Based on a supplemental evaluation performed by the applicant, the upper shell and primary

inlet nozzles and their associated welds are subjected to loss of fracture toughness due to

neutron irradiation embrittlement and will be managed with the reactor vessel surveillance AMP.

However, the staff notes that the applicant did not provide the USE and PTS evaluations for

these reactor pressure vessel subcomponents as required by Appendix G to10 CFR Part 50,

and 10 CFR 50.61, respectively. Therefore to confirm that the USE and PTS evaluations for

these subcomponents meet regulatory requirements at the end of the period of extended

operation, the staff requests the applicant to include the USE and PTS evaluation (similar to the

data currently in Tables 1 and 2 of the FSAR for the other reactor vessel subcomponents) for

the upper shell and primary nozzles and their associated welds into Tables 1 and 2 of the

Millstone Unit 3 FSAR supplement and determine the effect on the limiting materials.

This is issue is discussed in Section 3.1A.2.3.1..

Table 3.1.2-1 of the LRA did not specify loss of material/wear for the vessel flange and core

support ledge as identified by NUREG-1 801, Section IVA.2.5-f. Therefore, the applicant was

requested in RAI 3.1.3-1 to include the aging effect and the corresponding aging management

program recommended by NUREG-1801 (AMP XI.M1, "Inservice inspection") in the LRA or

provide justification for concluding that loss of material/wear is not an aging effect.

In its response to RAI 3.1.2-1, dated December 3, 2004, the applicant stated that loss of

material due to wear was not considered an applicable aging effect for the reactor vessel flange

and core support ledge since they do not experience relative motion other than normal reactor

disassembly and reassembly during refueling activities. These activities are closely monitored

by procedure and any degradation is dispositioned by supplemental examination, corrective

measures or repairs, analytical evaluation of the component function, or replacement of the

component to ensure continued structural integrity and function of the component. There is no

significant continuing wear to the reactor vessel flange and core support ledge that would lead

to a loss of component function that would require monitoring by an aging management

program. However, the staff considers wear to be an aging effect as' identified by NUREG1801, Section IVA.2.5-f, because the reactor vessel flange and support ledge do experience

relative motion during reactor disassembly and reassembly during refueling activities. This

aging effect should then be monitored. Since,the applicant stated this refueling activity is

monitored by procedures, some type of inspection must be performed to monitor wear of these

components. Therefore, the staff requested that the LRA specify loss of material due to wear as

an aging effect for the reactor vessel flange and core support ledge. In addition the applicant

was requested, in RAI 3.1.2-1 to discuss the inspections performed by the refueling activity.

procedures that monitors wear for these components or include the corresponding aging

management program recommended by NUREG-1 801 (AMP XI.M1, "Inservice Inspection").

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In its response dated February 8, 2005, to supplemental RAI 3.1.2-1, the applicant stated that

although wear of the reactor vessel flange and core support ledge is not expected to affect the

intended function of these components, loss of material due to wear will be considered as an

aging effect consistent with NUREG-1 801, Item IV.A2.5-f. The aging effect will be managed by

the Millstone inservice inspection program: reactor vessels internals AMP. The staff finds this

response acceptable since it has identified the applicable aging effect along with an appropriate

aging management program that is consistent with NUREG-1801 for these components. This

resolves RAI 3.1.2-1.

NUREG-1 801, Section IVB2.6-b specifies void swelling as an aging effect for the BMI guide

tubes. Therefore, the applicant was requested in RAI 3.1.1-4 to modify Table 3.1.2-1 of the LRA

to specify void swelling as an aging effect for the BMI guide tubes and provide a plant-specific

aging management program as recommended by NUREG-1 801 or provide justification for

concluding that void swelling is not an aging effect.

In response to RAI 3.1.14 in a letter dated December 3, 2004, the applicant stated that the flux

thimble guide tubes referred to in NUREG-1801 are a part of the reactor vessel internals

instrumentation support structure. This subcomponent is included in the Millstone Unit 3 LRA

Table 3.1.2-2 as "BMI Columns." Void swelling has been identified for the BMI columns in

accordance with NUREG-1801, Section IVB2.6-b, and is managed by the inservice inspection

program: reactor vessel internals. The BMI guide tubes listed in Millstone Unit 3 LRA, Table

3.1.2-1, are external to the reactor vessel and are not subject to void swelling. The staff accepts

this response, since the applicant has differentiated the BMI guide tube to be the external

component, and the BMI columns as the internal component. Since the BMI columns are

internal to the reactor vessel, void swelling is applicable and is identified in the LRA. Also, since

the BMI guide tube is external to the reactor vessel, void swelling is not an applicable aging

effect. Therefore, the applicant has specified the applicable aging effects and their

corresponding AMPs for the BMI guide tubes and flux thimble tubes. This resolves RAI 3.1.14.

In Table 3.1.2-1, the applicant identified cracking as an aging effect requiring management for

the CRDM pressure boundary components and the vessel head penetration components

manufactured from stainless steel and nickel-based alloys that are exposed to treated water.

The aging effect is managed by the inservice inspection program: systems, components and

supports, and the chemistry control for primary systems program. The aging effect, material,

and environment is consistent with NUREG 1801, Item IV.A2.2-a and Item IV.A2.2-b and no

further evaluation is required. The staff notes that the inservice inspection program: systems,

components and supports includes nickel-alloy nozzles and penetrations program. This

program is used to manage PWSCC of nickel alloys. The staff concludes the inservice

inspection program: systems, components and supports (which includes the nickel-alloy

nozzles and penetrations program) and the chemistry control for primary systems program will

be effective in managing cracking for the CRDM pressure boundary components and the vessel

head penetrations.

Based on the above information, the staff finds the applicant's management of cracking to be

acceptable.

In Table 3.1.2-1, the applicant also identified loss of material as an aging effect requiring

management for the CRDM pressure boundary components and the vessel head penetration

components manufactured from stainless steel and nickel-based alloys that are exposed to

treated water. The applicant stated the aging effect is managed by the chemistry control for

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primary systems program. The aging effect, material, and the environment is not addressed in

NUREG 1801 for Item IV.A2.2-a and Item IV.A2.2-b. In RAI 3.1-B-1, the staff requested that the

applicant provide justification on why the chemistry control for primary systems program alone

is sufficient to manage loss of material without the need to credit an inspection-based AMP to

verify that the chemistry control program is accomplishing its mitigative aging management

function.

In response to RAI 3.1-B-1, in a letter dated December 3, 2004, the applicant stated that the

stainless steel and nickel-based alloy materials exposed internally to primary treated water are

not expected to be subject to significant loss of material as a result of corrosion. In addition,

NUREG-1 801 does not identify loss of material due to corrosion as an aging effect requiring

management for these materials in the RCS. However, loss of material was conservatively

considered in the Millstone LRA for the RCS components in the primary water environment. The

chemistry control for primary systems program provides reasonable assurance that loss of

material resulting from corrosion will not prevent these components from performing their

intended functions.

Verification of the effectiveness of the chemistry control for primary systems program is.

provided by the work control process as described in LRA Appendix B, Section B2.1.5. The

work control process provides the opportunity to visually inspect the internal surfaces of

components during preventive and corrective maintenance activities on an ongoing basis. The

work control process provides input to the corrective action program if aging effects are

identified. The corrective actions program evaluates the cause and extent of the condition and,

if required, recommends enhancements to ensure continued effectiveness of the chemistry

control for primary systems program. This resolves RAI 3.1-B-1.

In LRA Table 3.1.2-1, the applicant identified no aging effects for the following stainless steel,

and nickel-based alloy reactor vessel component types exposed externally to air: CRDM

pressure housings, instrument tubes extension (top head), instrumentation tubes (bottom

head), primary nozzle safe-end, seal table and fitting, and instrument tubes. Air is not identified

in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. These components are exposed to high temperature internal flow, which causes a

dry air environment. Stainless steel and nickel-based alloy are not susceptible to general

corrosion that would affect the intended function of components in an air environment.

Therefore, the staff finds that there are no applicable aging effects requiring management for

metal in an air environment.

In LRA Table 3.1.2-1, the applicant proposed to manage loss of material for the following

stainless steel, nickel-based alloy, and low-alloy steel clad with stainless steel component types

of the reactor vessel - core support pads, bottom-mounted instrumentation (BMI) flux thimble

tube, CRDM pressure housings, instrument tubes extension (top head), instrumentation tubes

(bottom head), primary nozzles (and cladding), primary nozzle safe-end, seal table and fitting,

instrument tubes, bottom head (and cladding); closure head dome (and cladding), closure head

flange (and cladding), intermediate and lower shell (and cladding), and vessel flange and core

support ledge (and cladding) - exposed internally to treated, borated water using the AMP

B2.1.5, Chemistry Control for Primary.Systems Program." The staff reviewed the chemistry

control for primary systems program and its evaluation is documented in Section 3.0.3.2.2 of

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this SER. On the basis of its review, the staff finds this program acceptable for managing loss

of material for the above component types.

In LRA Table 3.1.2-1, for each of these same component and material combinations, the

applicant is also managing cracking using AMP B2.1.5, "Chemistry Control for Primary Systems

Program," and AMP B2.1.18, uInservice Inspection Program: Systems, Component and

Supports." AMP B2.1.18 is also credited with managing the effects of PWSCC in Alloy 600

base metal and Alloy 82/182 weld metals. The staff accepted the chemistry control for primary

systems program and the inservice inspection program: systems, components and supports

program and its evaluation of these programs is documented in Sections 3.0.3.2.2 and

3.0.3.2.13 of this SER, respectively. The staffs evaluation of the Alloy 600 base metal and Alloy

821182 weld metals portion of the MPS AMP is discussed in Section 3.0.3.2.13 of this SER. The

staff finds that the applicant manages cracking in a manner consistent with the GALL Report.

On the basis that cracking of stainless steel, nickel-based alloy, and low-alloy steel clad with

stainless steel is being managed by the water chemistry control and inservice inspection

programs, and the effects of pitting and crevice corrosion on stainless steel and nickel-based

alloy components are not significant in chemically treated, borated water, the staff finds that the

water chemistry control program is acceptable for managing loss of material.

The staff finds that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB during the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.1 B.2.3.2 Reactor Vessel Intemals - Aging Management Evaluation - Table 3.1.2-2

In Section 3.1.2.1.2 of the LRA, the applicant identified the materials, environments, and aging

effects requiring management. The applicant identified the following programs that manage the

aging effects requiring management for the reactor vessel internals and associated pressure

boundary components:

* chemistry control for primary systems program

* inservice inspection program: reactor vessel intemals

In Table 3.1.2-2 of the LRA, the applicant provided a summary of AMRs for the reactor vessel

internals and associated pressure boundary components and identified which AMRs it

considered to be consistent with the GALL Report.

The staff reviewed LRA Table 3.1.2-2, which summarizes the results of AMR evaluations for the

reactor vessel intermals component groups.

LRA Section 3.1.2.2.7.1 states that the reactor vessel flange leak detection line is not within the

scope of license renewal because it does not meet the criteria of 10 CFR 54.4(a) as an

intended function. However, NUREG-1 801, Section IV A.2.1-f specifies this component is in

scope and is subject to a crack initiation and growth/stress corrosion cracking aging

mechanism. Therefore, the applicant was requested in RAI 3.1.2-6 to provide a plant-specific.

aging management program as recommended by NUREG-1801 for cracking of this component.

In response to RAI 3.1.2-6, in a letter dated December 3, 2004, the applicant stated the reactor

vessel leak detection system, including the leak detection line, is not within the scope of license

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renewal. As stated on page 3-18 in the Millstone Unit 3 LRA, the reactor vessel closure head

and shell flanges are sealed by inner and outer.hollow metallic 0-rings. Any leakage through

this seal arrangement is directed to the leakage detection system through a 3/16-inch hole in

the vessel flange.

Leakage flow past the inner reactor vessel flange O-ring is limited in the event of seal failure by

the 3/16-inch diameter hole in the reactor vessel flange which is smaller than the inside

diameter of the leak detection line. Additionally, the potential flowrate through the 3/16-inch

diameter hole in the flange is within the normal make-up capability of the chemical and volume

control system such that the leak detection system doses not constitute the RCS pressure

boundary. The failure of the leak detection system components has been evaluated and cannot

affect the function of safety-related systems, structures or components. As such, the reactor

vessel flange seal leak detection system, including the leak detection line does not meet the

criteria of 10 CFR 54.4(a) and is not within the scope of license renewal. Therefore, the

applicant stated that the system is not subject to aging management review and there is no

aging management program applicable to the leak detection line. The staff review to determine

if this is acceptable is not yet complete. This is Open Item 3.1.2-6.

In LRA Table 3.1.2-2, the applicant proposed to manage loss of material for the following

stainless steel component types of the reactor vessel internals system - baffle/former plates,

BMI columns, core barrel, core barrel flange, core barrel outlet nozzles, head and vessel

alignment pins, hold-down spring, lower fuel alignment pins, lower support forging, lower

support plate column bolts, lower support plate columns, neutron panel, radial support keys, rod

cluster control assembly (RCCA) guide tube support pins, RCCA guide tubes, secondary core

support, upper core plate, upper core plate alignment pins, upper fuel alignment pins, upper

instrumentation columns, upper support column, and upper support plate - exposed internally to

treated, borated water using MPS AMP B2.1.5, "Chemistry Control for Primary Systems

Program." The staff accepted the chemistry control for primary systems program and its

evaluation of this program is documented in Section 3.0.3.2.2 of this SER.

In LRA Table 3.1.2-2, for each of these same component and material combinations, the

applicant is also managing cracking using AMP B2.1.5, "Chemistry Control for Primary Systems

Program," and AMP B2.1.17, 'Inservice Inspection Program: Reactor Vessel Intemals." AMP

B2.1.17 credits the ASME Section Xi, Subsection IWB, Category B-N-3 inservice inspections

and additional examinations based on future industry developments. The staff reviewed the

embrittlement effects of CASS portion of the inservice inspection program: reactor vessel

internals program and its evaluation of this part of the program is documented in Section

3.0.3.2.12 of this SER. The staff's evaluation of the PWR internals aging effects management

regarding such issues as void swelling (change in dimensions), stress corrosion cracking

(PWSCC and IGSCC), and loss of preload is documented in Section 3.0.3.2.12 of the SER.

The staff finds that the applicant manages cracking in a manner consistent with the GALL

Report. In addition, the staff reviewed the applicable part of MPS AMP B2.1.18, 'Inservice

Inspection Program: Systems, Components and Supports," which discusses the ASME Section

Xl, Subsection IWB, Category B-N-3 inservice inspection activities. The staff accepted this

program and its evaluation is documented in Section 3.0.3.2.13 of this SER.

On the basis that cracking of stainless steel is being managed by the water chemistry control

and inservice inspection programs, and the effects of pitting and crevice corrosion on stainless

steel components are not significant in chemically treated, borated water, the staff finds that

management of loss of material using water chemistry control is acceptable.

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The GALL Report recommends a loose parts monitoring program to manage loss of

mechanical closure integrity for the following reactor vessel internals component types - CEA

shroud extension shaft guides, cylinders, and bases; shroud base; shroud flow channel; shroud

flow channel cap; shroud shaft retention pin; shroud retention block; spanner nuts; shroud

fasteners; guide tubes; ICI thimble support plate assembly; ICI support plate, grid, lifting

support, lifting plate, column, plates, and funnel; pad, ring, nipple, hex bolt, and spacer;

threaded rod, hex jam nut, thimble support nut, and cap screws.

In the LRA, the applicant proposed to manage this aging effect using MPS AMP B2.1.17,

"Inservice Inspection Program: Reactor Vessel Internals." The staff reviewed and accepted this

program and its evaluation is documented in Section 3.0.3.2.12 of this SER.

On the basis that the reactor vessel internals programs detect aging effects prior to the loss of

mechanical integrity of these components, the staff finds that its use in lieu of a loose parts

monitoring program is acceptable.

The staff finds that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB during the

period of extended operation, as required by 10 CFR 54.21(a)(3).

3.1.B2.3.3 Reactor Coolant - Aging Management Evaluation - Table 3.1.2-3

In Section 3.1.2.1.3 of the LRA, the applicant identified the materials, environments, and aging

effects requiring management. The applicant identified the following programs that manage the

aging effects requiring management for the reactor coolant system and associated pressure

boundary components:

* boric acid corrosion

* chemistry control for primary systems program

* closed-cycle cooling water system

* general condition monitoring

* inservice inspection program: systems, components and supports

* work control process

In Table 3.1.2-3 of the LRA, the applicant provided a summary of AMRs for the reactor coolant

system and associated pressure boundary components and identified which AMRs it

considered to be consistent with the GALL Report.

The staff reviewed LRA Table 3.1.2-3, which summarizes the results of AMR evaluations for the

RCS component groups.

In Table 3.1.2-3, the applicant also identified loss of material as an aging effect requiring

management for the RCS components manufactured from stainless steel and nickel-based

alloys that are exposed to treated water. The applicant stated the aging effect is managed by

the chemistry control for primary systems program. The aging effect, material, and the

environment is not addressed in NUREG 1801 for the subject material/environment

combination. In RAI 3.1-A-1 the staff requested that the applicant provide justification on why

the chemistry control for primary systems program alone is sufficient to manage loss of material

without the need to credit an inspection-based AMP to verify that the chemistry control program

is accomplishing its mitigative aging management function.

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In response to RAI 3.1-A-3, in a letter dated December 3, 2004, the'bpplicant stated that the

stainless steel and nickel-based alloy materials exposed internally to primary treated water are

not expected to be subject to significant loss of material as a result of corrosion. In addition,

NUREG-1801 does not identify loss of material due to corrosion as an aging effect requiring

management for these materials in the RCS. However, loss of material was conservatively

considered in the Millstone LRA for the RCS components in the primary water environment. The

chemistry control for primary systems program provides reasonable assurance that loss of

material resulting from corrosion will not prevent these components from performing their

intended functions.

Verification of the effectiveness of the chemistry control for primary systems program is

provided by the work control process as described in LRA Appendix B, Section B2.1.5. The

work control process provides the opportunity to visually inspect the internal surfaces of

components during preventive and corrective maintenance activities on an ongoing basis. The

work control process provides input to the corrective action program if aging effects are

identified. The corrective actions program evaluates the cause and extent of the condition and,

if required, recommends enhancements to ensure continued effectiveness of the chemistry

control for primary systems program.

In LRA Table 3.1.2-3, the applicant identified no aging effects for the following stainless steel,

nickel-based alloy, and carbon steel component types of the RCS exposed externally to air flow

elements, flow indicators, flow orifices, piping, tubing,-valve; pressurizer nozzles, safe-ends,

and instruments and heaters (wells and sheathes), manway cover and insert; reactor coolant

pressurizer relief tank, RCP seal coolers, RCP thermal barriers, RCP casing, RCP rupture

disks. Air is not identified in the GALL Report as an environment for these components and

materials.

In the LRA, the applicant stated that the RCS stainless steel components are externally

insulated. The applicant's FSAR concludes (page 5.6) that the use of external thermal

insulation of RCS in conformance with RG 1.36 provides reasonable assurance that the reactor

coolant pressure boundary material will be adequately protected from conditions that would lead

to loss of integrity from stress corrosion. Based on its review of the applicant's FSAR, the staff

agrees with the applicant that the RCS stainless steel components are adequately protected

from conditions that could lead to loss of integrity from stress corrosion.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. These RCS components are exposed to high temperature internal flow, which

creates a high temperature dry air environment, and general corrosion is not likely to occur'-

under such an environment. Additionally, stainless steel and nickel-based alloys in a dry air

environment are not susceptible to general corrosion that would affect the intended function of

components. Therefore, the staff finds that there are no applicable aging effects requiring

management for metal in an air environment.

In LRA Table 3.1.2-3 (page 3-90), the applicant stated that cracking of the CASS RCP thermal

barrier exposed to treated water is to be managed by the chemistry control for primary systems

program and the inservice inspection program: systems, components and supports program.

During the audit, the staff asked the applicant to clarify which part of the inservice inspection

program is being credited with managing the aging effect for the RCP thermal barrier. The

applicant responded as follows:

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It was confirmed with the inservice inspection coordinator that the inservice

inspection program does not perform examinations associated with the thermal

barriers. The work control process program is credited for managing the effects

of aging for the reactor coolant pump thermal barriers. The reactor coolant

pumps are refurbished, designated as spares, and reinstalled during future

outages. Examples of work orders are identified where through the work control

process program the thermal barriers associated with spare RCPs are blown

down of the closed cooling water and a sample of the closed cooling water is

taken. (See automated work orders M3-97-17720 through M3-97-17723.)

The applicant, in an LRA supplement dated July 7, 2004, also stated that:

Note 6 should be added for Unit 3 LRA Table 3.1.2-3 (page 3-90) for the RCS

component group 'RCP Thermal Barriers' and aging effect 'Loss of Fracture

Toughness.' The Note for this item is revised by Item 42-1 of this clarification

letter and is applicable to this component because it is CASS material.

The "Inservice Inspection Program: Systems, Components and Supports" should

be replaced by the "Work Control Process" for Unit 3 Table 3.1.2-3 (page 3-90),

for the RCS component group 'RCP Thermal Barriers' and aging effect

'Cracking.' The Note for this item should be "E" in the Unit 3 LRA. Also, the

'Discussion' column in Unit 3 Table 3.1.1, Item 3.1.1-36 (page 3-34), should

read as follows:

Not consistent with NUREG-1 801. Cracking is managed with the

chemistry control for primary systems program and the inservice

inspection program: systems, components and supports except

for the RCP thermal barriers, which are managed with chemistry,

and the work control process. These programs take some

exceptions to the NUREG-1801 AMPs.

The staff reviewed the work control process program and the applicant's RRN-129 document,

"Reactor Coolant Pump Motor Refurbishment Report for Millstone Unit," and determined that

the applicant has demonstrated that the effects of aging of RCP thermal barriers will be

adequately managed.

The staff reviewed thermal sleeves for the pressurizer surge nozzle and spray nozzle, LRA

Table 3.1.2-3 (page 3-92), and identified that the weld material is of nickel-based alloy 82/182

material and that these locations are not covered by the nickel-based alloy aging management

activities. The applicant stated that it will evaluate this area as part of extent of condition when

responding to NRC Inspections and Enforcement Bulletin 2004-1, "Inspection of Alloy

82/182/600 Materials Used in the Fabrication of Pressurizer Penetrations and Steam Space

Piping Connections at Pressurized-Water Reactors," dated May 28, 2004, as part of the CLB.

This commitment is identified on the applicant's license renewal commitment list in the LRA,

Appendix A, Table A6.0-1, Item 15.

On the basis of its review of the LRA commitment and Bulletin 2004-1, the staff determined that

this issue is part of the CLB to be resolved with the applicant's response to Bulletin 2004-1.

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Table 3.1.2-3 of the LRA specifies the use of AMP B2.1.18, ulnservice Inspection Program:

Systems, Components and Supports," for closure bolting in the reactor coolant pump, valves,

and pressurizer manways. In addition, Section B2.0 of Appendix B of the LRA states that the

aging management review did not identify the need for the AMP. However, NUREG-1 801,

sections IVC2.3-e, IVC2.3-g, IVC2.4-e, IVC2.4-g, IVC2.5-n, and IVC2.5-p, specifies the use of

AMP XI.M18 for these components. AMP XI.M18 of NUREG-1 801 incorporates the

requirements and guidelines of NUREG-1339, EPRI NP-5769, and EPRI TR-104213

concerning material selection, bolting preload control, inservice inspections, plant operation and

maintenance, and evaluation of the structural integrity of bolted joints. Therefore, the applicant

was requested in RAI 3.1.3-1 to provide the AMP as recommended by NUREG-1801, or include

all of the necessary information discussed above in AMP B2.1.18 of the LRA.

In response to RAI 3.1.3-1, in a letter dated December 3, 2004, the applicant stated that it has

developed a specific AMP to manage the aging effects for closure bolting in the reactor coolant

pump, valves and pressurizer manway. This response is acceptable since the applicant will

manage the closure bolting of these components with an AMP, as specified in NUREG-1801.

The AMP is evaluated in Section 3.0.3.2.18 of this SER.

For the CASS spray head assembly identified in Table 3.1.2-3 of the LRA, the applicant

specified the chemistry control AMP to manage cracking. NUREG-1801, Section IVC2.5-j,

identifies a plant-specific AMP to be used to manage cracking. Therefore, the applicant was

requested in RAI 3.1.3-2 to provide this AMP to the NRC for evaluation as recommended by

NUREG-1801, Section IVC2.5j.

In response to RAI 3.1.3-2, in a letter dated December 3, 2004, the applicant stated that

material for the Millstone Unit 3 pressurizer spray-head is CASS. The plant-specific aging

management program for managing the aging effects associated with the pressurizer spray

head is the chemistry control for primary systems program.

The reactor coolant system stainless steel materials, including the pressurizer spray head, are

exposed internally to a high-quality primary water and/or steam environment that is not

expected to result in significant SCC.

Therefore, the applicant stated that the chemistry control for primary systems program AMP

provides reasonable assurance that cracking resulting from SCC will not prevent the spray

head from performing its intended function. In'Section 3.1.2.2.7 of NUREG-1800,- the staff

recommended that a plant-specific aging management program be proposed to manage crack

initiation and unacceptable crack growth in pressurizer spray heads because existing programs

may not be capable of mitigating or detecting crack initiation and growth due'to SCC. This

inspection should be capable of detecting and resolving cracks in the pressurizer spray heads.

Therefore, the staff agreed that the water chemistry can be used to mitigate SCC, but an

inspection was necessary to indicate whether the water chemistry has prevented SCC and to

characterize any cracking in the CASS pressurizer spray heads.

In its response to supplemental RAI 3.1.3-2B, dated February 8, 2005, the applicant committed

to either replace the Millstone Unit 3 pressurizer spray head assembly or inspect it utilizing the

best available inspection techniques (at the time of inspection) for detecting SCC, prior to

entering the period of extended operation. This commitment has been identified in the Millstone

LRA, Appendix A, Table A6.0-1 as Item 37 in the License Renewal Commitments Table. The

staff finds this response acceptable because the applicant will either verify that its water

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I:

chemistry program is effective in preventing SCC by performing an inspection of the assembly,

or replace the CASS pressurizer spray head assembly prior to entering the period of extended

of operation. This resolves RAI 3.1.3-2B.

The staff requested additional information from the applicant in order to determine which

components are susceptible to PWSCC and the appropriate AMP as recommended by

NUREG-1 801, Section IVC.2.5-k. Therefore, the applicant was requested in RAI 3.1.3-3 to

specify which of these components (safe-ends for surge, spray, relief and safety) in Table

3.1.2-3 of the LRA are nickel-based and which are stainless steel. In addition, the applicant was

asked if the surge line nozzle and safe-end cast austenitic steel (CASS). If the component is

CASS, then provide a plant-specific aging management program for cracking as recommended

by NUREG-1 801, Section IVC2.5-1.

In response to RAI 3.1.3-3, in a letter dated December 3, 2004, the applicant stated that the

safe-ends for the Millstone Unit 3 pressurizer surge, spray, relief, and safety nozzles are

fabricated from stainless steel. The transition welds between these stainless steel safe-ends

and the low-alloy steel of the pressurizer nozzles are nickel-based alloy. Neither the surge line

nozzle nor the safe-end is fabricated from CASS. The aging effect of cracking for these

components is managed by the chemistry control for primary systems program and the

inservice inspection program: systems, components, and supports. The Millstone Unit 3 LRA

(Appendix A, Table A6.0-1, commitment 15) states that Millstone Unit 3 will participate in

industry programs to determine appropriate measures to manage PWSCC and submit an

appropriate AMP to the NRC staff for approval prior to entering the extended period of

operation. This resolves RAI 3.1.3-3.

Table 3.1.2-3 of the Millstone Unit 3 LRA does not specify the pressurizer integral support that

is subject to fatigue, cracking/IASCC, and boric acid corrosion. The applicant was requested in

RAI 3.1.34 to include these aging effects and provide the necessary aging management

programs in the LRA for this component as identified by NUREG-1801, item IV.C.2.5.12.

In response to RAI 3.1.3-4, in a letter dated December 3, 2004, the applicant stated that the

integral supports identified in NUREG-1801 are considered to be the same as the component

type uPressurizer (Seismic Lugs)" and "Pressurizer (Support Skirt and Flange)" in the Millstone

Unit 3 LRA, Table 3.1.2-3. The aging effects of loss of material due to boric acid corrosion and

cracking are identified for these components consistent with NUREG-1 801, Item IV.C.2.5.12.

Fatigue is addressed as a TLAA and is identified in LRA Table 3.1.1, item 3.1.1-10.

Because the pressurizer seismic lugs, support skirt and flange are the integral supports, and

are identified in the LRA, along with the applicable AMPs consistent with NUREG-1 801, the

staff finds this response acceptable. This resolves RAI 3.1.34.

The staff finds that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB during the

period of extended operation, as required by 10 CFR 54.21(a)(3).

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3.1 B.2.3.4 Steam Generators - Aging Management Evaluation - Table 3.1.24

In Section 3.1.2.1.4 of the LRA, the applicant identified the materials, environments, and aging

effects requiring management. The applicant identified the following programs that manage the

aging effects requiring management for the steam generator and associated pressure boundary

components:

* boric acid corrosion

* chemistry control for primary systems program

* chemistry control for secondary systems program

* flow-accelerated corrosion

* inservice inspection program: systems, components and supports

* steam generator structural integrity

In Table 3.1.24 of the LRA, the applicant provided a summary of AMRs for the steam

generator and associated pressure boundary components and identified which AMRs it

considered to be consistent with the GALL Report.

Millstone Unit 3 has four Westinghouse Model F steam generators. Each SG contains 5626

thermally treated Alloy Inconel 600 tubes. Each tube has a nominal outside diameter of 0.688

inch and a nominal wall thickness of 0.040 inch. The tubes were hydraulically expanded at both

ends for the full length of the tubesheet and are supported by a number of stainless'steel Type

405 tube support plates with quatrefoil-broached holes and upper support anti-vibration bars.

The staff reviewed the LRA Table 3.1.2-4, which summarizes the results of AMR evaluations for

the steam generator component groups.

In LRA Table 3.1.24, the applicant identified cracking as an aging effect and the inservice -

inspection as the AMP for the primary manway.bolting in the air environment. In RAI 3.1.24-3,

the staff asked the applicant to clarify the aging mechanism for cracking and to explain how the

Inservice Inspection AMP is used to manage this aging effect similar to the recommended AMP

in the GALL.

By letter dated December 3, 2004, the applicant responded that consistent with GALL, the

aging mechanism for the primary manway bolting is stress corrosion cracking, which can result

from flaw initiation and growth. The applicant stated that it will implement a program to manage

the aging effect of stress corrosion cracking as stated in GALL IV.D1.1-l. The staff finds the

applicant's response acceptable because it is consistent with GALL.

In LRA Table 3.1.2-4, the applicant identified the only aging effect as cracking and the inservice

inspection program as the AMP for the secondary manway and handhole bolting in the air

environment. In RAI 3.1.2-4-4, the staff asked the applicant to justify why loss of preload and

stress relaxation are not applicable aging effects as stated in GALL IV.D1.1-f.

By letter dated December 3, 2004, the applicant responded that loss of preload due to stress

relaxation is not an applicable aging effect forthe ASME Class 2 secondary manway and

handhole bolting. The applicant uses SA-1 93, Grade B7 bolting for these applications. The

applicant stated that, according to ASME Section II, Part D, Table 4, stress relaxation may

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occur at temperatures of 700 OF or higher for Grade B7 bolting materials. The applicant's

normal operating RCS hot leg temperature, which bounds the maximum temperature for the SG

secondary side components, is 600.50 F for Unit 2 and 618 OF for Unit 3.

The applicant stated that since these temperatures are below the 700 0F, loss of preload due to

stress relaxation is not an aging effect requiring aging management. The staff reviewed the

operating thresholds and footnotes for stress relaxation in Section II of the ASME Boiler and

Pressure Vessel Code for these bolting materials and confirmed that the applicant's

determination is valid. The staff finds the applicant's response acceptable because the bolts will

not be exposed to temperatures in excess of the threshold for stress relaxation in the bolting

materials.

In LRA Table 3.1.2-4, the applicant identified loss of material as the aging effect for the tube

supports lattice rings. In RAI 3.1.2-4-5, the staff stated that cracking is also a potential aging

effect and therefore asked the applicant to justify why cracking is not considered as an aging

effect for the tube support lattice rings under treated water and steam.

By letter dated December 3, 2004, the applicant responded that only high-strength carbon

steels are susceptible to this stress corrosion cracking in this environment. Since the tube

support lattice rings are made of carbon steel and not high strength carbon steel, they are not

susceptible to stress corrosion cracking under the steam generator secondary-side

environment. The staff finds the applicant's response acceptable because based on operating

experience, carbon steel is not likely to be susceptible to stress corrosion cracking under the

steam generator secondary-side environment.

In LRA Table 3.1.2-4, the applicant identified no aging effects for the following stainless steel

and low-alloy steel component types of the steam generator exposed externally to air:

feedwater nozzle and safe-end, lower head drain nozzle, primary manway cover and

diaphragm, secondary manway and handhole covers, secondary-side nozzles (except main

steam and feedwater), steam nozzle and safe-end, top head, transition cone, and upper and

lower shell. Air is not identified in the GALL Report as an environment for these components

and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that dry air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air which is the

reactor building air environment2 Significant corrosion of low-alloy steel requires an electrolytic

environment, and a simultaneous presence of oxygen and moisture. Without the presence of

the aggressive environment, low-alloy steel components will experience insignificant amounts of

corrosion, and no aging effects are applicable to this component/commodity group. Stainless

steel is not susceptible to significant general corrosion that would affect the intended function of

components. Therefore, the staff finds that there are no applicable aging effects requiring

management for metal in a dry air environment.

In LRA Table 3.1.2-4, the applicant proposed to manage loss of material for the following

stainless steel, carbon steel, low-alloy steel, and nickel-based alloy component types of steam'

generator- anti-vibration bars, divider plate, feedwater inlet ring and support, feedwater nozzle

and safe-end, lower head (and cladding), lower head drain nozzle, primary manway cover and

diaphragm, primary nozzle and safe-end, secondary manway and handhole covers,

secondary-side nozzles (except main steam and feedwater), stay rod (including spacer pipes

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and nuts), steam nozzle and safe-end, steam nozzle flow restrictor, top head, tube plugs, tube

support plates, tube sheet (and cladding), upper and lower shell, and wrapper (includes jacking

blocks, jacking block studs, anti-rotation block, and cone) - exposed to treated water/steam,

borated water using the water chemistry control programs. Additionally, the tube sheet and

steam generator U-tubes are managed by the steam generator structural integrity program. The

staff accepted AMP B2.1.5, "Chemistry Control for Primary Systems Program," and AMP

B2.1.6,"Chemistry Control for Secondary Systems Program," and its evaluation of these AMPs

is documented in Sections 3.0.3.2.2 and 3.0.3.2.3 of this SER, respectively. The steam

generator structural integrity program is reviewed and evaluated in Section 3.0.3.1 of this SER.

On the basis of industry operating experience with this material and use of water chemistry

control programs consistent with the GALL Report, the staff finds this to be acceptable.

In LRA Table 3.1.2-4 (page 3-98), the applicant stated that cracking of the nickel-based alloy

steam generator primary manway cover and diaphragm is managed by MPS AMP B2.1.5,

'Chemistry Control for Primary Systems Program." During the audit and review, the staff asked

the applicant to provide justification for using the chemistry control for primary systems program

to prevent PWSCC. In its response, the applicant stated that:

Based on a review of the Bill of Materials (BOM) database, part number

information, and the vendor technical manual (figure 8-3 sheet 2 of 2, Detail C), it

was determined that Unit 3 has stainless steel diaphragms (inserts) as part of

the steam generator primary manway cover assemblies. The Unit 3 LRA AMR

Table currently identifies the diaphragm as a nickel-based alloy. The AMR Table

needs to be revised to identify stainless steel in lieu of a nickel-based alloy for

the diaphragms, and also clarify that the diaphragm is also referred to as an

insert.

In an LRA supplement dated July 7, 2004, the applicant stated as follows:

The material "Nickel-based Alloy" should be "Stainless Steel" for the 'Primary

Manway Cover and Diaphragm' component group in Unit 3 Table 3.1.2-4 (page

3-98).-

The applicant also stated that the primary manway is not included in the inservice inspection

program; however, the component is inspected each time the manway is opened. On the basis

of its review, the staff finds this to be acceptable.

In LRA Table 3.1.2-4 (page 3-95), the applicant proposed to manage cracking for the

nickel-based alloy divider plate exposed to borated water using water chemistry control

programs. During the audit and review, the staff asked the applicant to provide justification for

using the chemistry control for primary systems program to prevent PWSCC. In its response

during the audit, the applicant stated that:

The steam generator divider plate is located in the steam generator channel

head and functions to direct reactor coolant flow through the steam generator

tubes (flow distribution). The plate is welded to the primary side of the tube sheet

and to the inside of the steam generator channel head. The divider plate material

is ASTM SB-1 68 (Alloy 600) and the weld material is Alloy 82/182. The divider

plate, and associated welds, do not penetrate the steam generator

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III

pressure-retaining boundary; Since the steam generator divider plates, and

associated attachment welds, are not pressure retaining these components are

not included within the scope of the Unit 3 response to the generic issue related

to Alloy 600 degradation (PWSCC). Cracking of the welds cannot result in

leakage of borated water onto carbon steel pressure-retaining material, such that

wastage due to boric acid corrosion will not occur. The intended function

identified for the divider plate is flow distribution. Gross failure of the welds would

be required before divider plate deflection that is sufficient to affect the intended

function could occur. Additionally, there is no known industry operating

experience with failures of steam generator divider plates or welds from

PWSCC.

During the audit, the applicant also stated that this component is inspected under the steam

generator inspection program. The staff reviewed the applicant's program as documented in the

audit and review report and finds that the applicant adequately manages this aging effect.

On the basis of its review, the staff finds that management of cracking in low-alloy steel and

carbon steel exposed to treated water using water chemistry control verified by inservice

inspection is acceptable as recommended by the GALL Report.

The staff also finds that management of cracking in stainless steel exposed to treated water

using the chemistry control for secondary systems program is acceptable as recommended by

the GALL Report.

The staff finds that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB during the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

All other AMRs assigned to the staff in Tables 3.1.2-1 through 3.1.2-4 were evaluated. The staff

finds them to be acceptable.

Conclusion. On the basis of its review, the staff finds that the applicant appropriately evaluated

AMR results involving material, environment, aging effects requiring management, and AMP

combinations that are not evaluated in the GALL Report. The staff finds that the applicant has

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21 (a)(3).

3.1B.3 Conclusion

The staff concluded that the 'applicant provided sufficient information to demonstrate that the

effects of aging for the of the reactor vessel, internals, and reactor coolant system components

and component types that are within the scope of license renewal and subject to an AMR will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable FSAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the reactor vessel,

internals, and reactor coolant system components, as required by' 10 CFR 54.21(d).

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- -

3.2 Aging Management of Engineered Safety Features Systems

3.2A Unit 2 Aging Management of Engineered Safety Features Systems

This section of the SER documents the staffs review of the applicant's AMR results for the

engineered safety features (ESF) systems components and component groups associated with

the following systems:

* containment spray system

* safety injection system

* refueling water storage tank and containment sump system

* shutdown cooling system

* spent fuel pool cooling system

3.2A.1 Summary of Technical Information In the Application

In LRA Section 3.2, the applicant provided AMR results for ESF systems components and

component groups. In LRA Table 3.2.1, 'Summary of Aging Management Evaluations in

Chapter V of NUREG-1 801 for Engineered Safety Features," the applicant provided a summary

comparison of its AMRs with the AMRs evaluated in the GALL Report for the ESF systems

components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

aging effects requiring management (AERMs). These reviews included evaluation of plantspecific and industry operating experience. The plant-specific evaluation included reviews of

condition reports and discussions with appropriate site personnel to identify AERMs. The

applicant's review of industry operating experience included a review of the GALL Report and

operating experience issues identified since the issuance of the GALL Report.

3.2A.2 Staff Evaluation

The staff reviewed LRA Section 3.2 to determine if the applicant provided sufficient information

to demonstrate that the effects of aging for the ESF systems components that are within the

scope of license renewal and subject to an AMR will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

Also, the staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report. However, the staff did confirm that the material

presented in the LRA was applicable and that the applicant had identified the appropriate GALL

AMPs. The staffs evaluations of the AMPs are documented in Section 3.0.3 of this SER. The

staff's audit evaluation are documented in the MPS audit and review report and are summarized

in Section 3.2A.2.1 of this SER.

The staff also performed an onsite audit of those AMRs that were consistent with the GALL

Report and for which further evaluation is recommended. The staff confirmed that the

applicant's further evaluations were consistent with the acceptance criteria in Section 3.2.2.2 of

NUREG-1 800, 'Standard Review Plan for Review of License Renewal Applications for Nuclear

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Power Plants," dated July 2001. The staff's audit evaluation are documented in the MPS audit

and review report and are summarized in and summarized in Section 3.2A.2.2 of this SER.

The staff performed an onsite audit and conducted a technical review of the remaining AMRs

that were not consistent with or not address in the GALL Report. The review included evaluating

whether all plausible aging effects were identified and whetherthe aging effects listed were

appropriate for the combination of materials and environments specified. The staff's audit

evaluation are documented in the MPS audit and review report and are summarized in Section

3.2A.2.3 of this SER. The staff's evaluation of its technical review is also documented in Section

3.2A.2.3 of this SER.

Finally, the staff reviewed the AMP summary descriptions in the FSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the ESF system components.

Table 3.2A-1 provides a summary of the staff's evaluation of components, aging

effects/mechanisms, and AMPs listed in LRA Section 3.2 that are addressed in the GALL

Report.

Table 3.2A-1 Staff Evaluation for Engineered Safety Features System Components In the

GALL Report

Componerit Grouip' Agibng Effet/--A- A P n GA L- * ' ! ' in L Staff lIvluatlon I',' ,-'i , ! ' '.# Mechanism ' - -i Repor i i t ';. 

Piping, fittings, and Cumulative fatigue TLAA, evaluated in TLAA This TLAA is

valves in damage accordance with evaluated in Section

emergency core 10 CFR 54.21(c) 4.3A, Metal Fatigue

cooling system

(Item Number

3.2.1-01)

Components in Loss of material Plant-specific Not applicable (See

containment spray due to general Section 3.2A.2.2.2)

(PWR only), corrosion

standby gas

treatment (BWR

only), containment

isolation, and

emergency core

cooling system

(Item Number

3.2.1-03)

Components In Loss of material Plant-specific Chemistry control Consistent with

containment spray due to pitting and for primary systems GALL, which

(PWR only), crevice corrosion program (B2.1.5); recommends further

standby gas Tank inspection evaluation (See

treatment (BWR program (B2.1.24) Section 3.2A.2.2.3)

only), and

emergency core

cooling systems

(Item Number

3.2.1-05) .

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onet Gioup pComp Aglrg ffect- AP in GALL- A I LR : - taffEvauton

*-: ,-.;. 'Mechan ism ._ ...... _ i or ; - *

Containment Loss of material Plant-specific Chemistry control Consistent with

isolation valves and due to MIC for primary systems GALL, which

associated piping program (B2.1.5) recommends further

(Item Number evaluation (See -' ' 3.2.1-06) Section 3.2A.2.2.4)'

High pressure - - Loss of material Plant-specific Not applicable (See

safety injection due to erosion Section 3.2A.2.2.5)

(charging) pump The HPSI pumps

mini-flow orifice -are not used for

(Item Number normal charging.

32.1-08)

External surface of Loss of material Plant-specific General condition Consistent with

carbon steel due to general ,.. monitoring (B2.1.13) GALL, which'..:

components corrosion recommends further

(Item Number evaluation (See

3.2.1-10) Section 3.2A.2.2.2)

Piping and fittings Loss of fracture Thermal aging Inservice Inspection Consistent with

of CASS in toughness due to embrittlement of program: systems, GALL. which

emergency core thermal aging CASS components and recommends'no

cooling systems embrittlement supports (B2.1.18) further evaluation

(Item Number (See Section

3.2.1-11) 3.2A.2.1)

Components Loss of material Open-cycle cooling Not applicable

serviced by open- due to general water system There are no ESF

cycle cooling pitting, and crevice components in

system corrosion, MIC, and . open-cycle cooling

(Item Number biofouling; buildup water environments.

32.1-12) of deposit due to

biofouling

Components Loss of material Closed-cycle Closed-cycle cooling Consistent with

serviced by closed- due to general cooling water water system GALL, which

cycle cooling pitting, and crevice system (B2.1.7) recommends no

system corrosion further evaluation

(Item Number . . (See Section

3.2.1-13) 3.2A2.1)

Pumps, valves, Crack initiation and Water chemistry Chemistry control Consistent with

piping, and fittings, growth due to SCC for primary systems GALL, which

and tanks in program (B2.1.5); recommends no

containment spray Chemistry control further evaluation

and emergency' - , * for secondary (See Section

core cooling - systems program 3.2A.2.1)

systems (B2.1.6)

(Item Number

32.1-15) .

Carbon steel Loss of material . Boric acid corrosion Boric acid corrosion Consistent with

components due to boric acid . . (82.1.3); GALL (See Section

(Item Number corrosion . General condition 3.2A.2.1.1)

3.2.1-17) _ ._ ; monitoring (82.1.13)

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l] -4

Component Group' - Agng EffcUP- 'A-Pn In ' L- StfIf -ifIuIton

M ec han ni ; -Is- ... * ,i.. 

Closure bolting in Loss of material Bolting integrity Bolting integrity Consistent with

high-pressure or due to general (B2.1.26) GALL (See Section

high-temperature corrosion; crack 3.2A.2.1.2)

systems initiation and growth

(Item Number due to cyclic

3.2.1-18) loading andlor SCC

:

The staff's review of the Millstone ESF systems and associated components followed one of

several approaches. One approach, documented in Section 3.2A.2.1, involves the staffs review

of the AMR results for' components in the ESF systems that the applicant indicated are

consistent with the GALL Report and do not require further evaluation. Another approach,

documented in Section 3.2A.2.2, involves the staffs review of the AMR results for components

in the ESF systems that the applicant indicated are consistent with the GALL Report and for

which further evaluation is recommended. A third approach, documented in Section 3.2A.2.3,

involves the staffs review of the AMR results for components in the ESF systems that the

applicant indicated are not consistent with the GALL Report or are not addressed in the GALL

Report. The staff's review of AMPs that are credited to manage or monitor aging effects of the

ESF systems components is documented in Section 3.0.3 of this SER.

3.2A.2.1 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Not Recommended

Summary of Technical Information in the ADDlication. In LRA Section 3.2.2.1, the applicant

identified the materials, environments, and aging effects requiring management. The applicant

identified the following programs that manage the aging effects related to the ESF systems

components:

* boric acid corrosion program

* chemistry control for primary systems program

* closed-cycle cooling water system program

* general condition monitoring program

*. inservice inspection program: systems, components and supports program

tank inspection program

* work control process program

* bolting integrity program

Staff Evaluation. In Tables 3.2.2-1 through 3.2.2-5 of the LRA, the applicant provided a summary

of AMRs for the ESF systems and identified which AMRs it considered to be consistent with the

GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

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- - -

The applicant provided a note for each AMR line item. The notes described how the information

in the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicated the AMR was consistent with the GALL Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to confirm consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the AMP

identified in the GALL Report. The staff audited these line items to confirm consistency with the

GALL Report. The staff confirmed that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by the

applicant was consistent with the AMP identified in the GALL Report and whether the AMR was

valid for the site-specific conditions.

Note C indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP is consistent

with the AMP identified by the GALL Report. This note indicates that the applicant was unable to

find a listing of some system components in the GALL Report. However, the applicant identified

a different component in the GALL Report that had the same material, environment, aging

effect, and AMP as the component that was under review. The staff audited these line items to

confirm consistency with the GALL Report. The staff also determined whether the AMR line item

of the different component was applicable to the component under review and whether the AMR

was valid for the site-specific conditions.

Note D indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP takes some

exceptions to the AMP identified in the GALL Report. The staff audited these line items to

confirm consistency with the GALL Report. The staff verified whether the AMR line item of the

different component was applicable to the component under review. The staff verified whether

the identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The

staff also determined whether the AMP identified by the applicant was consistent with the AMP

identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note E indicated that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect; but a different aging management program is credited. The staff

audited these line items to confirm consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified by

the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the LRA, as documented

in its MPS audit and review report. The staff did not repeat its review of the matters described in

the GALL Report. However, the staff did verify that the material presented in the LRA was

applicable and that the applicant had identified the appropriate GALL Report AMRs. The staff

evaluation is discussed below. . - - - ;;

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I'u

3.2A.2.1.1 Loss of Material Due to Boric Acid Corrosion

In LRA Table 3.2.1, Item 3.2.1-17, the applicant stated that loss of material due to boric acid

corrosion is managed by MPS AMP B2.1.3, uBoric Acid Corrosion Program," and MPS AMP

B2.1.13, "General Condition Monitoring Program." The boric acid corrosion program includes

specific inspections of reactor coolant pressure boundary and supporting system components.

The boric acid corrosion program is evaluated in Section 3.0.3.1.2 of this SER.

The general condition monitoring program provides inspections for management of loss of

material due to boric acid corrosion beyond the scope of the boric acid corrosion program.

During the audit, the staff asked the applicant for clarification regarding how loss of material for

components not normally visible, or in infrequently accessed areas are managed by this

program. During the audit, further clarification was requested on how identification,

documentation, evaluation, and trending of boric acid leakage is performed under this program.

During the audit, the applicant stated that the general condition monitoring program is an

extension of the boric acid corrosion program in that general condition monitoring program

inspections identify borated water leakage and then, through the corrective action program, the

leak is assigned and evaluated by the boric acid corrosion program. When borated water

leakage is identified by the general condition monitoring program, a condition report is written to

identify the leak. During the daily review of the new condition reports, the leak is assigned to the

boric acid corrosion program where it gets fully evaluated and repaired as required. This is the

same process used to identify leaks in the boric acid corrosion program.

In the LRA, the applicant stated that for those areas identified as infrequently accessed areas,

for the purposes of detecting boric acid leakage, entry into the area is performed often enough

(at least once per refueling interval) to credit the general condition monitoring program. No:

infrequently accessed areas with systems containing borated water are identified for Unit 2. The

staffs evaluation of the general condition monitoring program is documented in Section 3.0.3.3.2

of this SER. Based on the applicant's response and review of the general condition monitoring

program, the staff concluded that this program is acceptable for managing loss of material since

visual inspection of external surfaces is performed during various walkdowns performed by plant

personnel to look for boron buildup and/or boric acid leaks.

3.2A.2.1.2 Loss of Material Due to General Corrosion; Crack Initiation and Growth Due to Cyclic

Loading and/or Stress Corrosion Cracking

In LRA Table 3.2.1, Item 3.2.1-18, the applicant stated that bolting in the ESF systems is not

subject to wetted conditions; therefore, loss of material due to general corrosion is not expected.

Additionally, cracking for bolting in ESF systems is not identified as an aging effect requiring

management.

The staff noted that Standard Review Plan for License Renewal (SRP-LR) Table 3.2-1

recommended GALL AMP XI.M18," for managing closure bolting in a high-pressure or

high-temperature system for loss of material due to general corrosion, crack initiation and growth

due to cyclic loading and/or stress corrosion cracking (SCC).

The staff questioned the applicant on whether all of the resolutions of the generic safety issue

for bolting, as stated in NUREG-1 339, are addressed. By letter dated December 3, 2004, the

applicant submitted an LRA supplement. in which it stated that it has developed a specific aging

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management program that addresses degradation of bolting at MPS. The program is addressed

in Section 3.0.3.2.18 of this SER.

By letter dated January 11, 2005, the applicant submitted its bolting aging management roll-up

item. In its response, the applicant replaced the existing information in the "Discussion" column

of LRA Table 3.2.1, Item 18, with "consistent with the NUREG-1801."

The staff reviewed the applicant's response, and finds this acceptable since it is consistent with

the GALL Report.

On the basis of its audit and review, the staff determined that for AMRs not requiring further

evaluation, as identified in LRA Table 3.2.1 (Table 1), the applicant's references to the GALL

Report are acceptable and no further staff review is required. On the basis of its audit and

review, the staff concluded that the applicant has demonstrated that the effects of aging will be

adequately managed so that the intended function(s) will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

Conclusion. The staff has evaluated the applicant's claim of consistency with GALL Report. The

staff also has reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff finds that the AMR results, which the applicant claimed to be consistent with the GALL

Report, are consistent with the AMRs in the GALL Report. Therefore, the staff finds that the

applicant has demonstrated that the effects of aging for these components will be adequately,

managed so that their intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.2A.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the ADolication. In LRA Section 3.2.2.2, the applicant

provided further evaluation of aging management as recommended by the GALL Report for ESF

systems. The applicant provided information concerning how it will manage the following aging

effects:

* cumulative fatigue damage

* loss of material due to general corrosion

* local loss of material due to pitting and crevice corrosion

* local loss of material due to microbiologically influenced corrosion(MIC)

* local loss of material due to erosion

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff reviewed the applicant's evaluation to determine whether it

adequately addressed the issues that were further evaluated. In addition', the staff audited the

applicant's further evaluations against the criteria contained in Section 3.2.2.2 of the SRP-LR.

Details of the staffs audit and review are documented in the staffs MPS audit and review report.

The GALL Report indicates that further evaluation should be performed for the aging effects

described in the following sections.

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3.2A.2.2.1 Cumulative Fatigue Damage

As stated in the SRP-LR, fatigue is a TLAA, as defined in 10 CFR 54.3. Applicants must

evaluate TLAAs in accordance with 10 CFR 54.21(c)(1). Section 4.3 of this SER documents the

staff's review of the applicant's evaluation of this TLAA. In performing this review, the staff

followed the guidance in Section 4.3 of the SRP-LR.

3.2A.2.2.2 Loss of Material Due to General Corrosion

The staff reviewed LRA Section 3.2.2.2.2 against the criteria in SRP-LR Section 3.2.2.2.2.

In LRA Section 3.2.2.2.2, the applicant addressed loss of material due to general corrosion that

could occur in the containment spray, containment isolation valves and associated piping, and

the external surfaces of carbon steel components.

SRP-LR Section 3.2.2.2.2.2 states that loss of material due to general corrosion could occur in

the containment spray, containment isolation valves and associated piping, and the external

surfaces of carbon steel components. The GALL Report recommends further evaluation on a

plant-specific basis to ensure that the aging effect is adequately managed.

The applicant stated in the LRA, that for loss of material from internal surfaces, this SRP-LR

item applies to carbon steel containment spray headers, nozzles, and valves; and to carbon

steel containment isolation piping and valves. The containment spray headers, nozzles, and

valves and containment isolation components in the ESF systems, are constructed of stainless

steel and are not subject to loss of material due to general corrosion. Containment isolation

components associated with other plant systems are evaluated for the effects of aging along

with the host system to which they are assigned.

For loss of material from external surfaces, this item applies to carbon steel ESF components.

Loss of material from external surfaces due to general corrosion is applicable to carbon steel

(including cast iron and low-alloy steel) components in an air environment when exposed to

intermittent wetting conditions. For these components, loss of material from external surfaces is

managed by MPS AMP B2.1.13, "General Condition Monitoring Program."

The staff concluded that loss of material due to general corrosion does not apply to stainless

steel components.

The staff reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.2 of this SER. The staff finds that the general condition monitoring program is

acceptable for managing loss of material due to general corrosion on external surfaces of

carbon steel components since visual inspections will be performed on external surfaces to

detect any sign of aging degradation.

On the basis of its review of the general condition monitoring program, the staff finds that the

applicant has appropriately evaluated AMR results involving management of the loss of material

due to general corrosion, as recommended in the GALL Report

3.2A.2.2.3 Local Loss of Material Due to Pitting and Crevice Corrosion

The staff reviewed LRA Section 3.2.2.2.3.2 against the criteria in SRP-LR Section 3.2.2.2.3.

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In LRA Section 3.2.2.2.3.2, the applicant addressed local loss of material from pitting and

crevice corrosion that could occur in the containment spray components, containment isolation

valves and associated piping, and the buried portion of the refueling water storage tank (RWST)

external surface.

SRP-LR Section 3.2.2.2.3.2 states that local loss of material from pitting and crevice corrosion

could occur in the containment spray components, containment isolation valves and associated

piping, and the buried portion of the refueling water tank external surface. The GALL Report

recommends further evaluation to ensure that the aging effect is adequately managed.

The applicant stated, in the LRA, that containment'isolation components are potentially subject

to a loss of material due to pitting and crevice corrosion. Loss of material for these components

is managed by AMP B2.1.5, Chemistry Control for Primary Systems Program."

Also, the external bottom surface of the RWST is potentially subject to a loss of material due to

pitting and crevice corrosion. Loss of material of the external surface of the RWST

bottom is managed by AMP B2.1.24, "Tank Inspection Program."

The applicant stated, in the LRA, that the chemistry control for primary systems program is

consistent with the GALL Report with an exception. The staff reviewed the chemistry control for

primary systems program, with the exception, and its evaluation is documented in Section - --

3.0.3.2.2 of this SER. The exception relates to a later revision of the Electric Power Research

Institute (EPRI) guidelines. On the basis of its review, the staff finds the chemistry control for

primary systems program acceptable for managing this aging effect for the above components.

The staff reviewed the tank inspection program, which includes an enhancement to measure

wall thickness to detect significant loss of material of the RWST bottom surface; and its

evaluation is documented in Section 3.0.3.2.17 of this SER. On the basis of its review, the staff

finds the program acceptable for managing loss of material due to pitting and crevice corrosion.

3.2A.2.2.4 Local Loss of Material Due to Microbiologically Influenced Corrosion

The staff reviewed LRA Section 3.2.2.2.4 against the criteria in SRP-LR Section 3.2.2.2.4.

In LRA Section 3.2.2.2.4, the applicant addressed local loss of material due to microbiologically

influenced corrosion (MIC). SRP-LR Section 3.2.2.2.4 states that containment isolation valves

and associated piping in systems could incur a local loss of material due to MIC that is not

addressed in other chapters of the GALL Report., The GALL Report recommends further

evaluation to ensure that the aging effect is adequately managed.

The applicant stated, in the LRA, that the containment isolation components are potentially

subject to a loss of material due to MIC. Loss of material for these components is managed by

AMP B2.1.5, Chemistry Control for Primary Systems Program."

The applicant stated, in the LRA, that the chemistry control for primary systems program is

consistent with the GALL Report with an exception. The staff reviewed the chemistry control for

primary systems program and its evaluation is documented in Section 3.0.3.2.2 of this SER. The

exception relates to a later revision of the EPRI guidelines. On the basis of its review, the staff

finds the chemistry control for primary systems program acceptable for managing this aging

effect.

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3.2A.2.2.5 Local Loss of Material Due to Erosion

The staff reviewed LRA Section 3.2.2.2.6 against the criteria in SRP-LR Section 3.2.2.2.6.

In LRA Section 3.2.2.2.6, the applicant addressed local loss of material due to erosion that could

occur in the HPSI miniflow orifice.

SRP-LR Section 3.2.2.2.6 states that local loss of material due to erosion could occur in the

high-pressure safety injection (HPSI) pump miniflow orifice. This aging mechanism and its effect

will apply only to pumps that are normally used as charging pumps in the chemical and volume

control systems. The GALL Report recommends further evaluation to ensure that the aging

effect is adequately managed.

The applicant stated, in the LRA, that the normal charging function is accomplished with positive

displacement charging pumps. The centrifugal HPSI pumps are not used for normal charging.

Therefore, this issue is not applicable to Unit 2.

Since this aging effect would apply to high head charging pumps only, the staff finds that loss of

material due to erosion is not applicable to positive displacement charging pumps.

3.2A.2.2.6 Quality Assurance for Aging Management of Non-Safety-Related Components

Section 3.0.4 of this SER provides the staffs evaluation of the applicant's Quality Assurance

Program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determines that (1) those attributes or features

for which the applicant claimed consistency with the GALL Report were indeed consistent and

(2) the applicant adequately addressed the issues that were further evaluated. The staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.2A.2.3 AMR Results That Are Not Consistent With or Not Addressed in the GALL

Report

Summary of Technical Information in the Application. In Tables 3.2.2-1 through 3.2.2-5 of the

LRA, the staff reviewed additional details of the results of the AMRs for material, environment,

aging effects requiring management, and AMP combinations that are not consistent with the

GALL Report or are not addressed in the GALL Report.

In Tables 3.2.2-1 through 3.2.2-5, the applicant indicated, via Notes F through J, that neither the

identified component nor the material and environment combination is evaluated in the GALL

Report, and it provided information concerning how the aging effect will be managed.

Staff Evaluation. For component type, material and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine whether

the applicant had demonstrated that the effects of aging will be adequately managed so that the

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intended function will be maintained consistent with the CLB during the period of extended

operation.

3.2A.2.3.1 Containment Spray - Aging Management Evaluation - Table 3.2.2-1

The staff reviewed LRA Table 3.2.2-1, which summarized the results of AMR evaluations for the

containment spray system component groups.

The applicant has not identified in the LRA any aging effect for low-alloy and stainless steel

components exposed to air, including bolting, orifice, piping, pump casing, tubing, spray nozzles,

and valve component types. Air is not identified in the GALL Report as an environment for these

components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on low-alloy and stainless steel components will not result in aging that will be of concern

during the period of extended operation. The external environments being referred to is typical of

ambient air (e.g., under a shelter, indoors, or an air-conditioned enclosure or room). Significant

amounts of corrosion of low-alloy steel require an electrolytic environment, and a simultaneous

presence of oxygen and moisture. Without the presence of the aggressive environment,

therefore, low-alloy steel components will experience insignificant amounts of corrosion, and no

aging effects would be applicable to this component/commodity group. Wrought austenitic

stainless steel is not susceptible to significant general corrosion that would affect the intended

function of components. Therefore, the staff concludes that there are no applicable aging effects

requiring management for metal in an air environment.

In the LRA, the applicant proposes to manage loss of material of the stainless steel orifice,

piping, pump casing, tubing, and valve component types exposed to treated water (chemicallytreated borated water) using only MPS AMP B2.1.5, Chemistry Control for Primary Systems

Program," which is consistent with GALL AMP XI.M2, "Water Chemistry," with an exception. The

staff reviewed the chemistry control for primary systems program and its evaluation is

documented in Section 3.0.3.2.2 of this SER. The exception relates to a later revision of the

EPRI guidelines. The staff finds that because the effects of pitting and crevice corrosion on

stainless steel components are not significant in chemically treated borated water, inspection of

selected components to confirm the absence of loss of material is not required. On the basis of

its review, the staff finds the chemistry control for primary systems program acceptable for

managing this aging effect.

3.2A.2.3.2 Safety Injection - Aging Management Evaluation - Table 3.2.2-2

The staff reviewed LRA Table 3.2.2-2, which summarizes the results of AMR evaluations for the

safety injection system component groups.

The applicant identified no aging effect for carbon steel, stainless steel, and CASS components

exposed to air, including flow elements, flow orifices, pipe, pumps, tubing, valves, and safety

injection tanks (carbon steel with SS clad) component types. Air is not identified in the GALL

Report as an environment for these components and materials.'

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environment being referred to is typical of ambient air (e.g., under a

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shelter, indoors, or an air-conditioned enclosure or room). Significant amounts of corrosion of carbon steel require an electrolytic environment, and a simultaneous presence of oxygen and moisture. Significant corrosion of carbon steel in an ambient air environment also requires the components to be subject to condensation. Without the presence of the aggressive environment, therefore, carbon steel components will experience insignificant amounts of corrosion, and no aging effects would be applicable to this component/commodity group. Wrought austenitic stainless steel and CASS are not susceptible to significant general corrosion that would affect the intended function of components. Therefore, the staff concludes that there are no applicable aging effects requiring management for metal in an air environment.

In the LRA, the applicant identified no aging effects for stainless steel (SS) components exposed internally to gas, including pipe and safety injection tanks (carbon steel with SS clad) component types. Gas is not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds that an internal environment of gas (which is similar to air) on metal will not result in aging that will be of concern during the period of extended operation. Therefore, the staff did not identify any concerns with the applicant's conclusions that there are no applicable aging effects requiring management for metal in a gas environment.

3.2A.2.3.3 Refueling Water Storage Tank and Containment Sump - Aging Management Evaluation - Table 3.2.2-3 and Table 3.2.2-3a

The staff reviewed Table 3.2.2-3 of the LRA and Table 3.2.2-3a in the applicant's letter dated January 11, 2005, which summarizes the results of AMR evaluations for the refueling water storage tank (RWST) and containment sump component groups.

In the LRA and in the applicant's letter, the applicant identified no aging effect for carbon steel, low-alloy steel, and stainless steel components exposed to air, including bolting, encapsulation piping and valves, pipe, rupture discs, trisodium phosphate dodecahydrate (TSP) basket, tubing, valves, RWST circulating pump, RWST heat exchanger (channel head), and RWST heat exchanger (shell) component types. Air is not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds that air on metal will not result in aging that will be of concern during the period of extended operation. The external environments being referred to are typical of ambient air (e.g., under a shelter, indoor, or air-conditioned enclosure or room). Significant amounts of corrosion of carbon

or low-alloy steel require an electrolytic environment and a simultaneous presence of oxygen ' and moisture. Significant corrosion of carbon steel in an ambient air environment also requires the components to be subject to condensation. Without the presence of the aggressive environment, therefore, carbon or low-alloy steel components will experience insignificant amounts of corrosion, and no aging effects would be applicable to this component/commodity group. Wrought austenitic stainless steel is not susceptible to significant general corrosion that would affect the intended function of components. Therefore, the staff concluded that it did not identify any concerns with the applicant's conclusions that there are no applicable aging effects requiring management for metal in an air environment.

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In the LRA, the applicant proposed to manage loss 6f material of stainless steel vortex breakers

component types exposed to treated water (chemically treated borated water) using MPS

AMP B2.1.5, Chemistry Control for Primary Syste sn Program," which is consistent with GALL

AMP XI.M2, Water Chemistry," with an exception'.The staff reviewed the chemistry control for

primary systems program and its evaluation is documebnted in Section 3.0.3.2.2 of this SER. The

exception relates to a later revision of the EPRI guidelines. The staff finds'that because the

effects of pitting and crevice corrosion on stainless steel components are not significant in

chemically treated borated water, inspection of selected components to confirm the absence of

loss of material is not required. On the basis of its' review, the staff finds the chemistry control for

primary systems program acceptable for manabing this'aging effect.

In the LRA, the applicant proposes to manage loss of material of stainless steel pipe, tubing, and

valve component types exposed to atmosphere/weather using MPS AMP B2.1 .13,'"General

Condition Monitoring Program." The applicant stated that this is a plant-specific program. The

staff reviewed the general condition monitoring program and its evaluation of this program is

documented in Section 3.0.3.3.2 of this SER. On'the basis of its review, the staff finds that the

general condition monitoring program is acceptable for managing loss of material due to pitting

and crevice corrosion since visual inspections will be performed on external surfaces to detect

any sign of aging degradation.

In the LRA, the applicant proposes to manage loss of material of carbon steel encapsulationpiping and valve component group exposed internally to moisture-laden air and/or intermittently

wetted environment using MPS AMP B2.1.25, "Work Control Process." The applicant stated that

this is a plant-specific program. The staff reviewed the work control process program and its,

evaluation is documented in Section 3.0.3.3.4 of this SER. The staff finds that visual inspections

of the internal surfaces of plant components and plant commodities are performed during the

performance of maintenance, in accordance with the work control process program, to

determine the presence of loss of material. The staff concluded that the work control process

program is acceptable for managing loss of material due to general corrosion since visual

inspections will be performed on internal surfaces of components to detect any sign of aging

degradation.

3.2A.2.3.4 Shutdown Cooling - Aging Management Evaluation - Table 3.2.2-4

The staff reviewed Table 3.2.2-4 of the LRA, which summarizes the results of AMR evaluations

for the shutdown cooling system component groups.

In the LRA, the applicant identified no aging effect for carbon steel, stainless steel, and CASS

components exposed to air, including carry-over tank, filters/strainers, flexible hose, flow

elements, pipe, restricting orifice, tubing, vacuum flask, vacuum pump, valves,' shutdown cooling

heat exchangers component types. Air is not identified in the GALL Report as an environment

for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will beof concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or an air-conditioned enclosure dr'room). Significant amounts of corrosion of

carbon steel require an electrolytic environment,'and a simultaneous presence of oxygen'and

moisture. Significant corrosion of carbon steel in an ambient air environment also requires the

components to be subject to condensation: Without the'presence of the' aggressive environment,

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therefore, carbon steel components will experience insignificant amounts of corrosion, and no aging effects would be applicable to this component/commodity group. Wrought austenitic stainless steels, and cast austenitic stainless steel (CASS) are not susceptible to significant general corrosion that would affect the intended function of components. Therefore, the staff concluded that it did not identify any concerns with the applicant's conclusions that there are no applicable aging effects requiring management for metal in an air environment.

In the LRA, the applicant identified no aging effect for stainless steel components exposed internally to air, including carry-over tank, filter/strainer, flexible hoses, vacuum flask, vacuum

pump component types. Air is not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds that air on metal will not result in aging that will be of concern during the period of extended operation. Wrought austenitic stainless steels are not susceptible to significant general corrosion that would affect the intended function of components. Therefore, the staff concluded that it did not identify any concerns with the applicant's conclusions that there are no applicable aging effects requiring management for metal in an air environment.

In the LRA, the applicant proposed to manage loss of material of stainless steel shutdown cooling heat exchangers (tubing) component types exposed to treated water using MPS AMP B2.1.25, "Work Control Process." The staff reviewed the work control process program and its evaluation is documented in Section 3.0.3.3.4 of this SER. The staff finds that the work control process program provides the opportunity to visually inspect the internal surfaces of components during preventive and corrective maintenance activities on an ongoing basis. The work control process program provides input to the corrective action program if aging effects are identified. On the basis of its review, the staff concluded that the work control process program is acceptable for managing the aging effects of loss of materials.

3.2A.2.3.5 Spent Fuel Pool Cooling - Aging Management Evaluation - Table 3.2.2-5 and Table 3.2.2-5a

The staff reviewed Table 3.2.2-5 of the Millstone LRA and Table 3.2.2-5a of the applicant's letter dated January 11, 2005, which summarized the results of AMR evaluations for the spent fuel pool cooling system component groups.

In the LRA and in the applicant's letter dated January 11, 2005, the applicant identified no aging effect for low-alloy and stainless steel components exposed to air, including expansion joints, flow elements, pipe, pumps, spent fuel pool heat exchangers (channel head), tubing, valves, filters, and mixing tank component types. Air is not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds that air on low-alloy and stainless steel components will not result in aging that will be of concern during the period of extended operation. The external environments being referred to are typical of ambient air (e.g., under a shelter, indoors, or an air-conditioned enclosure or room). Significant amounts of corrosion of low-alloy steel requires an electrolytic environment, and a simultaneous presence of oxygen and moisture. Without the presence of the aggressive environment, therefore, low-alloy steel components will experience insignificant amounts of corrosion, and no aging effects would be applicable to this component/commodity group.

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Wrought austenitic stainless steels are not susceptible to significant general corrosion that would

affect the intended function of components. Therefore, the staff concluded that it did not identify'

any concerns with the applicant's conclusions that there'are no applicable aging effects requiring

management for metal in an air environment.

In the LRA, the applicant proposed to manage loss of material of stainless steel expansion

joints, flow elements, pipe, pumps, spent fuel pool heat exchangers (channel head) component

types exposed to treated water (chemically treated borated water)-using only MPS AMP B2.1'.5,

"Chemistry Control for Primary Systems Program," which is consistent with GALL AMP XL.M2,

Water Chemistry," with an exception. The staff reviewed the chemistry control for primary

systems program and its evaluation is documented in Section 3.0.3.2.2 of this SER. The

exception relates to a later revision of the EPRI guidelines. The staff finds that because the

effects of pitting and crevice corrosion on stainless steel components are not significant in

chemically treated borated water, inspection of selected components to confirm the absence of

loss of material is not required. On the basis of its review, the staff concluded that the chemistry

Control for primary systems program is acceptable for managing this aging effect.

However, for other stainless steel components exposed to treated water, the applicant

considered them consistent with the GALL Report, since a different component type was:

referenced with a different program, identifying it in LRA Table Note E. During the site audit, the

staff asked the applicant to provide the basis for considering some components with the same

material, environment, and aging effect combination as consistent with the GALL Report,:!

referencing LRA Table Note E, and others as not consistent with GALL Report, referencing LRA

Table Note H. For example, in the LRA Table 3.2.2-5, page 3-138, the applicant-stated that for a

pipe component type exposed to treated water and subject to loss of material, this component,

material and environment combination is not consistent with the GALL Report (i.e., LRA Table

Note H). On the other hand, in LRA Table 3.2.2-5, page 3-140, the applicant stated that for

tubing and valve component types exposed to treated water and subject to loss of material

(same material, environment, and aging effect combination), this is consistent with the GALL

Report Item VII.C2.2-a (i.e., LRA Table Note E). The applicant submitted an LRA supplement

letter, dated July 7, 2004, and stated that the note should have been Note H for all of these

component types, and references to the GALL Report item and Table 1 item should be removed

from Table 2. The staff reviewed the applicant's'response and concludes that it is acceptable.

All other AMRs assigned to the staff in Tables 3.2.2-1 through 3.2.2-5 were evaluated. The staff

finds them to be acceptable.

Conclusion. On the basis of its review, the staff finds that the applicant appropriately evaluated

AMR results involving material, environment, aging effect requiring management, and AMP

combinations that are not evaluated in the GALL Report. The staff finds that the applicant has

demonstrated that the effects of aging will be'adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation; as

required by 10 CFR 54.21 (a)(3).

3.2A.3 Conclusion

On the basis of its review, the staff concludes that the applicant has demonstrated that the aging

effects associated with the ESF systems components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3). - '

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The staff also reviewed the applicable FSAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the engineering safety

features systems, as required by 10 CFR 54.21 (d).

3.2B Unit 3 Aging Manaaement of Engineered Safety Features Systems

This section of the SER documents the staffs review of the applicant's AMR results for the ESF

systems components and component groups associated with the following systems:

* containment recirculation system

* quench spray system

* safety injection system

* residual heat removal system

* fuel pool cooling and purification system

3.2B.1 Summary of Technical Information In the Application

In LRA Section 3.2, the applicant provided AMR results for ESF systems components and

component groups. In LRA Table 3.2.1, Summary of Aging Management Evaluations in Chapter

V of NUREG-1 801 for Engineered Safety Features," the applicant provided a summary

comparison of its AMRs with the AMRs evaluated in the GALL Report for the ESF systems

components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.2B.2 Staff Evaluation

The staff reviewed LRA Section 3.2 to determine if the applicant provided sufficient information

to demonstrate that the effects of aging for the ESF system components that are within the

scope of license renewal and subject to an AMR will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

Also, the staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report However, the staff did confirm that the material

presented in the LRA was applicable and that the applicant had identified the appropriate GALL

AMPs. The staffs evaluations of the AMPs are documented in Section 3.0.3 of this SER. The

staff's audit evaluation are documented in the staff's MPS audit and review report and

summarized in Section 3.2B.2.1 of this SER.

The staff also performed an audit of those AMRs that were consistent with the GALL Report and

for which further evaluation is recommended. Te staff confirmed that the applicant's further

evaluations were consistent with the acceptance criteria in Section 3.2.2.2 of NUREG-1800,

"Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants,"

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dated July 2001. The staffs audit evaluation are documented in the staffs MPS audit and review

report and summarized in Section 3.2B.2.2 of this SER.

The staff performed an onsite audit and conducted a technical review of the remaining AMRs

that were not consistent with or not address in the GALL Report. The audit and technical review

included evaluating whether all plausible aging effects were identified and the aging effects listed

were appropriate for the combination of materials and environments specified. The staffs audit

evaluation are address in the MPS audit and review report and summarized in Section 3.2B.2.3

of this SER. The staffs evaluation of its technical review is also documented in Section 3.2B.2.3

of this SER.

Finally, the staff reviewed the AMP summary descriptions in the FSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the ESF system components.

Table 3.2B-1 provides a summary of the staffs evaluation of components, aging

effects/mechanisms, and AMPs listed in LRA Section 3.2 that are addressed in the GALL

Report.

Table 3.2B-1 Staff Evaluation for Engineered Safety Features System Components In the

GALL Report

Comnponent Group ~..:-Ag ing Effect/ ' AMP in GAL: LR;Saff AP in Evaluation

-; -.. . ..- - - '-''M ech an is m -. .. .:' '; R' p ; r ' ' -:- _ _ _ _ _ _ _ _. _ _: _- _ - ' _ - . _ _ - : _ _' _. _:

Piping, fittings, and Cumulative fatigue TLAA, evaluated in TLAA This TLAA Is

valves in emergency damage accordance with evaluated In Section

core cooling system 10 CFR 54.21 (c) 4.3B, Metal Fatigue (Item Number

3.2.1-01)

Components in Loss of material due Plant-specific Not applicable (See containment spray to general corrosion Section 3.2B.2.2.2) (PWR only),

standby gas

treatment (BWR only), containment

isolation, and

emergency core

cooling system

(Item Number

3.2.1-03)

Components in Loss of material due Plant-specific Chemistry control for Consistent with

containment spray to pitting and primary systems GALL, which

(PWR only), crevice corrosion program (B2.1.5); recommends further

standby gas Work control evaluation (See

treatment (BWR . process (B2.1.25); Section 32B.2.2.3) only), and Tank inspection

emergency core program (B2.1.24) cooling systems

(Item Number

3.2.1-05)

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Component Group 'ffectI ' - M in GALLi- ing -- iAP In Li : i- f Evalati on

'":- -M chalnisr R .e..'pXContainment Loss of material due Plant-specific Chemistry control for Consistent with

isolation valves and to MIC primary systems GALL, which

associated piping program (82.1.5); recommends further

(Item Number Work control evaluation (See

3.2.1-06) process (B2.1.25) Section 3.28.2.2.4)

HPSI (charging) Loss of material due Plant-specific Work control Consistent with'

pump mini-flow to erosion process (12.1.25) GALL, which

orifice (Item Number recommends further

3.2.1-08) evaluation (See

Section 3.21.2.2.5)

Extemal surface of Loss of material due Plant-specific General condition Consistent with

carbon steel to general corrosion monitoring (B2.1.13) GALL, which

components recommends further

(Item Number evaluation (See 3.2.1-10) Section 3.2B.2.2.2)

Piping and fittings of Loss of fracture Thermal aging Inservice inspection Consistent with

CASS in emergency toughness due to embrittlement of program: systems, GALL, which

core cooling thermal aging CASS components and recommends no

systems embrittlement supports (B2.1.18) further evaluation

(Item Number (See Section

3.2.1-11) 3.28.2.1)

Components Loss of material due Open-cycle cooling Not applicable, no

serviced by to general pitting, water system further evaluation

open-cycle cooling and crevice (there are no ESF

system corrosion, MIC, and components In

(Item Number biofouling; buildup open-cycle cooling 3.2.1-12) of deposit due to water environments) biofouling

Components Loss of material due Closed-cycle Closed-cycle cooling Consistent with

serviced by to general pitting, cooling water water system GALL, which

closed-cycle cooling and crevice system (82.1.7) recommends no

system corrosion further evaluation

(Item Number (See Section

3.2.1-13) 3.28.2.1)

Pumps, valves, Crack initiation and Water chemistry Chemistry control for Consistent with

piping, and fittings, growth due to SCC primary systems GALL, which

and tanks in program (B2.1.5); recommends no

containment spray chemistry control for further evaluation

and emergency secondary systems (See Section

core cooling program (B2.1.6) 3.2B.2.1)

systems

(Item Number

3.2.1-15)

Carbon steel Loss of material due Boric acid corrosion Boric acid corrosion Consistent with

components to boric acid (82.1.3); GALL (See Sections

(Item Number corrosion General condition 3.28.2.1.1) 3.2.1-17) monitoring (82.1.13)

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Component'Group "Aoling Effectf-'I- Aln;GALL- n AMP 1n LRA -v; ' 'Staff Evaluation

- ehns. 2. .9 e6 -'.. ,.

Closure bolting in Loss of material due Bolting Integrity Bolting Integrity consistent with

high-pressure or to general (B2.1.26) GALL (See Section

high-temperature corrosion; crack 32B.2.1.2)

systems initiation and growth (Item Number due to cyclic loading

3.2.1-18) and/or SCC

The staff's review of the Millstone ESF systems'and associated components followed one of

several approaches. One approach, documented in Section 3.2B.2.1, involves the staffs review

of the AMR results for components in the ESF systems that the applicant indicated are

consistent with the GALL Report and do not require further evaluation. Another approach,

documented in Section 3.2B.2.2, involves the staff's review of the AMR results for components

in the ESF systems that the applicant indicated are consistent with the GALL Report and for

which further evaluation is recommended. A third approach, documented in Section 3.2B.2.3,

involves the staff's review of the AMR results for components in the ESF systems that the

applicant indicated are not consistent with the GALL Report or are not addressed in the GALL

Report. The staffs review of AMPs that are credited to manage or monitor aging effects of the

ESF systems components is documented in Section 3.0.3 of this SER.

3.2B.2.1 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Not Recommended

Summary of Technical Information in the ADDlication. In Sections 3.2.2.1.1 through 3.2.2.1.5 of

the LRA, the applicant identified the materials, environments, and aging effects requiring

management. The applicant identified the following programs that manage the aging effects

related to the ESF systems components:

* boric acid corrosion

* chemistry control for primary systems program

* general condition monitoring

* service water system (open-cycle cooling)

* work control process

* buried pipe inspection program

* tank inspection program

* closed-cycle cooling water system

* inservice inspection program: systems, components and supports

* bolting integrity program

Staff Evaluation. In Tables 3.2.2-1 through 3.2.2-5 of the LRA, the applicant provided a summary

of AMRs for the ESF systems and identified which AMRs it considered to be consistent with the

GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

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The applicant provided a note for each AMR line item. The notes described how the information

in the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicated the AMR was consistent with the GALL Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to confirm consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the AMP

identified in the GALL Report. The staff audited these line items to confirm consistency with the

GALL Report The staff confirmed that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by the

applicant was consistent with the AMP identified in the GALL Report and whether the AMR was

valid for the site-specific conditions.

Note C indicated that the component for the AMR line item is different, but consistent with the

GALL Report for material, environment, and aging effect. In addition, the AMP is consistent with

the AMP identified by the GALL Report. This note indicates that the applicant was unable to find

a listing of some system components in the GALL Report. However, the applicant identified a

different component in the GALL Report that had the same material, environment, aging effect,

and AMP as the component that was under review. The staff audited these line items to confirm

consistency with the GALL Report. The staff also determined whether the AMR line item of the

different component was applicable to the component under review and whether the AMR was

valid for the site-specific conditions.

Note D indicated that the component for the AMR line item is different, but consistent with the

GALL Report for material, environment, and aging effect. In addition, the AMP takes some

exceptions to the AMP identified in the GALL Report. The staff audited these line items to

confirm consistency with the GALL Report. The staff verified whether the AMR line item of the

different component was applicable to the component under review. The staff verified whether

the identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The

staff also determined whether the AMP identified by the applicant was consistent with the AMP

identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note E indicated that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to confirm consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified by

the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the LRA, as documented

in its MPS audit and review report. The staff did not repeat its review of the matters described in

the GALL Report. However, the staff did verify that the material presented in the LRA was

applicable and that the applicant had identified the appropriate GALL Report AMRs. The staff

evaluation is discussed below.

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3.2B.2.1.1 Loss of Material Due to Boric Acid Corrosion

In the discussion section of LRA Table 3.2.1, Item 3.2.1-17, the applicant stated that loss of

material due to boric acid corrosion is managed by MPS AMP B2.1.3, "Boric Acid Corrosion

Program," and MPS AMP B2.1.13, "General Condition Monitoring Program." The boric acid

corrosion program includes specific inspections of reactor coolant pressure boundary and

supporting systems components. The boric acid corrosion program and general condition

monitoring program are evaluated in Sections 3.0.3.1 and 3.0.3.3.2 of this SER,- respectively.

The general condition monitoring program provides inspections for management of loss of

material due to boric acid corrosion beyond the scope of the boric acid corrosion program.

During the audit, the staff asked the applicant for clarification regarding how loss of material for

components not normally visible, or in infrequently accessed areas are managed by this

program. During the audit clarification was requested on how identification, documentation,

evaluation, and trending of boric acid leakage is performed under this program. During the audit,

the applicant stated that the general condition monitoring program is an extension of the boric

acid corrosion program in that the general condition monitoring program inspections identify

borated water leakage and then,'through the corrective action program, the leak is assigned and

evaluated by the boric acid corrosion program.1 When borated water leakage is identified by the

general condition monitoring program, a condition report is written to identify the leak. During the

daily review of the new condition reports, it is assigned to the boric acid corrosion program

where it gets fully evaluated and repaired as required. This is the same process used to-identify

leaks in the boric acid corrosion program.

In the LRA, the applicant stated that for those areas identified as infrequently accessed areas,

for the purposes of detecting boric acid leakage, entry into the area is performed often enough

(at least once per refueling interval) to credit the general condition monitoring program. The one

exception is the Unit 3 demineralizer cubicles area. However, for this area, a video inspection is

performed at least once every 10 years to confirm the integrity of the equipment. There is

reasonable assurance that this inspection interval will detect borated water leakage prior to the

loss of intended function of the affected equipment. In addition, the inspection opportunities for

these cubicles will probably be more frequent than once every 10 years due to the need to -

perform corrective maintenance, filter changeout, etc. The Unit 3 areas accessed at least once

per refueling interval are typically observed by operations personnel during tagouts, health

physics during general area surveys or a survey performed for upcoming work in the area, or

during containment walkdowns as part of the boric acid corrosion program. The staff reviewed

the general condition monitoring program and its evaluation is documented in Section 3.0.3.3.2

of this SER. Based on the audit and review of the general condition monitoring program, the

staff finds that this program is acceptable for managing loss of material since visual inspection of

external surfaces is performed during various walkdowns performed by plant personnel to look

for boron buildup and/or boric acid leaks. -

3.2B.2.1.2 Loss of Material Due to General Corrosion; Crack Initiation and Growth Due to Cyclic

Loading and/or Stress Corrosion Cracking

In LRA Table 3.2.1, Item 3.2.1-18, the applicant stated that bolting in the ESF systems is not

subject to wetted conditions, therefore, loss of material due to general corrosion is not expected.

Additionally, cracking for bolting in ESF systems is not identified as an aging effect requiring

management.

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The staff noted that SRP-LR Table 3.2-1 recommended GALL AMP XI.M1 8, for managing

closure bolting in high pressure or high temperature system for loss of material due to general

corrosion; crack initiation and growth due to cyclic loading and/or SCC.

During the audit, the staff questioned the applicant whether all of the resolutions of the generic

safety issue for bolting, as stated in NUREG-1339, are addressed. By letter dated December 3,

2004, the applicant submitted its LRA supplement. in which it stated that it has developed a

specific aging management program that addresses degradation of bolting at MPS. The

program is addressed in Section 3.0.3.2.18 of this SER.

By letter dated January 11, 2005, the applicant submitted its bolting aging management roll-up

item. In its response, the applicant replaced the existing information in the "Discussion" column

of LRA Table 3.2.1, Item 18 with consistent with the NUREG-1801."

The staff reviewed the applicant's response and finds this acceptable since it is consistent with

the GALL Report.

On the basis of its audit and review, the staff determined that for AMRs not requiring further

evaluation, as identified in LRA Table 3.2.1 (Table 1), the applicant's references to the GALL

Report are acceptable and no further staff review is required.

Conclusion. The staff has evaluated the applicant's claim of consistency with GALL Report. The

staff also has reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff finds that the AMR results, which the applicant claimed to be consistent with the GALL

Report, are consistent with the AMRs in the GALL Report. Therefore, the staff finds that the

applicant has demonstrated that the effects of aging for these components will be adequately

managed so that their intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.2B.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation Is Recommended,

Summary of Technical Information in the Application. In Section 3.2.2.2 of the LRA, the applicant

provided further evaluation of aging management as recommended by the GALL Report for ESF

systems. Specifically, the applicant provided information concerning how it will manage the

following aging effects:

* cumulative fatigue damage

* loss of material due to general corrosion

* local loss of material due to pitting and crevice corrosion

* local loss of material due to microbiologically influenced corrosion

* local loss of material due to erosion

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff reviewed the applicant's evaluation to determine whether it

adequately addressed the issues that were further evaluated. In addition, the staff audited theapplicant's further evaluations against the criteria contained in Section 3.2.2.2 of the SRP-LR).

Details of the staffs audit and review are documented in the staffs MPS audit and review report.

3-224
The GALL Report indicates that further evaluation should be perfornmed for the aging effects

described in the following sections.

3.2B.2.2.1 Cumulative Fatigue Damage

As stated in the SRP-LR, fatigue is a TLAA, as defined in 10 CFR 54.3. Applicants must

evaluate TLAAs in accordance with 10 CFR 54.21 (c)(1). Section4.3 of this SER documents the

staffs review of the applicant's evaluation of this TLAA. In performing this review, the staff

followed the guidance in Section 4.3 of the SRP-LR.

3.2B.2.2.2 Loss of Material Due to General Corrosion

In LRA Section 3.2.2.2.2, the applicant addressed loss of material due to general corrosion that

could occur in the containment spray, containment isolation valves and associated piping, and

the external surfaces of carbon steel components.

SRP-LR Section 3.2.2.2.2 states that loss of material due to general corrosion could occur in the

containment spray, containment isolation valves and associated piping, and the external

surfaces of carbon steel components. The GALL Report recommends further evaluation on a

plant-specific basis to ensure that the aging effect is adequately managed.

The applicant stated, in the LRA, that for loss of material from internal surfaces; this SRP-LR

item applies to carbon steel containment spray headers, nozzles, and valves and to carbon steel

containment isolation piping and valves. The containment spray headers, nozzles, and valves

and containment isolation components in the ESF systems are constructed of stainless steel and

are not subject to loss of material due to general corrosion. Containment isolation components

associated with other plant systems are evaluated for the effects of aging along with the host

system to which they are assigned.

For loss of material from external surfaces, this item applies to carbon steel ESF components.

Loss of material from external surfaces due to general corrosion is applicable to carbon steel

(including cast iron and low-alloy steel) components in an air environment when exposed to

intermittent wetting conditions. For these components, loss of material from external surfaces is

managed by MPS AMP B2.1.13, "General Condition Monitoring Program."

The staff finds that loss of materials due to general corrosion does not apply to stainless steel

components.

The staff reviewed the general condition monitoring program, and its evaluation is documented

in Section 3.0.3.3.2 of this SER. The staff finds that the general condition monitoring program is

acceptable for managing loss of material due to general corrosion on external surfaces of

carbon steel components since visual inspections will be performed on external surfaces to

detect any sign of aging degradation.

On the basis of its review of the general condition monitoring program, the staff finds that the

applicant has appropriately evaluated AMR results involving management of the loss of material

due to general corrosion, as recommended in the GALL Report.

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3.21B.2.2.3 Local Loss of Material Due to Pitting and Crevice Corrosion

In LRA Section 3.2.2.2.3, the applicant addressed local loss of material from pitting and crevice

corrosion that could occur in the containment spray components, containment isolation valves

and associated piping, and the buried portion of the RWST external surfaces.

SRP-LR Section 3.2.2.2.3.2 states that local loss of material from pitting and crevice corrosion

could occur in the containment spray components, containment isolation valves and associated

piping, and the buried portion of the refueling water tank external surface. The GALL Report

recommends further evaluation to ensure that the aging effect is adequately managed.

In the LRA, the applicant stated that containment isolation components are potentially subject to

loss of material due to pitting and crevice corrosion. Loss of material for these components is

managed by MPS AMP B2.1.5, "Chemistry Control for Primary Systems Program," or, for those

components in a raw water environment, by MPS AMP B2.1.25, "Work Control Process."

Also, the external bottom surface of the RWST is potentially subject to loss of material due to

pitting and crevice corrosion. Loss of material of the external surface of the RWST bottom is

managed by MPS AMP B2.1.24, "Tank Inspection Program."

The applicant stated, in the LRA, that the chemistry control for primary systems program is

consistent with GALL with an exception. The staff reviewed the chemistry control for primary

systems program, with the exception, and its evaluation is documented in Section 3.0.3.2.2 of

this SER. The exception relates to use of a later, non-NRC-approved revision of the EPRI

guidelines. On the basis of its review, the staff finds the chemistry control for primary systems

program acceptable for managing this aging effect for the above components.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The staff finds that the work control process program provides the

opportunity to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. The work control process program also

provides input to the corrective action program if aging effects are identified. On the basis of its

review, the staff finds that the work control process program is acceptable for managing the

aging effect of loss of materials.

The staff reviewed the tank inspection program, which includes an enhancement to measure

wall thickness to detect significant loss of material of the RWST bottom surface, and its

evaluation is documented in Section 3.0.3.2.17 of this SER. On the basis of its review, the staff

finds the program to be acceptable for managing loss of material due to pitting and crevice

corrosion.

3.2B.2.2.4 Local Loss of Material Due to Microbiologically Influenced Corrosion

In LRA Section 3.2.2.2.4, the applicant addressed local loss of material due to MIC.

SRP-LR Section 3.2.2.2.4 states that local loss of material due to MIC could occur in

containment isolation valves and associated piping in systems that are not addressed in other

chapters of the GALL Report. The GALL Report recommends further evaluation to ensure that

the aging effect is adequately managed.

3-226
The applicant stated, in the LRA, that containment isolation components are potentially subject

to loss of material due to MIC. Loss of material for these components is managed by MPS AMP

B2.1.5, "Chemistry Control for Primary Systems Program," or, for those components in a raw

water environment, by MPS AMP B2.1.25, "Work Control Process."

The applicant stated, in the LRA, that the chemistry control for primary systems program is

consistent with GALL with an exception. The staff reviewed the chemistry control for primary

systems program, with the exception, and its evaluation is documented in Section 3.0.3.2.2 of

this SER. The exception relates to use of a later, non-NRC-approved revision of the EPRI

guidelines. On the basis of its review, the staff finds the chemistry control for primary systems

program to be acceptable for managing this aging effect for the above components.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The staff finds that the work control process program provides the

opportunity to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. The work control process program also

provides input to the corrective action program if aging effects are identified. On the basis of its

review, the staff finds that the work control process program is acceptable for managing the

aging effect of loss of materials.

3.21B.2.2.5 Local Loss of Material Due to Erosion

In LRA Section 3.2.2.2.6, the applicant addressed local loss of material due to erosion that could

occur in the HPSI miniflow orifice.

SRP-LR Section 3.2.2.2.6 states that local loss of material due to erosion could occur in the

HPSI pump miniflow orifice. This aging mechanism and its effect will apply only to pumps that

are normally used as charging pumps in the chemical and volume control systems. The GALL

Report recommends further evaluation to ensure that the aging effect is adequately managed.

The applicant stated, in the LRA, that loss of material due to erosion of the charging pump

miniflow recirculation orifices is managed by MPS AMP B2.1.25, "Work Control Process."

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The staff finds that the work control process program provides the

opportunity to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. It also provides input to the corrective

action program if aging effects are identified. On the basis of its review, the staff finds that the

work control process program is acceptable for managing the aging effects of loss of material

due to erosion, as recommended in the GALL Report.

3.21B.2.2.6 Quality Assurance for Aging Management of Non-Safety-Related Components

Section 3.0.4 of this SER provides the staffs evaluation of the applicant's Quality Assurance

Program.

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Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determines that (1) those attributes or features

for which the applicant claimed consistency with the GALL Report were indeed consistent and

(2) the applicant adequately addressed the issues that were further evaluated. The staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.2B.2.3 AMR Results That are Not Consistent With or Not Addressed in the GALL Report

Summary of Technical Information in the AnDlication. In Tables 3.2.2-1 through 3.2.2-5 of the

LRA, the staff reviewed additional details of the results of the AMRs for material, environment,

aging effect requiring management, and AMP combinations that are not consistent with the

GALL Report or are not addressed in the GALL Report. The staff also reviewed additional

systems and components, provided in the applicant's letter dated January 11, 2005.

In Tables 3.2.2-1 through 3.2.2-5, the applicant indicated, via Notes F through J, that neither the

identified component nor the material and environment combination is evaluated in the GALL

Report and provided information concerning how the aging effect will be managed.

Staff Evaluation. For component type, material and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine whether

the applicant had demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB during the period of extended

operation.

3.2B.2.3.1 Containment Recirculation - Aging Management Evaluation - Table 3.2.2-1

The staff reviewed Table 3.2.2-1 of the LRA, which summarizes the results of AMR evaluations

for the containment recirculation component groups.

The applicant has not identified in the LRA any aging effects for low-alloy and stainless steel

components exposed to air, including bolting, expansion joints, flow elements, flow indicators,

hoses, pipe, pump seal coolers, pump seal head tanks, pumps, restricting orifices, spray

nozzles, TSP baskets, tubing, and valve component types. Air is not identified in the GALL

Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on low-alloy and stainless steel components will not result in aging that will be of concern

during the period of extended operation. The external environments being referred to are typical

of ambient air (e.g., under a shelter, indoors, or an air-conditioned enclosure or room).

Significant corrosion of low-alloy steel requires an electrolytic environment, and a simultaneous

presence of oxygen and moisture. Without the presence of the aggressive environment,

therefore, low-alloy steel components will experience insignificant amounts of corrosion, and no

aging effects would be applicable to this componenttcommodity group. Wrought austenitic

stainless steels are not susceptible to significant general corrosion that would affect the intended

function of components. Therefore, the staff finds that it did not identify any concerns with the

applicant's conclusions that there are no applicable aging effects requiring management for

metal in an air environment.

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In the LRA, the applicant proposed to manage loss of material of stainless steel flow indicators,

hoses, piping, tubing, and valve component types exposed to chemically treated borated water

using only MPS AMP B2.1.5, 'Chemistry Control for Primary Systems Program," which is

consistent with GALL AMP XI.M2, "Water Chemistry," with an exception. The staff reviewed the

chemistry control for primary systems program, with an exception, and its evaluation is

documented in Section 3.0.3.2.2 of this SER. The exception relates to use of a later,

non-NRC-approved revision of the EPRI guidelines. The staff finds that because the effects of

pitting and crevice corrosion on stainless steel components are not significant in chemically

treated borated water, inspection of selected components to confirm the absence of loss of

material is not required. On the basis of its review, the staff finds the chemistry control for

primary systems program to be acceptable for managing this aging effect.

In the LRA, the applicant proposed to manage loss of material of stainless steel containment

recirculation coolers (shell) component types exposed to a moisture-laden air and/or

intermittently wetted environment using MPS AMP B2.1.13, "General Condition Monitoring." This

is a plant-specific program. The staff reviewed the general condition monitoring program and its

evaluation is documented in Section 3.0.3.3.2 of this'SER. On the basis of its review, the staff

finds that the general condition monitoring program is acceptable for managing loss of material

due to pitting and crevice corrosion since visual inspections will be performed on external

surfaces to detect any sign of aging degradation>-

In the LRA, the applicant proposed to manage loss of material of copper alloy containment

recirculation coolers (tubes) component types exposed externally to a moisture-laden air and/or

intermittently wetted environment using MPS AMP B2.1.25, "Work Control Process." This is a

plant-specific program. The staff reviewed the work control process program and its evaluation

is documented in Section 3.0.3.3.4 of this SER. The staff finds that visual inspections of the

internal and external surfaces of plant components and plant commodities are performed during

the performance of maintenance, in accordance with the work control process program, to

determine the presence of loss of material. On the basis of its review, the staff finds that the

work control process program is acceptable for managing loss of material due to general

corrosion since visual inspections will be performed on external surfaces of components to

detect any sign of aging degradation.

In the LRA, the applicant proposed to manage loss of material of stainless steel containment

recirculation coolers (shell), expansion joints, flow'elements, pipe, and restricting orifices

component types exposed internally to a moisture-laden air and/or intermittently wetted

environment using MPS AMP B2.1.25, "Work Control Process." This is a plant-specific program.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The staff finds that visual inspections of the internal and external

surfaces of plant components and plant commodities are performed during the performance of

maintenance, in accordance with the work control process program, to determine the presence

of loss of material. On the basis of its review, the staff finds that the work control process

program is acceptable for managing loss of material due to general corrosion since visual

inspections will be performed on internal surfaces of components to detect any sign of aging

degradation. :

In the LRA, the applicant proposed to manage loss of material of copper alloy containment

recirculation coolers (tubes) component types exposed internally to a moisture-laden air and/or

intermittently wetted environment using MPS AMP B2.1.21, "Service Water System (Open-Cycle

Cooling)," with exceptions. The applicant stated; in the LRA, that the tube side and the shell side

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I

of the containment recirculation coolers are in dry lay-up except when testing. The applicant's

exception to this line item relates to flushing and testing "infrequently used cooling loops," which

is recommended in the GALL Report. Since these coolers are maintained in a dry lay-up

condition, no mechanism exists for tube-side fouling; This does not have any impact on loss of

material. In addition, the applicant stated that this program is consistent with GALL AMP XL.M20,

"Open-Cycle Cooling Water System," which includes routine inspection and a maintenance

program to ensure that corrosion cannot degrade the performance of safety-related systems

serviced by open-cycle cooling water. The staff reviewed the service water system (open-cycle

cooling) program and its evaluation is documented in Section 3.0.3.2.15 of this SER. On the

basis of its review, the staff finds that this program is acceptable for managing this aging effect.

In the LRA, the applicant proposed to manage loss of material of stainless steel pipe, pump, and

valve component types exposed internally to raw water using MPS AMP B2.1.25, "Work Control

Process." The applicant stated, as documented in the technical report for the work control

process, that the system drains going into the containment sump are assumed to contain raw

water because of the potential contaminants and lack of chemistry control. The staff noted that

this is different from the raw water used in open-cycle cooling systems. The applicant stated per

Note H that the aging effect is not in NUREG-1 801 for this component, material, and

environment combination. Visual inspections of the internal surfaces of plant components and

plant commodities are performed during the performance of maintenance, in accordance with

the work control process program, to determine the presence of loss of material. The staff

reviewed the work control process program and its evaluation is documented in Section 3.0.3.3.4

of this SER. On the basis of its review, the staff finds that the work control process program is

acceptable for managing loss of material since visual inspections will be performed on internal

surfaces of components to detect any sign of aging degradation.

LRA Table 3.2.2-1 for the containment recirculation components identify loss of material as an

aging affect applicable to nickel based alloys and copper alloys exposed to internal and external

air environments. The LRA does not identify the alloy zinc content for these materials. The LRA

credits the work control process for managing loss of material of the nickel based alloy

containment recirculation cooler tubesheets and copper alloy tubes in an external air

environment and the AMP "Service Water System' for managing loss of material on the interior

of copper alloy channel heads and tubes and nickel based alloy tubesheets. Industry documents

such as EPRI Report 1003056 identify various corrosion mechanisms causing loss of material in

an air environment subject to moisture. Aging mechanisms such as selective leaching, crevice

corrosion and galvanic corrosion are material and location dependent. In RAI 3.2-1 the applicant

was requested to identify the alloy zinc content and clarify if selective leaching is an applicable

aging mechanism. If selective leaching is an applicable aging mechanism, clarify if hardness

testing and one-time inspection required by GALL AMP XL.M33 will be used. Also clarify how

visual inspections required by the aging management programs are effective- in managing loss

of material by providing for inspections at locations that are susceptible to the aging mechanism

such as the [the] tubesheet and channel head interiors which may be inaccessible for visual -

inspection. The applicant was also requested to provide the following additional information (a)

frequency of the inspections including the bases. (b) Inspection methods which verify the loss of

material in the recirculation cooler channel heads, tube sheets and tubes (c) Identify any

operating experience to demonstrate the effectiveness of the work control process and the

service water program to manage loss of material in nickel based alloys and copper alloys

exposed to an external air environment.

In its response dated November 9, 2004, the applicant stated:

I

II

I

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- - -

The containment recirculation cooler tubes and channel head lining are copper-nickel

material and the tubesheet is nickel-copper (Monel) material. Zinc is not an alloying

element for any of these materials. Therefore, selective leaching is not an applicable

aging mechanism for these components.

The containment recirculation coolers are maintained in a dry lay-up condition and loss of

material due to corrosion is not expected. However, since the coolers are flushed and

flow tested on a periodic basis, the aging management review conservatively considered

the environment for the coolers to be intermittently wetted. As a result, loss of material

due to corrosion was determined to be an applicable aging effect for the containment

recirculation coolers. The coolers are accessed and the tubesheets and channel head

interiors are inspected as part of the Service Water System (Open-Cycle Cooling AMP

described in LRA Appendix B, Section B2.1.21. In addition, components that are opened

or disassembled for maintenance activities are visually inspected as part of the Work

Control Process aging management program as described in Appendix B, Section

B2.1.25. For containment recirculation cooler locations that are not readily accessible for

visual inspection, the Work Control Process AMP remains effective in that other work

activities which are associated with components representative of the specific materials

and environments of the coolers provided an indication of the condition of the cooler

components.

The containment recirculation coolers are inspected every other refueling outage in

accordance with the Service Water System (Open-Cycle Cooling) AMP. The containment

recirculation cooler inlet ends are accessed and a visual inspection is performed.

Demonstration of the effectiveness of the Service Water System (Open-Cycle Cooling)

AMP is addressed in the discussion of operating experience provided in the LRA Section

B2.1.21. Operating experience related to the Work Control Process AMP is addressed in

LRA Section B2.1.25. ...

The staff finds the applicant's response reasonable and acceptable because the applicant has

clarified why selective leaching is not an applicable aging mechanism for these components.

The applicant has also identified inspection activities to appropriately manage the aging effects.

The applicant stated in the LRA "The Millstone Unit 3 containment recirculation coolers and

service water supply piping to these heat exchangers are infrequently used loops but are not

flushed in accordance with GL 89-13. The containment recirculation coolers are maintained in a

dry lay up condition. Thus, no mechanism exist for tube side fouling and the ability of the coolers

to perform their intended function is maintained. The service water supply piping to these heat

exchangers is flushed on a semi-annual basis to displace any mussel or hydroid colonies onto

screens installed on the tubesheets of these heat exchangers. The accumulated debris on the

screens is then removed after the flushing evolution. In RAI 3.2-2 the applicant was requested to

provide information based on inspections and applicant's self-assessment programs which

assure that with the present state of fouling the recirculation coolers in Unit 3 will be able to

perform to their intended function during the period of extended operation. For example are

visual inspections performed and correlated to an acceptable degree of fouling to determine the

effectiveness of the dry lay up program?

In its response dated November 9, 2004, the applicant stated:

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Review of the last three years of inspection data for the Unit 3 A, B, C and D containment

recirculation coolers and discussion with the system engineer indicate that the degree of

fouling is minor and did not affect the operability of the heat exchangers. The semiannual service water inlet piping flush and inspection did not identify foreign debris in

most cases. Some inspections did identify small amounts of mussel shell pieces and

evaluations in accordance with plant procedures were performed to determine if the heat

exchanger operation could have been impacted; however, no concerns were identified.

Based on the results of the current flushing and inspection frequency, the dry lay up

program is effective in maintaining the degree of fouling at a level that supports plant

operation. Any substantial change in the effectiveness of the flush and inspection

surveillance results would be addressed through the corrective action program.

The staff finds the applicant's response reasonable and satisfactory because the applicant's

operating experience and piping flush and inspection activities indicate that the operability of the

heat exchangers is not affected.

3.2B.2.3.2 Quench Spray - Aging Management Evaluation - Table 3.2.2-2 and Table 3.2.2-2a

The staff reviewed Table 3.2.2-2 of the LRA and Table 3.2.2-2a in the applicant's letter dated

January 11, 2005, which summarized the results of AMR evaluations for the quench spray

system component groups.

The applicant, in the LRA, has identified no aging effect for low-alloy and stainless steel

components exposed to air, including bolting, flow elements, pipe, pumps, spray nozzles, tubing,

and valve component types. Air is not identified in the GALL Report as an environment for these

components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or an air-conditioned enclosure or room). Significant corrosion of low-alloy steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, therefore, low-alloy steel components will

experience insignificant amounts of corrosion, and no aging effects would be applicable to this

component/commodity group. Wrought austenitic stainless steel is not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

concurs with the applicant's conclusions that there are no applicable aging effects requiring

management for metal in an air environment.

In the LRA, the applicant proposed to manage loss of material of stainless steel flow elements,

pipe, pump, tubing, and valve component types exposed to chemically treated borated water

using only MPS AMP B2.1.5, "Chemistry Control for Primary Systems Program," which is

consistent with GALL AMP XI.M2, "Water Chemistry," with an exception. The staff reviewed the

chemistry control for primary systems program, and its evaluation is documented in Section

3.0.3.2.2 of this SER. The exception relates to use of a later, non-NRC-approved revision of the

EPRI guidelines. The staff finds that because the effects of pitting and crevice corrosion on

stainless steel components are not significant in chemically treated borated water, inspection of

selected components to confirm the absence of loss of material is not required. On the basis of

its review, the staff finds this program to be acceptable for managing the aging effects for the

above components.

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In the LRA, the applicant proposed to manage loss of material of stainless steel pipe exposed

externally to a damp soil environment using MPS AMP B2.1.4, "Buried Piping Inspection

Program." The applicant stated that this program is consistent with GALL AMP Xl.M28, "Buried

Piping and Tanks Surveillance," and GALL AMP XI.M34, uBuried Piping and Tanks Inspection,"

with exceptions and enhancements. The staff reviewed the Buried Piping Inspection Program,

with the exceptions and enhancements, and its evaluation is documented in Section 3.0.3.2.1 of

this SER. The staff finds that this program includes a baseline inspection of a representative

sample of piping with different protective measures and inspections of buried components when

piping is excavated during maintenance or for any other reason. On the basis of its review, the

staff finds that the program is acceptable for managing loss of material of stainless steel pipe in

a damp soil external environment.

In the LRA and the LRA supplement letter dated January 11, 2005, the applicant proposed to

manage (1) loss of material of stainless steel restricting orifice component types exposed

externally to a moisture-laden air and/or intermittently wetted environment and (2) loss of loss of

material of stainless steel refueling water coolers (channel head) using MPS AMP B2.1.13,

'General Condition Monitoring." This is a plant-specific program. The staff reviewed the general

condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER.

On the basis of its review, the staff finds that the general condition monitoring program is

acceptable for managing loss of material due to pitting and crevice corrosion since visual

inspections will be performed on external surfaces to detect any sign of aging degradation.

3.2B.2.3.3 Safety Injection - Aging Management Evaluation - Table 3.2.2-3 and Table 3.2.2-3a

The staff reviewed Table 3.2.2-3 of the LRA and Table 3.2.2-3a in the applicant's letter dated

January 11, 2005, which summarized the results of AMR evaluations for the safety injection (SI)

system component groups.

The applicant, in the LRA and in the applicant's letter dated January 11, 2005, identified no

aging effect for carbon steel, cast iron, stainless steel, and CASS components exposed to air,

including filters/strainers, flow elements, pipe, pumps, restricting orifices, SI accumulator tanks

(carbon steel with stainless steel cladding), SI pump lube oil coolers (shell), SI pump lube'oil

reservoirs, tubing, valve, and hydro test pump component types. Air is not identified in the GALL

Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Significant corrosion of carbon steel in an ambient air environment also requires the components

to be subject to condensation. Without the presence of the aggressive environment, therefore,

carbon steel components will experience insignificant amounts of corrosion, and no aging effects

would be applicable to this component/commodity group. Wrought austenitic stainless steel and

CASS are not susceptible to significant general corrosion that would affect the intended function

of components. The staff finds that it did not identify any concerns with the applicant's

conclusions that there are no applicable aging effects requiring management for metal in an air

environment.

3-233
In the LRA, the applicant proposed to manage loss of material of stainless steel pipe exposed

externally to a damp soil environment using MPS AMP B2.1.4, "Buried Piping Inspection

Program." The applicant stated that this program is consistent with GALL AMP XL.M28, "Buried

Piping and Tanks Surveillance," and GALL AMP XI.M34, "Buried Piping and Tanks Inspection,"

with exceptions and enhancements. The staff reviewed the Buried Piping and Tanks Inspection,

with the exceptions and enhancements, and its evaluation is documented in Section 3.0.3.2.1 of

this SER. The staff finds that this program includes a baseline inspection of a representative

sample of piping with different protective measures and inspections of buried components when

piping is excavated during maintenance or for any other reason. On the basis of its review, the

staff finds that this program is acceptable for managing loss of material of stainless steel pipe

exposed externally to a damp soil environment.

The applicant, in the LRA, has identified no aging effect for carbon and stainless steel

components exposed internally to gas, including pipe, SI accumulator tanks (carbon steel with

stainless steel cladding), and valve component types. Gas is not identified in the GALL Report

as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (which is similar to air) on metal will not result in aging that

will be of concern during the period of extended operation. Therefore, the staff concurs with the

applicant's conclusion that there are no applicable aging effects requiring management for metal

in a gas environment.

In the LRA, the applicant proposed to manage loss of material of stainless steel SI pump lube oil

coolers (channel head) component types exposed to atmosphere/weather using MPS AMP

B2.1.13, "General Condition Monitoring." This is a plant-specific program. The staff reviewed the

general condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of

this SER. On the basis of its review, the staff finds that the general condition monitoring program

is acceptable for managing loss of material due to pitting and crevice corrosion since visual

inspections will be performed on external surfaces to detect any sign of aging degradation.

In the LRA, the applicant proposed to manage loss of material of carbon steel, cast iron, and

stainless steel filter/strainer, SI pump lube oil coolers (shell), SI pump lube oil coolers (tubes), SI

pump lube oil coolers (tube sheet), and SI pump lube oil reservoirs component types exposed

internally to oil, and in some cases externally to oil, using MPS AMP B2.1.25, "Work Control

Process." The staff reviewed the work control process program and its evaluation is documented

in Section 3.0.3.3.4 of this SER. The staff finds that visual inspections of internal surfaces of

components are performed during the performance of maintenance to determine the presence

of loss of material. Oil samples are analyzed periodically for contaminants that would indicate

degradation. On the basis of its review, the staff finds that the program is acceptable for

managing loss of materials for the above components.

In the LRA, the applicant proposed to manage loss of materials of copper alloy SI pump lube oil

coolers (tubes) component types in an environment of treated closed-cycle cooling water using

MPS AMP B2.1.7, "Closed-Cycle Cooling Water System." The Closed-Cycle Cooling Water

(CCCW) system program is consistent with GALL AMP XI.M21, "Closed-Cycle Cooling Water

Systems," with an exception. The staff reviewed the CCCW system program, with the exception,

and its evaluation is documented in Section 3.0.3.2.4 of this SER. On the basis of its review, the

staff finds that this program, with the exception, is acceptable for managing loss of material of

components in the treated water environment that are serviced by the CCCW system.

I

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3-234
3.2B.2.3.4 Residual Heat Removal - Aging Management Evaluation 'Table 3.2.2-4

The staff reviewed Table 3.2.2-4 of the LRA, which summarizes the results of AMR evaluations

in the SRP-LR for the residual heat removal systerm component groups.

The applicant, in the LRA; identified no aging effect for carbon steel, stainless steel, and CASS

components exposed to air, including flow elemnrits,"pipe, pumps, residual heat removal (RHR)

heat exchangers (channel head), tubing, and valve component types. Air is not'identified in the

GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical'of ambient air (e:g., under a

shelter, indoors, or an air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Significant corrosion of carbon steel in an ambient air'environment also requires the components

to be subject to condensation. Without the presence of the aggressive environment, therefore,

carbon steel components will experience insignificant amounts of corrosion, and no aging effects

would be applicable to this componentIcommodity group. Wrought austenitic stainless steel and

CASS are'not susceptible to significant general corrosion that would affect the intended function

of components. Therefore, the staff concurs with the applicant's conclusion that there are' no

applicable aging effects requiring management for metal in an air environment:

In the LRA, the applicant proposed to manage loss of material of stainless steel residual heat

removal heat exchanger (tubes) component types exposed internally to treated water using MPS

AMP B2.1.25, "Work Control Process." The staff reviewed the work control process program and

its evaluation is documented in Section 3.0.3.3.4 of this SER. The staff finds that visual

inspections of the internal surfaces of plant components and plant commodities are performed

during the performance of maintenance, in accordance with the work control process program,

to determine the presence of loss of material. On the basis of its review, the staff finds that the

work control process program is acceptable for managing loss of material since visual

inspections will be performed on internal surfaces of components to detect any sign of aging

degradations

3.2B.2.3.5 Fuel Pool Cooling and Purification -Table 3.2.2-5 and Table'3.2.2-5a

The staff reviewed Table 3.2.2-5 of the LRA and Table 3.2.2-5a in the applicant's letter dated

January 11, 2005, which summarized the results of AMR evaluations for the fuel pool cooling

and purification system component groups.

The applicant, in the LRA and the applicant's supplement dated January 11, 2005, identified no

aging effect for low-alloy and stainless steel components exposed to air, including bolting, flow

elements, fuel pool coolers (channel head), pipe, pumps, tubing, valve, fuel pool demineralizer,

fuel pool post filter, and strainers component types. Air is not identified in the GALL Report as an

environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or an air-conditioned enclosure or room). Therefore, the staff concurred with the

3-235
applicant's conclusion that there are no applicable aging effects requiring management for metal

in an air environment.

In the LRA, the applicant proposed to manage loss of material of stainless steel flow elements

and fuel pool coolers (channel head) component types exposed to chemically treated borated

water using only MPS AMP B2.1.5, "Chemistry Control for Primary Systems Program," which is

consistent with GALL AMP XI.M2, "Water Chemistry," with an exception. The staff reviewed the

Chemistry control for primary systems program and its evaluation is documented in Section

3.0.3.2.2 of this SER. The exception relates to use of a later, non-NRC-approved revision of the

EPRI guidelines. The staff finds that because the effects of pitting and crevice corrosion on

stainless steel components are not significant in chemically treated borated water, inspection of

selected components to confirm the absence of loss of material is not required. On the basis of

its review, the staff finds this program to be acceptable for managing the aging effects for the

above components.

All other AMRs in Tables 3.2.2-1 through 3.2.2-5 were evaluated. The staff finds them to be

acceptable.

Conclusion. On the basis of its review, the staff finds that the applicant appropriately evaluated

AMR results involving material, environment, aging effect requiring management, and AMP

combinations that are not evaluated in the GALL Report or not addressed in the GALL Report.

The staff finds that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the period

of extended operation, as required by 10 CFR 54.21 (a)(3).

3.2B.3 Conclusion

On the basis of its review, the staff concludes that the applicant has demonstrated that the aging

effects associated with the ESF systems components will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable FSAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the engineering safety

features systems, as required by 10 CFR 54.21(d).

3.3 Aging Management of Auxiliary Systems

3.3A Unit 2 Aging Management of Auxillary Systems

This section of the SER documents the staffs review of the applicant's AMR results for the

Unit 2 auxiliary systems components and component groups associated with the following

systems:

* circulating water system

* screen wash system

* service water system

* sodium hypochlorite system

* reactor building closed cooling water system

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* chilled water system

* instrument air system

* nitrogen system

* station air system

* chemical and volume control system

* sampling system.

* primary makeup water system

* access control area air conditioning system

* main condensers evacuation system

* containment air recirculation and cooling system,

* containment and enclosure building purge system

* containment penetration cooling system:,

* containment post-accident hydrogen control system

* control room air conditioning system

* control element drive mechanism cooling system

* ,diesel generator ventilation system

* engineered safety features (ESF) room air recirculation system

* enclosure building filtration system

* fuel handling area ventilation system

* main exhaust ventilation system - .i

* ,non-radioactive area ventilation system

* process and area radiation monitoring system

* radwaste area ventilation system

* turbine building ventilation system

* vital switchgear ventilation system

* Unit 2 fire protection system

* Unit 3Afire protection system -

* domestic water system

* diesel generator system

* diesel generator fuel oil system

* station blackout (SBO) diesel generator system

* ,security system

* clean liquid waste processing system

* gaseous waste processing system

* post-accident sampling system

* station sumps and drains system - i-

* turbine building closed cooling water system

3.3A.1 Summary of Technical Information In the Application

In LRA Section 3.3, the applicant provided AMR results for auxiliary systems components and

component groups. In LRA Table 3.3.1, "Summary of Aging Management Evaluations in Chapter

VII of NUREG-1 801 for AuxiliarySystems,".the applicant provided a summary comparison of its

aging management reviews (AMRs) with the AMRs evaluated in the Generic Aging Lessons

Learned (GALL) report for the auxiliary systems'components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

aging effects requiring management (AERMs).-These reviews included evaluation of plantspecific and industry operating experience.' The plant-specific evaluation included reviewsof

condition reports and discussions with appropriate site personnel to identify AERMs. The

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applicant's review of industry operating experience included a review of the GALL Report and

operating experience issues identified since the issuance of the GALL Report.

3.3A.2 Staff Evaluation

The staff reviewed LRA Section 3.3 to determine if the applicant provided sufficient information

to demonstrate that the effects of aging for the auxiliary system components that are within the

scope of license renewal and subject to an AMR will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

Also, the staff performed an onsite audit to confirm the applicant's claim that certain identified

AMRs were consistent with the GALL Report. The staff did not repeat its review of the matters

described in the GALL Report. However, the staff did verify that the material presented in the

LRA was applicable and that the applicant had identified the appropriate GALL aging

management programs (AMPs). The staffs evaluations of the AMPs are documented in Section

3.0.3 of this SER. Detail of the staffs audit evaluations are documented in the staffs MPS audit

and review report and summarized in Section 3.3A.2.1 of this SER.

The staff also performed an onsite audit of those AMRs that were consistent with the GALL

Report and for which further evaluation is recommended. The staff verified that the applicant's

further evaluations were consistent with the acceptance criteria in Section 3.3.2.2 of

NUREG-1 800, 'Standard Review Plan for Review of License Renewal Applications for Nuclear

Power Plants," dated July 2001. The staffs audit evaluation are documented in the staffs MPS

audit and review report and summarized in Section 3.3A.2.2 of this SER.

The staff performed an onsite audit conducted a technical review of the remaining AMRs that

were not consistent with or not addressed in the GALL Report The audit and technical review

included evaluating whether all plausible aging effects were identified and whether the aging

effects listed were appropriate for the combination of materials and environments specified. The

staffs audit evaluations are documented in the staffs MPS audit and review report and

summarized in Section 3.3A.2.3 of this SER. The staffs evaluation of its technical review is also

documented in Section 3.3A.2.3 of this SER.

Finally, the staff reviewed the AMP summary descriptions in the FSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the auxiliary system components.

Table 3.3A-1 below provides a summary of the staffs evaluation of components, aging

effectstmechanisms, and AMPs listed in LRA Section 3.3 that are addressed in the GALL

Report.

Table 3.3A-1 Staff Evaluation for Auxiliary System Components In the GALL Report

.L .n ;L.A.. -- P 

Comononft Group,-- Effotu: sAMP AP.Aging IGALL.-. :AMPhinFRAN s:. -- v

, ,,-.,..--...,.- ec anl sm .' :: p ~^ , --;*w

Components in Loss of material due Water chemistry Not applicable (See

spent fuel pool to general, pitting, and one time Section 3.3A.2.2.1)

cooling and cleanup and crevice inspection .

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Componeit Group x Aglng Sin S ffe - GALLS AMP in LR _Staff Evlu tioni

-, --. Mchanism - §R''''''''t ' ''''''- '.

Unings in spent fuel Hardening, cracking Plant-specific Work control process Consistent with

cooling and cleanup and loss of strength (82.1.25); General GALL (See Section

system; seals and due to elastomer condition monitoring 3.3A.2.2.2)

collars in ventilation degradation; loss of. (62.1.13)

systems material due to wear

(Item Number

3.3.1-02)

Components in load Cumulative fatigue TLAA, evaluated TLAA This TLAA is

handling, chemical damage in accordance with evaluated in Section

and volume control 10 CFR 52.21(c) 4.3A, Metal Fatigue

system (PWR), and

reactor water

cleanup and

shutdown cooling

systems (older

BWR)

(Item Number

3.3.1-03)

Heat exchangers in Crack initiation and Plant-specific Consistent with

reactor water growth due to SCC GALL (See Section

cleanup system or cracking 3.3A.2.2A)

(BWR); high

pressure pumps in

chemical and

volume control

system (PWR) (Item

Number

3.3.1-04) l

Components in Loss of material due Plant-specific General condition Consistent with

ventilation systems, to general, pitting, monitoring (62.1.13); GALL, which

diesel fuel oil and crevice Fire protection recommends further

system, and corrosion, and MIC program (82.1.10); evaluation (See

emergency diesel Work control process Section 3.3A.2.2.5)

generator systems; (82.1.25); Tank

external surfaces of inspection program

carbon steel (82.1.24);

components Structures monitoring

(Item Number program (82.1.23);

3.3.1-05) Infrequently accessed

areas inspection

;__ - program (B2.1.15)

Components in Loss of material due One-time Tank inspection Consistent with

reactor coolant to galvanic, general, inspection program (82.1.24); GALL (See Section

pump oil collection pitting, and crevice Work control process 3.3A.2.2.6)

system of fire corrosion (82.1.25)

protection

(Item Number

3.3.1-06)

3-239
j

Component'Group ' Agig Effec -I -AiP in GALL if AMP inL - iStaff EiW uatlo

an : Rpor-t -- i*4-R -' -;

Diesel fuel oil tanks Loss material due to Fuel oil chemistry Fuel oil chemistry Consistent with

in diesel fuel oil general, pitting, and and one-time program (B2.1.12), GALL, which

system and crevice corrosion, inspection Work control process recommends further

emergency diesel MIC, and biofouling (B2.1.25) Tank evaluaton(See

generator system inspection program Section 3.3A.2.2.7) (Item Number (B2.1 .24) 3.3.1-07) (B2.1.24)

Heat exchangers in Crack initiation and Water chemistry .Chemistry control for Consistent with

chemical and growth due to SCC and plant-specific primary systems GALL, which

volume control and cyclic loading verification program (B2.1.5), recommends further

system program Work control process evaluation (See

(Item Number (B2.1.25) Section 3.3A.2.2.9)

3.3.1-09) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

Neutron absorbing Reduction of Plant-specific Not applicable (See

sheets in spent fuel neutron absorbing Secton 3.3A.2.2.1 0) storage racks capacity and loss of

(Item Number material due to

3.3.1-10) general corrosion

(Boral, boron steel)

New fuel rack Loss of material due Structures Not consistent with

assembly to general. pitting monitoring GALL (See Section

(Item Number and, crevice 3.5A.2.3.4) 3.3.1-11) corrosion

The new fuel rack

assembly Is

fabricated from

stainless steel. No

aging effect

management is

required for the

stainless steel fuel

rack assembly.

Neutron absorbing Reduction of Boraflex Boraflex monitoring Consistent with

sheets in spent fuel neutron absorbing monitoring (B2.1.2) GALL, which

racks capacity due to recommends no

(Item Number Boraflex further evaluation

3.3.1-12) degradation (See Section

___ 3.3A.2.1)

Spent fuel storage Crack initiation and Water chemistry Not consistent with

racks and valves in growth due to stress GALL. The spent

spent fuel pool corrosion cracking fuel pool water

cooling and cleanup temperature is

(Item Number maintained below

3.3.1-13) the threshold

temperature of 140

degree F for SCC.

Closure bolting and Loss of material due Boric acid Boric acid corrosion Consistent with

external surfaces of to boric acid corrosion (B2.1.2); GALL (See Section

carbon steel and corrosion General condition 3.3A.2.1.1)

low-alloy steel monitoring (B2.1.13)

components

(Item Number

3.3.1-14)

3-240
Com'pnent Group -_Aging Effect A--MP InGALL' -' MP in LRA -;f -Staff Eva tion'

'--': -<- '" i;.<-Mechanism<Ar>r- : ;-" -- : ;;'':

Components in or Loss of material due Closed-cycle Closed-cycle cooling Consistent with

serviced by closed- to general, pitting, cooling water 'water system GALL, which

cycle cooling water and crevice system (B2.1.7); recommends no

system corrosion, and MIC Work control process further evaluation"

(Item Number (62.1 .25); - -- - (See Section

3.3.1-15) Chemistry control for 3.3A.2.1) primary systems'

program (B2.1.5);

Chemistry control for

secondary systems

program (62.1.6)

Cranes, including Loss of material due Overhead heavy Inspection activities: ' Consistent with

bridge and trolleys, to general corrosion load and light load load handling cranes 'GALL, which

and rail system in' and wear handling systems and devices (82.1.19) recommends no

load handling - further evaluation

system (See Section

(item Number 3.3A.2.1)

3.3.1-16) -

Components In or Loss of material due Open-cycle Service water system Consistent with

serviced by open- to general, pitting, cooling water (open-cycle cooling) GALL, which ' cycle cooling water crevice, and system (62.1.19); recommends no

systems galvanic corrosion. Work control process further evaluation'

(Item Number MIC, and boifouling; (B2.1.25); (See Section

3.3.1-17) buildup of deposit Closed-cycle cooling 3.3A.2.1.3) due to biofouling water system (B2.1.7)

Buried piping and Loss of material due Buried piping and Buried piping Consistent with

fittings to general, pitting, tank surveillance inspection (B2.1.4) GALL, which"

(item Number and crevice ' recommends further

3.3.1-18) corrosion, and MIC or evaluation (See

Section 3.3A.2.2.11) Buried piping and

tanks inspection

Components in Loss of material due Compressed air Work control process Consistent with

compressed air to general and monitoring (B2.1.25) GALL (See Section

system pitting corrosion '3.3A.2.1) (item Number

3.3.1-19) . . .

Components (doors Loss of material due Fire protection Fire protection Consistent with

and barrier to wear; hardening . program (B2.1.10); GALL (See Section

penetration seals) in and shrinkage due '*. Work control process 3.3A.2.1 .4)

concrete structures to weathering 2 .. (B2.1.25) in fire protection ( 3 12.

(Item Number

3.3.1-20) . ' :

Components In Loss of material due Fire water system Fire protection Consistent with

water-based fire to general, pitting, program (62.1.10); GALL (See Section

protection crevice, and Work control process 3.3A.2.1)

(item Number galvanic corrosion, (B2.1.25) ; Tank

3.3.1-21) MIC, and biofouling inspection program

(62.1.24)

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Comp~nonenGrou p. Eff ct' AM P-Agin -n GALL - AP InLRA taff luatlo! .-. ' Mehin anlism:.... i Repor:;- .- -; *

Components in Loss of material due Fire protection and Fuel oil chemistry Consistent with

diesel fire system to galvanic, general, fuel oil chemistry (B2.1.12) GALL (See Section

(Item Number pitting, and crevice 3.3A.2.1)

3.3.1-22) corrosion

Tanks in diesel fuel Loss of material due Above ground Tank inspection Consistent with

oil system to general, pitting, carbon steel tanks program (B2.1.24) GALL, which

(Item Number and crevice recommends no

3.3.1-23) corrosion further evaluation

(See Section

3.3A.2.1)

Closure bolting Loss of material due Bolting integrity Bolting integrity Consistent with

(Item Number to general GALL (See Section

3.3.1-24) corrosion; crack 3.3A.2.1) initiation and growth

due to cyclic loading

and SCC

Components Loss of material due Selective leaching Work control process Consistent with

(aluminum, bronze, to selective leaching of materials (B2.1.25); Buried GALL (See Section

brass, cast iron, piping inspection 3.3A.2.1.5)

cast steel) in open- (B2.1.4)

cycle and closedcycle cooling water

systems, and

ultimate heat sink

(Item Number

3.3.1-29)

Fire barriers, walls, Concrete cracking Fire protection and Not consistent with

ceilings, and floors and spalling due to structures GALL (See Section

in fire protection freeze-thaw, monitoring 3.5A.2.3.26)

(Item Number aggressive chemical

3.3.1-30) attack, and reaction

with aggregates; loss of material due

to corrosion of

embedded steel

The staffs review of the MPS auxiliary systems and associated components followed one of

several approaches. One approach, documented in Section 3.3A.2.1, involves the staffs review

of the AMR results for components in the auxiliary systems that the applicant indicated are

consistent with the GALL Report and do not require further evaluation. Another approach,

documented in Section 3.3A.2.2, involves the staffs review of the AMR results for components

in the auxiliary systems that the applicant indicated are consistent with the GALL Report and for

which further evaluation is recommended. A third approach, documented in Section 3.3A.2.3,

involves the staffs review of the AMR results for components in the auxiliary systems that the

applicant indicated are not consistent with the GALL Report or are not addressed in the GALL

Report. The staffs review of AMPs that are credited to manage or monitor aging effects of the

auxiliary systems components is documented in Section 3.0.3 of this SER.

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3.3A.2.1 AMR Results That are Consistent with the GALL Report, for Which Further

Evaluation is Not Recommended

Summary of Technical Information in the ADolication. In Sections 3.3.2.1.1 through 3.3.2.1.41 of

the LRA, the applicant identified the materials, environments, and aging effects requiring

management. The applicant identified the following programs that manage the aging effects

related to the auxiliary systems components:

* general condition monitoring program

* work control process program * boric acid corrosion program

* buried pipe inspection program

* infrequently accessed areas inspection program

* service water system (open-cycle cooling) program

* closed-cycle cooling water system program

* chemistry control for primary systems program

* chemistry control for secondary systems program

* inservice inspection program: systems, components and supports program

* fire protection program

* tank inspection program

* fuel oil chemistry program * -bolting integrity program

Staff Evaluation. In Tables 3.3.2-1 through 3.3.2-41 of the LRA, the applicant provided a

summary of AMRs for the auxiliary systems components and identified which AMRs it

considered to be consistent with the GALL Report. '

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item: The notes described how the information

in the tables aligns with the information in the GALL'Report. The staff audited those AMRs with

Notes A through E, which indicated the AMR was'consistent with the GALL Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by the

applicant was consistent with the AMP identified in the GALL Report and whether the AMR was

valid for the site-specific conditions.

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Note C indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP is consistent

with the AMP identified by the GALL Report. This note indicates that the applicant was unable to

find a listing of some system components in the GALL Report. However, the applicant identified

a different component in the GALL Report that had the same material, environment, aging

effect, and AMP as the component that was under review. The staff audited these line items to

verify consistency with the GALL Report. The staff also determined whether the AMR line item of

the different component was applicable to the component under review and whether the AMR

was valid for the site-specific conditions.

Note D indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP takes some

exceptions to the AMP identified in the GALL Report. The staff audited these line items to verify

consistency with the GALL Report. The staff verified whether the AMR line item of the different

component was applicable to the component under review. The staff verified whether the

identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The staff

also determined whether the AMP identified by the applicant was consistent with the AMP

identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note E indicated that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified by

the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the LRA, as documented

in its MPS audit and review report. The staff did not repeat its review of the matters described in

the GALL Report. However, the staff did verify that the material presented in the LRA was

applicable and that the applicant had identified the appropriate GALL Report AMRs. The staff

evaluation is discussed below.

3.3A.2.1.1 Loss of Material Due to Boric Acid Corrosion

In the discussion section of LRA Table 3.3.1, Item 3.3.1-14, the applicant stated that loss of

material due to boric acid corrosion is managed by MPS AMP B2.1.3, " Boric Acid Corrosion

Program;" and MPS AMP B2.1.13, "General Condition Monitoring Program." The boric acid

corrosion program includes specific inspections of reactor coolant pressure boundary and

supporting systems components. The boric acid corrosion program is evaluated in Section 3 of

this SER.

In the LRA, the applicant stated that the general condition monitoring program provides

inspections for management of loss of material due to boric acid corrosion beyond the scope of

the boric acid corrosion program. During the audit, the staff asked the applicant for clarification

on how loss of material for components not normally visible, or in infrequently accessed areas

are managed by this program. During the audit, further clarification was requested on how

identification, documentation, evaluation, and trending of boric acid leakage is performed under

this program. During the audit, the applicant stated that the general condition monitoring

program is an extension of the boric acid corrosion program in that the general condition

monitoring program identifies borated water leakage during inspections and then, through the

corrective action program, the leak is assigned and evaluated by the boric acid corrosion

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program. When borated water leakage is identified by the general condition monitoring program,

a condition report is written to identify the leak. During the daily review of the new condition

reports, it is assigned to the boric acid corrosion program where it gets fully evaluated and

repaired as required. This is the same process used to identify leaks in the boric acid corrosion

program.

For those areas identified as infrequently accessed areas, for the purposes of detecting boric

acid leakage, entry into the area is performed often enough (at least once per refueling interval)

to credit the general condition monitoring program. No infrequently accessed areas with systems

containing borated water are identified by the applicant.

The staffs evaluation of the general condition monitoring program is documented in Section

3.0.3.3.2 of this SER. On the basis of its review, the staff finds that this program is acceptable

for managing loss of material since visual inspection of external surfaces is performed during

various walkdowns performed by plant personnel to look for boron buildup and/or boric acid

leaks.

3.3A.2.1.2 Loss of Material Due to General, Pitting, and Crevice Corrosion, and MIC

In LRA Table 3.3.2-30 (page 3-274), the applicant listed both MPS AMP B2.1.25, 'Work Control

Process," and MPS AMP B.2.1.7, "Closed Water Cooling Systems," for loss of material exposed

intemally to treated water for the DC switchgear cooling coils. During the audit and review; the

applicant was asked to clarify which AMP is credited. In LRA supplement dated July 7, 2004, the

applicant stated that AMP B2.1.25, uWork Control Process," was inadvertently listed as an AMP

for managing loss of material in treated water environment for the DC switchgear air conditioning

unit cooling coils component group. The staff reviewed the applicant's response and based on

the clarification provided, finds it acceptable.

3.3A.2.1.3 Loss of Material Due to General, Pitting, and Galvanic Corrosion, MIC, and

Biofouling; Buildup of Deposit Due to Biofouling

In the discussion section of LRA Table 3.3.1, Item 3.3.1-17 (page 3-195), the applicant stated

that loss of material for components in an open-cycle cooling water environment is managed by

AMP B2.1.21, 'Service Water System (Open-Cycle Cooling) Program." However, Item 3.3.1-17

does not address buildup of deposits as an aging effect managed by the service water system

(open-cycle cooling) 'program'for the heat exchanger tubes and lined piping in a seawater

environment. In an LRA supplement dated July 7, 2004, the applicant stated that in

LRA Table 3.3.1, Item 3.3.1-17, the first sentence in the discussion should include "and Buildup

of Deposits" after "Loss of Material." The staff reviewed the applicant's response and finds it

acceptable.

3.3A.2.1.4 Loss of Material Due to Wear, Hardening and Shrinkage

In the discussion section of LRA Table 3.3.1, Item 3.3.1-20, the applicant stated that loss of

material due to wear is not an applicable aging effect for components (doors and barrier

penetration seals) in the fire protection system. Fire doors could see wear on hinges, locks, etc.,

due to periodic opening and closing. This could cause loss, of material and impact on the

intended function of fire doors. During the audit and review, the staff asked the applicant to

provide justification as to why this aging effect was not included. The applicant stated that fire

doors are passive features to seal passageways through fire-rated barriers. Fire doors are

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equipped with hardware and attachmentlclosure devices that perform their intended function

with moving parts and/or change of configuration and are considered to be active components.

As such, wear of the hardware, appurtenances, and attachment/closure mechanisms is not

considered to be an aging effect, but rather a consequence of frequent or rough usage. The

applicant restated that the conclusions in the LRA remain valid and unchanged. However, the

applicant initiated revisions to the technical report for miscellaneous structural commodities to

incorporate the above evaluation for wear of the hinges and locks for the fire doors. Based on

the fact that these components are active components, the staff finds the response acceptable.

3.3A.2.1.5 Loss of Material Due to Selective Leaching

In the discussion section of LRA Table 3.3.1, Item 3.3.1-29, the applicant stated that loss of

material due to selective leaching is managed using MPS AMP B2.1.25, "Work Control Process,"

and MPS AMP B2.1.4, "Buried Pipe Inspection Program." The applicant stated that these two

programs are not consistent with GALL AMP Xl.M33, "Selective Leaching," in that the GALL

program recommends a one-time visual inspection and hardness measurement of selected

components that may be susceptible to selective leaching to determine whether loss of material

due to selective leaching is occurring, and whether the process will affect the ability of the

components to perform their intended function for the period of extended operation. However,

the work control process program and the buried pipe inspection program perform only routine

visual inspection (which is more than a one-time inspection) when the opportunity arises, but do

not perform hardness testing.

Since selective leaching generally does not cause changes in dimension and is difficult to detect

by visual inspection alone, the staff asked the applicant to justify the use of visual inspection

only, or provide other means of detection (Brinnell hardness, destructive testing) or other

mechanical means (scraping, chipping, etc.). The staff's evaluation of the applicant's response is

documented in the evaluation of the work control process program and the buried pipe

inspection program in Sections 3.0.3.3.4 and 3.0.3.2.1 of this SER, respectively.

In the AMP technical report for the work control process program, the applicant stated that

selective leaching is an aging mechanism that causes an aging effect of change in material

properties. However, in the technical report of AMR results for the closed water system, the

applicant stated that selective leaching is an aging mechanism under the aging effect of loss of

material. The technical report for material aging effects considers selective leaching under loss

of material. The staff noted there is a discrepancy as to how selective leaching is considered

between the AMP and the AMR technical reports.

During the audit and review, the applicant was requested by the staff to provide a rationale for

considering selective leaching as causing change in material properties, which is generally an

aging effect associated with non-metallic, elastomer type materials. The applicant concurred that

all technical reports should have associated selective leaching with the aging effect of loss of

material. The staff reviewed the change document to the affected technical reports, which

identified the change to include selective leaching under the "loss of material" aging effect. On

the basis of its review, the staff finds this acceptable.

In an LRA supplement dated July 7, 2004, the applicant stated that LRA Table 3.3.2-32 (pages

3-286 through 3-297) should state, "3.3.1-29" for the second Table 1 Item' listed for components

with cast iron/raw water and copper alloy/raw water material/environment combinations. The

'NUREG-1801 Volume 2 Item' column for the affected component groups should be "VIL.CI.2-a"

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except for the 'Pipe' and 'Tubing' component groups, which should be "VII.C1.1-a." The staff

reviewed the applicant's response and finds that it is acceptable.

In LRA Table 3.3.2-41 (page 3-333), for the station sumps and drains system, and for loss of

material of cast iron pumps and copper alloy valve components in a raw water environment, the

applicant referenced LRA Table 3.3.1, Item 3.3.1-17. Item 3.3.1-17 only addressed loss of

material due to miscellaneous corrosion, but not selective leaching. During 'the audit and review,

the applicant was requested to provide a rationale for'not considering loss of material due to

selective leaching. In an LRA supplement dated July 7, 2004, the applicant stated that Unit 2

LRA Table 3.3.2-41 should contain additional information for the component groups 'pumps'

(cast iron/raw water) and 'valves' (copper alloy/raw water). Specifically, each component group

should have an additional entryforthe 'Aging Management Program,"NUREG-1801 Volume 2

Item,' Table 1 Item,' and 'Notes' columns which adds the entries "Work Control Process,"

'VII.C1.5-a".for pumps and "VII.C1.2-a" for valves, "3.3.1-29," and "E," respectively. Because the

applicant concurred that LRA Table 3.3.1, Item 3.3.1-29 is applicable, the staff finds the

response acceptable.

During the audit and review,' the staff questioned why various portions of the fire protection

system and diesel generator system were not included within the scope of license renewal and

subject to an AMR. In its LRA supplement letter dated July 7, 2004, the applicant added several

components 'in the fire protection system and diesel generator system that are subject to an

AMR. The addition of these components did not result in the addition of material/environment

combinations or AMPs for the fire protection system and diesel generator system AMR. The staff

finds this material/environment/aging effect/AMP combination to be acceptable. The staff's

evaluation of the scope of the fire protection system and diesel generator system' is documented'

in Section 2.3A.3.32 and Section 2.3A.3.34, respectively, of this SER.

3.3A.2.1.6 Loss of Material Due to General Corrosion; Crack Initiation and Growth Due to Cyclic

Loading and Stress Corrosion Cracking

In the discussion section of LRA Table 3.3.1, Item 3.3.1-24, the applicant stated that closure

bolting in the auxiliary systems is not subject to wetted conditions, therefore, loss of material due

to general corrosion is not expected. Additionally, cracking for bolting in auxiliary systems is not

identified as an AERM.:

During the review, the staff noted that SRP-LR Table 3.3-1 recommended GALL AMP XL.M18,

"Bolting Integrity," for managing closure bolting for loss of material due to general corrosion;

crack initiation and growth due to cyclic loading and/or SCC.

The staff questioned the applicant whether all of the resolutions of the generic safety issue for

bolting, as stated in NUREG-1339,-are addressedd.By letter dated December 3, 2004, the

applicant submitted its LRA supplement. In its 'response, the applicant stated that it has

developed a specific bolting integrity aging management program that addresses degradation of

bolting at MPS. The bolting integrity program is reviewed in Section 3.0.3.2.18 of this SER.

By letter dated January 11, 2005, the applicant submitted its bolting aging management roll-up

item. In its response, the applicant replaces the existing information in the "Discussion" column

of LRA Table 3.3.1, Item 24 with "consistent with NUREG-1 801."

.... , ; -. . '- :

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The staff reviewed the applicant's response and finds this acceptable since it is consistent with

the GALL Report.

Staff RAls Pertaining to Recent Operating Experience and Emerging Issues. Because the GALL

Report and SRP-LR were issued in July 2001, these documents do not reflect the most current

recommendations for managing certain aging effects that have been the subject of recent

operating experience or the topic of an emerging issue. As a result, the staff determined that

additional information was required related to the boric acid corrosion. The applicant's responses

and the staff evaluation of the responses are described below.

The LRA identifies a borated water leakage environment for various mechanical components in

auxiliary systems. Both the boric acid corrosion program and general condition monitoring

program are credited with managing loss of material from external surfaces of these

components. The LRA states that the general condition monitoring program is performed in

accessible plant areas. The applicant was requested to clarify how loss of material is managed

for auxiliary system components not normally visible, such as under insulation or in normally

inaccessible areas. In addition, the LRA states that the boric acid corrosion program is

consistent with GALL AMP XI.M10. The scope of GALL AMP XI.M10 is limited to components in

the vicinity of the reactor coolant pressure boundary. However, it appears that the MPS boric

acid corrosion program is credited with managing loss of material caused by borated water

leakage in systems that may not be in the vicinity of the reactor coolant pressure boundary, such

as the radwaste area ventilation system. The applicant was requested to clarify this potential

discrepancy. If the scope of the Millstone Units 2 and 3 boric acid corrosion program is different

from the GALL XI.M1 0 program, the applicant was requested to revise the Millstone Units 2 and

3 program description accordingly in the AMP and FSAR supplement. Also the applicant was

requested in RAI 3.3-A-1 to identify the basis for applying the boric acid corrosion program to

manage boric acid corrosion in copper alloy and cast iron materials that are not addressed in

GALL AMP XL.MIO and may require a different inspection frequency.

In a response dated December 3, 2004, the applicant clarified that general equipment (or

materials) inspections are performed as often as daily. The applicant indicated that an

independent assessment was performed by the Institute of Nuclear Power Operations (INPO) in

August 2003 and boric acid leaks are captured in the station corrective action program. INPO

noted that the computer based training module has increased awareness of station employees

with regard to boric acid corrosion and minor program enhancements are being addressed

through the corrective action program.

The applicant stated that the following clarification will be added to Section A2.1.3, Boric Acid

Corrosion Program, of the LRA:

The Boric Acid Corrosion program provides both detection and analysis of leakage of

borated water inside containment. The General Condition Monitoring program is the

primary method for detecting borated water leakage outside containment. The analysis of

the leakage is performed through the boric acid corrosion program. Any necessary

corrective actions are implemented through the corrective action program.

The staff reviewed the applicant's response and determined that the response was reasonable

and acceptable because the applicant credits a combination of the general condition monitoring

program and the boric acid corrosion program to detect and evaluate borated water leakage and

boric acid corrosion to maintain the intended function of the auxiliary system components. For

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areas outside containment, general equipment (or materials) inspections are performed

frequently. The inspections would be expected to identify any borated water leakage and any

required subsequent evaluation. The applicant has agreed to include a clarification in the FSAR

supplement to indicate that the general condition monitoring program is the primary method for

detecting borated water leakage outside containment and the analysis of the leakage is

performed through the boric acid corrosion program with corrective'actions implemented through

the corrective action program.

On the basis of its audit and review, the staff determined that for AMRs not requiring further

evaluation, as identified in LRA Table 3.3.1 (Table 1), the applicant's references to the GALL

Report are acceptable and no further project team review is required.

The staff has evaluated the applicant's claim of consistency with GALL Report. The staff also

has reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects.' On the basis of its review, the

staff finds that the AMR results, which the applicant claimed to be consistent with the GALL

Report, are consistent with the AMRs in the GALL Report. Therefore, the staff finds that the

applicant has demonstrated that the effects of aging for these components will be adequately

managed so that their intended function(s) will be maintained consistent with the CLB for the

period of extended operation,; as required by 10 CFR 54.21(a)(3).-

3.3A.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Application. In LRA Section 3.3.2.2, the applicant

provides further evaluation of aging management as recommended by the GALL Report for

auxiliary systems. The applicant provided information concerning how it will manage the

following aging effects:

* loss of material due to general, pitting, and crevice corrosion

* hardening and cracking or loss of strength due to elastome'r degradation or loss of

material due to wear

* cumulative fatigue damage

* crack initiation and growth'due to cra6king or stress corrosion cracking

* -loss of material due to general, microbiologically influenced, pitting, and crevice corrosion

* ' loss of material due to general, galvanic, pitting, and crevice corrosion

* loss of material due to general, pitting, crevice, and microbiologically influenced corrosion

and biofouling

* quality assurance for aging management of non-safety-related components

* crack initiation and growth due to stress corrosion cracking and cyclic loading

* reduction of neutron-absorbing capacity and loss of material due to general corrosion

* loss of material due to general, pitting; crevice, and microbiologically influenced corrosion

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report,' and for which the GALL Report recommends

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further evaluation, the staff reviewed the applicant's evaluation to determine whether it

adequately addressed the issues that were further evaluated. In addition, the staff reviewed the

applicant's further evaluations against the criteria contained in Section 3.3.3.2 of the SRP-LR.

Details of the staffs audit and review are documented in the staff's MPS audit and review report.

The GALL Report indicates that further evaluation should be performed for the aging effects

described in the following sections:

3.3A.2.2.1 Loss of Material Due to General, Pitting, and Crevice Corrosion

The staff reviewed LRA Section 3.3.2.2.1 against the criteria in SRP-LR Section 3.3.2.2.1. In

LRA Section 3.3.2.2.1, the applicant addressed loss of material in components of the spent fuel

pool system.

SRP-LR Section 3.3.2.2.1 states that loss of material due to general, pitting, and crevice

corrosion could occur in the channel head and access cover, tubes, and tube sheets of the heat

exchanger in the spent fuel pool cooling and cleanup system. The water chemistry program

relies on monitoring and control of reactor water chemistry based on EPRI TR-1 05714

guidelines for primary water chemistry and TR-1 02134 for secondary water chemistry to manage*

the effects of loss of material from general, pitting, or crevice corrosion. However, high

concentrations of impurities at crevices and locations of stagnant flow conditions could cause

general, pitting, or crevice corrosion. Therefore, verification of the effectiveness of the water

chemistry control program should be performed to ensure that corrosion is not occurring. The

GALL Report recommends further evaluation of programs to manage loss of material from

general, pitting, and crevice corrosion to verify the effectiveness of the water chemistry program.

A one-time inspection of selected components at susceptible locations is an acceptable method

for ensuring that corrosion is not occurring and that the component's intended function will be

maintained during the period of extended operation.

Further, SRP-LR Section 3.3.2.2.1 states that loss of material due to pitting and crevice

corrosion could occur in the filter housing, valve bodies, and nozzles of the ion exchanger in the

spent fuel pool cooling and cleanup system. The water chemistry program relies on monitoring

and control of reactor water chemistry based on EPRI TR-105714 guidelines for primary water

chemistry and TR-102134 for secondary water chemistry to manage the effects of loss of

material from pitting or crevice corrosion. However, high concentrations of impurities at crevices

and locations of stagnant flow conditions could cause pitting or crevice corrosion. Therefore,

verification of the effectiveness of the chemistry control program should be performed to ensure -

that corrosion is not occurring. The GALL Report recommends further evaluation of programs to

manage loss of material from pitting and crevice corrosion to verify the effectiveness of the water

chemistry program.

The AMP recommended by the GALL Report is GALL AMP Xi.M2, "Water Chemistry," for

management of loss of material due to general, pitting, and crevice corrosion.

The applicant stated in the LRA that as set forth in the GALL Report, this item applies to spent

fuel pool cooling and cleanup carbon steel components with elastomer linings. The spent fuel

pool cooling system does not contain carbon steel components with elastomer linings.

Therefore, this item is not applicable. The applicant included the spent fuel pool cooling system

in Unit 2 LRA Section 3.2, "Engineered Safety Features Systems." The staff reviewed the LRA'

Table 3.2.2-5 AMR for the spent fuel pool cooling system and verified that the system did not

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contain carbon steel components with elastomer linings. On the basis of its review, the staff

finds this line item not applicable for components in the spent fuel pool cooling system.

However, these components are fabricated from stainless steel material. As stated in

Section 3.2A.2.3.5 of this SER, the'applicant proposed to manage loss of material of stainless

steel expansion joints, flow elements, pipe, pumps, and spent fuel pool heat exchangers

(channel head) component types exposed to chemically treated borated water using only MPS

AMP B2.1.5, 'Chemistry Control for Primary Systems Program," which is consistent with GALL

* AMP XI.M2, "Water Chemistry," with an exception. The staff reviewed the chemistry control for

primary systems program and its evaluation is documented in Section 3.0.3.2.2 of this SER. The

exception related to use of a later, non-NRC-approved revision of the EPRI guidelines. The staff

finds that because the effects of pitting and crevice corrosion on stainless steel components are

not significant in chemically treated borated water, inspection of selected components to verify

the absence of loss of material is not required. On the basis of its review,'the staff finds that the'

chemistry control for primary systems program is acceptable for managing this aging effect.

3.3A.2.2.2 Hardening and Cracking or Loss of Strength Due to Elastomer Degradation or Loss

of Material Due to Wear

The staff reviewed LRA Section 3.3.2.2.2 against the criteria in SRP-LR Section 3.3.2.2.2.

In LRA Section 3.3.2.2.2, the applicant addressed the potential for degradation of elastomers in

collars and seals in spent fuel pool cooling system and ventilation systems.

SRP-LR Section 3.3.2.2.2 states that hardening and cracking due to elastomer degradation

could occur in elastomer linings of the filter, valve; and ion exchangers in spent fuel pool cooling

and cleanup systems. Hardening and loss of strength due to elastomer degradation could occur

in the collars and seals of the duct and in the elastomer seals of the filters in the control room'

area, auxiliary and radwaste area, and primary containment heating and ventilation systems, 'and

in the collars and seals of the duct in the diesel generator building ventilation system. Loss of

material due to wear could occur in the collars and seals of the duct in the ventilation systems.

The GALL Report recommends further evaluation to ensure that these aging effects are'

adequately managed.

The applicant stated in the LRA that the spent fuel pool cooling system does not contain carbon

steel components with elastomer linings. Therefore, this item is not applicable. The applicant has

included the spent fuel pool cooling system in LRA Section 3.2, "Engineered Safety Features

Systems." The staff reviewed the Table 3.2.2-5 AMR for spent fuel pool cooling system and

verified that the system did not contain carbon steel components with elastomer linings. On the

basis of its review, the staff finds that this line item is not applicable for components in spent fuel

pool cooling system.

The applicant stated in the LRA that elastomers are used in ventilation systems components and

are evaluated for cracking and change of material properties due to thermal and radiation

exposure. The applicant credited AMP B2.1.25, "Work Control Process," and AMP B2.1.13,

"General Condition Monitoring Program," for managing age-related degradation of elastomers

used in ventilation systems components. The work control process program provides the

opportunity for personnel to visually inspect the internal surfaces of components during

preventive and corrective maintenance activities on an ongoing basis. Also, this program

provides input to the corrective action program if aging effects are identified. The staff accepted

the work control process program for managing the aging effects of cracking and change in

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material properties and its evaluation of this program is documented in Section 3.0.3.3.4 of this

SER. The staff also accepted the general condition monitoring program for managing cracking

and change of material properties since visual inspections will be performed on external

surfaces to identify any sign of aging degradation. The staffs evaluation of the general condition

monitoring program is documented in Section 3.0.3.3.2 of this SER.

In LRA Section 3.2.2.2.2, the applicant stated that loss of material due to wear is not an AERM

for the elastomers in the ventilation systems. During the audit and review, the staff reviewed the

applicant's basis and determined that the elastomers in the ventilation systems are not subject to

motions which could result in wear. Based on the lack of motion, the staff finds that the loss of

material due to wear is not an aging effect requiring management for the elastomers in the

ventilation system.

3.3A.2.2.3 Cumulative Fatigue Damage

As stated in the SRP-LR, fatigue is a TLAA, as defined in 10 CFR 54.3. Applicants must

evaluate TLAAs in accordance with 10 CFR 54.21 (c)(1). Section 4.3 of this SER documents the

staffs review of the applicant's evaluation of this TLAA. In performing this review, the staff

followed the guidance in Section 4.3 of the SRP-LR.

3.3A.2.2.4 Crack Initiation and Growth Due to Cracking or Stress Corrosion Cracking

The staff reviewed LRA Section 3.3.2.2.4 against the criteria in SRP-LR Section 3.3.2.2.4. In

LRA Section 3.3.2.2.4, the applicant addressed the potential for cracking in the high-pressure

pumps of the chemical and volume control system (CVCS).

SRP-LR Section 3.3.2.2.4 addresses crack initiation and growth due to cracking in the

high-pressure pumps in the CVCS. The GALL Report recommends further evaluation to ensure

that these aging effects are adequately managed.

The applicant stated in the LRA that cracking is not identified as an AERM for the CVCS

high-pressure pump casing. The high-pressure pump casing is constructed of stainless steel

and operates at temperatures less than 140 OF. SCC is applicable to stainless steel components

in aqueous environments that experience operating temperatures greater than 140 OF.

The applicant stated that based on industry experience, a temperature criterion of greater than

140'F is used as the threshold for susceptibility of austenitic stainless steels to SCC. No

instances were identified that would bring this temperature threshold into question. On the basis

of its review, the staff finds the applicant's statement reasonable and acceptable because the

applicant's bases for excluding the aging effects of cracking in the CVCS high-pressure pump

casing are consistent with industry and site operating experience.

3.3A.2.2.5 Loss of Material Due to General, Microbiologically Influenced, Pitting, and Crevice

Corrosion

The staff reviewed LRA Section 3.3.2.2.5 against the criteria in SRP-LR Section 3.3.2.2.5. In

LRA Section 3.3.2.2.5, the applicant addressed the loss of material from corrosion that could

occur on internal and external surfaces of components exposed to air and the associated range

of atmospheric conditions.

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SRP-LR Section 3.3.2.2.5 states that loss of material due to general, pitting, and crevice

corrosion could occur in the piping and filter housing and supports in the control room area,

auxiliary and radwaste area, primary containment heating and ventilation systems, piping of the

diesel generator building ventilation system, aboveground piping and fittings, valves, and pumps

in the diesel fuel oil system and in the diesel engine starting air, combustion air intake, and

combustion air exhaust subsystems in the emergency diesel generator system. Loss of material

due to general, pitting, and crevice corrosion, and MIC could occur in the duct fittings, access

doors and closure bolts, equipment frames, and duct housing. Loss of material due to pitting and

crevice corrosion could occur in the heating/cooling coils of the air handler units, and due to

general corrosion could occur on the external surfaces of all carbon steel SCs, including bolting,

exposed to operating temperatures less than 2120F in the ventilation systems. The GALL Report -

recommends further evaluation to ensure that these aging effects are adequately managed.

The applicant stated that AMP B2.1.10, "Fire Protection Program;" AMP B2.1.24, 'Tank -

Inspection Program;" and AMP B2.1.25, "Work Control Process," managed loss of material due

to general corrosion, MIC, pitting, and crevice corrosion for the internal surfaces of ducts, piping,'

filter housings, compressed air systems components, and fuel oil systems components.-Loss of

material for external surfaces of carbon steel components is effectively managed by AMP -

B2.1.3, "General Condition Monitoring;" AMP B2.1.10, "Fire Protection Program;" AMP B2.1.23,'

"Structures Monitoring Program;" and AMP B2.1.24, NTank Inspection Program." Also, the

applicant stated that AMP B2.1.15, "Infrequently Accessed Areas Inspection Program," managed

this aging effect for components in infrequently accessed areas.

The staff identified a discrepancy between LRA Table 3.3.2-31, "Auxiliary Systems - Unit 2 Fire

Protection," and LRA Table 3.3.2-32, "AuxiliarySystems - Unit 3 Fire Protection." In LRA Table

3.3.2-31 (page 3-281), the applicant stated, for carbon steel pipe exposed internally to moist air,.

that the fire protection program is used for managing the aging effects of loss of material. In LRA

Table 3.3.2-32 (page 3-291), the applicant credited the work control process program to manage

loss of material and references Table 3.3.1, Item 3.3.1-05. During the audit and'review, the

applicant was requested to clarify which is correct. In an LRA supplement'dated

July 7, 2004, the applicant stated that LRA Table 3.3.2-32, the "Work Control Process" AMP for

the carbon steel 'Pipe' component group exposed internally to an air environment, should be

replaced with the "Fire Protection Program" AMP. The "NUREG-1801" item should be

WVII.H2.3-a" and the "Notes" should be "C,- 2."The staff reviewed the applicant's response and

finds it to be acceptable.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. The work control process program

provides input to the corrective action program If aging effects are identified. On the basis of its

review, the staff finds the work control process program acceptable for managing the aging

effects of loss of materials due to general corrosion, MIC, pitting, and crevice corrosion for the

internal surfaces of ducts, piping, filter housings, compressed air systems components, and fuel

oil systems components. ; :.

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The staff reviewed the fire protection program and its evaluation is documented in Section

3.0.3.2.7 of this SER. The fire protection program is consistent with GALL AMPs XI.M.26; "Fire

Protection," and XI.M.27, 'Fire Water System." On the basis of its review, the staff finds that the

fire protection program is acceptable for managing loss of material since visual inspections will,

be performed on internal surfaces to detect any sign of aging degradation when the system is

opened for maintenance and/or repair.

The staff reviewed the tank inspection program and its evaluation is documented in Section

3.0.3.2.17 of this SER. The tank inspection program is consistent with GALL AMP XI.M.29,

"Aboveground Carbon Steel Tanks." On the basis of its review, the staff finds that the tank

inspection program is acceptable for managing loss of material due to general corrosion since

wall thickness measurements will be performed on the lower portion of the tank.

The staff reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.2 of this SER. The general condition monitoring program uses visual inspections

to detect evidence of degradation or adverse conditions in accessible plant areas. System

engineers perform comprehensive visual inspections during walkdowns of plant systems and

components during normal operation and during refueling outages; plant equipment operators

perform equipment and structures inspections twice a day to maintain awareness of system and

plant operation and material condition during normal operation and refueling outages. On the

basis of its review, the staff finds that the general condition monitoring program is acceptable for

managing loss of materials since visual inspections will be performed on external surfaces to

detect any sign of aging degradation.

The staff reviewed the structures monitoring program and its evaluation is documented in

Section 3.0.3.2.16 of this SER. The structures monitoring program manages the aging effects of

cracking, loss of material, and change of material properties by monitoring structures and

structural support systems that are within the scope of license renewal. The majority of these

structures and structural support systems are monitored under 10 CFR 50.65 as addressed in

RG 1.160, Revision 2, and NUMARC 93-01, Revision 2. These two documents provide guidance

for development of licensee-specific programs to monitor the condition of structures and

structural components within the scope of the Maintenance Rule, such that there is no loss of

structure or structural component intended function. The remaining structures within the scope

of license renewal (such as non-safety-related buildings and enclosures, duct banks, valve pits

and trenches, high-energy line break barriers, and flood gates) are also monitored to ensure

there is no loss of intended function. The staff reviewed the structures monitoring program and

its evaluation is documented in Section 3.0.3.2.16 of this SER. On the basis of its review, the

staff finds that the structures monitoring program is acceptable for managing loss of material

since visual inspections will be performed on external surfaces for any sign of aging degradation.

The staff reviewed the infrequently accessed areas inspection program and its evaluation is

documented in Section 3.0.3.3.3 of this SER. The infrequently accessed areas inspection

program is a new, plant-specific program that manages the aging effects of loss of material

using visual inspections of the external surfaces of SCs. The program encompasses infrequently

accessed areas of the plant which contain in-scope equipment. All areas not normally accessible

for inspection and evaluation, and that contain SCs subject to aging management, have been

identified for inclusion in the program. On the basis of its review, the staff finds that the

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infrequently accessed areas inspection program is acceptable for managing loss of material due

to general corrosion on external surfaces of carbon steel components, since visual inspections

will be performed on external surfaces to detect any sign of aging degradation in the service

water system.

During the audit and review, the staff questioned why various portions of the diesel generator

system were not included within the scope of license renewal and subject to an AMR. In its LRA

supplement dated July 7, 2004, the applicant added several components in the diesel generator

system to those that are subject to an AMR. The addition of these components did not result in

the addition of material/environment combinations or AMPs for the diesel generator system AMR

for components addressed by LRA Section 3.3.2.2.5. Based on the applicant's addition of diesel

generator system components as subject to AMR, the staff finds this materiaVenvironment/aging

effect/AMP combination to be acceptable. The staffs evaluation of the scope of the diesel

generator system is documented in Section 2.3A.3.35 of this SER.

3.3A.2.2.6 Loss of Material Due to General, Galvanic, Pitting, and Crevice Corrosion

The staff reviewed LRA Section 3.3.2.2.6 against the criteria in SRP-LR Section 3.3.2.2.6. In

LRA Section 3.3.2.2.6, the applicant addressed further evaluation of programs to manage loss of

material in the RCP oil collection system to verify the effectiveness of the fire protection

program.

SRP-LR Section 3.3.2.2.6 states that loss of material due to general, galvanic, pitting, and

crevice corrosion could occur in tanks, piping,-valve bodies, and tubing in the RCP oil collection

system in fire protection. The fire protection program relies on a combination of visual and

volumetric examinations, in accordance with the guidelines of 10 CFR 50 Appendix R and

Branch Technical Position 9.5-1, to manage loss of material from corrosion. However, corrosion

may occur at locations where water from wash downs may accumulate. Therefore, verification of

the effectiveness of the program should be performed to ensure that corrosion is not occurring.

The GALL Report recommends further evaluation of programs to manage loss of material due to

general, galvanic, pitting, and crevice corrosion to verify the effectiveness of the program. A

one-time inspection of the bottom half of the interior surface of the RCP oil collection system

tank is an acceptable method to ensure that corrosion is not occurring and that the component's

intended function will be maintained during the period of extended operation.

The applicant stated in the LRA that loss of material is managed for the components associated

with the RCP oil collection system by MPS AMP B2.1.24, "Tank Inspection Program," which

subjects the RCP oil collection tanks to periodic internal and external inspections. Additionally,

during containment close-out activities, the RCP oil collection tanks are visually inspected and

verified to be empty.

The staff reviewed the tank inspection program, which is consistent with GALL AMP XI.29,

"Aboveground Carbon Steel Tanks," and its evaluation is documented in Section 3.0.3.2.17 of

this SER. Since the tank inspection program includes volumetric examinations for wall thickness

measurement of the RCP oil collection tank, the staff finds the program acceptable for managing

loss of material due to general, galvanic, pitting, and crevice corrosion.

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The applicant referenced LRA Table 3.3.1, Item 3.3.1-06 (page 3-190), for components exposed

internally to lube oil (Note 14) and loss of material aging effect combination in LRA Table

3.3.2-32, and credited the work control process program. In LRA Table 3.3.1, Item 3.3.1- 06, the

applicant stated that the loss of material aging effect is managed by the tank inspection

program. The staff noted that there is no mention in the table about the work control process

program. During the audit, the staff requested the applicant clarify the omission. In its LRA

supplement, dated July 7, 2004, the applicant stated that LRA Table 3.3.1, Item 3.3.1-06, should

include the following words between the second and third sentences:

For the non-tank components, loss of material is managed by the work control

process program.

Additionally, the applicant stated in the LRA supplement that LRA Section 3.3.2.2.6 (page 3-184)

should include the following words at the end of the first sentence:

For the non-tank components, loss of material is managed by the work control

process program.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The staff finds that the work control process program provides the

opportunity for personnel to visually inspect the internal surfaces of components during

preventive and corrective maintenance activities on an ongoing basis. It also provides input to

the corrective action program if aging effects are identified. On the basis of its review, the staff

finds the work control process program acceptable for managing the aging effects of loss of

material.

3.3A.2.2.7 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced

Corrosion and Biofouling

The staff reviewed LRA Section 3.3.2.2.7 against the criteria in SRP-LR Section 3.3A.2.2.7. In

LRA Section 3.3.2.2.7, the applicant addressed further evaluation of programs to manage loss of

material in the diesel fuel oil system to verify the effectiveness of the diesel fuel monitoring

activities.

SRP-LR Section 3.3.2.2.7 states that loss of material due to general, pitting, and crevice

corrosion, MIC, and biofouling could occur in the internal surface of tanks in the diesel fuel oil

system and due to general, pitting, and crevice corrosion and MIC in the tanks of the diesel fuel

oil system in the emergency diesel generator system. The existing AMP relies on the fuel oil

chemistry program for monitoring and control of fuel oil contamination in accordance with the

guidelines of ASTM Standards D4057, D1796, D2709, and D2276 to manage loss of material

due to corrosion or biofouling. Corrosion or biofouling may occur at locations where

contaminants accumulate. Verification of the effectiveness of the chemistry control program

should be performed to ensure that corrosion is not occurring. The GALL Report recommends

further evaluation of programs to manage corrosion/biofouling to verify the effectiveness of the

program. A one-time inspection of selected components at susceptible locations is an

acceptable method to ensure that corrosion is not occurring and that the component's intended

function will be maintained during the period of extended operation.

The AMPs recommended by the GALL Report are GALL AMP XI.M30, "Fuel Oil Chemistry," and

GALL AMP XI.M32, "One Time Inspection," for management of this aging effect.

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The applicant stated in the LRA that MPS AMP B2.1.12, 'Fuel Oil Chemistry," manages loss of

material for diesel fuel oil tanks and other components in the diesel generator fuel oil system, the

security system, and the station blackout diesel generator system. In lieu of a one-time

inspection program as described in SRP-LR Section 3.3.2.2.7, the applicant stated in LRA

Section 3.3.2.2.7 that MPS AMP B2.1.25, "Work Control Process," will be used to provide

confirmation of the effectiveness of the fuel oil chemistry program, and that tank inspections

performed under the applicant's MPS AMP B2.1.24, 'Tank Inspection Program," provide

additional confirmation that the fuel oil chemistry program is effective for managing aging effects

for applicable tanks.

The staff reviewed the fuel oil chemistry program and its evaluation is documented in Section

3.0.3.2.9 of this SER. The fuel oil chemistry program (1) monitors and controls fuel oil quality to

ensure that it is compatible with the materials of construction, and to manage the conditions that

cause general corrosion, pitting, and MIC of fuel tank internal surfaces; (2) establishes fuel oil

quality limits; and (3) samples and tests fuel oil used for equipment within the scope of license

renewal. On the basis of its review, the staff finds the fuel oil chemistry program to be

acceptable.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. The work control process program

provides input to the corrective action program if aging effects are identified. On the basis of its

review, the staff finds that the work control process program is acceptable for use in providing

confirmation of the effectiveness of the fuel oil chemistry program.

The staff reviewed the tank inspection program and its evaluation is documented in Section

3.0.3.2.17 of this SER. The tank inspection program is consistent with GALL AMP XI.M.29,

"Aboveground Carbon Steel Tanks." On the basis of its review, the staff finds that the tank

inspection program is acceptable for providing additional confirmation that the fuel oil chemistry

program is effective for managing aging effects for applicable tanks.

3.3A.2.2.8 Quality Assurance for Aging Management of Non-safety-related Components

Section 3.0.4 of this SER provides a separate evaluation of the applicant's Quality Assurance

Program.

3.3A.2.2.9 Crack Initiation and Growth Due to Stress Corrosion'Cracking and Cyclic Loading

The staff reviewed LRA Section 3.3.2.2.9 against the criteria in SRP-LR Section 3.3.2.2.9. In

LRA Section 3.3.2.2.9, the applicant addressed further evaluation of programs to manage

cracking in the chemical and volume control system (CVCS) to verify the effectiveness of the

water chemistry control program.

SRP-LR Section 3.3.2.2.9 states that crack initiation and growth due to SCC and cyclic loading

could occur in the channel head and access cover, tube sheet, tubes, shell and access cover,

and closure bolting of the regenerative heat exchanger and in the channel head and access

cover, tube sheet, and tubes of the letdown heat exchanger in the CVCS. The water chemistry

program relies on monitoring and control of water chemistry based on the EPRI TR-105714

guidelines for primary water chemistry to manage the effects of crack initiation and growth due

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to SCC and cyclic loading. Verification of the effectiveness of the chemistry control program

should be performed to ensure that crack initiation and growth are not occurring. The GALL

Report recommends further evaluation to manage crack initiation and growth from SCC and

cyclic loading for these systems to verify the effectiveness of the water chemistry program.

A one-time inspection of selected components and susceptible locations is an acceptable

method to ensure that crack initiation and growth are not occurring and that the component's

intended function will be maintained during the period of extended operation.

The AMPs recommended by the GALL Report are GALL AMP X1.M2, "Water Chemistry," and a

plant-specific verification program for management of this aging effect.

The applicant stated in the LRA that cracking due to SCC for the regenerative and letdown heat

exchangers is managed by MPS AMP B2.1.5, "Chemistry Control for Primary Systems

Program." Verification of the effectiveness of the chemistry control program is provided by MPS

AMP B2.1.25, 'Work Control Process." The work control process program provides the

opportunity for personnel to visually inspect the internal surfaces of components during

preventive and corrective maintenance activities on an ongoing basis. The work control process

program provides input to the corrective action program if aging effects are identified. The

corrective action program would evaluate the cause and extent of a condition and, if required,

recommend enhancements to ensure continued effectiveness of the chemistry control for

primary systems program.

The staff reviewed the chemistry control for primary systems program and its evaluation is

documented in Section 3.0.3.2.2 of this SER. The chemistry control for primary systems

program is consistent with GALL AMP XI.M2, 'Water Chemistry," with an acceptable exception.

The exception relates to use of a later, non-NRC-approved revision of the EPRI guidelines. On

the basis of its review, the staff finds that the chemistry control for primary systems program is

acceptable for managing this aging effect.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The staff finds that visual inspections of the internal surfaces of

plant components and plant commodities are performed during the performance of

maintenance, in accordance with the work control process program, to determine the presence

of crack initiation and growth. On the basis of its review, the staff finds that the work control

process program is acceptable for managing crack initiation and growth since visual inspections

will be performed on internal surfaces of components to detect any sign of aging degradation.

3.3A.2.2.10 Reduction of Neutron-Absorbing Capacity and Loss of Material Due to General

Corrosion

SRP-LR Section 3.3.2.2.10 states that reduction of neutron-absorbing capacity and loss of

material due to general corrosion could occur in the neutron-absorbing sheets of the spent fuel

storage rack in the spent fuel storage pool. The GALL Report recommends further evaluation to

ensure that these aging effects are adequately managed.

The applicant stated in the LRA 3.3.2.2.10 that Boral is not used in the spent fuel pool for

neutron absorption. Since Boral is not used at Unit 2, the staff agrees that this line item is not

applicable.

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3.3A.2.2.11 Loss of Material Due to'General, Pitting, Crevice, and Microbiologically Influenced

Corrosion

The staff reviewed LRA Section 3.3.2.2.11 against the criteria in SRP-LR Section 3.3.2.2.11.

In LRA Section 3.3.2.2.11, the applicant addressed the potential for loss of material in buried

piping of the service water and diesel fuel oil systems.

SRP-LR Section 3.3.2.2.11 states that loss of material due to general, pitting, and crevice

corrosion and MIC could occur in the underground piping and fittings in the open-cycle cooling

water system (service water system) and in the diesel fuel oil system. The buried piping and

tanks inspection program relies on industry practice, frequency of pipe excavation, and operating

experience to manage the effects of loss of material from general, pitting, and crevice corrosion'

and MIC. The effectiveness of the buried piping and tanks inspection program should be verified

to evaluate an applicant's inspection frequency and operating experience with buried

components, ensuring that loss of material is not occurring.

The AMP recommended by the GALL Report is GALL AMP XI.M34, "Buried Piping and Tanks

Inspection."

The applicant stated in the LRA that loss of material for buried piping and valves in the service

water system, and in the Unit 2 fire protection system, Unit 3 fire protection system, and

enclosure building filtration system, is managed by AMP B2.1.4, "Buried Pipe Inspection

Program."

In the LRA, the applicant stated that as part of the buried pipe inspection program, a baseline

inspection of representative in-scope buried piping is performed, which provides an effective

method for detection of aging effects. In addition, inspections are performed when the buried

components are excavated for maintenance or any other reason and provide an effective

method to evaluate the condition of the buried piping and protective coatings. Operating

experience with age-related degradation of buried piping is limited and no failures of in-scope . -

buried piping have been identified.

Also, the applicant stated that there is no buried piping in the diesel fuel oil systems.

The staff reviewed the buried pipe inspection program and its evaluation is documented -in

Section 3.0.3.2.1 of this SER. The staff finds that the buried pipe inspection program is

consistent with GALL AMP Xl.M28, "Buried Piping and Tanks Surveillance," and

GALL AMP XI.M34, "Buried Piping and Tanks Inspection," with exceptions and enhancements.

The staff also finds the exceptions and enhancements to be acceptable. The staff reviewed the

plant operating experience and found that the program is effective in identifying age-related

degradation, implementing repairs, and maintaining the integrity of buried pipe. On the basis of

its review, the staff finds that the buried pipe inspection program is acceptable for managing the

aging effects of loss of material in buried piping and fittings.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report,'and for which the GALL

Report recommends further evaluation, the staff determines that (1) those attributes or features

for which the applicant claimed consistency with the GALL Report were indeed consistent and

(2) the applicant adequately addressed the issues that were further evaluated. The staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so that

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the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.3A.2.3 AMR Results That Are Not Consistent With or Not Addressed in the GALL

Report

Summary of Technical Information in the ADplication. In Tables 3.3.2-1 through 3.3.241 of the

LRA, the staff reviewed additional details of the results of the'AMRs for material, environment,

AERM, and AMP combinations that are not consistent with the GALL Report or are not

addressed in the GALL Report.

In Tables 3.3.2-1 through 3.3.241, the applicant indicated, via Notes F through J, that neither

the identified component nor the material/environment combination is evaluated in the GALL

Report and provided information concerning how the AERM will be managed.

Staff Evaluation. For component type material/environment combinations not evaluated in the

GALL Report, the staff reviewed the applicant's evaluation to determine whether the applicant

had demonstrated that the effects of aging will be adequately managed so that the intended

function will be maintained consistent with the CLB during the period of extended operation.

The staff requested the applicant to provide additional information on the issues described in the

following general RAls. These RAls, the applicant's response, and the staff's evaluation of the

responses are described below.

Cracking in Dux Seal Joint Seals (RAI 3.3-A-2). The LRA identifies-cracking in ductwork joint

seals using Dux Seal material for various ventilation system components in the auxiliary

systems. The general condition monitoring program is credited with managing this aging effect

through the use of visual inspections of external surfaces and the LRA tables do not identify

aging effects for ductwork seals exposed to the internal environment In some cases, drying and

cracking of seals from the internal environment with continuous air flow could potentially be more

severe than the external environment. The general condition monitoring AMP, described in LRA

Section B2.1.13, did not identify specific criteria, including the inspection frequency and its

technical basis, unique to managing ductwork joint seals; and it was not clear how external

visual inspections will manage internal degradation. The applicant was requested to clarify how

visual inspection of the external surfaces of ductwork joint seals is adequate to detect internal'

cracking prior to loss of the component pressure boundary function. In addition, the general

condition monitoring program is limited to accessible plant areas. The applicant was requested

to clarify how ductwork joint seals in inaccessible areas are inspected and/or tested for cracking.

The applicant was also requested to provide the inspection frequency, including its technical

basis, and the operational history to demonstrate the effectiveness of the general condition

monitoring program to manage cracking in ductwork joint seals.

By letter dated November 9, 2004, the applicant responded as follows:

Dux Seal is an adhesive/sealant-saturated fabric cloth that is applied to the externalsurface of the ductwork at the crimped and rivited joints in order to provide a leak-tight

seal. The material (also termed Hardcast) cures hard and rigid, and is not similar to duct

tape. Since it is applied to the ouside surface of the duct, the primary exposure

environment is ambient air. No aging effects are expected to originate from inside the

ductwork due to the limited exposure to the ductwork internal environment. Therefore,

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the cracking aging effect has been determined to require management due to the

external environment.

Ductwork is generally not routed through inaccessible areas of the plant, and no

inaccessible ductwork joint seals were identified as part of the aging management

review.

The cracking aging effect for the ductwork joint seals is visually observable during the

inspections performed as part of the general condition monitoring aging management

program as described in LRA Appendix B, Section B2.1.13. Inspections are performed by

the systems engineers as part of the comprehensive system evaluations performed

quarterly, and by the plant equipment operators during daily rounds of plant areas to

verify proper component and system operation. Significant degradation of the ductwork

joint seals has not been identified, however, the effectiveness of the General Condition

Monitoring AMP is demonstrated by operating experience associated with other plant

components as cited in Appendix B, Section B2.1.13.

The staff reviewed the applicant's response and determined that the response was reasonable

and acceptable because the applicant provided sufficient information to conclude that cracking in

ductwork joint seals will be adequately managed by the general condition monitoring program

during the period of extended operation. The applicant clarified that Dux Seal is an

adhesive/sealant-saturated fabric cloth that cures hard and rigid. Since this material is applied to

the outside surface of ductwork joints, there is limited exposure to the internal environment and

cracking is applicable to the external environment. The applicant also identified that no

inaccessible ductwork joint seals were identified as part of the aging management review and

significant degradation of the ductwork joint seals has not been identified. Further, the applicant

clarified that cracking in ductwork joint seals is visually observable during the comprehensive

system evaluations performed by system engineers quarterly and by plant equipment operators

during daily rounds of plant areas to verify proper component and system operation. On the

basis of the applicant's response, all issues related to RAI 3.3-A-2 are resolved.

Selective Leaching in CoDDer Alloys (RAI 3.3-A-3); LRA Tables 3.3.2-34 and 3.3.2-36 for the

diesel generator and station blackout diesel generator respectively identify loss of material as an

aging effect applicable to nickel-based alloys and copper alloys exposed to a moisture-laden air

and/or intermittently wetted environment. The LRA did not identify the alloy zinc content for

these materials.- The LRA credited the work control process program for managing loss of

material in the interior of nickel-based alloy valves and the general condition monitoring program

for managing loss of material on the exterior of copper alloy radiators. These AMPs primarily rely

on visual inspections. Industry documents, such as EPRI report 1003056, .Non-Class-1

Mechanical Implementation Guideline and Mechanical Tools," Rev. 3, identify various corrosion

mechanisms, including selective leaching, that cause loss of material in copper alloys with

greater than 15 percent zinc content in an air environment subject to moisture. Loss of material

from selective leaching is specifically addressed in GALL AMP XL.M33, but page B-7 of the LRA

states that the AMRs did not identify the need for this AMP. The applicant was requested to

identify the alloy zinc content for these materials and clarify if selective leaching is an applicable

aging mechanism. If selective leaching is an applicable aging mechanism, the applicant was

requested to clarify if hardness measurement and one-time inspection required by GALL AMP

XI.M33 will be used to manage the aging effect.

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By letter dated November 9, 2004, the applicant responded as follows:

Dominion conservatively assumed that all copper alloys were of a material composition

that could be susceptible to selective leaching. Accordingly, the zinc content for copper

alloys was not identified in the LRA since it was not used as an input to the evaluation of

aging mechanisms. Selective leaching was not considered to be an applicable aging

mechanism for nickel-based alloys.

Selective leaching of copper alloys was not considered to be significant in a moistureladen air and/or an intermittently Wetted environment unless conditions were conducive to

water collection or pooling which would cause wetting for a significant period of time. If

water collection or pooling was present for a component, the component was evaluated

for a raw water environment as defined in LRA Table 3.0-1.

The copper alloy components in the diesel generator system associated with moistureladen air are the pipes and tubes of the turbocharger and intercooler air systems.

Wetting is possible during the operation of these components which normally occurs only

during monthly Technical Specification surveillance testing. Wetted conditions would

dissipate after use due to the elevated temperatures of operation. Therefore wetting for a

significant time period would not occur.

The copper alloy component in the diesel generator system associated with intermittent

wetting is the level indicator (sight glass) on the jacket cooling water expansion tanks.

Portions of this component are normally dry but may occasionally become wetted.

Wetting for a significant time period is not expected.

The copper alloy component in the station blackout diesel generator system associated

with intermittent wetting is the radiator that is exposed to an atmosphere/weather

environment. Atmosphere/weather environments and selective leaching are discussed in

the response to RAI 3.3-B-2.

Based on the above, loss of material due to selective leaching was not identified as an

aging effect for these components and the work control process and the general

condition monitoring AMPs provide management of this aging effect.

The staff reviewed the applicant's response and determined that the response was reasonable

and acceptable because the applicant provided sufficient information to conclude that selective

leaching is not a significant aging mechanism causing loss of material in copper alloy materials

in the diesel generator and station blackout diesel generator systems exposed to periodic

moisture. This conclusion is in part based on the applicant's clarified environmental conditions

that copper alloy components in these systems exposed to moisture-laden air and/or

intermittently wetted conditions are not exposed to wetted conditions for a significant period of

time. The staff agrees that selective leaching of nickel alloys is not considered to be a concern in

this environment. In addition, the applicant has agreed in its letter, dated July 7, 2004, to include

appropriate inspection criteria for selective leaching to its work control process AMP. On the

basis of the applicant's response, all issues related to RAI 3.3-A-3 are resolved.

The systems specific staff evaluation is discussed below.

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3.3A.2.3.1 Circulating Water - Aging Management Evaluation - Table 3.3.2-1

The staff reviewed LRA Table 3.3.2-1, which summarizes the results of AMR evaluations for the

circulating water system component groups. In the LRA, the applicant proposed to manage loss'

of material of stainless steel pipe and valve component types exposed to air using AMP B21.13,

"General Condition Monitoring," which is a plant-specific program. The staff reviewed the general

condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER.-

On the basis of its review, the staff finds that the general condition monitoring program is

acceptable for managing loss of material due to pitting and crevice corrosion since visual

inspections will be performed on external surfaces to detect any sign of aging degradation.

In the LRA, the applicant identified no aging effects for rubber expansion joints exposed to air.

The applicant stated, in the technical report of AMR results for open water, that change of

material properties due to thermal exposure and irradiation and cracking due to irradiation of

rubber components in air are aging effects that do not require aging management for the

components in this system.

The staff reviewed the current industry research and operating experience. On the basis of its

review, the staff finds the applicant correctly identified that no aging effects for rubber expansion

joints in air, since these components are not exposed to high levels of ultraviolet radiation,

ozone, or temperatures greater than 95 "F.

In the LRA, the applicant identified no aging effects for rubber expansion joints exposed to

seawater. The applicant stated in the technical report of AMR results for open water, that change

of material properties and cracking due to thermal exposure of rubber components in seawater

are aging effects that do not require aging management for the components in this system.

On the basis of current industry research and operating experience, the threshold temperature

for applying the aging effects of cracking and change of material properties to elastomers is

95'F. For, the surface temperature of the rubber expansion joints in the open water systems will

never exceed 95 OF, since the internal water (raw water from the Long Island Sound) is -

significantly less than 95 OF; On the basis of its review, the staff finds that the applicant correctly

identified no aging effect for this component, since they are not exposed to temperatures greater

than 951F.

3.3A.2.3.2 Screen Wash - Aging Management Evaluation - Table 3.3.2-2

The staff reviewed LRA Table 3.3.2-2, which summarizes the results of AMR evaluations for the

screen wash system component groups.

In the LRA, the applicant proposes to manage loss of material of stainless steel tubing and

valves and copper alloys strainers and valve component types exposed to air using MPS AMP

B2.1.13, "General Condition Monitoring," which is a plant-specific program. The staff reviewed

the general condition monitoring program and its evaluation is documented in Section 3.0.3.3.2

of this SER. On the basis of its review, the staff finds that the general condition monitoring

program is acceptable for managing loss of material on external surfaces of the stainless steel

components (due to pitting and crevice corrosion) and copper alloys components (due to general

corrosion), since visual inspections will be performed on external surfaces to detect any sign of

aging degradation.

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In the LRA, the applicant identified no aging effects for fiberglass piping component types

exposed to air. The applicant stated in the technical report for AMR results for open water, that

reduced strength due to ozone exposure of non-metallic is possible in an air environment. The

applicant explains that the fiberglass components exposed to air in this system are not located

near high-voltage electrical equipment. Therefore, ozone exposure is not a potential aging

mechanism, and review of operating experience has identified no concerns related to the

occurrence of ozone exposure in the open water systems for this evaluation.

On the basis of its review of the applicant's technical report, current industry research, and

operating experience, the staff finds that reduced strength due to ozone for fiberglass

components in air environment is not an aging effect that requires aging management.

In the LRA, the applicant identified no aging effects for fiberglass piping component types

exposed to seawater. The applicant stated in the technical report for AMR results for open water,

that exposure to ultraviolet radiation and ozone can cause damage to the chemical structure of

the epoxy matrix of fiberglass. The earliest signs of this effect can be changes in color, and

surface cracking or crazing. Fiberglass exposed to direct sun or high levels of ozone that might

be found in conjunction with high-voltage electrical equipment would be most prone to this effect.

On the basis of its review of the applicant's technical report, current industry research, and

operating experience, the staff concurs that the fiberglass components in a seawater

environment are not exposed to high levels of ultraviolet radiation or ozone. Therefore, the staff

finds that cracking in fiberglass components in seawater is not an aging effect that requires

aging management

In the LRA, the applicant identified no aging effects for polyvinyl chloride (PVC) valve component

types exposed to air and seawater. Current industry research and operating experience reviews

have identified instances of PVC degradation resulting from exposure to direct sunlight and

exposure to ozone from high voltage. The material aging effect report (MAER) identifies the

aging effect of reduced strength due to ozone exposure for PVC components exposed to

seawater, and reduced strength due to ozone exposure or ultraviolet exposure for PVC

components exposed to air. The AMR evaluated PVC components for the above aging effects

and concluded that no aging management was required. This conclusion was based on the fact

that the PVC components are not exposed to direct sunlight and are not exposed to high levels

of ozone, since they are not in close proximity to high-voltage electrical equipment.

On the basis of its review of the applicant's technical report, current industry research, and

operating experience, the staff concurs with the applicant and finds that reduction in strength of

PVC components in an air or seawater environment is not an aging effect that requires aging

management.

3.3A.2.3.3 Service Water - Aging Management Evaluation - Table 3.3.2-3

The staff reviewed LRA Table 3.3.2-3, which summarizes the results of AMR evaluations for the

service water system component groups. In LRA Table 3.3.2-3, the applicant proposed to

manage buildup of deposits for carbon steel pipe and strainers, and cast iron pipe component

types exposed to seawater using AMP B2.1.21, "Service Water System (Open-Cycle Cooling),"

which is consistent with GALL AMP XI.M20, 'Open-Cycle Cooling Water System." However,

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buildup of deposits due to biofouling is not identified in the GALL Report as an aging effect for

the pipes and strainers component types.

The applicant stated, in the AMR results for open water, that the carbon steel and cast iron

material-lined piping interfaces with seawater and is subject to macro-fouling, silting, and

sedimentation. Therefore, buildup of deposits'is a potential aging effect that requires aging

management for these components.

The applicant stated in LRA Appendix C (page C-24) that buildup of deposits due to biofouling is

an aging effect requiring management for heat exchanger tubes, tube sheets, and lined

components. The applicant stated that lined piping was included because piping can contribute

to heat exchanger fouling since small segments of the coating can become detached and foul'

associated heat exchangers. Buildup of deposits does not directly affect the pressure boundary

of the lined piping. However, prolonged operation'with deteriorated coatings would lead to loss of

material. For this reason, both buildup of deposits and loss of material are managed by the

service water system (open-cycle cooling) aging management activity. Specifically, internal

visual inspections of the service water piping are periodically performed.

During the audit and review, the staff asked the applicant to provide justification as to why

buildup of deposits is not applied to stainless steel service water filters/strainers since filtration is

an intended function. The applicant responded that the stainless steel service water

filters/strainers are not lined. Although filtration is an intended function, clogging of the filter is 'an

expected service condition and does not result from age-related degradation. The stainless steel

service water filters/strainers in question are equipped with differential pressure gauges and are

periodically cleaned based on differential pressure.

The staff reviewed the service water system (open-cycle cooling) program and its evaluation is

documented in Section 3.0.3.2.15 of this SER. On the basis of its review of the applicant's

program and technical report, together with current industry research and operating experience,

the staff finds that the service water program is acceptable for managing buildup of deposits for

the lined components, since internal visual inspections of the service water components will be

periodically performed to detect any sign of deposit build-up.

In the LRA, the applicant proposed to manage loss of material of copper alloy tubing and valve

external surfaces caused by borated water leakage using MPS AMP B2.1.13,- "General ' ''

Condition Monitoring," which is a plant-specific program. The staff reviewed the general

condition monitoring program and its evaluation is documented 'in Section 3.0.3.3.2 of this SER.

On the basis of its review, the staff finds use of the general condition monitoring program in'lieu

of the boric acid corrosion program acceptable for managing loss of material due to borated acid

leakage on external surfaces of copper alloy components in this system, since visual inspections

will be performed on external surfaces to detect any sign of aging degradation.

In LRA Table 3.3.2-3, the applicant proposed to manage loss of material for nickel-based alloy

expansion joints and tubing exposed to seawater using MPS AMP B2.1.21, 'Service Water

System (Open-Cycle Cooling)," which is consistent with GALL AMP XI.M20, Open-Cycle Cooling Water System." However, loss of material for nickel-based component types in treated

water as a component, material, environment, 'and aging effect combination is not identified in

the GALL Report.

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The applicant stated in the AMR results for open water that the nickel-based alloys, related to

pitting, in seawater are exposed to low-flow conditions with an aggressive environment.

Therefore, pitting corrosion is a potential aging mechanism.

The staff reviewed the service water system (open-cycle cooling) program and its evaluation is

documented in Section 3.0.3.2.15 of this SER. The staff finds that the service water system (open-cycle cooling) program is acceptable for managing loss of material (due to pitting corrosion) of nickel-based alloy components in a seawater environment for this system, since

this program implements the intent of GL 89-13.

In the LRA, the applicant proposed to manage loss of material of stainless steel and copper alloy pipe, tubing, valves, filter/strainers, flow elements, flow indicators, flow orifices, pumps, and

restricted orifices component types exposed to a moisture-laden air and/or intermittently wetted

environments using MPS AMP B2.1.13, "General Condition Monitoring," which is a plant-specific

program. The environments are not in the GALL Report for this component type and material.

The staff reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.2 of this SER. The staff finds that the general condition monitoring program is

acceptable for managing loss of material due to pitting and crevice corrosion since visual

inspections will be performed on external surfaces to detect any sign of aging degradation.

In the LRA, the applicant identified no aging effects for the fiberglass service water pump motor

protective tank exposed to air. The applicant stated in the AMR results report for open water that

reduced strength due to ozone exposure of non-metallic components is possible in an air

environment. The applicant explained that the fiberglass components exposed to air in this

system are not located near high-voltage electrical equipment. Therefore, ozone exposure is not

a potential aging mechanism, and review of operating experience has identified no concerns

related to the occurrence of ozone exposure in the open water systems for this evaluation.

On the basis of its review of the applicant's technical report, current industry research, and

operating experience, the staff concurred and finds that reduced strength due to ozone for

fiberglass components in air environment is not an aging effect that requires aging

management.

In the LRA, the applicant identified no aging effects for rubber expansion joints exposed to air.

The applicant stated in the AMR results for open water that change of material properties due to

thermal exposure and irradiation, and cracking due to irradiation of rubber components in air are

aging effects that do not require aging management for the components in this system.

On the basis of its review of the applicant's technical report, current industry research, and

operating experience, the staff concurred and finds that no aging effect for rubber expansion joints in air is acceptable, since these components are not exposed to high levels of ultraviolet

radiation, ozone, or temperatures greater than 95 "F.

In the LRA, the applicant identified no aging effects for rubber expansion joints exposed to

seawater. The applicant stated in the AMR results for open water that change of material

properties and cracking due to thermal exposure of rubber components in seawater are aging effects that do not require aging management for the components in this system.

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On the basis of current industry research and operating experience, the threshold temperature

for applying the aging effects of cracking and change of material properties to elastomers is

95 "F. For, the surface temperature of the rubber expansion joints in the open water systems will

never exceed 95 0F, since the temperature of the internal water (raw water from the Long Island

Sound) is significantly less than 95 "F. On the basis of its review, the staff finds that the applicant

correctly identified no aging effect for this item, since these components are not exposed to

temperatures greater than 95 OF.

3.3A.2.3.4 Sodium Hypochlorite - Aging Management Evaluation - Table 3.3.2-4

The staff reviewed LRA Table 3.3.2-4, which summarizes the results of AMR evaluations for the

sodium hypochlorite system component groups.

In the LRA, the applicant proposed to manage loss of material of stainless steel valve

component types exposed to a moisture-laden air and/or intermittently wetted environments

using MPS AMP B2.1.13, "General Condition Monitoring," which is a plant-specific program. The

environments are not in the GALL Report for this component type and material. The staff

reviewed the general condition monitoring program and its evaluation is documented in Section

3.0.3.3.2 of this SER. The staff finds that the general condition monitoring program is acceptable

for managing loss of material due to pitting and crevice corrosion since visual inspections will be

performed on external surfaces to detect any sign of aging degradation.

In the LRA, the applicant identified no aging effects for PVC pipes and valves exposed to air or

in a seawater environment. Current industry research and operating experience reviews have

identified instances of PVC degradation resulting from exposure to direct sunlight and exposure

to ozone from high voltage. The MAER identifies the aging effect of reduced strength due to

ozone exposure for PVC components exposed to seawater, and reduced strength due to ozone

exposure or ultraviolet exposure for PVC components exposed to air. The applicant stated that it

evaluated PVC components for the above aging effects and concluded that no aging

management was required. This conclusion was based on the fact that the PVC components are

not exposed to direct sunlight and are not exposed to high levels of ozone; since they are not in

close proximity to high-voltage electrical equipment.

On the basis of its review of the applicant's technical report, current industry research, and

operating experience, the staff finds that reduction in strength of PVC components in an air or

seawater environment is not an aging effect that requires aging management.

3.3A.2.3.5 Reactor Building Closed Cooling Water - Aging Management Evaluation -

Table 3.3.2-5 -

The staff reviewed LRA Table 3.3.2-5, which summarized the results of AMR evaluations for the

reactor building closed cooling water (RBCCW) system component groups.

In the LRA, the applicant proposed to manage loss of material for RBCCW heat exchanger

copper alloy tubes in treated water using AMP B2.1.25, "Work Control Process," which is a

plant-specific program. The staff reviewed the work control process program and its evaluation

is documented in Section 3.0.3.3.4 of this SER. Visual inspections of the internal surfaces of

plant components and plant commodities are performed during the performance of

maintenance, in accordance with the work control process program, to determine the presence

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of loss of material. The staff finds that the work control process program is acceptable for

managing loss of material due to general corrosion since visual inspections will be performed on

the external surfaces of heat exchanger tubes to detect any sign of aging degradation.

In the LRA, the applicant proposed to manage loss of material of copper alloy valve external surfaces caused by borated water leakage using AMP B2.1.13, uGeneral Condition Monitoring," which is a plant-specific program. The staff reviewed the general condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER. The staff finds that the use of the general condition monitoring program in lieu of the boric acid corrosion program is

acceptable for managing loss of material due to borated acid leakage on external surfaces of

copper alloy components in this system, since visual inspections will be performed on external

surfaces to detect any sign of aging degradation.

In the LRA, the applicant proposed to manage loss of material of stainless steel and copper alloy valves, flow elements, flow indicators, flow orifices, flow switches, and tubing component types exposed to a moisture-laden air and/or intermittently wetted environments using MPS AMP

B2.1.13, "General Condition Monitoring," which is a plant-specific program. The staff reviewed the general condition monitoring program and its evaluation is documented in Section 3.0.3.3.2

of this SER. The staff finds that the general condition monitoring program is acceptable for

managing loss of material due to pitting and crevice corrosion since visual inspections will be

performed on external surfaces to detect any sign of aging degradation.

3.3A.2.3.6 Chilled Water - Aging Management Evaluation - Table 3.3.2-6

The staff reviewed LRA Table 3.3.2-6, which summarized the results of AMR evaluations for the

chilled water system component groups.

In the LRA, the applicant proposed to manage loss of material of carbon steel chiller water surge tank component groups exposed internally to moisture-laden air and/or an intermittently wetted

environment using AMP B2.1.25, "Work Control Process," which is a plant-specific program. The

staff reviewed the work control process program and its evaluation is documented in Section

3.0.3.3.4 of this SER. Visual inspections of the internal surfaces of plant components and plant commodities are performed during the performance of maintenance, in accordance with the work control process program, to determine the presence of loss of material. The staff finds that

the work control process program is acceptable for managing loss of material due to general corrosion since visual inspections will be performed on internal surfaces of components to detect

any sign of aging degradation.

In the LRA, the applicant proposed to manage loss of material of copper alloy tubing and valve

external surfaces caused by borated water leakage using AMP B2.1.13, UGeneral Condition

Monitoring," which is a plant-specific program. The staff reviewed the general condition

monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER. The staff

finds that the use of the general condition monitoring program in lieu of the boric acid corrosion

program is acceptable for managing loss of material due to borated acid leakage on the external

surfaces of copper alloy components in this system, since visual inspections will be performed

on external surfaces to detect any sign of aging degradation.

In the LRA, the applicant proposed to manage loss of material of stainless steel and copper alloy tubing, valves, level indicators, flow elements, moisture indicators, and pumps component types

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exposed to a moisture-laden air and/or intermittently wetted environments using AMP B2.1.13,

"General Condition Monitoring," which is a plant-specific program. The staff reviewed the general

condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER.

The staff finds that the general condition monitoring program is acceptable for managing loss of

material due to pitting and crevice corrosion since visual inspections will be performed on the

external surfaces to detect any sign of aging degradation.

In the LRA, the applicant identified no aging effects for carbon steel, stainless steel, cast iron,

and copper alloy components exposed internally to gas for chilled water shell and tubes; chilled

water evaporators tubes, compressor casings, filter/strainers, level indicators, moisture

indicators, and valve component types. Gas is not identified in the GALL Report as an

environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (which is similar to air) on metal will not result in aging

effects that will be of concern during the period of extended operation. Therefore, the staff finds

that there are no applicable aging effects requiring management for metal in a gas environment.

3.3A.2.3.7 Instrument Air - Aging Management Evaluation - Table 3.3.2-7

The staff reviewed Table 3.3.2-7 of the LRA and Table 3.3.2-7a in the LRA supplement letter

dated January 11, 2005, which summarizes the results of AMR evaluations for the instrument air

system component groups. The staff reviewed the technical report of AMR results for air and

gas systems.

In the LRA, the applicant proposed to manage loss of material of copper alloy pipe, regulators,

tubing, and valve component types exposed toa borated water leakage external environment

using AMP B2.1.13, "General Condition Monitoring," which is a plant-specific program. However,

the GALL Report specifies GALL AMP XL.M10, "Boric Acid Corrosion," to manage this aging

effect. The applicant stated, in Note 1, that the boric acid corrosion program includes specific

inspections of reactor coolant pressure boundary and supporting systems components.

The staff reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.2 of this SER. The staff finds that the general condition monitoring program

provides inspections for the management of loss of material due to boric acid corrosion beyond

the scope of the boric acid corrosion program. Also, visual inspection of external surfaces is

performed during various walkdowns by plant personnel to look for boron buildup and/or boric

acid leaks. On the basis of its review, the staff finds that this program is acceptable for

managing loss of material of copper alloy pipe, tubing, and valves component types exposed to

a borated water leakage external environment..:

In the LRA and the applicant's letter, dated January 11, 2005, the applicant identified no aging

effects for carbon steel, stainless steel, copperalloys, and PVC components exposed internally

and externally to air, including accumulators (reserve air bottles), pipe, valves, hoses, regulators,

tubing, tubing (stored tubing and fittings), compressor after coolers (shell), compressors and

containment instrument air receiver tank component types. Air is not identified in the GALL

Report as an environment for these components and materials.

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On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, carbon steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Wrought austenitic stainless steel and'copper alloys are not

susceptible to significant general corrosion that would affect the intended function of

components. PVC is impervious to air. Therefore, the staff finds that there are no applicable

aging effects requiring management for metal or PVC in an air environment.

3.3A.2.3.8 Nitrogen - Aging Management Evaluation - Table 3.3.2-8 and Table 3.3.2-8a

The staff reviewed Table 3.3.2-8 of the LRA and Table 3.3.2-8a in the applicant's letter, dated

January 11, 2005, which summarized the results of AMR evaluations for the nitrogen system

component groups. The staff reviewed the technical report of AMR results for air and gas

systems.

In the LRA and the applicant's letter, dated January 11, 2005, the applicant identified no aging

effects for stainless steel components exposed externally to air, including pipe, valves, and flow

indicator component types. Air is not identified in the GALL Report as an environment for these

components and materials.

On the basis of current industry research and operating experience, the staff finds that air on

metal will not result in aging that will be of concern during the period of extended operation. The

external environments being referred to are typical of ambient air (e.g., under a shelter, indoors,

or in an air-conditioned enclosure or room). Wrought austenitic stainless steel is not susceptible

to significant general corrosion that would affect the intended function of components.

Therefore, the staff finds that there are no applicable aging effects requiring management for

metal in an air environment.

In the LRA and the applicant's letter, dated January 11, 2005, the applicant identified no aging

effects for stainless steel components exposed internally to gas for pipe, valves and flow

indicator component types. Gas is not identified in the GALL Report as an environment for these

components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (nitrogen, which is an inert gas) on metal will not result in

aging that will be of concern during the period of extended operation. Therefore, the staff finds

that there are no applicable aging effects requiring management for metal in a gas environment.

3.3A.2.3.9 Station Air - Aging Management Evaluation - Table 3.3.2-9 and Table 3.3.2-9a

The staff reviewed Table 3.3.2-9 of the LRA and Table 3.3.2-9a in the applicant's letter, dated

January 11, 2005, which summarized the results of AMR evaluations for the station air system

component groups. The staff reviewed the technical report of AMR results for air and gas

systems.

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In the LRA and the applicant's letter, dated January 11, 2005, the applicant identified no aging

effects for carbon steel, copper alloys, and cast iron components exposed externally to air,

including pipe, valves, air compressor after coolers (shell), air compressor intercoolers (shell),

and compressors component types. Air is not identified in the GALL Report as an environment -

for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments referred to are typical of ambient air (e.g., under a shelter,

indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Carbon steel and cast iron components that are exposed externally to a sheltered air'

environment and not exposed to moisture-laden air or intermittent wetting are expected to.'

experience insignificant amounts of corrosion, and no aging effects are'applicable to this

component/commodity group. Copper alloys are not susceptible to significant general corrosion

that would affect the intended function of components. Therefore, the staff finds that there are'

no applicable aging effects requiring management for metal in an air environment.

In the LRA, the applicant proposed to manage loss of material of copper alloy pipe and valve

component types exposed to a borated water leakage external environment using MPS AMP

B2.1.13, "General Condition Monitoring," which is a plant-specific program. In addition, the

applicant stated that the boric acid corrosion program includes specific inspections of reactor

coolant pressure boundary and supporting systems components. The staff reviewed the general

condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER.

The general condition monitoring program performs inspections for management of loss of

material due to boric acid corrosion beyond the scope of the boric acid corrosion program. The

staff finds that this program is acceptable for managing loss of material since visual inspections

of external surfaces are performed during various walkdowns by plant personnel to look for

boron buildup and/or boric acid leaks.

3.3A.2.3.10 Chemical and Volume Control - Aging Management Evaluation - Table 3.3.2-10

The staff reviewed LRA Table 3.3.2-10, which summarized the results of AMR evaluations for,

the CVCS component groups.

In the LRA, the applicant identified no aging effects for carbon steel, cast iron, and stainless

steel components exposed to air, including boric acid tanks, filter/strainer, flow elements, flow

indicators, letdown heat exchangers (channel head), level indicators, pipe, pulsation dampers,

pumps,- regenerative heat exchangers (channel head), regenerative heat exchangers (shell),

suction stabilizers,-sump tanks, tubing, valves; volume control tank, filters/strainers (housingcharging pump lube oil), lube oil reservoirs (charging pump), and pumps'(charging pump lube

oil) component types. Air is not identified in the GALL Report as an environment for these

components and materials. : : - . -

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or an air-conditioned enclosure or room). Significant corrosion of carbon steel.

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

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moisture. Without the presence of the aggressive environment, low-alloy steel components will

experience insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Wrought austenitic stainless steel is not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

finds that there are no applicable aging effects requiring management for metal in an air

environment.

In the LRA, the applicant proposed to manage loss of material of stainless steel, carbon steel,

cast iron, and copper alloy filter/strainer (housing - charging pump lube oil), lube oil reservoirs

(charging pump), pumps (charging pump lube oil), tubing, tubing (charging pump lube oil), and

valve component types exposed internally and externally to an environment of oil using MPS

AMP B2.1.25, "Work Control Process." The work control process program provides the

opportunity for personnel to visually inspect the internal surfaces of components during

preventive and corrective maintenance activities on an ongoing basis. Oil samples are analyzed

periodically for contaminants for indication of degradation. The work control process program

provides input to the corrective action program if aging effects are identified.

The staff finds the work control process program acceptable for managing the aging effect of

loss of material. The staff's evaluation of the work control process program is documented in

Section 3.0.3.3.4 of this SER.

In the LRA, the applicant identified no aging effects for stainless steel components exposed.

internally to an environment of gas for pipe, pulsation dampers, tubing, and valve component

types. Gas is not identified in the GALL Report as an environment for these components and

materials.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (which is similar to air) on metal will not result in aging that

will be of concern during the period of extended operation. Therefore, the staff finds that there

are no applicable aging effects requiring management for metal in a gas environment.

The inservice inspection program is credited for managing cracking in low-alloy steel bolting

exposed to air. During its review, the staff determined that additional information concerning the

application of this AMP to effectively manage stress corrosion cracking in auxiliary system

bolting was needed to complete its review. This request for information is described in RAI

3.3.11-A-1. RAI 3.3.11-A-1, the applicant's response to this RAI and the staff's evaluation of the

responses are described below.

The credited inservice inspection program AMP to manage CVCS bolting included exceptions to

GALL and RAI 3.3.1 1-A-1 requested the applicant to clarify if the credited program is different

from the GALL bolting integrity, for managing cracking in CVCS piping and bolting in the RCPB

and to identify the specific differences and the basis for those differences. The RAI also

requested the applicant to describe bolting practices to preclude stress corrosion cracking and

additional information to assure that aging degradation is detected before the loss of the

intended function of the closure bolting.

RAI 3.3.11-A-1

For CVCS bolting in an air environment, Note B in LRA Table 3.3.2-10 identifies that the

item is consistent with NUREG-1801 for component material, environment and aging-*

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effect, but the AMP takes some exceptions to NUREG-1 801 AMP. LRA Table 3.3.2-10

references LRA item 3.1.1-26 in Table 3.1.1and credits the inservice inspection program

for managing cracking in CVCS bolting. LRA item 3.1.1-26 states that this item is not

consistent with NUREG-1801 and page B-6 of the LRA states that the aging

management reviews did not identify the need for the GALL XI.M18 bolting integrity AMP.

NUREG-1339 (referenced in GALL AMP XI.M18) includes a condition that bolting -

degradation is resolved on the basis of a plant-specific bolting integrity program. Clarify if

the credited inservice inspection program is different from the GALL bolting integrity -

program for managing cracking in CVCS piping and valve bolting in the RCPB. If there

are differences, identify those specific differences to the GALL bolting integrity program

and the basis for those differences. Describe the bolting practices used to preclude

stress corrosion cracking such as the control of high strength bolting materials,

lubricants, bolt stress and hardness testing. Also, clarify how a visual inspection of CVCS

closure bolting in RCPB piping and valves is effective in detecting fine cracks or cracking

in bolting where the entire bolting surfaces are not readily visible.

By letter dated December 3, 2004, the applicant responded by providing the following

information:

As identified in Appendix B2.0, the Millstone LRA did not include a specific bolting

integrity aging management program (AMP) description with comparison to NUREG

1801, XI.Ml 8 'Bolting Integrity." However, due to NRC concerns related to how and

where Millstone addressed degradation of bolting, Millstone has developed a specific

bolting integrity AMP and is providing a supplement to the Millstone Units 2 and 3 LRAs.

In this letter, the applicant provided both an Appendix A and an Appendix B description of the

bolting integrity AMP. The bolting integrity AMP is identified by the applicant as an existing

program that is consistent with GALL XI.M18 with clarification and exceptions' The staff review

of the new bolting integrity AMP is described in Section 3.0.3.2.18 and Open Items 3.0.3.2.18-1

and 3.0.3.2.18-2.

On the basis of its review of the information provided in the LRA and the additional information

included in the applicant's response to the above RAls pending resolution of the AMP review,

the staff finds the applicant has identified appropriate AMPs for managing the aging effects

caused by leaking borated water on external surfaces of the chemical and volume'control

system component types.

3.3A.2.3.11 Sampling - Aging Management Evaluation - Table 3.3.2-11 and LRA Table

3.3.2-11 a

The staff reviewed Table 3.3.2-11 of the LRA and Table 3.3.2-11 a in the applicant's letter, dated

January 11, 2005, which summarized the results of AMR evaluations for the sampling system

component groups.

In the LRA and the January 11, 2005 supplement, the applicant identified no aging effects for

low-alloy steel and stainless steel bolting, pipe tubes, valves and secondary sample station/sink

component types exposed externally to air. Air is not identified in the GALL Report as an

environment for these components and materials.

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On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of air on metal will not result in aging that will be of concern during

the period of extended operation. Therefore, the staff finds that there are no applicable aging

effects requiring management for metal in an air environment.

In the applicant's letter, dated January 11, 2005, the applicant identified no aging effects for.

copper alloys components exposed internally to gas for sample chiller (tubes) component types.

Gas is not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (nitrogen, which is an inert gas) on metal will not result in

aging that will be of concern during the period of extended operation. Therefore, the staff finds

that there are no applicable aging effects requiring management for metal in a gas environment.

3.3A.2.3.12 Primary Makeup Water - Aging Management Evaluation - Table 3.3.2-12 and Table

3.3.2-12a

The staff reviewed Table 3.3.2-12 of the LRA and Table 3.3.2-12a of the applicant's letter, dated

January 11, 2005, which summarized the results of AMR evaluations for the primary makeup

water system component groups.

In the LRA and the applicant's January 11, 2005 supplement, the applicant identified no aging

effects for low-alloy steel and stainless steel bolting, pipe, flow elements, primary water head

tank, pumps, tubing, valves, deaerator transfer pump and make-up water vacuum deaerator

component types exposed externally to air. Aging effects for these combinations of components,

material, and environment are not identified in the GALL Report.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of air on metal will not result in aging that will be of concern during

the period of extended operation. Therefore, the staff finds that there are no applicable aging

effects requiring management for metal in an air environment.

In the applicant's letter, dated January 11, 2005, the applicant proposed to manage loss of

material of stainless steel for primary water storage tank component types exposed to an

atmosphere/weather environment using AMP B2.1.13, 'General Condition Monitoring Program,"

which is a plant-specific program. The staff reviewed the general condition monitoring program

and its evaluation is documented in Section 3.0.3.3.2 of this SER. The staff finds that the

general condition monitoring program is acceptable for managing loss of material due to pitting

and crevice corrosion since visual inspections will be performed on external surfaces to detect

any sign of aging degradation.

3.3A.2.3.13 Access Control Area Air Conditioning - Aging Management Evaluation -

Table 3.3.2-13 and Table 3.3.2-13a

The staff reviewed Table 3.3.2-13 of the LRA and Table 3.3.2-13a in the applicant's letter, dated

January 11, 2005, which summarized the results of AMR evaluations for the access control area

air conditioning system component groups.

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In the LRA and the applicant's January 11, 2005 supplement, the applicant identified no aging

effects for carbon steel damper housings and access control area air conditioning unit (housing)

components type exposed internally and externally to air environment that is not intermittently

wetted.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the components'

intended functions due to humidity in the absence of cyclic or intermittent wetting conditions,

such as condensation. The applicant interpreted the GALL Report environment termed "warm,

moist air" to be air with an undefined relative humidity level, and not a wetted environment. Since

the AMR approach considers loss of material only in a moisture-laden air and/or intermittently

wetted environment, the GALL Report items were determined to be not applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of -

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3A.2.3.14 Main Condensers Evacuation - Aging Management Evaluation - Table 3.3.2-14 and

Table 3.3.2-14a

The staff reviewed Table 3.3.2-14 of the LRA and Table 3.3.2-14a in the applicant's letter, dated

January 11, 2005, which summarized the results of AMR evaluations for the main condensers

evacuation system component groups.

In the LRA and the applicant's January 11,2005 supplement, the applicant identified no aging

effects for carbon steel components exposed externally to air, including damper housing,

ductwork, fan/blower housing, pipe, valves, filter/strainers, flow orifices, flow switches, and

steam jet air ejector vent condenser (shell) component types. Air is not identified in the GALL

Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or. room). Significant corrosion of carbon and

low-alloy steel requires an electrolytic environment,-and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, low-alloy steel components will

experience insignificant amounts of corrosion, and no aging effects are applicable tothis

component/commodity group. Wrought austenitic stainless steel and CASS are not susceptible

to significant general corrosion that would affect the intended function of components.

Therefore, the staff finds that there are no aging effects requiring management for metal in an

air environment.

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3.3A.2.3.15 Containment Air Recirculation and Cooling - Aging Management Evaluation -

Table 3.3.2-15

The staff reviewed Table 3.3.2-15 of the LRA, which summarized the results of AMR evaluations

for the containment air recirculation and cooling system component groups.

In the LRA, the applicant identified no aging effects for carbon steel and stainless steel HVAC

components exposed internally or externally to air that is not intermittently wetted, including

containment air recirculation cooling unit housings, damper housings, ductwork, fan/blower

housing, pipe, flow elements, tubing, and valve component types.

The applicant stated in the LRA that surfaces of carbon steel and stainless steel components

located within structures have not experienced corrosion degradation that would affect the

intended function of components due to humidity in the absence of cyclic or intermittent wetting

conditions, such as condensation. The applicant interprets the GALL Report environment termed

"warm, moist air" to be air with an undefined relative humidity level, and not a wetted

environment. Since the AMR approach considers loss of material only in a moisture-laden air

and/or intermittently wetted environment, the GALL Report items were determined to be not

applicable.

The staff reviewed operating experience as a confirmation of the validity of the AMR approach

for corrosion in an air environment. The operating experience reviews did not find significant

corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3A.2.3.16 Containment and Enclosure Building Purge - Aging Management Evaluation -

Table 3.3.2-16

The staff reviewed LRA Table 3.3.2-16, which summarized the results of AMR evaluations for

the containment and enclosure building purge system component groups. In the LRA, the

applicant identified no aging effects for carbon steel HVAC components exposed internally or

externally to air that is not intermittently wetted, including damper housings, ductwork, pipe, and

valve component types.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interpreted the GALL Report environment termed "warm, moist air"

to be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed operating experience as a confirmation of the validity of the AMR approach

for corrosion in an air environment. The operating experience reviews did not find significant

corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

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significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3A.2.3.17 Containment Penetration Cooling - Aging Management Evaluation - Table 3.3.2-17

The staff reviewed LRA Table 3.3.2-17, which summarized the results of AMR evaluations for

the containment penetration cooling system component groups. In the LRA, the applicant has

identified no aging effects for carbon steel HVAC components exposed internally and externally

to air that are not intermittently wetted, including damper housings, ductwork, and fan/blower

housing component types.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interpreted the GALL Report environment termed "warm, moist air"

to be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted -i

environment, the GALL Report items were determined to be not applicable.

The staff reviewed operating experience as a confirmation of the validity of the AMR approach

for corrosion in an air environment. The operating"experience reviews did not find significant

corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3A.2.3.18 Containment Post-Accident Hydrogen Control - Aging Management Evaluation -

Table 3.3.2-18

The staff reviewed LRA Table 3.3.2-18, which summarized the results of AMR evaluations for

the containment post-accident hydrogen control system component groups. -

In the LRA, the applicant identified no aging effects for carbon steel and stainless steel HVAC

components exposed internally and externally to air that is not intermittently wetted, including

fan/blower housing, pipe, tubing, valves,; detection chamber, flexible hose, flow elements,

hydrogen recombiner housings, and flow orifices component types.

The applicant stated in the LRA that surfaces of carbon steel and stainless steel components

located within structures have not experienced corrosion degradation that would affect the

intended function of components due to humidity in' the absence of cyclic or intermittent wetting

conditions, such as condensation. The applicant interpreted the GALL Report environment

termed "warm, moist air" to be air with an undefined relative humidity level, and not a wetted

environment. Since the AMR approach considers loss of material only in a moisture-laden air

and/or intermittently wetted environment, the GALL Report items were determined to be not'

applicable. -

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The staff reviewed the, operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, umoist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3A.2.3.19 Control Room Air Conditioning - Aging Management Evaluation - Table 3.3.2-19

The staff reviewed LRA Table 3.3.2-19, which summarized the results of AMR evaluations for

the control room air conditioning system component groups.

In the LRA, the applicant identified no aging effects for carbon steel HVAC components exposed

internally or externally to air that is not intermittently wetted, including compressor casings,

control room air handling units (housing), control room filter banks, damper housings, ductwork,

fan/blower housings (air-cooled condenser unit), fan/blower housings (control room air handling

unit), pipe, valves, and smoke detectors component types.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interpreted the GALL Report environment termed "warm, moist air'

to be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed operating experience as a confirmation of the validity of the AMR approach

for corrosion in an air environment. The operating experience reviews did not find significant

corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

In the LRA, the applicant identified no aging effects for copper alloy HVAC components exposed

internally or externally to air that is not intermittently wetted, including compressor casings (air

cooled compressor), filter/dryer, moisture indicator, muffler, pipe, tubing, and valve component

types.

The applicant stated in the LRA that surfaces of copper alloy components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interpreted the GALL Report environment termed "warm, moist air"

to be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

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The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, 'moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

In the LRA, the applicant identified no aging effects for copper alloy components exposed

internally to an environment of gas for compressor casings, compressor casings (air-cooled

condenser), control room air handling units (coils), filter/dryer, moisture indicator,.mufflers, pipe,

tubing, and valve component types. Gas is not identified in the GALL Report as an environment

for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (which is similar to air) on metal will not result in aging that

will be of concern during the period of extended operation. Therefore, the staff finds that there

are no applicable aging effects requiring management for metal in a gas environment.

During the audit and review, the staff questioned why various portions of the control room air

conditioning system were not included within the scope of license renewal and subject to an

AMR. In its LRA supplement letter dated July 7, 2004, the applicant added several components

to the control room air conditioning system components that are subject to an AMR. The addition

of these components did not result in the addition of material/environment combinations or

AMPs for the control room air conditioning system AMR. The staff finds this

material/environmentlaging effect/AMP combination to be acceptable. The staffs evaluation of

the scope of the control room air conditioning system AMR is documented in Section 2.3A.3.19

of this SER.

3.3A.2.3.20 Control Element Drive Mechanism Cooling - Aging Management Evaluation -

Table 3.3.2-20

The staff reviewed LRA Table 3.3.2-20, which summarized the results of AMR evaluations for

the CEDM cooling system component groups. In the LRA, the applicant proposed to manage

loss of material of stainless steel CEDM cooling coils component groups exposed internally to

moisture-laden air and/or an intermittently wetted environment using AMP B2.1.25, "Work

Control Process," which is a plant-specific program.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. Visual inspections of the internal surfaces of plant components

and plant commodities are performed during the performance of maintenance, in accordance

with the work control process program, to determine the presence of loss of material. The staff

finds that the work control process program is acceptable for managing loss of material due to

general corrosion since visual inspections will be performed on internal surfaces of components

to detect any sign of aging degradation. - 7

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. 'i

3.3A.2.3.21 Diesel Generator Ventilation - Aging Management Evaluation - Table 3.3.2-21

The staff reviewed LRA Table 3.3.2-21, which summarized the results of AMR evaluations for

the diesel generator ventilation system component groups. In the LRA, the applicant has

identified no aging effects for carbon steel HVAC components exposed internally and externally

to air that is not intermittently wetted, including damper housings, ductwork, and fan/blower

housing component types.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interpreted the GALL Report environment termed "warm, moist air"

to be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed operating experience as a confirmation of the validity of the AMR approach

for corrosion in an air environment. The operating experience reviews did not find significant

corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, 'moist air' alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3A.2.3.22 ESF Room Air Recirculation - Aging Management Evaluation - Table 3.3.2-22

The staff reviewed LRA Table 3.3.2-22, which summarized the results of AMR evaluations for

the ESF room air recirculation system component groups.

In the LRA, the applicant identified no aging effects for carbon steel HVAC components exposed

internally and externally to air that is not intermittently wetted, including damper housings,

ductwork, fan/blower housing, ESF room air recirculation unit housings, and pipe component

types.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interpreted the GALL Report environment termed "warm, moist air"

to be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, 'moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

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- -

3.3A.2.3.23 Enclosure Building Filtration - Aging Management Evaluation - Table 3.3.2-23

The staff reviewed LRA Table 3.3.2-23, which summarized the results of AMR evaluations for

the enclosure building filtration system component groups.

In the LRA, the applicant identified no aging effects for carbon and stainless steel HVAC

components exposed internally or externally to air that is not intermittently wetted, including

damper housing, ductwork, enclosure building filtration filter bank housing, fan/blower housing,

pipe, valves, and flow elements component types.

The applicant stated in the LRA that surfaces of carbon and stainless steel components located

within structures have not experienced corrosion degradation that would affect the intended

function of components due to humidity in the absence of cyclic or intermittent wetting

conditions, such as condensation. The applicant interpreted the GALL Report environment

termed *warm, moist air" to be air with an undefined relative humidity level, and not a wetted

environment. Since the AMR approach considers loss of material only in a moisture-laden air

and/or intermittently wetted environment, the GALL Report items were determined to be not

applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, 0

m oist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

In the LRA, the applicant identified no aging effects for copper alloy HVAC components exposed

internally or externally to air that is not intermittently wetted, including tubing and valve

component types.

The applicant stated in the LRA that surfaces of copper alloy components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interpreted the GALL Report environment termed "warm, moist air"

to be air with an undefined relative humidity level, and not a wetted environment. Since' the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews'did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment. -

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- .l

3.3A.2.3.24 Fuel Handling Area Ventilation - Aging Management Evaluation - Table 3.3.2-24

The staff reviewed LRA Table 3.3.2-24, which summarized the results of AMR evaluations for

the fuel handling area ventilation system component groups.

In the LRA, the applicant identified no aging effects for carbon and stainless steel HVAC

components exposed internally or externally to air that is not intermittently wetted, including

damper housing, ductwork, pipe, valves, and flow elements component types.

The applicant stated in the LRA that surfaces of carbon and stainless steel components located

within structures have not experienced corrosion degradation that would affect the intended

function of components due to humidity in the absence of cyclic or intermittent wetting

conditions, such as condensation. The applicant interpreted the GALL Report environment

termed "warm, moist air" to be air with an undefined relative humidity level, and not a wetted

environment. Since the AMR approach considers loss of material only in a moisture-laden air

and/or intermittently wetted environment, the GALL Report items were determined to be not

applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3A.2.3.25 Main Exhaust Ventilation - Aging Management Evaluation - Table 3.3.2-25

The staff reviewed LRA Table 3.3.2-25, which summarized the results of AMR evaluations for

the main exhaust ventilation system component groups.

In the LRA, the applicant identified no aging effects for carbon and stainless steel HVAC

components exposed to an internally or externally to air that is not intermittently wetted, including

damper housing, ductwork, filter bank housing, pipe, tubing, and valve component types.

The applicant stated in the LRA that surfaces of carbon and stainless steel components located

within structures have not experienced corrosion degradation that would affect the intended

function of components due to humidity in the absence of cyclic or intermittent wetting

conditions, such as condensation. The applicant interpreted the GALL Report environment

termed "warm, moist air" to be air with an undefined relative humidity level, and not a wetted

environment. Since the AMR approach considers loss of material only in a moisture-laden air

and/or intermittently wetted environment, the GALL Report items were determined to be not

applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

I

3-282
basis of its review, the staff finds'that there are no aging 'effects requiring management for metal

in an air environment.

In the LRA, the applicant identified no aging effects for copper alloy HVAC components exposed

internally or externally to air that is not intermittently wetted, including the tubing component

type.

The applicant stated in the LRA that surfaces of copper alloy components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interpreted the GALL Report environment termed "warm, moist air"

to be air with an undefined relative humidity level,' and not a wetted environ'ment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to'be not applicable.

The staff reviewed the operating experience as a confirmation of the validity of the'AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion 6f ventilation system components (other than 'cooling'coils and associated'

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, 'moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.'

3.3A.2.3.26 Non-Radioactive Area Ventilation --Aging Management Evaluation - Table 3.3.2-26

The staff reviewed LRA Table 3.3.2-26, which summarized the results of AMR evaluations for

the non-radioactive area ventilation system component groups.

In the LRA, the applicant identified no aging effects for carbon steel HVAC components exposed

internally and externally to air that is not intermittently wetted, including damper housings,

ductwork, and fan/blower housing component types.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic'or intermittent wetting conditions, such as

condensation.-,The applicant interpreted the GALL Report environrfient'termed warm, moist'air"

to be air with an undefined relative humidity level,'and not a wetted envirbnmernt.'Since' the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system'components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosioni for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

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3.3A.2.3.27 Process and Area Radiation Monitoring - Aging Management Evaluation -

Table 3.3.2-27

The staff reviewed LRA Table 3.3.2-27, which summarized the results of AMR evaluations for

the process and area radiation monitoring system component groups.

In the LRA, the applicant identified no aging effects for carbon and stainless steel HVAC

components exposed internally or externally to air that is not intermittently wetted, including

bolting, pipe, tubing, valves, fan blower housing, filter housing, and radiation detectors

component types.

The applicant stated in the LRA that surfaces of carbon and stainless steel components located

within structures have not experienced corrosion degradation that would affect the intended

function of components due to humidity in the absence of cyclic or intermittent wetting -

conditions, such as condensation. The applicant interpreted the GALL Report environment

termed "warm, moist air" to be air with an undefined relative humidity level, and not a wetted

environment. Since the AMR approach considers loss of material only in a moisture-laden air

and/or intermittently wetted environment, the GALL Report items were determined to be not

applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

During the audit and review, the staff questioned why various portions of the process and area

radiation monitoring system were not included within the scope of license renewal and subject to

an AMR. In its LRA supplement dated July 7, 2004, the applicant added several components to

the process and area radiation monitoring system list of components that are subject to an AMR.

The addition of these components did not result in the addition of materiaVenvironment

combinations or AMPs for the process and area radiation monitoring system AMR. The staff

finds this material/environmenitaging effect/AMP combination to be acceptable. Therefore, the

staff's evaluation of the scope of the process and area radiation monitoring system AMR is

documented in Section 2.3A.3.27 of this SER.

3.3A.2.3.28 Radwaste Area Ventilation - Aging Management Evaluation - Table 3.3.2-28

The staff reviewed LRA Table 3.3.2-28, which summarized the results of AMR evaluations for

the radwaste area ventilation system component groups. In the LRA, the applicant has identifiedno aging effects for carbon steel HVAC components exposed internally and externally to air that

is not intermittently wetted, including damper housings and ductwork component types.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interpreted the GALL Report environment termed "warm, moist air"

.

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to be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On thebasis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3A.2.3.29 Turbine Building Ventilation - Aging Management Evaluation - Table 3.3.2-29

The staff reviewed LRA Table 3.3.2-29, which summarized the results of AMR evaluations for

the turbine building ventilation system component groups. In the LRA, the applicant has

identified no aging effects for carbon steel HVAC components exposed internally and externally

to air that is not intermittently wetted, including the damper housings component type.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interpreted the GALL Report environment termed 'warm, moist air"

to be air with an undefined relative humidity level,'and not a wetted environment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3A.2.3.30 Vital Switchgear Ventilation - Aging Management Evaluation - Table 3.3.2-30

The staff reviewed LRA Table 3.3.2-30, which summarized the results of AMR evaluations for

the vital switchgear ventilation system component groups.

In the LRA, the applicant identified no aging effects for carbon steel and cast iron HVAC

components exposed internally and externally to air that is not intermittently wetted, including

damper housings, DC switchgear air conditioning unit housings, ductwork, fan/blower housings,

motor control center (MCC) air conditioning unit housing, pipe, valves, vital switchgear cooling

unit housings, and West 480V LCR cooling unit housings component types.

The applicant stated in the LRA that surfaces of carbon steel and cast iron components located

within structures have not experienced corrosion degradation that would affect the intended

function of components due to humidity in the absence of cyclic or intermittent wetting

conditions, such as condensation. The applicant interpreted the GALL Report environment

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termed "warm, moist air" to be air with an undefined relative humidity level, and not a wetted

environment. Since the AMR approach considers loss of material only in a moisture-laden air

and/or intermittently wetted environment, the GALL Report items were determined to be not

applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

In the LRA, the applicant identified no aging effects for copper alloy HVAC components exposed externally to air that is not intermittently wetted, including MCC air conditioning units

(accumulator), MCC air conditioning units (distributor), MCC air conditioning units (evaporator

coil), MCC air conditioning units (filter/dryer), MCC air conditioning units (receiver), MCC air

conditioning units (sight glass housing), MCC air conditioning units (tubing), and MCC air

conditioning units (valves) component types.

The applicant stated in the LRA that surfaces of copper alloy components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as'

condensation. The applicant interpreted the GALL Report environment termed "warm, moist air"

to be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

approach considers loss of material only in a wetted environment, the GALL Report items were

determined to be not applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that; based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

In the LRA, the applicant identified no aging effects for copper alloy components exposed

internally to an environment of gas for MCC air conditioning units (accumulator), MCC air

conditioning units (distributor), MCC air conditioning units (evaporator coil), MCC air conditioning

units (condenser coil), MCC air conditioning units (filter/dryer), MCC air conditioning units

(receiver), MCC air conditioning units (sight glass housing), MCC air conditioning units (tubing), and MCC air conditioning units (valves) component types. Gas is not identified in the GALL

Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (which is similar to air) on metal will not result in aging that

will be of concern during the period of extended operation. Therefore, the staff finds that there

are no applicable aging effects requiring management for metal in a gas environment.

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3.3A.2.3.31 Unit 2 Fire Protection - Aging Management Evaluation - Table 3.3.2-31

The staff reviewed LRA Table 3.3.2-31, which summarized the results of AMR evaluations for

the Unit 2 fire protection system component groups.''

In the LRA, the applicant identified no aging effects for carbon steel, stainless steel, cast iron,

copper alloy, and PVC components exposed to air, including flame arrestors, flex connections,

flow indicators, flow orifices, nozzles, pipe, pumps, retard chambers, sprinkler heads, strainers,

tubing, valves, and water motor gongs component types. Air is not identified in the GALL Report

as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, low-alloy steel components will

experience insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Wrought austenitic stainless steel and copper alloy are not

susceptible to significant general corrosion that would affect the intended function of

components. PVC is impervious to an air environment. Therefore, the staff finds that there are

no applicable aging effects requiring management for metal in an air environment.

In the LRA, the applicant proposed to manage loss of material of stainless steel drip pans and

tubing component types exposed externally to a moisture-laden air and/or intermittently wetted

environment using AMP B2.1.13, "General Condition Monitoring Program," which is a

plant-specific program. The staff reviewed the general condition monitoring program and its

evaluation is documented in Section 3.0.3.3.2 of this SER. The staff finds that the general

condition monitoring program is acceptable for managing loss of material due to pitting and

crevice corrosion since visual inspections will be performed on external surfaces to detect any

sign of aging degradation.

In the LRA, the applicant proposed to manage loss of material of copper alloy pipe, tubing, and

valve component types exposed to a borated water leakage external environment using MPS

AMP B2.1.13, 'General Condition Monitoring," which is a plant-specific program. However, the

GALL Report specifies GALL AMP XI.M10, "Boric Acid Corrosion," to manage this aging effect.

The applicant stated in Note 1 that the boric acid corrosion program includes specific inspections

of reactor coolant pressure boundary and supporting systems components.

The staff reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.2 of this SER. The staff finds that the general condition monitoring program

provides inspections for management of loss of material due to boric acid corrosion beyond the

scope of the boric acid corrosion program. Also, visual inspection of external surfaces is

performed during various walkdowns by plant personnel to look for boron buildup and/or boric

acid leaks. On the basis of its review, the staff finds that this program is acceptable for

managing loss of material of copper alloy pipe,-tubing, and valve component types exposed to a

borated water leakage external environment..,

3-287
In the LRA, the applicant identified no aging effects for carbon and stainless steel, PVC, and

copper alloy components exposed internally to an environment of air or gas, including flex

connections, flow orifices, nozzles, pipe, sprinkler heads, tubing, valves, and water motor gongs

component types. Gas is not identified in the GALL Report as an environment for these

components and materials. However, the staff identified a discrepancy between Unit 2 fire

protection system sprinkler heads and Unit 3 fire protection sprinkler heads in that the sprinkler

heads in Unit 3 were in a moist air environment and had an aging effect of loss of materials. In

its LRA supplement dated July 7, 2004, the applicant stated that the Unit 2 fire protection

system, as presented in LRA Table 3.3.2-31 (page 3-282), Note 2 (subject to moisture-laden air

and/or intermittently wetted environment), should be included with the copper alloy Nsprinkler

head" component group exposed internally to an air environment for the Unit 2 fire protection

system. The aging effect of "loss of material" should be added to this component group. The fire

protection program will manage these aging effects. Based on the addition of this aging effect,

the staff finds the applicant's response to be acceptable.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (which is similar to air) on metal will not result in aging that

will be of concern during the period of extended operation. Therefore, the staff finds that there

are no applicable aging effects requiring management for metal components in a gas

environment.

The applicant, in the LRA, proposed to manage loss of material of copper alloy pipe, tubing, and

valve component types exposed externally to a moisture-laden air and/or intermittently wetted

environment using AMP B2.1.10, OFire Protection Program," which is consistent with GALL AMP

XL.M26, "Fire Protection," and GALL AMP XI.M27, "Fire Water System." The staff reviewed the

fire protection program and its evaluation is documented in Section 3.0.3.2.7 of this SER. On the

basis of its review, the staff finds that the fire protection program is acceptable for managing loss

of material since visual inspections will be performed on internal surfaces to detect any sign of

aging degradation during maintenance activities.

In the LRA, the applicant proposed to manage loss of material of stainless steel flex connections

component type exposed internally to an environment of oil using AMP B2.1.25, "Work Control

Process." The staff reviewed the work control process program and its evaluation is documented

in Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. Oil samples are analyzed periodically for

contaminants that are an indication of degradation. The work control process program provides

input to the corrective action program if aging effects are identified. The staff finds the work

control process program acceptable for managing the aging effect of loss of material.

3.3A.2.3.32 Unit 3 Fire Protection - Aging Management Evaluation - Table 3.3.2-32

The staff reviewed LRA Table 3.3.2-32, which summarized the results of AMR evaluations for

the Unit 3 fire protection system component groups.

In the LRA, the applicant identified no aging effects for carbon steel, stainless steel, cast iron,

copper alloy, and PVC components exposed to air, including carbon dioxide (CO2) tank cooling

coils, coolant heat exchangers, flex hoses, flex connections, flow switches, instrument snubbers,

nozzles, restricting orifices, sprinkler heads, tubing, valves, flow indicators, housing, diesel fuel

3-288
storage tank, ductwork, exhaust silencer, expansion tank overflow' container, reactor coolant

pump oil collection tanks, flame arrestors, heater unit,- hydropneumatic tank, lube oil cooler,

odorizer, oil mist recovery unit, oil reservoir, pip'e, pumrps, vacuum limiter, and water manifold

component types. Air is not identified in the GALL Report as an environment for'these

components and materials.

On the basis of its review of current industry research and operating 'experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors,'or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture:-Without the presence of the aggressive environment, carbon steel and cast iron

components will experience insignificant amounts 6f corrosion, and no aging'effects are

applicable to this component/commodity group. Wrought austenitic stainless steel and copper

alloy are not susceptible to significant general corrosion that would affect the intended function

of components. PVC is impervious to an air environment.' Therefore, the staff finds that there are

no applicable aging effects requiring management for'metal in an air environment.

However, LRA Table 3.3.2-32, Auxiliary Systems - Unit 3 Fire Protection (page 3-296), for,

external surfaces of copper alloy valves in an ernvironirrint of air, did not include the aging effect

of loss of material as in Unit 2 Table 3.3.2-31,'Auxiliary Systems - Unit 2 Fire Protection (page 3-285). In LRA supplement dated July 7, 2004, the applicant stated that for' the Unit 3 fire

protection system, as presented in Unit 2 Table 3.3.2-32 (page 3-296),-Note'2 (subject to

moisture-laden air and/or intermittently wetted environment), should be included with the copper'

alloy "valves" component group exposed internally to an'air environment for Unit 2 LRA, Table

3.3.2-32, Auxiliary Systems - Unit 3 Fire Protection (page'3-296): The aging effect of "loss of

material" will be added to this component group.' The applicant stated that fire protection ' program will manage this aging effect. Based on'the addition of this aging effect, the staff finds

the applicant's response to be acceptable.

In the LRA, the applicant proposed to manage loss of material of copper alloy filter/strainer -

component type exposed externally to a moisture-laden air and/or intermittently wetted

environment using AMP B2.1.13, 'General Condition Monitoring," which is a plant-specific

program. The'staff reviewed the general condition monitoring'program and its evaluation is

documented in Section 3.0.3.3.2 of this SER. The staff finds that the general condition

monitoring program is acceptable for managing loss of material due to pitting and crevice

corrosi6n since visual inspections will be performed on'extemal surfaces to detect any sign of

aging degradation. r

In the LRA, the applicant identified no aging effects for carbon and stainless steel, PVC, and

copper alloy components exposed internally to an environment of air or gas for CO2 storage

tank, CO2 tank cooling coils, damper housing, fan/blower housing, ductwork flex hoses and

connections, nozzles, odorizers, restricting orifices, tubing, and valve component types. Gas is

not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

an internal environment of gas (which is similar to air) on metal will not result in aging that 'will be

of concern during the period of extended operation. Therefore, the staff finds that there are no

applicable aging effects requiring management for metal in a gas environment.

3-289
In the LRA, the applicant proposed to manage loss of material of copper alloy sprinkler heads

exposed externally to a moisture-laden air and/or intermittently wetted environment using MPS

AMP B2.1.10, 'Fire Protection Program," which is consistent with GALL AMP XI.M26, "Fire

Protection," and GALL AMP XL.M27, "Fire Water System." The staff reviewed the fire protection

program and its evaluation is documented in Section 3.0.3.2.7 of this SER. The staff finds that

the fire protection program is acceptable for managing loss of material since visual inspections

will be performed on internal surfaces to detect any sign of aging degradation during

maintenance activities.

In the LRA, the applicant proposed to manage loss of material of stainless steel'tubing

component type exposed internally to an environment of. oil using AMP B2.1.25, "Work Control

Process." The staff reviewed the work control process program and its evaluation is documented

in Section 3.0.3.3.4 of this'SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. Oil samples are analyzed periodically for

contaminants that are an indication of degradation. The work control process program provides

input to the corrective action program if aging effects are identified. The staff finds the work

control process program acceptable for managing the aging effect of loss of material.

In the LRA, the applicant proposed to manage loss of material of copper alloy and stainless steel

tubing and restricting orifices component types exposed internally to oil (fuel oil) using AMP

B2.1.12, Fuel Oil Chemistry." The staff reviewed the fuel oil chemistry program and its

evaluation is documented in Section 3.0.3.2.9 of this SER. The fuel oil chemistry program is

consistent with GALL AMP XI.M30, "Fuel Oil Chemistry," with acceptable exceptions. On the

basis of its review, the staff finds the program acceptable for managing the aging effects of loss

of material. The effectiveness of the fuel oil chemistry program is verified by MPS AMP B2.1.25,

'Work Control Process." The staff reviewed the work control process, program and its evaluation

is documented in Section 3.0.3.3.4 of this SER. The staff finds that the work control process

program is acceptable for managing loss of material due to general corrosion since visual

inspections will be performed on internal surfaces of components to detect any sign of aging

degradation.

During the audit and review, the staff questioned why various portions of the fire protection

system were not included within the scope of license renewal and subject to an AMR. In its LRA

supplement dated July 7, 2004, the applicant added several components to the fire protection

system that are subject to an AMR. The addition of these components did not result in the

addition of material/environment combinations or AMPs for the fire protection system AMR. The

staff finds this materiaVenvironmentlaging effect/AMP combination to be acceptable. The staffs

evaluation of the scope of the fire protection system is documented in Section 2.3A.3.32 of this

SER.

3.3A.2.3.33 Domestic Water - Aging Management Evaluation - Table 3.3.2-33 and Table

3.3.2-33a

The staff reviewed Table 3.3.2-33 of the LRA, and Table 3.3.2-33a of the applicant's letter,

dated January 11, 2005, which summarized the results of AMR evaluations for the domestic

water system component groups.

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In the LRA, the applicant proposed to manage loss of material of copper alloy pipe and valve

component types exposed externally to a moisture-laden air and/or intermittently wetted -

environment using AMP B2.1.13, "General Condition Monitoring," which is a plant-specificprogram. The staff reviewed the general condition monitoring program and its evaluation is

documented in Section 3.0.3.3.2 of this SER. The staff finds that the general condition

monitoring program is acceptable for managing loss of material due to pitting and crevice

corrosion since visual inspections will be performed on external surfaces to detect any sign of

aging degradation.

In the LRA, the applicant identified no aging effects for stainless steel and PVC components

exposed to air, including pipe and valve component types. Air is not identified in the GALL

Report as an environment for these components and materials. In addition, in the applicant's

letter, dated January 11, 2005, the applicant identified no aging effects for carbon steel

components exposed to air, including domestic water hot water tank component types.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Wrought austenitic stainless steel is

not susceptible to significant general corrosion that would affect the intended function of

components. PVC is impervious to an air environment. Therefore, the staff finds that there are

no applicable aging effects requiring management for metal in an air environment.

In the LRA, the applicant identified no aging effects for PVC pipe component type in a seawater

environment. Operating experience reviews have identified instances of PVC degradation

resulting from exposure to direct sunlight and exposure to ozone from high voltage. Since these

PVC components are not exposed to direct sunlight and are not exposed to high levels of ozone,

the staff concurred that there are no aging effects for PVC pipe components in a seawater'

environment.

3.3A.2.3.34 Diesel Generator - Aging Management Evaluation - Table 3.3.2-34

The staff reviewed LRA Table 3.3.2-34, which summarized the results of AMR evaluations for

the diesel generator system component groups. The staff reviewed the technical report that

provides the AMR results for the diesel generator and support systems.

In the LRA, the applicant proposed to manage loss of material of stainless steel, carbon steel,

cast iron, and copper alloy lube oil heat exchangers (shell), lube oil heaters, oil pans, pipe,

pumps, turbochargers, valves, filter/strainers, lube oil heat exchangers (tubes), lube oil heat

exchangers (tube sheet), tubing, and valve component types exposed internally or externally to

an environment of oil using AMP B2.1.25, uWork Control Process." The staff reviewed the work

control process program and its evaluation is documented in Section 3.0.3.3.4 of this SER. The

work control process program provides the opportunity for personnel to visually inspect the

internal surfaces of components during preventive and corrective maintenance activities on an

ongoing basis. Oil samples are analyzed periodically for contaminants that are an indication of

degradation. The work control process program provides input to the corrective action program if

aging effects are identified. The staff finds the work control process program acceptable for

managing the aging effect of loss of material.

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In the LRA, the applicant proposed to manage loss of material of copper-alloy air-cooling heat

exchangers (tubes) and jacket-water heat exchangers (tubes) component types exposed to

treated water using MPS AMP B2.1.25, "Work Control Process," which is a plant-specific

program. The staff reviewed the work control process program and its evaluation is documented

in Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and;

corrective maintenance activities on an ongoing basis. The work control process program

provides input to the corrective action program if aging effects are identified. The staff finds the

work control process program acceptable for managing the aging effect of loss of material.

In the LRA, the applicant identified no aging effects for carbon steel, stainless steel, cast iron,

nickel-based alloy, copper alloy, and aluminum components exposed internally and externally to

air, including filter/strainers, air cooling heat exchanger (shell), air intercoolers (shell), air start

distributors, jacket water expansion tanks, jacket water heat exchangers (shell), lube oil heat

exchangers (shell), lube oil heaters, oil pans, pipe, pumps, stand-by jacket coolant heaters,

starting air tanks, turbochargers, valves, air cooling heat exchangers (channel), governor,

hydraulic oil boosters, jacket water heat exchangers (channel), level indicators, lube oil heat

exchangers (channel), tubing, expansion joints, and flow orifices component types. Air is not

identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, carbon steel and cast iron

components will experience insignificant amounts of corrosion, and no aging effects are

applicable to this component/commodity group. Wrought austenitic stainless steel, copper alloy,

and aluminum are not susceptible to significant general corrosion that would affect the intended

function of components. Therefore, the staff finds that there are no applicable aging effects

requiring management for metal in an air environment.

The Work Control Process is credited with managing buildup of deposit on copper alloy

tubesheets exposed to an oil environment. During its review, the staff determined that additional

information concerning aging management for buildup of deposit was needed to complete its

review. This request for information is described in RAI 3.3.35-A-1. RAI 3.3.35-A-1, the

applicant's response to this RAI and the staffs evaluation of the responses are described below.

LRA Table 3.3.2-34 identifies copper alloy tubesheets in the lube oil heat exchangers as

susceptible to buildup of deposit in an oil environment. The LRA identifies heat transfer as an

intended function for the tube sheet and credits the work control process AMP for managing this

aging effect. This AMP identifies the use of lubricating oil analysis to detect contaminants and

visual inspections to detect buildup of deposits. In heat exchangers, buildup of deposit

(commonly known as fouling) can adversely affect the heat transfer function. The diesel

generators are normally only operated for short operational periods and the lubricating oil may

not have a chance to reach steady state or worse case conditions during testing. The applicant

was requested to clarify if heat exchanger performance tests to recognized industry practices

are used to detect fouling in the lube oil heat exchangers or are frequent visual inspections and

cleaning required. In the absence of heat exchanger performance testing, the applicant was

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requested to submit the technical justification that unacceptable buildup of deposit on the tube

sheet exposed to lubricating oil would be detected prior to loss of the required heat transfer

function.

By letter dated November 9, 2004, the applicant responded by providing the following

information: -

The performance of the lube oil heat exchangers is confirmed during emergency diesel

generator (EDG) periodic surveillance testing. In accordance with the plant Technical

Specifications, the EDGs are operated at a design load for a minimum of 60 minutes

each 31 days. This test loading and duration ensures that the diesel engine and its

auxiliary systems, including lubricating oil, reach steady state operating conditions for the

majority of the testing period, thereby providing sufficient data to evaluate the heat

transfer performance of the lube oil heat exchanger,

Buildup of deposit due to fouling in an oil environment is not expected to be significant,

but is conservatively assumed in the aging management review for these heat

exchangers because of water contamination of the oil. Buildup of deposit is managed by

the Work Control Process AMP, which includes the periodic testing of the EDGs. Lube oil

temperature is recorded during EDG testing and abnormal readings would initiate an

evaluation through the corrective action process to determine the cause of the elevated

temperatures. The frequency of the EDG performance tests ensures that fouling would

not prevent the intended function of the lube oil heat exchanger. In addition, a review of

Millstone operating experience indicates'that there has been no instances of fouling of

the EDG lube oil heat exchangers affecting the heat transfer intended function,

The staff reviewed the applicant's response and determined that the response was reasonable

and acceptable because the applicant provided sufficient information to conclude that buildup of

deposit in the EDG lube oil heat exchangers will be effectively managed by the work control

process AMP. This conclusion is based on the applicant's periodic surveillance testing of the

EDGs which records steady state lube oil temperatures to detect fouling.

3.3A.2.3.35 Diesel Generator Fuel Oil - Aging Management Evaluation - Table 3.3.2-35

The staff reviewed LRA Table 3.3.2-35, which summarized the results of AMR evaluations for

the diesel generator fuel oil system component groups. The staff reviewed the AMR results

report for the diesel generator and support systems.

In the LRA, the applicant proposed to manage loss of material of copper alloy, carbon steel, and

stainless steel pumps, tubing, valves, and filter/strainers component types exposed internally to

fuel oil using AMP B2.1.12, "Fuel Oil Chemistry." The applicant stated in LRA Section 3.3.2.2.7

that AMP B2.1.25, "Work Control Process," will be used to provide confirmation of theeffectiveness of the fuel oil chemistry program..

The staff reviewed the fuel oil chemistry program and its evaluation is documented in Section

3.0.3.2.9 of this SER. The fuel oil chemistry program (1) monitors and controls fuel oil quality to

ensure that it is compatible with the materials of construction and to manage the conditions that

cause general corrosion, pitting, and MIC of fuel tank internal surfaces; (2) establishes fuel oil

quality limits; and (3) samples and tests fuel oil used for equipment within the scope of license

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renewal. On the basis of its review, the staff finds the fuel oil chemistry program acceptable for

managing this aging effect.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. The work control process program

provides input to the corrective action program if aging effects are identified. The staff finds the

work control process program acceptable for confirming the effectiveness of the fuel oil

chemistry program.

In the LRA, the applicant identified no aging effects for carbon steel, stainless steel, cast iron,

copper alloy, and aluminum components-exposed internally and externally to air, including flame

arrestors, clean oil storage tanks, diesel oil supply tanks, level indicators, pipe, pumps, valves,

filter/strainers, and tubing component types. Air is not identified in the GALL Report as an

environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, carbon steel and cast iron

components will experience insignificant amounts of corrosion, and no aging effects are

applicable to this component/commodity group. Wrought austenitic stainless steel, copper alloy,

and aluminum are not susceptible to significant general corrosion that would affect the intended

function of components. Moreover, the diesel fuel oil tank is supported on saddle-type steel

supports and is not in contact with concrete or soil. Therefore, the staff finds that there are no

applicable aging effects requiring management for metal in an air environment.

3.3A.2.3.36 Station Blackout Diesel Generator - Aging Management Evaluation - Table 3.3.2-36

The staff reviewed Table 3.3.2-36 of the LRA, which summarized the results of AMR evaluations

for the station blackout (SBO) diesel generator system component groups. The staff reviewed

the technical report that provides the AMR results for the diesel generator and support systems.

In the LRA, the applicant proposed to manage cracking of stainless steel expansion tanks, pipe,

tubing, and valve component types exposed internally to treated water using AMP B2.1.25,

"Work Control Process," which is a plant-specific program. The staff reviewed the work control

process program and its evaluation is documented in Section 3.0.3.3.4 of this SER. The work

control process program provides the opportunity for personnel to visually inspect the internal

surfaces of components during preventive and corrective maintenance activities on an ongoirig

basis. The work control process program provides input to the corrective action program if aging

effects are identified. As stated above, the staff finds the work control process program

acceptable for managing the aging effect of cracking.

In the LRA, the applicant proposed to manage loss of material of stainless steel, carbon steel,

and cast iron flow indicators, lube oil coolers (channel), oil sumps, pipe, silencers, pumps, turbo

chargers, lube oil coolers (tubes), lube oil coolers (tube sheet), radiators, lubricators, restricting

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orifices, tubing, and valve component types exposed internally or externally to oil using AMP

B2.1.25, "Work Control Process," which is a plant-specific program. The staff reviewed the work

control process program and its evaluation is documented in Section 3.0.3.3.4 of this SER. The

work control process program provides the opportunity for personnel to visually inspect the

internal surfaces of components during preventive and corrective maintenance activities on an

ongoing basis. Oil samples are analyzed periodically for contaminants for indication of

degradation. The work control process program provides input to the corrective action program if

aging effects are identified. Also as stated above, the staff finds the work control process

program acceptable for managing the aging effect of loss of material.

In the LRA, the applicant proposed to'manage loss of material of stainless steel fuel heaters,

tubing, and valves component types exposed internally to fuel oil using AMP B2.1.12, 'Fuel Oil

Chemistry." The applicant stated in LRA Section 3.3.2.2.7 that AMP B2.1.25, "Work Control

Process,' will be used to provide confirmation of the effectiveness of the fuel oil chemistry

program. The staff reviewed the fuel oil chemistry program and its evaluation is documented in

Section 3.0.3.2.9 of this SER. The fuel oil chemistry program (1) monitors and controls fuel oil

quality to ensure that it is compatible with the materials of construction and to manage the

conditions that cause general corrosion, pitting, and MIC of fuel tank internal surfaces; (2)

establishes fuel oil quality limits; and (3) samples and tests fuel oil used for equipment within the

scope of license renewal. On the basis of its review, the staff finds the fuel oil chemistry program

acceptable for managing this aging effect.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. Oil samples are analyzed periodically for

contaminants for indication of degradation. The work control process program'provides input to

the corrective action program if aging effects are identified. The staff finds the work control -

process program acceptable for confirming the effectiveness of the fuel oil chemistry program.

In the LRA, the applicant proposed to manage loss of material of stainless steel expansion tanks

and valve component types exposed to atmosphere/weather using MPS AMP B2.1 .13, "General

Condition Monitoring," which is a plant-specific program. The staff reviewed the general

condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER.

The staff finds that the general condition monitoring program is acceptable for managing loss of'

material due to pitting and crevice corrosion since visual inspections will be performed on

external surfaces to detect any sign of aging degradation.

In the LRA, the applicant proposes to manage loss of material of stainless steel valve

component group exposed internally to moisture-laden air and/or an intermittently wetted

environment using AMP B2.1.25, 'Work Control Process," which is a plant-specific program. The

staff reviewed the work control process program and its evaluation is documented in Section

3.0.3.3.4 of this SER. Visual inspections of the internal surfaces of plant components and plant

commodities are performed during the performance of maintenance, in accordance with the

work control process program, to determine the presence of loss of material. The staff finds that

the work control process program is acceptable for managing loss of material due to pitting and

crevice corrosion since visual inspections will be performed on internal surfaces of components

to detect any sign of aging degradation. -

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In the LRA, the applicant identified no aging effects for carbon steel, stainless steel, cast iron,

and aluminum components exposed internally and externally to'air, including filter/strainers,

radiators, aftercoolers, aspirators, flow indicators, fuel heaters, fuel oil day tanks, immersion

heaters, injectors, lube oil coolers (channel), lube oil coolers (shell), oil sumps, pipe, silencers,

pump, turbochargers, air receivers, expansion joints, lubricators, pulsation dampeners,

restricting orifices, tubing, and valve component types. Air is not identified in the GALL Report as

an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, carbon steel and cast iron

components will experience insignificant amounts of corrosion, and no aging effects are

applicable to this component/commodity group. Wrought'austenitic stainless steel, and

aluminum are not susceptible to significant general corrosion that would affect the intended

function of components. Therefore, the staff concurs that there are no applicable aging effects

requiring management for metal in an air environment.

In the LRA, the applicant identified no aging effects for rubber expansion joints exposed to air.

Based on industry research and operating experience, change of material properties due to

thermal exposure and irradiation and cracking due to irradiation of rubber components in air is'

contingent on radiation levels, ambient temperatures, and exposure to ultraviolet radiation and

ozone.

On the basis of its review, the staff concurs with the applicant's finding that no aging effect for

rubber expansion joints in air is applicable, since these components are not exposed to high

levels of ultraviolet radiation, ozone, or temperatures greater than 95 "F.

In the LRA, the applicant identified no aging effects for aluminum filter/strainers component

types exposed internally to lubricating oil. The technical report of AMR results for the diesel

generator and support systems did not specifically evaluate aging effects for aluminum exposed

internally to oil. During the audit and review, the staff requested that the applicant provide a

basis for its conclusion that there are no aging effects requiring management for this

combination of component, material, and environment. During the audit, the applicant stated that

the MAER was used as the basis. The staff reviewed the applicant's MAER and finds that

additional information regarding the basis was necessary. The applicant revised its MAER and

the technical report of AMR results for the diesel generator and support systems to include the

basis. The staff reviewed the basis and finds it acceptable based on the addition of information

to the MAER and the technical report. In addition, the applicant stated that, in a lubricating oil

environment, significant corrosion is only expected where the water can settle or pool. Due to the

differential densities of lubricating oil and water, water will tend to-separate and settle in l6w-flow

or stagnant areas where the flow velocity is insufficient to flush the water through the system.

Lube oil systems are assumed to be free of water contamination as their initial condition. Lubeoil systems are typically closed systems that have little potential for ingress of contaminants

unless a component failure occurs. License renewal does not assume component failures as a

means to establish the conditions necessary for aging to occur. For example, tube failures in

lube oil coolers are not assumed. Therefore, water contamination of lube oil is event-driven, and

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would be addressed by corrective mnaintenance. For license renewal purposes, lube oil is

therefore assumed to be free of water contamination. On the basis of its review, the staff

concurs that there are no applicable aging effects requiring management for aluminum in a fuel

oil environment. -

In the LRA, the applicant identified no aging effects for aluminum radiators component types

exposed externally to atmosphere/weather. -The technical report that provides the AMR results

for the diesel generator and support systems did not specifically evaluate aging effects for '.

aluminum in an external environment of atmosphere/weather. During the audit and review, the

staff requested that the applicant provide a basis for its conclusion that there are no aging

effects requiring management for this combination of component, material, and environment.

During the audit, the applicant stated that the technical report was revised to add the following

statement:

Industry experience identified a potential conflict with the MAER with regard to

aluminum in an air environment. St. Lucie identified corrosion problems with the

aluminum and copper components associated with the cooling fins of a radiator in

a cooling water system. The St. Lucie evaluation identified that it was an unusual

occurrence since aluminum elsewhere in the plant did not demonstrate similar

problems. Accordingly, and in conjunction with the MAER basis, operating

experience was used to validate that no problems of this type had occurred.

The staff reviewed the revised technical report and operating experience. On the basis of its

review, the staff finds that there are no applicable aging effects requiring management for

aluminum in an atmosphere/weather environment.

3.3A.2.3.37 Security - Aging Management Evaluation - Table 3.3.2-37

The staff reviewed LRA Table 3.3.2-37, which summarized the results of AMR evaluations for

the security system component groups. The staff reviewed the AMR results report for the diesel

generator and support systems.

In the LRA, the applicant proposed to manage loss of material of carbon steel, cast iron, and

copper alloy coolers (shell), fan/blower housings, heaters, oil pans, pipe, pump, valves,

filter\strainers, coolers (tubes), and coolers (tube sheet) component types exposed internally or

externally to lubricating oil using AMP B2.1.25, :Work Control Process." The staff reviewed the

work control process program and its evaluation is documented in Section 3.0.3.3.4 of this SER.

The work control process program provides the opportunity for personnel to visually inspect the

internal surfaces of components during preventive and corrective maintenance activities on an

ongoing basis. Oil samples are analyzed periodically for contaminants for indication of

degradation. The work control process program provides input to the corrective action program if

aging effects are identified. The staff finds the work control process program acceptable for

managing the aging effect of loss of material;

In the LRA, the applicant proposed to manage loss of material of copper alloy pipe, tubing, and

valve component types exposed internally to fuel oil using AMP B2.1.12, "Fuel Oil Chemistry."

The applicant stated in LRA Section 3.3.2.2.7 that AMP B2.1.25, "Work Control Process," will be

used to provide confirmation of the effectiveness of the fuel oil chemistry program. The staff

reviewed the fuel oil chemistry program and its evaluation is documented in Section 3.0.3.2.9 of

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this SER. The fuel oil chemistry program (1) monitors and controls fuel oil quality to ensure that

it is compatible with the materials of construction and to manage the conditions that cause

general'corrosion, pitting, and MIC of fuel tank internal surfaces; (2) establishes fuel oil quality

limits; and (3) samples and tests fuel oil used for equipment within the scope of license renewal.

The staff finds the fuel oil chemistry program acceptable.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The staff finds the work control process program provides the

opportunity for personnel to visually inspect the internal surfaces of components during

preventive and corrective maintenance activities on an ongoing basis. It also provides input to

the corrective action program if aging effects are identified. On the basis of its review, the staff

concluded that the work control process program is acceptable for confirming the effectiveness

of the fuel oil chemistry program.

In the LRA, the applicant identified no aging effects for carbon steel, cast iron, and copper alloy

components exposed internally and externally to air, including coolers (channel head), coolers

(shell), diesel fuel oil storage tank, fan/blower housings, filter/strainers, heaters, oil pans, pipe,

pumps, valves, filter/strainers, tubing, and radiators component types. Air is not identified in the

GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon'steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, carbon steel and cast iron

components will experience insignificant amounts of corrosion, and no aging effects are

applicable to this component/commodity group. Copper alloys are not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

finds that there are no applicable aging effects requiring management for metal in an air

environment.

In the LRA, the applicant identified no aging effects for the aluminum radiators component type

exposed externally to air. The technical report of AMR results for the diesel generator and

support systems did not specifically evaluate aging effects for aluminum in an external

environment of air. During the audit and review, the staff requested that the applicant provide a

basis for its conclusion that there are no aging effects requiring management for this

combination of component, material, and environment. The applicant stated to the staff that the

technical report was revised to add the following statement:

Industry experience identified a potential conflict with the MAER with regard to

aluminum in an air environment. St. Lucie Power Plant identified corrosion

problems with the aluminum and copper components associated with the cooling

fins of a radiator in a cooling water system. The St. Lucie evaluation identified that

it was an unusual occurrence since aluminum elsewhere in the plant did not

demonstrate similar problems. Accordingly, and in conjunction with the MAER

basis, operating experience was used to validate that no problems of this type

had occurred.

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The staff reviewed the revised technical report and operating experience. On the basis of its

review, the staff finds that there are no applicable aging effects requiring management for

aluminum in an air environment.

3.3A.2.3.38 Clean Liquid Waste Processing - Aging Management Evaluation - Table 3.3.2-38

and Table 3.3.2-38a

The staff reviewed Table 3.3.2-38 of the LRA and Table 3.3.2-38a of the applicant's letter, dated

January 11, 2005, which summarized the results of AMR evaluations for the clean liquid waste

processing system component groups.

In the LRA, the applicant credits AMP B2.1.6, 'Chemistry Control Program for Secondary

Systems," for managing the loss of material aging effect for the carbon steel degasifier

preheater shell component type exposed internally to steam. The applicant stated that the

environment is not in the GALL Report for this component type and material. The applicant

further stated that the chemistry control for secondary systems program provides reasonable

assurance that water quality is compatible with the materials of construction in the plant systems

and equipment in order to minimize loss of material and cracking. The program provides an

environment that minimizes material degradation, maintains material integrity, and reduces the

amount of corrosion product that could interfere with equipment operation and heat transfer. The

applicant stated that the chemistry control for secondary systems program is based on EPRI

guidelines provided in TR-102134, "PWR Secondary Water Chemistry Guidelines." These

guidelines reflect industry operating experience to optimize plant chemistry control.

The staff reviewed the chemistry control for secondary systems program and its evaluation is

documented in Section 3.0.3.2.3 of this SER. The staff finds that this program is consistent with

GALL AMP XI.M2 with acceptable exceptions.

On the basis of its review of current industry research, operating experience,- and the technical

report for AMR results for steam and power conversion systems, the staff finds that the

chemistry control for secondary systems program is acceptable for managing loss of material

due to general corrosion and crevice corrosion of carbon steel components in steam, since this

program provides an environment that minimizes material degradation, maintains material

integrity, and reduces the amount of corrosion.

In the LRA, the applicant proposes to manage loss of material of stainless steel primary drain

tank and quench cooler tubes and tube sheet component types exposed to treated water using

MPS AMP B2.1.25, Work Control Process," which is a plant-specific program. The staff

reviewed the work control process program and its evaluation is documented in Section 3.0.3.3.4

of this SER. The work control process program provides the opportunity for personnel to visually

inspect the internal surfaces of components during preventive and corrective maintenance

activities on an ongoing basis. The work control process program provides input to the corrective

action program if aging effects are identified. The staff finds the work control process program

acceptable for managing the aging effect of loss of material.

In the LRA and the applicant's supplement, dated January 11, 2005, the applicant proposed to

manage loss of material of the stainless steel primary drain tank and equipment drain tank

component type exposed internally to moisture-laden air and/or an intermittently wetted

environment using AMP B2.1.25, "Work Control Process," which is a plant-specific program. The

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staff reviewed the work control process program is its evaluation is documented in Section

3.0.3.3.4 of this SER. Visual inspections of the internal surfaces of plant components and plant

commodities are performed during the performance of maintenance, in accordance with the

work control process program, to determine the presence of loss of material. The staff finds that

the work control process program is acceptable for managing loss of material due to general

corrosion since visual inspections will be performed on internal surfaces of components to detect

any sign of aging degradation.

In the applicant's January 11, 2005 supplement, the applicant proposed to manage loss of

material of the stainless steel for the degasifier vent condenser (shell) and the degasifiers

exposed to treated water and steam environment using AMP B2.1.5, "Chemistry Control for

Primary Systems Program." The staff reviewed the chemistry control for primary systems

program and its evaluation is documented in Section 3.0.3.2.2 of this SER. The staff finds that

this program is consistent with GALL AMP XI.M2, "Water Chemistry," with an acceptable

exception. Since this program is consistent with the GALL Report recommendation for other

components with the same material, environment, and aging effect, the staff finds this to be

acceptable.

In the LRA and the applicant's letter, dated January 11, 2005, the applicant identified no aging

effects for carbon steel and stainless steel components exposed to a sheltered air environment

for degasifier effluent cooler shell and degasifier preheater shells, degasifier aftercooler helicoil

tubes, flow elements, primary drain tank, and quench tank cooler shell, pipe, primary drain tank,

pumps, strainers, tubing, valves, conductivity element, degasifier vent condenser (shell), -

degasifiers, equipment drain sump tank, flexible hoses and flow indicators component types. Air

is not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of air on metal will not result in aging that will be of concern during

the period of extended operation. Therefore, the staff finds that there are no applicable aging

effects requiring management for metal in an air environment.

3.3A.2.3.39 Gaseous Waste Processing - Aging Management Evaluation - Table 3.3.2-39

The staff reviewed LRA Table 3.3.2-39, which summarized the results of AMR evaluations for

the gaseous waste processing system component groups.

In the LRA, the applicant identified no aging effects for carbon steel components exposed to air,

including after coolers (shell), pipe, valves, and waste gas compressor seal coolers component

types. Air is not identified in the GALL Report as an environment for these components and

materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The extemal environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, carbon steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

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component/commodity group. Therefore, the staff finds that there are no applicable aging effects

requiring management for metal in an air environment.

In the LRA, the applicant proposes to manage loss of material of stainless steel after coolers

(tubes), after coolers (tube sheet), pipe, and valve component types exposed internally to

moisture-laden air and/or an intermittently wetted environment using AMP B2.1.25, Work

Control Process," which is a plant-specific program. The staff reviewed the work control process

program and its evaluation is documented in Section 3.0.3.3.4 of this SER. Visual inspections of

the internal surfaces of plant components and'plant commodities are performed during the

performance of maintenance, in accordance with the work control process program, to

determine the presence of loss of material. The staff finds that the work control process program

is acceptable for managing loss of material due to pitting and crevice corrosion since visual

inspections will be performed on internal surfaces of components to detect any sign of aging

degradation.

3.3A.2.3.40 Post-Accident Sampling - Aging Management Evaluation - Table 3.3.2-40

The staff reviewed LRA Table 3.3.2-40, which summarized the results of AMR evaluations for

the post-accident sampling system component groups.

In the LRA, the applicant identified no aging effects for stainless steel components exposed to

air, including bolting, flushing accumulators, nitrogen accumulators, filter/strainers, flow.,

elements, pumps, reservoir, sample chambers, tubing, and valve component types. Air is not

identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Without the presence of an

aggressive environment, no aging effects are applicable to this component/commodity group.

Wrought austenitic stainless steel is not susceptible to significant general corrosion that would

affect the intended function of components. Therefore, the staff finds that there are no

applicable aging effects requiring management for metal in an air environment.

In the LRA, the applicant proposed to manage loss of material of stainless steel flushing

accumulators, sample chambers, reservoir, pumps, tubing, and valve component types exposed

internally to moisture-laden air and/or an intermittently wetted environment using AMP B2.1.25,

"Work Control Process," which is a plant-specific program. The staff reviewed the work control

process program and its evaluation is documented in Section 3.0.3.3.4 of this SER. Visual

inspections of the internal surfaces of plant components and plant commodities are performed

during the performance of maintenance, in accordance with the work control process program,.

to determine the presence of loss of material. The staff finds that the work control process

program is acceptable for managing loss of material due to general corrosion since visual

inspections will be performed on internal surfaces of components to detect any sign of aging

degradation.

In the LRA, the applicant identified no aging effects for stainless steel components exposed

internally to gas for nitrogen accumulators, tubing, and valve component types. Gas is not

identified in the GALL Report as an environment for these components and materials.

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____________ __________ _____________________________________________j

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (which is similar to air) on metal will not result in aging that

will be of concern during the period of extended operation. Therefore, the staff concurs that

there are no applicable aging effects requiring management for metal in a gas environment.

3.3A.2.3.41 Station Sumps and Drains - Aging Management Evaluation - Table 3.3.2-41 and

Table 3.3.2-41a

The staff reviewed Table 3.3.2-41 of the LRA and Table 3.3.2-41 a in the supplement, dated

January 11, 2005, which summarized the results of AMR evaluations for the station sumps and

drains system component groups.

In the LRA and the applicant's letter, dated January 11, 2005, the applicant identified no aging effects for copper-alloy, carbon and stainless steel, cast iron, and PVC components exposed to

air, including piping, pumps, tubing, valves, collection section tank, flow indicators, and filter

component types. Air is not identified in the GALL Report as an environment for these

components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room).. Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, carbon steel and cast iron

components will experience insignificant amounts of corrosion, and no aging effects are

applicable to this component/commodity group. Wrought austenitic stainless steel is not

susceptible to significant general corrosion that would affect the intended function of

components. PVC is impervious to a dry air environment. Therefore, the staff concurs that there

are no applicable aging effects requiring management for metal in an air environment.

In the LRA and the January 11, 2005, supplement, the applicant proposed to manage loss of

material of the copper alloy valve component types and of stainless steel collection section tank

component types exposed internally to moisture-laden air and/or an intermittently wetted internal

environment using AMP B2.1.25, "Work Control Process," which is a plant-specific program. The

staff reviewed the work control process program and its evaluation is documented in Section

3.0.3.3.4 of this SER. Visual inspections of the internal surfaces of plant components and plant commodities are performed during the performance of maintenance, in accordance with the

work control process program, to determine the presence of loss of material. The staff finds that

the work control process program is acceptable for managing loss of material due to pitting and

crevice corrosion since visual inspections will be performed on internal surfaces of components to detect any sign of aging degradation.

In the LRA and its letter dated January 11, 2005, the applicant identified no aging effects for

PVC material of pipe and filters component type in a raw water environment. Operating experience reviews have identified instances of PVC degradation resulting from exposure to

direct sunlight and exposure to ozone from high voltage. Since these PVC components are not

exposed to direct sunlight and are not exposed to high levels of ozone, the staff concurs that

there are no aging effects for PVC material of pipe and filters component types in a raw water

environment.

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Operating experience reviews have identified instances of PVC degradation resulting from

exposure to direct sunlight and exposure to ozone from high voltage. Since these PVC

components are not exposed to direct sunlight and are not exposed to high levels of ozone, the

staff concurs that there are no aging effects for PVC pipe components in seawater environment.

3.3A.2.3.42 Table 1: Auxiliary Systems - Aerated Liquid Radwaste - Aging Management

Evaluation

In the LRA letter of November 9, 2004, the applicant identified no aging effects for stainless steel

exposed to air, including conductivity element, flow elements, flow indicator, pipe, pumps, tubing,

and valve component types. Air is not identified in the GALL Report as an environment for these

components and materials.

On the basis of current industry research and operating experience, stainless'steel exposed

externally to air are not susceptible to significant general corrosion that would affect the intended

function of components. Therefore, the staff finds that there are no applicable aging effects for

stainless steel components in an air environment.-

3.3A.2.3.43 Table 2: Auxiliary Systems - Solid Waste Processing - Aging Management

Evaluation

In the LRA supplement of November 9, 2004, the applicant identified no aging effects for

stainless steel exposed to air, including flow indicator, pipe, pumps, spent resin fill head tank,

tubing, and valve component types. Air is not identified in the GALL Report as an environment

for these components and materials.

On the basis of current industry research and operating experience, stainless steel exposed

externally to air are not susceptible to significant general corrosion that would affect the intended

function of components. Therefore, the staff finds that there are no applicable aging effects for

stainless steel components in an air environment.

3.3A.2.3.44 Table 3: Auxiliary Systems - Turbine Building Closed Cooling Water - Aging'

Management Evaluation

In the LRA supplement of November 9, 2004, the applicant stated that loss of material of

chemical addition tank, flexible hoses, flow elements, flow orifices and tubing of stainless steel

exposed to moisture-laden air and/or intermittently wetted environment in the auxiliary system is

managed using AMP B.2.1.13, "General Condition Monitoring." The staff reviewed the general

condition monitoring and its evaluation is documented in Section 3.0.3.3.2 of this SER. The staff

finds that this program is acceptable for managing loss of material since visual inspection of

external surfaces is performed during various walkdowns.

In the LRA supplement of November 9, 2004, the applicant identified no aging effects for copper

alloys exposed to gas in for the chiller condensers (tubes) component types. Gas is not identified

in the GALL Report as an environment for these components and materials. On the basis of

current industry research and operating experience, copper alloys exposed externally to gas are

not susceptible to significant general corrosion that would affect the intended function of

components.

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In the LRA supplement of November 9, 2004, the applicant stated that loss of material of

TBCCW heat exchangers (tubes) of copper alloys stainless steel in treated water environment in

the auxiliary system is managed using AMP B.2.1.25, 'Work Control Process."

The staff reviewed the work control process and its evaluation is documented in Section

3.0.3.3.4 of this SER. The work control process program performs maintenance activities to

provide visual inspection and tracks the performance of inspection and surveillance activities. On

this basis, the staff finds that the management of cracking for these components is adequate.

3.3A.2.3.45 Table 4: Auxiliary Systems - Water Box Priming - Aging Management Evaluation

In the LRA supplement of November 9, 2004, the applicant identified no aging effects for copper

alloys and stainless steel exposed to indoors air environment and are not intermittently wetted

for the filler/strainers, flow orifices, flow switches, pipe, and valve component types.

On the basis of current industry research and operating experience, copper alloys and stainless

steel exposed externally to indoors air environment and are not intermittently wetted are not

susceptible to significant general corrosion that would affect the intended function of

components.

All other AMRs in LRA Tables 3.3.2-1 through 3.3.2-41 and LRA supplements were evaluated.

The staff finds them to be acceptable.

Conclusion. On the basis of its review, the staff finds that the applicant appropriately evaluated

AMR results involving combinations of material, environment, AERM, and AMP that are not

evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the

effects of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.3A.3 Conclusion

On the basis of its review, the staff concludes that the applicant has demonstrated that the aging

effects associated with the auxiliary systems components will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable FSAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the auxiliary systems, as

required by 10 CFR 54.21(d).

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3.31B Unit 3 Aging Management of Auxiliary Systems

This section of the SER documents the staffs review of the applicant's AMR results for the

Unit 3 auxiliary systems components and component groups associated with the following

systems:

* circulating water system

* service water system

* sodium hypochlorite system

* reactor plant component cooling system

* turbine plant component cooling water system

* chilled water system

* charging pumps cooling system

* safety injection pumps cooling system

* neutron shield tank cooling system

* containment atmosphere monitoring system

* containment instrument air system

* instrument air system

* nitrogen system

* service air system

* chemical and volume control system

* reactor plant sampling system

* primary grade water system

* auxiliary building ventilation system

* circulating and service water pumphouse ventilation system

* containment air recirculation system

* containment purge air system

* containment leakage monitoring system

* containment vacuum system

* control building ventilation system

* control rod drive mechanism (CRDM) ventilation and cooling system

* emergency generator enclosure ventilation system

* engineered safety features (ESF) building ventilation system

* .fuel building ventilation system

* hydrogen recombiner and hydrogen recombiner building HVAC system

* main steam valve building ventilation system

* service building ventilation and air-conditioning system

* station blackout (SBO) diesel generator building ventilation system

* supplementary leak collection-and-release system

* technical support HVAC and filtration systems

* turbine building area ventilation system

* waste disposal building ventilation system

* Unit 2 fire protection system

* Unit 3 fire protection system

* domestic water system

* emergency diesel generator system

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* emergency diesel generator fuel oil system

* SBO diesel generator system

* security system

* boron recovery system

* radioactive liquid waste processing system

* radioactive gaseous waste system

* post-accident sampling system

* radioactive solid waste system)

* reactor plant aerated drains system

* reactor plant gaseous drains system

* sanitary water system

3.3B.1 Summary of Technical Information In the Application

In LRA Section 3.3, the applicant provided AMR results for auxiliary systems components and

component groups. In LRA Table 3.3.1, "Summary of Aging Management Evaluations in Chapter

VII of NUREG-1801 for Auxiliary Systems," the applicant provided a summary comparison of its

AMRs with the AMRs evaluated in the GALL Report for the auxiliary systems components and

component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.3B.2 Staff Evaluation

The staff reviewed LRA Section 3.3 to determine if the applicant provided sufficient information

to demonstrate that the effects of aging for the auxilary system components that are within the

scope of license renewal and subject to an AMR will be adequately managed so that the'

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

Also, the staff performed an onsite audit of AMRs to confirm the applicant's' claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report. However, the staff did verify that the material presented

in the LRA was applicable and that the applicant had identified the appropriate GALL AMPs. The

staff's evaluations of the AMPs are documented in Section 3.0.3 of this SER. Details of the

staff's audit evaluation are documented in the staffs MPS audit and report and summarized in

Section 3.3B.2.1 of this SER.

The staff also performed an onsite audit of those AMRs that were consistent with the GALL

Report and for which further evaluation is recommended. The staff verified that the applicant's

further evaluations were consistent with the acceptance criteria in Section 3.3.2.2 of

NUREG-1 800, "Standard Review Plan for Review of License Renewal Applications for Nuclear

Power Plants," dated July 2001. The staffs audit evaluation are documented in the staff's MPS

audit and report and summarized in Section 3.3B.2.2 of this SER.

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The staff performed an onsite audit and conducted a'technical review of the remaining AMRs

that were not consistent with or not addressed in the' GALL Report. The audit and technical

review included evaluating whether all plausible aging effects were identified and whether the

aging effects listed were appropriate for the combination' of materials and environments

specified. The staff's audit evaluations are documented in the staff's MPS audit and report and

summarized in Section 3.3B.2.3 of this SER. The staffs evaluation of its technical review is also

documented in Section 3.3B.2.3 of this SER.

Finally, the staff reviewed the AMP summary descriptions in the FSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the auxiliary system components.

Table 3.3B-1 below provides a summary of the staffs evaluation of components, aging effects/mechanisms, and AMPs listed in LRA Section 3.3 that are addressed in the GALL

Report.

Table 3.3B-1 Staff Evaluation for Auxiliary System Components in the GALL Report

.Comnonent Group i'-';Aging Effect/- -'AMP in GALL.- _ _ .AMPiin LRA - -Staff Evaluation

Mechanism:.-:%

Components in Loss of material due Water chemistry Not applicable Not applicable (See

spent fuel pool to general, pitting, and one time Section 3.3B.2.2.1)

cooling and cleanup and crevice inspection

(Item Number corrosion

3.3.1-01) ' ' __' -;

Linings in spent fuel Hardening, cracking Plant-specific Work control process Consistent with

cooling and cleanup and loss of strength (82.1.25); General GALL (See Section

system; seals and due to-elastomer : condition monitoring 3.38.2.2.2)

collars in ventilation' degradation; loss of (82.1.13)

systems material due to wear

(Item Number

3.3.1-02) " ''

Components In load Cumulative fatigue TLAA, evaluated TLAA This TLAA is

handlingchemical damage in accordance with evaluated in Section

and volume control 10 CFR 52.21(c) 4.38, Metal Fatigue

system (PWR), and

reactor water

cleanup and

shutdown cooling

systems (older ,

BWR)

(Item Number

3.3.1-03) , :-_,

Heat exchangers In Crack initiation and Plant-specific Consistent with

reactor water growth due to SCC GALL (See Section

cleanup system or cracking 3.3B.2.2A)

(BWR); high

pressure pumps In

chemical and

volume control

system (PWR) (Item

Number 3.3.1-04) - I

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ComponentGroup- AgingEfActM A iPGALnL . ,,a -"M f Evluatio n: ~ i.- --, ha-na ism . 7 .; - R- epiort' .. e.. 'i -;

Components in Loss of material due Plant-specific General condition Consistent with

ventilation systems, to general, pitting, monitoring (B2.1.13); GALL, which

diesel fuel oil and crevice Fl re protection recommends further

system, and corrosion, and MIC program (B2.1.10); evaluation (See

emergency diesel Work control process Section 3.3B.2.2.5)

generator systems; (B2.1.25); Tank

external surfaces of inspection program

carbon steel (B2.1.24);

components Structures monitoring

(Item Number program (B2.1.23);

3.3.1-05) Infrequently accessed

areas inspection

program (B2.1.15)

Components in Loss of material due One-time Tank inspection Consistent with

reactor coolant to galvanic, general, inspection program (B2.1.24); GALL (See Section

pump oil collection pitting, and crevice Work control process 3.3B.2.2.6)

system of fire corrosion (B2.11.25)

protection

(Item Number

3.3.1-06)

Diesel fuel oil tanks Loss material due to Fuel oil chemistry Fuel oil chemistry Consistent with

in diesel fuel oil general, pitting, and and one-time program (B2.1.12); GALL, which

system and crevice corrosion, inspection Work control process recommends further

emergency diesel MIC, and biofouling (B2.1.25) evaluation (See

generator system Section 3.3B.2.2.7)

(Item Number

3.3.1-07)

Heat exchangers in Crack initiation and Water chemistry Chemistry control for Consistent with

chemical and growth due to SCC and plant-specific primary systems GALL, which

volume control and cyclic loading verification program (B2.1.5); recommends further

system program Work control process evaluation (See

(Item Number (B2.1.25) Section 3.3B.2.2.9)

3.3.1-09)

Neutron absorbing Reduction of Plant-specific Chemistry control for Consistent with

sheets in spent fuel neutron absorbing primary systems GALL, which

storage racks capacity and loss of program (B2.1.5) recommends further

(Item Number material due to evaluation (See'

3.3.1-10) general corrosion Section 3.3B.2.2.1 0)

(Boral, boron steel) ._.._.

New fuel rack Loss of material due Structures Not consistent with

assembly to general, pitting monitoring GALL (See Section

(Item Number and, crevice 3.5B.2.3.4)

3.3.1-11) corrosion

The new fuel rack

assembly is

fabricated from

stainless steel. No

aging effect

management is

required for the

stainless steel fuel

rack assembly.

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ComponentGroup6 ' -. Aging ff iKiR:R vR 

; -a:-:- >-:_"Mechanism: . : e r - P. x ,

Neutron absorbing Reduction of Boraflex Boraflex neutron

sheets in spent fuel neutron absorbing absorbing sheetsro

racks capacity due to used in the spent

(Item Number Boraflex fuel storage racks

3.3.1-12) degradation are not credited

spent fuel pool

criticality analysis.

Therefore, the

Boraflex sheets

perform no intended

function;

Spent fuel storage Crack initiation and Water chemistry Not consistent with

racks and valves in growth due to stress GALL The spent

spent fuel pool corrosion cracking fuel pool water

cooling and cleanup temperature is

(Item Number maintained below

3.3.1-13) the threshold

temperature of 140

degree F for SCC.

Closure bolting and Loss of material due Boric acid Boric acid corrosion Consistent with

external surfaces of to boric acid corrosion (B2.1.3; GALL (See Section

carbon steel and corrosion General condition 3.3B.2.1.1)

low-alloy steel monitoring (B2.1 .13)

components

(Item Number

3.3.1-14)

Components in or Loss of material due. Closed-&ycle Closed-cycle cooling Consistent with

serviced by to general, pitting, cooling water water system GALL, which

closed-cycle cooling and crevice system (82.1.7); recommends no

water system corrosion, and MIC Work control process further evaluation

(Item Number (B2.1.25); (See Section

3.3.1-15) Chemistry control for 3.3B.2.1)

primary systems

program (b2.1.5);

Chemistry control for

secondary systems

program (82.1.6)

Cranes, Including Loss of material due Overhead heavy Inspection activities: Consistent with

bridge and trolleys, to general corrosion load and light load load handling cranes GALL, which

and rail system In and wear handling systems and devices (B2.1.19) recommends no

load handling further evaluation

system (See Section

(Item Number 3.3B.2.1)

3.3.1-16) .

Components In or Loss of material due Open-cycle Service water system Consistent with

serviced by to general, pitting, cooling water (open-cycle cooling) GALL, which

open-cycle cooling crevice, and system (B2.1.21); recommends no

water systems galvanic corrosion, Work control process further evaluation

(Item Number MIC, and biofouling; (B2.1.25); (See Section

3.3.1-17) buildup of deposit Closed-cycle cooling 3.3B.2.1.2)

due to biofouling water system (B2.1.7)

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ComponentGroup. .- Aging Effecthr AMP in GALL ''' x-x AMP In LRA *'.. 'St ffEvaiuatlon. - -~~~f;- -A n M-echanis m ' S Re'p'or d~'' t'*'_' c'; ............................. -, i '--E'_--';' -'

Buried piping and Loss of material due Buried piping and Buried piping Consistent with

fittings to general, pitting, tank surveillance inspection (B2.1.4) GALL, which

(Item Number and crevice recommends further

3.3.1-18) corrosion, and MIC or evaluation (See Section 3.3B.2.2.1 1)

Buried piping and

tanks inspection

Components in Loss of material due Compressed air Work control process Not consistent with

compressed air to general and monitoring (B2.1.25); Tank GALL (See Section

system pitting corrosion Inspection program 3.3B.2.3)

(Item Number (B2.1.24)

3.3.1-19)

Components (doors Loss of material due Fire protection Fire protection Consistent with

and barrier to wear, hardening program (B2.1.10); GALL (See Section

penetration seals) in and shrinkage due Work control process 3.3B.2.1.3)

concrete structures to weathering (B2.1.25)

in fire protection

(Item Number

3.3.1-20) . . .

Components in Loss of material due Fire water system Fire protection Not consistent with

water-based fire to general, pitting, program (B2.1.10); GALL (See Section

protection crevice, and Work control process 3.33.2.3)

(Item Number galvanic corrosion, (B2.1.25) ; Tank

3.3.1-21) MIC, and biofouling inspection program

(32.1.24) -

Components in Loss of material due Fire protection and Fuel oil chemistry Not consistent with

diesel fire system to galvanic, general, fuel oil chemistry (B2.1.12) GALL (See Section

(Item Number pitting, and crevice 3.36.2.3)

3.3.1-22) corrosion

Tanks in diesel fuel Loss of material due Above ground Tank inspection Consistent with

oil system to general,'pitting, carbon steel tanks program (B2.1.24) GALL, which

(Item Number and crevice recommends no

3.3.1-23) corrosion further evaluation

(See Section

3.3B.2.1)

Closure bolting Loss of material due Bolting integrity Bolting integrity Consistent with

(Item Number to general GALL (See Section

3.3.1-24) corrosion; crack 3.3B.2.1.6) initiation and growth

due to cyclic loading

and SCC

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Co,

-Component Group -Agn Effcl _ - AMP InGALL-` -AP nLR Saf`vIuto J. . - r i.t

-p~~ Mehais-StaffprV>- .- ______ lua on__

Components Loss of material due Selective leaching Work control process Consistent with

(aluminum, bronze, to selective leaching of materials (B2.1.25); Buried GALL (See Section

brass, cast iron. piping inspection 3.3B.2.1 A)

cast steel) in (82.1.4) open-cycle and

closed-cycle cooling

water systems, and

ultimate heat sink

(Item Number

3.3.1-29) : ; :. '

Fire barriers, walls, Concrete cracking Fire protection and Not consistent with

ceilings, and floors and spalling due to structures GALL (See Section

in fire protection freeze-thaw, monitoring 3.58.2.3.37)

(Item Number aggressive chemical

3.3.1-30) attack, and reaction

with aggregates; loss of material due

to corrosion of

embedded steel

The staffs review of the MPS auxiliary systems and associated components followed one of

several approaches. One approach, documented in Section 3.31B.2.1, involves the staffs review

of the AMR results for components in the auxiliary systems that the applicant indicated are

consistent with the GALL Report and do not require further evaluation. Another approach,

documented in Section 3.31B.2.2, involves the staff's review of the AMR results for components

in the auxiliary systems that the applicant indicated are consistent with the GALL Report and for

which further evaluation is recommended. A third approach, documented in Section 3.31B.2.3,

involves the staffs review of the AMR results for components in the auxiliary systems that the

applicant indicated are not consistent with the GALL Report or are not addressed in the GALL

Report. The staffs review of AMPs that are credited to manage or monitor aging effects of the

auxiliary systems components is documented in Section 3.0.3 of this SER.

3.3B.2.1 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Not Recommended

Summary of Technical Information in the Apolication. In Section 3.3.2.1 of the Unit 3 LRA, the

applicant identified the materials, environments, and aging effects requiring management. The

applicant identified the following programs that manage the aging effects related to the auxiliary

systems components:

* infrequently accessed areas inspection program

* work control process

* service water system (open-cycle cooling)

* closed-cycle cooling water system

* boric acid corrosion

* general condition monitoring

* buried pipe inspection program . -.

* tank inspection program'

* chemistry control for primary systems program

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* chemistry control for secondary systems program * inservice inspection program: systems, components, and supports

* fire protection program

* fuel oil chemistry

* bolting integrity program

Staff Evaluation. In Tables 3.3.2-1 through 3.3.2-50 of the Unit 3 LRA, the applicant provided a

summary of AMRs for the auxiliary systems components and identified which AMRs it

considered to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes described how the information

in the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicated the AMR was consistent with the GALL Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicated that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP takes some exceptions to the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by the

applicant was consistent with the AMP identified in the GALL Report and whether the AMR was

valid for the site-specific conditions.

Note C indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP is consistent

with the AMP identified by the GALL Report. This note indicates that the applicant was unable to

find a listing of some system components in the GALL Report. However, the applicant identified

a different component in the GALL Report that had the same material, environment, aging effect, and AMP as the component that was under review. The staff audited these line items to

verify consistency with the GALL Report. The staff also determined whether the AMR line item of

the different component was applicable to the component under review and whether the AMR

was valid for the site-specific conditions.

Note D indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP takes some

exceptions to the AMP identified in the GALL Report. The staff audited these line items to verify consistency with the GALL Report. The staff verified whether the AMR line item of the different

component was applicable to the component under review. The staff verified whether the

identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The staff

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also determined whether the AMP identified by the applicant was consistent with the AMP

identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note E indicated that the AMR line item is consistent with the GALL Report for material, -

environment, and aging effect, but a different aging management program is credited. The staff*

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified by

the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the LRA, as documented

in its MPS audit and review report. The staff did not repeat its review of the matters described in

the GALL Report. However, the staff did verify that the material presented in the LRA was

applicable and that the applicant had identified the appropriate GALL Report AMRs. The staff

evaluation is discussed below.

3.3B.2.1.1 Loss of Material Due to Boric Acid Corrosion

In the discussion section of LRA Table 3.3.1, Item 3.3.1-14, the applicant stated that loss of

material due to boric acid corrosion is managed by MPS AMP B2.1.3, "Boric Acid Corrosion

Program," and MPS AMP B2.1.13, "General Condition Monitoring Program." The boric acid

corrosion program includes specific inspections of reactor coolant pressure boundary and

supporting systems components. The boric acid corrosion program and general condition

monitoring program are evaluated in Sections 3.0.3.1 and 3.0.3.3.2 of this SER.

In the Unit 3 LRA, the applicant stated that the general condition monitoring program provides

inspections for management of loss of material due to boric acid corrosion beyond the scope of

the boric acid corrosion program. During the audit, the staff asked the applicant for clarification

of how loss of material for components not normally visible, or in infrequently accessed areas, is

managed by this program. During the audit, further carification was requested on how

identification, documentation, evaluation, and trending of boric acid leakage is performed under

this program. During the audit, the applicant stated that the general condition monitoring

program is an extension of the boric acid corrosion program in that it identifies borated water

leakage during inspections and then, through the corrective action program, the leak is assigned

and evaluated by the boric acid corrosion program. When borated water leakage is identified by

the general condition monitoring program, a condition report is written to identify the leak. During

the daily review of the new condition reports, it is assigned to the boric acid corrosion program

where it gets fully evaluated and repaired as required. This is the same process used to identify

leaks in the boric acid corrosion program.

For those areas identified as infrequently accessed areas, for the purposes of detecting boric

acid leakage, entry into the area is performed often enough (at least once per refueling interval)

to credit the general condition monitoring program. The one exception is the Unit 3 demineralizer

cubicles area. However, for this area, a video inspection is performed at least once every 10

years to verify the integrity of the equipment. There is reasonable assurance that this inspection

interval will detect borated water leakage prior to the loss of intended function of the affected

equipment. In addition, the inspection opportunities for these cubicles will probably be more

frequent than once every 10 years due to the need to perform corrective maintenance, filter

changeout, etc. The Unit 3 areas accessed at least once per refueling interval are typically

observed by operations personnel during tagouts, health physics during general area surveys or

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a survey performed for upcoming work in the area, or during containment walkdowns as part of

the boric acid corrosion program.

The staff's evaluation of the general condition monitoring program is documented in Section

3.0.3.3.2 of this SER. On the basis of its review, the 'staff finds that this program is acceptable

for managing loss of material since visual inspections of external surfaces are performed during

various walkdowns by plant personnel to detect boron buildup and/or boric acid leaks.

3.3B.2.1.2 Loss of Material Due to General, Pitting, and Galvanic Corrosion, MIC, and

Biofouling; Buildup of Deposits Due to Biofouling

In the discussion section of LRA Table 3.3.1, Item 3.3.1-17, the applicant stated that loss of

material for components in an open-cycle cooling water environment is managed by MPS AMP

B2.1.21, uService Water System (Open-Cycle Cooling) Program." However, Item 3.3.1-17 does

not address buildup of deposits in a seawater environment for the heat exchanger tubes and

lined piping as an aging effect managed by the service water program. In LRA supplement dated

July 7, 2004, the applicant stated that Unit 3 LRA Table 3.3.1, Item 3.3.1-17 (page 3-210), the

first sentence in the discussion should include "and Buildup of Deposits" after "Loss of Material."

The staff reviewed the applicant's response and finds that response is acceptable.

In an LRA supplement dated November 9, 2004, the applicant added the groundwater

underdrains storage tank to the scope of license renewal and performed an aging management

review. The applicant stated that loss of material of stainless steel is managed using MPS AMP

B2.1.24, "Tank Inspection Program." The applicant also stated that visual inspections are

performed that look for loss of material (e.g., pitting, MIC, etc). Because the subject tank is fully

accessible from underneath (i.e., it is not resting on the ground or concrete), volumetric

inspection is not necessary. The staff reviewed the tank inspection program and its evaluation is

documented in Section 3.0.3.2.17 of this SER. On the basis of its review, the staff finds that the

tank inspection is acceptable for managing this aging effect.

3.3B.2.1.3 Loss of Material Due to Wear, Hardening and Shrinkage Due to Weathering

In the discussion section of LRA Table 3.3.1, Item 3.3.1-20, the applicant stated that loss of

material due to wear is not an applicable'aging effect for components (doors and barrier

penetration seals) in the fire protection system. Fire doors could'see wear on hinges, locks, etc.,

due to periodic opening and closing. This could cause loss of material and impact on the

intended function of fire doors. During the audit and review, the staff asked the applicant to

provide justification as to why this aging effect was not included. The applicant stated that fire

doors are passive features to seal passageways through fire-rated barriers. Fire doors are

equipped with hardware and attachmentlclosure'devices that perform their intended function

with moving parts and/or change of configuration, and are considered to be active components.

As such, wear of the hardware, appurtenances, and attachment/closure mechanisms is not

considered to be an aging effect, but rather a consequence of frequent or rough usage. The

applicant restated that the conclusions in the Unit 3 LRA remain valid and unchanged. However,

the applicant initiated revisions to the Unit 3 technical report for miscellaneous structural'

commodities to incorporate, in Section 2.0 of this SER, the above evaluation for wear of the

hinges and locks for the fire doors. On the basis of its review, the staff finds the applicant's

response to be acceptable.

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3.3B.2.1.4 Loss of Material Due to Selective Leaching

In the discussion section of LRA Table 3.3.1, Item 3.3.1-29, the applicant stated that loss of

material due to selective leaching is managed using MPS AMP B2.1.25, "Work Control Process,"

and MPS AMP B2.1.4, "Buried Pipe Inspection Program." The applicant stated that these two

programs are not consistent with GALL AMP XL.M33, "Selective Leaching of Materials," in that

the GALL Report recommends a one-time visual inspection and hardness measurement of

selected components that may be susceptible to selective leaching to determine whether loss of

materials due to selective leaching is occurring and whether the process will affect the ability of

the components to perform their intended function for the period of extended operation.

However, the work control process program and the buried pipe inspection program perform

only routine visual inspections (which is more than a one-time inspection) when the opportunity

arises, but do not perform hardness testing. The staff reviewed the work control process

program and the buried pipe inspection program and its evaluation is documented in Sections

3.0.3.3.4 and 3.0.3.2.1 of this SER, respectively.

Since selective leaching generally does not cause changes in dimension and is difficult to detect

by visual inspection alone, the staff asked the applicant to justify the use of visual inspection

only, or provide other means of detection (Brinnell hardness, destructive testing) or other

mechanical means (scraping, chipping, etc.).

In the Unit 3 technical report for the work control process, the applicant stated that selective

leaching is an aging mechanism that causes an aging effect of change in material properties.

However, in Unit 3 technical report for closed water system AMR, the applicant stated that

selective leaching is an aging mechanism under the aging effect of loss of material. Unit 3

technical report for the closed water system AMR also references the Unit 3 technical report for

the material aging effect report, which considers selective leaching under loss of material. The

staff noted there is a discrepancy as to how selective leaching is considered between the AMP

and the AMR technical reports.

During the audit and review, the applicant was requested to provide a rationale for considering

selective leaching as causing change in material properties, which is generally an aging effect

associated with non-metallic, elastomer type materials. The applicant concurred that the

technical report for the work control process should have associated selective leaching with the

aging effect of loss of material. The staff reviewed the change document to the technical report

for the work control process, which identifies the change to include selective leaching under the

"loss of material" aging effect. On the basis of its review, the staff finds this to be acceptable.

During the audit and review, the staff also noted that there was an error in the line item for cast

iron and copper alloys in LRA Table 3.3.2-37 (pages 3-341 to 3-352) Unit 3 fire protection

system. It appeared that the applicant may have intended to reference Table 3.3.1, Item

3.3.1-29 for selective leaching instead of referencing Table 3.3.1, Item 3.3.1-21. Unit 2 has

referenced this correctly. Also, the GALL Report item should be Vil.C.1.2-a, similar to that

referenced in the Millstone LRA.

In an LRA supplement dated July 7, 2004, the applicant stated that the Unit 3 LRA Table

3.3.2-37 (pages 3-341 to 3-352) should state, "3.3.1-29" for the second Table 1 Item listed for

components with cast iron/raw water and copper alloy/raw water material/environment

combinations. The NUREG-1801 Volume 2 Item column for the affected component groups

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should be 'VII.Cl.2-a' except for the 'Pipe" and 'Tubing" component groups, which should be

"VII.C1.1-a." The staff reviewed the applicant's response and finds that it is acceptable.

3.3B.2.1.5 Loss of Fracture Toughness Due to Thermal Aging Embrittlement

The applicant identified, in LRA Table 3.3.2-15 (page 3-268), for the CVCS, loss of fracture

toughness as an aging effect for stainless steel regenerative heat exchanger (page 3-268) and

valves (page 3-275). The staff noted that loss of fracture toughness is an aging effect normally

associated with CASS material. During the audit and review, the applicant was requested to

clarify the material. In LRA supplement dated July 7, 2004, the applicant stated that the material

listed for the regenerative heat exchanger (channel head) and regenerative channel head (shell)

in Unit 3 LRA Table 3.3.2-15 should be "stainless steel (CASS)" rather than just "stainless steel."

The staff reviewed the applicant's response and finds it acceptable.

During the audit and review, the staff also questioned why various portions of the fire protection

system were not included within the scope of license renewal and subject to an AMR. In its LRA

supplement letter July 7, 2004, the applicant added several components to the fire protection

system list of components that are subject to an AMR. The addition of these components did not

result in the addition of material/environment combinations or AMPs for the fire protection

system AMR. The staff finds this material/environmentlaging effect/AMP combination to be

acceptable. The staffs evaluation of the scope of the fire protection system is documented in

Section 3.0.3.2.7 of this SER.

3.3B.2.1.6 Loss of Material Due to General Corrosion; Crack Initiation and Growth Due to Cyclic

Loading and Stress Corrosion Cracking

In LRA Table 3.3.1, Item 3.3.1-24, the applicant stated that bolting in the auxiliary systems is not

subject to wetted conditions, therefore, loss of material due to general corrosion is not expected.

Additionally, cracking for bolting in auxiliary systems is not identified as an AERM.

The staff noted that SRP-LR Table 3.3-1 recommended GALL AMP Xl.M18, "Bolting Integrity,"

for managing closure bolting in high pressure or high temperature system for loss of material

due to general corrosion; crack initiation and growth due to cyclic loading and SCC.

The staff questioned the applicant whether all the resolution of generic safety issue for bolting,

as stated in NUREG-1 339, are addressed. By letter dated December 3, 2004, the applicant

submitted its LRA supplement. In its response, the applicant stated that it has developed a

specific bolting integrity aging management program that addressed degradation of bolting at

MPS. The bolting integrity program is reviewed in Section 3.0.3.2.18 of this SER.

By letter dated January 11, 2005, the applicant submitted its bolting aging management roll-up

item. In its response, the applicant replaced the existing information in the "Discussion" column

of Unit 3 LRA Table 3.3.1, Item 24 with "consistent with the NUREG-1 801.

The staff reviewed the applicant's response and finds this acceptable since it is consistent with

the GALL Report.

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On the basis of its audit and review, the staff determined that for all other AMRs not requiring

further evaluation, as identified in the Unit 3 LRA Table 3.3.1 (Table 1), the applicant's

references to the GALL Report are acceptable and no further staff review is required.

Staff RAls Pertaining to Recent Operatina Experience and Emerging Issues. Because the GALL

Report and SRP-LR were issued in July 2001, these documents do not reflect the most current

recommendations for managing certain aging effects that have been the subject of recent

operating experience or the topic of an emerging issue. As a result, the staff issued an RAI to

determine how the applicant proposed to address these items for license renewal. The

applicant's response to this RAI, and the staff's evaluations of the response, is documented as

follows.

Boric Acid Corrosion (RAI 3.3-B-1). The LRA identified a borated water leakage environment for

various mechanical components in auxiliary systems. Both the boric acid corrosion program and

general condition monitoring program are credited with managing loss of material from external

surfaces of these components. The LRA stated that the general condition monitoring program is

performed in accessible plant areas. The applicant was requested to clarify how loss of material

is managed for auxiliary system components not normally visible, such as under insulation or in

normally inaccessible areas. In addition, the LRA states that the boric acid corrosion program is

consistent with GALL AMP XI.M1 0. The scope of GALL AMP Xl.M1 0 is limited to components in

the vicinity of the reactor coolant pressure boundary. However, it appears that the MPS boric

acid corrosion program is credited with managing loss of material caused by borated water

leakage in systems that may not be in the vicinity of the reactor coolant pressure boundary, such

as the radwaste area ventilation system. The applicant was requested to clarify this potential

discrepancy. If the scope of the MPS boric acid corrosion program is different from the GALL

XI.M10 program, the applicant was requested to revise the MPS program description

accordingly in the AMP and FSAR supplement. Also the applicant was requested to identify the

basis for applying the boric acid corrosion program to manage boric acid corrosion in copper

alloy and cast iron materials that are not addressed in GALL AMP XL.MI0 and may require a

different inspection frequency.

By letter dated December 3 2004, the applicant responded as follows:

In a response dated December 3, 2004, the applicant clarified that general equipment (or

materials) inspections are performed as often as daily. The applicant indicated that an

independent assessment was performed by INPO in August 2003 and boric acid leaks are

captured in the station corrective action program. INPO noted that the computer based training

module has increased awareness of station employees with regard to boric acid corrosion and

minor program enhancements are being addressed through the corrective action program.

The applicant stated that the following clarification will be added to Section A2.1.2, Boric Acid

Corrosion Program, of the Unit 3 LRA:

The boric acid corrosion program provides both detection and analysis of leakage of

borated water inside containment. The general condition monitoring program is the

primary method for detecting borated water leakage outside containment. The analysis of

the leakage is performed through the boric acid corrosion program. Any necessary

corrective actions are implemented through the corrective action program.

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The staff reviewed the applicant's response and determined that the response was reasonable

and acceptable because the applicant credits a combination of the general condition monitoring

program and the boric acid corrosion program to detect and evaluate borated water leakage and

boric acid corrosion to maintain the intended function of the auxiliary system components. For

areas outside containment, general equipment (or materials) frequent inspections are performed

as often as daily, which would identify any borated water leakage and any required subsequent

evaluation. The applicant has agreed to include a clarification in the FSAR supplement to

indicate that the general condition monitoring program is the primary method for detecting

borated water leakage outside containment and the analysis of the leakage is performed through

the boric acid corrosion program with corrective actions implemented through the corrective

action program.

On the basis of its audit and review, the staff determined that for AMRs not requiring further

evaluation, as identified in LRA Table 3.3.1 (Table 1), the applicant's references to the GALL

Report are acceptable and no further project team review is required.

Conclusion. The staff has evaluated the applicant's claim of consistency with GALL Report. The

staff also has reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff finds that the AMR results, which the applicant claimed to be consistent with the GALL

Report, are consistent with the AMRs in the GALL Report. Therefore, the staff finds that the

applicant has demonstrated that the effects of aging for these components will be adequately

managed so that their intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.3B.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Anplication. In LRA Section 3.3.2.2, the applicant

provides further evaluation of aging management as recommended by the GALL Report for

auxiliary systems. The applicant provided information concerning how it will manage the

following aging effects:

* loss of material due to general, pitting, and crevice corrosion

* hardening and cracking or loss of strength due to elastomer degradation or loss of

material due to wear

* cumulative fatigue damage

* crack initiation and growth due to cracking or stress corrosion cracking

* loss of material due to general, microbiologically influenced, pitting, and crevice corrosion

* loss of material due to general, galvanic, pitting, and crevice corrosion

* loss of material due to general, pitting, crevice, and microbiologically influenced corrosion

and biofouling

* quality assurance for aging management of non-safety-related components

* crack initiation and growth due to stress corrosion cracking and cyclic loading

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* reduction of neutron-absorbing capacity and loss of material due to general corrosion

* loss of material due to general, pitting, crevice, and microbiologically influenced corrosion

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff reviewed the applicant's evaluation to determine whether it

adequately addressed the issues that were further evaluated. In addition, the staff audited the

applicant's further evaluations against the criteria contained in Section 3.3B.2.2 of the Standard

Review Plan for License Renewal. Details of the staff's audit and review are documented in the

staff's audit and review report.

The GALL Report indicates that further evaluation should be performed for the aging effects

described in the following sections.

3.3B.2.2.1 -Loss of Material Due to General, Pitting, and Crevice Corrosion

In LRA Section 3.3.2.2.1, the applicant addressed loss of material in components of the spent

fuel pool system.

SRP-LR Section 3.3.2.2.1 states that loss of material due to general, pitting, and crevice

corrosion could occur in the channel head and access cover, tubes, and tube sheets'of the heat

exchanger in the spent fuel pool cooling and cleanup system. The water chemistry program

relies on monitoring and control of reactor water chemistry based on EPRI TR-1 05714 -' -'

guidelines for primary water chemistry and TR-I 021 34 for secondary water chemistry to manage

the effects of loss of material from general, pitting, or crevice corrosion. However, high

concentrations of impurities at crevices and locations of stagnant flow conditions could cause

general, pitting, or crevice corrosion. Therefore, verification of the effectiveness of the chemistry

control program should be performed to ensure that corrosion is not occurring. The GALL Report

recommends further evaluation of programs to manage loss of material from general, pitting,

and crevice corrosion to verify the effectiveness of the water chemistry program.' A one-time

inspection of selected components at susceptible locations is an acceptable method for ensuring

that corrosion is not occurring and that the component's intended function will be maintained

during the period of extended operation. .~ ,, e -

Further, SRP-LR Section 3.3.2.2.1 states that loss of material due to pitting and crevice

corrosion could occur in the filter housing, valve bodies, and nozzles of the ion exchanger in the

spent fuel pool cooling and cleanup system. The water chemistry program relies on monitoring

and control of reactor water chemistry based on EPRI TR-1 05714 guidelines for primary water

chemistry and TR-1 02134 for secondary water chemistry to manage the effects of loss of

material from pitting or crevice corrosion. However, high concentrations of impurities at crevices

and locations of stagnant flow conditions could cause pitting or crevice corrosion. Therefore,

verification of the effectiveness of the chemistry control program should be performed to ensure

that corrosion is not occurring. The GALL- Report recommends further evaluation of programs to

manage loss of material from pitting and crevice corrosion to verify the effectiveness of the water

chemistry program. A one-time inspection of selected components at susceptible locations is an

acceptable method to ensure that corrosion is not occurring and that the component's intended

function will be maintained during the period of extended operation.

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The AMP recommended by the GALL Report is GALL AMP Xl.M2, 'Water Chemistry," for

management of loss of material due to general, pitting, and crevice corrosion.

The applicant stated in the LRA that as set forth in the GALL Report, this item applies to spent

fuel pool cooling and cleanup carbon steel components with elastomer linings. The spent fuel

pool cooling system does not contain carbon steel components with elastomer linings.

Therefore, the applicant concluded that this item is not applicable. The applicant has included

the spent fuel pool cooling system in Unit 3 LRA Section 3.2, "Engineered Safety Features

Systems." The staff reviewed Unit 3 LRA Table 3.2.2-5, AMR for spent fuel pool cooling system,

and verified that the system did not contain carbon steel components with elastomer linings. On

the basis of its review, the staff finds this line item is not applicable for components in the Unit 3

spent fuel pool cooling system.

However, these components are fabricated from stainless steel material. As stated in Section

3.2B.2.3.5 of this SER, the applicant proposed to manage loss of material of stainless steel

expansion joints, flow elements; pipe, pumps, and spent fuel pool heat exchangers (channel

head) component types exposed to chemically treated borated water using only

MPS AMP B2.1.5, 'Chemistry Control for Primary Systems Program," which is consistent with

GALL AMP XI.M2, "Water Chemistry," with an exception. The staff reviewed the chemistry

control for primary systems program and its evaluation is documented in Section 3.0.3.2.2 of this

SER. The exception relates to use of a later, non-NRC-approved revision of the EPRI guidelines.

The staff finds that because the effects of pitting and crevice corrosion on stainless steel

components are not significant in chemically treated borated water, inspection of selected

components to verify the absence of loss of material is not required. On the basis of its review,

the staff finds that the chemistry control for primary systems program is acceptable for managing

this aging effect. *

3.3B.2.2.2 Hardening and Cracking or Loss of Strength Due to Elastomer Degradation or Loss

of Material Due to Wear

In LRA Section 3.3.2.2.2, the applicant addressed the potential for degradation of elastomers in

collars and seals in spent fuel cooling systems and ventilation systems.

SRP-LR Section 3.3.2.2.2 states that hardening and cracking due to elastomer degradation

could occur in elastomer linings of the filter, valve, and ion exchangers in spent fuel pool cooling

and cleanup systems. Hardening and loss of strength due to elastomer degradation could occur

in the collars and seals of the duct and in the elastomer seals of the filters in the control room

area, auxiliary and radwaste area, and primary containment heating ventilation systems and in

the collars and seals of the duct in the diesel generator building ventilation system. Loss of

material due to wear could occur in the collars and seals of the duct in the ventilation systems;

The GALL Report recommends further evaluation to ensure that these aging effects are

adequately managed.

The applicant stated in the LRA that the spent fuel pool cooling system does not contain carbon

steel components with elastomer linings. Therefore, this item is not applicable. The applicant has'

included the spent fuel pool cooling system in LRA Section 3.2, Engineered Safety Features :

Systems." The staff reviewed Table 3.2.2-5, AMR for spent fuel pool cooling system, and verified

that the system did not contain carbon steel components. with elastomer linings. On the basis of

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its review, the staff agrees that this line item is not applicable for components in the Unit 3 spent

fuel pool cooling system.

The applicant also stated in the LRA that elastomers are used in ventilation system components

and are evaluated for cracking and change of material properties due to thermal and radiation

exposure. The applicant credited MPS AMP B2.1.25, "Work Control Process," and MPS AMP

B2.1.13, "General Condition Monitoring Program," for managing age-related degradation of'

elastomers used in ventilation system components. Also, this program provides input to the

corrective action program if aging effects are identified. The staff accepted the work control

process program for managing the aging effects of cracking and change in material properties

and its evaluation of this program is documented in Section 3.0.3.3.4 of this SER. The staff also

accepted the general condition monitoring program for managing cracking and change of

material properties since visual inspections will be performed on external surfaces to detect any

sign of aging degradation. The staff's evaluation of the general condition monitoring program is

documented in Section 3.0.3.3.2 of this SER.-

In LRA Section 3.3.2.2.2, the applicant stated that loss of material due to wear is not an AERM

for the elastomers in the ventilation systems. During the audit and review, the staff requested

further clarification concerning the applicant's assertion. The rationale offered by the applicant

was that the elastomers in the ventilation systems are not subject to motions which could result

in wear. The staff finds that the applicant's justification is acceptable.

3.3B.2.2.3 Cumulative Fatigue Damage

As stated in the SRP-LR, fatigue is aTLAA, as defined in 10 CFR 54.3. Applicants must

evaluate TLAAs in accordance with 10 CFR 54.21(c)(1). Section 4.3 of this SER documents the -

staffs review of the applicant's evaluation of this TLAA. In performing this review, the staff

followed the guidance in Section 4.3 of the SRP-LR.

3.38.2.2.4 Crack Initiation and Growth Due to Cracking or Stress Corrosion Cracking

The staff reviewed LRA Section 3.3.2.2.4 against the criteria in SRP-LR Section 3.3.2.2.4. In

LRA Section 3.3.2.2.4, the applicant addressed the potential for cracking in the high-pressure

pumps of the chemical and volume control system.

SRP-LR Section 3.3.2.2.4 addresses crack initiation and growth due to cracking in the

high-pressure pump in the CVCS. The GALL Report recommends further evaluation to ensure

that these aging effects are adequately managed.

The applicant stated in the LRA that cracking is not identified as an AERM for the CVCS

high-pressure pump casing. The high-pressure pump casing is constructed of stainless steel

and operates at temperatures less than 140 OF: SCC is applicable to stainless steel components

in aqueous environments that experience operating temperatures greater than'

140 OF. . .,

The applicant stated that based on industry experience, a temperature criterion of greater than

140'F is used as the threshold for susceptibility of austenitic stainless steel to SCC. No

instances were identified that would bring this temperature threshold into question. On the basis

of its review, the staff finds the applicant's statement reasonable and acceptable because the

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applicant's bases for excluding the aging effects of cracking in the Unit 3 CVCS high-pressure

pump casing are consistent with industry and site operating experience.

3.3B.2.2.5 Loss of Material Due to General, Microbiologically Influenced, Pitting, and Crevice

Corrosion

In LRA Section 3.3.2.2.5, the applicant addressed the loss of material from corrosion that could

occur on internal and external surfaces of components exposed to air and the associated range

of atmospheric conditions.

SRP-LR Section 3.3.2.2.5 states that loss of material due to'general, pitting, and crevice

corrosion could occur in the piping and filter housing and supports in the control room area, the

auxiliary and radwaste area, the primary containment heating and ventilation systems, in the

piping of the diesel generator building ventilation system, in the above-ground piping and fittings,

valves, and pumps in the diesel fuel oil system and in the diesel engine starting air, combustion

air intake, and combustion air exhaust subsystems in the EDG system. Loss of material due to

general, pitting, crevice, and MIC could occur in the duct fittings, access doors, and closure

bolts, equipment frames and housing of the duct; loss of material due to pitting and crevice

corrosion could occur in the heating/cooling coils of the air handler heating/cooling; and loss of

material due to general corrosion could occur on the external surfaces of all carbon steel SCs,

including bolting exposed to operating temperatures less than 212OF in the ventilation systems.

The GALL Report recommends further evaluation to ensure that these aging effects are

adequately managed.

The applicant stated that MPS AMP B2.1.10, "Fire Protection Program;" MPS AMP B2.1.24,

"Tank Inspection Program;" and MPS AMP B2.1.25, 'Work Control Process," manage loss of

material due to general corrosion, MIC, pitting, and crevice corrosion for the internal surfaces of

ducts, piping, filter housings, compressed air systems components, and fuel oil systems

components. Loss of material for external surfaces of carbon steel components is managed by

MPS AMP B2.1.13, -General Condition Monitoring Program;" MPS AMP B2.1.10, "Fire

Protection Program;" MPS AMP B2.1.23, Structures Monitoring Program;" and MPS

AMP B2.1.24, "Tank Inspection Program." MPS AMP B2.1.15, "Infrequently Accessed Areas

Inspection Program," mnanages this aging effect for components in infrequently accessed areas.

The staff identified a discrepancy between LRA Table 3.3.2-36: Auxiliary Systems - Unit 2 Fire

Protection and LRA Table 3.3.2-37: Auxiliary Systems - Unit 3 Fire Protection. In LRA Table

3.3.2-36 (page 3-334), the applicant stated, for carbon steel pipe exposed to internally moist air,

that the fire protection program is used to manage the aging effects of loss of material. In LRA

Table 3.3.2-37 (page 3-346), the applicant credited the work control process program to manage

loss of material and references LRA Table 3.3.1, Item 3.3.1-05. During the audit and review, the

staff requested the applicant to clarify which is appropriate for managing the aging effect of loss

of material. In an LRA supplement dated July 7, 2004, the applicant stated that for LRA Table

3.3.2-37 (page 3-346), the "Work Control Process" AMP for the carbon steel "Pipe" group

exposed internally to an air environment should be the "Fire Protection Program" AMP. The

"NUREG-1 801" item should be "VII.H2.3-a' and the "Notes" should be "C, 2." The staff reviewed

the applicant's response and finds it to be acceptable.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

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personnel to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. The work control process program

provides input to the corrective action program if aging effects are identified. On the basis of its

review, the staff finds the work control process program to be acceptable for managing the aging

effects of loss of material due to general corrosion, MIC, pitting, and crevice corrosion for the

internal surfaces of ducts, piping, filter housings, compressed air systems components, and fuel

oil systems components.

The staff reviewed the fire protection program and its evaluation is documented in Section

3.0.3.2.7 of this SER. The fire protection program is consistent with GALL AMPs XI.M.26, 'Fire

Protection," and XI.M.27, "Fire Water System." On the basis of its review, the staff finds that the

fire protection program is acceptable for managing loss of material since visual inspections will

be performed on internal surfaces to detect any sign of aging degradation when the system is

opened for maintenance and/or repair.

The staff reviewed the tank inspection program and its evaluation is documented in Section

3.0.3.2.17 of this SER. The tank inspection program is consistent with GALL AMP XI.M.29,

uAboveground Carbon Steel Tanks." On the basis of its review, the staff finds that the tank

Inspection program is acceptable for managing loss of material due to general corrosion since

wall thickness measurements will be performed on the lower portion of the tank.

The staff reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.2 of this SER. The general condition monitoring program performs visual

inspections to detect evidence of degradation or adverse conditions in accessible plant areas.

System engineers perform comprehensive visual inspections during walkdowns of plant systems

and components during normal operation and during refueling outages; plant equipment

operators perform equipment and structures inspections twice a day to maintain awareness of

system and plant operation and material condition during normal operation and refueling

outages. On the basis of its review, the staff finds that the general condition monitoring program

is acceptable for managing loss of materials since visual inspections will be performed on

external surfaces to detect any sign of aging degradation.

The structures monitoring program manages the aging effects of cracking, loss of material, and

change of material properties by monitoring structures and structural support systems that are

within the scope of license renewal. The majority of these structures and structural support

systems are monitored under 10 CFR 50.65 pursuant to guidance contained in RG 1.160,

Revision 2, and NUMARC 93-01, Revision 2. These two documents provide guidance for

development of licensee-specific programs to monitor the condition of structures and structural

components within the scope of the Maintenance Rule, such that there is no loss of structure or

structural component intended function. The remaining structures within the scope of license

renewal (such as non-safety-related buildings and enclosures, duct banks, valve pits and

trenches, high-energy line break barriers, and flood gates) are also monitored to ensure there is

no loss of intended function. The staff reviewed the structures monitoring program and its

evaluation is documented in Section 3.0.3.2.16 of this SER. On the basis of its review, the staff

finds that the structures monitoring program is acceptable for managing loss of materials since

visual inspections will be performed on external surfaces to detect any sign of aging

degradation.

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The staff reviewed the infrequently accessed areas inspection program and its evaluation is

documented in Section 3.0.3.3.3 of this SER. The infrequently accessed areas inspection

program is a new, plant-specific program that manages the aging effects of loss of material

using visual inspections of the external surfaces of SCs. The program encompasses infrequently accessed areas of the plant which contain in-scope equipment. All areas not normally accessible

for inspection and evaluation, and that contain SCs subject to aging management, have been

identified for inclusion in the program. On the basis of its review, the staff finds that the

infrequently accessed areas inspection program is acceptable for managing loss of material due

to general corrosion on external surfaces of carbon steel components, since visual inspections will be performed on external surfaces to detect any sign of aging degradation in the service

water system.

During the audit and review, the staff questioned why various portions of the diesel generator system were not included within the scope of license renewal and subject to an AMR. In its

response dated July 7, 2004, the applicant added several components to the diesel generator system that are subject to an AMR. The addition of these components did not result in the

addition of material/environment combinations or AMPs for the diesel generator system AMR for

components addressed by LRA Section 3.3.2.2.5. The staff finds this

material/environment/aging effect/AMP combination to be acceptable. The staffs evaluation of

the scope of the diesel generator system is documented in Section 2.3A.3.34 of this SER.

3.3B.2.2.6 Loss of Material Due to General, Galvanic, Pitting, and Crevice Corrosion

In LRA Section 3.3.2.2.6, the applicant addressed further evaluation of programs to manage loss

of material in the reactor coolant pump (RCP) oil collection system to verify the effectiveness of

the fire protection program.

SRP-LR Section 3.3.2.2.6 states that loss of material due to general, galvanic, pitting, and

crevice corrosion could occur in tanks, piping, valve bodies, and tubing in the RCP oil collection

system in fire protection. The fire protection program relies on a combination of visual and

volumetric examinations in accordance with the guidelines of 10 CFR Part 50, Appendix R and

Branch Technical Position 9.5-1 to manage loss of material from corrosion. However, corrosion

may occur at locations where water from washdowns may accumulate. Therefore, verification of

the effectiveness of the program should be performed to ensure that corrosion is not occurring.

The GALL Report recommends further evaluation of programs to manage loss of material due to

general, galvanic, pitting, and crevice corrosion to verify the effectiveness of the program. A

one-time inspection of the bottom half of the interior surface of the tank of the RCP oil collection

system is an acceptable method to ensure that corrosion is not occurring and that the

component's intended function will be maintained during the period of extended operation. This

would be provided by a program consistent with GALL AMP XL.M32, "One-Time Inspection."

The applicant stated in the LRA that loss of material is managed for the components associated

with the RCP oil collection system by MPS AMP B2.1.24, "Tank Inspection Program," which

subjects the RCP oil collection tanks to periodic internal and external inspections. Additionally, during containment close-out activities, the RCP oil collection tanks are visually inspected and

verified to be empty.

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The staff reviewed the tank inspection program, which is consistent with GALL AMP XI.29,

"Aboveground Carbon Steel Tanks," and its evaluation is documented in Section 3.0.3.2.17 of

this SER. Since the tank inspection program includes volumetric examination for wall thickness

measurement of the RCP oil collection tank, the staff finds the program acceptable for managing

loss of material due to general, galvanic, pitting, and crevice corrosion.

The applicant referenced LRA Table 3.3.1, Item 3.3.1:06 (page 3-205), for components exposed

internally to lube oil (Note 14) and loss of material aging effect combination in LRA Table

3.3.2-36, and credits the work control process program. In the discussion of Item 3.3.1-06, the

applicant stated that the loss of material is managed by the tank inspection program. The staff

noted that there is no mention of the work control process program in the discussion. In an LRA

supplement dated July 7, 2004, the applicant stated that LRA Table 3.3.1, Item 3.3.1-06, should

include the following words between the second and third sentences:

For the non-tank components, loss of material is managed by the work control

process.

Additionally, LRA Section 3.3.2.2.6 (page 3-198) should include the following words at the end of

the first sentence:

For the non-tank components, loss of material is managed by the work control

process.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The staff finds that the work control process program provides the

opportunity for personnel to visually inspect the internal surfaces of components during

preventive and corrective maintenance activities on an ongoing basis. It also provides input to

the corrective action program if aging effects are identified. On the basis of its review, the staff

finds that the work control process program is acceptable for managing the aging effect of loss

of material. -

3.3B.2.2.7 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced

Corrosion and ~iofouling

In LRA Section 3.3.2.2.7, the applicant addressed further evaluation of programs to manage loss

of material in the diesel fuel oil system to verify the effectiveness of the diesel fuel monitoring

program.

SRP-LR Section 3.3.2.2.7 states that loss of material due to general, pitting, and crevice

corrosion, MIC, and biofouling could occur in the internal surface of tanks in the diesel fuel oil

system and that loss of material due to general, pitting, and crevice corrosion and MIC could

occur in the tanks of the diesel fuel oil system in the EDG system. The existing AMP relies on

the fuel oil chemistry program formonitoring and control of fuel oil contamination in accordance

with the guidelines of ASTM Standards D4057, D1796, D2709, and D2276 to manage loss of

material due to corrosion or biofouling. Corrosion or biofouling may occur at locations where

contaminants accumulate. Verification of the effectiveness of the chemistry control program

should be performed to ensure that corrosion is not occurring. The GALL Report recommends

further evaluation of programs to manage corrosionlbiofouling to verify the effectiveness of the

program. A one-time inspection of selected components at susceptible locations is an

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acceptable method to ensure that corrosion is not occurring and that the component's intended

function will be maintained during the period of extended operation.

The GALL Report recommends programs consistent with uFuel Oil Chemistry' (Xl.M30) and

"One Time Inspection" (XI.M32) for management of this aging effect.

The applicant stated in the LRA that MPS AMP B2.1.12, "Fuel Oil Chemistry," manages loss of

material for diesel fuel oil tanks and other components in the diesel generator fuel oil system, the

security system, and the SBO diesel generator system. In lieu of a one-time inspection as

described in SRP-LR Section 3.3.2.2.7, the applicant stated in LRA Section 3.3.2.2.7 that MPS

AMP B2.1.25, "Work Control Process," will be used to provide confirmation of the effectiveness

of the fuel oil chemistry program, and that tank inspections performed under the applicant's MPS

AMP B2.1.24, uTank Inspection Program,' provide additional confirmation that the fuel oil

chemistry program is effective for managing aging effects for applicable tanks.

The staff reviewed the fuel oil chemistry program and its evaluation is documented in Section

3.0.3.2.9 of this SER. The fuel oil chemistry program (1) monitors and controls fuel oil quality to

ensure that it is compatible with the materials of construction, and to manage the conditions thatl

cause general corrosion, pitting, and MIC of fuel tank internal surfaces; (2) establishes fuel oil

quality limits; and (3) samples and tests fuel oil used for equipment within the scope of license

renewal. On the basis of its review, the staff finds the fuel oil chemistry program to be

acceptable.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. The work control process program

provides input to the corrective action program if aging effects are identified. On the basis of its

review, the staff finds that the work control process program is acceptable for use to provide

confirmation of the effectiveness of the fuel oil chemistry program.

The staff reviewed the tank inspection program and its evaluation is documented in Section

3.0.3.2.17 of this SER. The tank inspection program is consistent with GALL AMP XL.M29,

"Aboveground Carbon Steel Tanks." On the basis of its review, the staff finds that the tank

inspection program is acceptable for providing additional confirmation that the fuel oil chemistry

program is effective for managing aging effects for applicable tanks.

3.3B.2.2.8 Quality Assurance for Aging Management of Non-safety-related Components

Section 3.0.4 of this SER provides a separate evaluation of the applicant's quality assurance

program.

3.3B.2.2.9 Crack Initiation and Growth Due to Stress Corrosion Cracking and Cyclic Loading

In LRA Section 3.3.2.2.9, the applicant addressed further evaluation of programs to manage

cracking in the chemical and volume control system to verify the effectiveness of the water

chemistry control program.

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SRP-LR Section 3.3.2.2.9 states that crack initiation and growth due to SCC and cyclic loading

could occur in the channel head and access cover, tubesheet, tubes, shell and access cover,

and closure bolting of the regenerative heat exchanger and in the channel head and access

cover, tubesheet, and tubes of the letdown heat exchanger in the chemical and volume control

system. The water chemistry program relies on monitoring and control of water chemistry based

on the guidelines of EPRI TR-1 05714, "PWR Primary Water Chemistry Guidelines: Revision 4,"

to manage the effects of crack initiation and growth due to SCC and cyclic loading. Verification

of the effectiveness of the chemistry control program should be performed to ensure that crack

initiation and growth are not occurring. The GALL Report recommends further evaluation to

manage crack initiation and growth from SCC and cyclic loading for these systems to verify the

effectiveness of the water chemistry program. A one-time inspection of selected components

and susceptible locations is an acceptable method to ensure that crack initiation and growth are

not occurring and that the component's intended function will be maintained during the period of.

extended operation. -

The AMPs recommended by the GALL Report are TM

Water Chemistry" (Xl .M2) and a

plant-specific verification program for management of this aging effect.

The GALL Report recommends that the water chemistry program be augmented by verifying the

absence of cracking due to SCC and cyclic loading, or loss of material due to pitting and crevice

corrosion. The GALL Report states that an acceptable verification program is to include

temperature and radioactivity monitoring of the shell side water, and eddy current testing of

tubes.

The applicant stated in the LRA that cracking due to SCC for the regenerative and letdown heat

exchangers is managed by MPS AMP B2.1.5, "Chemistry Control for Primary Systems

Program." Verification of the effectiveness of the chemistry control program is provided by MPS

AMP B2.1.25, "Work Control Process." The work control process program provides the

opportunity for personnel to visually inspect the internal surfaces of components during

preventive and corrective maintenance activities on an ongoing basis. The work control process

program provides input to the corrective action program if aging effects are identified. The'

corrective action program would evaluate the cause and extent of condition and, if required,

recommend enhancements to ensure continued effectiveness of the chemistry control for

primary systems program.

The staff reviewed the chemistry control for the primary systems program and its evaluation is

documented in Section 3.0.3.2.2 of this SER. The chemistry control for primary systems

program is consistent with the GALL Report, with an acceptable exception. The exception

relates to use of a later, non-NRC-approved revision of the EPRI guidelines. On the basis of its

review, the staff finds the chemistry control for primary systems program to be acceptable for

managing this aging effect.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The staff notes that visual inspections of the internal surfaces of

plant components and plant commodities-are performed during the performance of

maintenance, in accordance with the work control process program, to determine the presence

of crack initiation and growth. On the basis of it review, the staff finds that the work control

process program is acceptable for managing crack initiation and growth since visual inspections

will be performed on internal surfaces of components to detect any sign of aging degradation.

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3.3B.2.2.10 Reduction of Neutron-Absorbing Capacity and Loss of Material Due to General

Corrosion

In LRA Section 3.3.2.2.10, the applicant addressed reduction of neutron-absorbing capacity and

loss of material due to general corrosion, which could occur in the neutron absorbing sheets of

the spent fuel storage rack in the spent fuel storage system.

SRP-LR Section 3.3.2.2.10 states that reduction of neutron-absorbing capacity and loss of

material due to general corrosion could occur in the neutron-absorbing sheets of the spent fuel

storage rack in the spent fuel storage. The GALL Report recommends further evaluation to

ensure that these aging effects are adequately managed.

The applicant stated in the LRA that the neutron absorber elements credited in the criticality

analysis for the spent fuel pool are constructed of Boral. Boral is a thermal neutron poison

composed of boron carbide and 1100 alloy aluminum. Boron carbide is a compound having a

high boron content in a-physically stable and chemically inert form. The neutron-absorbing

central layer of Boral is clad with aluminum. The boron carbide and aluminum materials in Boral

are unaffected by long-term exposure to radiation.

The applicant stated in the LRA that the Boral has shown no signs of degradation in

neutron-absorbing capability. The applicant concluded, based on the design of the neutron

absorber elements and the results of surveillance testing, that reduction of neutron-absorbing

capacity is not an aging effect that requires management for Boral in the spent fuel pool. On the

basis of its review, the staff concurs with the applicant's conclusion that there are no applicable

aging effects requiring management for the Boral in the spent fuel pool.

In the LRA, the applicant stated that the aluminum cladding of the neutron absorber elements is

not subject to general corrosion in the spent fuel pool environment. However, the applicant

stated that pitting corrosion could occur if spent fuel pool water chemistry exceeded specific

contaminant levels. The applicant stated, for the neutron absorber elements, loss of material is

managed by maintaining the quality of the spent fuel pool water chemistry. The applicant

credited MPS AMP B2.1.5, "Chemistry Control for Primary Systems Program," for this purpose.

The staff reviewed the chemistry control for primary systems program, with exception, and its

evaluation is documented in Section 3.0.3.2.2 of this SER. The exception relates to use of a

later, non-NRC-approved revision of the EPRI guidelines. On the basis of its review, the staff

finds that the chemistry control for primary systems program is acceptable for managing this

aging effect

3.3B.2.2.11 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced

Corrosion

In LRA Section 3.3.2.2.11, the applicant addressed the potential for loss of material in buried

piping of the SW and diesel fuel oil systems.

SRP-LR Section 3.3.2.2.11 states that loss of material due to general, pitting, and crevice

corrosion and MIC could occur in the underground piping and fittings in the open-cycle cooling

water system (SW system) and in the diesel fuel oil system. The buried piping and tanks

inspection program relies on industry practice, frequency of pipe excavation; and operating

experience to manage the effects of loss of material from general, pitting, and crevice corrosion

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and MIC. The effectiveness of the buried piping and tanks inspection program should be verified

to evaluate an applicant's inspection frequency and operating experience with buried

components, ensuring that loss of material is not occurring.

The AMP recommended by the GALL Report is the GALL AMP XL.M34, "Buried Piping and

Tanks Inspection," for management of this aging effect.

The applicant stated in the LRA that loss of material for buried piping and valves in the service

water system, and in the Unit 2 fire protection system, Unit 3 fire protection system, and

enclosure building filtration system, is managed by MPS AMP B2.1.4, "Buried Pipe Inspection

Program.".

In the LRA, the applicant stated that as part of the buried pipe inspection program a baseline

inspection of representative in-scope buried piping is performed, which provides an effective

method for detection of aging effects. In addition, inspections are performed when the buried

components are excavated for maintenance or any other reason, which provides an effective

method to evaluate the condition of the buried piping and protective coatings. Operating

experience with age-related degradation of buried piping is limited, and no failures of in-scope

buried piping have been identified. The applicant stated that there is no buried piping in the

diesel fuel oil systems.

The staff reviewed the buried pipe inspection program and its evaluation is documented in

Section 3.0.3.2.1 of this SER. The staff finds that the buried pipe inspection program, which is

consistent with GALL AMP XI.M28, "Buried Piping and Tanks Surveillance," and GALL AMP

XL.M34, "Buried Piping and Tanks Inspection," with exceptions and enhancements, to be

acceptable. The staff also finds the exceptions and enhancements to be acceptable. The staff

reviewed the plant operating experience and found that the program is effective in identifying

age-related degradation, implementing repairs, and maintaining the integrity of buried pipe. On

the basis of its review, the staff finds that the buried pipe inspection program is acceptable for

managing the aging effect of loss of material in buried piping and fittings.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determines that (1) those attributes or features

for which the applicant claimed consistency with the GALL Report were indeed consistent and

(2) the applicant adequately addressed the issues that were further evaluated. The staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

3.3B.2.3 AMR Results That Are Not Consistent With or Not Addressed in the GALL

Report

Summary of Technical Information in the Application. In LRA Tables 3.3.2-1 through 3.3.2-50,

the staff reviewed additional details of the results of the AMRs for material, environment, AERM,

and AMP combinations that are not consistent with the GALL Report or are not addressed in the

GALL Report. The staff also reviewed additional systems and components, provided in the

applicant's letter, dated January 11, 2005.

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In LRA Tables 3.3.2-1 through 3.3.2-50, the applicant indicated, via Note F through J, that

neither the identified component nor the material and environment combination is evaluated in

the GALL Report and provided information concerning how the aging effect require management

will be managed.

Staff Evaluation. For component type materiaVenvironment combinations not evaluated in the

GALL Report, the staff reviewed the applicant's evaluation to determine whether the applicant

had demonstrated that the effects of aging will be adequately managed so that the intended

function will be maintained consistent with the CLB during the period of extended operation.

The staff requested the applicant to provide additional information on the issues described in the

following general RAI.

Selective Leaching in Copper Alloys (RAI 3.3-B-2)

LRA Tables 3.3.2-2, 3.3.2-12, 3.3.2-15 and 3.3.2-41 for the service water, instrument air, CVCS

and SBO diesel generator systems respectively identify loss of material as an aging effect

applicable to nickel-based and copper alloys exposed to an atmosphere/weather and treated

water environments. The LRA did not identify the'alloy zinc content for these materials. The LRA

credits the general condition monitoring program for managing loss of material on the exterior of

various nickel-based or copper alloy materials and the work control process for managing loss of

material in the interior of copper alloy tubes and tubesheets.-These AMPs primarily rely on visual

inspections. Industry documents, such as EPRI report 1003056, "Non-Class-I Mechanical

Implementation Guideline and Mechanical Tools," Rev. 3, identify various corrosion

mechanisms, including selective leaching, causing loss of material in copper alloys with greater

than 15 percent zinc content in a treated water environment or an air environment subject to

moisture. Loss of material from selective leaching is specifically addressed in GALL AMP

XI.M33, but page B-7 of the LRA states that the aging management reviews did not identify the

need for this aging management program. The applicant was requested to identify the alloy zinc

content for these materials and clarify if selective leaching is an applicable aging mechanism.

If selective leaching is an applicable aging mechanism, the applicant was requested to clarify if

hardness measurement and one-time inspection required by GALL AMP XL.M33 will be used to

manage the aging effect.

By letter dated November 9, 2004, the applicant responded as follows:

Dominion conservatively assumed that all copper alloys were of a material composition

that could be susceptible to selective leaching. Accordingly, the zinc content for copper

alloys was not identified in the LRA since it was not used as an input to the evaluation' of

aging mechanisms. Selective leaching was not considered to be an applicable aging

mechanism for nickel-based alloys.

Selective leaching of copper alloy components in the instrument air and station blackout

diesel generator systems was not considered to be significant in an atmosphere/weather

environment since this environment only involves periodic wetting of surfaces due to

precipitation. Generally, surfaces would dry'out and remain dry the majority of the time. If

water collection or pooling from precipitation was present for a component, the

component material was evaluated with a raw water environment as defined in LRA

Table 3.0-1. However, loss of material due to general corrosion was conservatively

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identified as an aging effect for these components and the General Condition Monitoring

AMP provides overall management of this aging effect.

Selective leaching of copper alloy components in the instrument air, station blackout and,

CVCS syitems that are subjected to a treated water environment has been re-evaluatedand considered to be an applicable aging mechanism. Although the treated water is

adjusted'to'specifically control corrosion by the reduction of oxygen and/or the addition of

corrosion inhibitor compounds, there us potential for selective leaching of susceptible

materials in this environment. Management of loss of material due to selective leaching

of copper alloy components in a treated water, environment is performed by the Work

Control Process AMP. Specific inspections for selective leaching by the Work Control

Process are addressed in Audit Item #85 in the Dominion letter to the NRC staff dated

July 7,'2004, (Serial No. 04-320).

No copper alloy components in the service water system are associated with a treated

water or atmrosphere/weather environment.

The staff reviewed the applicant's response and determined that the response was reasonable

and acceptable because the applicant provided sufficient information to evaluate selective,

leaching in copper alloy components in auxiliary system components. The applicant re-evaluated

selective leaching of copper alloys in a treated water environment and concluded that this is an

aging mechanism. The applicant has agreed in its letter dated July 7, 2004, to include

appropriate inspection criteria for selective leaching to its work control process AMP. The

applicant also provided a reasonable'basis to conclude that selective leaching is not a significant.

aging mechanism causing loss of material in'copper alloy materials in auxiliary systems exposed

to periodic moisture. This conclusion is in part based on the applicant's clarified environmental

conditions that copper alloy components in systems exposed to atmosphere/weather conditions

are not exposed to wetted conditions for a significant period of time. The staff agrees that, -

selective leaching of nickel alloys is not 'considered to be a concern in this environment.- On the

basis of the applicant's response, all issues related to RAI 3.3-B-2 are resolved.

The system-specific staff evaluation is discussed below.

3.3B.2.3.1 Circulating Water - Aging Management Evaluation - Table 3.3.2-1

The staff reviewed LRA Table 3.3.2-1, which summarized the results of AMR evaluations for the

circulating water system component groups.

In the LRA, the applicant identified no aging effects for fiberglass pipe component types exposed

to air. The applicant stated, in its technical report for open water, that reduced strength due to

ozone exposure of non-metallic is possible in an air environment. The applicant explained that

the fiberglass components exposed to air in this system are not located near high-voltage

electrical equipment. Therefore, ozone exposure is not a potential aging mechanism. In addition,

a review of operating experience has identified no concerns related to the occurrence of ozone

exposure in the open'water systems. The staff reviewed the technical report, current industry

research and operating experience. On the basis of its review, the staff. concludes that reduced

strength 'due to ozone for fiberglass components in' air environment is not an aging effect that

requires aging management.

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In the LRA, the applicant identified no aging effects for fiberglass' pipe component types exposed

to seawater. The applicant stated, its technical report for open water, that exposure to ultraviolet

radiation and ozone can cause damage to the chemical structure of the epoxy matrix of

fiberglass. The earliest signs'of this effect can be changes in color and surface cracking or

crazing. Fiberglass exposed to direct sun or high levels of ozone that might be found in

conjunction with high-voltage electrical equipment would be most prone to this effect. The staff

reviewed the technical report, current industry-research and operating experience and finds that

fiberglass components in seawater environment are not exposed to high level of ultraviolet

radiation or ozone. On the basis'of its review,' the staff concludes that cracking in fiberglass

components in sea water is not an aging effect that requires aging management.

In the LRA, the applicant identified no aging effects for rubber expansion joints exposed to air.

The applicant explained, in its technical report for open water, that change of material properties

due to thermal exposure and irradiation and cracking due to irradiation of rubber components in

air are aging effects that do not require aging management for the components in this system.

The staff reviewed the technical report, current industry research and operating experience and

finds that these components are not exposed to high levels of ultraviolet radiation, ozone, or

temperatures greater than 95 "F. On the basis'of its review, the staff concludes that it did not

identify any concerns with the applicant's conclusions that there' are no applicable aging effects

requiring management for rubber expansion joints exposed to air.

In the LRA, the applicant has identified no aging effects for rubber expansion joints exposed to

sea water. The applicant explained, in its technical report for open water, that change of material

properties and cracking due'to thermal of rubber components exposed to sea water are aging

effects that do not require aging nmanagement for the components in this system. The staff

reviewed the technical report, current industry research and operating experience and finds that

the threshold temperature for applying the aging effects of 'cracking and change' of material

properties to elastomers' is 95 OF. In addition, the surface temperature of the rubber expansion

joints in the open water systems will likely never exceed 95 OF, since the internal water (raw

water from the Long Island Sound) is significantly less than 95 0F. On the basis of its review, the

staff concludes that it did not identify any concerns with the applicant's conclusions that there

are no applicable aging effects for rubber expansion joints exposed to sea water since these

components are not exposed to temperatures greater than 95 F.

3.3B.2.3.2 Service Water - Aging Management Evaluation - Table 3.3.2-2

The staff reviewed LRA Table 3.3.2-2, which summarized the results of AMR evaluations for the

service water system component groups.

In LRA Table 3.3.2-2, the applicant proposed to manage build up of deposit of carbon steel pipe

component type exposed to sea Water using MPS AMP B2.1.21, "S'ervice Water System," which

is consistent with GALL AMP XI.M20, "Open-Cycle Cooling Water System." However, buildup of

deposits due to biofouling is not identified in the GALL Report as an aging effect for the pipes'

and strainers component types. The applicant,' in its technical report for open water, stated that'

the carbon steel and cast iron material lined piping interfaces with sea water and is subject to

macro-fouling, silting, and sedimentation. Therefore, buildup of deposits is a potential aging

effect for these components that requires aging management.

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The applicant, in LRA Appendix C (page C-24), described that buildup of deposits due to

biofouling is an aging effect requiring aging management for heat exchanger tubes, tube sheets,

and lined components. The applicant stated that lined piping was included because piping can

contribute to heat exchanger fouling since small segments of the coating can become detached

and foul associated heat exchangers. Buildup' of deposits does not directly effect the pressure

boundary of the lined piping. However, prolonged operation with deteriorated coatings would

lead to loss of material. For this reason, both buildup'of deposits and loss of material are

managed by the service water system (open-cycle cooling) aging management activity.

Specifically, internal visual inspections of the service water piping are periodically performed.

The staff reviewed the service water system program and its evaluation is documented in

Section 3.0.3.2.15 of this SER. On the basis of its review of the applicant program and technical

report, together with current industry research and operating experience, the staff finds that the

service water program is acceptable for managing buildup of deposits for the lined components,

since internal visual inspections of the service water components will be periodically performed

to detect any sign of deposit build up.

In the LRA, the applicant proposed to manage loss of material of stainless steel and copper alloy

pipe control building HVAC booster pump, MCC and rod control HVAC booster pump, valves, -

and tubing types exposed to a moisture-laden air and/or intermittently wetted environments

using MPS AMP B2.1.13, 'General Condition Monitoring," which is a plant-specific program. Thestaff reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.2 of this SER. On the basis of its review, the staff finds that the general condition

monitoring program is acceptable for managing loss of material due to pitting and crevice

corrosion since visual inspections will be performed on external surfaces to detect any sign of

aging degradation.

The applicant, in the LRA, proposed to manage loss of material of copper alloy pipe and valve

external surfaces caused by borated water leakage using MPS AMP B2.1.13, "General

Condition Monitoring," which is a plant-specific program. The staff reviewed the general

condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER.

The staff finds that visual inspections will be performed on external surfaces to detect any sign

of aging degradation. On the basis of its review, the staff concludes that the use of the general

condition monitoring program in lieu of the boric acid corrosion program is acceptable for'

managing loss of material due to borated acid leakage on external surfaces of copper alloy

components in this system.

In LRA Table 3.3.2-2, the applicant proposed to manage loss of material for nickel-based alloys

expansion joints, flow elements, pipe and restricting orifices exposed to sea water using MPS

AMP B2.1.21, -Service Water System (Open-Cycle Cooling)," which is consistent with the GALL

XI.M20 program. However, loss of material for nickel-based components types in treated water

as a component, material, environment, and aging effect combination is not identified in the

GALL Report.-The applicant, in its technical report for open water,-stated that the nickel-based

alloys in sea water are exposed to low flow conditions with an aggressive environment.'

Therefore, pitting corrosion is a potential aging mechanism. The staff reviewed the service water

system program and its evaluation is documented in Section 3.0.3.2.15 of this SER. The staff

finds that this program implements the intent of GL 89-13. On the basis of its review of the

applicant's program and technical report, together with current industry research and operating

experience, the staff finds that the service water program is acceptable for managing loss of

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material of nickel-based alloys (due to pitting corrosion) components in a sea water environment for this system.

In LRA Table 3.3.2-2, the applicant proposed to manage loss of material for titanium valves exposed to sea water using MPS AMP B2.1.21, "Service Water System (Open-Cycle Cooling)," which is consistent with the GALL XI.M20 program. However, loss of material for titanium

component types in treated water is not identified in the GALL Report. The applicant, in its technical report for open water, stated that loss of material due to erosion of titanium component is possible in a sea water environment The titanium components in this application have flow

rates greater than 50 feet per second (fps) or contain fluids with high particulates. Therefore, erosion is a potential aging mechanism. The staff reviewed the service water system program and its evaluation is documented in Section 3.0.3.2.15 of this SER. The staff finds that this

program implements the intent of the NRC Guidelines set forth in GL 89-13. On the basis of its review of the applicant's program and technical report, together with current industry research and operating experience, the staff finds that the service water program is acceptable for managing loss of material due to erosion/corrosion for titanium valves in a sea water environment.

In the LRA, the applicant identified no aging effects for rubber expansion joints exposed to air. The applicant explained, in its technical report for open water, that change of material properties due to thermal exposure and irradiation and cracking due to irradiation of rubber components in air are aging effects that do not require aging management for the components in this system.

In the LRA, the applicant identified no aging effects for rubber expansion joints exposed to air. The applicant explained, in its technical report for open water, that change of material properties due to thermal exposure and irradiation and cracking due to irradiation of rubber components in air are aging effects that do not require aging management for the components in this system. The staff reviewed the technical report, current industry research and operating experience and finds that these components are not exposed to high levels of ultraviolet radiation, ozone, or

temperatures greater than 95 OF. On the basis of its review, the staff concludes that it did not identify any concerns with the applicant's conclusions that there are no applicable aging effects requiring management for rubber expansion joints exposed to air.

In the LRA, the applicant identified no aging effects for rubber expansion joints exposed to sea water. The applicant stated in its technical report for open water, stated that change of material properties and cracking due to thermal of rubber components in sea water are aging effects that do not require aging management for the components in this system.

The staff reviewed technical report, current industry research and operating experience and finds that the threshold temperature for applying the aging effects of cracking and change of material properties to elastomers is 950 F.; In addition, the surface temperature of the rubber expansion joints in the open water systems will never exceed 95OF, since the internal water (raw water from the Long Island Sound) is significantly less than 95 OF. On the basis of its review, the staff concludes that it did not identify any concerns with the applicant's conclusions that there

are no applicable aging effects for rubber expansion joints exposed to sea water since these

components are not exposed to temperatures greater than 95"F.

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In the LRA, the applicant has identified no aging effects for stainless steel spool piece and

titanium valves exposed internally/externally to air. Air is not identified in the GALL Report as an

environment for this combination of component and material.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Wrought austenitic stainless steel

and titanium are not susceptible to significant general corrosion that would affect the intended

function of components. Therefore, the staff concludes that there are no aging effects requiring

management for metal in an air environment. - -

3.31B.2.3.3 Sodium Hypochlorite - Aging Management Evaluation - Table 3.3.2-3

The staff reviewed LRA Table 3.3.2-3, which summarized the results of AMR evaluations for the

sodium hypochlorite system component groups.

The applicant, in the LRA, proposed to manage loss of material of copper alloy pipes exposed to

a moisture-laden air and/or intermittently wetted environments using MPS AMP B.2.1.13,

"General Condition Monitoring," which is a plant-specific program. The staff reviewed the general

condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER.

The staff finds that visual inspections will be performed on external surfaces to detect any sign

of aging degradation. On the basis of its review, the staff concludes that the general condition

monitoring program is acceptable for managing loss of material due to pitting and crevice

corrosion.

In the LRA, the applicant identified no aging effects for fiberglass piping component types

exposed to air. The applicant, in its technical report for. open water, stated that reduced strength

due to ozone exposure of non-metallic is possible in an air environment. The applicant explained

that the fiberglass components exposed to air in this system are not located near high-voltage

electrical equipment. Therefore, ozone exposure is not a potential aging mechanism. In addition,

a review of operating experience has identified no concerns related to the occurrence of ozone

exposure in the open water systems. The staff reviewed the technical report, current industry

research and operating experience. On the basis of its review, the staff concludes that reduced

strength due to ozone for fiberglass components in air environment is not an aging effect that

requires aging management.

Based on the review of the applicant's open water technical report and on the basis of current

industry research and operating experience, the staff finds that reduced strength due to ozone

for fiberglass components in air environment is not an aging effect that requires aging

management.

The applicant identified no aging effects for fiberglass piping component types exposed to sea

water. The applicant stated, in its open water system AMR technical report, that exposure to

ultraviolet radiation and ozone can cause damage to the chemical structure of the epoxy matrix

of fiberglass. The earliest signs of this effect can be changes in color and surface cracking or

crazing. Fiberglass exposed to direct sun or high levels of ozone that might be found in

conjunction with high-voltage electrical equipment would be most prone to this effect.

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On the basis of the open water technical report, current industry research, and operating

experience, the fiberglass components in sea water environment are not exposed to high levels

of ultraviolet radiation or ozone. Therefore, the staff finds that cracking in fiberglass components

in sea water is not an aging effect that requires aging management.

The applicant identified no aging effects for PVC pipe and valve component types exposed to air

and sea water. Current industry research and operating experience reviews have identified -

instances of PVC degradation resulting from exposure to direct sunlight and exposure to ozone

from high voltage. The MPS MAER technical report identifies the aging effect of reduced

strength due to ozone exposure for PVC components exposed to sea water, and reduced

strength due to ozone exposure or ultraviolet exposure for PVC components exposed to air. The

AMR evaluated PVC components for the above aging effects and concluded that no aging

management was required. This conclusion was based on the fact that the PVC components are

not exposed to direct sunlight and are not exposed to high levels of ozone, since they are not in

close proximity to high voltage electrical equipment.

On the basis of the open water technical report, current industry research, and operating

experience, the staff finds that reduced strength PVC components in air or seawater

environment is not an aging effect that requires aging management.

3.3B.2.3.4 Reactor Plant Component Cooling - Aging Management Evaluation - Table 3.3.2-4

and Table 3.3.2-4a

The staff reviewed LRA Table 3.3.2-4 and the applicant's letter, dated January 11, 2005, which

summarize the results of AMR evaluations for the reactor plant component cooling (RPCC)

system component groups.

In the LRA, the applicant proposed to manage loss of RPCC heat exchanger copper alloy tubes

in treated water using MPS AMP B2.1.25, "Work Control Process," which is a plant-specific

program. The staff reviewed the work control process and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The staff finds that visual inspections of the internal surfaces of

plant components and plant commodities are performed during the performance of

maintenance, in accordance with the work control process program, to determine the loss of

material. On the basis of its review, the staff concludes that the work control process program is

acceptable for managing loss of material due to general corrosion since visual inspections will

be performed external surfaces of heat exchanger tubes to detect any sign of aging degradation.

In the LRA, the applicant proposed to manage loss of material of external surfaces of the copper

alloy RPCC heat exchanger channel and valves exposed to borated water leakage using the

MPS AMP B2.1.13, -General Condition Monitoring," which is a plant-specific program. The staff

reviewed the general condition monitoring program and its evaluation is documented in Section

3.0.3.3.2 of this SER. The staff finds that visual inspections will be performed on external

surfaces to detect any sign of aging degradation. On the basis of its review, the staff concludes

that the use of the general condition monitoring program in lieu of boric acid corrosion is

acceptable for managing loss of material due to borated acid leakage on external surfaces of

copper alloy components in this system.

In the LRA and supplement dated January 11, 2005, the applicant proposed to manage loss of

material of stainless steel and copper alloy RPCC heat exchanger channel, valves, flow

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elements, hoses, tubing, and radiation detectors component types exposed to a moisture-laden

air and/or intermittently wetted environments using MPS AMP B2.1.13, "General Condition

Monitoring," which is a plant-specific program.:The staff reviewed the general condition

monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER. On the

basis of its review, the staff finds that the general condition monitoring program is acceptable for

managing loss of material due to pitting and crevice corrosion since visual inspections will be

performed on external surfaces to detect any sign of aging degradation.

3.31B.2.3.5 Turbine Plant Component Cooling Water - Aging Management Evaluation -

Table 3.3.2-5

The staff reviewed LRA Table 3.3.2-5, which summarized the results of AMR evaluations for the

turbine plant component cooling water system component groups.

In the Unit 2 LRA, the applicant proposed to manage loss of material of stainless steel pipe and

valve component types exposed to a moisture-laden air and/or intermittently wetted

environments using MPS AMP B2.1.13, "General Condition Monitoring," which is a plant-specific

program; The staff reviewed the general condition monitoring program an its evaluation is

documented in Section 3.0.3.3.2 of this SER. On the basis of its review; the staff finds that the

general condition monitoring program is acceptable for managing loss of material due to pitting

and crevice corrosion since visual inspections will be performed on external surfaces to detect

any sign of aging degradation.

3.31B.2.3.6 Chilled Water - Aging Management Evaluation - Table 3.3.2-6

The staff reviewed LRA Table 3.3.2-6, which summarized the results of AMR evaluations for the

chilled water system component groups.

In the LRA, the applicant proposed to manage loss of material of external surfaces of the copper

alloy tubing and valves exposed to borated water-leakage using the MPS AMP B2.1.13, '-

"General Condition Monitoring," which is a plant-specific program. The staff reviewed the general

condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER.

The staff finds that visual inspections will be performed on external surfaces to detect any sign

of aging degradation. On the basis of its review, the staff concludes that the use of the general

condition monitoring program in lieu of the boric acid corrosion program is acceptable for -

managing loss of material due to borated acid leakage on external surfaces of copper alloy

components in this system.

In the LRA, the applicant also proposed to manage loss of material of stainless steel and copper

alloy tubing; valves, flow elements, and hoses component types exposed to a moisture-laden air

and/or intermittently wetted environments using MPS AMP B2.1.13, 'General Condition

Monitoring," which is a plant-specific program. The staff reviewed the general condition

monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER. The staff

finds that visual inspections will be performed on external surfaces to detect any sign of aging

degradation. On the basis of its review, the staff concludes that the general condition monitoring

program is acceptable for managing loss of material due to pitting and crevice corrosion.

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3.31B.2.3.7 Charging Pumps Cooling - Aging Management Evaluation - Table 3.3.2-7

The staff reviewed LRA Table 3.3.2-7, which summarized the results of AMR evaluations for the

charging pumps cooling system component groups.

In the LRA, the applicant proposed to manage loss of material of external surfaces of the copper

alloy valves exposed to borated water leakage using MPS AMP B2.1.13, "General Condition

Monitoring," which is a plant-specific program. The staff reviewed the general condition

monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER. The staff

finds that visual inspections will be performed on external surfaces to detect any sign of aging

degradation. On the basis of its review, the staff concludes that the general condition monitoring

program in lieu of boric acid corrosion is acceptable for managing loss of material due to borated

acid leakage on external surfaces of copper alloy components in this system.

In the LRA, the applicant proposed to manage loss of material of stainless steel and copper alloy

charging pump coolers channel and shell, valves, flow elements, pumps, and tubing component

types exposed to a moisture-laden air and/or intermittently wetted environments using MPS AMP

B2.1.13, 'General Condition Monitoring," which is a plant-specific program. The staff reviewed

the general condition monitoring program and its evaluation is documented in Section 3.0.3.3.2

of this SER. The staff finds that visual inspections will be performed on external surfaces to

detect any sign of aging degradation. On the basis of its review, the staff concludes that the

general condition monitoring program is acceptable for managing loss of material due to pitting

and crevice corrosion.

3.31B.2.3.8 Safety Injection Pumps Cooling - Aging Management Evaluation - Table 3.3.2-8

The staff reviewed LRA Table 3.3.2-8, which summarized the results of AMR evaluations for the

safety injection pumps cooling system component groups.

In the LRA, the applicant proposed to manage loss of material of external surfaces of the copper

alloy safety injection pump coolers shell and channel and valves exposed to borated water

leakage using MPS AMP B2.1.13, 'General Condition Monitoring," which is a plant-specific

program. The staff reviewed the general condition monitoring program and its evaluation is

documented in Section 3.0.3.3.2 of this SER. The staff finds that visual inspections will be

performed on external surfaces to detect any sign of aging degradation. On the basis of its

review, the staff concludes that the general condition monitoring program is acceptable for

managing loss of material due to borated acid leakage on external surfaces of copper alloy

components in this system.

In the LRA, the applicant proposed to manage loss of material of stainless steel and copper alloy

safety injection pump coolers shell and channel, valves flow elements, pumps, restricting I

orifices, and tubing component types exposed to a moisture-laden air and/or intermittently

wetted environments using MPS AMP B2.1.13, "General Condition Monitoring," which is a

plant-specific program. The staff reviewed the general condition monitoring program and its

evaluation is documented in Section 3.0.3.3.2 of this SER. The staff finds that visual inspections

will be performed on external surfaces to detect any sign of aging degradation. On the basis of

its review, the staff concludes that the general condition monitoring program is acceptable for

managing loss of material due to pitting and crevice corrosion.

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3.3B.2.3.9 Neutron Shield Tank Cooling - Aging Management Evaluation - Table 3.3.2-9

The staff reviewed LRA Table 3.3.2-9,-which summarized the results of AMR evaluations for the

neutron shield tank cooling system component groups.

In the LRA, the applicant proposed to manage loss of material of external surfaces of the copper

alloy valves exposed to borated water leakage using MPS AMP B2.1.13, "General Condition

Monitoring," which is a plant-specific program. The staff reviewed the general condition

monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER. The staff

finds that visual inspections will be performed on external surfaces to detect any sign of aging

degradation. On the basis of its review, the staff concludes that the general condition monitoring

program in lieu of boric acid corrosion is acceptable for managing loss of material due to borated

acid leakage on external surfaces of copper alloy components in this system.

In the LRA, the applicant proposed to manage loss of material of stainless steel and copper alloy

valves and tubing component types exposed to a moisture-laden air and/or intermittently wetted

environments using MPS AMP B2.1.13, "General Condition Monitoring," which is a plant-specific

program. The staff reviewed the general condition monitoring program and its evaluation is

documented in Section 3.0.3.3.2 of this SER. The staff finds that visual inspections will be

performed on external surfaces to detect any sign of aging degradation. On the basis of its

review, the staff concludes that the general condition monitoring program is acceptable for

managing loss of material due to pitting and crevice corrosion.

3.3B.2.3.1 0 Containment Atmosphere Monitoring - Aging Management Evaluation -

Table 3.3.2-10

The staff reviewed LRA Table 3.3.2-1 0, which summarized the results of AMR evaluations for

the containment atmosphere monitoring system component groups. The staff reviewed the

technical report for AMR results for the air and gas systems.

In the LRA, the applicant identified no aging effects for low-alloy and stainless steel components

exposed internally or externally to air, including bolting, pipe, and valves component types. Air is

not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of low-alloy

steel requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, low-alloy steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

componenticommodity group. Wrought austenitic stainless steel is not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

concludes that there are no applicable aging effects for metal in an air environment.

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3.3B.2.3.11 Containment Instrument Air - Aging Management Evaluation - Table 3.3.2-11

The staff reviewed LRA Table 3.3.2-11, which summarized the results of AMR evaluations for

the containment instrument air system component groups. The staff reviewed the technical

report for AMR results for the air and gas systems.

In the LRA, the applicant proposed to manage loss of material of copper alloy pipe, tubing, and

valve component types exposed externally to a borated water leakage environment using the

MPS AMP B2.1.13, 'General Condition Monitoring," which is a plant-specific program. However,

the GALL Report specifies GALL AMP XI.M10, uBoric Acid Corrosion" to manage this aging

effect. The applicant stated, in Note 1, that the boric acid corrosion program includes specific

inspections of reactor coolant pressure boundary and supporting systems components. The staff

reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.2 of this SER. The staff finds that the general condition monitoring program

provides inspections for management of loss of material due to boric acid corrosion beyond the

scope of the boric acid corrosion program. Also, visual inspection of external surfaces is

performed during various walkdowns performed by plant personnel to look for boron buildup

and/or boric acid leaks. On the basis of its review, the staff concludes that this program is

acceptable for managing loss of material of copper alloy pipe, tubing, and valves component

types exposed to a borated water.

In the LRA, the applicant identified no aging effects for stainless steel, low-alloy steel, and

copper alloys components exposed internally or externally to air, including bolting, pipe, tubing,

and valve component types. Air is not identified in the GALL Report as an environment for these

components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of low-alloy

steel requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, low-alloy steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this -

component/commodity group. Wrought austenitic stainless steel and copper alloys are not

susceptible to significant general corrosion that would affect the intended function of :

components. Therefore, the staff concludes that there are no applicable aging effects requiring

management for metal in an air environment.

3.3B.2.3.12 Instrument Air - Aging Management Evaluation - Table 3.3.2-12

The staff reviewed LRA Table 3.3.2-12, which summarized the results of AMR evaluations for

the instrument air system component groups. The staff reviewed the technical report for AMR

results for the air and gas systems.

In the LRA, the applicant proposed to manage loss of material of copper alloy pipe and valve

component types exposed externally to a borated water leakage environment using MPS AMP

B2.1.13, "General Condition Monitoring," which is a plant-specific program. However, the GALL

Report specifies GALL AMP XI.M10, "Boric Acid Corrosion" to manage this aging effect. The

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applicant stated, in Note 1, that the boric acid corrosion program includes specific inspections of

reactor coolant pressure boundary and supporting systems components.

The staff reviewed the general condition monitoring program and its evaluation is'documented in

Section 3.0.3.3.2 of this SER. The staff finds that the general condition monitoring program

provides inspections for management of loss of-material due to boric acid corrosion beyond the

scope of the boric acid corrosion program. Also, visual inspection of external surfaces is

performed during various walkdowns by plant personnel to look for boron buildup and/or boric

acid leaks. On the basis of its review, the staff finds that this program is acceptable for

managing loss of material of copper alloy pipe and valves exposed externally to a borated water

leakage environment.

In the LRA, the applicant identified no aging effects for carbon steel, cast iron, and copper alloys

components exposed extemally, including air dryers,-filters, instrument air aftercooler (shell),

instrument air compressor (intercooler shell), instrument air filter silencer, instrument air receiver,

pipe, strainers, traps, valves, instrument air compressor, tubing, and valve component types. Air

is not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended '

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, carbon steel and cast iron

components will experience insignificant amounts of corrosion, and no aging effects are

applicable to this component/commodity group. Copper alloys are not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

finds that there are no applicable aging effects requiring management for metal in an air

environment.

In the LRA, the applicant also proposed to manage loss of materials of copper alloy instrument

air aftercooler (tubing) component type in an environment of treated water (closed cooling water)

using MPS AMP B2.1.7, "Closed-Cycle Cooling Water System." The staff reviewed the

closed-cycle cooling water system program and its evaluation is documented in Section 3.0.3.2.4

of this SER. The staff finds that the dosed-cycle cooling water system program is consistent with

GALL AMP XL.M21, "Closed-Cycle Cooling Water System," with an acceptable exception. On the

basis of its review, the staff finds that the closed-cycle cooling water system program is -

acceptable for managing loss of material of components in the treated water environment that

are serviced by closed-cycle cooling system. ;

In the LRA, the applicant proposed to manage loss of material of copper alloy pipe exposed

externally to a damp soil environment using MPS AMP B2.1.4, "Buried Piping Inspection

Program." The staff reviewed the buried piping inspection program and its evaluation is

documented in Section 3.0.3.2.1 of this SER. The staff finds that the buried piping inspection

program is consistent with GALL AMP XI.M28, mBuried Piping and Tanks Surveillance" and

GALL AMP XI.M34, "Buried Piping and Tanks'Inspection," with acceptable exceptions and

enhancements. The program includes a baseline inspection of representative samples of piping

with different protective measures and also inspections of buried components when piping is

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excavated during maintenance or for any other reason. On the basis of its review, the staff finds

that the program is acceptable for managing loss of material.

In the LRA, the applicant proposed to manage loss of material of copper alloy instrument air

compressor (intercooler tubing) component groups exposed externally to moisture-laden air

and/or an intermittently wetted environment (but internal to the air compressor) using MPS

AMP B2.1.25, 'Work Control Process," which is a plant-specific program. The staff reviewed the

work control process and its evaluation is documented in Section 3.0.3.3.4 of this SER. The staff

finds that visual inspections of the internal surfaces of plant components and plant commodities

are performed during maintenance, in accordance with the work control process program,' to

determine the presence of loss of material. On the basis of its review, the staff finds that the

work control process program is acceptable for managing loss of material due to general

corrosion since visual inspections will be performed on internal surfaces of components (external

surface of intercooler tubing) to detect any sign of aging degradation.

In the LRA, the applicant identified no aging effects for the cast iron air compressor component

type exposed internally to oil. However, the combination of cast iron in oil was not addressed in

the applicant's technical report for AMR results for the air and gas systems, and that no basis

was evident for the applicant's conclusion that there was no aging effect for this component type.

During the audit and review, the staff requested that the applicant provide a basis for

considering no aging effects. In an LRA supplement dated July 7, 2004, the applicant stated that

the oil environment was inadvertently listed for the instrument air compressor. On the basis of its

review, the staff finds the applicant's response acceptable.

3.3B.2.3.13 Nitrogen - Aging Management Evaluation - Table 3.3.2-13

The staff reviewed LRA Table 3.3.2-13, which summarized the results of AMR evaluations for

the nitrogen system component groups. The staff reviewed the applicant's technical report,

which provides the AMR results for the air and gas systems.

In the LRA, the applicant identified no aging effects for carbon steel components exposed

externally to air, including pipe and valve component types. Air is not identified in the GALL

Report as an environment for these components and materials.

On the basis of current industry research and operating experience, the staff finds that air on

metal will not result in aging that will be of concern during the period of extended operation. The

external environments being referred to are typical of ambient air (e.g., under a shelter, indoors,

or in an air-conditioned enclosure or room). Significant corrosion of carbon steel requires an

electrolytic environment, and a simultaneous presence of oxygen and moisture. Without the

presence of the aggressive environment, carbon steel components will experience insignificant

amounts of corrosion, and no aging effects are applicable to this componentcommodity group.

Therefore, the staff finds that there are no applicable aging effects requiring management for

metal in an air environment.

In the LRA, the applicant identified no aging effects for carbon steel components exposed

internally to gas for pipe and valve component types. Gas is not identified in the GALL Report as

an environment for these components and materials.

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On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (nitrogen, which is an inert gas) on metal will not result in

aging that will be of concern during the period of extended operation. Therefore, the staff finds

that there are no applicable aging effects requiring management for metal in a gas environment.

In the LRA, the applicant proposed to manage loss of material of stainless steel pipe component

types exposed to atmosphere/weather using MPS AMP B2.1.13, "General Condition Monitoring,"

which is a plant-specific program. The staff reviewed the general condition monitoring program

and its evaluation is documented in Section 3.0.3.3.2 of this SER. The staff finds that visual

inspections will be performed on external surfaces to detect any sign of aging degradation. On

the basis of its review, the staff concludes that the general condition monitoring program is

acceptable for managing loss of material due to pitting and crevice corrosion.

3.3B.2.3.14 Service Air - Aging Management Evaluation - Table 3.3.2-14 and Table 3.3.2-14a

;- .. , 1.i - ... ,:

The staff reviewed Table 3.3.2-14 of the LRA and Table 3.3.2-14a in the applicant's letter dated

January 11, 2005, which summarizes the results of AMR evaluations for the service air system

component groups. The staff reviewed the applicant's technical report, which provides the AMR

results for the air and gas systems. ;

In the LRA, the applicant proposed to manage loss of material of stainless steel pipe, and valve -

component types exposed to atmosphere/weather using MPS AMP B2.1.13,-aGeneral Condition

Monitoring," which is a plant-specific program. The staff reviewed the general condition

monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER. The staff

that visual inspections will be performed on external surfaces to detect any sign of aging

degradation. On the basis of its review, the staff notes that the general condition monitoring

program is acceptable for managing loss of material due to pitting and crevice corrosion.

In the LRA and the applicant's supplement dated January 11, 2005, the applicant proposed to

manage loss of material of stainless steel pipe, valves, and flow transmitters component groups

exposed internally to moisture-laden air and/or an intermittently wetted environment using MPS

AMP B2.1.25,7Work Control Process," which is a plant-specific program. The staff reviewed the

work control process and its evaluation is documented in Section 3.0.3.3.4 of this SER. The staff

finds that visual inspections of the internal surfaces of plant components and plant commodities

are performed during the performance of maintenance, in accordance with the work control

process program, to determine the presence of loss of material. On the basis of its review, the

staff finds that the work control process program is acceptable for. managing loss of material due

to general corrosion since visual inspections will be performed on internal surfaces of

components to detect any sign of aging degradation.

In LRA and the applicant's letter dated January. 11, 2005, the applicant identified no aging

effects for carbon steel and stainless steel components exposed externally to air, including pipe, -

valves and flow transmitters component types. Air, is not identified in the GALL Report as an

environment for-these components and materials. .. ;

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

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requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, carbon steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Therefore, the staff finds that there are no applicable aging effects

requiring management for metal in an air environment.

3.3B.2.3.15 Chemical and Volume Control - Aging'Management Evaluation - Table 3.3.2-15 and

Table 3.3.2-15a

The staff reviewed Table 3.3.2-15 of the LRA and the applicant's letter, dated January 11, 2005,

which summarized the results of AMR evaluations for the CVCS component groups.

In the LRA and the applicant's supplement dated January 11, 2005, the applicant identified no

aging effects for carbon steel, low-alloy steel, and stainless steel components exposed to air,

including bolting, charging pump lube oil coolers (shell), chiller surge tank, letdown chiller heat

exchanger (shell), level indicators, lube oil reservoirs, pipe, pumps, thermal regeneration'chiller

compressor oil cooler (channel head), thermal regeneration chiller compressor oil cooler (shell),

thermal regeneration chiller condenser (channel head) thermal regeneration chiller condenser

(shell), thermal regeneration chiller evaporator (shell), valves, boric acid blender and tanks,

chemical mixing tank, demineralizer, excess letdown heat exchanger (channel head),

filter/strainer, flexible hoses, flow element, letdown chiller heat exchanger (channel head),

letdown heat exchanger (channel head), letdown reheat heat exchanger (channel head and

shell), moderating heat exchanger (channel head and shell), moderating heat exchanger (shell),'

RCP seal standpipes, regenerative heat exchanger (channel head), regenerative heat'

exchanger (shell), restricting orifices, seal water heat exchanger (channel head), tubing,'volume

control tank, and boric acid batching tank component types. Air is not identified in the GALL

Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff findsthat air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and low-alloy steel requires anrelectrolytic environment, and a simultaneous presence of oxygen

and moisture. Without the presence of the aggressive'environm ent, low-alloy steel components

will experience insignificant amounts of corrosion, and no aging'effects are applicable to this

component/commodity group. Wrought austenitic stainless steel is not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

finds that there are no applicable aging effects requiring management for metal in an air

environment.

In the LRA, the applicant proposed to manage loss of material of carbon steel, and copper alloy

charging pump lube oil coolers (tubes), charging pump lube oil coolers (tubesheet), charging

pump lube oil coolers (shell), CS manifolds (charging pump LO), flexible hoses, level indicators,

lube oil reservoirs, pipe, pumps, thermal regeneration chiller compressor oil cooler (channel

head), thermal regeneration chiller compressor oil cooler (tube sheet), thermal regeneration

chiller compressor oil cooler (tubes), tubing, and valve component types exposed internally or

externally to oil using MPS AMP B2.1.25, "Work Control Process." The work control process

program provides the opportunity for personnel to visually inspect the internal surfaces of ';

components during preventive and corrective maintenance activities on an ongoing basis. Oil

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samples are analyzed periodically for contaminants for indication of degradation. The work

control process program provides input to the corrective action program if aging effects are

identified. The staff finds the work control process program acceptable for managing the aging

effect of loss of material. The staffs evaluation of the work control process program is

documented in Section 3.0.3.3.4 of this SER.;-

In the LRA, the applicant identified no aging effects for stainless steel components exposed

internally to gas or air for pipe, valves, and volume control tank component types. Gas is not

identified in' the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (which is similar to air) or air on metal will not result in aging

that will be of concern during the' period of extended operation. Therefore, the staff finds that

there are no applicable aging effects requiring management for metal in a gas or air

environment.

In the LRA,'the applicant identified no aging effects for carbon steel components exposed

internally to air for thermal regeneration chiller condenser (shell), thermal regeneration chiller,

evaporator (shell), and valve, component types. Air is not identified in the GALL Report as an

environment for these components and materials. However, the applicant identifies Note ,5 for

these components (page 3-273 and page 3-276). Specifically, Note 5 addresses external

environment of air and not internal environment. During the audit and review, the applicant was

requested to clarify this issue. In an LRA supplement dated July 7, 2004, the applicant stated

that the Note 5 should be replaced with Note 6 in LRA Table 3.3.2-15 (page 3-273) for CVCS

component groups OThermal Regeneration Chiller-Condenser (shell)" and "Thermal

Regeneration Chiller Evaporator (shell)" for an internal environment of air. On the basis of its

review, the staff finds the applicant's response acceptable.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of air on metal will not result in aging that will be of concern during

the period of extended operation.'Therefore, the staff concludes that there are no applicable

aging effects requiring management for metal in an air environment.

In the LRA,'the applicant proposed to manage loss of material of copper alloy charging pump

lube oil coolers (tubes), and charging pump lube oil coolers (tube sheet) component types

exposed internally to treated water using MPS AMP B2.1.7, "Closed-Cycle Cooling Water.

System."- The staff reviewed the closed-cycle cooling water system program and its evaluation is

documented in Section 3.0.3.2.4 of this SER. The staff finds that the closed-cycle cooling water

system program is consistent with GALL AMP XI.M.21, "Closed-Cycle Cooling Water System"

with an acceptable exception. The exception is performance testing of the closed-cycle cooling

water side of heat exchangers. On the basis 6f its review, the staff finds the closed-cycle cooling

water program 'acceptable for managinj the aging effect of loss of material for these component

groups.

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3.3B.2.3.16 Reactor Plant Sampling - Aging Management Evaluation - Table 3.3.2-16 and

Table 3.3.2-16a

The staff reviewed Table 3.3.2-16 of the LRA and Table 3.3.2-16a in the applicant's letter, dated

January 11, 2005, which summarizes the results of AMR evaluations for the reactor plant

sampling system component groups.

In the LRA, the applicant identified no aging effects for low-alloy and stainless steel components

exposed to air, including bolting, flexible hoses, piping, tubing, and valve component types. Air is

not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of'concem during the period 'of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of low-alloy

steel requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, low-alloy steel components will experience'

insignificant amounts of corrosion, and nb aging effects are" applicable to this

component/commodity group. Wrought austenitic stainless steel is not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

concludes that there are no aging effects requiring management for metal in an air environment.

3.3B.2.3.17 Primary Grade Water- Aging Management Evaluation - Table 3.3.2-17

The staff reviewed LRA Table 3.3.2-17, which summarized the results of AMR evaluations for

the primary grade water system component groups.

In the LRA, the applicant identified no aging effects for low-alloy and stainless steel components

exposed to air, including bolting, piping, and valve component types. Air is not identified in the

GALL Report as an environment for'these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of low-alloy'

steel requires an electrolytic environment; and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, low-alloy steel components will experience

insignificant amounts of corrosion,' and no aging effects are applicable to this

component/commodity group. Wrought austenitic stainless steel is not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

finds that there are no aging effects requiring management for metal in an air environment.

3.3B.2.3.18 Auxiliary Building Ventilation - Aging Management Evaluation - Table 3.3.2-18

The staff reviewed LRA Table 3.3.2-18, which summarized the results of AMR evaluations for

the auxiliary building ventilation system component groups.

In the LRA, the applicant proposed to manage loss of material of stainless steel flow elements,

pipe, and tubing component types exposed to atmosphere/weather using MPS AMP B2.1.13,

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"General Condition Monitoring," which is a plant-specific program. The staff reviewed the general

condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER.

The staff finds that visual inspections will be performed on external surfaces to detect any sign

of aging degradation. On the basis of its review, the staff finds the general condition monitoring

acceptable for managing loss of material due to pitting and crevice corrosion.

In the LRA, the applicant identified no aging effects for carbon and stainless steel HVAC

components exposed internally or externally to air that is not intermittently wetted, including

auxiliary building filter bank housings, damper housings, ductwork, filter bank housing, MCC rod

control and cable vault air conditioning air supply unit, pipe, silencers, valves, flow elements, and

tubing component types.

The applicant stated in the LRA that surfaces of carbon and stainless steel components located

within structures have not experienced corrosion degradation that would affect the intended

function of components due to humidity in the absence of cyclic or intermittent wetting

conditions, such as condensation. The applicant interprets the GALL Report environment termed

awarm, moist air" to be air with an undefined relative humidity level, and not a wetted

environment. Since the AMR approach considers loss of material only in a moisture-laden air

and/or intermittently wetted environment, the GALL Report items were determined to be not'

applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

In the LRA, the applicant identified no aging effects for copper alloy HVAC components exposed

internally or externally to air that is not intermittently wetted, including auxiliary building heating

and ventilation air supply heating coils component types.

The applicant stated in the LRA that surfaces of copper alloy components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interprets the GALL-Report environment termed "warm, moist air" to

be air with an undefined relative humidity level,.and not a wetted environment. Since the AMR

approach considers loss of material only in a wetted environment, the GALL Report items were

determined to be not applicable.

The staff reviewed the operating experience as a confirmation'of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air", alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

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3.3B.2.3.19 Circulating and Service Water Pumphouse Ventilation - Aging Management Evaluation - Table 3.3.2-19

The staff reviewed LRA Table 3.3.2-19, which summarized the results of AMR evaluations for

the circulating and service water pumphouse ventilation system component groups.

In the LRA, the applicant identified no aging effects for carbon steel HVAC components exposed internally and externally to air that is not intermittently wetted, including damper housings, ductwork, fan/blower housing, and silencer component types.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interprets the GALL Report environment termed "warm, moist air" to

be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

approach considers loss of material only in a wetted environment, the GALL Report items were

determined to be not applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, mmoist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging.effects requiring management for metal

in an air environment.

3.3B.2.3.20 Containment Air Recirculation - Aging Management Evaluation - Table 3.3.2-20

The staff reviewed LRA Table 3.3.2-20 which summarized the results of AMR evaluations for the

containment air recirculation system component groups.

In the LRA, the applicant identified no aging effects for carbon steel and stainless steel HVAC

components exposed internally or externally to air that is not intermittently wetted, including containment air recirculation cooling unit housings, damper housings, ductwork, fan/blower

housing, and tubing component types.

The applicant stated in the LRA that surfaces of carbon steel and stainless steel components located within structures have not experienced corrosion degradation that would affect the

intended function of components due to humidity in the absence of cyclic or intermittent wetting conditions, such as condensation. The applicant interprets the GALL Report environment termed

"warm, moist air" to be air with an undefined relative humidity level, and not a wetted

environment. Since the AMR approach considers loss of material only in a wetted environment,

the GALL Report items were determined to be not applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

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basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3B.2.3.21 Containment Purge Air - Aging Management Evaluation - Table 3.3.2-21

The staff reviewed LRA Table 3.3.2-21, which summarized the results of AMR evaluations for

the containment purge air system component groups.

In the LRA, the applicant identified no aging effects for carbon steel components exposed to air,

including damper housing, ductwork, pipe, and valve component types. Air is not identified in the

GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, carbon steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Therefore, the staff finds that there are no applicable aging effects

requiring management for metal in an air environment.

In the LRA, the applicant identified no aging effects for carbon steel components exposed

internally to air, including damper housing, ductwork, pipe, and valve component types. Air is not

identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The internal environment is air. Significant amounts of corrosion of carbon steel

require an electrolytic environment, and a simultaneous presence of oxygen and moisture. .

Significant corrosion of carbon steel in air environment also requires the components to be

subject to condensation. Without the presence of the aggressive environment, therefore, carbon

steel components will experience insignificant amounts of corrosion, and no aging effects would

be applicable to this component/commodity group. Therefore, the staff did not identify any.

concerns with the applicant's conclusions that there are no applicable aging effects requiring

management for metal in an air environment.

In the LRA, the applicant identified no aging effects for copper alloy components exposed to air,

including containment purge heating and ventilation air supply heating coils component types.

Air is not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Without the presence of the

aggressive environment, copper alloy components will experience insignificant amounts of,

corrosion, and no aging effects are applicable to this component/commodity group. Therefore,

the staff finds that there are no applicable aging effects requiring management for metal in an air

environment.

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3.3B.2.3.22 Containment Leakage Monitoring - Aging Management Evaluation - Table 3.3.2-22

The staff reviewed LRA Table 3.3.2-22, which summarized the results of AMR evaluations for

the containment leakage monitoring system component groups. In the LRA, the applicant

identified no aging effects for carbon and stainless steel components exposed to air, including

pipe, tubing, and valve component types. Air is not identified in the GALL Report as an

environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, carbon steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Wrought austenitic stainless steel is not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

finds that there are no applicable aging effects requiring management for metal in an air

environment.

In the LRA, the applicant identified no aging effects for carbon and stainless steel components

exposed internally to air, including pipe, tubing, and valve component types. Air is not identified

in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The internal environment is dry air. Significant amounts of corrosion of carbon steel

require an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Significant corrosion of carbon steel in-air environment also requires the components to be

subject to condensation. Without the presence of the aggressive environment, therefore, carbon

steel components will experience insignificant amounts of corrosion, and no aging effects would

be applicable to this component/commodity group. Wrought austenitic stainless steel is not

susceptible to significant general corrosion that would affect the intended function of

components. Therefore, the staff did not identify any concerns with the applicant's conclusions

that there are no applicable aging effects requiring management for metal in an air environment.

3.3B.2.3.23 Containment Vacuum - Aging Management Evaluation - Table 3.3.2-23 and

Table 3.3.2-23a

The staff reviewed Table 3.3.2-23 of the LRA and Table 3.3.2-23a in the applicant's supplement

dated January 11, 2005, which summarized the results of AMR evaluations for the containment

vacuum system component groups.

In the LRA, the applicant identified no aging effects for carbon steel components exposed to air,

including bolting component types. Air is not identified in the GALL Report as an environment for

these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

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operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Significant corrosion of carbon steel in air environment'also requires the components to be

subject to condensation. Without the presence of the aggressive environment, carbon steel

components will experience insignificant amounts of corrosion, and no aging effects are

applicable to this component/commodity group.-Wrought austenitic stainless steel is not

susceptible to significant general corrosion that would affect the intended function of

components. Therefore, the staff finds that there are no applicable aging effects requiring

management for metal in an air environment. -

In the LRA and the applicant's supplement dated January 11, 2005, the applicant identified no

aging effects for stainless steel components exposed to an indoors air environment and are not

intermittently wetted, including pipe, valves, pumps, and vacuum ejector component types. Air is

not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. Therefore, the staff did not identify any concerns with the applicant's conclusions that

there are no applicable aging effects requiring management for metal in an air environment.

3.3B.2.3.24 Control Building Ventilation - Aging Management Evaluation - Table 3.3.2-24

The staff reviewed LRA Table 3.3.2-24, which summarized the results of AMR evaluations for

the control building ventilation system component groups.

In the LRA, the applicant proposed to manage loss of material of stainless steel and carbon

steel chiller reservoirs, filter/strainer housing, pipe, valves, pumps (control building HVAC chiller

oil pump), chiller oil coolers (shell), chiller oil coolers (tubes),and chiller oil coolers (tubesheet)

component types exposed internally or externally to oil using MPS AMP B2.1.25, "Work Control

Process." The work control process program provides the opportunity for personnel to visually

inspect the internal surfaces of components during preventive and corrective maintenance

activities on an ongoing basis. Oil samples are analyzed periodically for contaminants for

indication of degradation. The work control process program provides input to the corrective

action program if aging effects are identified.

The staff finds the work control process program acceptable for managing the aging effect of

loss of material. The staff reviewed the work control process program and its evaluation is

documented in Section 3.0.3.3.4 of this SER.

In the LRA, the applicant proposed to manage loss of material of stainless steel expansion

joints, flow elements, moisture indicators, tubing, and valve component types exposed to

atmosphere/weather using MPS AMP B2.1.13, 'General Condition Monitoring," which is a

plant-specific program. The staff reviewed the general condition monitoring program and its

evaluation is documented in Section 3.0.3.3.2 of.this SER. The staff finds that visual inspections

will be performed on external surfaces to detect any sign of aging degradation. On the basis of

its review, the staff finds that the general condition monitoring program is acceptable for

managing loss of material due to pitting and crevice corrosion.

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In the LRA, the applicant identified no aging effects for carbon steel and stainless steel HVAC

components exposed internally or externally to air that is not intermittently wetted, including air

storage tanks, control building air handling units (housing), control room emergency ventilation

filter bank housings, damper housings, duct flow restrictors, ductwork, fan blower housing, filter/strainer housing, heater housing, humidifiers, pipe, tubing, and valves component types.

The applicant stated in the LRA that surfaces of carbon and stainless steel components located

within structures have not experienced corrosion degradation that would affect the intended

function of components due to humidity in the absence of cyclic or intermittent wetting

conditions, such as condensation. The applicant interprets the GALL Report environment termed

"warm, moist air" to be air with an undefined relative humidity level, and not a wetted

environment. Since the AMR approach considers loss of material only in a moisture-laden air

and/or intermittently wetted environment, the GALL Report items were determined to be not

applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that;- based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

In the LRA, the applicant identified no aging effects for cast iron and copper alloy components

exposed internally or externally to gas for economizers, evaporator (shell), evaporator

(tubesheet), evaporator (tubes), and compressor component types. Gas is not identified in the

GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (which is similar to air) on metal will not result in aging that

will be of concern during the period of extended operation. Therefore, the staff finds that there

are no applicable aging effects requiring management for metal in a gas environment.

3.3B.2.3.25 CRDM Ventilation and Cooling - Aging Management Evaluation - Table 3.3.2-25

The staff reviewed LRA Table 3.3.2-25, which summarized the results of AMR evaluations for

the CRDM ventilation and cooling system component groups.

All line items in this system are consistent with the GALL Report.

3.3B.2.3.26 Emergency Generator Enclosure Ventilation - Aging Management Evaluation - Table 3.3.2-26

The staff reviewed LRA Table 3.3.2-26, which summarized the results of AMR evaluations for

the emergency generator enclosure ventilation system component groups. In the LRA, the

applicant identified no aging effects for carbon steel HVAC components exposed internally and

externally to air that is not intermittently wetted, including damper housings, ductwork, and fan

blower housing component types.

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The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interprets the GALL Report environment termed "warm, moist air" to

be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of'

significant corrosion, moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3B.2.3.27 ESF Building Ventilation - Aging Management Evaluation - Table 3.3.2-27

The staff reviewed LRA Table 3.3.2-27, which summarized the results of AMR evaluations for

the ESF building ventilation system component groups.

In the LRA Table 3.3.2-27 the applicant credits MPS AMP B.2.1.25, "Work Control Process," to

manage loss of material of carbon steel condensers (shell) and copper alloy condenser (tubes)

exposed internally and externally to gas, respectively (Note G). However, also in LRA

Table 3.3.2-27, the staff identified several other carbon steel and copper alloy component types

that have no aging effect in the same environment (Note G). During the audit and review, the

staff asked the applicant to justify the difference in aging effects and AMPs between the two

material, environment, aging effect, and AMP combinations.

In the applicant's response, dated January 11, 2005, the applicant stated that it was

conservatively assumed that a small amount of moisture may be present in the refrigerant gas

environment. This moisture could condense in the condenser shell-side due to exposure to

cooling water (cold seawater) on the tube-side of the condenser. Therefore, the loss of material

aging effect was applied to the condenser shell and tubes exposed to a gas environment. Other

carbon steel and copper alloy components are not exposed to potential condensation and,

therefore, would not experience the same aging effect.

In LRA Table 3.3.2-27, the applicant credits MPS AMP B.2.1.25, 'Work Control Process," to

manage loss of material of copper alloy condensers (tubes) exposed externally to gas (Note A).

This AMR line item references the GALL Report Item VII.F.2.2-a, which is an environment of

warm, moist air. The staff asked the applicant to clarify the environment, aging effect, -and aging

management program combination.

In its response, dated January 11, 2005, the applicant stated that the potential for moisture in

the refrigerant gas was incorrectly compared to the warm, moist air environment described in

GALL Report Item VII.F2.2-a. No matching item from the GALL Report should have been listed

in LRA Table 3.3.2-27 for this item and Note G should have been listed instead of Note A. On

the basis of its review, the staff finds the applicant's response acceptable.

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3.3B.2.3.28 Fuel Building Ventilation - Aging Management Evaluation - Table 3.3.2-28

The staff reviewed LRA Table 3.3.2-28, which summarized the results of AMR evaluations for

the fuel building ventilation system component groups.

In the LRA, the applicant identified no aging effects for carbon steel, copper alloys and stainless

steel HVAC components exposed internally or externally to air that is not intermittently wetted,

including damper housing, ductwork, fan blower housing, fuel building filter bank housing, heating coils (fuel building), pipe, silencers, tubing, and valve component types.

The applicant stated in the LRA that surfaces of carbon steel, copper alloys and stainless steel

components located within structures have not experienced corrosion degradation that would

affect the intended function of components due to humidity in the absence of cyclic or

intermittent wetting conditions, such as condensation. The applicant interprets the GALL Report environment termed "warm, moist air" to be air with an undefined relative humidity level, and not

a wetted environment. Since the AMR approach considers loss of material only in a

moisture-laden air and/or intermittently wetted environment, the GALL Report items were

determined to be not applicable.

The staff reviewed the Unit 3 operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment

3.3B.2.3.29 Hydrogen Recombiner and Hydrogen Recombiner Building HVAC - Aging Management Evaluation - Table 3.3.2-29

The staff reviewed LRA Table 3.3.2-29, which summarized the results of AMR evaluations for

the hydrogen recombiner and hydrogen recombiner building HVAC system component groups.

In the LRA, the applicant identified no aging effects for carbon steel and stainless steel HVAC

components exposed internally or externally to air that is not intermittently wetted, including airblast heat exchangers, damper housing, ductwork, fan/blower housing, pipe, flow elements, radiant heaters, reaction chamber, tubing, and valve component types.

The applicant stated in the LRA that surfaces of carbon and stainless steel components located

within structures have not experienced corrosion degradation that would affect the intended

function of components due to humidity in the absence of cyclic or intermittent wetting conditions, such as condensation. The applicant interprets the GALL Report environment termed

"warm, moist air" to be air with an undefined relative humidity level, and not a wetted

environment. Since the AMR approach considers loss of material only in a moisture-laden air

and/or intermittently wetted environment, the GALL Report items were determined to be not

applicable.

The staff reviewed the Unit 3 operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

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significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, 'moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment. -

3.3B.2.3.30 Main Steam Valve Building Ventilation - Aging Management Evaluation - Table

3.3.2-30

The staff reviewed LRA Table 3.3.2-30, which summarized the results of AMR evaluations for

the main steam valve building ventilation system component groups.

In the LRA, the applicant identified no aging effects for carbon steel and copper alloy HVAC

components exposed internally or externally to air that is not intermittently wetted, including

damper housing, ductwork, fan/blower housing, and heating coils (main steam valve building)

component types.

The applicant stated in the LRA that surfaces of carbon steel and copper alloy components

located within structures have not experienced corrosion degradation that would affect the,

intended function of components due to humidity in the absence of cyclic or intermittent wetting

conditions, such as condensation. The applicant interprets the GALL Report environment termed

Swarm, moist air" to be air with an undefined relative humidity level, and not a wetted ,;

environment. Since the AMR approach considers loss of material only in a moisture-laden air

and/or intermittently wetted environment, the GALL Report items were determined totbe not

applicable. :

The staff reviewed the Unit 3 operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of!

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment. --

3.3B.2.3.31 Service Building Ventilation and Air-Conditioning - Aging Management Evaluation -

Table 3.3.2-31

The staff reviewed LRA Table 3.3.2-31, which summarized the results of AMR evaluations for

the service building ventilation and air-conditioning system component groups. In the LRA, the

applicant identified no aging effects for carbon steel HVAC components exposed internally or

externally to air that is not intermittently wetted, including damper housing, and ductwork

component types.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interprets the GALL Report environment termed "warm, moist air" to

be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

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approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed the Unit 3 operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3B.2.3.32 SBO Diesel Generator Building Ventilation - Aging Management Evaluation - Table

3.3.2-32

The staff reviewed LRA Table 3.3.2-32, which summarized the results of AMR evaluations for

the SBO diesel generator building ventilation system component groups. In the LRA, the

applicant identified no aging effects for carbon steel HVAC components exposed internally or

externally to air that is not intermittently wetted, including air conditioning units; self contained

housing component types.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interprets the GALL Report environment termed "warm, moist air" to

be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed the operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, 'moist air' alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3B.2.3.33 Supplementary Leak Collection and Release - Aging Management Evaluation -

Table 3.3.2-33

The staff reviewed LRA Table 3.3.2-33, which summarized the results of AMR evaluations for

the supplementary leak collection-and-release system component groups.

In the LRA, the applicant identified no aging effects for carbon and stainless steel components

exposed to air, including damper housings, ductwork, fanlblower housings, flow elements, pipe,

pipe (stack), filter bank housings, tubing, valves, valves (stack) component types. Air is not

identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

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operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, carbon steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Wrought austenitic stainless steel is not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

concludes that there are no applicable aging effects requiring management for metal in an air

environment.

In the LRA, the applicant identified no aging effects for carbon and stainless steel components

exposed internally to air, including damper housings, ductwork, fan/blower housings, flow

elements, pipe, pipe (stack), filter bank housings, tubing, valves, valves (stack) component

types. Air is not identified in the GALL Report as an environment for these components and

materials.,

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The internal environment is dry air. Significant amounts of corrosion of carbon steel

require an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Significant corrosion of carbon steel in air environment also requires the components to be

subject to condensation. Without the presence of the aggressive environment, therefore, carbon

steel components will experience insignificant amounts of corrosion, and no aging effects would

be applicable to this component/commodity group. Wrought austenitic stainless steel is not

susceptible to significant general corrosion that would affect the intended function of

components. Therefore, the staff did not identify any concerns with the applicant's conclusions,

that there are no applicable aging effects requiring management for metal in an air environment.

3.3B.2.3.34 Turbine Building Area Ventilation - Aging Management Evaluation - Table 3.3.2-34

The staff reviewed LRA Table 3.3.2-34, which summarized the results of AMR evaluations for

the turbine building area ventilation system component groups. In the LRA, the applicant'

identified no aging effects for carbon steel HVAC components exposed internally and externally

to air that is not intermittently wetted, including damper housings component types. :

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interprets the GALL Report environment termed "warm, moist air" to

be air with an undefined relative humidity level,- and not a wetted environment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed the Unit 3 operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

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basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3B.2.3.35 Waste Disposal Building Ventilation - Aging Management Evaluation - Table

3.3.2-35

The staff reviewed LRA Table 3.3.2-35, which summarized the results of AMR evaluations for

the waste disposal building ventilation system component groups. In the LRA, the applicant'

identified no aging effects for carbon steel HVAC components exposed internally and externally

to air that is not intermittently wetted, including damper housings, and ductwork component

types.

The applicant stated in the LRA that surfaces of carbon steel components located within

structures have not experienced corrosion degradation that would affect the intended function of

components due to humidity in the absence of cyclic or intermittent wetting conditions, such as

condensation. The applicant interprets the GALL Report environment termed "warm, moist air" to

be air with an undefined relative humidity level, and not a wetted environment. Since the AMR

approach considers loss of material only in a moisture-laden air and/or intermittently wetted

environment, the GALL Report items were determined to be not applicable.

The staff reviewed the Unit 3 operating experience as a confirmation of the validity of the AMR

approach for corrosion in an air environment. The operating experience reviews did not find

significant corrosion of ventilation system components (other than cooling coils and associated

components) due to the air environment. The staff finds that, based on the absence of

significant corrosion, "moist air" alone does not result in corrosion for these components. On the

basis of its review, the staff finds that there are no aging effects requiring management for metal

in an air environment.

3.3B.2.3.36 Unit 2 Fire Protection - Aging Management Evaluation - Table 3.3.2-36

The staff reviewed LRA Table 3.3.2-36, which summarized the results of AMR evaluations for

the Unit 2 fire protection system component groups.

In the LRA, the applicant identified no aging effects for carbon steel, stainless steel, cast iron,

copper alloy, and PVC components exposed to air, including flame arrestors, flex connections,

flow indicators, flow orifices, nozzles, pipe, pumps, retard chambers, sprinkler heads, strainers,

tubing, valves, and water motor gongs component types. Air is not identified in the GALL Report

as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, low-alloy steel components will

experience insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Wrought austenitic stainless steel and copper alloy are not

susceptible to significant general corrosion that would affect the intended function of

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components. PVC is impervious to an air environment. Therefore, the staff finds that there are

no applicable aging effects requiring management for metal in an air environment.

In the LRA, the applicant proposed to manage loss of material of stainless steel drip pans'and

tubing component types exposed externally to a moisture-laden air and/or intermittently wetted

environment using AMP B2.1.13, "General Condition Monitoring Program," which is a

plant-specific program. The staff reviewed the general condition monitoring program and its

evaluation is documented in Section 3.0.3.3.2 of this SER. The staff finds that the general

conditionr'monitoring program is acceptable for managing loss of material due to pitting and

crevice corrosion since visual inspections will be performed on external surfaces to detect any

sign of aging degradation.

In the LRA, the applicant proposed to manage loss of material of copper alloy pipe, tubing, and

valve component types exposed to a borated water leakage external environment using MPS

AMP B2.1.13, "General Condition Monitoring," which is a plant-specific program. However, the

GALL Report specifies GALL AMP XI.M1 0, Boric Acid Corrosion," to manage this aging effect.

The applicant stated in Note 1 that the boric acid corrosion program includes specific inspections

of reactor coolant pressure boundary and supporting systems components.

The staff reviewed the general condition monitoring program and its evaluation is documented in'

Section 3.0.3.3.2 of this SER. The staff finds that the general condition monitoring program

provides inspections for management of loss of material due to boric acid corrosion beyond the

scope of the boric acid corrosion program. Also, visual inspection of external surfaces is

performed during various walkdowns by plant personnel to look for boron buildup and/or boric

acid leaks. On the basis of its review, the staff finds that this program is acceptable for'

managing loss of material of copper alloy pipe,-tubing,-and valve component types exposed to a

borated water leakage external environment.

In the LRA,-the applicant identified no aging effects for carbon and stainless steel, PVC,'and

copper alloy components exposed internally to an environment of air or gas, including flex

connections, flow orifices, nozzles, pipe, sprinkler heads, tubing, valves, and water motor gongs

component types. Gas is not identified in the GALL Report as an environment for these

components and materials. However, the staff identified a discrepancy between Unit 2 fire

protection system sprinkler heads and Unit 3 fire protection sprinkler heads in that the sprinkler

heads in Unit 3 were in a moist air environment and had an aging effect of loss of materials. In

its LRA supplement dated July 7, 2004, the applicant stated that the Unit 2 fire protection

system, as presented in LRA Table 3.3.2-36, Note 2 (subject to moisture-laden air and/or

intermittently wetted environment), should be included with the copper alloy "sprinkler head"

component group exposed internally to an air environment for the Unit 2 fire protection system.

The aging effect of "loss of material" should be added to this component group. The fire

protection program will manage these aging effects. Based on the addition of this aging effect,

the staff finds the applicant's response to be acceptable.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (which is similar to air) on metal will not result in aging that

will be of concern during the period of extended operation. Therefore, the staff finds that there

are no applicable aging effects requiring management for metal components in a gas

environment.

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The applicant, in the LRA, proposed to manage loss of material of copper alloy pipe, tubing, and

valve component types exposed externally to a moisture-laden air and/or intermittently wetted

environment using AMP B2.1.10, "Fire Protection Program," which is consistent with GALL AMP

XI.M26, "Fire Protection," and GALL AMP XL.M27, "Fire Water System." The staff reviewed the

fire protection program and its evaluation is documented in Section 3.0.3.2.7 of this SER. On the

basis of its review, the staff finds that the fire protection program is acceptable for managing loss

of material since visual inspections will be performed on internal surfaces to detect any sign of

aging degradation during maintenance activities.

In the LRA, the applicant proposed to manage loss of material of stainless steel flex connections

component type exposed internally to an environment of oil using AMP B2.1.25, "Work Control

Process." The staff reviewed the work control process program and its evaluation is documented

in Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. Oil samples are analyzed periodically for

contaminants that are an indication of degradation. The work control process program provides

input to the corrective action program if aging effects are identified. The staff finds the work

control process program acceptable for managing the aging effect of loss of material.

3.3B.2.3.37 Unit 3 Fire Protection - Aging Management Evaluation - Table 3.3.2-37

The staff reviewed LRA Table 3.3.2-37, which summarized the results of AMR evaluations for

the Unit 3 fire protection system component groups.

In the LRA, the applicant identified no aging effects for carbon steel, stainless steel, cast iron,

copper alloy, and PVC components exposed to air, including carbon dioxide (CO2) tank cooling

coils, coolant heat exchangers, flex hoses, flex connections; flow switches, instrument snubbers,

nozzles, restricting orifices, sprinkler heads, tubing, valves, flow indicators, housing, diesel fuel

storage tank, ductwork, exhaust silencer, expansion tank overflow container, reactor coolant

pump oil collection tanks, flame arrestors, heater unit, hydropneumatic tank, lube oil cooler,

odorizer, oil mist recovery unit, oil reservoir, pipe, pumps, vacuum limiter, and water manifold

component types. Air is not identified in the GALL Report as an environment for these

components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, carbon steel and cast iron

components will experience insignificant amounts of corrosion, and no aging effects are

applicable to this component/commodity group. Wrought austenitic stainless steel and copper

alloy are not susceptible to significant general corrosion that would affect the intended function

of components. PVC is impervious to an air environment. Therefore, the staff finds that there are

no applicable aging effects requiring management for metal in an air environment.

However, LRA Table 3.3.2-37, Auxiliary Systems - Unit 3 Fire Protection, for external surfaces of

copper alloy valves in an environment of air, did not include the aging effect of loss of material

as in Unit 2 Table 3.3.2-36, Auxiliary Systems - Unit 2 Fire Protection. In LRA supplement dated

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July 7, 2004, the applicant stated that for the Unit 3 fire protection system, as presented in Unit 2

Table 3.3.2-36, Note 2 (subject to moisture-laden air and/or intermittently wetted environment),

should be included with the copper alloy "valves" component group exposed internally to an air

environment for Unit 2 LRA, Table 3.3.2-36, Auxiliary Systems - Unit 3 Fire Protection. The

aging effect of "loss of material" will be added to this component group. The applicant stated that

fire protection program will manage this aging effect. Based on the addition of this aging effect,

the staff finds the applicant's response to be acceptable..

In the LRA, the applicant proposed to manage loss of material of copper alloy filter/strainer

component type exposed externally to a moisture-laden air and/or intermittently wetted

environment using AMP B2.1.13, "General Condition Monitoring," which is a plant-specific

program. The staff reviewed the general condition monitoring program and its evaluation is

documented in Section 3.0.3.3.2 of this SER. The staff finds that the general condition

monitoring program is acceptable for managing loss of material due to pitting and crevice

corrosion since visual inspections will be performed on external surfaces to detect any sign of

aging degradation.

In the LRA, the applicant identified no aging effects for carbon and stainless steel, PVC, and,

copper alloy components exposed internally to an environment of air or gas for C02 storage

tank, C02 tank cooling coils, damper housing, fan/blower housing, ductwork flex hoses and

connections, nozzles, odorizers, restricting orifices, tubing, and valve component types. Gas is

not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

an internal environment of gas (which is similar to air) on metal will not result in aging that will be

of concern during the period of extended operation. Therefore, the staff finds that there are no

applicable aging effects requiring management for metal in a gas environment.

In the LRA, the applicant proposed to manage loss of material of copper alloy sprinkler heads

exposed externally to a moisture-laden air and/or intermittently wetted environment using MPS

AMP B2.1.10, "Fire Protection Program," which is consistent with GALL-AMP XL.M26, "Fire

Protection," and GALL AMP XL.M27, "Fire Water System." The staff reviewed the fire protection

program and its evaluation is documented in Section 3.0.3.2.7 of this SER. The staff finds that

the fire protection program is acceptable for managing loss of material since visual inspections

will be performed on internal surfaces to detect any sign of aging degradation during

maintenance activities.

In the LRA, the applicant proposed to manage loss of material of stainless steel tubing

component type exposed internally to an environment of oil using AMP B2.1.25, "Work Control

Process." The staff reviewed the work control process program and its evaluation is documented

in Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. Oil samples are analyzed periodically for

contaminants that are an indication of degradation. The work control process program provides

input to the corrective action program if aging effects are identified. The staff finds the work

control process program acceptable for managing the aging effect of loss of material.-

In the LRA, the applicant proposed to manage loss of material of copper alloy and stainless steel

tubing and restricting orifices component types exposed internally to oil (fuel oil) using AMP

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B2.1.12, 'Fuel Oil Chemistry." The staff reviewed the fuel oil chemistry program and its

evaluation is documented in Section 3.0.3.2.9 of this SER. The fuel oil chemistry program is

consistent with GALL AMP XI.M30,."Fuel Oil Chemistry," with acceptable exceptions. On the

basis of its review, the staff finds the program acceptable for managing the aging effects of loss

of material. The effectiveness of the fuel oil chemistry program is verified by MPS AMP B2.1.25,

"Work Control Process." The staff reviewed the work control process program and its evaluation

is documented in Section 3.0.3.3.4 of this SER. The staff finds that the work control process

program is acceptable for managing loss of material due to general corrosion since visual

inspections will be performed on internal surfaces of components to detect any sign of aging degradation.

During the audit and review, the staff questioned why various portions of the fire protection

system were not included within the scope of license renewal and subject to an AMR. In its LRA

supplement dated July 7, 2004, the applicant added several components to the fire protection

system that are subject to an AMR. The addition of these components did not result in the

addition of material/environment combinations or AMPs for the fire protection system AMR. The

staff finds this material/environmentlaging effect/AMP combination to be acceptable. The staff's

evaluation of the scope of the fire protection system is documented in Section 2.3B.3.39 of this

SER.

3.3B.2.3.38 Domestic Water - Aging Management Evaluation - Table 3.3.2-38

The staff reviewed LRA Table 3.3.2-38, which summarized the results of AMR evaluations for

the domestic water system component groups.

In the LRA, the applicant proposed to manage loss of material of copper alloy pipe, shock

absorbers, strainers, and valve component types exposed externally to a moisture-laden air

and/or intermittently wetted environment using MPS AMP B2.1.13, "General Condition

Monitoring," which is a plant-specific program. The staff reviewed the general condition

monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER. The staff

finds that the general condition monitoring program is acceptable for managing loss of material

due to general corrosion since visual inspections will be performed on external surfaces to

detect any sign of aging degradation.

In the LRA, the applicant identified no aging effects for carbon steel heater component type

exposed to air. Air is not identified in the GALL Report as an environment for these components

and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, carbon steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Therefore, the staff finds that there are no applicable aging effects

requiring management for metal in an air environment.

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In the LRA, the applicant proposed to manage loss of material of copper alloy pipe and valves

exposed externally to an environment of borated water leakage using MPS AMP B2.1.13,

"General Condition Monitoring," which is a plant-specific program. However, the GALL Report

specifies GALL AMP XI.MIO, Boric Acid Corrosion' to manage this aging effect. The applicant

stated, in Note 1, that the boric acid corrosion program includes specific inspections of reactor

coolant pressure boundary and supporting systems components. The staff reviewed the general

condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER.

The staff finds that the general condition monitoring program provides inspections for

management of loss of material due to boric acid corrosion beyond the scope of the boric acid

corrosion program. Also, a visual inspection of external surfaces is performed during various

walkdowns performed by plant personnel to look for boron buildup and/or boric acid leaks. On

the basis of its review, the staff finds that this program is acceptable for managing loss of

material of copper alloy pipe and valves exposed to externally to an environment of borated

water.

3.3B.2.3.39 Emergency Diesel Generators - Aging Management Evaluation - Table 3.3.2-39

The staff reviewed LRA Table 3.3.2-39, which summarized the results of AMR evaluations for

the emergency diesel generators system component groups. The staff reviewed the technical

report for the AMR results for the diesel generator and support systems.

In the LRA, the applicant proposed to manage loss of material of stainless steel, carbon steel,

cast iron, and copper alloy engine sumps, filter/strainers, governor lube oil coolers (shell), jacket

water heaters, lube oil heat exchangers (shell), oil reservoirs, oil separators, pipe, pre-lube oil

heaters, pumps, valves,-turbochargers, governor lube oil coolers (tubes), lube oil heat

exchangers (tubes), lube oil heat exchangers (tubesheet), and tubing component types exposed

internally or externally to oil using MPS AMP B2.1.25, "Work Control Process." The staff

reviewed the work control process program and its evaluation is documented in Section 3.0.3.3.4

of this SER. The work control process program provides the opportunity for personnel to visually

inspect the internal surfaces of components during preventive and corrective maintenance

activities on an ongoing basis. Oil samples are analyzed periodically for contaminants for

indication of degradation. The work control process program provides input to the corrective

action program if aging effects are identified. The staff finds the work control process program

acceptable for managing the aging effect of loss of material.

In the LRA, the applicant proposed to manage loss of material due to selective leaching of

copper alloy diesel engine jacket water cooler heat exchangers (tubes), and engine air cooler

water heat exchangers (tubes) component types exposed to treated water using

MPS AMP B2.1.25, 'Work Control Process," which is a plant-specific program. The staff

reviewed the work control process program and its evaluation is documented in Section 3.0.3.3.4

of this SER. The work control process program provides the opportunity for personnel to visually

inspect the internal surfaces of components during preventive and corrective maintenance

activities on an ongoing basis. The work control process program provides input to the corrective

action program if aging effects are identified: The staff finds the work control process program

acceptable for managing the aging effect of loss of material due to selective leaching since other

mechanical means will be used in addition to visual inspection to detect selective leaching.

In the LRA, the applicant proposed to manage loss of material of stainless steel pipe component

types exposed externally to an atmosphere/weather environment using MPS AMP B2.1.13,

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"General Condition* Monitoring," which is a plant-specific program. The staff reviewed the general condition monitoring program and its review is documented in Section 3.0.3.3.2 of this SER. The

staff finds that visual inspections will be performed on external surfaces to detect any sign of

aging degradation. The staff finds the general condition monitoring program acceptable for

managing loss of material due to pittng and crevice corrosion.

In the LRA, the applicant identified no aging effects for carbon steel, stainless steel, cast iron,

copper alloy and aluminum components exposed internally and externally to air, including air

distributors, air receiver tanks, air tanks, crankcase vacuum manometers, diesel engine jacket water cooler heat exchangers (shell), engine air cooler water heat exchangers (shell), engine

sumps, filter/strainers, fresh water expansion tanks, governor lube oil coolers (shell), jacket

water heaters, lube oil heat exchangers (channel), lube oil heat exchangers (shell), oil reservoirs, oil separators, pipe, pre-lube oil heaters, pumps, servo fuel rack shutdown and starting boosters, silencers, valves, turbochargers, level indicators, tubing, diesel engine jacket water cooler heat

exchangers (channel), and engine air cooler water heat exchangers (channel, expansion joints, and restricting orifices component types. Air is not identified in the GALL Report as an

environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, carbon steel and cast iron

components will experience insignificant amounts of corrosion, and no aging effects are

applicable to this component/commodity group. Wrought austenitic stainless steel, copper alloy, and aluminum are not susceptible to significant general corrosion that would affect the intended

function of components. Therefore, the staff finds that there are no applicable aging effects

requiring management for metal in an air environment.

3.3B.2.3.40 Emergency Diesel Generator Fuel Oil - Aging Management Evaluation - Table

3.3.2-40

The staff reviewed LRA Table 3.3.2-40, which summarized the results of AMR evaluations for

the emergency diesel generator fuel oil system component groups. The staff reviewed the

technical report for the AMR results for the diesel generator and support systems.

In the LRA, the applicant proposed to manage loss of material of copper alloy, and stainless

steel pumps, tubing, valves, flow elements, restricting orifices, and filter/strainers component

types exposed internally to fuel oil using MPS AMP B2.1.12, uFuel Oil Chemistry." The applicant stated in LRA Section 3.3.2.2.7 that MPS AMP B2.1.25, "Work Control Process," will be used to

provide confirmation of the effectiveness of the fuel oil chemistry program.

The staff reviewed the fuel oil chemistry program and its evaluation is documented in Section

3.0.3.2.9 of this SER. The fuel oil chemistry program (1) monitors and controls fuel oil quality to

ensure that it is compatible with the materials of construction and to manage the conditions that

cause general corrosion, pitting, and MIC of fuel tank internal surfaces; (2) establishes fuel oil

quality limits; and (3) samples and tests fuel oil used for equipment in license renewal scope. On

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the basis of its review, the staff finds the fuel oil chemistry program acceptable for managing this

aging effect.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis. The work control process program

provides input to the corrective action program if aging effects are identified. The staff finds the

work control process program acceptable for confirming the effectiveness of the fuel oil

chemistry program.

In the LRA, the applicant identified no aging effects for carbon steel, stainless steel, cast iron,

copper alloy and aluminum components exposed internally and externally to air, including flame

arrestors, flow elements, accumulator tanks, fuel oil day tanks, fuel oil storage tank, injectors,

pipe, pumps, valves, restricting orifices, filter/strainers, and tubing component types. Air is notidentified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, carbon steel and cast iron

components will experience insignificant amounts of corrosion, and no aging effects are-*

applicable to this component/commodity group. Wrought austenitic stainless steel, copper alloy,

and aluminum are not susceptible to significant general corrosion that would affect the intended

function of components. Therefore, the staff finds that there are no applicable aging effects

requiring management for metal in an air environment.

3.3B.2.3.41 Station Blackout Diesel Generator - Aging Management Evaluation - Table 3.3.2-41

The staff reviewed LRA Table 3.3.2-41, which summarized the results of AMR evaluations for

the SBO diesel generator system component groups. The staff reviewed the technical report for

the AMR results for the diesel generator and support systems.

In the LRA, the applicant proposed to manage cracking of stainless steel expansion tanks, pipe,

tubing, and valve component groups exposed internally to treated water using MPS AMP

B2.1.25, "Work Control Process," which is a plant-specific program. The staff reviewed the work

control process program is its evaluation is documented in Section 3.0.3.3.4 of this SER. The -

work control process program provides the opportunity for personnel to visually inspect the

internal surfaces of components during preventive and corrective maintenance activities on an

ongoing basis. The work control process program provides input to the corrective action

program if aging effects are identified. The staff finds the work control process program

acceptable for managing the aging effect of cracking.

In the LRA, the applicant proposed to manage loss of material of stainless steel, carbon steel,

and cast iron flow indicators, lube oil coolers (channel), oil sumps, pipe,- silencers, pumps, turbo

chargers, lube oil coolers (tubes), lube oil coolers (tubesheet), lubricators, restricting orifices,

tubing, and valve component types exposed internally or externally to oil using MPS AMP

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B2.1.25, "Work Control Process." The, staff reviewed the work control process program and its

evaluation is documented in Section 3.0.3.3.4 of this SER. The staff finds that the work control

process program provides the opportunity for personnel to visually inspect the internal surfaces

of components during preventive and corrective maintenance activities on an ongoing basis. Oil

samples are analyzed periodically for contaminants for indication of degradation. The work

control process program provides input to the corrective action program if aging effects are

identified. The staff finds the work control process program acceptable for managing the aging

effect of loss of material.

In the LRA, the applicant proposed to manage loss of material of stainless steel fuel heaters,

tubing, and valve component types exposed internally to fuel oil using MPS AMP B2.1.12, 'Fuel

Oil Chemistry." The applicant stated, in LRA Section 3.3.2.2.7, that MPS AMP B2.1.25, "Work

Control Process" will be used to provide confirmation of the effectiveness of the fuel oil chemistry

program. The staff reviewed the fuel oil chemistry program and its evaluation is documented in

Section 3.0.3.2.9 of this SER. The fuel oil chemistry program (1) monitors and controls fuel oil

quality to ensure that it is compatible with the materials of construction and to manage the

conditions that cause general corrosion, pitting, and MIC of fuel tank internal surfaces; (2)

establishes fuel oil quality limits; and (3) samples and tests fuel oil used for equipment within the

scope of license renewal: On the basis of its review, the staff finds the fuel oil chemistry program

acceptable for managing this aging effect.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and

corrective maintenance activities on an ongoing basis.. Oil samples are analyzed periodically for

contaminants for indication of degradation. The work control process program provides input to,

the corrective action program if aging effects are identified. The staff finds the work control

process program acceptable for confirming the effectiveness of the fuel oil chemistry program.

In the LRA, the applicant proposed to manage loss of material of stainless steel expansion

tanks, and valve component types exposed to atmosphere/weather using MPS AMP B2.1.13,

"General Condition Monitoring," which is a plant-specific program. The staff reviewed the general

condition monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER.

The staff finds that the general condition monitoring program is acceptable for managing loss of

material due to pitting and crevice corrosion since visual inspections will be performed on

external surfaces to detect any sign of aging degradation.

In the LRA, the applicant proposed to manage loss of material of stainless steel valve

component groups exposed internally to moisture-laden air and/or an intermittently wetted

environment using MPS AMP B2.1.25, "Work Control Process," which is a plant-specific -

program. The staff reviewed the work control process program and its evaluation is documented

in Section 3.0.3.3.4 of this SER. Visual inspections of the internal surfaces of plant components

and plant commodities are performed during the performance of maintenance, in accordance

with the work control process, to determine the presence of loss of material. The staff finds that

the work control process program is acceptable for managing loss of material due to pitting and

crevice corrosion since visual inspection will be performed on internal surfaces of components to

detect any sign of aging degradation.

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In the LRA, the applicant identified no aging effects for carbon steel, stainless steel, cast iron,

and aluminum components exposed internally and externally to air, including filter/strainers,

radiators, aftercoolers, aspirators, flow Indicators, fuel heaters, fuel oil day tanks, immersion

heaters, injectors, lube oil coolers (channel), lube oil coolers (shell), oil sumps, pipe, silencers,

pump, turbochargers, air receivers, expansion joints, lubricators, pulsation dampeners,

restricting orifices, tubing, and valve component types. Air is not identified in the GALL Report as

an environment for these components and materials. -

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive'environment, carbon steel and cast iron

components will experience insignificant amounts of corrosion, and no aging effects are

applicable to this component/commodity group. Wrought austenitic stainless ste'el,'and :-

aluminum are not susceptible to significant general corrosion that would affect the intend6d

function of components. Therefore, the staff concurs that there are no applicable aging effects

requiring management for metal in an air environment.

In the LRA, the applicant identified no aging effects for rubber expansion joints exposed to air.'

Based on industry research and operating experience, change of material properties due to

thermal exposure and irradiation and cracking due to irradiation of rubber components in air is

contingent on radiation levels, ambient temperatures, and exposure to ultraviolet radiation and

ozone.

On the basis of its review, the staff concurs with the applicant's finding that no aging effect for

rubber expansion joints in air to be acceptable, since these components are not expected to be

exposed to high levels of ultraviolet radiation, ozone, or temperatures greater than 95 F.

In the LRA, the applicant identified no aging effect for aluminum filter/strainers component group

exposed internally to lubricating oil. The technical report for AMR results for the diesel generator

and support systems did not specifically evaluate'aging effects for aluminum exposed internally

to oil. During the audit and review, the staff requested that the applicant provide a basis for its

conclusion that there are no aging effects requiring management for this combination of

component, material, and environment. The applicant stated that the MAER was used as the

basis. The staff reviewed the applicant's MAER -and finds that additional information regarding

the basis was necessary. The applicant revised its MAER and the technical report to include the

basis. The staff reviewed the basis and finds it acceptable. In addition,, the applicant stated that,

in a lubricating oil environment, significant corrosion is only expected where the water can settle

or pool. Due to the differential densities of lubricating oil and water, water will tend to separate

and settle in low flow or stagnant areas where the flow velocity is insufficient to flush the water

through the system. Lube oil systems are assumed to be free of water contamination as their

initial condition. Lube oil systems are typically closed systems that have little potential for ingress

of contaminants unless a component failure occurs. License renewal does not assume

component failures as a means to establish the conditions necessary for aging to occur. For

example, tube failures in lube oil coolers are not assumed. Therefore, water contamination of

lube oil is event driven, and would be addressed by corrective maintenance. For license renewal

purposes, lube oil is therefore assumed to be free of water contamination. On the basis of its

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review, the staff concurs that there are no applicable aging effects requiring management for

aluminum in a fuel oil environment.

In the LRA, the applicant identified no aging effects for aluminum radiators component group in

an external environment of atmosphere/weather. The technical report for AMR results for the'

diesel generator and support systems did not specifically evaluate aging effects for aluminum in

an external environment of atmosphere/weather. During the audit and review, the staff

requested that the applicant provide a basis for its conclusion that there are no aging effects

requiring management for this combination of component, material, and environment. During the

audit, the applicant stated that the technical report was revised to add the following statement:

Industry experience identified a potential conflict with the MAER with regard to

Aluminum in an air environment. St; Lucie identified corrosion problems with the

aluminum and copper components associated with the cooling fins of a radiator in

a cooling water system. The St. Lucie evaluation identified that it was an unusual

occurrence since aluminum elsewhere in the plant did not demonstrate similar

problems. Accordingly, and in conjunction with the MAER basis, operating

experience was used to validate that no problems of this type had occurred.

The staff reviewed the revised technical report and operating experience. On the basis of its

review, the staff finds that there are no applicable aging effects requiring management for

aluminum in an atmosphere/weather environment.

3.3B.2.3.42 Security - Aging Management Evaluation - Table 3.3.2-42

The staff reviewed LRA Table 3.3.2-42, which summarized the results of AMR evaluations for

the security system component groups. The staff reviewed the technical report for AMR results

for the diesel generator and support systems.

In the LRA, the applicant proposed to manage loss of material of carbon steel, cast iron, and

copper alloy coolers (shell), fan/blower housings, heaters, oil pans, pipe, pump, valves,

filter\strainers, coolers (tubes), and coolers (tubesheet) component types exposed internally or

externally to lubricating oil using MPS AMP B2.1.25, uWork Control Process." The staff reviewed

the work control process program and its evaluation is documented in Section 3.0.3.3.4 of this

SER. The work control process program provides the opportunity for personnel to visually

inspect the internal surfaces of components during preventive and corrective maintenance

activities on an ongoing basis. Oil samples are analyzed periodically for contaminants for

indication of degradation.,The work control process program provides input to the corrective

action program if aging effects are identified. The staff finds the work control process program

acceptable for managing the aging effect of loss of material.

In the LRA, the applicant proposed to manage loss of material of copper alloy pipe, tubing, and

valve component types exposed internally to fuel oil using MPS AMP B2.1.12, "Fuel Oil

Chemistry." The applicant stated in LRA Section 3.3.2.2.7 that MPS AMP B2.1.25, uWork Control

Process," will be used to provide confirmation of the effectiveness of the fuel oil chemistry

program. The staff reviewed the fuel oil chemistry program and its evaluation is documented in

Section 3.0.3.2.9 of this SER. The fuel oil chemistry program (1) monitors and controls fuel oil

quality to ensure that it is compatible with the materials of construction and to manage the

conditions that cause general corrosion, pitting, and MIC of fuel tank internal surfaces; (2)

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establishes fuel oil quality limits; and (3) samples and tests fuel oil used for equipment within the

scope of license renewal. The staff finds the fuel oil chemistry program acceptable.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The staff finds the work control process program provides the

opportunity for personnel to visually inspect the internal surfaces of components during -

preventive and corrective maintenance activities on an ongoing basis. It also provides input to

the corrective action program if aging effects are identified. On the basis of its review, the staff

concludes that the work control process program is acceptable for confirming the effectiveness

of the fuel oil chemistry program. . -

In the LRA, the applicant identified no aging effects for carbon steel, cast iron, and copper alloy

components exposed internally and externally to air, including coolers (channel head), coolers

(shell), diesel fuel oil storage tank, fan/blower housings, filter/strainers, heaters, oil pans, pipe,

pumps, valves, filter/strainers, tubing, and radiators component types.-Air is not identified in the

GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of carbon steel

and cast iron requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, carbon steel and cast iron

components will experience insignificant amounts of corrosion, and no aging effects are

applicable to this component/commodity group. Copper alloys are not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

finds that there are no applicable aging effects requiring management for metal in an air

environment.

In the LRA, the applicant identified no aging effects for aluminum radiators component type in an

external environment of air. The technical report for AMR results for the diesel generator and

support systems did not specifically evaluate aging effects for aluminum in anextemal'

environment of air. During the audit and review, the staff requested that the applicant provide a

basis for its conclusion that there are no aging effects requiring management for this -

combination of component, material, and environment. The applicant stated to the staff that the

technical report was revised to add the following statement:

Industry experience identified a potential conflict with the MAER with regard to

Aluminum in an air environment. St. Lucieidentified corrosion problems with the

aluminum and copper components associated with the cooling fins of a radiator in

a cooling water system. The St. Lucie evaluation identified that it was an unusual

occurrence since aluminum elsewhere in the plant did not demonstrate similar

problems. Accordingly, and in conjunction with the MAER basis,.operating

experience was used to validate that no problems'of this type had occurred.

The staff reviewed the revised technical report and operating experience. On the basis of its

review, the staff finds that there are no applicable aging effects requiring management for

aluminum in an air environment. ;

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3.3B.2.3.43 Boron Recovery - Aging Management Evaluation - Table 3.3.2-43 and

Table 3.3.2-43a

The staff reviewed Table 3.3.2-43 of the LRA and Table 3.3.2-43a in the applicant's letter, dated

January 11, 2005, which summarized the results of AMR evaluations for the boron recovery

system component groups.

In the LRA and the applicant's letter, dated January 11, 2005, the applicant identified no aging

effects for low-alloy steel and stainless steel components exposed to air, including boron

recovery tanks, cesium removal ion exchangers, filters/strainers, pipe, tubing, valves, boron

distillate cooler (shell), boron distillate tank, boron evaporator, boron evaporator bottoms coolant

preheater, boron evaporator bottons cooler (shell), boron evaporator condenser (channel head),

boron evaporator condenser (shell), boron evaporator reboiler (channel head), boron evaporator

reboiler (shell), boron evaporator sample cooler (shell),- density element, flow indicating switch,

flow indicating transmitter, flow transmitters, pumps and traps component types. Air is not

identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of low-alloy

steel requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, low-alloy steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Wrought austenitic stainless steel is not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

finds that there are no applicable aging effects requiring management for metal in an air

environment.

In LRA Table 3.4.2-43, the applicant proposed to manage loss of material for the stainless steel

boron recovery tanks exposed internally to air environment using MPS AMP B2.1.24, "Tank

Inspection Program." The staff reviewed the tank inspection program and its evaluation is

documented in Section 3.0.3.2.17 of this SER. On the basis of its review, the staff finds

management of loss of material for this component using the tank inspection program to be

adequate.

In the applicant's letter, dated January 11, 2005, the applicant proposed to manage loss of

material for the boron distillate cooler (shell) and the boron evaporator exposed externally to air

environment using MPS AMP B2.1.5, "Chemistry Control for Primary Systems Program." The

staff reviewed the chemistry control for primary systems program and its evaluation is

documented in Section 3.0.3.2.2 of this SER. The chemistry control for primary systems

program is consistent with the GALL Report, with an acceptable exception. The exception

relates to use of a later, non-NRC-approved revision of the EPRI guidelines. On the basis of its

review, the staff finds the chemistry control for primary systems program to be acceptable for

managing this aging effect.

In the applicant's letter dated January 11, 2005, the applicant proposed to manage cracking of

carbon steel for density element, flow transmitters, pumps and restricting orifices component -

types exposed externally to treated water environment using MPS AMP B2.1.25, "Work Control

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Process." The staff reviewed the work control process program and its evaluation is documented

in Section 3.0.3.3.4 of this SER. The work control process program provides the opportunity for

personnel to visually inspect the internal surfaces of components during preventive and ; -

corrective maintenance activities on an ongoing basis. Oil samples are analyzed periodically for

contaminants for indication of degradation. The work control process program provides input to

the corrective action program if aging effects are identified. The staff finds the work control

process program acceptable for managing the aging effect of cracking.

3.3B.2.3.44 Radioactive Liquid Waste Processing -,Aging Management Evaluation - Table

3.3.2-44 and Table 3.3.2-44a

The staff reviewed Table 3.3.2-44 of the LRA and Table 3.3.2-44a in the applicant's letter, dated

January 11, 2005, which summarized the results of AMR evaluations for the radioactive liquid

waste processing system component groups.

In the LRA and applicant's supplement dated January 11, 2005, the applicant identified no aging

effects for low-alloy and stainless steel components exposed to air, including flow elements,

piping, valves, pumps, radiation detectors, and tubing component types. Air is not identified in

the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended|

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of low-alloy

steel requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, low-alloy steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Wrought austenitic stainless steel is not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

finds that there are no aging effects requiring management for metal in an air environment.

3.3B.2.3.45 Radioactive Gaseous Waste - Aging Management Evaluation - Table 3.3.2-45 and

Table 3.3.2-45a

The staff reviewed Table 3.3.2-45 of the LRA and Table 3.3.2-45a in the applicant's supplement,

dated January 11, 2005, which summarized the results of AMR evaluations for the radioactive

gaseous waste system component groups.-

In the LRA, the applicant identified no aging effects for carbon steel and stainless steel

components exposed to air, including damper housings, ductwork, pipe, process vent cooler,

valves, degasifier condenser (shell), degasifers feed preheater (shell), degasifers, and tubing

component types. Air is not identified in the GALL Report as an environment for these

components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or.room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

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Without the presence of the aggressive environment, carbon steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Wrought austenitic stainless steel is not susceptible to significant

general corrosion that would affect the intended function of components. Therefore, the staff

finds that there are no applicable aging effects requiring management for metal in an air

environment.

In the LRA, the applicant proposed to manage loss of material of carbon steel and stainless

steel pipe and valve component groups exposed internally to moisture-laden air and/or an

intermittently wetted environment using MPS AMP B2.1.25, 'Work Control Process," which is a

plant-specific program. The staff reviewed the work control process program and its evaluation

is documented in Section 3.0.3.3.4 of this SER. The staff finds that visual inspections of the

internal surfaces of plant components and plant commodities are performed during the

performance of maintenance, in accordance with the work control process program, to

determine the presence of loss of material. On the basis of its review, the staff finds that the

work control process program is acceptable for managing loss of material due to general

corrosion.

In the applicant's letter dated January 11, 2005, the applicant proposed to manage loss of

material of stainless steel for the degasifers and tubing exposed internally to treated water and

steam environment using MPS AMP B2.1.5, "Chemistry Control for Primary Systems Program."

The staff reviewed the chemistry control for primary systems program and its evaluation is

documented in Section 3.0.3.2.2 of this SER. The chemistry control for primary systems

program is consistent with the GALL Report, with an acceptable exception; The exception

relates to use of a later, non-NRC-approved revision of the EPRI guidelines. On the basis of its,

review, the staff finds the chemistry control for primary systems program to be acceptable for

managing this aging effect. |

3.3B.2.3.46 Post-Accident Sampling - Aging Management Evaluation - Table 3.3.2-46

The staff reviewed LRA Table 3.3.2-46, which summarized the results of AMR evaluations for

the post-accident sampling system component groups.

In the LRA, the applicant identified no aging effects for stainless steel components exposed

internally and/or externally to gas or air for accumulators, de-ionized water flush tank, drain|

tanks, filter/strainers, flow elements, hoses, hydrogen sensors, pipe, pumps, sample coolers

shell, sample cylinders/chambers tubing and valve component types. Gas is not identified in the

GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that an internal environment of gas (which is similar to air) on metal will not result in aging that

will be of concern during the period of extended operation. Therefore, the staff concludes that

there are no applicable aging effects requiring management for metal in a gas environment.

In the LRA, the applicant proposed to manage loss of material of stainless steel de-ionized water

flush tank, drain tanks, hydrogen sensors, pipe, vacuum pump, sample cylinders/chambers,

tubing, and valve component groups exposed internally to a moisture-laden air and/or an

intermittently wetted environment using MPS AMP B2.1.25, "Work Control Process," which is a

plant-specific program. The staff reviewed the work control process program and its evaluation

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is documented in Section 3.0.3.3.4'6f this SER.Visual inspections of the internal surfaces of

plant components and plant commodities are performed during the performance of

maintenance, in accordance with the work control process program, to determine the presence of loss of material. The staff finds that the work control process program is acceptable for

managing loss of material due to general corrosion since visual inspections will be performed on

internal surfaces of components to detect any sign of aging degradation.

During the audit and review, the staff determined that additional components/structures were

added to the scope of license renewal and subject to an AMR. By letter dated July 7, 2004, the

applicant submitted additional information, entitled, 'Millstone Power Station Units 2 and 3 !'

Additional Information in Support of Application for renewed Operation'Licenses." The applicant added, in Attachment 1 to its letter, the component type "hydrogen tanks" and "restricting orifices" to the LRA post-accident sampling system screening results and AMR, LRA Table

2.3.3.46 and Table 3.3.2-46, respectively. The applicant stated that the addition of these

components did not result in the addition of materiaVenvironmentlaging effect/program combinations for the LRA post-accident sampling system. The staff reviewed the applicant's

response.- On the basis of its review, the staff finds the additional AMR results in LRA Table

3.3.2-46 for the hydrogen tanks and restricting orifices component types acceptable.

3.3B.2.3.47 Radioactive Solid Waste - Aging Management Evaluation - Table 3.3.2-47

The staff reviewed LRA Table 3.3.2-47, which summarized the results of AMR evaluations for

the radioactive solid waste system component groups. In the LRA, the applicant identified no

aging -effects for stainless steel components exposed to air, including pipe, and valve component

types. Air. is not identified in the GALL Report as an environment for these components and

materials.-

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Wrought austenitic stainless steel is

not susceptible to significant general corrosion that would affect the intended function of

components. Therefore, the staff finds that there are no applicable aging effects requiring management for metal in an air environment.

3.3B.2.3.48 Reactor Plant Aerated Drains - Aging Management Evaluation - Table 3.3.2-48 and

Table 3.3.2-48a

The staff reviewed Table 3.3.2-48 of the LRA and Table 3.3.2-48a in the applicant's letter dated

January 11, 2005, which summarized the results of AMR evaluations for the reactor plant

aerated drains system component groups. ' ;

In the LRA, the applicant identified no aging effects for carbon and stainless steel, PVC,

fiberglass, copper alloys, and ethylene propylene diene monomer components exposed to air,

including expansion joints, filters/strainers, flow elements, flow indicators, groundwater sumps, pipe, pumps, restricting orifices, tubing, and valve component types. Air is not identified in the

GALL Report as an environment for these components and materials.

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On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The internal environment is air without the presence of moisture. The external

environments being referred to are typical of ambient air (e.g., under a shelter, indoors, or in an

air-conditioned enclosure or room). Significant corrosion of carbon steel and copper alloys

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, carbon steel copper alloy components will

experience insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Wrought austenitic stainless steel is not susceptible to significant

general corrosion that would affect the intended function of components. PVC, fiberglass and

EPDM are impervious to an air environment. Therefore, the staff finds that there are no

applicable aging effects requiring management for metal in an air environment.

In the LRA, the applicant proposed to manage loss of material of stainless steel pipe and valve

component types exposed to atmosphere/weather using MPS AMP B2.1.13, "General Condition

Monitoring," which is a plant-specific program. The staff reviewed the general condition

monitoring program and its evaluation is documented in Section 3.0.3.3.2 of this SER. Visual

inspections will be performed on external surfaces to detect any sign of aging degradation. On

the basis of its review, the staff finds that the general condition monitoring program is acceptable

for managing loss of material due to pitting and crevice corrosion.

In the LRA, the applicant proposed to manage loss of material of stainless steel expansion joint,

groundwater sump, and pipe component groups exposed internally to a moisture-laden air

and/or an intermittently wetted environment using MPS AMP B2.1.25, "Work Control Process,"

which is a plant-specific program. The staff reviewed the work control process program and its

evaluation is documented in Section 3.0.3.3.4 of this SER. Visual inspections of the internal

surfaces of plant components and plant commodities are performed during the performance of

maintenance, in accordance with the work control process program, to determine the presence

of loss of material. On the basis of its review, the staff finds that the work control process

program is acceptable for managing loss of material due to general corrosion since visual

inspections will be performed on internal surfaces of components to detect any sign of aging

degradation.

In the LRA, the applicant identified no aging effects for PVC and fiberglass pipe, and tubing

components exposed internally and externally to raw water and seawater. Both PVC and

fiberglass material are benign in this environment.

On the basis of its review of current industry research and operating experience, the staff finds

that a raw/sea water environment does not have significant aging effect on materials like PVC

and fiberglass. Therefore, the staff did not identify any concerns with the applicant's conclusions

that there are no applicable aging effects requiring management for PVC and fiberglass in

raw/sea water environment.

In the applicant's letter dated January 11, 2005, the applicant proposed to manage loss of

material of the stainless steel for the groundwater underdrains storage tank exposed to

atmosphere/weather environment using MPS AMP B2.1.24, "Tank Inspection Program." The

staff reviewed the tank inspection program and its evaluation is documented in Section

3.0.3.2.17 of this SER. On the basis of its review, the staff finds management of loss of material

for this component using the tank inspection program to be adequate.

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3.3B.2.3.49 Reactor Plant Gaseous Drains - Aging Management Evaluation - Table 3.3.2-49

and Table 3.3.2-49a

The staff reviewed Table 3.3.2-49 of the LRA and Table 3.3.2-49a in the applicant's supplement,

dated January 11, 2005, which summarized the results of AMR evaluations for the reactor plant

gaseous drains system component groups.

In the LRA and the January 11,2005, supplement, the applicant identified no aging effects for

stainless steel components exposed to air, including flow indicators, pipe, pump, tubing, valves;

containment drains transfer tank, and primary drains transfer tank component types. Air is not

identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Wrought austenitic stainless steel is

not susceptible to significant general corrosion that would affect the intended function of

components. Therefore, the staff finds that there are no applicable aging effects requiring

management for metal in an air environment.

In the LRA, the applicant proposed to manage cracking of stainless steel flow indicators, pipe,

pump, tubing, and valves exposed internally to treated water using MPS AMP B2.1.25, "Work

Control Process," which is a plant-specific program. However, the applicant identified Note E for

these components and references Table 3.3.1, Item 3.3.1-15. The staff noted that Item 3.3.1-15

applies to loss of material aging effect and not cracking. The staff requested clarification for this

reference. In response Audit Item 146 dated July 7, 2004, the applicant stated, that LRA Table

3.3.2-49 should not include entries in the 'NUREG-1801 Volume 2 Item' and 'Table 1 Item'

columns for all line entries associated with the 'Cracking' aging effect. The Note for each

'Cracking' line entry should be "H." On the basis of its review, the staff finds the applicant's

response acceptable.

Also, in the its January 11, 2005, letter, the applicant proposed to manage cracking of stainless

steel containment drains transfer tank and the primary drains transfer tank exposed to internally

to the environment of treated water using MPS AMP B2.1.25, "Work Control Process."

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. Visual inspections of the internal surfaces of plant components

and plant commoditiesare performed during the performance of maintenance, in accordance.

with the work control process program, to determine the presence of loss of material. On the -

basis of its review, the staff finds that the work control process program is acceptable for

managing loss of material due to general corrosion since visual inspections will be performed on

internal surfaces of components to detect any sign of aging degradation.

3.3B.2.3.50 Sanitary Water - Aging Management Evaluation - Table 3.3.2-50

The staff reviewed LRA Table 3.3.2-50, which summarized the results of AMR evaluations for

the sanitary water system component groups. In the LRA, the applicant identified no aging

effects for cast iron and carbon steel components exposed to air, including pipe, and valves

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component types. Air is not identified in the GALL Report as an environment for these

components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoors, or in an air-conditioned enclosure or room). Significant corrosion of cast iron

and carbon steel requires an electrolytic environment, and a simultaneous presence of oxygen

and moisture. Without the presence of the aggressive environment, cast iron and carbon steel

components will experience insignificant amounts of corrosion, and no aging effects are

applicable to this componentlcommodity group. Therefore, the staff finds that there are no

applicable aging effects requiring management for metal in an air environment.

All other AMRs assigned to the staff in LRA Tables 3.3.2-1 through 3.3.2-50 were evaluated.

The staff finds them to be acceptable.

Conclusion. On the basis of its review, the staff finds that the applicant appropriately evaluated

AMR results involving material, environment, AERM, and AMP combinations that are not

evaluated in the GALL Report. The staff finds that the applicant has demonstrated that the

effects of aging will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.3B.3 Conclusion

On the basis of its review, the staff concludes that the applicant has demonstrated that the aging

effects associated with the auxiliary systems components will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of

extended operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable FSAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the auxiliary systems, as

required by 10 CFR 54.21(d).

3.4 Aalng Management of Steam and Power Conversion System

3.4A Unit 2 Aging Management of Steam and Power Conversion System

This section of the SER documents the staffs review of the applicant's AMR results for the

Unit 2 steam and power conversion components and component groups associated with the

following systems:

* main steam system

* extraction steam system

* feedwater system

* condensate system

* condensate storage and transfer system

* condensate demin mixed bed system

* auxiliary feedwater system

* feedwater heater vents and drains system

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* moisture separation and reheat system

* plant heating and condensate recovery system

* secondary chemical feed system

* turbine gland sealing system

* electro hydraulic control system

* turbine lube oil system

* exciter air cooler system

* stator liquid cooler system

* auxiliary steam reboiler and deaerating feedwater system

3.4A.1 Summary of Technical Information in the Application

In LRA Section 3.4, the applicant provided AMR results for steam and power conversion system'

components and component groups. In LRA Table 3.4.1, "Summary of Aging Management

Evaluations in Chapter Vil of NUREG-1 801 for steam and power conversion system," the

applicant provided a summary comparison of its AMRs with the AMRs evaluated in the GALL

Report for the steam and power conversion system components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.4A.2 Staff Evaluation

The staff reviewed LRA Section 3.4 to determine if the applicant provided sufficient information

to demonstrate that the effects of aging for the steam and power conversion system

components that are within the scope of license renewal and subject to an AMR will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

Also, the staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report. However, the staff did determine that the material

presented in the LRA was applicable and that the applicant had identified the appropriate GALL

AMPs. The staff's evaluations of the AMPs are-documented in-Section 3.0.3 of this SER. Details

of the staff's audit evaluation are documented in the staffs MPS audit and review report and

summarized in Section 3.4A.2.1 of this SER.

The staff also performed an onsite audit of those AMRs that were consistent with the GALL

Report and for which further evaluation is recommended. The staff verified that the applicant's

further evaluations were consistent with the acceptance criteria in Section 3.4.2.2 of

NUREG-1 800, "Standard Review Plan for Review of License Renewal Applications for Nuclear

Power Plants," dated July 2001. The staff's audit evaluations are documented in the staffs MPS

audit and review report and summarized in Section 3.4A.2.2 of this SER.

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The staff performed an onsite audit and conducted a technical review of the remaining AMRs

that were not consistent with the GALL Report. The audit and technical review included

evaluating whether all plausible aging effects were identified and the aging effects listed were

appropriate for the combination of materials and environments specified. The staffs audit

evaluations are documented in the staffs MPS audit and review report and summarized in

Section 3.4A.2.3 of this SER. The staffs evaluation of its technical review is also documented in

Section 3.4A.2.3 of this SER.

Finally, the staff reviewed the AMP summary descriptions in the FSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the steam and power conversion system components.

Table 3.4A-1 below provides a summary of the staffs evaluation of components, aging

effects/mechanisms, and AMPs listed in LRA Section 3.4 that are addressed in the GALL

Report.

Table 3.4A-1 Staff Evaluation for Steam and Power Conversion System In the GALL

Report

Compnont Group - Aging' Effct' ' .,' - AMP GAAMP In L RA ' - Staff Evaluaton'

- :- - .- -: ' '''Manlmotif~ .-X- '":i -Report. - -

Piping and fittings in Cumulative fatigue TLAA, evaluated TLAA This TLAA is

main feedwater line, damage in accordance with evaluated in Section

steam line, and 10 CFR 54.21 (c) 4.3A, Metal Fatigue

auxiliary feedwater

(AFW) piping (PWR

only)

(Item Number

3.4.1-01)

Piping and fittings, Loss of material due Water chemistry Chemistry control for Consistent with

valve bodies and to general (carbon and one-time secondary systems GALL, which

bonnets, pump steel only), pitting, inspection program (B2.1.6); recommends further

casings, tanks, and crevice Work control process evaluation (See

tubes, tubesheets, corrosion (B2.1.25) Section 3.4A.2.2.2)

channel head, and

shell (except main

steam system) (Item

Number

3.4.1-02)

AFW piping Loss of material due Plant-specific Not applicable (See

(Item Number to general, pitting, Section 3.4A.2.2.3)

3.4.1-03) and crevice

corrosion, MIC and

biofouling

Oil coolers in AFW Loss of material due Plant-specific Not applicable (See

system (lubricating to general (carbon Section 3.4A.2.2.5)

oil side possibly steel only), pitting,

contaminated with and crevice

water) corrosion, and MIC

(Item Number 3.4.1-04)

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,Component Group.' Aging'Effct ..- '- AMP In .GALL. A .nStf E'ion - --.- -Mochanism ' .. 1Rep 6.-r: .7.

External surface of Loss of material due Plant-specific General condition -Consistent with

carbon steel to general corrosion :monitoring (82.1.13) GALL, which

components recommends further

(Item Number evaluation (See

3.4.1-05) Section 3.4A.2.2.4)

Carbon steel piping Wall-thinning due to Flow-accelerated Flow-accelerated Consistent with

and valve bodies flow-accelerated corrosion corrosion (B2.1.11) GALL, which

(Item Number corrosion - recommends no

3.4.1-06) further evaluation

(See Section ___ l3.4A2.1)

Carbon steel piping Loss of material due Water chemistry Chemistry control for Consistent with

and valve bodies in to pitting and . secondary systems GALL, which ' main steam system crevice corrosion program (82.1.6) recommends no

(Item Number - further evaluation

3.4.1-07) . (See Section

3.4A.2.1)

Closure bolting in Loss of material due Bolting integrity Bolting integrity Consistent with

high-pressure or to general ; GALL (See Section

high-temperature corrosion; crack 3.4A.2.1.2),'

systems initiation and growth (Item Number due to cyclic loading

3.4.1-08) and/or SCC

Heat exchangers Loss of material due Open-cycle Not applicable. and ' to general (carbon cooling water There are no incoolers/condensers steel only), pitting, system scope components

by open-cycle and crevice in the steam and'

cooling water corrosion, MIC and power conversion

(Item Number biofouling; buildup systems that are

3.4.1-09) of deposit due to serviced by Open- biofouling Cycle Cooling Water System.

Heat exchangers ' Loss of material due Closed-cycle Closed-cycle cooling Consistent with

and to general (carbon cooling water - water system (82.1.7) GALL, which

coolers/condensers steel only), pitting, system 'recommends no

by closed-cycle and crevice - ** . further evaluation

cooling water corrosion (See Section

(Item Number 3.4A.2.1.3)

3.4.1-10) _ ; 

External surface of Loss of material due Aboveground ; Tank inspection Consistent with'

aboveground to general (carbon carbon steel tanks program (82.1.24) GALL, which:

condensate storage steel only), pitting, recommends no

tank and crevice , further evaluation

(Item Number corrosion . (See Section

3.4.1-11) 3AA.2.1)

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Comp'onetAGroup Aging Effect) ' AMP in GALL ,' : 'AM- in L -: : taff Evaluatlon

Mechanis i,.- R-prt -.- ' _._

External surface of Loss of material due Buried piping and Not applicable (See

buried condensate to general, pitting, tanks surveillance Section 3.4A.2.2.5)

storage tank and and crevice

AFW piping corrosion, and MIC or

(Item Number

3.4.1-12)

Buried piping and

tanks inspection

External surface of Loss of material due Boric acid Boric acid corrosion Consistent with

carbon steel to boric acid corrosion (B2.1.3); General GALL (See Section

components corrosion condition monitoring 3.4A.2.1.1)

(Item Number (B2.1.13)

3.4.1-13) _ _

The staffs review of the MPS steam and power conversion system and associated components

followed one of several approaches. One approach, documented in Section 3.4A.2.1, involves

the staffs review of the AMR results for components in the steam and power conversion system

that the applicant indicated are consistent with the GALL Report and do not require further

evaluation. Another approach, documented in Section 3.4A.2.2, involves the staffs review of the

AMR results for components in the steam and power conversion system that the applicant

indicated are consistent with the GALL Report and for which further evaluation is recommended.

A third approach, documented in Section 3.4A.2.3, involves the staff's review of the AMR results

for components in the steam and power conversion system that the applicant indicated are not

consistent with the GALL Report or are not addressed in the GALL Report. The staffs review of

AMPs that are credited to manage or monitor aging effects of the steam and power conversion

system components is documented in Section 3.0.3 of this SER.

3.4A.2.1 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation Is Not Recommended

Summary of Technical Information in the ADplication. In Section 3.4.2.1 of the LRA, the applicant

identified the materials, environments, and aging effects requiring management. The applicant

identified the following programs that manage the aging effects related to the main steam, main

feedwater, and emergency feedwater system components:

* boric acid corrosion program

* chemistry control for secondary systems program

* closed-cycle cooling water system program

* flow-accelerated corrosion program

* general condition monitoring program

* work control process program

* tank inspection program

* bolting integrity program

Staff Evaluation. In Tables 3.4.2-1 through 3.4.2-12 of the LRA, the applicant provided a

summary of AMRs for the main feedwater, main steam, auxiliary feedwater, and blowdown

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system components and identified which AMRs it considered to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes described how the information

in the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicated the AMR was consistent with the GALL Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component,.

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicated that the AMR line item is consistent with the GALL Report for component,

material, environment,- and aging effect. In addition, the AMP takes some exceptions to the AMP -

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by the

applicant was consistent with the AMP identified in the GALL Report and whether the AMR was

valid for the site-specific conditions.

Note C indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP is consistent

with the AMP identified by the GALL Report. This note indicates that the applicant was unable to

find a listing of some system components in the GALL Report. However, the applicant identified

a different component in the GALL Report that had the same material, environment, aging -

effect, and AMP as the component that was under review. The staff audited these line items to

verify consistency with the GALL Report. The staff also determined whether the AMR line item of

the different component was applicable to the component under review and whether the AMR

was valid for the site-specific conditions.

Note D indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition,-the AMP takes some

exceptions to the AMP identified in the GALL Report. The staff audited these line items to verify

consistency with the GALL Report. The staff verified whether the AMR line item of the different

component was applicable to the component under review. The staff verified whether the :

identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The staff

also determined whether the AMP identified by the applicant was consistent with the AMP

identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note E indicated that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified by

the GALL Report and whether the AMR was valid for the site-specific conditions.

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The staff conducted an audit and review of the information provided in the LRA, as documented

in its MPS audit and review report. The staff did not repeat its review of the matters described in

the GALL Report. However, the staff did verify that the material presented in the LRA was

applicable and that the applicant had identified the appropriate GALL Report AMRs. The staff

evaluation is discussed below.

3.4A.2.1.1 Loss of Material Due to Boric Acid Corrosion

In the discussion section of Table 3.4.1, Item 13, of the LRA, the applicant stated that loss of

material due to boric acid corrosion is managed by MPS AMP B2.1.3, "Boric Acid Corrosion' and

AMP B2.1.13, "General Condition Monitoring." The boric acid corrosion program includes

specific inspections of steam and power conversion and supporting systems components. The

boric acid corrosion program and the general condition monitoring program are evaluated in

Sections 3.0.3.1 and 3.0.3.2 of this SER respectively.

The LRA identifies a borated water leakage environment for various components in the steam

and power conversion and ESF systems and both the boric acid corrosion program and general

condition monitoring program are credited with managing loss of material from external surfaces.

The boric acid corrosion program described in LRA Section B2.1.3 appears to be limited to

components located inside containment, as addressed in NUREG-1801, Section XL.M10. In RAI

3.4-1, the applicant was requested to clarify why the boric acid corrosion program is credited for

managing boric acid corrosion in systems that are located outside containment. Also, in regard

to the effectiveness of the general condition monitoring program, the applicant was requested to

clarify:

i) How the program manages loss of material for components not normally

accessible.

ii) The basis of the inspection frequency (once per refueling outage) considering the

potential rate for material loss.

iii) What acceptance criteria and corrective actions are applied to the visual

indication of boric acid crystals without material degradation.

iv) How the program provides for promptly identifying the specific cause and location

of the borated water leakage.

In its response dated November 9, 2004, the applicant provided the following information:

The Boric Acid Corrosion Program provides requirements to adequately manage boric

acid related degradation of the reactor coolant system, ASME Class 1, 2 and 3

components, and associated or neighboring systems, structures, and components that

are in the scope of License Renewal. The requirements of the Millstone Boric Acid

Corrosion Program surpass the requirements listed in NUREG-1801, Section XL.M1O, in

that it is additionally applied to an identified boric acid system leak anywhere in the plant.

As part of the Aging Management Review process, the Boric Acid Corrosion Program,

along with the General Condition Monitoring Program, is credited for managing aging for

the external surface of equipment located in a building that contains a boric acid liquid

system (such as the Steam and Power Conversion system, the ESF system, and the

Radwaste Ventilation system).

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The General Condition Monitoring Program and the Boric Acid Corrosion Program are

both listed for various components in the steam and power conversion, ESF, and

radwaste ventilation systems because collectively they manage the loss of material for

the external surfaces of these components. The General Condition Monitoring Program

provides supplemental inspections to the Boric Acid Corrosion Program for managing

loss of material due to boric acid corrosion in systems that are located outside

containment, such as steam and power conversion, ESF, and radwaste ventilation

systems. Any instances of boric acid leakage identified during general condition

monitoring activities are entered into the corrective action program and evaluated using

the guidance of the Boric Acid Corrosion Program.

The effectiveness questions identified are addressed by the Boric Acid Corrosion

Program, not the General Condition Monitoring Program, since the Boric Acid Corrosion

Program provides the evaluation and corrective actions when any evidence of boric acid

leakage is identified. A more detailed answer is as follows:

i) Non-insulated components are examined by inspecting the accessible

external surfaces for direct and indirect evidence of leakage. For

components whose external surfaces are inaccessible for direct visual

examination, the surrounding areas (including equipment surfaces located

underneath the components) are examined for signs of leakage and other

areas are considered where leakage may be channeled.

The Boric Acid Corrosion Program recognizes that boric acid leaks can

travel down sloped piped or under insulation. Evidence of leakage can

also be determined for components with vertical surfaces of insulation by

examining the lowest elevation where the leakage may be detectable.

Horizontal surfaces of insulation can be examined at insulation joints.

When there is doubt as to a leak's origin, the evidence (i.e., accumulation

of boric acid crystals) needs to be preserved until an evaluation has been

performed to estimate the source, pathway, target and amount that may

be affected. This includes the removal of insulation to determine the leak

location.

For those areas identified as infrequently accessed areas, for the

purposes of detecting boric acid leakage, entry into the area is performed

often enough (at least once per refueling interval) to credit the inspections

in the General Condition Monitoring AMP and the Boric Acid Corrosion

AMP. The one exception is the Unit 3 demineralizer cubicles area.

However, for this area, a video inspection is performed at least once per

ten years to verify the integrity of the equipment. Based on operating

experience, there' is reasonable assurance that this inspection interval will

detect borated water leakage prior to the loss of intended function of the

affected equipment. ,

ii) The Millstone Boric Acid Corrosion Program examines locations

susceptible to boric acid leakage inside Containment during each refueling

outage. It is not practical to perform these examinations while the reactor

plant is operating.

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Any boric acid leakage identified by plant personnel is either corrected

prior to the end of the outage or is evaluated to ensure the intended

function is maintained until a repair can be performed. Dominion is aware

of the issues associated with boric acid corrosion, and the plant operating conditions that could be indicative of boric acid leakage. For potential boric

acid corrosion leakage, which may develop between refueling cycles, changes in plant parameters would provide indication that a potential leak

may exist. Both identified and unidentified leakage is strictly monitored

and trended for changes in sump level, flow rates, and frequency of pump operation. Changes in ambient conditions inside containment also provide indication of potential boric acid leakage.

Abnormal ambient conditions inside containment are documented through the corrective action process, which may require a shutdown of the reactor

plant in order to repair a leak inside containment. Plant operating experience indicates that boric acid inspections performed once per

refueling cycle are adequate to maintain the intended function of the

equipment in containment. Plant and industry operating experience indicates that a boric acid leak that starts during the operating cycle does

not damage the equipment to the point where it cannot perform its

intended function.

iii) In accordance with the Boric Acid Corrosion Program, any boric acid

leakage identified by plant personnel (including boric acid crystals without

material degradation) is documented through the corrective action process (10 CFR 50, Appendix B). Minor leakage may be just cleaned or, if

leakage is more severe, a Boric Acid Corrosion Program assessment of

the boric acid build-up is performed prior to clean-up. The leakage source,

path, and target areas are located, and corrective actions are

implemented as determined by the Boric Acid Corrosion Program. Corrective actions include timely repair of the leakage after detection to

prevent or mitigate the extent of boric acid corrosion. Where evaluations

are performed without repair or replacement, engineering analysis

reasonably assures that the intended function is maintained consistent

with the current licensing basis.

iv) The Boric Acid Corrosion Program provides for prompt identification of the

specific cause and location of borated water leakage.

See response in item iii above.

Accessible areas are traversed on a daily basis by plant personnel who

have been informed of expectations related to boric acid identification and

corrective action. Personnel are expected to attempt to identify the

leakage source as well as the extent of condition on secondary plant equipment. The Corrective Action Process triggers an investigation by the

Boric Acid Corrosion Program. Minor boric acid may be just cleaned, more

substantial leakage requires equipment to be repaired to stop the leak or

an engineering evaluation be performed to ensure the intended function of

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the equipment is maintained until such a time that the leak can be

repaired.

The staff reviewed the applicant's response and determined that the response was reasonable'

and acceptable because the applicant credits a combination of the general condition monitoring

program and the boric acid corrosion program to detect and evaluate borated water leakage and

boric acid corrosion to maintain the intended function of the auxiliary system components. For

areas outside containment, general equipment (or materials) frequent inspections are performed

as often as daily, which would identify any borated water leakage and any required subsequent

evaluation. In response to staff's request of RAI 3.3-B-1, the applicant committed to the following

clarification to the Unit 2 Appendix A UFSAR Supplement," Section A2.1.3, Boric Acid Corrosion,

Program Description and the Unit 3 Appendix A "FSAR Supplement," Section A2.1.2, Boric Acid

Corrosion, Program Description. (Refer to Section 3.3A for additional details.)

3.4A.2.1.2 Loss of Material Due to General Corrosion; Crack Initiation and Growth Due to Cyclic

Loading and/or Stress Corrosion Cracking

In the discussion section of Table 3.4.1, Item 8, of the LRA, the applicant stated that loss of

material due to general corrosion, crack initiation and growth due to cyclic loading and/or stress

corrosion cracking (SCC), for closure bolting in high-pressure or high-temperature systemscomponents, in the steam and power conversion systems are not subject to wetted conditions,

therefore, loss of material due to general corrosion is not expected. Additionally, cracking for

bolting in steam and power conversion systems is not identified as an aging effect requiring

management. However, SRP-LR Table 3.4-1 stipulates that the AMR evaluations consider crack

initiations and growth due to cyclic loading for components closure bolting in high pressure or hitemperature systems and that the applicant could manage the aging effects via GALL

AMP XI.M18, 'Bolting Integrity."

The applicant stated in the LRA, that SCC is an aging mechanism that requires the simultaneous

action of a corrosive environment, a sustained tensile stress, and a susceptibler'material.

Elimination of any one of these elements will eliminate the susceptibility to SCC. Further, the

applicant states that steam and power conversion systems bolting is fabricated to ASTM Al 94,

Grade B7 standard, is not high yield strength (>150 ksi), and is not subjected to adverse -

environment that could result in SCC. Therefore, cracking is not an aging effect requiring

management.

The staff noted that SCC could occur in corrosive environment and that the environment does

not have to be in a wetted condition. The staff questioned the applicant whether the good bolting

practices, bolting preload considerations, and 'proper sealant and lubricant, as stated in NUREG1339, are followed. By letter dated December 3, 2004, the applicant submitted its LRA

supplement. In its response, the applicant stated that it has developed a specific bolting integrity

aging management program that addresses degradation of bolting at MPS. The bolting integrity

program is addressed in Section 3.0.3.2.18 of this SER.

By supplement dated January 11, 2005, the applicant submitted its bolting aging management

roll-up item. In its response, the applicant replaces the existing information in the "Discussion"

column of LRA Table 3.4.1, Item 8 with "consistent with the NUREG-1 801." The staff reviewed

the applicant's response and the staff finds this acceptable because it is consistent with the

GALL Report.

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3.4A.2.1.3 Loss of Material Due to General (Carbon Steel Only) Pitting and Crevice Corrosion

In the discussion section of LRA Table 3.4.1, Item 10, the applicant stated that for components

in a treated water environment other than closed-cycle cooling water, loss of material is

managed by the chemistry control for secondary systems or the work control process.

The GALL Report identifies that further evaluation is required for components managed by water

chemistry program in the steam and power conversion system. During the audit and review, the

staff requested that the applicant provide clarification of how those components that are

managed by the chemistry control program do not require further evaluation.

By supplement dated November 9, 2004, the applicant stated that GALL Report, Item VIII.E.4-a,

which references GALL AMP XI.M2, 'Water Chemistry," should have been chosen for these

components, along with a Note D to indicate that the component is different than the component

described in the NUREG-1801. The further evaluation recommended, associated with GALL

Report Item VIII.E.4-a in LRA Table 3.4.1, Item 3.4.1-02, is addressed in LRA Section 3.4.2.2.2.

The applicant also stated in the LRA, that the effectiveness of AMP B2.1.6, "Chemistry Control

for Secondary Systems Program" is confirmed by AMP B2.1.25, "Work Control Process." The

work control process program provides the opportunity to visually inspect the internal surfaces of

components during preventive and corrective maintenance activities on an ongoing basis. The

work control process program provides input to the corrective action program if and when aging

effects are identified. The corrective action program evaluates the cause and extent of the

condition and, if required, recommends enhancements to ensure continued effectiveness of the

chemistry control for secondary systems program. The staff finds the applicant's response

acceptable and to be consistent with the GALL Report.

On the basis of its audit and review, the staff determined that for AMRs not requiring further

evaluation, as identified in the LRA Table 3.4.1 (Table 1), the applicant's references to the GALL

Report are acceptable and no further staff review is required.

Conclusion. The staff has evaluated the applicant's claim of consistency with GALL Report. The

staff also has reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff finds that the AMR results, which the applicant claimed to be consistent with the GALL

Report, are consistent with the AMRs in the GALL Report. Therefore, the staff finds that the

applicant has demonstrated that the effects of aging for these components will be adequately

managed so that their intended function(s) will be maintained consistent with the CLB for the

period of extended operation; as required by 10 CFR 54.21 (a)(3).

3.4A.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Apolication. In Section 3.4.2.2 of the LRA, the applicant

provides further evaluation of aging management as recommended by the GALL Report for

steam and power conversion system. The applicant provided information concerning how it will'

manage the following aging effects:

cumulative fatigue damage

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* toss of material due to general, pitting, and crevice corrosion

* loss of material due to general, pitting, and crevice corrosion, microbiologically influenced

corrosion, and biofouling

* general corrosion

* loss of material due to general, pitting, crevice, and microbiologically influenced corrosion

* quality assurance for aging management of non-safety-related components

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff reviewed the applicant's evaluation to determine whether it

adequately addressed the issues that were further evaluated. In addition, the staff audited the

applicant's further evaluations against the criteria contained in Section 3.4.2.2 of the Standard

Review Plan for License Renewal. Details of the staffs audit review are documented in the

staffs audit and review report.

The GALL Report indicates that further evaluation should be performed for the aging effects

described in the following sections of this SER.

3.4A.2.2.1 Cumulative Fatigue Damage

As stated in the SRP-LR, fatigue is a TLAA, as defined in 10 CFR 54.3. Applicants must

evaluate TLAAs in accordance with 10 CFR 54.21 (c)(1). Section 4.3 of this SER documents the

staffs review of the applicant's evaluation of this TLAA. In performing this review, the staff

followed the guidance in Section 4.3 of the SRP-LR.

3.4A.2.2.2 Loss of Material Due to General (Carbon Steel Only), Pitting, and Crevice Corrosion

In LRA Section 3.4.2.2.2, the applicant addressed loss of material due to general (carbon steel

only), pitting, and crevice corrosion that could occur in the carbon steel piping and fittings, valve

bodies and bonnets, pump casings, pump suction and discharge lines, tanks, tubesheets,

channel heads, and shells except for main steam system components and for loss of material

due to pitting and crevice corrosion for stainless steel tanks and heat exchanger/cooler tubes.

SRP-LR Section 3.4.2.2.2 states that management of loss of material due to general, pitting, and

crevice corrosion should be evaluated further.for carbon steel piping and fittings, valve bodies

and bonnets, pump casings, pump suction and discharge lines, tanks, tubesheets, channel

heads, and shells except for main steam system components and for loss of material due to

pitting and crevice corrosion for stainless steel tanks and heat exchanger/cooler tubes. The

water chemistry program relies on monitoring and control of water chemistry based on the

guidelines in EPRI guideline TR-1 02134 for secondary water chemistry to manage the effects of

loss of material due to general, pitting, or crevice corrosion. However, corrosion 'may occur at

locations of stagnant flow conditions. Therefore, the effectiveness of the chemistry control

program should be verified to ensure that corrosion is not occurring. The GALL Report

recommends further evaluation of programs to .manage loss of material due to general, pitting,

and crevice corrosion to verify the effectiveness of the water chemistry program. A one-time

inspection of select components and susceptible locations is an acceptable method to ensure

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that corrosion is not occurring and that the component's intended function will be maintained

during the period of extended operation.

The AMPs recommended by the GALL Report are GALL AMP XI.M2, "Water Chemistry," and

GALL AMP XL.M32, -One Time Inspection," for management of this aging effect.

The applicant stated in the LRA that the loss of material due to general corrosion, pitting, and

crevice corrosion in the steam and power conversion system components is managed by control

of water chemistry through MPS AMP B2.1.6, "Chemistry Control for Secondary Systems." The

applicant also stated that in lieu of a one-time inspection, MPS AMP B2.1.25, 'Work Control

Process," is used to provide confirmation of the effectiveness of the chemistry control for

secondary systems program. The work control process provides the opportunity to visually

inspect the internal surfaces of components during preventive and corrective maintenance

activities on an ongoing basis and provides input to the corrective action program if aging effects

are identified. The corrective action program would evaluate the cause and extent of the

condition and, if required, recommend enhancements to ensure continued effectiveness of the

chemistry control for secondary systems program.

The staff reviewed the chemistry control for secondary systems and its evaluation is

documented in Section 3.0.3.2.3 of this SER. In addition, in response to the staff's query

regarding the one-time inspection, the applicant stated that the work control process program

provides more opportunities for inspection of signs of aging than would a one-time inspection

program. In addition, it provides confirmation of chemistry control effectiveness on a continuing

basis, rather than a single point in time afforded by a one-time inspection program. The

applicant confirmed that indications of age-related degradation would be evaluated and the

extent of the condition be determined through the corrective action system. Enhancements to

water chemistry control programs and follow-up inspections would be initiated, as necessary, to

provide effective management of aging effects.

The staff reviewed the information provided in the LRA and concurs that the applicant's

approach is consistent with GALL AMP XI.M32, "One-time Inspection," which states: "An

alternate acceptable program may include routine maintenance or a review of repair records to

confirm that these components have been inspected for aging degradation and significant aging

degradation has not occurred and thereby verify the effectiveness of the existing AMPs." Also,

the staff reviewed operating experience associated with the work control process program as it

applied to the steam and power conversion system, specifically, the applicant's technical report

on work control inspection opportunities which provided the results of a plant-wide review of

maintenance history for a 10-year period. The staff finds that more than 50 work control related

inspection opportunities were listed against the steam and power conversion system, which the

staff found to be more than adequate to provide confirmation of the effectiveness of the

chemistry control for secondary systems program.

3.4A.2.2.3 Loss of Material Due to General, Pitting, and Crevice Corrosion, Microbiologically

Influenced Corrosion, and Biofouling

In LRA Section 3.4.2.2.3, the applicant addressed local loss of material due to general, pitting,

and crevice corrosion, MIC and biofouling that could occur in carbon steel piping and fittings for

untreated water from the backup water supply in the auxiliary feedwater system.

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SRP-LR Section 3.4.2.2.3 states that loss of material due to general corrosion, pitting and

crevice corrosion, MIC, and biofouling could occur in carbon steel piping and fittings for

untreated water from the backup water supply in the PWR auxiliary feedwater system. The:

GALL Report recommends further evaluation to ensure that these aging effects are adequately

managed. Acceptance criteria are described in Branch Technical Position RLSB-1 (Appendix

A.1, of the standard review plan).

The applicant stated in LRA Section 3.4.2.2.3 that the backup water supply for the auxiliary

feedwater system is the Unit 2 fire protection system. The backup water source is maintained

isolated from the auxiliary feedwater system by two normally closed valves. A tell-tale drain valve

between the two closed valves is left open to ensure that leakage past the closed valves can be

detected, thus ensuring that untreated water from the fire protection system does not enter the

auxiliary feedwater pumps suction piping. The applicant also stated that the backup water supply

piping and components were evaluated to be satisfactory for the effects of aging with the Unit 2

fire protection system.

During the audit and review, the staff reviewed Unit 2 piping and instrumentation diagram and

found that there was effective isolation to ensure that untreated water from the fire protection

system does not enter the auxiliary feedwater pumps suction piping.

Since the untreated water environment is isolated from the auxiliary feedwater pumps suction

piping, this aging effect is not applicable to auxiliary feedwater pumps suction piping. On this

basis, the staff concludes that not including this aging effect is acceptable.

3.4A.2.2.4 Loss of Material Due to General Corrosion

In LRA Section 3.4.2.2.4, the applicant addressed loss of material due to general corrosion that

could occur on the external surfaces of all carbon steel SCs, including closure boltings, exposed

to operating temperature less than 212*F.

SRP-LR Section 3.4.2.2.4 states that loss of material due to general corrosion could occur on

the external surfaces of all carbon steel SCs, including closure boltings, exposed to operating

temperature less than 212'F. The GALL Report recommends further evaluation to ensure that

this aging effect is adequately managed.

The applicant stated in the LRA that general corrosion is applicable to carbon steel, low-alloy

steel, and cast iron components in an air environment only when it is exposed to intermittent

wetting. The applicant also stated that loss of material due to general corrosion of external

surfaces is managed by MPS AMP B2.1.13, "General Condition Monitoring."

The staff reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.2 of this SER. On the basis of its review, the staff concludes that this program is

acceptable for managing loss of material since visual inspection of external surfaces is

performed during various walkdowns.

3.4A.2.2.5 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced

Corrosion -

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In LRA Section 3.4.2.2.5, the applicant addressed the loss of material due to general, pitting,

crevice and microbiologically influenced corrosion that could occur in the stainless steel and

carbon steel shells, tubes, and tubesheets within the bearing oil coolers (for steam turbine

pumps) in the auxiliary feedwater system and in the underground piping and fittings and

emergency condensate storage tank in the auxiliary feedwater system and the underground

condensate storage tank in the condensate system.

The applicant stated in LRA Sections 3.4.2.2.5.1 and 3.4.2.2.5.2 that the auxiliary feedwater

pumps are not equipped with oil coolers and that there are no underground, carbon steel

components associated with the auxiliary feedwater system, and therefore, this item is not

applicable.

SRP-LR Section 3.4.2.2.5 addresses loss of material due to general corrosion (carbon steel

only), pitting and crevice corrosion, and MIC which could occur in stainless steel and carbon

steel shells, tubes, and tubesheets within the bearing oil coolers (for steam turbine pumps) in the

auxiliary feedwater system. The GALL Report recommends further evaluation to ensure that

these aging effects are adequately managed.

SRP-LR 3.4.2.2.5 also addresses loss of material due to general corrosion, pitting and crevice

corrosion, and MIC, which could occur in underground piping and fittings and emergency

condensate storage tank in the auxiliary feedwater system and the underground condensate

storage tank in the condensate system.

On the basis that the auxiliary feedwater pumps are not equipped with oil coolers and that there

are no buried components in the steam and power conversion systems, the staff concurs with

the applicant and finds that this aging effect is not applicable.

3.4A.2.2.6 Quality Assurance for Aging Management of Non-Safety-Related Components

Section 3.0.4 of this SER provides the staffs evaluation of the applicant's quality assurance

program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL*

Report recommends further evaluation, the staff determines that (1) those attributes or features

for which the applicant claimed consistency with the GALL Report were indeed consistent and

(2) the applicant adequately addressed the issues that were further evaluated. The staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.4A.2.3 AMR Results That Are Not Consistent With or Not Addressed in the GALL

Report

Summary of Technical Information in the ADDlication. In Tables 3.4.2-1 through 3.4.2-12 of the

LRA, the staff reviewed additional details of the results of the AMRs for material, environment,

aging effect requiring management, and AMP combinations that are not evaluated in the GALL

Report or are not addressed in the GALL Report. The staff also reviewed additional systems and

components, provided by LRA supplement letters dated November 9, 2004; December 3, 2004;

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and the applicant's letter dated January11, 2005. In Tables 3.4.2-1 through 3.4.2-12, the

applicant indicated, via Notes F through J, that neither the identified component nor the material

and environment combination is evaluated in the GALL Report and provided information

concerning how the aging effect will be managed.

Staff Evaluation. For component type, material and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine whether

the applicant had demonstrated that the effects of aging will be adequately managed so that the -

intended function(s) will be maintained consistent with the CLB during the period of extended

operation.

The staff evaluation is discussed below.

3.4A.2.3.1 Main Steam - Aging Management Evaluation - Table 3.4.2-1 and 3.4.2-1a

The staff reviewed Table 3.4.2-1 of the LRA and Table 3 3.4.2-1a of the supplement dated

January 11, 2005, which summarized the results of AMR evaluations for the main steam system

component groups. -

In LRA Table 3.4.2-1, the applicant identified no aging effects for the following carbon steel, and

low alloy steel main steam component types exposed externally to air: condensing pots,

moisture separators/reheaters (shell), pipe, steam traps, strainers, turbine casings, valves. -

(atmospheric dumps and main steam safety/relief), and steam generator blowdown tank.

During the audit and review, the staff requested that the applicant provide clarification as to why

there are no aging effects for these components. The applicant stated that the steam and power

conversion systems components are normally operated at high temperatures (> 212 OF) and the

external surface of the component was determined to be dry. The applicant also stated that

these components are located inside buildings and because of the high operating temperature,

would not be subject to condensation. These components were determined not to be susceptible

to loss of material due to corrosion based on the dry environment, as described in LRA Appendix

C, Section C3.7.15. ; ,. -

The staff expressed concern regarding possible long-term shutdown such as the plant shutdown

in the 1990s. The applicant stated that the only potential source of wetting of the external

surfaces for these components, in a sheltered environment, is condensation. However,

intermittent wetting conditions would not be expected during out-of-service periods for these

components because for condensation to occur, the surface temperature of the components

would have to decrease below the dew point of the ambient environment. These normally high

temperature components are located in buildings with warm to hot temperatures and they are

insulated. Therefore, conditions for condensation are not expected even when the components

are out-of-service for long periods of time. -,.- -

Since the external surface temperature for these main steam system components is high

enough to preclude condensation and these components are not exposed to the intermittent

wetting, the staff finds there are no applicable aging effects for the above-mentioned

components. - l - -

3-391.
In LRA Table 3.4.2-1, the applicant also identified no aging effects for the following stainless

steel main steam component types exposed externally to air: expansion joints, flexible hoses,

flow elements, flow orifices, tubing, and valves.

On the basis of current industry research and operating experience, stainless steel exposed

externally to air are not susceptible to significant general corrosion that would affect the intended

function of components. Therefore, the staff finds that there are no applicable aging effects for

stainless steel components in an air environment.

In LRA Table 3.4.2-1, the applicant proposed to manage loss of material and cracking for the

following stainless steel main steam component types - expansion joints, flexible hoses, flow

elements, flow orifices, valves and tubing - exposed internally to treated water and steam using

AMP B2.1.6, 'Chemistry Control for Secondary Systems."

The applicant also proposed to manage cracking for the following stainless steel main steam

component types - quench tank heat exchangers (tubes and tubesheet) - exposed internally and

externally to treated water using AMP B2.13.6, "Chemistry Control for Secondary Systems" and.

AMP B2.1.7, 'Closed-cycle Cooling Water System." The staff reviewed the chemistry control for

secondary systems program and closed-cycle cooling water system program and its evaluation

of these programs is documented in Sections 3.0.3.2.3 and 3.0.3.2.4 of this SER, respectively.

The effectiveness of the chemistry control program is further provided by MPS AMP B2.1.25,

"Work Control Process," and is documented in Section 3.0.3.3.4 of this SER.

On the basis of its review, and because the effects of pitting and crevice corrosion on stainless

steel is not expected to be significant in treated water or steam, the staff finds that management

of loss of material for stainless steel components using the chemistry control for secondary

systems and closed-cycle cooling water system AMP is adequate.

The applicant stated in the LRA that stress corrosion cracking is an aging mechanism that

requires the simultaneous action of a corrosion environment, a sustained stress, and a

susceptible material. The applicant also stated that elimination of any one of these elements will

eliminate the susceptibility to stress corrosion cracking. The applicant credits MPS AMP B2.1.6,

"Chemistry Control for Secondary Systems," to manage this aging mechanism since it removed

one of the three required actions.

Since the chemistry control program for secondary systems maintains a controlled environment

with low contaminant concentration and the applicant's operating experience has shown this

program to be effective for the management of cracking due to stress corrosion cracking, the

staff finds that management of stress corrosion cracking for stainless steel components using

chemistry control for secondary systems is adequate.

In LRA Table 3.4.2-1, the applicant proposed to manage loss of material for carbon steel main

steam component type - silencers - exposed internally to air, with MPS AMP B2.1.25, "Work

Control Process."

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The work control process provides the opportunity to visually

inspect the internal surfaces of components during preventive and corrective maintenance

activities on an ongoing basis. The work control process provides input to the corrective action

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program if aging effects are identified. On the basis of its review, the staff finds the work control

process program acceptable for managing the aging effect of loss of material for the carbon

steel silencer.

3.4A.2.3.2 Extraction Steam - Aging Management Evaluation - Table 3.4.2-2

The staff reviewed Table 3.4.2-2 of the LRA, which summarized the results of AMR evaluations

in the SRP-LR for the extraction steam system component groups.,

In Unit 2 LRA Table 3.4.2-2, the applicant proposed to manage loss of material and cracking for

the following stainless steel extraction steam system component types - expansion joints, and

tubing - exposed internally to steam, using AMP B2.1.6, 'Chemistry Control for Secondary

Systems."

The material, environment,'aging effects, and aging management program (MEAP) for

extraction steam components is the same as that for the main steam components. Since both

have the same MEAP combination, the staff finds that management of loss of material and

cracking for stainless steel components using the chemistry control for secondary systems

program to be adequate. The staff reviewed the chemistry control for secondary systems

program and its evaluation is documented in Section 3.0.3.2.3 of this SER.

The applicant identified no aging effects for the following carbon low-alloy steel extraction steam

system component types - pipe, steam traps, strainers, and valves - exposed externally to air.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these carbon low-alloy steel components

exposed externally to air. The staff's evaluation is documented in Section 3.4A.2.3.1 of this SER.

3.4A.2.3.3 Feedwater - Aging Management Evaluation - Table 3.4.2-3

The staff reviewed LRA Table 3.4.2-3, which summarized the results of AMR evaluations for the

feedwater system component groups.

In Unit 2 LRA Table 3.4.2-3, the applicant proposed to manage loss of material and cracking for

the following stainless steel feedwater system component types - flow elements, flow orifices,

and tubing - exposed internally to steam using AMP B2.1.6, "Chemistry Control for Secondary

Systems."

The material, environment, aging effects, and aging management program (MEAP) for

feedwater components is the same as that forthe main steam components. Since both have the

same MEAP combination, the staff finds that management of loss of material and cracking for

stainless steel components using the chemistry control for secondary systems program to be

adequate. The staff reviewed the chemistry control for secondary systems program and its

evaluation is documented in Section 3.0.3.2.3 of this SER.

In Unit 2 LRA Table 3.4.2-3, the applicant proposed to manage loss of material for the carbon

steel feedwater system pumps exposed internally to treated water using MPS AMP B2.1.6,

"Chemistry Control for Secondary Systems" and MPS AMP B2.1.25, "Work Control Process."

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The GALL Report recommends GALL AMP XI.M2, "Water Chemistry," to be augmented by verifying the effectiveness of water chemistry control by a supplementary program. GALL AMP XI.M32, "One-Time Inspection' is an acceptable verification program.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The effectiveness of the chemistry control program is provided further by MPS AMP B2.1.25, "Work Control Process," and is documented in Section 3.0.3.3.4

of this SER. The staff determined that the applicant's work control process program is an

acceptable alternate inspection program for this component to manage the aging effects.

The applicant identified no aging effects for the following carbon steel feedwater system

component types exposed externally to air: heaters (feedwater heater channel head), and

heaters (feedwater heater shell).

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these carbon steel components exposed externally to air. The staff's evaluation is documented in Section 3.4A.2.3.1 of this SER.

3.4A.2.3.4 Condensate - Aging Management Evaluation - Table 3.4.24

The staff reviewed LRA Table 3.4.2-4, which summarized the results of AMR evaluations for the

condensate system component groups.

In LRA Table 3.4.2-4, the AMR for rubber expansion joints is reviewed by the staff and its

evaluation is documented in Section 3 of this SER.

In LRA Table 3.4.2-4, the applicant identified no aging effects for the following stainless

steel/carbon steel/low-alloy steel/cast iron condensate system component types exposed externally to air flow elements, flow orifices, tubing, condensers (main condenser shell), drain

coolers (channel head), drain coolers (shell), heat exchanger steam jet air ejectors (shell),

heaters (feedwater heater channel head), heaters (feedwater heater shell), pipe, steam packing exhauster (channel head), steam packing exhauster (shell), valves, and pumps.

On the basis that these have the same previously discussed MEAP combination as the main

steam components, the staff finds that there are no aging effects for these stainless steel/carbon

steel/low-alloy steel/cast iron components exposed externally to air. The staff's evaluation is

documented in Section 3.4A.2.3.1 of this SER.

In LRA Table 3.4.2-4, the applicant proposed to manage loss of material and cracking for

stainless steel condensate system component types - flow elements, flow orifices, and tubing - exposed internally to treated water using AMP B2.1.6, "Chemistry Control for Secondary Systems."

The material, environment, aging effects, and aging management program (MEAP) for

condensate components is the same as that for the main steam components. Since both have;

the same MEAP combination, the staff finds that management of loss of material and cracking

for stainless steel components using the chemistry control for secondary systems program to be

adequate. The staff reviewed the chemistry control for secondary systems program and its

evaluation is documented in Section 3.0.3.2.3 of this SER.

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The LRA Table 3.4.2-4 credits the AMP B2.1.25, "Work Control Process," to manage the change

in material properties and cracking of rubber in various expansion joints in a treated water

environment. The applicant has identified no aging effect for these expansion joints in an

external air environment. The work control process AMP described in LRA Section B2.1.25 does

not identify specific criteria unique to managing rubber expansion joints, and it is not clear how

external visual inspections will manage internal degradation. In RAI 3.4-3 the staff requested the

applicant to clarify how visual inspection of the external surfaces of the expansion joints is

adequate to detect internal cracking prior to loss of the component pressure boundary function.

In addition to visual inspections, the applicant was requested to clarify if other testing methods

will be used, such as hardness testing to determine change of material properties. The applicant

was also requested to Identify any operating experience pertaining to rubber expansion joint

inspections to demonstrate the effectiveness of the work control process program to manage

cracking and change in material properties in rubber expansion joints exposed to treated water

and external air.

In its response dated November 9, 2004, the applicant stated:

There are no external aging effects applicable to these expansion joints. In addition,

there are no external visual inspections credited for management of internal aging

effects of the expansion joints. The Work Control Process aging management of internal

aging referenced in LRA Table 3.4.2-4 for these expansion joints uses internal

inspections to detect signs of aging as described in LRA Appendix B Section B2.1.25.

Maintenance activities performed in accordance with the Work Control Process provide

opportunities to visually inspect the internal surfaces of these components.

Internal cracking and change of material properties for these elastomer components are

visually observable by such conditions as evidence of cracking and crazing, discoloration,

distortion, evidence of swelling, tackiness, evaluation of resiliency and indentation

recovery, etc.

Millstone Unit 2 commitment item 25 (and commitment item 26 for Millstone Unit 3)

identified in LRA Appendix A, Table A6.0-1, provides for changes to maintenance and

work control procedures to ensure inspections are appropriately and consistently

performed.

A review of operating experience associated with these expansion joints indicates that

degradation is observable through the Work Control Process activities. Conditions

such as cracking and swelling have been noted resulting in replacement of the affected

expansion joints.

Therefore, the Work Control Process manages the internal aging effects of the

expansion joints to provide reasonable assurance that the intended function will be

maintained.

The staff finds the applicant's response reasonable and acceptable, because the applicant has

committed to make changes to maintenance and work control procedures to ensure inspections

are appropriately and consistently performed to detect degradation prior to loss of component

function.

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3.4A.2.3.5 Condensate Storage and Transfer - Aging Management Evaluation - Table 3.4.2-5

The staff reviewed LRA Table 3.4.2-5, which summarized the results of AMR evaluations for the

condensate storage and transfer system component groups.

In LRA Table 3.4.2-5, the AMR for the carbon steel and low alloy steel condensate storage tank

and the stainless steel rupture disks exposed internally to gas is reviewed the staff and its

evaluation is documented in Section 3 of this SER.

In LRA Table 3.4.2-5, the AMR for the stainless steel rupture disks exposed externally to

atmospheretweather is reviewed by the staff and its evaluation is documented in Section 3 of

this SER.

In LRA Table 3.4.2-5, the applicant identified no aging effects for stainless tubing exposed

externally to air.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for this stainless component exposed externally to

air. The staff's evaluation is documented in Section 3.4A.2.3.1 of this SER.

In LRA Table 3.4.2-5, the applicant proposed to manage loss of material for carbon steel and

low-alloy steel pipe exposed externally to an atmosphere/weather environment with MPS AMP

B2.1.13, uGeneral Condition Monitoring."

The staff reviewed the general condition monitoring program and its evaluation is documented in

3.0.3.3.2. The staff finds that this program is acceptable for managing loss of material since

visual inspection of external surfaces is performed during various walkdowns.

3.4A.2.3.6 Condensate Demin Mixed Bed - Aging Management Evaluation - Table 3.4.2-6

The staff reviewed LRA Table 3.4.2-6, which summarized the results of AMR evaluations for the

condensate demin mixed bed system component groups.

In LRA Table 3.4.2-6, the applicant identified no aging effects for stainless steel tubing exposed

externally to air.

On the basis that these components have the same previously discussed MEAP combination,

the project teams finds that there are no aging effects for this stainless component exposed

externally to air. Its evaluation is documented in Section 3.4A.2.3.1 of this SER.

3.4A.2.3.7 Auxiliary Feedwater - Aging Management Evaluation - Table 3.4.2-7

The staff reviewed LRA Table 3.4.2-7, which summarized the results of AMR evaluations for the

auxiliary feedwater system component groups.

In the LRA Table 3.4.2-7, the applicant identified no aging effects for the following stainless

steel/carbon steel/low-alloy steel auxiliary feedwater system component types exposed

externally to air flow elements, flow orifices, tubing, and turbine casing.

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On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless steel/carbon steel/low-alloy steel

component exposed externally to air. The staff's evaluation is documented in Section 3.4A.2.3.1

of this SER. -

In LRA Table 3.4.2-7, the applicant proposed to manage loss material for the carbon steel and

low-alloy steel turbine casing exposed internally to treated water and steam environment using

AMP B2.1.6, "Chemistry Control for Secondary Systems" and AMP B2.1.25, 'Work Control

Process."

The staff reviewed the chemistry control for secondary systems program and the work control

process and its evaluation is documented in Sections 3.0.3.2.3 and 3.0.3.3.4 of this SER,

respectively. The chemistry control program purposes to provide reasonable assurance that

water quality is compatible with the materials of construction in the plant systems and equipment

in order to minimize loss of material. The work control process ensures effectiveness of the:

water chemistry control for secondary systems. On this basis, the staff finds that management of

loss of material for this component is adequate.

3.4A.2.3.8 Feedwater Heater Vents and Drains - Aging Management Evaluation - Table 3.4.2-8

The staff reviewed LRA Table 3.4.2-8, which summarized the results of AMR evaluations for the

feedwater heater vents and drains system component groups.

In LRA Table 3.4.2-8, the applicant proposed to manage cracking for stainless steel feedwater

heater vents and drains system component types - expansion joints, flow elements, flow orifices,

restricting orifices, tubing, and valves - exposed internally to a treated water and steam

environment using AMP B2.1.6, 'Chemistry Control for Secondary Systems Program."

The MEAP for feedwater heater vents and drains components is the same as that for the main

steam components. Since both have the same MEAP combination, the staff finds that

management of loss of material and cracking for stainless steel components using chemistry

control for secondary systems program is adequate. The staff's evaluation is documented in

Section 3.4A.2.3.1 of this SER.

In LRA Table 3.4.2-8, the applicant identified no aging effects for the following stainless

steel/carbon steel/low-alloy steel feedwater heater vents and drains system component types -

condensing pots, expansion joints, flow elements, flow orifices, heater drains tank, level

indicators, pipe, pumps, restricting orifices, tubing, and valves - exposed externally to air.

On the basis that these components have the same previously discussed MEAP combination,

the project teams finds that there are no aging effects for these stainless steel/carbon

steel/ow-alloy steel components exposed externally to air. The staff's evaluation is documented

in Section 3.4.2.3.1 of this SER.

In LRA Table 3.4.2-8, the applicant proposed to manage loss of material for the copper alloy

gland seal coolers (coils) exposed internally and externally to a treated water environment using

AMP B2.1.6, "Chemistry Control for Secondary Systems," and AMP B2.1.25, "Work Control

Process."

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The staff reviewed the chemistry control for secondary systems program and the work control

process and its evaluation is documented in Sections 3.0.3.2.3 and 3.0.3.3.4 of this SER,

respectively. The chemistry control program purposes to provide reasonable assurance that

water quality is compatible with the materials of construction in the plant systems and equipment

in order to minimize loss of material. The work control process ensures effectiveness of the

water chemistry control for secondary systems and provides opportunity to inspect the outside

surface of the cooler coils. On this basis, the staff finds that management of loss of material for

this component is adequate.

3.4A.2.3.9 Moisture Separation and Reheat - Aging Management Evaluation - Table 3.4.2-9

The staff reviewed LRA Table 3.4.2-9, which summarized the results of AMR evaluations for the

moisture separation and reheat system component groups.

In LRA Table 3.4.2-9, the applicant proposed to manage loss of material/cracking for stainless'

steel moisture separation and reheat system component types - condensing pots, drains pots,

flow elements, and tubing - exposed internally to treated water and steam environment using

MPS AMP B2.1.6, 'Chemistry Control for Secondary Systems."

The MEAP for moisture separation and reheat components is the same as that for the main

steam components. Since both have the same MEAP combination, the staff finds that

management of loss of material and cracking for stainless steel components using the chemistry

control for secondary systems program to be adequate. The staffs evaluation is documented in

Section 3.4A.2.3.1 of this SER.

In LRA Table 3.4.2-9, the applicant identified no aging effects for stainless steel/carbon

steel/low-alloy steel moisture separation and reheat system component types exposed externally

to air condensing pots, drains pots, drain tanks, flow elements, tubing, and valves.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless steel/carbon steel/low-alloy steel

components exposed externally to air. The staffs evaluation is documented in Section 3.4.2.3.1

of this SER.

3.4A.2.3.10 Plant Heating and Condensate Recovery - Aging Management Evaluation -

Table 3.4.2-10

The staff reviewed LRA Table 3.4.2-10, which summarized the results of AMR evaluations for

the plant heating and condensate recovery system component groups.

In LRA Table 3.4.2-10, the applicant proposed to manage loss of material for copper alloys plant

heating and condensate recovery system component types - heating and ventilation Units(coils),

and heating coils - exposed internally to a steam environment using AMP B2.1.6, 'Chemistry

Control for Secondary Systems."

The staff reviewed the chemistry control for secondary systems program and its evaluation is

documented in Section 3.0.3.2.3 of this SER. The chemistry control program purposes to -

provide reasonable assurance that water quality is compatible with the materials of construction

in the plant systems and equipment in order to minimize loss of material. The work control

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process ensures effectiveness of the water chemistry control for secondary systems. On this

basis, the staff finds that management of loss of material for this component is adequate.

In LRA Table 3.4.2-10, the applicant proposed to manage loss of material for the copper alloys

plant heating and condensate recovery system sample coolers (tubes) exposed internally and

externally to a treated water environment using AMP B2.1.25, "Work Control Process" and AMP

B2.1.7, "Closed-cycle Cooling Water System."

The staff reviewed the work control process program and the closed-cycle cooling water system

program. Its evaluation of these programs is documented in Sections 3.0.3.3.4 and 3.0.3.2.4 of

this SER, respectively. The closed-cooling water system program monitors chemical parameters

and provides inspection to further verify the chemistry control. The work control process program

performs maintenance activities to provide visual inspection and tracks the performance of

inspection and surveillance activities. On this basis, the staff finds that the management of loss

material for these components is adequate.

In LRA Table 3.4.2-10, the applicant proposed to manage loss of material for carbon steel and

low-alloy steel plant heating and condensate recovery system type components - pipe, reservoir,

and steam traps - exposed externally to the atmosphere/weather environment using MPS AMP

B2.1.13, 'General Condition Monitoring."

The staff reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.2 of this SER. The staff finds that this program is acceptable for managing loss

of material since visual inspection of external surfaces is performed during various walkdowns.

In the LRA Table 3.4.2-10, the applicant proposed to manage cracking for the stainless steel

tubing exposed internally to a treated water and steam environment using MPS AMP B2.1.6,

"Chemistry Control for Secondary Systems."

The material, environment, aging effects, and aging management program (MEAP) for plant

heating and condensate recovery components is the same as that for the main steam

components. Since both have the same MEAP combination, the staff finds that the management

of cracking for stainless steel components using chemistry control for secondary systems

program to be adequate. The staff's evaluation is documented in Section 3.4A.2.3.1 of this SER.

In LRA Table 3.4.2-1 0, the applicant identified no aging effects for the following stainless

steel/carbon steel/low-alloy plant heating and condensate recovery system component types -

pipe, sample traps, strainers, tubing and valves - exposed externally to air.

On the basis that these components have the same previously discussed MEAP combination,

the project teams finds that there are no aging effects for these steel/carbon steel/low-alloy

components exposed externally to air. The staffs evaluation is documented in Section 3.4.2.3.1

of this SER.

3.4A.2.3.11 Secondary Chemical Feed - Aging Management Evaluation - Table 3.4.2-11

The staff reviewed LRA Table 3.4.2-1, which summarized the results of AMR evaluations for the

secondary chemical feed system component groups.

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In LRA Table 3.4.2-11, the applicant proposed to manage cracking for stainless steel secondary

chemical feed system type components - tubing and valves - exposed internally to a treated

water environment using AMP 2.1.6, "Chemistry Control for Secondary Systems."

The material, environment, aging effects, and aging management program (MEAP) for

secondary chemical feed components is the same as that for the main steam components.

Since both have the same MEAP combination, the staff finds that management of cracking for

stainless steel components using the chemistry control for secondary systems program to be

adequate. The project team's evaluation is documented in Section 3.4A.2.3.1 of this SER.

In LRA Table 3.4.2-11, the applicant identified no aging effects for stainless steel secondary

chemical feed system type components - tubing and valves - exposed externally to air.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless steel components exposed

externally to air. The staff's evaluation is documented in Section 3.4A.2.3.1 of this SER.

3.4A.2.3.12 Turbine Gland Sealing - Aging Management Evaluation - Table 3.4.2-12

The staff reviewed LRA Table 3.4.2-12, which summarized the results of AMR evaluations for

the turbine gland sealing system component groups.

In LRA Table 3.4.2-12, the applicant identified no aging effects for the following stainless

steel/carbon steel/low-alloy steel turbine gland sealing system type components - flow orifices,

pipe, tubing, valves, and water pot - exposed externally to air.

On the basis that these components have the same previously discussed MEAP combination,

the project teams finds that there are no aging effects for these stainless steel/carbon

steel/low-alloy steel components exposed externally to air. The staff's evaluation is documented

in Section 3.4A.2.3.1 of this SER.

In LRA Table 3.4.2-12, the applicant proposed to manage cracking and loss of material for

stainless steel turbine gland sealing system type components - flow orifices, tubing, and valves -

exposed internally to a steam environment using AMP B2.1.6, "Chemistry Control for Secondary

Systems."

The material, environment, aging effects, and aging management program (MEAP) for turbine

gland sealing components is the same as that for the main steam components. Since both have

the same MEAP combination, the staff finds that management of cracking and loss of material

for stainless steel components using the chemistry control for secondary systems program to be

adequate. The staff reviewed the chemistry control for secondary systems program and its

evaluation is documented in Section 3.0.3.2.3 of this SER.

3.4A.2.3.13 Table 5: Steam and Power Conversion System - Auxiliary Steam Reboiler and

Deaerating Feedwater - Aging Management Evaluation

In the LRA supplement letter of November 9, 2004, the applicant identified no aging effects for

carbon steel and low-alloy steel exposed to an air environment for the auxiliary steam feedwater

surge tank, pipe, and valve component types.

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On the basis of current industry research and operating experience, carbon steel and low-alloy

steel exposed air are not susceptible to significant general corrosion that would affect the

intended function of components. Therefore, the staff finds that there are no applicable aging

effects for carbon steel and low-alloy steel components in an air environment.

3.4A.2.3.14 Table 6: Steam and Power Conversion System - Exciter Air Cooler - Aging

Management Evaluation

In the LRA supplement letter of November 9, 2004, the applicant stated that loss of material of

main transfomer and generator isophase bus duct cooling exchangers (coils) of copper alloys

exposed to air and treated water environment in the exciter air cooler system is managed using

AMP B.2.1.25, "Work Control Process."

The staff reviewed the work control process and its evaluation is documented in Section

3.0.3.3.4 of this SER. The work control process program performs maintenance activities to

provide visual inspection and tracks the performance of inspection and surveillance activities. On

this basis, the project team finds that the management of loss material for these components is

adequate.

3.4A.2.3.15 Table 7: Steam and Power Conversion System - Stator Liquid Cooler- Aging

Management Evaluation

In the LRA supplement letter of November 9, 2004, the applicant stated that loss of material of

tubing and valve of stainless steel exposed to moisture-laden air or intermittent wetted

environment in the stator liquid cooler is managed using AMP B.2.1.13, 'General Condition

Monitoring."

The staff reviewed the general condition monitoring and its evaluation is documented in Section

3.0.3.3.2 of this SER. The staff finds that this program is acceptable for managing loss of

material since visual inspection of external surfaces is performed during various walkdowns.

3.4A.2.3.16 Table 8: Steam and Power Conversion System - Turbine Lube Oil- Aging

Management Evaluation

In the LRA supplement dated November 9, 2004, the applicant identified no aging effects for

stainless steel exposed to air, including pipe, tubing, and valve component types.

On the basis of current industry research and operating experience, stainless steel exposed

externally to air are not susceptible to significant general corrosion that would affect the intended

function of components. Therefore, the staff finds that there are no applicable aging effects for

stainless steel components in an air environment.

In the LRA supplement dated November 9, 2004, the applicant stated that cracking of pipe,

tubing and valves of stainless steel exposed to oil environment in the turbine lube oil is managed

using AMP B.2.1.25, !Work Control Process." ;

The staff reviewed the work control process and its evaluation is documented in Section

3.0.3.3.4 of this report. The work control process program performs maintenance activities to

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provide visual inspection and tracks the performance of inspection and surveillance activities. On

this basis, the staff finds that the management of cracking for these components is adequate.

All other AMRs assigned in Tables 3.4.2-1 through 3.4.2-12 of the LRA the LRA supplements

were evaluated. The staff finds them to be acceptable.

Conclusion. On the basis of its review, the staff finds that the applicant appropriately evaluated

AMR results involving material, environment, aging effect requiring management, and AMP

combinations that are not evaluated in the GALL Report. The staff finds that the applicant has

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3).

3.4A.3 Conclusion

On the basis of its review, the staff concludes that the applicant has demonstrated that the aging

effects associated with the steam and power conversion components will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the period

of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable FSAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the steam and power

conversion, as required by 10 CFR 54.21(d).

3.4B Unit 3 Aging Mananement of Steam and Power Conversion System

This section of the SER documents the staff's review of the applicant's AMR results for the

Unit 3 steam and power conversion components and component groups associated with the

following systems:

* main steam system

* feedwater system

* condensate make-up and draw-off system

* steam generator blowdown system

* auxiliary feedwater system

* auxiliary steam system

* auxiliary boiler condensate and feedwater system

* hot water heating system

* hot water pre-heating system

* steam generator chemical addition system

* turbine plant miscellaneous drains system

3.4B.1 Summary of Technical Information In the Application

In LRA Section 3.4,-the applicant provided AMR results for steam and power conversion system

components and component groups. In LRA Table 3.4.1, "Summary of Aging Management

Evaluations in Chapter Vil of NUREG-1801 for Steam and Power Conversion System," the

applicant provided a summary comparison of its AMRs with the'AMRs evaluated in the GALL

Report for the steam and power conversion system components and component groups.

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The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs.:The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report. .

3.4B.2 Staff Evaluation

The staff reviewed LRA Section 3.4 to determine if the applicant provided sufficient information

to demonstrate that the effects of aging for the steam and power conversion system

components that are within the scope of license renewal and subject to an AMR will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

Also, the staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report. However, the staff did verify that the material presented

in the LRA was applicable and that the applicant had identified the appropriate GALL AMPs. The

staff's evaluations of the AMPs are documented in Section 3.0.3 of this SER. Detail of the staffs

audit evaluation are documented in the staffs MPS audit and review report and summarized in

Section 3.4B.2.1 of this SER.

The staff also performed an audit of those AMRs that were consistent with the GALL Report and

for which further evaluation is recommended. The staff verified that the applicant's further

evaluations were consistent with the acceptance criteria in Section 3.4.2.2 of NUREG-1 800,

"Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants,"-

dated July 2001. The staffs audit evaluations are documented in the staffs MPS audit and

review report and summarized in Section 3.4B.2.2 of this SER.

The staff performed an onsite audit and conducted a technical review of the remaining AMRs

that were not consistent with or not addressed in the GALL Report. The audit and technical

review included evaluating whether all plausible aging effects were identified and the aging effects listed were appropriate for the combination of materials and environments specified. The

staff's audit evaluations are documented in the staffs MPS audit and review report and

summarized in Section 3.4B.2.3 of this SER.

Finally, the staff reviewed the AMP summary descriptions in the FSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the steam and power conversion system components.

Table 3.4B-1 below provides a summary of the staffs evaluation of components, aging

effects/mechanisms, and AMPs listed in LRA Section 3.4 that are addressed in the GALL

Report.

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Table 3.4B-1 Staff Evaluation for Steam and Power Conversion System in the GALL

Report I ,

Component u . ---;Aging .- Effect 1-- , -. AMP In GALL- ' AMP ''1Staff inLRA ' '.~'- EVa''ation

Mechnm . .Report..~.~.7

Piping and fittings in Cumulative fatigue TLAA, evaluated TLAA This TLAA Is

main feedwater line, damage in accordance with evaluated in Section

steam line, and 10 CFR 54.21 (c) 4.3B, Metal Fatigue

auxiliary feedwater

(AFW) piping (PWR

only)

(Item Number

3.4.1-01) . .

Piping and fittings, Loss of material due Water chemistry Chemistry control for Consistent with

valve bodies and to general (carbon and one-time secondary systems GALL, which

bonnets, pump steel only), pitting, inspection program (B2.1.6); recommends further

casings, tanks, and crevice Work control process evaluation (See . ,

tubes, tubesheets, corrosion (B2.1.25) Section 3.4B.2.2.2)

channel head, and

shell (except main

steam system) (Item

Number 3.4.1-02) .

AFW piping Loss of material due Plant-specific Not applicable (See

(Item Number to general, pitting, Section 3.4B.2.2.3)

3.4.1-03) and crevice

corrosion, MIC and

biofouling

Oil coolers in AFW Loss of material due Plant-specific Work control process Consistent with

system (lubricating to general (carbon (B2.1.25) GALL, which. .

oil side possibly steel only), pitting, recommends further

contaminated with and crevice evaluation (See

water) corrosion, and MIC Section 3.4B.2.2.5)

(Item Number

3.4.1-04) .

External surface of Loss of material due Plant-specific General condition Consistent with

carbon steel to general corrosion monitoring (82.1.13) GALL, which,:;

components recommends further

(Item Number evaluation (See

3.4.1-05) Section 3AB.2.2.4)

Carbon steel piping Wall-thinning due to Flow-accelerated Flow-accelerated Consistent with

and valve bodies Flow-accelerated corrosion corrosion (B2.1.1 1) GALL, which

(Item Number corrosion recommends no

3.4.1-06) further evaluation

(See Section

. 3.4B.2.1) . ..

Carbon steel piping Loss of material due Water chemistry Chemistry control for Consistent with

and valve bodies in to pitting and secondary systems GALL, which

main steam system crevice corrosion program (B2.1.6) recommends no

(Item Number further evaluation

3.4.1-07) (See Section

3.4B.2.1)

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-Component Groupi ;- KingEffectIKn -: i ' GE -. inAMPLR ; St f i uion . -^'a; -- ** : ' - -ehnim ,- . - 6 t , . .

Closure bolting in Loss of material due Bolting integrity Baiting Integrity Consistent with

high-pressure or to general GALL (See Section

high-temperature corrosion; crack 3.4B12.1.2)

systems Initiation and growth

(Item Number due to cyclic loading

3.4.1-08) and/or SCC

Heat exchangers Loss of material due Open-cycle Work control process Not applicable (See'

and to general (carbon cooling water (B2.1.25) Section 3.4B.2.1.3) coolers/condensers steel only), pitting, system

by open-cycle and crevice

cooling water corrosion, MIC and

(Item Number biofouling; buildup 3.4.1-9) of deposit due to

biofouling

Heat exchangers Loss of material due Closed-cycle Closed-cycle cooling Consistent with

and to general (carbon cooling water water system (B2.1.7) GALL, which''

coolers/condensers steel only), pitting, system recommends no

by closed-cycle and crevice further evaluation

cooling water corrosion (See Section

(Item Number 3.41B.2.1 A)

3.4.1-10)

External surface of Loss of material due Aboveground Tank Inspection Consistent with

aboveground to general (carbon carbon steel tanks Program (B2.1.24) GALL, which

condensate storage steel only), pitting, recommends no

tank and crevice further evaluation

(Item Number corrosion (See Section

3.4.1-11) i . 3AB.2.1)

External surface of Loss of material due Buried piping and Not applicable (See

buried condensate to general, pitting, tanks surveillance Section 3.4B.2.2.5)

storage tank and and crevice

AFW piping corrosion, and MIC

(Item Number or

3.4.1-12)

Buried piping and

tanks inspection

External surface of Loss of material due' Boric acid" ' Boric acid corrosion Consistent with

carbon steel to boric acid corrosion - . (B2.1.3); General GALL (See Sections

components corrosion condition monitoring 3.4B.2.1.1) (Item Number (B2.1.13) 3.4.1-13)

The staffs review of the MPS steam and power.conversion system'and associated components

followed one of several approaches. One approach, documented in Section 3.4B.2.1, involves

the staffs review of the AMR results for components in the steam and power conversion system

that the applicant indicated are consistent with the GALL Report and do not require further

evaluation. Another approach,'documented in'Section 3.4B.2.2, involves the staffs review of the

AMR results for components' in the' steam arid 'power 'conversion system that the applicant

indicated are consistent with the GALL Report and for which further. evaluation'is recommended.

A third approach,-documented in Section 3.4B.2.3,jinvolves the staffs'review of the AMR results

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for components in the steam and power conversion system that the applicant indicated'are not

consistent with the GALL Report or are not addressed in the GALL Report. The staff's review of

AMPs that are credited to manage or monitor aging effects of the steam and power conversion

system components is documented in Section 3.0.3 of this SER.

3.4B.2.1 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Not Recommended

Summary of Technical Infomrnition in the Application. In Section 3.4.2.1 of the LRA, the applicant identified the materials, environments, and aging effects requiring management. The applicant identified the following programs that manage the aging effects related to the steam and power conversion system components:

* boric acid corrosion program

* buried pipe inspection program

* chemistry control for secondary systems program

* closed-cycle cooling water system program

* flow-accelerated corrosion program * general condition monitoring program

* tank inspection program

* work control process program

* bolting integrity program

Staff Evaluation. In Tables 3.4.2-1 through 3.4.2-11 of the LRA, the applicant provided a

summary of AMRs for the main feedwater, main steam, auxiliary feedwater, and blowdown

system components and identified which AMRs it considered to be consistent with the GALL

Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not 'recommend further.

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes described how the information

in the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicated the AMR was consistent with the GALL Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component,- material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicated that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP takes some exceptions to the AMP

identified in the GALL Report. The staff audited these line items to'verify consistency with the

GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by the

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applicant was consistent with the AMP identified in the GALL Report and whether the AMR was

valid for the site-specific conditions.

Note C indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP is consistent

with the AMP identified by the GALL Report. This note indicates that the applicant was unable to

find a listing of some system components in the GALL Report. However, the applicant identified

a different component in the GALL Report that had the same material, environment, aging

effect, and AMP as the component that was under review. The staff audited these line items to

verify consistency with the GALL Report. The staff also determined whether the AMR line item of

the different component was applicable to the component under review and whether the AMR

was valid for the site-specific conditions.

Note D indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP takes some

exceptions to the AMP identified in the GALL Report. The staff audited these line items to verify

consistency with the GALL Report. The staff verified whether the AMR line item of the different

component was applicable to the component under review. The staff verified whether the

identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The staff

also determined whether the AMP identified by the applicant was consistent with the AMP

identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note E indicated that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified by

the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the LRA, as documented

in its MPS audit and review report. The staff did not repeat its review of the matters described in

the GALL Report. However, the staff did verify that the material presented in the LRA was

applicable and that the applicant had identified the appropriate GALL Report AMRs. The staff

evaluation is discussed below.

3.4B.2.1.1 Loss of Material Due to Boric Acid Corrosion

In the discussion section of Table 3.4.1, item 13, of the LRA, the applicant stated that loss of

material due to boric acid corrosion is managed by MPS AMP B2.1.3, "Boric Acid Corrosion,"

and MPS AMP B2.1.13, "General Condition Monitoring." The boric acid corrosion program

includes specific inspections of steam and power conversion and supporting systems

components. The boric acid corrosion program and the general condition monitoring program

are evaluated in Sections 3.0.3.1 and 3.0.3.2 of this SER respectively.

The LRA identifies a borated water leakage environment for various components in the steam

and power conversion and ESF systems and both the boric acid corrosion program and general

condition monitoring program are credited with managing loss of material from external surfaces.

The boric acid corrosion program described in LRA Section B2.1.3 appears to be limited to

components located inside containment, as addressed in NUREG-1801, Section XI.M1O. In RAI

3.4-1, the applicant was requested to clarify why the boric acid corrosion program is credited for

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managing boric acid corrosion in systems that are located outside containment. Also, in regard

to the effectiveness of the general condition monitoring program, the applicant was requested to

clarify:

i) How the program manages loss of material for components not normally

accessible.

ii) The basis of the inspection frequency (once per refueling outage) considering the

potential rate for material loss.

iii) What acceptance criteria and corrective actions are applied to the visual

indication of boric acid crystals without material degradation.

iv) How the program provides for promptly identifying the specific cause and location

of the borated water leakage.

In its response dated November 9, 2004, the applicant provided the following information:

The Boric Acid Corrosion Program provides requirements to adequately manage boric

acid related degradation of the reactor coolant system, ASME Class 1, 2 and 3

components, and associated or neighboring systems, structures, and components that

are in the scope of License Renewal. The requirements of the Millstone Boric Acid

Corrosion Program surpass the requirements listed in NUREG-1801, Section XL.M10, in

that it is additionally applied to an identified boric acid system leak anywhere in the plant.

As part of the Aging Management Review process, the Boric Acid Corrosion Program,

along with the General Condition Monitoring Program, is credited for managing aging for

the external surface of equipment located in a building that contains a boric acid liquid

system (such as the Steam and Power Conversion system, the ESF system, and the

Radwaste Ventilation system).

The General Condition Monitoring Program and the Boric Acid Corrosion Program are

both listed for various components in the steam and power conversion, ESF, and

radwaste ventilation systems because collectively they manage the loss of material for

the external surfaces of these components. The General Condition Monitoring Program

provides supplemental inspections to the Boric Acid Corrosion Program for managing

loss of material due to boric acid corrosion in systems that are located outside

containment, such as steam and power conversion, ESF, and radwaste ventilation

systems. Any instances of boric acid leakage identified during general condition

monitoring activities are entered into the corrective action program and evaluated using

the guidance of the Boric Acid Corrosion Program.

The effectiveness questions identified are addressed by the Boric Acid Corrosion

Program, not the General Condition Monitoring Program, since the Boric Acid Corrosion

Program provides the evaluation and corrective actions when any evidence of boric acid

leakage is identified. A more detailed answer is as follows:

i) Non-insulated components are examined by inspecting the accessible

external surfaces for direct and indirect evidence of leakage. For

components whose external surfaces are inaccessible for direct visual

examination, the surrounding areas (including equipment surfaces located

underneath the components) are examined for signs of leakage and other

areas are considered where leakage may be channeled.

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The Boric Acid Corrosion Program recognizes that boric acid leaks can

travel down sloped piped or under insulation. Evidence of leakage can

also be determined for components with vertical surfaces of insulation by

examining the lowest elevation where the leakage may be detectable.

Horizontal surfaces of insulation can be examined at insulation joints.

When there is doubt as to a leak's origin, the evidence (i.e., accumulation

of boric acid crystals) needs to be preserved until an evaluation has been

performed to estimate the source, pathway, target and amount that may

be affected. This includes the removal of insulation to determine the leak

location.

For those areas identified as infrequently accessed areas, for the

purposes of detecting boric acid leakage, entry into the area is performed

often enough (at least once per refueling interval) to credit the inspections

in the General Condition Monitoring AMP and the Boric Acid Corrosion

AMP. The one exception is the Unit 3 demineralizer cubicles area.

However, for this area, a video inspection is performed at least once per

ten years to verify the integrity of the equipment. Based on operating

experience, there is reasonable assurance that this inspection interval will

detect borated water leakage prior to the loss of intended function of the

affected equipment.

ii) The Millstone Boric Acid Corrosion Program examines locations

susceptible to boric acid leakage inside Containment during each refueling

outage. It is not practical to perform these examinations while the reactor

plant is operating.

Any boric acid leakage identified by plant personnel is either corrected

prior to the end of the outage or is evaluated to ensure the intended

function is maintained until a repair can be performed. Dominion is aware

of the issues associated with boric acid corrosion, and the plant operating

conditions that could be indicative of boric acid leakage. For potential boric

acid corrosion leakage, which may develop between refueling cycles,

changes in plant parameters would provide indication that a potential leak

may exist. Both identified and unidentified leakage is strictly monitored

and trended for changes in sump level, flow rates, and frequency of pump

operation. Changes in ambient conditions inside containment also provide

indication of potential boric acid leakage.

Abnormal ambient conditions inside containment are documented through

the corrective action process, which may require a shutdown of the reactor

plant in order to repair a leak inside containment. Plant operating experience indicates that boric acid inspections performed once per

refueling cycle are adequate to maintain the intended function of the

equipment in containment. Plant and industry operating experience

indicates that a boric acid leak that starts during the operating cycle does

not damage the equipment to the point where it cannot perform its

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iii) In accordance with the Boric Acid Corrosion Program, any boric acid

leakage identified by plant personnel (including boric acid crystals without

material degradation) is documented through the corrective action process

(10 CFR 50, Appendix B). Minor leakage may be just cleaned or, if

leakage is more severe, a Boric Acid Corrosion Program assessment of

the boric acid build-up is performed prior to clean-up. The leakage source,

path, and target areas are located, and corrective actions are

implemented as determined by the Boric Acid Corrosion Program.

Corrective actions include timely repair of the leakage after detection to

prevent or mitigate the extent of boric acid corrosion. Where evaluations

are performed without repair or replacement, engineering analysis

reasonably assures that the intended function is maintained consistent

with the current licensing basis.

iv) The Boric Acid Corrosion Program provides for prompt identification of the

specific cause and location of borated water leakage.

See response in item iii above.

Accessible areas are traversed on a daily basis by plant personnel who

have been informed of expectations related to boric acid identification and

corrective action. Personnel are expected to attempt to identify the

leakage source as well as the extent of condition on secondary plant

equipment. The Corrective Action Process triggers an investigation by the

Boric Acid Corrosion Program. Minor boric acid may be just cleaned, more

substantial leakage requires equipment to be repaired to stop the leak or

an engineering evaluation be performed to ensure the intended function of

the equipment is maintained until such a time that the leak can be

repaired.

The staff reviewed the applicant's response and determined that the response was reasonable

and acceptable because the applicant credits a combination of the general condition monitoring

program and the boric acid corrosion program to detect and evaluate borated water leakage and

boric acid corrosion to maintain the intended function of the auxiliary system components. For

areas outside containment, general equipment (or materials) frequent inspections are performed

as often as daily, which would identify any borated water leakage and any required subsequent

evaluation. In response to staff's request of RAI 3.3-B-1, the applicant committed to the following

clarification to the Unit 2 Appendix A "FSAR Supplement," Section A2.1.3, Boric Acid Corrosion,

Program Description, and the Unit 3 Appendix A "FSAR Supplement," Section A2.1.2, Boric Acid

Corrosion, Program Description. (Refer to Section 3.3A for additional details.)

3.4B.2.1.2 Loss of Material Due to General Corrosion; Crack Initiation and Growth Due to Cyclic

Loading and/or Stress Corrosion Cracking

In Table 3.4.1, Item 8, for loss of material due to general corrosion, crack initiation and growth

due to cyclic loading and/or stress corrosion cracking (SCC) for closure bolting in high-pressure

or high-temperature systems components, the applicant stated that bolting in the steam and

power conversion systems were not subject to wetted conditions. Therefore, loss of material due

to general corrosion is not expected. Additionally, cracking for bolting in steam and power

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conversion systems was not identified as an aging effect requiring management. However,

SRP-LR Table 3.4-1 stipulates that the AMR evaluations consider crack initiations and growth

due to cyclic loading for component's closure bolting in high-pressure or high-temperature

systems and that the applicant should manage the aging effects using GALL AMP XL.M18,

"Bolting Integrity."

The applicant stated in the LRA that SCC is an aging mechanism that requires the simultaneous

action of a corrosive environment, a sustained tensile stress, and a susceptible material.

Elimination of any one of these elements will eliminate the susceptibility to SCC. Further, the

applicant stated that steam and power conversion systems bolting is fabricated to ASTM Al 94,

Grade B7 standard, is not high yield strength (>150 ksi), and is not subject to an adverse

environment that could result in SCC. Therefore, cracking is not an aging effect requiring

management.

The staff noted that SCC could occur in corrosive environment and that the environment does

not have to be in a wetted condition. The staff questioned the applicant whether good bolting

practices, bolting preload considerations, and proper sealant and lubricant, as stated in

NUREG-1339, are followed.

By letter dated December 3, 2004, the applicant submitted a supplement. The applicant stated

that it had developed a specific bolting integrity aging management program that addresses

degradation of bolting at MPS. The bolting integrity program is addressed in Section 3.0.3.2.18

of this SER.

By letter dated January 11, 2005, the applicant submitted its bolting aging management roll-up

item. In its response, the applicant replaced the existing information in the "Discussion" column

of LRA Table 3.4.1, Item 8 with "consistent with the NUREG-1 801." The staff reviewed the

applicant's response and finds this acceptable since it is consistent with the GALL Report.

The staff reviewed the applicant's response and finds this acceptable since it is consistent with

the GALL Report.

3.4B.2.1.3 Loss of Material Due to General Corrosion (Carbon Steel Only), Pitting, and Crevice

Corrosion, MIC, and Biofouling; Buildup of Deposit Due to Biofouling

In the discussion section of Table 3.4.1, Item 9, of the LRA, the applicant proposed to manage

loss of material due to general (carbon steel), pitting, and crevice corrosion, MIC, and biofouling

and buildup of deposit due to biofouling hot water heating and pre-heating component serviced'

by open-cycle cooling water components using MPS AMP B2.1.25, "Work Control Process." The

GALL Report recommends GALL AMP XI.M20, ",Open-Cycle Cooling Water System," to manage

the aging effects. The applicant proposed to manage the aging effects by MPS AMP B2.1.25,

"Work Control Process," for those components identified in LRA Tables 3.4.2-8 and 3.4.2-9.

The staff reviewed the service water system (open-cycle cooling) and work control process

program and its evaluation of these programs is documented in Sections 3.0.3.2.15 and

3.0.3.3.4 of this SER, respectively. On the basis of its review, the staff concludes that applicant's

work control process program is an acceptable alternate inspection program for this component

to manage the aging effects.

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3.4B.2.1.4 Loss of Material Due to General (Carbon Steel Only), Pitting, and Crevice Corrosion

In the discussion section of Table 3.4.1, iteml10, of the LRA, the applicant stated that for

components in a treated water environment other than closed-cycle cooling water, loss of

material is managed by the chemistry control for secondary systems or the work control process.

The GALL Report identifies that further evaluation is required for components managed by water

chemistry program in the steam and power conversion system. During the audit and review, the

staff requested that the applicant provide clarification why those components that are managed

by the chemistry control program do not require further evaluation.

By letter dated November 9, 2004, the applicant submitted its response. In its response, the

applicant stated that GALL Report, Item VIII.E.4-a, which references GALL AMP XI.M2, "Water

Chemistry," should have been chosen for these components, along with a Note D to indicate that

the component is different than the component described in the NUREG-1 801. The further

evaluation recommended, associated with GALL Report, Item VIII.E.-a in LRA Table 3.4.1, Item

3.4.1-02, is addressed in LRA Section 3.4.2.2.2.

The applicant also stated, in the LRA, that the effectiveness of MPS AMP B2.1.6, "Chemistry

Control for Secondary Systems Program," is confirmed by MPS AMP B2.1.25, "Work Control

Process." The work control process program provides the opportunity to visually inspect the

internal surfaces of components during preventive and corrective maintenance activities on an

ongoing basis. The work control process program provides input to the corrective action

program if and when aging effects are identified. The corrective action program evaluates the

cause and extent of the condition and, if required, recommends enhancements to ensure

continued effectiveness of the chemistry control for secondary systems program. The staff finds

that the applicant's response is acceptable and consistent with the GALL Report.

On the basis of its audit and review, the staff determined that for AMRs not requiring further

evaluation, as identified in the LRA Table 3.4.1 (Table 1), the applicant's references to the GALL

Report are acceptable and no further staff review is required.

Conclusion. The staff has evaluated the applicant's claim of consistency with GALL Report. The

staff also has reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff finds that the AMR results, which the applicant claimed to be consistent with the GALL

Report, are consistent with the AMRs in the GALL Report. Therefore, the staff finds that the

applicant has demonstrated that the effects of aging for these components will be adequately

managed so that their intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.4B.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Application. In Section 3.4.2.2 of the LRA, the applicant

provides further evaluation of aging management as recommended by the GALL Report for

steam and power conversion systems. The applicant provided information concerning how it will

manage the following aging effects:

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* cumulative fatigue damage

* loss of material due to general,'pitting, and crevice corrosion

* loss of material due to general, pitting, and crevice corrosion, microbiologically influenced

corrosion, and biofouling

* general corrosion

* loss of material due to general, pitting, crevice, and microbiologically influenced corrosion

* quality assurance for aging management of non'-safety-related components

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff reviewed the applicant's evaluation to determine'whether it

adequately addressed the issues that were further evaluated. In addition, the staff audited the

applicant's further evaluations against the criteria contained in Section 3.4.2.2 of the Standard

Review Plan for License Renewal. Details'of the staffs audit and review are documented in the

staffs MPS audit and review report.

The GALL Report indicates that further evaluation should be performed for the aging effects

described in the following sections.

3.4B.2.2.1 Cumulative Fatigue Damage

As stated in the SRP-LR, fatigue is a TLAA, as defined in 10 CFR 54.3. Applicants must

evaluate TLAAs in accordance with 10 CFR 54.21 (c)(1). Section 4.3 of this' SER documents the

staff's review of the applicant's evaluation of this TLAA. In performing' this review, the staff

followed the guidance in Section 4.3 of the SRP-LR.

3.4B.2.2.2 Loss of Material Due to General (Carbon Steel Only), Pitting, and Crevice Corrosion

SRP-LR Section 3.4.2.2.2 states that the management of loss of material due to general, pitting,'

and crevice corrosion should be evaluated furtherlfor carbon steel piping and fittings, valve

bodies and bonnets, pump casings, pump suction and discharge lines, tanks, tubesheets,

channel heads, and shells except for main steam system components and for loss of material

due to pitting and crevice corrosion for stainless steel tanks and heat exchanger/cooler tubes.

The water chemistry program relies on monitoring and control of water chemistry based on the

EPRI guidelines of TR-102134, UPWR Secondary Water Chemistry Guideline-Revision 3," for

secondary water chemistry to manage the effects of loss of material due'to general, pitting, or

crevice corrosion. However, corrosion may occur at locations of stagnant flow conditions.

Therefore, the effectiveness of the chemistry cofitrol program should be verified to ensure that

corrosion is not occurring. The GALL Report recommends further evaluation of programs to

manage loss of material due to general, pitting, and crevice corrosion to verify the effectiveness

of the water chemistry program. A one-time' inspection of select components and susceptible

locations is an acceptable method to ensure that corrosion is not occurring and that the

component's intended function will be maintained during the period of extended operation.

The AMPs recommended by the GALL Report are GALL AMP XI.M2, "Water Chemistry," and

GALL AMP XI.M32, "One Time Inspection," for management of this aging effect.

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The applicant stated in the LRA that the loss of material due to general corrosion, pitting, and

crevice corrosion in the steam and power conversion system components is managed by control

of water chemistry through MPS AMP B2.1.6, "Chemistry Control for Secondary Systems." The

applicant also stated that in lieu of a one-time inspection, MPS AMP B2.1.25, "Work Control

Process" is used to provide confirmation of the effectiveness of the chemistry control for

secondary systems program. The work control process provides the opportunity to visually

inspect the internal surfaces of components during preventive and corrective maintenance

activities on an ongoing basis and provides input to the corrective action program if aging effects

are identified. The corrective action program would evaluate the cause and extent of the

condition and, if required, recommend enhancements to ensure continued effectiveness of the

chemistry control for secondary systems program.

The staff reviewed the chemistry control for secondary systems and its evaluation is

documented in Section 3.0.3.2.3 of this SER. In addition, during the audit, in response to the

staff's query regarding the one-time inspection, the applicant stated that the work control

process program provides more opportunities for inspection of signs of aging than would a

one-time inspection program. In addition, it provides confirmation of chemistry control

effectiveness on a continuing basis, rather than at a single point in time afforded by a one-time

inspection program. The applicant confirmed that indications of age-related degradation would

be evaluated and the extent of the condition be determined through the corrective action system.

Enhancements to water chemistry control programs and follow-up inspections would be initiated,

as necessary, to provide effective management of aging effects.

The staff reviewed the information provided in the LRA and concurs that the applicant's

approach is consistent with GALL AMP XL.M32, "One-time Inspection," which states: "An

alternate acceptable program may include routine, maintenance or a review of repair records to

confirm that these components have been inspected for aging degradation and significant aging

degradation has not occurred and thereby verify the effectiveness of the existing AMPs." Also,

the staff reviewed operating experience associated with the work control process program as it

applied to the steam and power conversion system. The staff reviewed the applicant's technical

report for work control inspection opportunities, which provided the results of a plant-wide review

of maintenance history for a 1 0-year period. The staff finds that more than 50 work control

related inspection opportunities were listed against the steam and power conversion system.

The staff finds this to be adequate for providing confirmation of the effectiveness of the

chemistry control for secondary systems program.

3.4B.2.2.3 Loss of Material Due to General, Pitting, and Crevice Corrosion, Microbiologically

Influenced Corrosion, and Biofouling

SRP-LR Section 3.4.2.2.3 states that loss of material due to general, pitting, and crevice

corrosion, MIC, and biofouling could occur in carbon steel piping and fittings for untreated water

from the backup water supply in the auxiliary feedwater system. The GALL Report recommends

further evaluation to ensure that these aging effects are adequately managed. Acceptance

criteria are described in Branch Technical Position RLSB-1 (Appendix A.1, of the SRP-LR).

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The applicant stated, in LRA Section 3.4.2.2.3, that the backup water supply for the auxiliary

feedwater system is the service water system. The backup water source is maintained isolated

from the auxiliary feedwater system by removed spool pieces, which are normally maintained in

storage, thus ensuring that untreated water from the service water system does not enter the

auxiliary feedwater pumps suction piping. The applicant also states that the backup water supply

piping and components were evaluated to be satisfactory for the effects of aging with the service

water system.

During the audit and review, the staff reviewed Unit 3 piping and instrumentation diagrams

related to the service water system. On the basis of its review, the staff finds that there was

effective isolation to ensure that untreated water from the service water system does not enter

the auxiliary feedwater pumps suction piping.

Since the untreated water environment is isolated from the auxiliary feedwater pumps suction

piping, this aging effect is not applicable to auxiliary feedwater pumps suction piping. On this

basis, the staff concludes that not including this aging effect is acceptable.

3.4B.2.2.4 Loss of Material Due to General Corrosion

SRP-LR Section 3.4.2.2.4 states that loss of material due to general corrosion could occur on

the external surfaces of all carbon steel SCs, including closure boltings, exposed to operating

temperatures less than 212 F. The GALL Report recommends further evaluation to ensure that

this aging effect is adequately managed.

The applicant stated in the LRA that general corrosion is applicable to carbon steel, low-alloy

steel, and cast iron components in an air environment only when it is exposed to intermittent

wetting. The applicant also stated that loss of material due to general corrosion of external

surfaces is managed by MPS AMP B2.1.13, "General Condition Monitoring."

The staff reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. On the basis of its review, the staff concludes that this program is

acceptable for managing loss of material since visual inspection of external surfaces is

performed during various walkdowns.

3.4B.2.2.5 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced

Corrosion

SRP-LR Section 3.4.2.2.5 addresses loss of material due to general corrosion (carbon steel

only), pitting and crevice corrosion, and MIC which could occur in stainless steel and carbon

steel shells, tubes, and tubesheets within the bearing oil coolers (for steam turbine pumps) in the

auxiliary feedwater system. The GALL Report recommends further evaluation to ensure that

these aging effects are adequately managed; '

SRP-LR Section 3.4.2.2.5 also addresses loss of material due to general corrosion, pitting and

crevice corrosion, and MIC, which could occur in underground piping and fittings and emergency

condensate storage tank in the auxiliaryfeedwater system and the underground condensate

storage tank in the condensate system. The buried piping and tanks inspection program relies

on industry practice, frequency of pipe excavation, and operating experience to manage the

effects of loss of material from general corrosion, pitting and crevice corrosion, and MIC. The

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effectiveness of the buried piping and tanks inspection program should be verified to evaluate an

applicant's inspection frequency and operating experience with buried components, ensuring

that loss of material is not occurring.

The applicant stated, in LRA Section 3.4.2.2.5.1, that loss of material of the auxiliary feedwater

pump lube oil coolers is managed by the work control process. The applicant further stated, in

LRA Section 3.4.2.2.5.2, that there are no underground, carbon steel components associated

with the auxiliary feedwater system, and therefore, this item is not applicable.

In LRA Table 3.4.2-5, the applicant proposed to manage loss of material due to pitting, crevice

corrosion, and microbiologically influenced corrosion for the stainless steel oil coolers in auxiliary

feedwater (AFW) system exposed to oil using MPS AMP B2.1.25, "Work Control Process."

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The work control process provides the opportunity to visually

inspect the components during preventive and corrective maintenance activities on an ongoing

basis. The work control process provides input to the corrective action program if aging effects

are identified. On the basis of its review, the staff finds that using the work control process

program to manage the aging effect of loss of material for the oil cooler in AFW system is

adequate.

On the basis that there are no buried components in steam and power conversion systems at

MPS, the staff finds that this aging effect is not applicable.

3.41B.2.2.6 Quality Assurance for Aging Management of Non-Safety-Related Components

Section 3.0.4 of this SER provides the staffs evaluation of the applicant's quality assurance

program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determines that (1) those attributes or features

for which the applicant claimed consistency with the GALL Report were indeed consistent and

(2) the applicant adequately addressed the issues that were further evaluated. The staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

3.4B.2.3 AMR Results That Are Not Consistent With or Not Addressed in the GALL

Report

Summary of Technical Information in the Application. In Tables 3.4.2-1 through 3.4.2-11 of the

LRA, the staff reviewed additional details of the results of the AMRs for material, environment,

aging effect requiring management, and AMP combinations that are not evaluated in the GALL

Report or are not addressed in the GALL Report. The staff also reviewed additional systems and

components, provided in applicant's letter dated January 11, 2005.

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In Tables 3.4.2-1 through 3.4.2-11, the applicant indicated, via Notes F through J, that neither

the identified component nor the material and environment combination is evaluated in the GALL

Report and provided information concerning how the aging effect will be managed.

Staff Evaluation. For component type, material and environment combination that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine whether

the applicant had demonstrated that the effects of aging will be adequately managed so that the

intended function will be maintained consistent with the CLB during the period of extended

operation.

The staff evaluation is discussed below.

3.4B.2.3.1 -Main Steam - Aging Management Evaluation - Table 3.4.2-1

The staff reviewed Table 3.4.2-1 of the LRA, which summarized the results of AMR evaluations

for the main steam system component groups.:'

In LRA Table 3.4.2-1, the applicant identified no aging effects for the following carbon steel, and

low alloy steel main steam component types - pipe, steam traps, valves, and valves

(atmospheric dumps and main steam safety/relief) - exposed externally to air.

During the audit and review, the staff requested that the applicant provide clarification as to why

there are no aging effects for these components. The applicant stated that the steam and power

conversion systems components are normally operated at high temperatures (> 212 OF) and the

external surface of the component was determined to be dry. The applicant also stated that

these components are located inside buildings and because of the high operating temperature,

would not be subject to condensation. These components were determined not to be susceptible

to loss of material due to corrosion based on the dry environment, as described in LRA Appendix

C, Section C3.7.15.

The staff expressed concern regarding possible long-term shutdown such as the plant shutdown

in the 1990s. The applicant stated that the only potential source of wetting of the external

surfaces for these components, in a sheltered environment, is condensation. However,

intermittent wetting conditions would not be expected during out-of-service periods for these

components because for condensation to occur, the surface temperature of the components

would have to decrease below the dew point of the ambient environment. These normally .high

temperature components are located in buildings with warm to hot temperatures and they are

insulated. Therefore, conditions for condensation are not expected even when the components

are out of service for long periods of time.

Since the external surface temperature for these main steam system components is high'

enough to preclude condensation and these components are not exposed to the intermittent

wetting, the staff finds there are no applicable aging effects for the above-mentioned

components.

In LRA Table 3.4.2-1, the applicant identified no aging effects for the following stainless steel

and nickel-based alloy main steam component types exposed externally to air: expansion joints,

flexible hoses, flow elements, tubing, and valves. -

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On the basis of current industry research and operating experience, stainless steeVnickel-based

alloy exposed externally to air is not susceptible to significant general corrosion that would affect

the intended function of components. Therefore, the staff finds that there are no applicable aging effects for stainless steel components exposed externally to air.

In LRA Table 3.4.2-1, the applicant proposed to manage loss of material and cracking for the

following stainless steel and nickel-based alloy main steam component types - expansion joints, flexible hoses, flow elements, and tubing - exposed internally to steam using MPS AMP B2.1.6,

wChemistry Control for Secondary Systems."

The staff reviewed the chemistry control for secondary systems program and its evaluation of

this program is documented in Section 3.0.3.2.2 of this SER. The effectiveness of the chemistry control program is further provided by MPS AMP B2.1.25, 'Work Control Process" and is

documented in Section 3.4.2.2.2 of this SER.

On the basis of its review and its determination that the effects of pitting and crevice corrosion

on stainless steel and nickel-based alloys are not significant in treated water or steam, the staff

finds that management of loss of material for stainless steel/nickel-based alloy components using the chemistry control for secondary systems program is adequate.

The applicant stated in the LRA that stress corrosion cracking is an aging mechanism that

requires the simultaneous action of a corrosion environment, a sustained stress, and a

susceptible material. The applicant also stated that elimination of any one of these elements will

eliminate the susceptibility to stress corrosion cracking. The applicant credits MPS AMP B2.1.6,

"Chemistry Control for Secondary Systems," to manage this aging mechanism since it, removed

one of the three required actions (corrosion environment).

The chemistry control program for secondary systems maintains a controlled environment with

low contaminant concentration and the applicant's operating experience has shown this program to be effective for the management of cracking due to stress corrosion cracking, the staff

therefore finds that the applicant has demonstrated that the effects of aging for stress corrosion

cracking for stainless steel and nickel-based components using chemistry control for secondary systems will be adequately managed so that the intended functions will be maintained consistent

with the CLB during the period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.4B.2.3.2 Feedwater - Aging Management Evaluation - Table 3.4.2-2

The staff reviewed LRA Table 3.4.2-2, which summarized the results of AMR evaluations for the

feedwater system component groups.

In LRA Table 3.4.2-2, the applicant proposed to manage cracking for the following stainless

steel feedwater steam system component types - flow elements, tubing, and valves - exposed internally to steam using MPS AMP B2.1.6, "Chemistry Control for Secondary Systems."

The material, environment, aging effects, and aging management program (MEAP) for

feedwater steam components is the same as that for the main steam components. Since both

have the same MEAP combination, the staff finds that management of cracking for stainless

steel components using the chemistry control for secondary systems program is adequate. The

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staff reviewed the chemistry control for secondary systems program and its evaluation is

documented in Section 3.0.3.2.3 of this SER.

The applicant identified no aging effects for the following stainless steel, carbon steel, and

low-alloy steel feedwater steam system component types flow elements, pipe, tubing, and

valves - exposed externally to air.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless steel, carbon steel and low-alloy

steel components exposed externally to air. The staffs evaluation is documented in Section

3.4.2.3.1 of this SER.

3.46.2.3.3 Condensate Make-Up and Draw-Off - Aging Management Evaluation - Table 3.4.2-3

The staff reviewed LRA Table 3.4.2-3, which summarized the results of AMR evaluations for the

condensate make-up and draw-off system component groups.

In LRA Table 3.4.2-3, the applicant identified no aging effects for the following stainless steel

condensate make-up and draw-off system component types exposed externally to air pipe,

tubing, and valves.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless steel components exposed

externally to air. The staffs evaluation is documented in Section 3.4.2.3.1 of this SER.

In LRA Table 3.4.2-3, the applicant identified no aging effects for the stainless steel condensate

make-up and draw-off system rupture disk, and aluminum condensate storage tank exposed

internally to gas environment.

On the basis of current industry research and operating experience, an internal environment of

gas (which is similar to air) on metal will not result in aging that will be of concern during the

period of extended operation. Therefore, the staff concludes that there are no applicable aging

effects for metal in a gas environment.

In LRA Table 3.4.2-3, the applicant proposed to manage loss of material for the stainless steel

pipe exposed externally to damp soil environment using MPS AMP B2.1.4, "Buried Pipe

Inspection Program."

The staff reviewed the buried pipe inspection program and its evaluation is documented in

Section 3.0.3.2.1 of this SER. On the basis of its review, the staff finds that using the buried pipe

inspection program to manage the aging effect of loss of material for the buried pipe component

is adequate.

The LRA Table 3.4.2-3 credits the AMP B2.124 "Tank Inspection Program" for managing the

loss of material of the aluminum condensate storage tank in a damp soil environment. In RAI

3.4-2, the staff requested the applicant to provide the following additional information regarding

the aging management of this tank: (a) the alloy content of the aluminum and the welded joints

or connections; (b) the type of coatings and/or linings, if any; (c) the support configuration of the

tank in the moist soil environment; (d) the NDE methods which are employed to determine

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degradation of the tank walls and bottom; (e) the frequency of the wall thickness measurements,

their locations and acceptance criteria; and (f) the operating history of the tank relating to

degradation and remedial actions taken in the past.

In its response dated November 9, 2004, the applicant stated:

(a) The aging management review for the condensate storage tank did not credit any

specific alloy content in the determination of applicable aging mechanisms/effects

for the aluminum tank or welds.

(b) The condensate storage tank is not coated or lined. Additionally, as stated in LRA

Appendix C, Section C2.4, coatings and linings were not credited in the

determination of applicable aging effects for in-scope components, including

tanks.

(c) The support configuration for the condensate storage tank consists of a

reinforced concrete foundation with an oiled sand cushion as described in LRA

Section 2.4.2.32. The oiled sand tank bottom supporting material was

conservatively assumed to be equivalent to moist soil for the purposes of the

aging management review.

(d) The aging management review for the condensate storage tank concluded that

the tank bottom could be subject to loss of material. As discussed in LRA

Appendix B, Section B2.1.24 "Tank Inspection Program," thickness measurement

of the tank bottom will be performed using volumetric non-destructive examination

methods.

(e) Per LRA Appendix A, Table A6.0-1, commitment 24, a baseline inspection of the

condensate storage tank bottom will be performed prior to the period of extended

operation. After that, as a minimum (depending upon baseline inspection results),

inspections will occur every ten years. As noted in (d) above, the tank bottom

thickness will be measured using volumetric non-destructive examination

methods prior to the period of extended operation. Subsequent inspections will be

performed on a frequency consistent with scheduled tank intemals inspection

activities.

(f) The operating history associated with the condensate storage tank is described in.

LRA Appendix B, Section B2.1.24. During a past inspection of the tank, water was

found to be slowly leaking from the tank. Previous inspections of the tank had.

detected only occasional wetness. Internal operating experience had identified

that the bottom of a similarly designed tank (the condensate surge tank) had

already been replaced. The condensate surge tank did not have a barrier installed

between the aluminum tank bottom and the sand that forms part of the base mat.

An alkaline solution resulting from groundwater intrusion to the concrete

foundation ring caused pitting of the aluminum and eventual through-wall

leakage. An engineering evaluation concluded that the condensate storage tank

and condensate surge tank were both built at the same time using a similar

design. As a result of the investigation and previous operating experience, a

design change was implemented to replace the condensate storage tank bottom.

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The new tank bottom was essentially a one for one replacement. In addition, the

existing oil and sand mixture under the tank bottom was replaced with washed,

clean, neutral, dry, low chloride and compacted sand, and asphalt impregnated

fiber board was installed as a barrier between the aluminum tank and concrete

foundation ring.

The staff finds the applicant's response reasonable and acceptable because the applicant is

employing appropriate NDE methods for determining tank bottom degradation as well as

remedial action to prevent degradation in the future.

3.4B.2.3.4 Steam Generator Blowdown - Aging Management Evaluation - Table 3.4.2-4 and

Table 3.4.2-4a

The staff reviewed LRA Table 3.4.2-4 and Table 3.4.2-4a of the applicant's letter dated January

11, 2005, which summarized the results of AMR evaluations in the SRP-LR for the steam

generator blowdown system component groups.

In LRA Table 3.4.2-4, the applicant identified no aging effects for the following stainless steel,

carbon steel and low-alloy steel steam generator blowdown system component types exposed

externally to air flow elements, pipe, and tubing.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless steel, carbon steel and low-alloy

steel components in external air. The staffs evaluation is documented in Section 3.4.2.3.1 of this

SER.

In LRA Table 3.4.2-4, the applicant proposed to manage cracking for the following stainless

steel steam generator blowdown system component types - flow elements, and tubing - exposed

internally to treated water using MPS AMP B2.1.6, Chemistry Control for Secondary Systems."

The material, environment, aging effects, and aging management program (MEAP) for steam

generator blowdown components is the same as that for the main steam components. Since

both have the same MEAP combination, the staff finds that management of loss of material and

cracking for stainless steel components using chemistry control for secondary systems program

to be adequate. The staffs evaluation is documented in Section 3.4.2.3.1 of this SER.

In LRA Table 3.4.2-4 and Table 3.4.2-4a of the applicant's letter dated January 11, 2005, the

applicant identified no aging effects for the following stainless steel, carbon steel and low-alloy

steel steam generator blowdown system component types - flow elements, pipe, tubing, and

steam generator blowdown tank - exposed externally to air. On the basis that these components

have the same MEAP combination as previously discussed, the staff finds that there are no

aging effects for these stainless steel, carbon steel and low-alloy steel components exposed

externally to air. The staffs evaluation is documented in Section 3.4.2.3.1 of this SER.

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3.4B.2.3.5 Auxiliary Feedwater - Aging Management Evaluation - Table 3.4.2-5 and Table

3.4.2-5a

The staff reviewed LRA Table 3.4.2-5 and Table 3.4.2-5a of the applicant's letter dated January

11, 2005, which summarizes the results of AMR evaluations for the auxiliary feedwater system

component groups.

In LRA Table 3.4.2-5, the applicant identified no aging effects for the following stainless steel

auxiliary feedwater system component types exposed externally to air AFW pump oil coolers

(channel heads), AFW pump oil coolers (shell), cavitating venturies, flow elements, level

indicators, pipe, restricting orifices, tubing, valves and carbon steel turbine casings.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless components exposed externally

to air. The staff's evaluation is documented in Section 3.4.2.3.1 of this SER.

In LRA Table 3.4.2-5, the applicant has identified no aging effects for copper alloy spool pieces

exposed internally and externally to air.-

The applicant stated, in LRA Section 3.4.2.2.3, the removable spool pieces are normally

maintained in storage. On the basis of current industry research and operating experience, an

internal storage environment of air on copper alloys will not result in aging that will be of concern

during the period of extended operation. Therefore, the staff concludes that there are no

applicable aging effects for copper alloy spool pieces in an air environment.

In LRA Table 3.4.2-5, the applicant proposed to manage loss of material for the stainless steel

demineralized water storage tank exposed internally to a treated water and air environment and

carbon steel turbine casings exposed internally to treated water using MPS AMP B2.1.6,

"Chemistry Control for Secondary Systems" and MPS AMP B2.1.25, "Work Control Process."

The GALL Report recommends GALL AMP XI.M2, "Water Chemistry," to be augmented by

verifying the effectiveness of water chemistry control by a supplementary program.

GALL AMP XI.M32, -One-Time Inspection," is an acceptable verification program.

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The effectiveness of the chemistry control program is provided

further by MPS AMP B2.1.25, "Work Control Process," and is documented in Section 3.0.3.2.3

of this SER. The work control process provides the opportunity to visually inspect the surfaces of

components during preventive and corrective maintenance activities on an ongoing basis. The

work control process also provides input to the corrective action program if aging effects are

identified. On the basis on its review, the staff finds management of loss of material for these'

components using the chemistry control for secondary systems and work control process

program to be adequate.

In LRA Table 3.4.2-5, the applicant proposed to manage loss of material for the stainless steel

pipe exposed externally to damp soil environment using MPS AMP B2.1.4, "Buried Pipe

Inspection Program."

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The staff reviewed the buried pipe inspection program and its evaluation is documented in

Section 3.0.3.2.1 of this SER. On the basis of its review, the staff finds the buried pipe inspection

program acceptable for managing the aging effect of loss of material for the buried pipe

component.

In LRA Table 3.4.2-5, the applicant proposed to manage loss of material for the stainless steel

demineralized water storage tank exposed externally to atmosphere/weather environment using

MPS AMP B2.1.24, 'Tank Inspection Program."

The staff reviewed the tank inspection program and its evaluation is documented in Section

3.0.3.2.17 of this SER. On the basis of its review, the staff finds management of loss of material

for this component using the tank inspection program to be adequate.

In LRA Table 3.4.2-5, the applicant proposed to manage cracking for the following stainless

steel auxiliary feedwater system component types, AFW pump oil coolers (tube sheets) and

AFW pump oil coolers (tube), exposed externally to oil environment and AFW pump oil coolers

(shell) exposed internally to oil environment using MPS AMP B2.1.25, "Work Control Process."

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The work control process provides the opportunity to visually

inspect the surfaces of components during preventive and corrective maintenance activities on

an ongoing basis. The work control process provides input to the corrective action program if

aging effects are identified. On the basis of its review, the staff finds the work control process

program acceptable for managing the aging effect of cracking for stainless steel AFW pump oil

cooler tubesheets, tubes and shell.

3.4B.2.3.6 Auxiliary Steam - Aging Management Evaluation - Table 3.4.2-6

The staff reviewed LRA Table 3.4.2-6, which summarized the results of AMR evaluations for the

auxiliary steam system component groups.

In LRA Table 3.4.2-6, the applicant identified no aging effects for the stainless steel/carbon

steel/low-alloy steel pipe, tubing, and valves exposed externally to air.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless components exposed externally

to air. The staff's evaluation is documented in Section 3.4.2.3.1 of this SER.

In LRA Table 3.4.2-6, the applicant proposed to manage cracking for stainless steel tubing

exposed internally to a treated water and steam environment using MPS AMP B2.1.6,

"Chemistry Control for Secondary Systems Program."

MEAP for auxiliary steam is the same as that for the main steam components as discussed in

Section 3.4B.2.3.1. Since both have the same MEAP combination, the staff finds that

management of loss of material and cracking for stainless steel components using the chemistry

control for secondary systems program to be adequate. The staff reviewed the chemistry control

for secondary systems program and its evaluationi is documented in Section 3.0.3.2.3 of this

SER.

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3.4B.2.3.7 Auxiliary Boiler Condensate and Feedwater - Aging Management Evaluation -

Table 3.4.2-7 and Table 3.4.2-7a

The staff reviewed LRA Table 3.4.2-7 and Table 3.4.2-7a of the applicant's supplement dated

January 11, 2005, which summarizes the results of AMR evaluations for the auxiliary boiler

condensate and feedwater system component groups.

In Table 3.4.2-7 of the LRA and Table 3.4.2-7a of the applicant's letter dated January 11, 2005,

the applicant identified no aging effects for the following stainless steel/carbon steel/low-alloy

steel auxiliary boiler condensate and feedwater system component types exposed externally to

air: auxiliary condensate flash tank, restricting orifices, sample coolers, steam traps, tubing, flow

elements, and radiation detectors.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless steel/carbon steelflow-alloy steel

components exposed externally to air. The staffs evaluation is documented in Section

3.4B.2.3.1 of this SER.

3.4B.2.3.8 Hot Water Heating - Aging Management Evaluation - Table 3.4.2-8

The staff reviewed LRA Table 3.4.2-8, which summarizes the results of AMR evaluations for the

hot water heating system component groups.

In LRA Table 3.4.2-8, the applicant identified no aging effects for the following stainless

steel/carbon steel/low-alloy steel hot water heating system component types exposed externally

to air flex connections, flow elements, pipe, and tubing.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless steel/carbon steel/low-alloy steel

components exposed externally to air. The staff's evaluation is documented in

Section 3.4B.2.3.1 of this SER.

In LRA Table 3.4.2-8, the applicant has identified no aging effects for the copper alloy unit

heaters exposed externally to air.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these copper alloy components in external air.

Its evaluation is documented in Section 3.4.2.3.5 of this SER.

3.4B.2.3.9 Hot Water Pre-Heating - Aging Management Evaluation - Table 3.4.2-9

Summary of Technical Information in the Aimlication. The staff reviewed LRA Table 3.4.2-9,

which summarized the results of AMR evaluations for the hot water pre-heating system

component groups.

In LRA Table 3.4.2-9, the applicant identified no aging effects for the following stainless

steel/carbon steel/low-alloy steel hot water pre-heating system component types exposed

externally to air flow elements, pipe, tubing, and valves.

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On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless steel/carbon steel/low-alloy steel

components exposed externally to air. The staffs evaluation is documented in Section

3.4B.2.3.1 of this SER.

3.4B.2.3.10 Steam Generator Chemical Addition - Aging Management Evaluation -

Table 3.4.2-1 0

The staff reviewed LRA Table 3.4.2-1 0, which summarized the results of AMR evaluations for

the steam generator chemical addition system component groups.

In the LRA Table 3.4.2-1 0, the applicant identified no aging effects for stainless steel pipe and

valves exposed externally to air.

On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless steel/carbon steel/low-alloy steel

components exposed externally to air. The staffs evaluation is documented in Section

3.4B.2.3.1 of this SER.

In LRA Table 3.4.2-10, the applicant proposed to manage loss of material for the stainless steel

pipe exposed externally to an atmosphere/weather environment using MPS AMP B2.1.13,

uGeneral Condition Monitoring Program."

The staff reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The staff finds that this program is acceptable for managing loss

of material since visual inspections of external surfaces are performed during various,

walkdowns.

In LRA Table 3.4.2-1 0, the applicant proposed to manage cracking for the stainless steel piping

and valves exposed internally to a treated water environment using MPS AMP B2.1.25, "Work

Control Process."

The staff reviewed the work control process program and its evaluation is documented in

Section 3.0.3.3.4 of this SER. The work control process provides the opportunity to visually

inspect the internal surfaces of components during preventive and corrective maintenance

activities on an ongoing basis. The work control process provides input to the corrective action

program if aging effects are identified. On the basis of its review, the staff finds that using the

work control process program to manage the aging effect of loss of material for these

components is adequate.

3.4B.2.3.11 Turbine Plant Miscellaneous Drains - Aging Management Evaluation -

Table 3.4.2-11

The staff reviewed LRA Table 3.4.2-11, which summarized the results of AMR evaluations for

the turbine plant miscellaneous drains system component groups.

In LRA Table 3.4.2-11, the applicant identified no aging effects for carbon steel and low-alloy

steel pipe, steam traps, and valves exposed externally to air.

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On the basis that these components have the same previously discussed MEAP combination,

the staff finds that there are no aging effects for these stainless steel components exposed

externally to air. The staffs evaluation is documented in Section 3.4B.2.3.1 of this SER.

The staff reviewed all other AMRs assigned in Tables 3.4.2-1 through 3.4.2-11 of the LRA and

LRA supplements. The staff finds them to be acceptable.

Conclusion. On the basis of its review, the staff finds that the applicant appropriately evaluated

AMR results involving material, environment, aging effect requiring management, and AMP

combinations that are not evaluated in the GALL Report. The staff finds that the applicant has

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21 (a)(3).

3.4B.3 Conclusion

On the basis of its review, the staff concludes that the applicant has demonstrated that the aging

effects associated with the steam and power conversion system components will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the period

of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable FSAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the steam and power

conversion system, as required by 10 CFR 54.21(d).

3.5 Aging Management of Containment. Structures and Component Supports

3.5A Unit 2 Aging Management of Containment. Structures and Component Supports

This section of the SER documents the staffs review of the applicant's AMR results for the

containment, structures and component supports components and component groups

associated with the following structures:

* containment

* structures and structural components:

* Unit 2 containment enclosure building

* Unit 2 auxiliary building

* Unit 2 warehouse building

* Unit 2 turbine building

* Unit I turbine building

* Unit 1 control room and radwaste treatment building

* Unit 2 fire pump house

* Unit 3 fire pump house

* SBO diesel generator enclosure and fuel oil tank vault

* Unit 2 condensate polishing facility and warehouse no. 5

* security diesel generator enclosure

* stack monitoring equipment building

* millstone stack

* switchyard control house

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* retaining wall

* 345kV switchyard

* Unit 2 intake structure

* sea walls

* Unit 2 discharge tunnel and discharge structure

* Unit 2 bypass line

* tank foundations

* yard structures

* NSSS equipment supports

* general structural supports

* miscellaneous structural commodities

* load handling cranes and devices

3.5A.1 Summary of Technical Information in the Application

In LRA Section 3.5, the applicant provided AMR results for containment, structures and

component supports components and component groups. In LRA Table 3.5.1, "Summary of

Aging Management Evaluations in Chapters II and IlIl of NUREG-1801 for Structures and

Component Supports," the applicant provided a summary comparison of its AMRs with the

AMRs evaluated in the GALL Report for the containment, structures and component supports

components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The-applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.5A.2 Staff Evaluation

The staff reviewed LRA Section 3.5 to determine if the applicant provided sufficient information

to demonstrate that the effects of aging for the containment, structures and 'components

supports system components that are within the scope of license renewal and subject to an AMR

will be adequately managed so that the intended functions will be maintained consistent with the

CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

Also, the staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report.' However, the staff did verify that the material presented

in the LRA was applicable and that the applicant had identified the appropriate GALL AMPs. The

staff's evaluations of the AMPs are documented in Section 3.0.3 of this SER. Details of the

staff's audit evaluation are documented in the staffs MPS audit and review report and

summarized in Section 3.5A.2.1 of this SER. ;

The staff also performed an onsite audit of those AMRs that were consistent with the GALL

Report and for which further evaluation is recommended. The' staff verified that the applicant's

further evaluations were consistent with the acceptance criteria in Section 3.5.2.2 of

NUREG-1 800, uStandard Review Plan for Review of License Renewal Applications for Nuclear

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Power Plants," dated July 2001. The staff's audit evaluations are documented in the staffs MPS

audit and review report and summarized in Section 3.5A.2.2 of this SER.

The staff performed an onsite audit and conducted a technical review of the remaining AMRs

that were not consistent with the GALL Report. The audit and technical review included

evaluating whether all plausible aging effects were identified and the aging effects listed were

appropriate for the combination of materials and environments specified. The staffs audit

evaluations are documented in the staffs MPS audit and review report and summarized in

Section 3.5A.2.3 of this SER. The staffs evaluation of its technical review is also documented in

Section 3.5A.2.3 of this SER.

Finally, the staff reviewed the AMP summary descriptions in the FSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the containment, structures and components supports system components.

Table 3.5A-1 below provides a summary of the staffs evaluation of components, aging

effects/mechanisms, and AMPs listed in LRA Section 3.5 that are addressed in the GALL

Report.

Table 3.5A-1 Staff Evaluation for Containment, Structures and Component Supports in the

GALL Report

omponntGAgin EAMP In LR. i Sta-f-f Evatl^ a

1-j :Mechanism Re-. prt- - *:-F -

Common Components of All Types of PWR and BWR Containment

Penetration sleeves, Cumulative fatigue TLAA evaluated in TLAA This TLAA is

penetration bellows, damage(CLB accordance with evaluated in Section

and dissimilar metal fatigue analysis 10 CFR 54.21 (c) 4.6A.

welds exists) (Item Number

3.5.1-01)

Penetration sleeves, Cracking due to Containment Not Consistent with

bellows, and cyclic loading; crack Inservice GALL (See Section

dissimilar metal initiation and growth inspection (ISI) 3.5A.2.2.1)

welds due to SCC and Containment

(Item Number leak rate test

3.5.1-02)

Penetration sleeves, Loss of material due Containment ISI Inservice inspection Consistent with

bellows, and to corrosion and Containment program: containment GALL, which

dissimilar metal leak rate test inspections (B2.1.16) recommends no,

welds further evaluation

(Item Number (See Section

3.5.1-03) . . 3.5A.2.1)

Personnel airlock Loss of material due Containment ISI Inservice inspection Consistent with

and equipment to corrosion and Containment program: containment GALL, which

hatch leak rate test inspections (B2.1.16) recommends no

(Item Number further evaluation'

3.5.1-04) (See Section

._ _3.5A.2.1)

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pConpoientGroup '--'Aging'Effect_- t-AMPln .- 'GALL -2 P in vIR . -Staff Evaluation

- " _ Mechinls --- . e * ' :.'r _

Personnel airlock Loss of leak Containment leak Inservice inspection Consistent with

and equipment tightness In closed rate test and Plant program: containment GALL, which

hatch - position due to Technical Inspections (82.1.16) recommends no

(Item Number mechanical wear of Specifications further evaluation

3.5.1-05) locks, hinges, and (See Section

closure 3.5A.2.1)

mechanisms

Seal, gaskets, and Loss of sealant and Containment ISI Inservice inspection Not Consistent with

moisture barriers leakage through and Containment program: containment GALL (See Section

(Item Number containment due to leak rate test inspections (82.1.16); 3.5A.2.2.1)

3.5.1-06) deterioration of joint . Work control process

seals, gaskets, and (82.1.25)

moisture barriers

PWR Concrete (Reinforced and Prestressed) and Steel Containment

BWR Concrete (Mark 11 and ll) and Steel (Mark l, II, and l1l) Containment

Concrete elements: Aging of accessible Containment ISI Inservice Inspection Consistent with

foundation, dome, and inaccessible program: containment GALL, which

and wall (Item concrete areas due Inspections (82.1.16) recommends further

Number 3.5.1-07) to leaching of evaluation (See

calcium hydroxide, Section 3.5A.2.2.1)

aggressive chemical

attack, and

corrosion of

embedded steel

Concrete elements: Cracks, distortion, Structures Not Consistent with

foundation and Increases in Monitoring * GALL (See Section

(Item Number component stress 3.5A.2.2.1)

3.5.1-08) level due to

settlement

Concrete elements: Reduction In Structures Not Consistent with

foundation foundation strength Monitoring GALL (See Section

(Item Number due to erosion of 3.5A.2.2.1)

3.5.1-09) porous concrete

subfoundation

Concrete elements: Reduction of Plant-specific Not Applicable (See

foundation, dome, strength and Section 3.5A.2.2.1)

and wall (Item modulus due to

Number 3.5.1-10) elevated

temperature

Prestressed Loss of prestress -TLAA evaluated In - TLAA - This TLAA is

containment: due to relaxation, accordance with evaluated in Section

tendons and shrinkage, creep, 10 CFR 54.21(c) 4.5

anchorage and elevated

components temperature

(Item Number

3.5.1-11) . -- .

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'Comj~ori~entGroup . : ^Aging Effe -lH AMPin ,P GALL AMP in LRA - tf aiuationi

.-9 ,-+- '.x3ft Mechanism,,- 'a r-Ž ', aReport----i-> '-'' ; -- ;!>:.i-:-e;!'-".:. 

Steel element: liner Loss of material due Containment ISI Inservice inspection Consistent with

plate and to corrosion in and Containment program: containment GALL, which

containment shell accessible and leak rate test Inspections (82.1.16) recommends further

(Item Number inaccessible areas evaluation (See

3.5.1-12) Section 3.5A.2.2.1)

Steel elements: Loss of material due Protective coating Inservice inspection Not Consistent with

protected by coating to' corrosion In monitoring and program: containment GALL (See Section

(item Number accessible areas maintenance inspections (82.1.16) 3.5A.2.2.1)

3.5.1-14) only

Prestressed Loss of material due Containment ISI Inservice inspection Consistent with

containment to corrosion of program: containment GALL, which

tendons and prestressing inspections (82.1.16) recommends no

anchorage tendons and further evaluation

components anchorage (See Section.

(item Number components 3.5A.2.1)

3.5.1-15)

Concrete elements: Scaling, cracking, Containment ISI Inservice inspection Consistent with

foundation, dome, and spalling due to program: containment GALL, which

and wall freeze-thaw; inspections (82.1.16) recommends no

(Item Number expansion and further evaluation

3.5.1-16) cracking due to (See Section

reaction with 3.5A.2.1)

aggregate

Class I Structures

All Groups except All types of aging Structures Structures monitoring Not Consistent with

Group 6: accessible effects Monitoring program (82.1.23); GALL (See Section

interior/exterior Infrequently accessed 3.5A.2.2.2)

concrete steel areas Inspection

components program (82.1.15)

(Item Number

3.5.1-20) . _

Groups 1-3, 5. 7-9: Aging of Plant-specific Structures monitoring Consistent with

Inaccessible inaccessible program (82.1.23) GALL, which

concrete concrete areas due recommends further

components, such to aggressive evaluation (See

as exterior walls chemical attack, Section 3.5A.2.2.2)

below grade and and corrosion of

foundation embedded steel

(Item Number

3.5.1-21)

Group 6: all All types of aging Inspection of Structures monitoring Not Consistent with'

accessible I effects, including water-control program (82.1.23); GALL (See Section

inaccessible loss of material due structures or Infrequently accessed 3.5A.2.1)

concrete, steel, and to abrasion, FERCIUS Army areas inspection

earthen cavitation, and Corp of Engineers program (B2.1.15)

components corrosion dam inspection

(Item Number and maintenance

3.5.1-22)

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Co pontGroui- pI- - TAMPIn LL n i tEffact ff Eluation n

- -A -T-~ Mecha nismnf : . R6rt A - - ; : .

Group 5: liners Crack initiation and Water chemistry Chemistry control for Consistent with

(Item Number growth due to SCC; and monitoring primary systems GALL, which

3.5.1-23) loss of material due spent fuel pool program (B2.1.5) recommends no

to crevice corrosion water level further evaluation

(See Section

3.5A.2.1)

Groups 1-3,5, 6: all Cracking due to Masonry Wall Structures monitoring Consistent with

masonry block walls restraint, shrinkage, program (B2.123) GALL, which

(Item Number creep, and recommends no

3.5.1-24) aggressive further evaluation

environment (See Section

3.5A.2.1)

Groups 1-3, 5, 7-9: Cracks, distortion, Structures Not Consistent with

foundation and increases in Monitoring GALL (See Section

(Item Number component stress 3.5A.2.2.1)

3.5.1-25) level due to

settlement

Groups 1-3, 5-9: Reduction in Structures Not Consistent with

foundation foundation strength Monitoring GALL (See Section

(Item Number due to erosion of 3.5A.2.2.1)

3.5.1-26) porous concrete . subfoundation

Groups 1-5: Reduction of Plant-specific Not Applicable (See

concrete strength and , Section 3.5A.2.2.1)

(Item Number modulus due to.

3.5.1-27) elevated

temperature

Component Supports

Groups 7, 8: liners Crack initiation and Plant-specific Not Consistent with

(Item Number growth due to SCC; . GALL (See Section

3.5.1-28) loss of material due 3.5A.2.2.2)

to crevice corrosion

All Groups support Aging of component Structures Structures monitoring Not Consistent with

members: anchor supports Monitoring program (82.1.23); GALL (See Section

bolts, concrete - General condition 3.5A.2.2.3)

surrounding anchor monitoring (B2.1.13); bolts, welds, grout Battery rack

pad, bolted Inspections (82.1.1); connections, etc. Infrequently accessed

(Item Number areas Inspection

3.5.1-29) . program (82.1.15)

Groups B1.1, B1.2, Cumulative fatigue TLAA evaluated In TLAA This TLAA is

and B1.3: support damage (CLB accordance with evaluated in Section

members: anchor fatigue analysis 10 CFR 54.21 (c) 4.3A, Metal Fatigue bolts and welds exists) (Item Number

3.5.1-30)

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Component Grupb .-- Agin Ef cn ' AM InGALL -'' D--A - AMP in LR '.'- Sa at auation im ffen ;.-.'- -- -- .pr I i M ;___;__':_'___to_-j 

All Groups: support Loss of material due Boric acid Boric Acid Corrosion Not Consistent with

members: anchor to boric acid corrosion (B2.1.3); GALL

bolts and welds corrosion General Condition (See Section

(Item Number Monitoring (B2.1.13) 3.5A.2.3.25)

3.5.1-31)

Groups B13.1, B13.2, Loss of material due ISI Inservice inspection Consistent with

and B13.3: support to environmental program: systems, GALL, which

members: anchor corrosion; loss of components and recommends no

bolts, welds, spring mechanical function supports (B2.1.18); further evaluation

hangers, guides, due to corrosion, Structures monitoring (See Section

stops, and vibration distortion, dirt, program (B2.1.23); 3.5A.2.1) isolaters overload, etc. General condition

(Item Number monitoring (B2.1.13)

3.5.1-32)

Group B1.1: high Crack initiation and Bolting integrity Not Consistent with

strength low-alloy growth due to SCC GALL

bolts (See Section

(Item Number 3.5A.2.3.24)

3.5.1-33)

The staffs review of the MPS containment, structures and component supports and associated

components followed one of several approaches. One approach, documented in Section

3.5A.2. 1, involves the staffs review of the AMR results for components in the containment,

structures and component supports that the applicant indicated are consistent with the GALL

Report and do not require further evaluation. Another approach, documented in Section

3.5A.2.2, involves the staff's review of the AMR results for components in the containment,

structures and component supports that the applicant indicated are consistent with the GALL

Report and for which further evaluation is recommended. A third approach, documented in

Section 3.5A.2.3, involves the staff's review of the AMR results for components in the

containment, structures and component supports that the applicant indicated are not consistent

with the GALL Report or are not addressed in the GALL Report. The staff's review of AMPs that

are credited to manage or monitor aging effects of the containment, structures and component

supports components is documented in Section 3.0.3 of this SER.

3.5A.2.1 AMR Results ThatAre Consistent with the GALL Report, for Which Further

Evaluation is Not Recommended

Summary of Technical Information in the Application. In Sections 3.5.2.1.1 through 3.5.2.1.27 of

the LRA, the applicant identified the materials, environments, and aging effects requiring

management. The applicant identified the following programs that manage the aging effects

related to the containment, structures and component supports components:

* boric acid corrosion program

* chemistry control for primary systems program

* general condition monitoring program

* inservice inspection program: containment inspections

* structures monitoring program

* work control process program

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* Boraflex monitoring program

* infrequently accessed areas inspection program

* inservice inspection program: systems, components and supports

* ebattery rack inspections

* fire protection program

* inspection activities: load handling cranes and devices

Staff Evaluation. In Tables 3.5.2-1 through 3.5.2-27 of the LRA, the applicant provided a

summary of AMRs for the containment and containment intemals, auxiliary building, turbine'

building and intake structure, yard structures, and structural commodities, and identified which

AMRs it considered to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these component groups were bounded by the GALL Report

evaluation.

The applicant provided a note for each AMR line item. The notes described how the information

in the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicated the AMR was consistent with the GALL Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the'AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been,

reviewed and accepted by the staff. The staff also determined whether the AMP identified by the

applicant was consistent with the AMP identified in the GALL Report and whether the AMR was

valid for the site-specific conditions.

Note C indicated that the component for the AMR line item is different, but consistent with the

GALL Report for material, environment, and aging effect. In'addition, the AMP is consistent with

the AMP identified by the GALL Report. This note indicates that the applicant was unable to find

a listing of some system components in the GALL Report. However, the applicant identified a'

different component in the GALL Report that had the same material, environment, aging effect,

and AMP as the component that was under review. The staff audited these line items to verify

consistency with the GALL Report. The staff also determined whether the AMR line item of the

different component was applicable to the component under review and whether the AMR was

valid for the site-specific conditions.

Note D indicated that the component for the AMR line item is different, but consistent with the

GALL Report for material, environment, and aging effect. In addition, the AMP takes some

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exceptions to the AMP identified in the GALL Report. The staff audited these line items to verify consistency with the GALL Report. The staff verified whether the AMR line item of the different

component was applicable to the component under review. The staff verified whether the

identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The staff also determined whether the AMP identified by the applicant was consistent with the AMP

identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note E indicated that the AMR line item is consistent with the GALL Report for material, environment, and aging effect, but a different aging management program is credited. The staff audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified by the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the LRA, as documented in its MPS audit and review report. The staff did not repeat its review of the matters described in

the GALL Report. However, the staff did verify that the material presented in the LRA was

applicable and that the applicant had identified the appropriate GALL Report AMRs. The staff

evaluation is discussed below.

3.5A.2.1.1 Aging of Component Supports

In LRA Table 3.5.2-25 (page 3-535), the applicant stated that the loss of material of carbon steel and low-alloy steel for structural support components in an air or atmosphere/weather environment is managed by MPS AMP B2.1.15, uInfrequently Accessed Areas Inspection Program," MPS AMP B2.1.23, Structures Monitoring Program," and MPS AMP B2.1.13, "General Condition Monitoring," and GALL that Item lIl.B2.1-a is matched. During the audit and

review, the staff asked the applicant to explain why Note E was used for the infrequently accessed areas inspection program, Note A used for the structures monitoring program, and Note C used for the general condition monitoring program. The applicant stated that Note C was incorrectly applied to the general condition monitoring line items. Note A should have been applied since the general condition monitoring program performs the same inspections of

structural supports as the structures monitoring program and is considered equivalent to GALL AMP Xl.S6 "Structures Monitoring Program." MPS AMP B2.1.23 is used to manage aging of, non-ASME class, large equipment supports; and MPS AMP B2.1.13 is used to manage aging of other non-ASME class supports.

In an LRA supplement dated July 7, 2004, the applicant stated that Note C should be Note A for the general condition monitoring line items in LRA Table 3.5.2-25 (pages 3-532 through 3-538) since the general condition monitoring program performs the same inspections of structural

supports as the structures monitoring program and is considered equivalent to GALL AMP XI.S6, "Structures Monitoring Program."

On the basis of its review of the applicant's response, the staff finds the response to be

acceptable.

On the basis of its audit and review, the staff determined that for AMRs not requiring further

evaluation, as identified in LRA Table 3.5.1 (Table 1), the applicant's references to the GALL

Report are acceptable, that the line items are consistent with GALL, and no further staff review

is required.

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Staff RAls Pertaining to Recent Ooerating Experience and Emerging Issues. Because the GALL

Report and SRP-LR were issued in July 2001, these documents do not reflect the most current

recommendations for managing certain aging effects that have been the subject of recent

operating experience or the topic of an emerging issue. As a result, the staff issued RAls to

determine how the applicant proposed to address these items for license renewal. The

applicant's responses to these RAls, and the staff's evaluations of the responses, are

documented as follows.

In RAI 3.5-5, the staff requested information about the members of structures other than

containments that uses the structures monitoring program as an AMP. Under column "Structural

Member" in Table 3.5.2-x, structures and component supports, structures monitoring program is

listed as an AMP for many structural members, such as doors, sliding bearings, metal siding

sealants, roofing, siding, scuppers, miscellaneous steel, expansion joint/seismic gap material,

and flood door/gate gasket. Item 18 in Table A6.0-1, License Renewal Commitments,

states,"The Structures Monitoring Program and implementing procedures will be modified to

include all in-scope structures." The staff assumes that the words "in-scope structures" include

all structural members listed in Table 3.5.2-x that use the structures monitoring program as an

AMP. Please confirm whether the staffs assumption is correct or not.

By letter dated November 9, 2004, the applicant stated that this assumption is correct. Any in

scope structural members that are not currently in the structures monitoring program, such as

those listed above, but are required to be inspected, will be added to the program prior to the

period of extended operation. -

The staff finds the applicant's response acceptable.

In RAI 3.5-6, the staff requested information about the work control process AMP. The work

control process is listed as an AMP for many structural members, such as the rubber seal of the

spent fuel pool gate, the carbon steel sump liner, and the neoprene gaskets in junction, terminal,

and pull boxes. The staff did not find that these structural members were included in the scope

of program of the b2.1.25 work control process or that Table A6.0-1 lists these structural

members in the work control process as a license renewal commitment. The applicant was

asked to explain how the work control process includes and tracks the structural members listed

in Table 3.5.2-x that use the work control process as an AMP.

The applicant stated that the work control process inspects materials and environments in lieu of

specific component types. Inspections are performed as part of preventive maintenance,

corrective maintenance, predictive analysis, periodic surveillance, etc. A review of the work

control process inspection opportunities for each material and environment group that is in

scope of License Renewal was performed for Millstone Units 2 and 3. It demonstrated adequate

inspection opportunities for the vast majority of material and environment combinations. A review

of the work control process inspection opportunities for each material and environment group

supplemental to the initial review conducted during the development of the LRA will be

performed. Baseline inspections will be performed for the material and environment

combinations that have not been inspected as part of the work control process. This

commitment is identified in Appendix A, Table A6.0-1 License Renewal Commitments, Item 30

(Unit 2) and 31 (Unit 3). These inspections will address the above item if no opportunity for

inspection has been provided, prior to the period of extended operation. Unacceptable inspection

results will be identified in the corrective action process. Corrective actions will consider the

3435'
extent of condition of all component types included in that material and environment

combination.

The staff finds the applicant's response acceptable. The staff evaluation of the work control

process AMP is documented in Section 3.0.3.3.4.

In RAI 3.5-11, the staff requested the applicant to discuss whether Millstone Units 2 or 3 had

piping and component supports that are anchored to concrete by using bolts with yield strength

greater than 150 ksi? If yes, identify the AMP for those bolts and provide basis for the selection

of the AMP if Bolting Integrity program is not selected.

By letter dated November 9, 2004, the applicant stated that no piping or component supports in

Millstone Unit 2 or 3 have been identified as being anchored to concrete using anchor bolts with

specified yield strengths greater than 150 ksi.

The staff finds the applicant's response acceptable.

As a result of issues raised during the scoping and screening methodology audit (discussed in

Section 2.1.3.1), the staff requested additional information concerning newly in scope structures.

The following is a discussion of the applicant's responses and the staff evaluations.

In response to RAI 2.4-7 (Unit 2) and RAI 2.4-11 (Unit 3), the applicant stated that the posttensioned anchorage system for the sea walls is within the scope of license renewal and the

AMR result concluded that there are no aging effects requiring management. The staff reviewed

the anchorage detail, as shown in FSAR Figure 2.5-15, and found that there are sufficient

concrete surrounding the post-tensioned anchorage system to protect it from the environment

and, therefore, concurs with the applicant's conclusion.

In response to RAI 2.4-1, the applicant added the condensate polishing service water strainer

house to the scope of license renewal and stated that the aging effects are loss of material,

cracking, and change of material properties for concrete and they will be monitored by the

structures monitoring program AMP. The staff concurs with the applicant's proposal.

In response to RAI 2.4-1, the applicant added Unit 2 hydrogen cylinder storage area (building

226) to the scope of license renewal. The structural members of the building consists of

reinforced concrete in soil and atmosphere/weather environments and masonry block walls in an

atmosphere/weather environment. The applicant stated that the aging effects are loss of

material, cracking, and change of material properties for concrete and cracking for masonry

block walls, and they will be monitored by the structures monitoring program AMP. The staff

concurs with the applicant's proposal.

In response to RAI 2.4-2, the applicant added Unit 2 sodium hypochlorite building to the scope of

license renewal. The structure consists of structural reinforced concrete in soil, air, and

atmosphere/weather environments and structural steel members in air. The applicant stated that

the aging effects are loss of material, cracking, and change of material properties for concrete

and loss of material for structural steel, and they will be monitored by the structures monitoring

program AMP which is described in LRA Section B2.1.23. The staff concurs with the applicant's

proposal.

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In response to RAI 2.4-3, the applicant added thermal insulation around high temperature piping

containment penetrations to the scope of license renewal. The applicant's AMR result concluded

that there are no aging effects for the fiberglass, asbestos, and calcium silicate piping

penetration thermal insulation. However, the applicant stated that the localized concrete

temperature in the vicinity of high energy piping containment penetrations is maintained below

the threshold value by the containment penetration cooling system, which consists of a

ventilation system in Unit 2 (the containment penetration cooling system described in LRA

Section 2.3.3.18) and a water cooling system in Unit 3 (as part of the reactor plant component

cooling system described in LRA Section 2.3.3.6); Since the concrete temperature around the

containment penetration is properly maintained, the staff considers the applicant's proposal

acceptable.

In response to RAI 2.4-5, the applicant added the sealant and the penetration seals component

types to the scope of license renewal, and stated that they will be monitored by the containment

inspection AMP as modified by the response to RAI 3.5-1 provided in' Dominion letter dated

November 9, 2004. The staff accepts the AMP as discussed in Section 3.5A.2.3.1 and

3.5B.2.3.1 of this SER.

The staff accepts the applicant's clarification.

On the basis of its audit and review, the staff determined that, for AMRs not requiring further

evaluation, as identified in LRA Table 3.5.1 (Table l), the applicant's references to the GALL

Report are acceptable, the line items are consistent with GALL, and no further staff review is

required. On the basis of its audit and review, the staff concludes that the applicant has

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21 (a)(3).

Conclusion. The staff has evaluated the applicant's claim of consistency with GALL Report. The

staff also has reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff finds that the AMR results, which the applicant claimed to be consistent with the GALL

Report, are consistent with the AMRs in the GALL Report. Therefore, the' staff finds that the

applicant has demonstrated that the effects of aging for these components will be adequately

managed so that their intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.5A.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation Is Recommended

Summary of Technical Information in the Application. In Section 3.5.2.2 of the LRA, the applicant

provides further evaluation of aging management as recommended by the GALL Report for

containment, structures and component supports. Specifically, the applicant provided

information concerning how it will manage the following aging effects:

aging of inaccessible concrete'areas

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v cracking, distortion, and increase in component stress level due to settlement; reduction

of foundation strength due to erosion of porous concrete subfoundations, if not covered

by structures monitoring program

* reduction of strength and modulus of concrete structures due to elevated temperature

* loss of material due to corrosion in inaccessible areas of steel containment shell or liner

plate

* loss of prestress due to relaxation, shrinkage, creep, and elevated temperature

* cumulative fatigue damage

* cracking due to cyclic loading and SCC

* aging of structures not covered by structures monitoring program

* aging management of inaccessible areas

* aging of supports not covered by structures monitoring program

* cumulative fatigue damage due to cyclic loading

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff reviewed the applicant's evaluation to determine whether it

adequately addressed the issues that were further evaluated. In addition, the staff audited the

applicant's further evaluations against the criteria contained in Section 3.5.2.2 of the Standard

Review Plan for License Renewal. Details of the staffs audit and review are documented in the

staff's MPS audit and review report.

The GALL Report indicates that further evaluation should be performed for the aging effects

described in the following sections of this SER.

3.5A.2.2.1 PWR Containments

The staff reviewed LRA Section 3.5.2.2.1 against the criteria in SRP-LR Section 3.5.2.2.1, which

addresses several areas discussed below.

Aging of Inaccessible Concrete Areas. In LRA Section 3.5.2.2.1.1, the applicant addressed

aging of inaccessible concrete areas of the containment.

For inaccessible portions of the containment structure, 10 CFR 50.55a(b)(2)(ix) requires that the

applicant evaluate the acceptability of inaccessible areas when conditions exist in accessible

areas that could indicate the presence of, or result in, degradation to inaccessible areas.

The AMP recommended by the GALL Report for managing the aging of the accessible portions

of the containment structures is GALL AMP XI.S2, "ASME Section Xl, Subsection IWL." The

applicant addressed this with MPS AMP B2.1.16, "Inservice Inspection Program: Containment

Inspections." The staff reviewed the inservice inspection program: containment inspections

program and its evaluation is documented in Section 3.0.3.2.11 of this SER. ASME

Subsection IWL exempts from examination those portions of the concrete containment that are

inaccessible (e.g., foundation, below-grade exterior walls, or concrete covered by liner).

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The applicant also used MPS AMP B2.1.23, "Structures Monitoring Program," to monitor

accessible areas for evidence of aging effects that may be applicable to containment structures.

This program, which is consistent with GALL AMP XI.S6, 'Structures Monitoring Program," with

enhancements, was reviewed by the staff and its evaluation is documented Section 3.0.3.2.16 of

this SER. The applicant also credited the structures monitoring program for the examination of

below-grade concrete when it is exposed by excavation.

In the GALL Report, Volume 2, Chapter II, Table Al (as modified by ISG-3), further evaluation is

recommended to manage the aging effects for containment concrete components located in

inaccessible areas if the aging mechanisms of.(1) freeze-thaw, (2) leaching of calcium

hydroxide, (3) aggressive chemical attack, (4) reaction with aggregates, or (5) corrosion of

embedded steel are significant. Possible aging effects for containment concrete structural

components due to these five aging mechanisms are cracking, change in material properties,

and loss of material.

(1) Freeze-thaw - SRP-LR Section 3.5.2.2.1.1 does not address freeze-thaw as an aging

mechanism for concrete containments because no further evaluation is recommended in

the GALL Report. However, ISG-3, "Chapters 11 and IlIl of GALL Report on Aging

Management of Concrete Elements," dated November 21, 2003, clarified the staffs

position that further evaluation is appropriate if the applicant's facility is subject to ,

moderate to severe weather conditions unless the concrete meets certain specifications

and subsequent inspections have confirmed that the aging mechanism has not caused

degradation of the concrete.

MPS is located in a region considered to be subject to severe weather conditions. In the

LRA, the applicant stated that Unit 2 concrete structures are designed in accordance with

ACI specification 318-63, "Building Code Requirements for Reinforced Concrete," which

results in low permeability and resistance to aggressive chemical solutions by requiring

the following:

* high cement content

* low water-to-cement ratio

* proper curing

* adequate air entrainment

In the LRA, the applicant stated that Unit 2 concrete also meets requirements of the

guideline ACI 201.2R-77, "Guide to Durable Concrete." ACI 318-63 and ACI 201.2R-77

use the same ASTM standards for selection, application, and testing of concrete. . ,;-

During the audit and review, the staff interviewed members of the applicant's technical

staff and reviewed relevant operating experience to confirm that loss of material from

freeze-thaw has not been observed, either through the inservice inspection - IWL:

program or the structures monitoring program.

On the basis of its review, the staff finds that loss of material and cracking due to

freeze-thaw will be adequately managed by the containment inservice inspection

program because: (1) concrete that satisfies the requirements of ACI 318-63 will meet

the recommendations of ISG-3, (2) an audit of operating experience evaluated under-the

inservice inspection program: containment inspections and structures monitoring

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programs, and (3) the containment structure is protected from the elements by an

enclosed structure.

(2) Leaching of calcium hydroxide - SRP-LR Section 3.5.2.2.1.1 states that cracking,

spalling, and increases in porosity and permeability due to leaching of calcium hydroxide

could occur in inaccessible areas of PWR concrete and steel containments. The GALL

Report, as updated by ISG-3, recommends further evaluation of plant-specific programs

to manage the aging effects for inaccessible areas if specific criteria cannot be satisfied.

The GALL Report states that leaching of calcium hydroxide becomes significant only if

the concrete is exposed to flowing water. Even if reinforced concrete is exposed to

flowing water, such leaching is not significant if the concrete is constructed to ensure that

it is dense, well-cured, has low permeability, and that cracking is well controlled.

In the LRA, the applicant stated that the Unit 2 concrete structures are designed in

accordance with specification ACI 318-63 and meet the requirements of guideline

ACI 201.2R-77.

The staff finds that because ACI 318-63 and ACI 201.2R-77 provide assurance that the

criteria of the GALL Report and ISG-3 are met, leaching of calcium hydroxide is not

significant at Unit 2, and therefore concludes that the inservice inspection program:

containment inspections program will be sufficient to manage increases in porosity and

permeability from this aging mechanism. A plant-specific aging management program is

not required to address this aging effect.

(3) Aggressive chemical attack - SRP-LR Section 3.5.2.2.1.1 states that cracking, spalling,

and increases in porosity and permeability due to aggressive chemical attack could occur

in inaccessible areas of PWR concrete and steel containments. The GALL Report

recommends further evaluation of plant-specific programs to manage the aging effects

for inaccessible areas if specific criteria defined in the GALL Report and updated in

ISG-3 cannot be satisfied.

The GALL Report, as updated by ISG-3, states that aggressive chemical attack is not

significant unless pH is less than 5.5, chlorides are greater than 500 ppm, or sulfates are

greater than 1,500 ppm. ISG-3 also states that a plant-specific program is required to

examine representative samples of below-grade concrete when excavated for any

reason.

In the LRA, the applicant stated that the below-grade environment is not aggressive (pH

is greater than 5.5, chlorides are less than 500 ppm, and sulfates are less than

1,500 ppm). In addition, the staff noted that the applicant uses the structures monitoring

program to examine below-grade concrete when it is exposed by excavation.

On the basis of the information provided in the LRA and the guidelines provided in the

SRP-LR, the GALL Report, and ISG-3, the staff finds that increases in porosity andpermeability, loss of material (spalling, scaling), and cracking due to aggressive chemical

attack are not significant for concrete in inaccessible areas of the Unit 2 containment.

The applicant uses MPS AMP B2.1.23, Structures Monitoring Program," to test the

groundwater on a periodic basis, considering seasonal variations, to ensure the aging

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mechanism of aggressive chemical attack does not become significant in the future and

also to examine below-grade concrete when it is exposed by excavation. The staff

reviewed the structures monitoring program and its evaluation is documented in Section

3.0.3.2.16 of this SER. The staff finds that the structures monitoring program is an

appropriate program for examination of below-grade concrete when it becomes

accessible.

(4) Reaction with aggregates - SRP-LR Section 3.5.2.2.1.1 does not address reaction with

aggregates as an aging mechanism for concrete containments because no further

evaluation is recommended in the GALL Report. However, ISG-3 clarified the staff's

position that further evaluation is appropriate if investigations, tests, or examinations

have demonstrated that the aggregates are reactive.

In the LRA, the applicant stated that Unit 2 concrete structures are designed in

accordance with specification ACI 318-63 and meet the recommendations of guideline

ACI 201.2R-77. The ACI standard specifies the'testing of aggregates at the time of

construction.

Through interviews with the applicant's technical staff, the staff confirmed that the results

of those tests show that the aggregates used for the Unit 2 concrete containment at MPS

are not reactive. The staff finds that this aging effect does not require management at

MPS. However, the applicant stated, in the LRA, that it will manage change of material

properties as a potential aging effect on concrete structures. In the LRA, the applicant

stated that change of material properties for the Unit 2 containment due to alkali

(cement)-aggregate reaction of concrete in an air environment is managed by AMP

B2.1.16, "Inservice Inspection Program: Containment Inspections," and AMP B2.1.23

"Structures Monitoring Program." The staff reviewed these programs and its evaluations

are documented in Sections 3.0.3.2.11 and 3.0.3.2.16 of this SER, respectively.

(5) Corrosion of embedded steel - SRP-LR Section 3.5.2.2.1.1 states that loss of material

due to corrosion of embedded steel could occur in inaccessible areas of PWR concrete

and steel containments. The GALL Report (updated in ISG-3) recommends further

evaluation of plant-specific programs to manage the aging effects for inaccessible areas

if specific criteria defined in the GALL Report cannot be satisfied.

For cracking, loss of bond, and loss of material (spalling, scaling) due to corrosion of

embedded steel, the GALL Report states that a plant-specific'program is only required if'

the below-grade environment is aggressive. ISG-3 also states that a plant-specific

program is required to examine representative samples of below-grade concrete when

excavated for any reason.

In the LRA, the applicant stated that the below-grade environment is not aggressive (pH

greater than 5.5, chlorides less than 500 ppm, and sulfates less than 1,500 ppm). The

staff noted that the applicant credited the structures monitoring program for the

examination of below-grade concrete when it is exposed by excavation. In addition, the

applicant committed, in its structures monitoring program, to periodically monitor

below-grade chemistry to ensure that the groundwater is not sufficiently aggressive to

cause the below-grade concrete to degrade.

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The staff finds that in accordance with the criteria of the GALL Report this aging effect is

not significant and is adequately managed.

The staff reviewed the results of the applicant's AMR for inaccessible concrete areas. On

the basis of its audit and review, the staff finds that the applicant appropriately evaluated

AMR results involving management of aging of inaccessible concrete areas for the

containment, as recommended in the GALL Report and ISG-3. Since the applicant's AMR results are otherwise consistent with the GALL Report, the staff finds that the

applicant has demonstrated that the effects of aging will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of

extended operation, as required byA10 CFR 54.21(a)(3).

Cracking. Distortion, and Increase in Component Stress Level Due to Settlement: Reduction of

Foundation Strength Due to Erosion of Porous Concrete Subfoundations. if Not Covered by Structures Monitoring Program In LRA Section 3.5.2.2.1.2, the applicant addressed (1) cracking, distortion, and increase in component stress level due to settlement, and (2) reduction of

foundation strength due to erosion of porous concrete subfoundations in the containment.

SRP-LR Section 3.5.2.2.1.2 states that cracking, distortion, and increase in component stress

level due to settlement could occur in PWR concrete and steel containments. Also, reduction of

foundation strength due to erosion of porous concrete subfoundations could occur in all types of

PWR containments. Some plants may rely on a'de-watering system to lower the site ground water level. If the plant's CLB credits a de-watering system, the GALL Report recommends

verification of the continued functionality of the de-watering system during the period of extended

operation. The GALL Report recommends no further evaluation if this activity is included in the

scope of the applicant's structures monitoring program.

The applicant stated, in the LRA, that aging effects (cracking, distortion, and increase in

component stress level) due to settlement, and reduction of foundation strength due to erosion

of porous concrete subfoundations are not expected at Unit 2. The applicant also stated that

Unit 2 structures are founded on bedrock, well-consolidated in-situ material, or compacted fill.

No structures utilize porous concrete subfoundations. Unit 2 has no de-watering system.

On the basis of its review, the staff concluded that foundation settlement is not an aging mechanism at Unit 2.

Reduction of Strenqth and Modulus of Concrete Structures Due to Elevated Temnerature. In

LRA Section 3.5.2.2.1.3, the applicant addressed reduction of strength and modulus of concrete

structures due to elevated temperature in containment.

SRP-LR Section 3.5.2.2.1.3 states that reduction of strength and modulus of elasticity due to

elevated temperatures could occur in PWR concrete and steel containments. The GALL Report calls for a plant-specific aging management program and recommends further evaluation if any portion of the concrete containment components exceeds specified temperature limits (i.e., general area temperature 660C (1 50°F) and local area temperature 930C (2000F)).

I

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In LRA Section 3.5.2.2.1.3, the applicant stated that during normal operation, all areas within the

containment building do not experience elevated temperatures greater than 150 IF general and

greater than 200 'F local. Therefore, change in material properties due to elevated temperature

is an aging effect not requiring management for the Unit 2 containment concrete.

On the basis of its review, the staff concurred with the applicant and concluded that change in

material properties due to elevated temperature is an aging effect not requiring management for

the Unit 2 containment concrete.

Loss of Material Due to Corrosion in Inaccessible Areas of Steel Containment Shell or Liner

Plate. In LRA Section 3.5.2.2.1.4, the applicant addressed loss of material due to corrosion in

inaccessible areas of the steel containment shell or the steel liner plate for the containment.

SRP-LR Section 3.5.2.2.1.4 states that loss of material due to corrosion could occur in

inaccessible areas of the steel containment shell or the steel liner plate for all types of PWR

containments. The GALL Report recommends further evaluation of plant-specific programs to

manage this aging effect for inaccessible areas if the following specific criteria defined in the

GALL Report cannot be satisfied: (1) concrete meeting the requirements of ACI 318 or ACI 349

and the guidance of ACI 201.2R was used for the containment concrete in contact with the

embedded containment shell or liner; (2) the accessible concrete is monitored to ensure that it is

free of penetrating cracks that provide a path for water seepage to the surface of the

containment shell or liner; (3) the accessible portion of the moisture barrier, at the junction where

the shell or liner becomes embedded, is subject to aging management activities in accordance

with ASME Subsection IWE requirements; (4) borated water spills and water ponding on the

containment concrete floor are not common and when detected are cleaned up in a timely

manner.

In the LRA, the applicant stated that the containment concrete in contact with the steel liner plate

is designed in accordance with ACI 318-63, and meets the recommendations or criteria of

guideline ACI 201.2R-77. Accessible concrete of the containment structure is monitored for

penetrating cracks under MPS AMP B2.1.16, t nservice Inspection Program: Containment

Inspections." In addition, the applicant stated, in the LRA, that the accessible portions of the,

steel liner plate and moisture barrier where the liner becomes embedded are inspected in

accordance with MPS AMP B2.1.16, "Inservice Inspection Program: Containment Inspections."

Spills (e.g., borated water spill) are cleaned up in a timely manner. The aging effect of loss of

material due to corrosion has not been significant for the Unit 2 liner plate. The staff reviewed

the inservice inspection program: containment inspections program, with exceptions, and its

evaluation is documented in Section 3.0.3.2.11 of this SER.

On the basis of its review, the staff finds that all of the criteria identified in the GALL Report are

satisfied. The staff finds that no additional, plant-specific aging management program is required

to manage inaccessible areas of the steel containment liner plate.

On the basis of its audit and review, the staff finds that the applicant appropriately evaluated

AMR results involving loss of material due to corrosion in inaccessible areas of the steel

containment shell or the steel liner plate, as recommended in the GALL Report. Since the

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applicant's AMR results are otherwise consistent with the GALL Report, the staff finds that the

applicant has demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

Loss of Prestress Due to Relaxation. Shrinkage. Creep. and Elevated Temperature. As stated in

SRP-LR, loss of prestress due to relaxation, shrinkage, creep, and elevated temperature is a

TLAA, as defined in 10 CFR 54.3, and TLAAs must be evaluated in accordance with

10 CFR 54.21 (c)(1). The staff documents its review of the applicant's evaluation of this TLAA in

Section 4.5.of this SER. In performing this review, the staff followed the guidance in Section 4.5

of the SRP-LR.

Cumulative Fatigue Damage. As stated in the SRP-LR, fatigue is a TLAA, as defined in

10 CFR 54.3. Applicants must evaluate TLAAs in accordance with 10 CFR 54.21(c)(1). Section

4.3 of this SER documents the staffs review of the applicant's evaluation of this TLAA. In

performing this review, the staff followed the guidance in Section 4.3 of the SRP-LR.

Cracking Due to Cyclic Loading and Stress Corrosion Cracking. In LRA Section 3.5.2.2.1.7, the

applicant addressed aging mechanisms that can lead to cracking of penetration sleeves and

penetration bellows, such as cyclic loads and SCC.

SRP-LR Section 3.5.2.2.1.7 states that cracking of containment penetrations (including penetration sleeves, penetration bellows, and dissimilar metal welds) due to cyclic loading or

SCC could occur in containments. Further evaluation of inspection methods is recommended to

detect cracking due to cyclic loading and SCC, since visual VT-3 examinations may be unable to

detect this aging effect.

In LRA Section 3.5.2.2.1.7, the applicant stated that SCC is applicable to carbon and low-alloy steel in air only if the fabrication material is high yield-strength steel. SCC of stainless steel in air

is only applicable to sensitized stainless steel that is exposed to intermittent wetting. Unit 2

containment penetrations, including penetration sleeves, bellows, and dissimilar metal welds, are

not fabricated from high yield-strength steel and the stainless steel materials are not subject to

intermittent wetting. Therefore, the applicant concluded that cracking due to SCC does not

require aging management for the Unit 2 containment.

The staff reviewed and concurred with the applicant that cracking due to SCC is not an

applicable aging effect for the Unit 2 containment, and augmented inspection to detect cracking is not necessary.

Cracking due to cyclic loading of the liner plate and penetrations is a TLAA which is evaluated

and addressed in Section 4.6 of this SER.

On the basis of its audit and review, the staff finds that the applicant appropriately evaluated

AMR results involving management of cracking due to SCC for containment components, as

recommended in the GALL Report. Since the applicant's AMR results are otherwise consistent

with the GALL Report, the staff finds that the applicant has demonstrated that the effects of

aging will be adequately managed so that the intended functions will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

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3.5A.2.2.2 Class 1 Structures

The staff reviewed LRA Section 3.5.2.2.2 against the criteria in SRP-LR Section 3.5.2.2.2, which

addressed several areas discussed below.

Aging of Structures Not Covered by Structures Monitoring Program. In LRA Section 3.5.2.2.2.1,

the applicant addressed aging of Class 1 structures not covered by the structures monitoring

program.

SRP-LR Section 3.5.2.2.2.1 states that the GALL Report recommends further evaluation of

certain structure/aging effect combinations if they are not covered by the structures monitoring

program. This is described in GALL Report Chapter III and includes (1) scaling, cracking, and

spalling due to repeated freeze-thaw for Groups 1-3, 5, and 7-9 structures; (2) scaling, cracking,

spalling and increase in porosity and permeability due to leaching of calcium hydroxide and

aggressive chemical attack for Groups 1-5 and 7-9 structures; (3) expansion and cracking due to

reaction with aggregates for Groups 1-5 and 7-9 structures; (4) cracking, spalling, loss of bond,

and loss of material due to corrosion of embedded steel for Groups 1-5 and 7-9 structures; (5)

cracks, distortion, and increase in component stress level due to settlement for Groups 1-3, 5,

and 7-9 structures; (6) reduction of foundation strength due to erosion of porous concrete

subfoundations for Groups 1-3 and 5-9 structures; (7) loss of material due to corrosion of -

structural steel components for Groups 1-5 and 7-8 structures; (8) loss of strength and modulus

of concrete structures due to elevated temperatures for Groups 1-5 structures; and (9) crack

initiation and growth due to SCC and loss of material due to crevice corrosion of stainless steel

liner for Groups 7 and 8 structures. Further evaluation is necessary only for structure/aging

effect combinations not covered by the structures monitoring program.

Technical details of the aging management issue are presented in SRP-LR

Subsection 3.5.2.2.1.2 for structure/aging effect combinations Items (5) and (6) and SRP-LR

Subsection 3.5.2.2.1.3 for Item (8), above.

In LRA Table 3.5.1, Item 3.5.1-20 (page 3-432); the applicant credited MPS AMP B2.1.23,

"Structures Monitoring Program," for all types of aging effects and all component groups,-except

Group 6, of accessible interior and exterior concrete and steel components of Class 1 structures.

The staff reviewed the structures monitoring program and its evaluation is documented

Section 3.0.3.2.16 of this SER. Additional discussion of specific structure/aging effect

combinations follows. . -

(1) Freeze-thaw - SRP-LR Section 3.5.2.2.2.1 addresses freeze-thaw as an aging

mechanism for Class 1 structures. ISG-3 clarifies the staff position that further evaluation

is appropriate if the applicant's facility is subject to moderate to severe weather

conditions, unless the concrete meets certain specifications and subsequent inspections

have confirmed that the aging mechanism has not caused degradation of the concrete.

MPS is located in a region considered .to be subject to severe weather conditions. In the

LRA, the applicant stated that Unit 2 structures are designed in accordance with

specification ACI 318-63, which results in low permeability and resistance to aggressive

chemical solutions by requiring the following:

* high cement content

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* low water-to-cement ratio

* proper curing

* adequate air entrainment

In addition to ACI 318-63, the applicant stated that Unit 2 concrete also meets the

guideline of ACI 201.2R-77. ACI 318-63 and ACI 201.2R-77 use the same ASTM

standards for selection, application, and testing of concrete.

The staff interviewed members of the applicant's technical staff and reviewed relevant

operating experience to confirm that loss of material from freeze-thaw has not been

observed through MPS AMP 62.1.23, 'Structures Monitoring Program." The staff

reviewed the structures monitoring program and its evaluation is documented in Section

3.0.3.2.16 of this SER.

Because the concrete satisfies the criteria of ACI 318-63 will meet the requirements of

ISG-3, and on the basis of an audit of operating experience evaluated under the

structures monitoring program, the staff finds that loss of material and cracking due to

freeze-thaw will be adequately managed by the structures monitoring program.

(2a) Leaching of calcium hydroxide - SRP-LR Section 3.5.2.2.2.1 states that cracking, spalling, and increases in porosity and permeability due to leaching of calcium hydroxide could occur in Class 1 structures. The GALL Report requires a plant-specific AMP for

inaccessible areas, unless the criteria of ACI 201.2R-77 for Class 1 structural concrete

are met.

The GALL Report states that leaching of calcium hydroxide becomes significant only if

the concrete is exposed to flowing water. Even if reinforced concrete is exposed to

flowing water, such leaching is not significant if the concrete is constructed to ensure that

it is dense, well-cured, has low permeability, and that cracking is well controlled.

In the LRA, the applicant stated that Unit 2 concrete structures are designed in

accordance with specification ACI 318-63 and meet the criteria of guideline ACI 201.2R-77.

The staff reviewed the structures monitoring program and its evaluation is documented in

Section 3.0.3.2.16 of this SER. The staff finds that because ACI 318-63 provides

assurance that the criteria of the GALL Report and ISG-3 are met, leaching of calcium

hydroxide is not significant at Unit 2, and therefore concludes that the structures

monitoring program will be sufficient for management of increases in porosity and

permeability from this aging mechanism. A plant-specific aging management program is

not required to address this aging effect.

(2b) Aggressive chemical attack - SRP-LR Section 3.5.2.2.2.1 states that cracking, spalling, and increases in porosity and permeability due to aggressive chemical attack could occur

in inaccessible areas of Class I structures. The GALL Report recommends further'

evaluation of plant-specific programs to manage the aging effects for inaccessible areas

if specific criteria defined in the GALL Report and updated in ISG-3 cannot be satisfied.

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The GALL Report, as updated by ISG-3, states that aggressive chemical attack is not

significant unless pH is less than 5.5, chlorides are greater than 500 ppm, or sulfates are

greater than 1,500 ppm. ISG-3 also states that a plant-specific program is recommended

to examine representative samples of below-grade concrete when excavated for any

reason.

In the LRA, the applicant stated that the below-grade environment is not aggressive (pH

is greater than 5.5, chlorides are less than 500 ppm, and sulfates are less than

1,500 ppm). In addition, the staff noted that the applicant uses the structures monitoring

program for the examination of below-grade concrete when it is exposed by excavation.

The staff reviewed the structures monitoring program and its evaluation is documented in

Section 3.0.3.2.16 of this SER.

On the basis of its review of the information provided in the LRA and the guidelines

provided in the SRP-LR, the GALL Report, and ISG-3, the staff finds that increases in

porosity and permeability, loss of material (spalling, scaling), and cracking due to -

aggressive chemical attack are not significant for concrete in inaccessible areas. The

staff finds that an appropriate aging management program for examination of

below-grade concrete (specifically, an enhancement to the structures monitoring

program) has been identified.

(3) Reaction with aggregates - SRP-LR Section 3.5.2.2.2.1 addresses reaction with

aggregates as an aging mechanism for Class 1 structures. ISG-3 clarifies the staff

position that further evaluation is appropriate if investigations, tests, or examinations

have demonstrated that the aggregates are reactive.

In the LRA, the applicant stated that Unit 2 concrete structures are designed in

accordance with specification ACI 318-63 and meet the criteria of guideline

ACI 201.2R-77. The ACI standard specifies testing of aggregates at the time of

construction.

On the basis of interviews with the applicant's technical staff, the staff confirmed that the

results of those tests showed that the aggregates used for concrete Class 1 structures at

Unit 2 are not reactive. However, the applicant stated that it will manage cracking as a

potential aging effect on concrete structures. In the LRA, the applicant stated that change

of material properties and cracking due to alkali (cement)-aggregate reaction of concrete

in various environments is managed by MPS AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER.

(4) Corrosion of embedded steel - SRP-LR Section 3.5.2.2.2.1 states that cracking, spalling,

loss of bond, and loss of material due to corrosion of embedded steel could occur in

inaccessible areas of Class 1 structures. The GALL Report (updated in ISG-3)

recommends further evaluation of plant-specific programs to manage the aging effects

for inaccessible areas if specific criteria defined in the GALL Report cannot be satisfied.

Also, for cracking, loss of bond, and loss of material (spalling, scaling) due to corrosion of

embedded steel, the GALL Report states that a plant-specific program is only necessary

if the below-grade environment is aggressive. ISG-3 also states that a plant-specific

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program is recommended to examine representative samples of below-grade concrete

when excavated for any reason.

The staff finds, in accordance with the criteria of the GALL Report, that these aging

effects are not significant and are adequately managed by MPS AMP B2.1.23,

"Structures Monitoring Program." The staff reviewed the structures monitoring program

and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also finds

an enhancement to the structures monitoring program for examination of below-grade

concrete to be acceptable.

(5) Settlement - SRP-LR Section 3.5.2.2.2.1 refers to Section 3.5.2.2.1.2 for the discussion

of settlement. SRP-LR Section 3.5.2.2.1.2 states that cracking, distortion, and increase in

component stress level due to settlement could occur in Class 1 structures. Some plants

may rely on a de-watering system to lower the site groundwater level. If the plant's CLB

credits a de-watering system, the GALL Report recommends verification of the continued

functionality of the de-watering system during the period of extended operation. The

GALL Report recommends no further evaluation if this activity is included in the scope of

the applicant's structures monitoring program.

The applicant stated, in the LRA, that aging effects (cracking, distortion, and increase in

component stress level) due to settlement, and reduction of foundation strength due to

erosion of porous concrete subfoundations are not expected at Unit 2. The applicant

stated that Unit 2 structures are founded on bedrock, well-consolidated in-situ material,

or compacted fill. No structures utilize porous concrete subfoundations. Unit 2 has no

de-watering system.

Based on the fact that Unit 2 structures are founded on bedrock, well-consolidated in-situ

material or compacted fill without the use of porous concrete subfoundations, the staff

concluded that foundation settlement is not an aging mechanism at Unit 2.

On the basis of its audit and review, the staff finds that the applicant appropriately

evaluated AMR results involving management of settlement, as recommended in the

GALL Report. Since the applicant's AMR results are otherwise consistent with the GALL

Report, the staff finds that the applicant has demonstrated that the effects of aging will

be adequately managed so that the intended functions will be maintained consistent with

the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

(6) Erosion of porous concrete subfoundation - SRP-LR Section 3.5.2.2.2.1 refers to

Section 3.5.2.2.1.2 for the discussion of erosion of porous concrete subfoundation.

SRP-LR Section 3.5.2.2.1.2 states that reduction of foundation strength due to erosion of

porous concrete subfoundations could occur in all types of Class 1 structures. Some

plants may rely on a de-watering system to lower the site groundwater level. If the plant's

CLB credits a de-watering system, the GALL Report recommends verification of the

continued functionality of the de-watering system during the period of extended

operation. The GALL Report recommends no further evaluation if this activity is included

in the scope of the applicant's structures monitoring program.

The applicant stated, in the LRA, that aging effects (cracking, distortion, and increase in

component stress level) due to settlement, and reduction of foundation strength due to

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erosion of porous concrete subfoundations are not expected at Unit 2. Unit 2 structures

are founded on bedrock, well-consolidated in-situ material, or compacted fill. No

structures utilize porous concrete subfoundations. Unit 2 has no de-watering system.

Based on the fact that no Unit 2 structures utilize porous concrete subfoundations, the

staff concluded that erosion of porous concrete subfoundation is not an aging

mechanism at Unit 2.

On the basis of its audit and review, the staff finds that the applicant appropriately

evaluated AMR results involving management of erosion of porous concrete

subfoundation, as recommended in the GALL Report. Since the applicants AMR results

are otherwise consistent with the GALL Report, the staff finds that the applicant has

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

(7) Corrosion of structural steel components - SRP-LR Section 3.5.2.2.2.1 states that

corrosion of structural steel components could occur and that further evaluation is

necessary only for structure/aging effect combinations not covered by the structures

monitoring program.

In LRA Section 3.5.2.2.2.1, the applicant stated that the aging effects associated with

structures are managed by MPS AMP B2.1.23, Structures Monitoring Program."

However, aging effects for infrequently accessed portions of the structures are managed

by MPS AMP B2.1.15, -Infrequently Accessed Areas Inspection Program.'

The staff reviewed the AMR results involving management of aging effects resulting from

corrosion of structural steel components and confirmed that MPS AMP B2.1.23,

Structures Monitoring Program," and MPS AMP B2.1.15, infrequently Accessed Areas

Inspection Program," address each of the affected structures and components. The staff

reviewed these programs and its evaluations are documented in Sections 3.0.3.2.16 and

3.0.3.3.3 of this SER, respectively.

On the basis of this audit and review, the staff finds that the applicant has appropriately

evaluated AMR results involving this aging effect and that corrosion of structural steel

components is adequately managed by the structures monitoring program and

infrequently accessed areas inspection program.

(8) Elevated temperatures - SRP-LR Section 3.5.2.2.2.1 refers to Section 3.5.2.2.1.3 for the

discussion of elevated temperatures. SRP-LR Section 3.5.2.2.1.3 states that reduction of

strength and modulus of elasticity due to elevated temperatures could occur in Class I

structures in Groups 1-5. The GALL Report calls for a plant-specific AMP and

recommends further evaluation if any portion of the concrete components exceeds

specified temperature limits (i.e., general area temperature 66"C (150F) and local area

temperature 93°C (200°F)).

In LRA Section 3.5.2.2.1.3, the applicant stated that during normal operation, all general

concrete areas in Class 1 structures remain below 150 OF and local area temperatures

remain below 200 F. Therefore, the applicant concluded that change in material

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properties due to elevated temperature is an aging effect not requiring management for

Unit 2 Class I structures.

On the basis of its review, the staff concurred with the applicant and finds that change in

material properties due to elevated temperature is an aging effect not requiring

management for the Unit 2 Class I structures.

(9) Aging effects for stainless steel liners for tanks - SRP-LR Section 3.5.2.2.2.1 states that

crack initiation and growth due to SCC and loss of material due to crevice corrosion of

stainless steel liners for Group 7 and 8 structures could occur and further evaluation is

necessary only for structure/aging combinations not covered by the structures monitoring

program.

The applicant stated, in the LRA, that no tanks with stainless steel liners are included in

the structural AMRs. Tanks subject to an AMR are evaluated with their respective

mechanical systems.

On the basis of its review, the staff concurred that no tanks with stainless steel liners are

included in the structural AMRs.

Aging Management of Inaccessible Areas. In LRA Section 3.5.2.2.2.2, the applicant addressed

aging of inaccessible areas of Class 1 structures.

SRP-LR Section 3.5.2.2.2.2 states that cracking, spalling, and Increases in porosity and

permeability due to aggressive chemical attack, and cracking, spalling, loss of bond, and loss of

material due to corrosion of embedded steel could occur in below-grade inaccessible concrete

areas. The GALL Report recommends further evaluation to manage these aging effects in

inaccessible areas of Groups 1-3, 5, and 7-9 structures, if an aggressive below-grade

environment exists. ISG-3 identifies additional recommendations.

The GALL Report, as updated by ISG-3, states that aggressive chemical attack and corrosion of

embedded steel is not significant unless pH is less than 5.5, chlorides are greater than 500 ppm,

or sulfates are greater than 1,500 ppm. ISG-3 also states that a plant-specific program is

recommended to examine representative samples of below-grade concrete when excavated for

any reason.

In LRA Section 3.5.2.2.2.2, the applicant stated that the below-grade environment is not

aggressive (pH is greater than 5.5, chlorides are less than 500 ppm, and sulfates are less

than 1,500 ppm). The applicant stated in the LRA that it credited the enhanced

MPS AMP B2. 1.23, -Structures Monitoring Program," to examine below-grade concrete when it

is exposed by excavation. The staff reviewed the structures monitoring program and its

evaluation is documented in Section 3.0.3.2.16 of this SER. The staff finds that the structures

monitoring program, as enhanced, is an appropriate program for examination of below-grade

concrete when it becomes accessible.

The applicant stated, in the LRA, that inspections of accessible concrete have not revealed

degradation from aggressive chemical attack or corrosion of embedded steel.

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Because the below-grade environment is not aggressive, the applicant performed periodic

groundwater monitoring considering seasonal variations. The staff finds that increases in

porosity and permeability, loss of material (spalling, scaling) cracking due to aggressive

chemical attack, and cracking, spalling, loss of bond, and loss of material due to corrosion of

embedded steel are adequately managed for concrete In inaccessible areas.

On the basis of its audit and review, the staff finds that the applicant appropriately evaluated

AMR results involving management of inaccessible areas, as recommended in the GALL Report.

Since the applicant's AMR results are otherwise consistent with the GALL Report, the staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

3.5A.2.2.3 Component Supports

The staff reviewed LRA Section 3.5.2.2.3 against the criteria In SRP-LR Section 3.5.2.2.3, which

addresses several areas discussed below.

Aping of SuDports Not Covered by Structures Monitoring Program. In LRA Section 3.5.2.2.3.1,

the applicant addressed aging of component supports that are not managed by the structures

monitoring program.

SRP-LR Section 3.5.2.2.3.1 states that the GALL Report recommends further evaluation of

certain component supportlaging effect combinations if they are not covered by the structures

monitoring program. This includes (1) reduction In concrete anchor capacity due to degradation

of the surrounding concrete for Groups B1 -B5 supports; (2) loss of material due to

environmental corrosion for Groups B2-B5 supports; and (3) reduction/loss of isolation function

due to degradation of vibration isolation elements for Group B4 supports. Further evaluation is

necessary only for structure/aging effect combinations not covered by the structures monitoring

program.

The applicant, in the LRA, has included the GALL Report AMP under the applicant's general

MPS AMP B2.1.23, Structures Monitoring Program.' However, this program is not consistent

with the GALL Report since the component groups are not completely within the scope of the

applicant's structures monitoring program, thus requiring further evaluation. The applicant stated

in LRA Section 3.5.2.2.3.1 that the structures monitoring program only manages aging effects

associated with large equipment supports. The applicant also stated that MPS AMP B2.1.13,

OGeneral Condition Monitoring," is used to manage aging effects for supports for other

components and piping, and MPS AMP B2.1.1, 1Battery Rack Inspections,3 is used to manage

age-related degradation specific to battery supports. The aging effects for supports in

infrequently accessed areas are managed by MPS AMP B2.1.15, 'Infrequently Accessed Areas

Inspection Program.* The staff reviewed these programs and its evaluations are documented in

Sections 3.0.3.3.2, 3.0.3.3.1, and 3.0.3.3.3 of this SER, respectively. The staff finds the

structures monitoring program acceptable, in conjunction with the other three programs, for

managing aging of component supports for all GALL Report component support groups.

On the basis of its audit and review, the staff finds that the applicant appropriately evaluated

AMR results involving management of aging of components supports, as recommended in the

GALL Report. Since the applicant's AMR results are otherwise consistent with the GALL Report,

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the staff finds that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the period

of extended operation, as required by 10 CFR 54.21 (a)(3).

Cumulative Fatigue Damage Due to Cyclic Loading. As stated in the SRP-LR, fatigue is a TLAA,

as defined in 10 CFR 54.3. Applicants must evaluate TLAAs in accordance with

10 CFR 54.21(c)(1). Section 4.3 of this SER documents the staffs review of the applicant's

evaluation of this TLAA. In performing this review, the staff followed the guidance in Section 4.3

of the SRP-LR.

3.5A.2.2.4 Quality Assurance for Aging Management of Non-Safety-Related Components

Section 3.0.4 of this SER provides a separate evaluation of the applicant's Quality Assurance

Program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determines that (1) those attributes or features

for which the applicant claimed consistency with the GALL Report were indeed consistent and

(2) the applicant adequately addressed the issues that were further evaluated. The staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

3.5A.2.3 AMR Results That Are Not Consistent With or NotAddressed In the GALL

Report

Summary of Technical Information in the Apglication. In Tables 3.5.2-1 through 3.5.2-27 of the

LRA, the staff reviewed additional details of the results of the AMRs for material, environment,

aging effect requiring management, and AMP combinations that are not consistent with the

GALL Report or are not addressed in the GALL Report.

In Tables 3.5.2-1 through 3.5.2-27, the applicant indicated, via Notes F through J, that neither

the identified component nor the material and environment combination is evaluated in the GALL

Report and provided information concerning how the aging effect requiring management will be

managed.

Staff Evaluation. For component type, material and environment combination that are not

evaluated in the GALL Report, the staff reviewed the applicants evaluation to determine whether

the applicant had demonstrated that the effects of aging will be adequately managed so that the

intended function will be maintained consistent with the CLB during the period of extended

operation.

The staff evaluation is discussed below.

3.5A.2.3.1 Unit 2 Containment - Aging Management Evaluation -Table 3.5.2-1

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The staff reviewed Table-3.5.2-1 of the LRA, which summarized the results of AMR evaluations

for the Unit 2 containment system component groups. The staff interviewed the applicant's

technical staff and reviewed the AMR technical justification for containmient.

In the LRA, the applicant identified no aging effects for stainless steel components exposed to

air, including fuel transfer tube gate valve, containment sump screen,neutron shield tank,

reactor cavity seal ring, refueling cavity liner,; pipe', valve bodies, fuel transfer tube, expansion

bellows, and fuel transfer tube penetration component types. Air is not identified in the GALL

Report as an environment for these components and material.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Without the presence of an aggressive

environment, stainless steel components will experience insignificant amounts of corrosion, and

no aging effects are applicable to this component/commodity group. Therefore, the staff finds

that there are no aging effects requiring management for metal in an air environment.

The applicant stated, in the LRA, that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that, based on tests conducted on the aggregate and the low-alkali cement used at Unit 2, alkali

(cement)-aggregate reaction is not a significant concem. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

The applicant stated in the LRA that change of material properties for equipment pads/grout, jet

impingement barriers, and structural reinforced concrete (beams, columns, floor slabs,

foundation mat slabs, pedestals, and walls) due to alkali (cement)-aggregate reaction of

concrete in an air environment is managed by AMP B2.1.23, "Structures Monitoring Program."

The staff reviewed the structures monitoring program and its evaluation is documented in

Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR.

On the basis of its review, the staff finds this program acceptable for managing the aging

effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment.

The applicant stated in the LRA that change of material properties for containment shell

(cylindrical wall and dome), and tendon gallery due to alkali (cement)-aggregate reaction of

concrete in an air environment is managed by MPSAMP.B2.1.16, ulnservice Inspection

Program: Containment Inspections," with exceptions. The staff reviewed the program and its

evaluation is documented in Section 3.0.3.2.11 of this SER. The staff also reviewed this program

with respect to the SRP-LR. On the basis of its review, the staff finds this program acceptable for

managing the aging effects, for the above components, of change in material properties due to

alkali (cement)aggregate reaction of concrete in an air environment.

For item numbers 3.5.1-03 to 3.5.1-06 (Table 3.5.1) of the LRA, the applicant cited containment

ISI and containment leak rate test as the aging management programs. A review of AMP B2.1.6

indicated that the Appendix J leak rate testing is part of the ISI Program: Containment

Inspections. In the Appendix J program, the applicant takes credit for only Type A tests to

measure the overall primary containment leakage rates. This is a major deviation from

NUREG-1801, Section XL.S4 program. Also, the review indicated that the applicant was taking

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credit for the 1998 Edition of Subsections IWE of Section Xl of the ASME Code, without citing

compliance with the limitations and modifications, associated with this Edition of the Code in

10 CFR 50.55a (67 FR 60520). The staff identified this as a major deviation from NUREG-1 801

Section XI.S1 program and the requirements of the regulation. In view of these deviations, and

the fact that the Type A leak rate testing may occur every 10 to 15 years, the applicant was

requested to provide information as to how it planned to monitor the aging and leak-tightness of

the components covered by item numbers 3.5.1-03 to 3.5.1-06. The applicant was also

requested in RAI 3.5-1 to address seals and gaskets associated with equipment hatches, air

locks, and, electrical and mechanical penetrations.

This item was identified as Audit Item 47 during the AMP/AMR Audit conducted the week of

May 3, 2004. Dominion provided a supplemental response to Audit Item 47 as in a letter dated

July 7, 2004. In this response, the applicant stated that the Millstone LRA has been

supplemented to additionally credit Type B Local Leak Rate Tests (in accordance with

10 CFR 50, Appendix J) as part of the containment isi aging management program. Type B

Local Leak Rate Testing will ensure that the containment pressure boundary function associated

with the seals and gaskets for equipment hatches, air-locks, and, electrical and mechanical

penetrations will be maintained during the period of extended operation.

The typical frequency for performing Type B Local Leak Rate tests is every four refuelingoutages (approximately every six years). Twenty-five percent of Type B electrical penetrations

are performed on-line just prior to or following each refueling outage (approximately every 1 Y/2

years).

The staff finds the response to RAI 3.5-1 acceptable as the implementation of the revised

process will assure the integrity of the containment pressure boundary penetrations during the

period of extended operation.

In RAI 3.5-4, the staff inquired about the means of monitoring the temperatures of the

containment concrete (around the high energy lines) and that of the concrete structures inside

the containments, and the operating experience related to their degradation, as follows:

In addressing item 3.5.1-27, for the reinforced concrete structures subjected to elevated

temperatures (e.g., primary shield walls, pressurizer and steam generator enclosures,

reactor vessel supports, and the containment concrete around high energy penetrations)

the applicant stated: UNUREG-1801 is not applicable." Items IIA1.1-h and IlI.A4-1c of

NUREG-1801 are directly applicable to Group 4 structural concrete. For these structures,

the applicant is requested to provide the following information:

1. The method(s) of monitoring the concrete temperatures in these structures.

2. If the primary shield wall concrete, the containment concrete, or any other

structural components within Millstone 2 and 3 containments are kept below the

threshold temperature (i.e. 150 F) by means of air cooling, provide the operating

experience related to the performance of the cooling system.

3. The results of the latest inspection of these structures, in terms of cracking,

spalling, and condition of reactor vessel support structures, etc.

By letter dated November 9, 2004, the applicant stated as follows:

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1. For Millstone Unit 2, the temperature of the primary shield wall concrete in the

area of the reactor vessel supports is monitored and an alarm is provided in the

control room if the temperature exceeds 150 "F. Embedded cooling coils are

provided at these locations to remove heat from the concrete. Although not

directly measured, the temperature of the concrete in other areas of the Unit 2

containment, and in the Unit 3 containment, is maintained below threshold values

by the design of ventilation systems. The containment ventilation systems

maintain average containment internal air temperature below 120 "F in

accordance with Technical Specification requirements. Local ambient air

temperatures in areas such as the steam generator cubicles and the pressurizer

cubicle are maintained well below 150 "F. The localized concrete temperature in

the vicinity of high energy piping containment penetrations is maintained below

-the threshold value by the containment penetration cooling system, which ' ;

consists of a ventilation system in Unit 2 (the Containment Penetration Cooling

System described in LRA Section 2.3.3.18) and a water cooling system in Unit 3

(as part of the Reactor Plant Component Cooling System described in LRA

Section 2.3.3.6).

2. The containment ventilation systems operate consistently in order to provide

compliance with Technical Specification containment average temperature limit of

120'F. Failures of these systems to provide adequate cooling requires plant

shutdown and, therefore, the threshold values for concrete temperature would not

be exceeded. The containment concrete in the area of the Unit 2 high energy

piping penetrations is cooled by the'containment penetration cooling system. A

review of plant operating experience has indicated that this system also operates

consistently and there are no identified failures that would have resulted in local

concrete temperatures exceeding threshold values.

3. The latest inspections of the containment structure were performed in March

- 2001 and October 2003 for Unit 2 and in September 2002 for Unit 3. These

inspections did not identify instances of significant cracking or spalling in the

primary shield wall, pressurizer and steam generator enclosures, reactor vessel'

support concrete, or the containment concrete around high-energy penetrations.

These inspection results provide further assurance that elevated temperature of

containment concrete is not a significant concern for Millstone Unit 2 and Unit 3

containments.

The staff finds the response acceptable, as the applicant employs positive means to control

temperatures around the high energy containment penetrations as well as around the areas

likely to be subjected to elevated temperatures in the concrete.

In RAI 3.5-14, the staff requested information regarding the operating experience related to

corrosion of steel liner for Millstone Units 2 and 31'Specifically, in discussion of Item 3.5.1-12 in

Section 3.5.2.2.1.4, the applicant noted that the moisture barrier is monitored under containment

inspection program for aging degradation. The industry experience indicates that the moisture

barrier degrades with time, and any moisture accumulation in the degraded barrier corrodes the

steel liner. The applicant was requested to provide information regarding the operating

experience related to the degradation of moisture barrier and the containment liner plate at

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Millstone 2 and 3. The applicant was requested to include a discussion of acceptable liner plate

corrosion before it was reinstated to the nominal thickness.

In response, the applicant provided the following responses.

The containment ISI program conforms to ASME Xl Subsection IWE (1 998 Edition) for

monitoring the effects of aging associated with both the moisture barrier and the steel liner. The

inspection of moisture barriers is intended to prevent undetected intrusion of moisture to

inaccessible areas of the pressure retaining liner. Subsection IWE identifies the moisture barrier

examination method (visual), and the examination extent and frequency (100% each inspection

period). By Subsection IWE requirements, the acceptance standards are "owner defined."

Millstone Units 2 and 3 have defined the general and detailed visual acceptance criteria in plantspecific procedures. For augmented examinations of the liner that involve Ultrasonic Testing

(UT), ASME Section Xl, Subparagraph IWE-3511.3 requires that loss of material in a local area

projected to exceed 10% of the nominal wall thickness prior to the next examination shall be

documented. Such areas are entered into the corrective action program and either accepted by

engineering evaluation or corrected by performance of repair/replacement activities.

For Millstone Units 2 and 3, various examples of operating experience associated with the

moisture barrier and the liner (such as the results of baseline examinations performed under the

containment isi program) are available for review at the station. The extent of the visual

examinations and the necessity of additional volumetric examinations have been as specified in

the IWE Inspection Schedule. Examples of containment operating experience for Millstone Units

2 and 3 are provided in the License Renewal Application Appendix B (Section B2.1.16).

Millstone Unit 2

The moisture barrier for the Unit 2 containment liner was inspected in 2000 as part of the ASME

Section Xl, Subsection IWE examinations. The inspection revealed indications, which upon

evaluation required that the moisture barrier material be removed, a detailed IWE examination of

the liner be performed, the liner be recoated, and the moisture barrier be replaced. The work

scope was completed in two phases, approximately 50% of the locations in outage 2R1 3 and the

remainder in outage 2R1 5. During the examination, some pitting of the liner was observed and

determined to be acceptable by engineering evaluation and the requirements of Subsection IWE

of ASME Section Xl and acceptable for continued service.

Millstone Unit 3

In 2000 the moisture barrier for the Unit 3 containment liner was inspected as part of the ASME

Section Xl, Subsection IWE examinations. The inspection revealed unacceptable results where,

for specific areas, the moisture barrier had not been installed. These areas were documented

and repaired in accordance with Subsection IWE requirements. Detailed visual examinations of

the moisture barrier are performed as directed by IWE requirements and the Millstone

containment ISI program. The liner surface for the depth of the exposed joint was acceptable

and required no further supplemental examination.

Recognizing the susceptibility of the below grade portion of the containment liners to corrosion,

in a follow-up request, the staff requested the applicant to provide information regarding

corrosion of the liners above the bottom floor levels. By letter dated December 3, 2004, the

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applicant provided detailed descriptions of the liner corrosion, and the results of UT

measurements taken for Unit 2 in April 2000, May 2000, March 2002, and in November 2003 for

Unit 2, and in February 2001 for Unit 3. A typical evaluation of liner corrosion consisted of the

following approach:

Specifically, the UT examination results indicated that the area in question had a liner

wall thickness of 0.239 inches. The design nominal thickness of the liner is 0.250 inches.

I In accordance with ASME Section Xl, Subparagraph IWE 3122.3,-local areas exhibiting

less than 10% wall loss are acceptable for continued service. The reading of 0.239

inches was greater than the 0.225 inches minimum wall thickness allowable (for 10 %

wall loss), and therefore, met the acceptance standards of ASME Section Xl.

The description also included examples where the liner thickness was found to be more than

10% of the nominal thickness allowed by Subsection IWE of Section Xl of the ASME Code. In

those cases the applicant performed engineering analysis to demonstrate'that the liner could

perform its intended function.

The above description clearly indicates that the below grade portions of the liner plate have been,

subjected to corrosion, and the applicant was taking appropriate actions to monitor and control

the future instances of corrosion. The staff believes that an appropriate implementation of AMP

B.2.1.16, "Inservice Inspection Program: Containment Inspection," including its containment leak,

rate testing program will monitor and control corrosion of liner plates during the period of

extended operation,-and therefore,- finds the process used by the applicant acceptable.

In RAI 3.5-15, for Millstone 2 only, the staff requested information regarding the condition of

prestressing tendons located below the grade level. Specifically, a review of Appendix 5F of the

Millstone 2 FSAR indicates that the hoop and vertical tendons located in the below-grade portion

of the containment have experienced continuous problem of water leakage through them. The

corrective action adopted for the hoop tendons is to keep the sheathing filler in the affected

tendons at pressures slightly above hydrostatic pressure. For this sustained condition the

applicant was requested to describe the conditions of vertical tendons affected by the water

leakage. For the purpose of lift-off testing during tendon surveillance, the applicant was asked

whether it selected some tendons from these affected tendons as additional samples. Third, the

hydrostatic pressure on the hoop tendons at the bottom of the cylinder could be significant. Such

high-sustained pressures could give rise to leakage of corrosion protection medium (CPM) from

the sheathing (see Trojan Plant experience in NUREG-1 522). The applicant was asked to

provide an assessment of the CPM leakage and presence of water for the affected tendons in

terms of the acceptance criteria in IWL-3221.2; IWL-3221.3, and IWL-3221.4.

By letter dated November 9, 2004, the applicant provided the following responses.

First, the Millstone Unit 2 containment structure is environmentally protected by an Enclosure

Building, which eliminates most degradation mechanisms. Operating experience has been

provided in LRA Appendix B (Section B2.1.16) regarding the long-term effects of water intrusion.

The discussion specifically states that the condition of the tendon gallery has improved and

water intrusion has decreased. This section also discusses the 25th year physical surveillance of

Millstone Unit 2 containment post-tensioning performed in accordance with ASME Section Xl,

Subsection IWL requirements, and includes the results of the tendon surveillance examinations

and tests. The section identifies that the losses in tendon forces were less than expected for a*

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plant of its age, and concludes that the containment structure has experienced no abnormal

degradation of the post tensioning system. The section identifies that a regression analysis of

the tendon forces was performed, which predicts that the values will remain above minimum

design requirements well beyond the next surveillance interval.

The 25th year physical surveillance for Millstone Unit 2 included the inspection of anchorage

components. Grease caps were selected and removed in accordance with Subsection IWL

requirements, and a complete grease coating was found for all tendon ends inspected including

those vertical tendons selected. All wire samples were acceptable for diameter, corrosion

condition, and physical properties. All tendons were resealed and regreased, with no more than

10% duct volume added.

The presence of water was found in one surveillance tendon (vertical tendon 31V24). The

amount of free water present was 16 ounces (Note: The total grease net duct volume for this

tendon is 191.94 gallons); This same vertical tendon had also been selected for lift-off testing

with satisfactory results. The grease caps for the adjacent tendons (31 V22, 31V23 and 31V25)

were removed for examination of the tendon ends. No free water was present, and the CPM was

tested with satisfactory results. The anchor head corrosion condition of all four tendons was -

excellent and no broken wires were found. In addition, the exterior of tendon anchorage grease

cans (including all vertical tendons) were inspected for the presence of water and grease leaks

and none were found."

Second, Millstone Unit 2 does not select any additional tendons from the affected hoop tendons

for lift-off testing, and only tests those affected tendons that were selected to comply with ASME

Section Xl, Subsection IWL requirements. When affected tendons are lift-off tested in

accordance with IWL requirements, Millstone Unit 2 lift-off tests the adjacent tendons as

additional samples in accordance with Subsection IWL should unsatisfactory lift-off test results

be identified for the affected tendons."

As a result of the Millstone Unit 2 tendon surveillance program, seventeen hoop tendons were

identified as subject to groundwater intrusion. These tendons were modified to ensure that

grease is continuously supplied at a pressure that is slightly above the hydrostatic pressure of

the groundwater. The number of tendons containing water has significantly reduced from the ten

tendons identified during the third and fourth tendon surveillances to only one tendon identified

during each of the last two surveillances. For the tendon identified with free water during the last

surveillance (12H01), an inspection of head revealed acceptable levels of corrosion with nobutton heads missing (other than those intentionally removed for corrosion inspection). The CPM

for each of the identified seventeen hoop tendons was sampled and replaced during the 25th

year physical surveillance. The analysis of the CPM samples taken from each tendon showed

acceptable results for all tests (ions, water and neutralization number). These grease

replacement tendons were also successfully filled with no more than 10% net duct volume

added, as required in accordance with Subsection IWL.

As previously identified, the operating experience for Millstone Unit 2 identifies that the condition

of the tendon gallery has improved, the water intrusion has decreased, and the containment

structure has experienced no abnormal degradation of the post tensioning system.

The staff considers the inspection and maintenance activities associated with the below grade

tendons acceptable, as the continuation of the process during the period of extended operation

I

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will manage the aging of these corrosion susceptible tendons. Additional discussion regarding

the selection of these tendons for examination and lift-off testing is discussed in Section 4.5 of

this SER.

3.5A.2.3.2 Unit 2 Containment Enclosure Building - Aging Management Evaluation - Table

3.5.2-2

The staff reviewed Table 3.5.2-2 of the LRA, which summarized the results of AMR evaluations

for the Unit 2 containment enclosure building component groups. The staff interviewed the

applicant's technical staff and reviewed the AMR technical justification for Class 1 structures.

The applicant stated, in the LRA, that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 2, alkali

(cement)-aggregate reaction is not a significant concern. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

The applicant also stated in the LRA that change of material properties for flood/spill barriers

including curbs, dike, toe plates and stop logs, and structural reinforced concrete (caisson, floor

slabs, grade beams, slabs on grade, and walls), due to alkali (cement)-aggregate reaction of

concrete in an air environment is managed by AMP B2.1.23, "Structures Monitoring Program."

The staff reviewed the structures monitoring program and its evaluation is documented in

Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR.

On the basis of its review, the staff finds this program acceptable for managing the aging

effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment.

The applicant stated, in the LRA, that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant also stated that based on tests conducted on

the aggregate and the low-alkali cement used at Unit 2, alkali (cement)-aggregate reaction is not

a significant concern. The applicant stated that the use of high-density, low-permeability

concrete, and proper arrangement and distribution of reinforcement to control cracking, prevents

the leaching of calcium hydroxide from Class 1 structures' concrete to be of concern. Therefore,

the applicant stated that it will manage change of material properties as a potential aging effect

on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (caisson, floor slabs, grade beams, slabs on grade, and walls) due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment is managed by AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

3-459 -
Tables 3.5.2-2 of LRAs for both Units 2 and 3 are related to the aging management of the

enclosure buildings surrounding the containments. For Unit 2, the applicant incorporated the

aging management of blow-off panels. This was not the case for Unit 3. In RAI 3.5-16 the

applicant was requested to discuss the reasons for the difference.

By letter dated December 3, 2004, the applicant stated that the main steam lines for Millstone

Unit 2 go through the enclosure building, and the potential exists for excessive pressure to

build-up inside this building during a main steam line leak. For this reason blow-off panels were

incorporated into the Unit 2 enclosure building design, and the aging management of these

blow-off panels has been included for License Renewal.

The applicant further stated that the main steam lines for Millstone Unit 3 go through the main

steam valve building, and not the enclosure building. For this reason blow-off panels are

installed in the main steam valve building, and the aging management of these blow-off panels

has been included for License Renewal. Because the main steam lines for Millstone Unit 3 do

not go through the enclosure building, the potential for excessive pressure to build-up inside this

building does not exist, and blow-off panels were not installed.

The staff finds the clarification acceptable.

3.5A.2.3.3 Unit 2 Auxiliary Building - Aging Management Evaluation - Table 3.5.2-3

The staff reviewed Table 3.5.2-3 of the LRA, which summarized the results of AMR evaluations

for the Unit 2 auxiliary building component groups. The staff interviewed the applicant's technical

staff and reviewed Unit 2 Technical Report MP-LR-3602, "Class I Structures," Revision 3.

In the LRA, the applicant identified no aging effects for stainless steel components exposed to

air, including miscellaneous steel (embedded steel exposed surfaces, shapes, plates, unistrut,

etc.), ladders, platforms, grating, and stairs component types. Air is not identified in the GALL

Report as an environment for these components and material.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Without the presence of an aggressive

environment, stainless steel components will experience insignificant amounts of corrosion, and

no aging effects are applicable to this component/commodity group. Therefore, the staff finds

that there are no aging effects requiring management for metal in an air environment.

In the LRA, the applicant identified no aging effects for carbon steel components exposed to air,

including metal smoke barrier and control room ceiling support component types. Air is not

identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, carbon steel components will experience

3460

. .1
-

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Therefore, the staff finds that there are no aging effects requiring

management for metal in an air environment.

In the LRA, the applicant identified no aging effects for aluminum components exposed to air,

including the control room ceiling panel component type. The GALL Report does not include this

material for these components.

The applicant stated, as documented in the staff's MPS audit and review report for the AMR, that

for aluminum in an air or an atmosphere/weather environment, there are no potential aging

mechanisms for this aluminum and environment combination. The applicant stated in the MAER

that for aluminum material in an air or atmosphere/weather environment, there are no potential

aging mechanisms for this material and environment combination at Unit 2. This conclusion is

based on engineering text references that indicate that aluminum and its alloys resist attack to a

wide range of environments and many chemical compounds. On the basis of its review of the

applicant's documentation, the staff concurred with the applicant and finds that there are no

aging effects requiring management for aluminum in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant also

stated, however, that based on tests conducted on the aggregate and the low-alkali cement

used at MPS, alkali (cement)-aggregate reaction is not a significant concern. However, the

applicant stated that it will manage change of material properties as a potential aging effect on

concrete structures.

In the LRA, the applicant also stated that change of material properties for flood/spill barriers,

including curbs, dikes, toe plates and stop logs, structural reinforced concrete (beams, columns,

floor slabs, foundation mat slabs, roof slabs, slabs on grade, and walls), and tunnels component

types due to alkali (cement)-aggregate reaction of concrete in an air environment is managed by AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures 'monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR.-On the basis of its review, the staff finds this

program acceptable for managing the aging effectsfor the above components, of change in

material properties due to alkali (cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant further stated that based on tests conducted on

the aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not

a concern. The applicant stated that the use of high-density, low-permeability concrete, and

proper arrangement and distribution of reinforcement to'control cracking, prevents the leaching

of calcium hydroxide from Class 1 structures' concrete from being of concern. Nevertheless, the

applicant stated that it will manage change of material properties as a potential aging effect on

concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (beams, columns, floor slabs, foundation mat slabs, roof slabs, slabs on grade; and

walls) component types due to alkali (cement)-aggregate reaction and leaching of calcium

hydroxide of concrete in an atmosphere/weather environment is managed by MPS AMP

3-461
B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring program

and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this

program with respect to the SRP-LR. On the basis of its review, the staff finds this program

acceptable for managing the aging effects, for the above components, of change in material

properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of

concrete in an atmosphere/weather environment.

In the LRA, the applicant stated that loss of material for stainless steel spent fuel storage racks

exposed to treated water is managed using AMP B2.1.5, "Chemistry Control for Primary

Systems Program." The staff reviewed the chemistry control for primary systems program and

its evaluation is documented in Section 3.0.3.2.2 of this SER. The staff finds that this program is

consistent with GALL AMP XI.M2, 'Water Chemistry," with an acceptable exception. Since this

program is consistent with the GALL Report recommendation for other components with the

same material, environment, and aging effect, the staff finds this to be acceptable.

3.5A.2.3.4 Unit 2 Warehouse Building - Aging Management Evaluation - Table 3.5.24-

The staff reviewed Table 3.5.2-4 of the LRA, which summarized the results of AMR evaluations

for the Unit 2 warehouse building system component groups. The staff interviewed the

applicant's technical staff and reviewed the AMR technical justification for Class 1 structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 2, alkali

(cement)-aggregate reaction is not a significant concern. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for flood/spill barriers,

including curbs, dikes, toe plates and stop logs, structural reinforced concrete (floor slabs,

foundation mat slabs, roof slabs, and walls), and tunnels component types in an air environment

is managed by AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures

monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff

also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds

this program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 2, alkali (cement)-aggregate reaction is not a

concem. The applicant stated that the use of high-density, low-permeability concrete, and proper

arrangement and distribution of reinforcement to control cracking, prevents the leaching of

calcium hydroxide from Class 1 structures' concrete to be of concem. Therefore, the applicant

stated that it will manage change of material properties as a potential aging effect on concrete

structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (floor slabs, foundation mat slabs, roof slabs, and walls) component types due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

I

I

3-462
atmosphere/weather environment is managed by MPS AMP B2.1.23, .Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

In the LRA, the applicant identified no aging effects for stainless steel components exposed to

air, including cask wash pit liner and new fuel rack assembly component types. Air is not

identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Without the presence of an aggressive -

environment, stainless steel components are expected to experience insignificant amounts of

corrosion, and no aging effects are applicable to this component/commodity group; Therefore,

the staff finds that there are no aging effects requiring management for metal in an air

environment.

3.5A.2.3.5 Unit 2 Turbine Building - Aging Management Evaluation - Table 3.5.2-5

The staff reviewed Table 3.5.2-5 of the LRA, which summarized the results of AMR evaluations

for the Unit 2 turbine building system component groups. The staff interviewed the applicant's

technical staff and reviewed the AMR technical justification for Class I structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)-aggregate reaction is not a significant concern. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for flood/spill barriers,

including curbs, dikes, toe plates and stop logs, structural reinforced concrete (floor slabs,

footing and grade beams, pedestals, roof slabs, slabs'on grade, spread footing, and turbine

pedestal walls), and hatches component types in an air environment is managed by AMP

B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring program

and its evaluation is documented in Section 3.0.3.2;16 of this SER. The staff also reviewed this

program with respect to the SRP-LR. On the basis of its review, the staff finds this'program

acceptable for managing the aging effects, for the above componentg,-of change in material

properties due to alkali (cement)-aggregate reaction of concrete in an air environment.

I, .

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the -

aggregate and the low-alkali cement used at MPS, alkali (cement)aggregate reaction is not a

concem. The applicant stated that the use of high-density, low-permeability concrete, and proper

arrangement and distribution of reinforcements to control cracking, prevents the leaching of

3463
calcium hydroxide from Class I structures' concrete from being of concern. Nevertheless, the

applicant stated that it will manage change of material properties as a potential aging effect on

concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (floor slabs, footing and grade beams, pedestals, roof slabs; slabs on grade, spread footing, and turbine pedestal walls) component types due to alkali (cement)-aggregate reaction

and leaching of calcium hydroxide of concrete in an atmosphere/weather environment is

managed by MPS AMP B2.1.23, TMStructures Monitoring Program." The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment.

3.5A.2.3.6 Unit 1 Turbine Building - Aging Management Evaluation - Table 3.5.2-6

The staff reviewed Table 3.5.2-6 of the LRA, which summarized the results of AMR evaluations

for the Unit 1 turbine building system component groups. The staff interviewed the applicant's technical staff and reviewed the AMR technical justification for Class I structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 2, alkali

(cement)aggregate reaction is not a significant concern. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (floor slabs, foundation mat slabs, and walls) component types in an air environment is

managed by AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures

monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff

also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds

this program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)aggregate reaction of concrete in an air environment:

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concern. The applicant stated that the use of high-density, low-permeability concrete, and proper arrangement and distribution of reinforcements to control cracking, prevents the leaching of

calcium hydroxide from Class 1 structures' concrete from being of concern. Therefore, the -

applicant stated that it will manage change of material properties as a potential aging effect on

concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (floor slabs, foundation mat slabs, and walls) component types due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment is managed by MPS AMP B2.1.23, "Structures Monitoring

I

3-464
Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

In the LRA, the applicant identified no aging effects for carbon steel H-piles components

exposed to soil. The applicant stated, as documented in the staffs MPS audit and review report

for the AMR for Class 1 structures, that for carbon steel in a soil environment, there are no.

potential aging mechanisms for this carbon steel and environment combination. The applicant

stated that test data indicated that undisturbed soils are deficient in oxygen at levels a few feet

below the ground surface or below the water table. Carbon steel piles driven into undisturbed

soils are not appreciably affected by corrosion, regardless of the soil type or the soil properties.

The effects of corrosion are negligible for well-compacted soil because it does not contain

sufficient oxygen. Therefore, the applicant finds that the loss of material due to corrosion is not a

potential aging mechanism.

On the basis of its review of the applicant's documentation, the staff concurred with the applicant

and finds that loss of material due to corrosion is not a potential aging effect. Therefore, the staff

finds that, for carbon steel in a soil environment, there is a negligible aging mechanism for this

carbon steel and environment combination.

3.5A.2.3.7 Unit 1 Control Room and Radwaste Treatment Building - Aging Management

Evaluation - Table 3.5.2-7

The staff reviewed Table 3.5.2-7 of the LRA, which summarized the results of AMR evaluations

for the Unit 1 control room and radwaste treatment building system component groups. The staff

interviewed the applicant's technical staff and reviewed the AMR technical justification for Class

1 structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)-aggregate reaction is not a significant concem. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (floor slabs, foundation mat slabs, roof slabs, and walls) component types in an air

environment is managed by AMP B2.1.23, "Structures Monitoring Program." The staff reviewed

the structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

3-465
aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concern. The applicant stated that the use of high-density, low-permeability concrete, and proper

arrangement and distribution of reinforcements to control cracking, prevents' the leaching of

calcium hydroxide from Class 1 structures' concrete from being of concem. Nevertheless, the

applicant stated that it will manage change of material properties as a potential aging effect on

concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (floor slabs, foundation'mat slabs, roof slabs, and walls) component types due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment is managed by AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

3.5A.2.3.8 Unit 2 Fire Pump House - Aging Management Evaluation - Table 3.5.2-8

The staff reviewed Table 3.5.2-8 of the LRA, which summarized the results of AMR evaluations

for the Unit 2 fire pump house system component groups. The staff interviewed the applicant's

technical staff and reviewed AMR technical justification for miscellaneous structures.

In the LRA, the applicant stated that cracking for concrete (masonry block walls) component

types exposed to an atmosphere/weather environment is managed using AMP B2.1.23,

"Structures Monitoring Program." The applicant also stated that cracking of masonry block walls

due to long-term creep and variation in stiffness, dry shrinkage of'concrete, and expansion or

contraction, is possible in an atmosphere/weather environment. Masonry block walls are subject

to all of these aging mechanisms, which require aging management.

The staff reviewed the structures monitoring program and its evaluation is documented in

Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR.

On the basis of its review, the staff finds this program acceptable for managing the aging

effects, for the above components, of concrete cracking due to long-term creep and variation in

stiffness, dry shrinkage of concrete, and expansion or contraction in this environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)-aggregate reaction is not a significant concern. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (foundation mat slabs and roof slabs) component types in an air environment is

managed by MPS AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

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components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment.

3.5A.2.3.9 Unit 3 Fire Pump House - Aging Management Evaluation - Table 3.5.2-9

The staff reviewed Table 3.5.2-9 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 fire pump house system component groups. The staff interviewed the applicant's

technical staff and reviewed the AMR technical justification for miscellaneous structures.

In the LRA, the applicant stated that cracking for concrete (masonry block walls) component

types exposed to an atmosphere/weather environment is managed using AMP B2.1.23,

OStructures Monitoring Program." The applicant stated that cracking of masonry block walls due

to long-term creep and variation in stiffness, dry shrinkage of concrete, and expansion or

contraction, is possible in an atmosphere/weather environment. Masonry block walls are subject

to all of these aging mechanisms, which require aging management.

The staff reviewed the structures monitoring program and its evaluation is documented in

Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR.

On the basis of its review, the staff finds this program acceptable for managing the aging -

effects, for the above components, of concrete cracking due to long-term creep and variation in

stiffness, dry shrinkage of concrete, and expansion or contraction in this environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)-aggregate reaction is not a significant concern. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (foundation mat slabs, and roof slabs) component types in an air environment is

managed by MPS AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment.

3.5A.2.3.10 SBO Diesel Generator Enclosure and Fuel Oil Tank Vault - Aging Management

Evaluation -Table 3.5.2-10

The staff reviewed Table 3.5.2-10 of the LRA, which summarized the results of AMR evaluations

for the SBO diesel generator enclosure and fuel oil tank vault system component groups. The

staff interviewed the applicant's technical staff and reviewed the AMR technical justification for

miscellaneous structures.

In the LRA, the applicant identified no aging effects for aluminum components exposed to air,

including roofing and siding component types. The GALL Report does not include this material

for these components. -

3-467.
The applicant stated, as documented in the staffs MPS audit and review report for the AMR

miscellaneous structures, that for aluminum in an air or an atmosphere/weather environment,

there are no potential aging mechanisms for this aluminum and environment combination. The

applicant stated in its MAER that for aluminum material in an air or atmosphere/weather

environment, there are no potential aging mechanisms for this material and environment

combination at Unit 2. This conclusion is based on engineering text references that indicate that

aluminum and its alloys resist attack to a wide range of environments and many chemical

compounds. On the basis of its review of the applicant's documentation, the staff concurred with

the applicant and finds that there are no aging effects requiring management for aluminum in an

air environment.

In the LRA, the applicant identified no aging effects for aluminum components exposed to an

atmosphere/weather environment, including roofing and siding component types. The GALL

Report does not include this material for these components.

The applicant stated, as documented in the staffs MPS audit and review report for the AMR for

miscellaneous structures, that for aluminum in an air or an atmosphere/weather environment,

there are no potential aging mechanisms for this aluminum and environment combination. The

applicant stated in its MAER that for aluminum material in an air or atmosphere/weather

environment, there are no potential aging mechanisms for this material and environment

combination at Unit 2. This conclusion is based on engineering text references that indicate that

aluminum and its alloys resist attack to a wide range of environments and many chemical

compounds. On the basis of its review of the applicant's documentation, the staff concurred with

the applicant and finds that there are no aging effects requiring management for aluminum in an

atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)aggregate reaction is not a significant concern. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (foundation mat slabs) component types in an air environment is managed by

AMP B2.1.23, 'Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this

program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concem. The applicant stated, in the LRA, that the use of high-density, low-permeability

concrete, and proper arrangement and distribution of reinforcements to control cracking,

prevents the leaching of calcium hydroxide from structural concrete to be of concern. Therefore,

the applicant stated that it will manage change of material properties as a potential aging effect

on concrete structures.

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In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (foundation mat slabs) component types due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment is managed by

AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this

program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment.

3.5A.2.3.1 1 Unit 2 Condensate Polishing Facility and Warehouse No. 5 - Aging Management

Evaluation - Table 3.5.2-11

The staff reviewed Table 3.5.2-11 of the LRA, which summarized the results of AMR evaluations

for the Unit 2 condensate polishing facility and warehouse no. 5 system component groups. The

staff interviewed the applicant's technical staff and reviewed the AMR technical justification for

miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to'alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)-aggregate reaction is not a significant concem. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (beams, columns, floor slabs, spread footing, and walls) component types in an air

environment is managed by AMP B2.1.23, "Structures Monitoring Program." The staff reviewed

the structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concem. The applicant stated that the use of high-density, low-permeability concrete, and proper

arrangement and distribution of reinforcements to control cracking, prevents the leaching of

calcium hydroxide from structural concrete from being of concem. Therefore, the applicant

stated that it will manage change of material properties as a potential aging effect on concrete

structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (beams, columns, floor slabs, spread footing, and walls) component types due to alkali

(cement-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment is managed by MPS AMP B2.1.23, Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

3-469
to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

3.5A.2.3.12 Security Diesel Generator Enclosure - Aging Management Evaluation -

Table 3.5.2-12

The staff reviewed Table 3.5.2-12 of the LRA, which summarized the results of AMR evaluations

for the security diesel generator enclosure system component groups. The staff interviewed the

applicant's technical staff and reviewed the AMR technical justification for miscellaneous

structures.

In the LRA, the applicant identified no aging effects for aluminum components exposed to air,

including roofing, siding, and structural framing component types. The GALL Report does not

include this material for these components.

The applicant stated, as documented in the staffs MPS audit and review report for the AMR for

miscellaneous structures, that for aluminum in an air environment, there are no potential aging

mechanisms for this aluminum and environment combination. The applicant stated in the MAER

that for aluminum material in an air environment, there are no potential aging mechanisms for

this material and environment combination at Unit 2. This conclusion is based on engineering

text references that indicate that aluminum and its alloys resist attack from a wide range of

environments and many chemical compounds. On the basis of its review of the applicant's

documentation, the staff concurred with the applicant and finds that there are no aging effects

requiring management for aluminum in an air environment.

In the LRA, the applicant identified no aging effects for aluminum components exposed to an

atmosphere/weather environment, including roofing and siding component types. The GALL

Report does not include this material for these components.

The applicant stated, as documented in the staffs MPS audit and review report for the AMR for

miscellaneous structures, that for aluminum in an atmospherelweather environment, there are

no potential aging mechanisms for this aluminum and environment combination. The applicant

stated in its MAER that for aluminum material in an atmospheretweather environment there are

no potential aging mechanisms for this material and environment combination at Unit 2. This

conclusion is based on engineering text references that indicate that aluminum and its alloys

resist attack from a wide range of environments and many chemical compounds. On the basis of

its review of the applicant's documentation, the staff concurred with the applicant and finds that

there are no aging effects requiring management for aluminum in an atmosphere/weather

environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concem. The applicant stated that the use of high-density, low-permeability concrete, and proper

arrangement and distribution of reinforcements to control cracking, prevents the leaching of

calcium hydroxide from structural concrete. However, the NRC staff has expressed concerns

3-470
regarding aging of concrete. Therefore, the applicant will manage change of material properties

as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (foundation mat slabs) component types due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment is managed by

AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this

program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment.

3.5A.2.3.13 Stack Monitoring Equipment Building - Aging Management Evaluation -

Table 3.5.2-13

The staff reviewed Table 3.5.2-13 of the LRA, which summarized the results of AMR evaluations

for the stack monitoring equipment building system component groups. The staff interviewed the

applicant's technical staff and reviewed the AMR technical justification for miscellaneous

structures.

In the LRA, the applicant stated that cracking for concrete (masonry block walls) component

types exposed to an atmosphere/weather environment is managed using AMP B2.1.23,

IStructures Monitoring Program." The applicant stated that cracking of masonry block walls due

to long-term creep and variation in stiffness, dry shrinkage of concrete, and expansion or

contraction, is possible in an atmosphere/weather environment. Masonry block walls are subject

to all of these aging mechanisms, which require aging management. The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of concrete cracking due to long-term creep and variation in stiffness, dry

shrinkage of concrete, and expansion or contraction in this environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)-aggregate reaction is not a significant concem. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(roof slabs, slabs on grade, spread footing, and walls) component types in an air environment is

managed by MPS AMP B2.1.23, uStructures Monitoring Program." The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

3-471 :
atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concern. The applicant stated that the use of high-density, low-permeability concrete, and proper

arrangement and distribution of reinforcements to control cracking, prevents the leaching of

calcium hydroxide from structural concrete from being of concern. Therefore, the applicant

stated that it will manage change of material properties as a potential aging effect on concrete

structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (roof slabs, slabs on grade, spread footing, and walls) component types due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment is managed by MPS AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

3.5A.2.3.14 Millstone Stack - Aging Management Evaluation -Table 3.5.2-14

The staff reviewed Table 3.5.2-14 of the LRA, which summarized the results of AMR evaluations

for the MPS stack system component groups. The staff interviewed the applicant's technical

staff and reviewed the AMR technical justification for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)-aggregate reaction is not a significant concern. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (floor slabs, foundation mat slabs, and walls) component types in an air environment is

managed by AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures

monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff

also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds

this program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate'reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concern. The applicant stated that the use of high-density, low-permeability concrete, and proper

arrangement and distribution of reinforcements to control cracking, prevents the leaching of

calcium hydroxide from structural concrete to be of concern. Therefore, the applicant stated that

it will manage change of material properties as a potential aging effect on concrete structures.

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In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (floor slabs, foundation mat slabs, and walls) component types due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment is managed by AMP B2.1.23, "Structures Monitoring:

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)-aggregate reaction is not a significant concerm. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures in

infrequently accessed areas.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (floor slabs, foundation mat slabs, and walls) component types in infrequently accessed

areas in an air environment is managed by AMP B2.1.15, "Infrequently Accessed Areas

Inspection Program," which is a plant-specific program. The staff reviewed the infrequently

accessed areas inspection program and its evaluation is documented in Section 3.0.3.3.3 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due'to alkali (cement)-aggregate reaction of

concrete in an air environment for infrequently accessed areas.

3.5A.2.3.15 Switchyard Control House - Aging Management Evaluation - Table 3.5.2-15

The staff reviewed Table 3.5.2-15 of the LRA, which summarized the results of AMR evaluations

for the switchyard control house system component groups. The staff interviewed the applicant's

technical staff and reviewed the AMR technical justification for miscellaneous structures.

In the LRA, the applicant stated that cracking of concrete (masonry block walls) component

types exposed to an atmosphere/weather environment is managed using AMP B2.1.23,

IStructures Monitoring Program." The applicant also stated that cracking of masonry block walls

due to long-term creep and variation in stiffness, dry shrinkage of concrete, and expansion or

contraction, is possible in an atmosphere/weather environment. Masonry block walls are subject

to all of these aging mechanisms which require aging management. The staff reviewed the

structures monitoring program and its evaluation is'documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of concrete cracking due to long-term creep and variation in stiffness, dry

shrinkage of concrete, and expansion or contraction in this environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

3-473
(cement)-aggregate reaction is not a significant concern. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete component types in an air environment is managed by AMP B2.1.23, 'Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concern. The applicant stated that the use of high-density, low-permeability concrete, and proper arrangement and distribution of reinforcements to control cracking, prevents the leaching of

calcium hydroxide from structural concrete from being of concern. Therefore, the applicant stated that it will manage change of material properties as a potential aging effect on concrete

structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete component types due to alkali (cement)-aggregate reaction and leaching of calcium

hydroxide of concrete in an atmosphere/weather environment is managed by AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring program and its

evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this program acceptable for

managing the aging effects, for the above components, of change in material properties due to

alkali (cement)aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

3.5A.2.3.16 Retaining Wall - Aging Management Evaluation - Table 3.5.2-16

The staff reviewed Table 3.5.2-16 of the LRA, which summarized the results of AMR evaluations

for the retaining wall system component groups. The staff interviewed the applicant's technical

staff and reviewed the AMR technical justification for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement-aggregate reaction is not a

concern. The applicant stated that the use of high-density, low-permeability concrete, and proper arrangement and distribution of reinforcements to control cracking, prevents the leaching of

calcium hydroxide from structural concrete from being of concern. Therefore, the applicant stated that it will manage change of material properties as a potential aging effect on concrete

structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (footing and walls) component types due to alkali (cement)-aggregate reaction and

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3-474
leaching of calcium hydroxide of concrete in an atmosphere/weather environment is managed by

AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section'3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this

program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment.

3.5A.2.3.17 345kV Switchyard - Aging Management Evaluation - Table 3.5.2-17

The staff reviewed Table 3.5.2-17 of the LRA, which summarized the results of AMR evaluations

for the 345kV switchyard system component groups. The staff interviewed the applicant's

technical staff and reviewed AMR technical justification for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concem. The applicant stated that the use of high-density, low-permeability concrete, and proper

arrangement and distribution of reinforcements to control cracking, prevents the leaching of

calcium hydroxide from structural concrete from being of concern. Therefore; the'applicant

stated that it will manage change of material properties as a potential aging effect on concrete

structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete component types due to alkali (cement)-aggregate reaction and leaching of calcium

hydroxide of concrete in an atmosphere/weather environment is managed by AMP B2.1 .23,

I Structures Monitoring Program." The staff reviewed the structures monitoring program and its

evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program

with respect to the SRP-LR. On the basis of its review, the staff finds this program acceptable for'

managing the aging effects, for the above components, of change in material properties due to

alkali (cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

3.5A.2.3.18 Unit 2 Intake Structure - Aging Management Evaluation - Table 3.5.2-18

The staff reviewed Table 3.5.2-18 of the LRA, which summarized the results of AMR evaluations

for the Unit 2 intake structure system component groups.-The staff interviewed the applicant's

technical staff and reviewed the AMR technical justification for intake and discharge structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)-aggregate reaction is not a significant concem. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (beams, columns, floor slabs, foundation mat slabs, roof slabs, and walls) and hatches

component types in an air environment is managed by AMP B2.1.23, "Structures Monitoring

3-475 '
Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing the aging effects, for the above components, of change in material properties due to alkali

(cement-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concern. The applicant stated that the use of high-density, low-permeability concrete, and proper arrangement and distribution of reinforcements to control cracking, prevents the leaching of

calcium hydroxide from structural concrete from being of concern. Therefore, the applicant stated that it will manage change of material properties as a potential aging effect on concrete

structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (beams, columns, floor slabs, foundation mat slabs, roof slabs, and walls) and hatches

component types due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of

concrete in an atmosphere/weather environment is managed by AMP B2.1.23, 'Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in a sea water environment. The applicant stated that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a concern. During the audit and review, the staff

expressed concerns regarding aging of concrete. The applicant stated that it will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced.

concrete (beams, columns, floor slabs, foundation mat slabs, roof slabs, and walls) component types in a sea water environment is managed by AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is documented in" - Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR.

On the basis of its review, the staff finds this program acceptable for managing the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in a sea water environment.

In RAI 3.5-7, the staff requested information about the members that will be monitored by the

structures monitoring program and infrequently accessed area inspection program as follows:

Structures Monitoring Program and Infrequently Accessed Area Inspection Program

were listed as AMPs for Structural Reinforced Concrete (Beams, Columns, Floor slabs, Foundation mat slabs, Roof slabs, Walls) under column "Structural Member" and under

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column "Notes" H, 20 in Tables 3.5.2-18 for Unit 2 and H, 23 in Table 3.5.2-27 for Unit

3. Please identify the structural components, such as beams and walls that are

managed by either program or by both programs and provide basis for the selection of

the program.

By letter dated November 9,'2004, the applicant stated that the structural member "Structural

Reinforced Concrete" in Unit 2 LRA Table 3.5.2-18 and Unit 3 LRA Table 3.5.2-27 includes

beams, columns, floor slabs, foundation mat slabs, roof slabs, and walls. The structural

reinforced concrete components associated with the table line item with Note H, 20 (Unit 2) or H,

23 (Unit 3) are only the floor slabs, foundation mat slabs, and walls. As indicated in Note 20 in

the Unit 2 LRA table (or Note 23 in the Unit 3 LRA table), the infrequently accessed area

inspection program manages the effects of aging for structural members/components in the

intake structure water bays between the waterline and the bottom of the'intake structure

operating deck since this area is infrequently accessed as described in LRA Appendix B, Section

b2.1.15. The structures monitoring program manages the effects of aging for structural

members/components in the water bay below the waterline since this area is inspected by the

structures monitoring program AMP. The effects of aging for the walls are managed by both the

infrequently accessed areas inspection program (above the waterline) and the structures

monitoring program (below the waterline). The'infrequently accessed area inspection program

manages the effects of aging for the floor slabs (underside of the operating deck) and the

structures monitoring program manages the effects of aging for the foundation mat slabs.

The staff finds the applicant's response acceptable because it identifies each structural

component and its associated AMP.

3.5A.2.3.19 Sea Walls - Aging Management Evaluation - Table 3.5.2-19

The staff reviewed Table 3.5.2-19 of the LRA, which summarized the results of AMR evaluations

in the SRP-LR for the sea walls system component groups. The staff interviewed the applicant's

technical staff and reviewed the AMR technical justification for intake and discharge structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concem. The applicant stated that the use of high-density, low-permeability concrete, and proper

arrangement and distribution of reinforcements' to control cracking, prevents the leaching of

calcium hydroxide from structural concrete from being of concern. Therefore, the applicant

stated that it will manage change of material properties as a potential aging effect on concrete

structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (footings and walls) component types due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment is managed by

AMP B2.1.23, Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this

program acceptable for managing the aging effects, for the above components, of change in

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material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an atmosphere/weather environment. -

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in a sea water environment. The applicant stated that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a concern. However, the NRC staff has expressed

concerns regarding aging of concrete. Therefore, the applicant will manage change of material

properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (footings and walls) component types in a sea water environment is managed by AMP

B2.1.23, Structures Monitoring Program." The staff reviewed the structures monitoring program and its evaluation of this program is documented in Section 3.0.3.2.16 of this SER. The staff

also reviewed this program with respect to the SRP-LR. For these components, the staff finds

this program acceptable for managing the aging effects of change in material properties due to

alkali (cement)-aggregate reaction of concrete in a sea water environment.

3.5A.2.3.20 Unit 2 Discharge Tunnel and Discharge Structure - Aging Management Evaluation -

Table 3.5.2-20

The staff reviewed Table 3.5.2-20 of the LRA, which summarized the results of AMR evaluations

for the Unit 2 discharge tunnel and discharge structure system component groups. The staff

interviewed the applicant's technical staff and reviewed the AMR technical justification for intake

and discharge structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concern. The applicant stated that the use of high-density, low-permeability concrete, and proper arrangement and distribution of reinforcements to control cracking, prevents the leaching of

calcium hydroxide from structural concrete from being of concern. Therefore, the applicant stated that it will manage change of material properties as a potential aging effect on concrete

structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (floor slabs, roof slabs, and walls) component types due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an atmosphere/weather environment is

managed by AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures

monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff

also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds

this program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in a sea water environment. The applicant stated that based on tests conducted on the aggregate and the low-alkali cement used at MPS,

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alkali (cement)-aggregate reaction is not a significant concern. However, the applicant stated

that it will manage change of material properties as a potential aging effect on concrete

structures.

In the LRA,~ the applicant stated that change of material properties for structural reinforced

concrete (floor slabs, roof slabs, and walls) component types in a sea water environment is

managed by AMP B2.1 .23, "Structures Monitoring Program." The staff reviewed the structures

monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff

also reviewed this program With respect to the SRP-LR. On the basis of its review, the staff finds

this program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction of concrete in a sea water

environment.

3.5A.2.3.21 Unit 2 Bypass Line -Aging Management Evaluation - Table 3.5.2-21

The staff reviewed Table 3.5.2-21 of the LRA, which summarized the results of AMR evaluations

for the Unit 2 bypass line system component groups.

In RAI 3.5-13, the staff requested a clarification as to the reason Table 3.5.2-21 of Unit 2 and

Table 3.5.2-31 of Unit 3 listed infrequently accessed area inspection program three times as the

AMP for concrete pipes. The applicant was requested to explain the reason for listing the

program three times.

By letter dated November 9, 2004, the applicant stated that each line item for concrete pipe in

Unit 2 LRA Table 3.5.2-21 on page 3-507 and in Unit 3 Table 3.5.2-31 on page 3-613 was a

unique line item with acorresponding NUREG-I18l Volume2 Item and/or anote. As aresult,

some table data (such as the AMP) was repeated multiple times for these lines.. For example, for

the lines in the tables associated with the change of material properties aging effect for the

concrete pipe, the first line is associated with NUREG-1IB0l item II LA6.1 -b for the leaching of

calcium hydroxide aging mechanism. The second line is associated with NUREG-1 801 item

IIl.A6.1 -e for the aggressive chemical attack aging mechanism. Finally, the third line is not

associated With a NUREG-1801 item since the alkali-aggregate reaction aging mechanism

leading to a change of material properties is not included in NUREG-1 801, although Dominion

has conservatively included this aging mechanism as discussed in LRA Appendix C, Section

C3.2.2. For each of these aging mechanisms that result in the change of material properties aging effect for the concrete pipe, the infrequently accessed areas inspection program AMP

manages the identified aging effect.

The staff finds the applicant's response acceptable because it provided the reason for listing the

infrequently accessed area inspection program as AMP three times for concrete pipes.

3.5A.2.3.22 Tank Foundations - Aging Management Evaluation - Tables 3.5.2-22 and 3.5.2-22a

The staff reviewed Table 3.5.2-22 of the LRA'and Table 3.5.2-22a of the Applicant's supplement dated January11, 2005, which summarized the results of AMR evaluations for the tankfoundations system component groups. The staff interviewed the applicant's technical staff and

reviewed the AMR technical justification for miscellaneous structures.

3-479'..,
In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concern. The applicant stated that the use of high-density, low-permeability concrete, and proper

arrangement and distribution of reinforcements to control cracking, prevents the leaching of

calcium hydroxide from structural concrete from being of concern. Therefore, the applicant

stated that it will manage change of material properties as a potential aging effect on concrete

structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (foundation mat slabs and walls) of the CST foundation and missile barrier, structural

reinforced concrete (footing) of the fire water tanks 1 and 2 foundations, structural reinforced

concrete of the diesel fuel oil storage tank foundation, and structural reinforced concrete

(foundation mat slabs) of the RWST foundation and SBO diesel fuel oil storage tank foundation

component types due to alkali (cement-aggregate reaction and leaching of calcium hydroxide of

concrete in an atmosphere/weather environment is managed by MPS AMP B2.1.23, "Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

In the Applicant's supplement dated January 11, 2005, the applicant stated that change of

material properties of concrete for the structural reinforced concrete of the Unit 2 primary water

storage tank in an atmosphere/weather environment is managed by AMP B2.1.23, 'Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effect of change in material properties of concrete in an atmosphere/weather

environment.

3.5A.2.3.23 Yard Structures - Aging Management Evaluation - Table 3.5.2-23

The staff reviewed Table 3.5.2-23 of the LRA, which summarized the results of AMR evaluations

for the yard structures system component groups. The staff interviewed the applicant's technical

staff and reviewed the AMR technical justification for miscellaneous structures.

In the LRA, the applicant identified no aging effects for aluminum components exposed to an

atmosphere/weather environment, including the lighting poles component type. The GALL

Report does not include this material for these components.

The applicant stated, as documented in the staff's MPS audit and review report for the AMR for

miscellaneous structures, that for aluminum in an air or an atmosphere/weather environment,

there are no potential aging mechanisms for this aluminum and environment combination. The

applicant stated in its MAER that for aluminum material in an air or atmosphere/weather

environment there are no potential aging mechanisms for this material and environment

combination at Unit 2. This conclusion is based on engineering text references that indicate that

3-480
aluminum and its alloys resist attack from a wide range of environments and many chemical

compounds. On the basis of its review of the applicant's documentation, the staff concurred with

the applicant and finds that there are no aging effects requiring management for aluminum in an

atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)-aggregate reaction is not a significant concem. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (foundation mat slabs, roof slabs, and walls) of the RWST valve pit, hatches of pipe

trenches, and structural reinforced concrete (foundation mat slabs and walls) of pipe trenches

component types in an air environment is managed by AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

concem. The applicant stated that the use of high-density, low-permeability concrete, and proper

arrangement and distribution of reinforcements to control cracking, prevents the leaching of

calcium hydroxide from structural concrete from being of concem. Therefore, the applicant

stated that it will manage change of material properties as a potential aging effect on concrete

structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (footings and walls) of transformer firewalls and dikes, structural reinforced concrete of

the A700 switchgear enclosure dike, structural reinforced concrete (footing) of the diesel fuel oil

storage tank dike, structural reinforced concrete (foundation mat slabs, roof slabs, and walls) of

the RWST valve pit, hatches of pipe trenches, and structural reinforced concrete (footing) of

security lighting supports component types due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment is managed by

AMP B2.1.23, "Structures Monitoring Program."iThe staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this

program acceptable for managing the aging effectsfor the above components, of change in

material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment.

3.5A.2.3.24 NSSS Equipment Supports - Aging Management Evaluation - Table 3.5.2-24

The staff reviewed Table 3.5.2-24 of the LRA, which summarized the results of AMR evaluations

for the NSSS equipment supports system component groups. The staff interviewed the

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applicant's technical staff and reviewed the AMR technical justification for NSSS equipment

supports.

In the LRA, the applicant stated that the GALL Report does not include a borated water leakage

environment for the copper alloy steam generator support sliding support assembly component

type. The applicant stated, as documented in the staffs MPS audit and review report for the

AMR for NSSS equipment supports, that for copper alloys in a borated water leakage

environment, boric acid corrosion Is an aging mechanism for loss of material. The applicant

stated that these components do not exceed the temperature threshold of 350 "F. Therefore,

boric acid corrosion is a potential aging mechanism for copper alloys. On the basis of its review

of the applicant's document, the staff concurred with the applicant and finds that boric acid

corrosion is a potential aging mechanism for copper alloys.

In the LRA, the applicant stated that loss of material for the copper alloy steam generator

support sliding support assembly component type in a borated water leakage environment is

managed by AMP B2.1.13, uGeneral Condition Monitoring,' which is a plant-specific program.

The staff reviewed the general condition monitoring program and its evaluation is documented in

Section 3.0.3.3.2 of this SER. The general condition monitoring program manages these aging

effects by visual inspections for evidence of degradation or adverse conditions and includes

heath physics inspections of radiologically controlled areas, system walkdowns by system

engineering, and daily inspections of accessible areas of the plant by plant operators. Evidence

of boron precipitation and active radioactive system leaks is identified during area observations

made by health physics technicians while performing radiologically controlled area surveys. On

the basis of its review, the staff finds the general condition monitoring program acceptable to

manage the aging effect of loss of material for copper alloys for this environment.

In the discussion section of LRA Table 3.5.1, Item 3.5.1-33, the applicant stated, for Group B1.1:

high strength low-alloy bolts in structures and component support systems, that cracking due to

SCC is not an aging effect requiring management for NSSS equipment support bolting.

During the audit and review, the staff noted that SRP-LR Table 3.5-1 recommended GALL AMP

XI.M18, "Bolting Integrity," for managing high strength bolting for NSSS components supports

for crack initiation and growth due to SCC.

By letter dated January 11, 2005, the applicant stated:

For NSSS component supports, bolting material with estimated maximum yield strength

that marginally exceeds 150 ksi is used in limited applications. This bolting is located

inside the Containment in areas where the environment is typically dry and not subject to

high levels of contaminants, such as halogens and sulfur compounds, that result in the

potential for SCC. Leakage within the Containment is monitored and strictly controlled

during plant operation and is investigated and corrected such that the potential for

wetting of NSSS component support bolting is minimal. Based on the marginally

susceptible bolting materials and a dry, non-conducive (benign) service environment,

cracking due to SCC is not an aging effect requiring management for this bolting.

As identified in Millstone Power Station Unit 2 LRA Table 3.5.2-24 and Millstone Power

Station Unit 3 LRA Table 3.5.2-35, loss of material is conservatively considered an aging

effect requiring management for NSSS component support bolting and is managed by

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the Inservice Inspection Program: Systems, Components and Supports AMP (which

includes the elements of the ASME Section Xl, Subsection IWF requirements as

described in LRA Appendix B2.1.18). In addition, loss of material due to the potential for

borated water leakage from nearby components is managed by the boric acid corrosion

and general condition monitoring AMPs.-

Since the boric acid corrosion and general condition monitoring programs ensure a dry, nonconducive (benign) service environment and the bolting material is managed by the inservice

inspection program, the staff finds this acceptable.

3.5A.2.3.25 General Structural Supports - Aging Management Evaluation - Table 3.5.2-25

The staff reviewed Table 3.5.2-25 of the LRAwhich summarizes the results of AMR evaluations

for the general structural supports system component groups. The staff interviewed the

applicant's technical staff and reviewed the AMR technical justification for general structural

supports.

In the LRA, the applicant identified no aging effects for stainless steel components exposed to

air, including structural support components (plate structural shapes, etc.), vendor-supplied

specialty items (spring hangers, struts, clampsvibration isolators, etc.), and sliding support

bearing and sliding surfaces component types.,

During the audit and review, the staff questioned the applicant as to why the AMP B.2.1.18,

'Inservice Inspection Program: Systems, Components and Supports," was not credited to

manage loss of mechanical function, as described in the GALL Report. By letter dated January

11, 2005, the applicant stated that the inspection requirements for these supports associated

with ASME XI IWF that are part of the CLB will carry forward to the period of extended

operation.

On the basis of its review, the staff concurred with the applicant concerning the adequacy of

inspections in accordance with ASME XI IWF.

The applicant also stated in the LRA that the sliding support assemblies within this component

group include parts that are subject to relative motion. Therefore, the components may be

exposed to hard particles that slide or roll across component surfaces under pressure. The

portions of the support assembly that experience relative motion are in contact with Teflon based

Fluorogold pads for low friction. Additionally, the relative motion is a result of thermal growth of

the piping systems due to plant heat-up and cool-down cycles. The plant thermal cycles occur

relatively infrequently and result in limited actual motion for wear to occur. Erosion (wear) of the

surfaces is expected to be insignificant and erosion is not a potential aging mechanism.

Therefore, no aging effects are applicable to this component/commodity group. On the basis of

its review, the staff concurred with the applicant and finds that there are no aging effects

requiring management for metal in an air environment.

In the LRA, .the applicant identified no aging effects for galvanized steel components exposed to

air, including electrical conduit and cable tray component types. Air is not identified in the GALL

Report as an environment for these components and materials.

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On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Significant corrosion of carbon (galvanized

steel) steel requires an electrolytic environment, and a simultaneous presence of oxygen and

moisture. Without the presence of the aggressive environment, carbon steel components will

experience insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Therefore, the staff finds that there are no aging effects requiring

management for metal in an air environment.

In the LRA, the applicant identified no aging effects for aluminum components exposed to an

atmosphere/weather environment, including electrical conduit and cable tray component types.

The GALL Report does not include this material for these components.

The applicant stated, as documented in the staffs MPS audit and review report for the AMR for

general structural supports, that for aluminum in an air or an atmosphere/weather environment,

there are no potential aging mechanisms for this aluminum and environment combination. The

applicant stated in its MAER that for aluminum material in an air or atmosphere/weather

environment there are no potential aging mechanisms for this material and environment

combination at Unit 2. This conclusion is based on engineering text references that indicate that

aluminum and its alloys resist attack from a wide range of environments and many chemical

compounds. On the basis of its review of the applicant's documentation, the staff concurred with

the applicant and finds that there are no aging effects requiring management for aluminum in an

atmosphere/weather environment.

In the LRA, the applicant stated that the GALL Report does not include a borated water leakage

environment for copper alloy sliding support bearing and sliding surfaces component types. The

applicant stated, as documented in the staffs MPS audit and review report for the AMR for

general structural supports, that for copper alloys in a borated water leakage environment, boric

acid corrosion is an aging mechanism for loss of material. The applicant stated that these

components do not exceed the temperature threshold of 350 'F. On the basis of its review of the

applicant's document, the staff concurred with the applicant and finds that boric acid corrosion is

a potential aging mechanism for copper alloys.

In the LRA, the applicant stated that loss of material for copper alloy sliding support bearing and

sliding surfaces component types in a borated water leakage environment is managed by

AMP B2.1.13, "General Condition Monitoring," which is a plant-specific program. The staff

reviewed the general condition monitoring program and its evaluation is documented in Section

3.0.3.3.2 of this SER. The general condition monitoring program manages these aging effects

by visual inspections for evidence of degradation or adverse conditions, and includes heath

physics inspections of radiologically controlled areas, system walkdowns by system engineering,

and daily inspections of accessible areas of the plant by plant operators: Evidence of boron -

precipitation and active radioactive system leaks is identified during area observations made by

health physics technicians while performing radiologically controlled area surveys. On the basis

of its review, the staff finds that the general condition monitoring program is acceptable for

managing the aging effect of loss of material for copper alloys for this environment.

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In the LRA, the applicant identified no aging effects for aluminum components exposed to an air

environment, including electrical conduit and cable tray component types. The GALL Report

does not include this material for these components.

The applicant stated, as documented in the staffs MPS audit and review report for the AMR for

general structural supports, that for aluminum in an air or an atmosphere/weather environment,

there are no potential aging mechanisms for this material and environment combination. The

applicant stated in its MAER that for aluminum material in an air or atmosphere/weather

environment there are no potential aging mechanisms for this material and environment

combination at Unit 2. This conclusion is based on engineering text references that indicate that

aluminum and its alloys resist attack from a wide range of environments and many chemical

compounds. On the basis of its review of the applicant's documentation, the staff concurred with

the applicant and finds that there are no aging effects requiring management for aluminum in an

air environment.

In RAI 3.5-12, the staff requested the information about the boric acid corrosion program on

galvanized steel electrical conduit and cable trays. Table 3.5.2-25 of Unit 2 and Table 3.5.2-36 of

Unit 3 list boric acid corrosion as an MP for galvanized steel electrical conduit and cable trays.

The staff did not find that alvanized steel was included in the boric acid corrosion program as

described in 2.1.3, and requested that the applicant address the discrepancy.

By letter dated November 9, 2004, the applicant stated the electrical conduit and cable trays

listed in Unit 2 LRA Table 3.5.2-25 and Unit 3 LRA Table 3.5.2-36 are fabricated from carbon

steel material that was galvanized for corrosion protection, and has been termed 'galvanized

steel" in the tables. Since no credit has been taken for the galvanized coating as described in

LRA Appendix C, Section C2.4, the electrical conduit and cable trays loss of material aging

effect due to boric acid corrosion is managed with the boric acid corrosion program. Accordingly,

the applicant concluded that this material is in the category of materials termed "carbon and low

alloy steel" in the boric acid corrosion program as described in B2.1.3.

The staff finds the applicant's response acceptable.

3.5A.2.3.26 Miscellaneous Structural Commodities - Aging Management Evaluation -

Table 3.5.2-26

The staff reviewed Table 3.5.2-26 of the LRA, which summarized the results of AMR evaluations

for the miscellaneous structural commodities component groups. The staff interviewed the

applicant's technical staff and reviewed the AMR technical justification for miscellaneous

structural commodities. - -

In the LRA, the applicant stated that the GALL Report does not include silicone rubber for

expansion joint/seismic gap material (between adjacent buildings/structures) component types in

an air environment. The applicant stated, as documented in the staffs MPS audit and review

report for the AMR for miscellaneous structural commodities, that for silicone rubber in an air

environment, irradiation and thermal exposure are aging mechanisms for change of material

properties. The applicant stated that expansion joint/seismic gap material may be exposed to

ionizing radiation values greater than the threshold radiation of 1 OE6 rads and temperatures

greater than the threshold of 95 "F. On the basis of its review of the applicant's document, the

3-485.
staff concurred with the applicant and finds that irradiation and thermal exposure are potential

aging mechanisms for silicone rubber.

In the LRA, the applicant stated that change of material properties for expansion joint/seismic

gap material (between adjacent buildings/structures) component types in an air environment is

managed by AMP B2.1.23, Structures Monitoring Program." The staff reviewed the structures

monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff

also reviewed this program with respect to the SRP-LR. The staff finds that structural monitoring

activities are intended to assess the overall integrity and condition of structures, components,

support systems, and specified architectural details. Qualified personnel perform periodic

inspections to identify any changes in the structural condition, such as change in material

properties. On the basis of its review, the staff finds this program acceptable for managing the

aging effects, for the above components, of change in material properties due to irradiation and

thermal exposure of silicone rubber in an air environment.

In the LRA, the applicant stated that the GALL Report does not include silicone rubber for

expansion joint/seismic gap material (between adjacent buildings/structures) component types in

an air environment. The applicant stated, as documented in the staffs MPS audit and review

report for the AMR for miscellaneous structural commodities, that for silicone rubber in an air

environment, irradiation and thermal exposure are aging mechanisms for cracking. The applicant

stated that expansion joint/seismic gap material may be exposed to ionizing radiation values

greater than the threshold radiation of 10E6 rads and temperatures greater than the threshold of

95 OF. On the basis of its review of the applicant's document, the staff concurred with the

applicant and finds that irradiation and thermal exposure are potential aging mechanisms for

silicone rubber.

In the LRA, the applicant stated that cracking for expansion joint/seismic gap material (between

adjacent buildings/structures) component types in an air environment is managed by

AMP B2.1.23, 'Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. Structural monitoring activities are intended

to assess the overall integrity and condition of structures, components, support systems, and

specified architectural details. Qualified personnel perform periodic inspections to identify any

changes in the structural condition, such as cracking. On the basis of its review, the staff finds

this program acceptable for managing the aging effects, for the above components, of cracking

due to irradiation and thermal exposure of silicone rubber in an air environment.

In the LRA, the applicant stated that the GALL Report does not include Pyrocrete for

fire-resistant coatings component types in an air environment. The applicant stated, as

documented in the staffs MPS audit and review report for the AMR for miscellaneous structural

commodities, that for Pyrocrete in an air environment, irradiation is an aging mechanism for '

change of material properties. The applicant stated that fire-resistant coatings material may be

exposed to ionizing radiation values greater than the threshold radiation of 10E6 rads. On the

basis of its review of the applicant's documentation, the staff concurred with the applicant and

finds that irradiation is a potential aging mechanism for Pyrocrete.

In the LRA, the applicant stated that change of material properties for fire-resistant coatings in

an air environment is managed by AMP B2.1.10, "Fire Protection Program," with an exception.

The staff reviewed the fire protection program and its evaluation is documented in Section

3-486
3.0.3.2.7 of this SER. The staff also reviewed this program with respect to the SRP-LR. The staff

finds that the fire protection program, with an exception, manages, through periodic inspection

and tests, the aging effects on penetration seals, fire barrier walls, ceilings, floors, and all

fire-rated doors that perform a fire barrier intended function. Qualified personnel perform

periodic inspections to identify any changes in condition, such as change in material properties.

On the basis of its review, the staff finds this program acceptable for managing the aging

effects, for the above components, of change in material properties due to irradiation of

Pyrocrete in an air environment. - -

In the LRA, the applicant stated that the GALL Report does not include Pyrocrete for

fire-resistant coating component types in an air environment. The applicant stated, as

documented in the staffs MPS audit and review report for the AMR for miscellaneous structural

commodities, that for Pyrocrete in an air environment, differential movement, shrinkage, and,

vibration are aging mechanisms for cracking. On'the basis of its review of the applicant's

documentation, the staff concurred with the applicant and finds that differential movement,

shrinkage, and vibration are potential aging mechanisms for Pyrocrete.

In the LRA, the applicant stated that cracking forfire-resistant coatings in an air environment is

managed by AMP B2.1.10, "Fire Protection Program," with an exception. The staff reviewed the

fire protection program and its evaluation is documented in Section 3.0.3.2.7,of this SER. The

staff also reviewed this program with respect to the SRP-LR. The staff finds that the fire' -

protection program, with an exception, manages, through periodic inspection and tests, theaging effects on penetration seals, fire barrier walls, ceilings, floors, and all fire-rated doors that

perform a fire barrier intended function. Qualified personnel perform periodic inspections to- .

identify any changes in condition, such as cracking. On the basis of its review, the staff finds this

program acceptable for managing the aging effects, for the above components, of cracking due

to differential movement, shrinkage, and vibration of Pyrocrete in an air environment.

In the LRA, the applicant stated that there are no aging effects for ceramic fire/EQ barrier

penetration seals and concluded that no AMPs are required. The applicant stated that its AMR

conclusion for the material is consistent with the GALL Report, which only calls for aging

management of ceramic fire-barrier penetration seals that are exposed to an outdoor *

environment. On the basis of its review of the applicant's documentation and the fact that the

ceramic materials are exposed only to indoor environments, the staff concurred with the*-

applicant and finds that ceramic fire/EQ barrier penetration seals do not require aging .

management for the period of extended operation.

In the LRA, the applicant identified no aging effects for stainless steel components exposed to

air, including fire boot component types. Air is not identified in the GALL Report as an

environment for these components and materials.,7

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Without the presence of an aggressive

environment, stainless steel components will experience insignificant amounts of corrosion,'and

no aging effects are applicable to this component/commodity group. Therefore, the staff' -

concludes that there are no aging effects requiring management for metal in an air environment.

3-487-
In the LRA, the applicant identified no aging effects for carbon steel components exposed to air,

including cable tray cover and assembly; junction, terminal, and pull boxes; panels and cabinets;

switchgear enclosures; and electrical component supports within cabinets and panels

component types. Air is not identified in the GALL Report as an environment for these

components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended,

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, carbon steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Therefore, the staff finds that there are no aging effects requiring

management for metal in an air environment.

In the LRA, the applicant stated that the GALL Report does not include marinite radiant energy

shields component types in an air environment. The applicant stated, as documented in the

staff's MPS audit and review report for the AMR for miscellaneous structural commodities, that

for marinite radiant energy shields in an air environment, irradiation is a potential aging

mechanism for change of material properties. The applicant stated that marinite radiant energy

shields may be exposed to ionizing radiation values greater than the threshold radiation level of

10E6 rads. On the basis of its review of the applicant's documentation, the staff concurred with

the applicant and finds that irradiation is a potential aging mechanism for marinite radiant energy

shields.

In the LRA, the applicant stated that change of material properties for marinite radiant energy

shields in an air environment is managed by AMP B2.1.1O, 'Fire Protection Program," with an

exception. The staff reviewed the fire protection program and its evaluation is documented in

Section 3.0.3.2.7 of this SER. The staff also reviewed this program with respect to the SRP-LR.

The staff finds that the fire protection program, with an exception, manages, through periodic. -

inspection and tests, the aging effects on penetration seals, fire barrier walls, ceilings, floors, :

and all fire-rated doors that perform a fire barrier intended function. Qualified personnel perform'

periodic inspections to identify any changes in condition, such as change in material properties.

On the basis of its review, the staff finds this program acceptable for managing the aging

effects, for the above components, of change in material properties due to irradiation of marinite

radiant energy shields in an air environment.

In the LRA, the applicant stated that the GALL Report does not include marinite radiant energy

shields component types in an air environment. The applicant stated, as documented in thestaffs MPS audit and review report for the AMR for miscellaneous structural commodities, that

for marinite radiant energy shields in an air environment, differential movement, shrinkage, and',

vibration as aging mechanisms for cracking. The applicant stated that marinite radiant energy

shields are subject to cracking due. to differential movement,- shrinkage, and vibration. On the

basis of its review of the applicant's documentation, the staff concurred with the applicant and

finds that differential movement, shrinkage, and vibration are potential aging mechanisms for

marinite radiant energy shields.

3488
In the LRA, the applicant stated that cracking for marinite radiant energy shields in an air

environment is managed by AMP B2.1.10, "Fire Protection Program," with an exception. The

staff reviewed the fire protection program and its evaluation is documented in Section 3.0.3.2.7

of this SER. The staff also reviewed this program with respect to the SRP-LR. The staff finds

that the fire protection program, with an acceptable exception, manages, through periodic

inspection and tests, the aging effects on penetration seals, fire barrier walls, ceilings, floors,

and all fire-rated doors that perform a fire barrier intended function. Qualified personnel perform

periodic inspections to identify any changes in condition, such as cracking. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of cracking due to differential movement, shrinkage, and vibration of marinite

radiant energy shields in an air environment. '.

In the LRA, the applicant stated that the GALL-Report does not include cracking of rubber for

flood prevention plugs component types in an air environment. The applicant stated, as

documented in the staffs -MPS audit and review report for the AMR for miscellaneous structural

commodities, that for rubber in an air environment, thermal exposure is an aging mechanism for

cracking. The applicant stated that rubber for flood prevention plugs may be exposed to.

temperatures greater than the threshold of 95 OF. On the basis of its review of the applicant's

documentation, the staff concurred with the applicant and finds that thermal exposure is a

potential aging mechanism for rubber. '

In the LRA, the applicant stated that cracking for rubber flood prevention plugs in an air

environment is managed by AMP B2.1.23, "Structures Monitoring Program." The staff reviewed

the structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. The staff finds that

structural monitoring activities are intended to assess the overall integrity and condition of

structures, components, support systems, and specified architectural details. Qualified personnel perform periodic inspections to identify any changes in condition, such as cracking. On the basis

of its review, the staff finds this program acceptable for managing the aging effects, for the

above components, of.cracking due to thermal exposure of rubber in an air environment.

The applicant stated, as documented in the staffs MPS audit and review report for the AMR for

miscellaneous structural commodities, that the MAER includes an evaluation of aluminum

material in an air or an atmosphere/weather environment, and concluded that there are no

potential aging mechanisms for these material/environment combinations. During the audit and,

review, the staff asked the applicant to explain why the evaluation is not in the MAER and the

basis for its conclusions. The applicant stated to the staff that the MAER addresses aluminum

material in an air or atmosphere/weather environment, and concluded that there are no potential

aging mechanisms for these materiaVenvironment combinations at Unit 2. This conclusion is

based on engineering test references, 1Handbook of Corrosion Data," and "Uhlig's Corrosion

Handbook." The "Handbook of Corrosion Data" indicates that aluminum and its alloys resist

attack by a wide range of environments and many chemical compounds. Consequently,

aluminum is one of the metals most thought of.by the public and engineering community when

lower temperature corrosion resistance is considered. "Uhlig's Corrosion Handbook" indicates

that aluminum-based alloys as a class are highly resistant to normal outdoor exposure

conditions. This conclusion in the MAER is also based on staff determinations, as presented in

3-489 .
the SERs for other applicants' LRAs for plants that have environments, particularly outdoor

environments, similar to MPS. Further, this conclusion is also supported by a review of Unit 2

plant-specific operating experience, which identifies no instances of loss of material for -

aluminum in an air or atmosphere/weather environment. The applicant stated to the staff that the

conclusions in the LRA remain valid and unchanged. However, the applicant initiated a

document modification request revise the MAER. Specifically, the MAER was revised to include

the cited references in the aluminum/air and aluminum/atmosphere/weather sections. On the

basis of its review, the staff finds the applicant's response to be acceptable.

The applicant stated, as documented in the staffs MPS audit and review report for the AMR for

miscellaneous structural commodities that, for fire/EQ barrier penetration seals' (including*

ceramic damming material) indicates N/A for the evaluation group. During the audit and review,

the staff asked the applicant to explain how the ceramic damming material was evaluated for

aging effects. The applicant stated to the staff that ceramic materials are similar to the glass and

porcelain that are described in the MAER as having no aging effects. In its review, the staff finds

that the applicant did not properly document this conclusion and the MAER does not specifically

address ceramics. The applicant stated that the conclusions in the LRA remain valid and

unchanged. However, the applicant initiated document modification request to revise the MAER

to include ceramic along with glass and porcelain as having no aging effects that require

evaluation for any application or environment to which it is exposed. In addition, the applicant

initiated document modification requests to revise the AMR for miscellaneous structural

commodities to indicate, in Section 4.0, that the MAER indicates no potential aging effects and

no aging management required for ceramics: Therefore, the AMR does not evaluate aging

mechanisms for the ceramic blanket or ceramic board in an air environment. On the basis of its

review, the staff finds the applicant's response to be acceptable.

3.5A.2.3.27 Load Handling Cranes and Devices - Aging Management Evaluation -

Table 3.5.2-27

The staff reviewed Table 3.5.2-27 of the LRA, which summarized the results of AMR evaluations

for the load handling cranes and devices component groups. The staff interviewed the

applicant's technical staff and reviewed the AMR technical justification for load handling cranes

and devices.

In LRA, the applicant identified no aging effects for stainless steel components exposed to air,

including fuel transfer machine and tilting mechanism support members (structural frame, tracks,

and anchorage) component types. Air is not identified in the GALL Report as an environment for

these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Without the presence of an aggressive

environment, stainless steel components will experience insignificant amounts of corrosion, and

no aging effects are applicable to this componenrtcommodity group. Therefore, the staff

concluded that there are no aging effects requiring management for metal in an air environment.

3-490
3.5A.2.3.28 Unit 2 Condensate Polishing Service Water Strainer House, Unit 2 Hydrogen

Cylinder Storage Area, Unit 2 Sodium Hypochlorite Building

In its LRA supplement dated December 3,2004, the applicant stated that changes of material

properties in the structural reinforced concrete in an air or atmosphere/weather is managed by

the AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. The staff finds that structural monitoring

activities are intended to assess the overall integrity and condition of structures,-components,

support systems, and specified architectural details. Qualified personnel perform periodic

inspections to identify any changes in condition, such as cracking. On the basis of its review, the

staff finds this program acceptable for managing the aging effects of changes of material

properties for the above component.

In the LRA supplement dated December 3, 2004, the applicant also stated that cracking of the

concrete masonry block walls in atmosphere/weather environment is is managed by

AMP B2.1.23, 'Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. The staff finds that structural monitoring

activities are intended to assess the overall integrity and condition of structures, components,

support systems, and specified architectural details. Qualified personnel perform periodic

inspections to identify any changes in condition, such as cracking. On the basis of its review, the

staff finds this program acceptable for managing the aging effects of cracking for the above

component.

Conclusion. On the basis of its review, the staff finds that the applicant appropriately evaluated

AMR results involving material, environment, aging effect requiring management, and AMP

combinations that are not evaluated in the GALL Report. The staff finds that the applicant has

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21 (a)(3).

3.5A.3 Conclusion

On the basis of its review, the staff concludes that the applicant has demonstrated that the aging

effects associated with the containment, structures and component supports systems

components will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by 1 0 CFR 54.21 (a)(3).

The staff also reviewed the applicable FSAR supplement program summaries and concludes

that they are adequately describe the AMPs credited for managing aging of the containment,

structures and component supports systems, as required by 10 CFR 54.21(d).

3-491
3.5B Unit 3 Aging Management of Containment. Structures and Component Supports

This section of the SER documents the staffs review of the applicant's AMR results for the

containment, structures and component supports associated with the following structures:

* containment

* structures and structural components

* Unit 3 containment enclosure building

* Unit 3 auxiliary building

* Unit 3 control building

* Unit 3 fuel building

* railroad canopy

* Unit 3 hydrogen recombiner building

* Unit 3 engineered safety features building

* Unit 3 main steam valve building

* Unit 3 emergency generator enclosure and fuel oil tank vault

* Unit 2 fire pump house

* Unit 3 fire pump house

* Unit 3 service building

* Unit 3 turbine building

* Unit 3 auxiliary boiler enclosure

* Unit 3 technical support center

* Unit 3 maintenance shop

* Unit 3 Waste Disposal Building

* SBO diesel generator enclosure and fuel oil tank vault

* Unit 3 condensate polishing enclosure

* Unit 2 condensate polishing facility and warehouse no. 5

* security diesel generator enclosure'

* stack monitoring equipment building

* millstone stack

* switchyard control house

* 345kV switchyard

* Unit 3 circulating and service water pumphouse

* Unit 3 west retaining wall

* sea wall

* Unit 3 circulating water discharge tunnel and discharge structure

Unit 3 recirculation tempering line

* vacuum priming pumphouse

* tank foundations

* yard structures

* NSSS equipment supports

* general structural supports

* miscellaneous structural commodities

* load handling cranes and devices

3-492
3.5B.1 Summary of Technical Information in the Application

In LRA Section 3.5, the applicant provided AMR results for containment, structures and

component supports components and component groups. In LRA Table 3.5.1, "Summary of

Aging Management Evaluations in Chapters II and IlIl of NUREG-1801 for Structures andComponent Supports," the applicant provided a summary comparison of its AMRs with the

AMRs evaluated in the GALL Report for the containment, structures and component supports

components and component groups.

The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The-plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.5B.2 Staff Evaluation

The staff reviewed LRA Section 3.5 to determine if the applicant provided sufficient information

to demonstrate that the effects of aging for the containment, structures and components

supports system components that are within the scope of license renewal and subject to an AMR

will be adequately managed so that the intended functions will be maintained consistent with the.

CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

Also, the staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report; However, the staff did verify that the material presented

in the LRA was applicable and that the applicarit had identified the appropriate GALL AMPs. The

staffs evaluations of the AMPs are documented in Section 3.0.3 of this SER. Details of the

staffs audit evaluation are documented in the staffs MPS audit report and summarized in

Section 3.5B.2.1 of this SER.

The staff also performed an onsite audit of those AMRs that were consistent with the GALL

Report and for which further evaluation is recommrended. The staff verified that the applicant's

further evaluations were bconsistent with the acceptance criteria in Section 3.5.2.2 of

NUREG-1800, aStandard Review Plan for Review of License Renewal Applications for Nuclear

Power Plants," dated July 2001. The staff's audit evaluations are documented in the staff's MPS

audit report and summarized in Section 3.5B.2.2 of this SER.

The staff performed an onsite audit and conducted a technical review of the remaining AMRs

that were not consistent with the GALL Report. The audit and technical review included

evaluating whether all plausible aging effects were identified and the aging effects listed were

appropriate for the combination of materials and environments specified. The staffs audit

evaluations are documented in the staffs MPS audit report and summarized in Section 3.5B.2.3

of this SER. The staffs evaluation of its technical review is also documented in Section 3.5B.2.3

of this SER.

3-493
Finally, the staff reviewed the AMP summary descriptions in the FSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the containment, structures and components supports system components.

Table 3.5B-1 below provides a summary of the staffs evaluation of components, aging effects/mechanisms, and AMPs listed in LRA Section 3.5 that are addressed in the GALL

Report.

Table 3.5B-1 Staff Evaluation for Containment, Structures and Component Supports in the

GALL Report

Component Group . AgingEffctV.--.-AMPi ' --. .' GALI.' DMP in LRA - Staff Evaluatlon'.

;^.;- '.L} nl rnh;. '-. R': Po.: i-... - i .7 . -

Common Components of All Types of PWR and BWR Containment

Penetration sleeves, Cumulative fatigue TLAA evaluated in TLAA This TLAA is

penetration bellows, damage (CLB accordance with evaluated in Section

and dissimilar metal fatigue analysis 10 CFR 54.21 (c) 4.6B.

welds exists)

(Item Number

3.5.1-01)

Penetration sleeves, Cracking due to Containment Not Consistent with

bellows, and cyclic loading; crack inservice GALL (See Section

dissimilar metal initiation and growth inspection (ISI) 3.5B.2.2.1)

welds due to SCC and Containment

(Item Number leak rate test

3.5.1-02) .

Penetration sleeves, Loss of material due Containment ISI Inservice inspection Consistent with

bellows, and to corrosion and Containment program: containment GALL, which

dissimilar metal leak rate test inspections (B2.1.16) recommends no

welds further evaluation

(Item Number (See Section

3.5.1-03) 3.5B.2.1)

Personnel airlock Loss of material due Containment IS3 Inservice inspection Consistent with

and equipment to corrosion and Containment program: containment GALL, which

hatch leak rate test inspections (B2.1.16) recommends no

(Item Number further evaluation

3.5.1-04) (See Sections

3.0.3.2.11 and

. 3.5B.2.1)

Personnel airlock Loss of leak Containment leak Inservice inspection Consistent with

and equipment tightness in closed rate test and Plant program: containment GALL, which

hatch position due to Technical inspections (B2.1.16) recommends no

(Item Number mechanical wear of Specifications further evaluation

3.5.1-05) locks, hinges, and (See Sections

closure 3.0.3.2.11 and

mechanisms 3.5B.2.1)

3-494
C orint Group zAging Effec AM li. AM-_; -. AMPIn LRAi_.- -taff Evluation

*:-ic:'Ž

2

. -. , _:.Mechanism 'a.7RoeprtPw-.:- -

Seal, gaskets, and Loss of sealant and Containment ISI Inservice inspection Not Consistent with

moisture baniers leakage through and Containment program: containment GALL (See Sections

(Item Number containment due to leak rate test inspections (B2.1.16); 3.0.3.2.11 and

3.5.1-06) deterioration of joint Work control process 3.0.3.3.4)

seals, gaskets, and (B2.1.25)

moisture barriers

PWR Concrete (Reinforced and Prestressed) and Steel Containment

BWR Concrete (Mark 11 and l1l) and Steel (Mark I, II, and l1l) Containment

Concrete elements: Aging of accessible Containment ISI Inservice inspection Consistent with

foundation, dome, and inaccessible program: containment GALL, which

and wall concrete areas due inspections (82.1.16) recommends further

(Item Number to leaching of evaluation (See

3.5.1-07) calcium hydroxide, Section 3.5B.2.2.1)

aggressive chemical

attack, and

corrosion of

embedded steel

Concrete elements: Cracks, distortion, Structures Structures monitoring Consistent with

foundation and increases in Monitoring program (82.1.23) GALL (See Section

(Item Number component stress 3.58.2.2.1)

3.5.1-08) level due to

settlement

Concrete elements: Reduction In Structures - Structures monitoring Consistent with

foundation - foundation strength Monitoring program (B2.1.23) GALL (See Section

(Item Number due to erosion of 3.58.2.2.1) 3.5.1-09) porous concrete

subfoundation

Concrete elements: Reduction of Plant-specific Not Applicable (See

foundation, dome, strength and Section 3.58.2.2.1)

and wall modulus due to

(Item Number elevated

3.5.1-10) temperature

Prestressed Loss of prestress TLAA evaluated in TLAA Not Applicable. This

containment: due to relaxation, accordance with TLAA Is evaluated

tendons and shrinkage, creep, 10 CFR 54.21 (c) in Section 4.5.1.

anchorage and elevated

components temperature (Item Number

3.5.1-11)

Steel element: liner Loss of material due Containment ISI Inservice inspection Consistent with

plate and ; to corrosion in and Containment program: containment GALL, which

containment shell accessible and leak rate test inspections (82.1.16) recommends further

(Item Number inaccessible areas evaluation (See

3.5.1-12) Section 3.58.2.2.1)

Steel elements: Loss of material due Protective coating Inservice inspection Not Consistent with

protected by coating to corrosion in monitoring and program: containment GALL (See Section

(Item Number accessible areas maintenance inspections (82.1.16) 3.5B.2.2.1)

3.5.1-14) only

3-495
Component Group' ;- AgIni ffecl .t- A Ii G A in LRA tff Ea ti

;_________________ ' .': ''- ri M '..i ; -Re 

Prestressed Loss of material due Containment ISI Inservice inspection Not applicable,

containment, -to corrosion of program: containment containment Is not a

tendons and prestressing inspections (B2.1.16) prestressed

anchorage tendons and structure. (See

components anchorage Section 3.5B.2.2.1)

(Item Number components

3.5.1-15)

Concrete elements: Scaling, cracking, Containment ISI Inservice inspection Consistent with

foundation, dome, and spalling due to program: containment GALL, which

and wall freeze-thaw; inspections (62.1.16) recommends no

(Item Number expansion and further evaluation

3.5.1-16) cracking due to (See Section

reaction with 3.5B.2.2.1)

aggregate

Class I Structures

All Groups except All types of aging Structures Structures monitoring Not Consistent with

Group 6: accessible effects Monitoring program (B2.1.23); GALL (See Section

interiorlexterior Infrequently accessed 3.5B.2.2.2)

concrete steel areas inspection

components program (62.1.15)

(Item Number 3.5.1-20)

Groups 1-3, 5, 7-9: Aging of Plant-specific Structures monitoring Consistent with

Inaccessible inaccessible program (62.1.23) GALL, which

concrete concrete areas due recommends further

components, such to aggressive evaluation (See

as exterior walls chemical attack, Section 3.5B.2.2.2)

below grade and and corrosion of

foundation embedded steel

(Item Number

3.5.1-21)

Group 6: all All types of aging Inspection of Structures monitoring Not Consistent with

accessible I effects, including water-control program (B2.1.23); GALL (See Sections

inaccessible loss of material due structures or Infrequently accessed 3.0.3.2.16 and

concrete, steel, and to abrasion, FERCIUS Army areas inspection 3.0.3.3.3)

earthen cavitation, and Corp of Engineers program (B2.1.15)

components corrosion dam inspection

(Item Number and maintenance

3.5.1-22)

Group 5: liners Crack Initiation and Water chemistry Chemistry control for Consistent with

(Item Number growth due to SCC; and monitoring primary systems GALL, which

3.5.1-23) loss of material due spent fuel pool program (62.1.5) recommends no

to crevice corrosion water level further evaluation

(See Section

3.56.2.1)

Groups 1-3, 5, 6: all Cracking due to Masonry Wall Structures monitoring Consistent with

masonry block walls restraint, shrinkage, program (62.1.23) GALL, which

(Item Number creep, and recommends no

3.5.1-24) aggressive further evaluation

environment (See Section

3.5B.2.1)

3-496
Comiponent Groupb' -. 'AgIrg Effec iAMPn:n ,. GALL AMP LStaff :- EvaluatIon-.

, _ ' Mechanismr . R:ort-.'--.;. "

Groups 1-3, 5, 7-9: Cracks, distortion, Structures Not Consistent with

foundation and Increases in Monitoring GALL (See Section

(Item Number component stress 3.58.2.2.1)

3.5.1-25) level due to

settlement

Groups 1-3, 5-9: Reduction in Structures Not Consistent with

foundation foundation strength Monitoring GALL (See Section

(Item Number due to erosion of 3.58.2.2.1)

3.5.1-26) porous concrete

subfoundation

Groups 1-5: Reduction of Plant-specific Not Applicable (See

concrete strength and Section 3.58.2.2.1)

(Item Number modulus due to

3.5.1-27) elevated '

temperature '

Component Supports

Groups 7. 8: liners ' Crack initiation and Plant-specific Work control process Not Consistent with

(Item Number growth due to SCC; (82.1.25) GALL (See Section

3.5.1-28) loss of material due. 3.58.2.2.2)

to crevice corrosion

All Groups support Aging of component Structures Structures monitoring Not Consistent with

members: anchor supports Monitoring program (82.1.23); GALL (See Section

bolts, concrete General condition 3.58.2.2.3)

surrounding anchor . monitoring (82.1.13);

bolts, welds, grout Battery rack

pad, bolted i inspections (82.1.1);

connections, etc. . Infrequently accessed

(Item Number areas Inspection

3.5.1-29) _ program (82.1.15)

Groups 81.1, 81.2, Cumulative fatigue TLAA evaluated In TLAA This TLAA is

and 81.3: support damage (CLB accordance with - evaluated In Section

members: anchor fatigue analysis 10 CFR 54.21(c) 4.38, Metal Fatigue

bolts and welds exists)

(Item Number

3.5.1-30)

All Groups: support Loss of material due Boric acid Boric acid corrosion Not Consistent with

members: anchor to boric acid corrosion' (B2.1.3); GALL

bolts and welds corrosion i General condition (See Sections

(Item Number monitoring (82.1.13) 3.58.2.3.35 and

3.5.1-31) 3.58.2.3.36)

Groups 81.1, 81.2, Loss of material due ISI - - Inservice Inspection Not Consistent with

and 81.3: support to environmental program: systems, GALL, which

members: anchor corrosion; loss of - components and recommends no

bolts, welds, spring mechanical function supports (82.1.18); further evaluation

hangers, guides, due to corrosion, Structures monitoring (See Section

stops, and vibration distortion, dirt,', -. .program (82.1.23); 3.58.2.1)

isolaters overload, etc. - : General condition

(Item Number monitoring (82.1.13)

3.5.1-32) -

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Component Group-AMPn ' - Staff Ev aIuatio'w _si- - 'a; Mechanism _ epor: '.-..

Group BI.1: high Crack initiation and Bolting integrity Consistent with

strength low-alloy growth due to SCC GALL

bolts (See Section

(Item Number 3.5B.2.3.35)

3.5.1-33)

The staff's review of the MPS containment, structures and component supports and associated

components followed one of several approaches. One approach, documented in Section

3.5B.2.1, involves the staff's review of the AMR results for components in the containment,

structures and component supports that the applicant indicated are consistent with the GALL

Report and do not require further evaluation. Another approach, documented in Section

3.5B.2.2, involves the staff's review of the AMR results for components in the containment,

structures and component supports that the applicant indicated are consistent with the GALL

Report and for which further evaluation is recommended. A third approach, documented in

Section 3.5B.2.3, involves the staff's review of the AMR results for components in the

containment, structures and component supports that the applicant indicated are not consistent

with the GALL Report or are not addressed in the GALL Report. The staff's review of AMPs that

are credited to manage or monitor aging effects of the containment, structures and component

supports components is documented in Section 3.0.3 of this SER.

3.5B.2.1 AMR Results ThatAre Consistent with the GALL Report, for Which Further

Evaluation is Not Recommended

Summary of Technical Information in the ADplication. In Sections 3.5.2.1.1 through 3.5.2.1.38 of

the LRA, the applicant identified the materials, environments, and aging effects requiring

management. The applicant identified the following programs that manage the aging effects

related to the containment, structures and component supports components:

* boric acid corrosion program

* chemistry control for primary systems program

* general condition monitoring program

* inservice inspection program: containment inspections

* structures monitoring program

* work control process program

* infrequently accessed areas inspection program

* inservice inspection program: systems, components and supports * battery rack inspections

* fire protection program

* inspection activities: load handling cranes and devices

Staff Evaluation. In Tables 3.5.2-1 through 3.5.2-38 of the LRA, the applicant provided a

summary of AMRs for the containment and containment internals, auxiliary building, turbine

building and circulating and service water pumphouse,, yard structures, and structural

commodities, and identified which AMRs it considered to be consistent with the GALL Report.

For component groups evaluated in the GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the GALL Report does not recommend further

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evaluation, the staff performed an audit and review to determine whether the plant-specific

components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes described how the information

in the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicated the AMR was consistent with the GALL Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the-AMP is consistent with the'AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicated that the AMR line item is consistent with the GALL Report for component,

material, environment; and aging effect. In addition, the AMP takes some exceptions to the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by the

applicant was consistent with the AMP identified in the GALL Report and whether the AMR was

valid for the site-specific conditions.

Note C indicated that the component for the AMR line item is different, but consistent with the

GALL Report for material, environment, and aging effect. In addition, the AMP is consistent with

the AMP identified by the GALL Report. This note indicates that the applicant was unable' to find

a listing of some system components in the GALL Report. However, the applicant identified a

different component in the GALL Report that had the same material, environment, aging effect,

and AMP as the component that was under review. The staff audited these line items to verify

consistencywith the GALL'Report. The staff also determined whether the AMR line item of the

different component was applicable to the component under review and whether the AMR was

valid for the site-specific conditions.

Note D indicated that the component for the'AMR line item is different, but consistent with the'

GALL Report for material, environment, and aging effect. In addition, the AMP takes some

exceptions to the AMP identified in the GALL Report. The staff audited these line items to verify

consistency with the GALL Report. The staff verified whether the AMR line item of the different

component was applicable to the component un'der review. The staff verified whether the'.

identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The staff

also determined whether the AMP identified by the applicant was consistent with the AMP

identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note E indicated that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report., The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified by

the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the LRA, as documented

in its MPS audit and review report. The staff did not repeat its review of the matters described in

the GALL Report. However, the staff did verify'that the material presented in the LRA was

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applicable and that the applicant had identified the appropriate GALL Report AMRs. The staff

evaluation is discussed below.

3.5B.2.1.1 Aging of Component Supports

In LRA Table 3.5.2-37 (page 3-655), the applicant stated that change of material properties and

cracking of rubber material for watertight door gaskets in an air environment is managed by

MPS AMP B2.1.23, 'Structures Monitoring Program." The applicant also referenced GALL Item

Ill. Item B4.2-a which specifies GALL AMP XI.S6, "Structures Monitoring Program" to manage

these aging effects. The staff noted that Note E was used and that the component listed in the

GALL Report is for vibration isolation elements while the component listed in the LRA table is a

watertight door gasket. During the audit and review, the staff asked the applicant to explain why

Note E was used instead of Note C.

In an LRA supplement dated July 7, 2004, the applicant stated that Note E should be Note C for

the rubber material of the watertight door gasket structural member. In addition, the applicant

made the same correction in the Unit 3 technical report for miscellaneous structural

commodities. On the basis of its review, the staff finds the applicant's response acceptable.

In LRA Table 3.5.2-25 (page 3-535), the applicant stated that loss of material of carbon steel

and low-alloy steel for structural support components in an air or atmosphere/weather

environment is managed by MPS AMP B2.1.15, "Infrequently Accessed Areas Program," MPS

AMP B2.1.23, "Structures Monitoring Program," and MPS AMP B2.1.13, "General Condition.

Monitoring" and GALL Item I I.B2.1-a is matched. During the audit and review, the staff asked

the applicant to explain why Note E was used for the infrequently accessed areas inspection

program, Note A used for the structures monitoring program, and Note C was used for the

general condition monitoring program. The applicant stated in that the Note C was incorrectly

applied to these general condition monitoring line items and includes similar line items in LRA

Table 3.5.2-36. Note A should have been applied since the general condition monitoring

program performs the same inspections of structural supports as the structures monitoring

program and is considered equivalent to GALL AMP XI.S6, "Structures Monitoring Program."

MPS AMP B2.1.23 is used to manage aging of non-ASME class, large equipment supports; andMPS AMP B2.1.13 is used to manage aging of other non-ASME class supports.

In an LRA supplement dated July 7, 2004, the applicant stated that Note C should be Note A for

the general condition monitoring line items in Unit 3 Table 3.5.2-36 (pages 3-643 through 3-648)

since the general condition monitoring program performs the same inspections of structural

supports for the structures monitoring program and is considered equivalent to GALL AMP

XI.S6, 'Structures Monitoring Program."

On the basis of its review of the applicant response, the staff finds the response acceptable.

On the basis of its audit and review, the staff determined that for AMRs not requiring further

evaluation, as identified in LRA Table 3.5.1 (Table 1), the applicant's reference to the GALL

Report are acceptable, that the line items are consistent with GALL, and no further staff review

is required.

Staff RAls Pertaining to Recent Operating Experience and Emerging Issues. Because the GALL

Report and SRP-LR were issued in July 2001, these documents do not reflect the most current

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recommendations for managing certain aging effects that have been the subject of recent

operating experience or the topic of an emerging issue. As a result, the staff issued RAls to

determine how the applicant proposed to address these items for license renewal.

In RAI 3.5-5, the staff requested information about the members of structures other than

containments that uses the structures monitoring program as an AMP. Under column "Structural

Member" in Table 3.5.2-x, structures and component supports, structures monitoring program

was listed as an AMP for many structural members, such as doors, sliding bearings, metal siding

sealants, roofing, siding, scuppers, miscellaneous steel, expansion joint/seismic gap material,

and flood door/gate gasket. Item 18 in Table A6.0-1, License Renewal Commitments, stated,

"The Structures Monitoring Program and implementing procedures will be modified to include all

in-scope structures." The staff assumed that the words win-scope structures" included all

structural members listed in Table 3.5.2-x that use the structures monitoring program as an

AMP. The staff requested that the applicant confirm whether the staff's assumption is correct.

By letter dated November 9, 2004, the applicant stated that this assumption is correct. Any in

scope structural members that are not currently in the structures monitoring program, such as

those listed above, but are required to be inspected, will be added to the program prior to the

period of extended operation.

The staff finds the applicant's response acceptable.

In RAI 3.5-11, the staff requested the applicant to discuss whether Millstone Units 2 or 3 had

piping and component supports that are anchored to concrete by using bolts with yield strength

greater than 150 ksi. If yes, the applicant was requested to identify the AMP for those bolts and

provide basis for the selection of the AMP if bolting integrity program is not selected.

By letter dated November 9,2004, the applicant stated that no piping or component supports in

Millstone Unit 2 or 3 have been identified as being anchored to concrete using anchor bolts with

specified yield strengths greater than 150 ksi.

The staff finds the applicant's response acceptable.

As a result of issues raised during the scoping and screening methodology audit (discussed in

Section 2.1.3.1), the staff requested additional information concerning newly in-scope structures.

The following is a discussion of the applicant's responses and the staff evaluations.

In response to RAI 2.4-7 (Unit 2) and RAI 2.4-11 (Unit 3), the applicant stated that the posttensioned anchorage system for the sea walls is in scope and the AMR result concluded that

there are no aging effects requiring management. The staff reviewed the anchorage detail, as

shown in FSAR Figure 2.5-15, and found that there is sufficient concrete surrounding the posttensioned anchorage system to protect it from the environment and, therefore, concurs with the

applicant's conclusion.

In response to RAI 2.4-3, the applicant added thermal insulation around high temperature piping

containment penetrations to the scope of license renewal. The'applicant's AMR result concluded

that there are no aging effects for the fiberglass, asbestos, and calcium silicate piping

penetration thermal insulation. However, the applicant stated that the localized concrete

temperature in the vicinity of high energy piping containment penetrations is maintained below

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the threshold value by the containment penetration cooling system, which consists of a

ventilation system in Unit 2 (the containment penetration cooling system described in LRA

Section 2.3.3.18) and a water cooling system in Unit 3 (as part of the reactor plant component

cooling system described in LRA Section 2.3.3.6). Since the concrete temperature around the

containment penetration is properly maintained, the staff considers the applicant's proposal

acceptable.

In response to RAI 2.4-5, the applicant added the sealant and the penetration seals component

types to the scope of license renewal, and stated that they will be monitored by containment

Inspection AMP as modified by the response to RAI 3.5-1 provided in Dominion letter SN 04-

674, dated November 9, 2004. The staff accepts the AMP as discussed in Section 3.5B.2.3.1 of

this SER.

In response to RAI 2.4-13, the applicant stated that the groundwater underdrains storage tank

and associated piping have bee added to the scope of license renewal. The staff evaluation is

documented in Section 2.4B.1.2 of this SER.

In response to RAI 2.4-14, the applicant stated that rock dowels and rock anchors are in scope

and are included in the structural member "Structural Reinforced Concrete" in LRA Tables 2.4.2-

2, 2.4.2-12, and 2.4.2-13 and subject to aging management. The applicant was requested to

identify the (1) the difference between rock dowels and rock anchors, and (2) the respective

AMR/AMP sections in the LRA, if they were already included, or provide the AMR/AMP if they

did not exist.

The applicant stated in its January 11, 2005 response that the rock dowels were designed as a

passive support system (not pre-stressed). The rock anchors were stressed and locked off at a

permanent load (pre-stressed) during installation. The rock dowels and rock anchors are not

uniquely identified in the license renewal application, but are considered to be embedded steel in

concrete, similar to reinforcing steel, plates, and anchor bolts, as described in LRA Section

C3.3.3 'Corrosion of Embedded Steel - Concrete. The rock dowels and rock anchors are

included with the structural reinforced concrete structural member in the aging management

review results tables for the applicable structures. Rock dowels are part of the Auxiliary Building

foundation mat slab and the aging management review results are provided in LRA Table 3.5.2-

3 as structural reinforced concrete in a soil environment. Rock anchors are part of the foundation

mat slab for the Service Building and part of the footing and grade beams for the Turbine

Building and the aging management review results are provided in LRA Tables 3.5.2-13 and

3.5.2-14 as structural reinforced concrete in a soil environment.

The staff accepts the applicant's clarification.

On the basis of its audit and review, the staff determined that for AMRs not requiring further

evaluation, as identified in LRA Table 3.5.1 (Table 1), the applicant's references to the GALL

Report are acceptable, that the line items are consistent with GALL, and no further staff review

is required.

Conclusion. The staff has evaluated the applicant's claim of consistency with GALL Report. The:

staff also has reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff finds that the AMR results, which the applicant claimed to be consistent with the GALL

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Report, are consistent with the AMRs in the GALL Report. Therefore, the staff finds that the

applicant has demonstrated that the effects of aging for these components will be adequately

managed so that their intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.5B.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Application. In Section 3.5.2.2 of the LRA, the applicant

provided further evaluation of aging management as recommended by the GALL Report for

containment, structures and component supports.~ The applicant provided information concerning

how it will manage the following aging effects: -

* aging of inaccessible concrete areas

* cracking, distortion, and increase in component stress level due to settlement; reduction

of foundation strength due to erosion of porous concrete subfoundations, if not covered

by structures monitoring program

* reduction of strength and modulus of concrete structures due to elevated temperature

* loss of material due to corrosion in inaccessible areas of steel containment shell or liner

plate

* loss of prestress due to relaxation, shrinkage, creep, and elevated temperature

* cumulative fatigue damage

* cracking due to cyclic loading and SCC -

* aging of structures not covered by structures monitoring program

* aging management of inaccessible areas

* aging of supports not covered by structures monitoring program

* cumulative fatigue damage due to cyclic loading

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff reviewed the applicant's evaluation to determine whether it

adequately addressed the issues that were further evaluated. In addition, the staff audited the

applicant's further evaluations against the criteria contained in Section 3.5.2.2 of the Standard

Review Plan for License Renewal. Details of the staff's audit review are documented in the

staffs MPS audit and review report.

The GALL Report indicates that further evaluation should be performed for the aging effects

described in the following sections.

3.5B.2.2.1 PWR Containments

The staff reviewed LRA Section 3.5.2.2.1 against the criteria in SRP-LR Section 3.5.2.2.1, which

addresses several areas discussed below.

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Aging of Inaccessible Concrete Areas. The staff reviewed LRA Section 3.5.2.2.1.1 against the

criteria in SRP-LR Section 3.5.2.2.1.1. In LRA Section 3.5.2.2.1.1, the applicant addressed aging

of inaccessible concrete areas for the Unit 3 containment.

For inaccessible portions of the containment structure, 10 CFR 50.55a(b)(2)(ix) requires that the

applicant evaluate the acceptability of inaccessible areas when conditions exist in accessible

areas that could indicate the presence of, or result in, degradation to inaccessible areas.

The AMP recommended by the GALL Report for managing the aging of the accessible portions

of the containment structures is GALL AMP XI.S2, "ASME Section Xl, Subsection IWL." The

applicant addressed this with MPS AMP B2.1.16, "Inservice Inspection Program: Containment

Inspections." The staff reviewed the inservice inspection program: containment inspections and

its evaluation is documented in Section 3.0.3.2.11 of this SER. Subsection IWL exempts from

examination those portions of the concrete containment that are inaccessible (e.g., foundation,

below-grade exterior walls, or concrete covered by liner).

The applicant also used MPS AMP 82.1.23, 'Structures Monitoring Programs where accessible

areas are monitored for evidence of aging effects that may be applicable to containment

structures. This program, which is consistent with GALL AMP XI.S6, "Structures Monitoring

Program," with enhancements, was reviewed by the staff and its evaluation is documented

Section 3.0.3.2.16 of this SER. The applicant also credited the structures monitoring program for

the examination of below-grade concrete when it is exposed by excavation.

In the GALL Report, Volume 2, Chapter II, Table Al (as modified by ISG-3), further evaluation is

recommended to manage the aging effects for containment concrete components located in

inaccessible areas if the aging mechanisms of (1) freeze-thaw, (2) leaching of calcium

hydroxide, (3) aggressive chemical attack, (4) reaction with aggregates, or (5) corrosion of

embedded steel are significant. Possible aging effects for containment concrete structural

components due to these five aging mechanisms are cracking, change in material properties,

and loss of material.

(1) Freeze-thaw - SRP-LR Section 3.5.2.2.1.1 does not address freeze-thaw as an aging

mechanism for concrete containments because no further evaluation is recommended in

the GALL Report. However, ISG-3, 'Chapters 11 and IlIl fo GALL Report on Aging

Management of Concrete Elements," clarifies the staff position that further evaluation is

appropriate if the applicant's facility is subject to moderate to severe weathering

conditions unless the concrete meets certain specifications and subsequent inspections

have confirmed that the aging mechanism has not caused degradation of the concrete.

Unit 3 is located in a region considered to be subject to severe weather conditions. In the

LRA, the applicant stated that Unit 3 concrete structures are designed in accordance with

specification ACI 318-63, "Building Code Requirements for Reinforced Concrete," which

results in low permeability and resistance to aggressive chemical solutions by requiring

the following:

* high cement content

* low water-to-cement ratio

* proper curing

* adequate air entrainment

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In addition to ACI 318-63, the applicant stated that Unit 3 concrete also meets the criteria

of guidelines ACI 201.2R-77, "Guide to Durable Concrete." ACI 318-63 and

ACI 201 .2R-77 use the same ASTM standards for selection, application, and testing of

concrete.

The Unit 3 containment structure is protected from precipitation by an enclosure building

which also prevents potential freeze-thaw action. During' the audit and review, the staff

interviewed members of the applicant's technical staff and reviewed relevant operating

experience to confirm that loss of material from freeze-thaw has not been observed,"

either through the inservice inspection - IWL program or the structures monitoring

program.

On the basis of its review, the staff finds that loss of material and cracking due to

freeze-thaw will be adequately managed by the containment inservice inspection

program because: (1) that concrete that satisfies the requirements of ACI 318-63 will

meet the requirements of ISG-3, (2) an audit of operating experience evaluated under

the inservice inspection program. containment inspections' and structures monitoring

programs, and (3) the containment structure is protected from the elements by an

enclosure structure.

(2) Leaching of calcium hydroxide - SRP-LR Section 3.5.2.2.1.1 states that cracking,'

spalling, and increases in porosity and permeability due to leaching of calcium hydroxide

could occur in inaccessible areas of PWR concrete and steel containments. The GALL

Report, as updated by ISG-3, recommends further evaluation of plant-specific programs

to manage the aging effects for inaccessible areas if specific criteria' cannot be satisfied.

The GALL Report states that leaching of calcium hydroxide becomes significant only if

the concrete is exposed to flowing water. Even if reinforced concrete is exposed to

flowing water, such leaching is not significant if the concrete is constructed to ensure that

it is dense, well-cured, has low permeability, and that cracking is well controlled.

In the LRA, the applicant stated that Unit 3 concrete structures are designed in

accordance with specification ACI 318-63 and meet the criteria of guideline

ACI 201.2R-77.

The staff finds that because ACI 318 and ACI 201 .2R-77 provides assurance that the

criteria of the GALL Report and ISG-3 are met, leaching of calcium hydroxide is not

significant at Unit 3. The staff therefore concludes that the inservice inspection program:

containment inspections program will be-sufficient for management of increases in

porosity and permeability from this aging mechanism. A plant-specific AMP is not

required to address this aging effect.

(3) Aggressive chemical attack - SRP-LR Section'3.5.2.2.1.1 states that cracking, spalling,

and increases in porosity and permeability due to aggressive chemical attack could occur

in inaccessible areas of PWR concrete and steel containments. The GALL Report

recommends further evaluation of plant-specific programs to manage the aging effects

for inaccessible areas if specific criteria defined in the GALL Report and ISG-3 cannot be

satisfied.

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The GALL Report, as updated by ISG-3, states that aggressive chemical attack is not

significant unless pH is less than 5.5, chlorides are greater than 500 ppm, or sulfates are

greater than 1,500 ppm. ISG-3 also states that a plant-specific program is required to

examine representative samples of below-grade concrete when excavated for any

reason.

In the LRA, the applicant stated that the below-grade environment is not aggressive (pH is less than 5.5, chlorides are less than 500 ppm, and sulfates are less than

1,500 ppm). In addition, the staff noted that the applicant used the structures monitoring

program for the examination of below-grade concrete when it is exposed by excavation.

On the basis of the information provided in the LRA and the guidelines provided in the

SRP-LR, the GALL Report, and ISG-3, the staff finds that increases in porosity and

permeability, loss of material (spalling, scaling) and cracking due to aggressive chemical

attack are not significant for concrete in Unit 3 containment inaccessible areas. The

applicant used MPS AMP B2.1.23, "Structures Monitoring Program" to test the ground water on a periodic basis, considering seasonal variations to ensure the aging mechanism of aggressive chemical attack does not become significant in the future and

also to examine below-grade concrete when it is exposed by excavation. The staff

reviewed the structures monitoring program and its evaluation is documented in Section

3.0.3.2.16 of this SER. The staff finds that the structures monitoring program is an

appropriate program for examination of below-grade concrete when it becomes

accessible.

(4) Reaction with aggregates - SRP-LR Section 3.5.2.2.1.1 does not address reaction with

aggregates as an aging mechanism for concrete containments because no further

evaluation is recommended in the GALL Report. However, ISG-3 clarifies the staff

position that further evaluation is appropriate if investigations, tests, or examinations

have demonstrated that the aggregates are reactive.

In the LRA, the applicant stated that Unit 3 concrete structures are designed in

accordance with specification ACI 318-63 and meet the criteria of guideline ACI 201.2R-77. The ACI standards call for the testing of aggregates at the time of

construction.

On the basis of interviews with the applicant's technical staff, the staff confirmed that the

results of those tests show that the aggregates used for the Unit 3 concrete containment

at MPS are not reactive. The staff finds that this aging effect does not require

management at MPS. However, the applicant stated, in the LRA, that it will manage change of material properties as a potential aging effect on concrete structures. In

the LRA, the applicant stated that change of material properties for the Unit 3

containment due to alkali (cement)-aggregate reaction of concrete in an air environment

is managed by MPS AMP B2.1.16, 'Inservice Inspection Program: Containment

Inspections' and MPS AMP B2.1.23, "Structures Monitoring Program." The staff reviewed

these programs and its evaluation is documented in Sections 3.0.3.2.11 and 3.0.3.2.16 of

this SER, respectively.

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(5) Corrosion of embedded steel - SRP-LR Section 3.5.2.2.1.1 states that loss of material

due to corrosion of embedded steel could occur in inaccessible areas of PWR concrete

and steel containments. The GALL Report (updated in ISG-3) recommends further

evaluation of plant-specific programs to manage the aging effects for inaccessible areas

if specific criteria defined in the GALL Report cannot be satisfied.

For cracking, loss of bond, and loss of material (spalling, scaling) due to corrosion of

embedded steel, the GALL Report states that a plant-specific program is only

recommended if the below-grade environment is aggressive. ISG-3 also states that a

plant-specific program is recommended to examine representative samples of

below-grade concrete when excavated for any reason.

In the LRA, the applicant stated that the below-grade environment is not aggressive

(pH greater than 5.5, chlorides less than 500 ppm, and sulfates less than 1,500 ppm).

The staff noted that the applicant credited the structures monitoring program for the

examination of below-grade concrete when it is exposed by excavation. In addition, the

applicant committed, in its structures monitoring program, to periodically monitor

below-grade chemistry to ensure that the groundwater is not sufficiently aggressive to

cause the below-grade concrete to degrade.

The staff finds that, in accordance with the criteria of the GALL Report, this aging effect

is not significant and is adequately managed.

The staff reviewed the results of the applicant's AMR for inaccessible concrete areas. On

the basis of its audit and review, the staff finds that the applicant appropriately evaluated

AMR results involving management of aging of inaccessible concrete areas for

containment, as recommended in the GALL Report and ISG-3. Since the applicant's

AMR results are otherwise consistent with the GALL Report, the staff finds that the

applicant has demonstrated that the effects of aging will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of

extended operation, as required by 10 CFR 54.21 (a)(3).

Cracking. Distortion, and Increase in Component Stress Level Due to Settlement: Reduction of

Foundation Strength Due to Erosion of Porous Concrete Subfoundations, if Not Covered by

Structures Monitoring Program. The staff reviewed LRA Section 3.5.2.2.1.2 against the criteria in

SRP-LR Section 3.5.2.2.1.2.

In LRA Section 3.5.2.2.1.2, the applicant addressed (1) cracking, distortion and increase in

component stress level due to settlement and (2) reduction of foundation strength due to erosion

of porous concrete subfoundations in the containment.

SRP-LR Section 3.5.2.2.1.2 states that cracking, distortion, and increase in component stress

level due to settlement could occur in PWR concrete and steel containments. Also, reduction of

foundation strength due to erosion of porous concrete subfoundations-could occur in all types of

PWR containments. Some plants may rely on a de-watering system to lower the site ground

water level. If the plant's CLB credits a de-watering system, the GALL Report recommends

verification of the continued functionality of the de-watering system during the period of extended

operation. The GALL Report recommends no further evaluation if this activity is included in the

scope of the applicant's structures monitoring program.

3-507.
The applicant stated, in the LRA, that aging effects (cracking, distortion, and increase in*

component stress level) due to settlement; and reduction of foundation strength due to erosion

of porous concrete subfoundations are not expected at Unit 3. The applicant also stated that

Unit 3 structures are founded on bedrock, well-consolidated in-situ material, or compacted fill. A

porous concrete subfoundation is installed beneath the reinforced concrete foundation mat for

Unit 3 containment and a portion of the ESF building to control groundwater seepage through or

around the waterproof membrane. Breaches in the waterproof membrane around the Unit 3

containment have been identified, which has resulted in water seepage through the membrane

and the porous concrete subfoundation. Aging effects associated with porous concrete

subfoundation degradation and the resulting potential for settlement of Unit 3 containment are

managed by MPS AMP B2.1.23, "Structures Monitoring Program." An installed de-watering

system removes water that seeps through the membrane. Most of the ESF building is founded

on bedrock and only a small portion of the ESF building is founded on a porous concrete

subfoundation that is placed on the bedrock. Therefore, cracking due to settlement is not a

concern associated with the ESF building. The staff reviewed the structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed the

AMR results involving management of aging effects resulting from settling and erosion of porous

concrete subfoundations and confirmed that the structures monitoring program addressed each

of the affected structures and components.

In RAI 3.5-3, the staff requested information regarding the erosion of high-alumina cement from

the porous concrete sub-foundation as follows:

In item number 3.5.1-08, the applicant asserts that settlement is not expected to occur

during the period of extended operation. Further evaluation provided in Subsection

3.5.2.2.1.2 indicates that the containment and part of the engineering safety feature

building foundation mats are sitting on porous concrete foundation. During years

1996-1997, it was revealed that drainage water through the porous foundation consisted

of significant amount of high alumina cement, and that the applicant was monitoring depletion of cement and settlement of the affected structures (see NRC Info Notice

97-11). The applicant was requested to provide a summary of the quantitative

assessment of the depletion of cement and its affects on the settlement of the structures

during the period of extended operation. Also, the applicant was requested to justify why this item should not require a TLAA.

By letter dated December 3, 2004, the applicant stated:

Settlement of the Millstone Unit 3 containment structure is not considered a TLAA. This

analysis does not involve time-limited assumptions since even assuming the worst case

situation represented by a complete loss of all concrete in the porous concrete

subfoundation, the resultant change in frequency characteristics are within the

uncertainty range allowed for the peak broadened spectra used in the design of the

containment structure (M. H. Brothers to NRC, Millstone Power Station Unit No. 3 - Response to Request for Additional Information on Erosion of Cement from the

Underlying Porous Concrete Drainage System, Millstone Unit No. 3, Letter B16403 dated

April 30, 1997).

Millstone Unit 3 has performed extensive analysis of the condition of the porous concrete

subfoundation, including the effect of cement erosion, the potential loss of strength of the

I

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i

11

3-508
subfoundation due to conversion of the high alumina cement, the effect of cement

erosion on the load bearing capacity of the porous concrete, and the functional integrity

of the containment structure (J. A. Price to NRC, Millstone Power Station Unit No. 3

License Renewal - Requdst'for'Exerniptio'n From the Requirements of 10 CFR 54.17(c),

Response to Request for Additional Information, Letter BI 8948 dated September 3,

2003). The mass loss of high alumina (calcium-alumina) residue discharged into the ESF

sumps has been monitored since the startup of Millstone Unit 3 in 1986. A commitment

(captured in the structures monitoring program) to continue this periodic monitoring was

made as a means of insuring that no new or adverse changes are'occurring in the

porous concrete subfoundation (M. L. Bowling to NRC, Millstone Nuclear Power Station

Unit 3, Response to Request for Additional Information - Erosion of Cement From the

Underlying Porous Concrete Drainage System, Letter B17115 dated April 16, 1998). ESF

sump sample results can be found in Table 1. These results are conservatively projected

to year 2026 (480 months) in Figure 1. The 480 months represents the'current 40-year

license x 12 months/year. By 2026 approximately 3,600 pounds (or 0.5%) of the 670,000

pounds of calcium-alumina cement in the porous media could be lost. This loss is not

expected to adversely affect the function of the porous media (NRC to M. L. Bowling,

NRC Combined Inspection 50-245/98-208; 50-336/98-208; 50-423/98-208 and Notice of

Violation, Letter A13866 dated August 12, 1998).

As a result of a follow-up question related to the cumulative effect of the erosion and its effects

on the settlement of the Millstone 3 containment structure, the applicant provided a detailed

summary of the analyses and inspections it had performed, and commitments it has made to

NRC. The essential items of the commitments (Table 2) as applicable during the period of

extended operation are as follows:

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Table 2 Millstone Unit 3 - Containment Basemat Commitments Made in Previous

Correspondence

Numb~er' " ' - . ~m -:: m nt ''; t' '

B17115-01 Monitoring of the HAC porous concrete and portland Yearly

cement porous concrete groundwater chemistry to

confirm the subcontainment chemical and

environmental conditions

B17115-02 Measuring 'of the white' residue/mass-loss of calcium- Semi-annually

alumina in the ESF sumps .

B17115-03 Inspection of the sub-containment drainage piping in Yearly

the ESF sumps

B17115-04 Containment structure settlement monitoring External

surveys every 2

years; internal

ISI every 3

years

I

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I

Based on the trend line drawn by the applicant, the cumulative projected loss of high alumina

cement is about half a percent of the calcium alumina cement in porous media by the year 2026.

Based on the review of a number of analyses (including seismic analysis) performed by the

applicant during CLB, the staff agrees with the applicant's assertion that containment will

perform its intended function during the period of extended operation. The staff believes that this

item is a candidate for a TLAA. However, based on the commitments made by the applicant to

monitor the magnitude of erosion of the porous concrete from the subfoundation and monitoring

the containment structures for signs of differential settlement, the staff finds the applicant's

program for managing the erosion of the containment subfoundation acceptable.

On the basis of this review, the staff concludes that the applicant has appropriately evaluated

AMR results involving cracking, distortion, and increase in component stress level from

settlement and reduction of foundation strength from erosion, as recommended in the GALL

Report.

The staff finds that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the period

of extended operation, as required by 10 CFR 54.21 (a)(3).

3-510
Reduction of Strength and Modulus of Concrete Structures Due to Elevated Temperature. In

LRA Section 3.5.2.2.1.3, the applicant addressed reduction of strength and modulus of concrete

structures due to elevated temperature in containments.

SRP-LR Section 3.5.2.2.1.3 states that reduction of strength and modulus of elasticity due to

elevated temperatures could occur in PWR concrete and steel containments. The GALL Report

calls for a plant-specific aging management program and recommends further evaluation if any

portion of the concrete containment components exceeds specified temperature limits (i.e.,

general area temperature 66°C (1500F) and local area temperature 930C (2000F)).

In LRA Section 3.5.2.2.1.3, the applicant stated that during normal operation, all areas within the

containment building do not experience elevated temperatures greater than 150 0F general and

greater than 200 OF local. Therefore, change in material properties due to elevated temperature

is an aging effect not requiring management for the Unit 3 containment concrete.

On the basis of its review, the staff concurs with the applicant and concludes that change in

material properties due to elevated temperature is'an aging effect not requiring management for

the Unit 3 containment concrete.

Loss of Material Due to Corrosion in Inaccessible Areas of Steel Containment Shell or Liner

Plate. The staff reviewed LRA Section 3.5.2.2.1.4 against the criteria in SRP-LR

Section 3.5.2.2.1.4.

In LRA Section 3.5.2.2.1.4, the applicant addressed loss of material due to corrosion in

inaccessible areas of the steel containment shell or the steel liner plate for the containment.

SRP-LR Section 3.5.2.2.1.4 states that loss of material due to corrosion could occur in

inaccessible areas of the steel containment shell or the steel liner plate for all types of PWR

containments. The GALL Report recommends further evaluation of plant-specific programs to

manage this aging effect for inaccessible areas if the following specific criteria defined in the

GALL Report cannot be satisfied: (1) concrete meeting the guidelines of ACI 318 or ACI 349 and

the guidance of 201.2R was used for the containment concrete in contact with the embedded

containment shell or liner, (2) the accessible concrete is monitored to ensure that it is free of

penetrating cracks that provide a path for water seepage to the surface of the containment shell

or liner; (3) the accessible portion of the moisture barrier, at the junction where the shell or liner

becomes embedded, is subject to aging management activities in accordance with IWE

requirements; (4) borated water spills and water~ponding on the containment concrete floor are

not common and when detected are cleaned up in a timely manner.

In the LRA, the applicant stated that the containment concrete in contact with the steel liner plate

is designed in accordance with ACI 318-63, and meets the guideline ACI 201.2R-77. Accessible

concrete of the containment structure is monitored for penetrating cracks under MPS AMP

B2.1.16, "lnservice Inspection Program: Containment Inspections." The staff reviewed the

inservice inspection program: containment inspections program, with exceptions, and its

evaluation is documented in Section 3.0.3.2.11 :of this SER. In addition,-the applicant stated, in

the LRA, that the accessible portions of the steel liner plate and moisture barrier where the liner

becomes embedded are inspected in accordance with MPS AMP B2.1.16, 'Inservice Inspection

3-511
Program: Containment Inspections." Spills (e.g., borated water spill) are cleaned up in a timely

manner. The aging effect of loss of material due to corrosion has not been significant for Unit 3

liner plate.

On the basis of its review, the staff finds that all of the criteria identified in the GALL Report are

satisfied. The staff finds that no additional, plant-specific AMP is required to manage

inaccessible areas of the steel containment liner plate.

On the basis of its audit and review, the staff finds that the applicant appropriately evaluated

AMR results involving loss of material due to corrosion in inaccessible areas of the steel

containment shell or the steel liner plate, as recommended in the GALL Report. Since the

applicant's AMR results are otherwise consistent with the GALL Report, the staff finds that the

applicant has demonstrated that the effects of aging will be adequately managed so that the

intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

Loss of Prestress Due to Relaxation. Shrinkage. Creep. and Elevated Temperature. In LRA

Section 3.5.2.2.1.5, the applicant stated that the Unit 3 containment is not a prestressed

structure therefore, this item is not applicable.

The staff concurs with the applicant and finds that this aging effect is not applicable to MPS

Unit 3.

Cumulative Fatigue Damage. As stated in the SRP-LR, fatigue is a TLAA, as defined in

10 CFR 54.3. Applicants must evaluate TLAAs in accordance with 10 CFR 54.21 (c)(1). Section

4.6 of this SER documents the staff's review of the applicant's evaluation of this TLAA. In

performing this review, the staff followed the guidance in Section 4.6 of the SRP-LR.

Cracking Due to Cyclic Loading and Stress Corrosion Cracking. The staff reviewed LRA

Section 3.5.2.2.1.7 against the criteria in SRP-LR Section 3.5.2.2.1.7.

In LRA Section 3.5.2.2.1.7, the applicant addressed aging mechanisms that can lead to cracking

of penetration sleeves and penetration bellows such as cyclic loads and SCC.

SRP-LR Section 3.5.2.2.1.7 states that cracking of containment penetrations (including

penetration sleeves, penetration bellows, and dissimilar metal welds) due to cyclic loading or

SCC could occur in containments. Further evaluation of inspection methods is recommended to

detect cracking due to cyclic loading and SCC since visual VT-3 examinations may be unable to

detect this aging effect.

In LRA Section 3.5.2.2.1.7, the applicant stated that stress corrosion cracking is applicable to

carbon and low-alloy steel in air only if the fabrication material is high yield strength steel. SCC

of stainless steel in air is only applicable to sensitized stainless steel that is exposed to

intermittent wetting. Unit 3 containment penetrations, including penetration sleeves, bellows, and

dissimilar metal welds, are not fabricated form high yield strength steel and the stainless steel

materials are not subject to intermittent wetting. Therefore, cracking due to SCC does not

require aging management for the Unit 3 containment.

3-512
The staff reviewed and concurs with the applicant that cracking due to SCC is not an applicable

aging effect for MPS, and augmented inspection to detect cracking is not necessary.

In RAI 3.5-2, the staff requested information about the containment pressure boundary bellows

as follows:

In discussing item number 3.5.1-03 (Table 3.5.1) of the LRA, the applicant asserted that

the Millstone AMR results are consistent with NUREG-1 801. NUREG-1801 under item

A3.1 (page 11 A3.6) recommends further evaluation regarding the stress corrosion

cracking of containment bellows. Table 3.5.2, under Expansion Bellows" makes

reference to the Table items 3.2.1-05 and 3.2.1-06. However, they did not address the

expansion bellows associated with the containment pressure boundary. Normally,

applicants take credit for properly designed Type B tests to ensure the leak tight behavior

of the bellows. However, in AMP B2.1.6, the applicant does not take credit for Type B

testing. The applicant was requested to provide additional information regarding the

containment pressure boundary bellows at Millstone 2 and 3, relevant operating

experience, and method(s) used to detect their age related degradation.

By letter dated December 3, 2004, the applicant provided the following response:

As identified in the response to RAI 3.5-1 Dominion will credit Local Leak Rate Tests in

accordance with 10 CFR 50 Appendix J requirements for Type B penetrations. Both

Millstone Units 2 and 3 have bellows type penetrations associated with the design of their.

respective fuel transfer tubes. These are the only examples of bellows type penetrations

for either unit. The Millstone Unit 2 bellows type penetration does not form any portion of

the Containment pressure boundary, and therefore, does not require leak rate testing in

accordance with Appendix J requirements. Millstone Unit 3 includes the bellows type

penetration for the fuel transfer tube in its Appendix J program as a Type B containment

penetration. In accordance with Appendix J requirements, each time a Type B

penetration has been opened, it must have a Type B test performed after closure to

reestablish the containment boundary integrity. As such, this bellows type penetration is

Local Leak Rate Tested during each refueling outage after completion of refueling

activities and after the penetration flange has been reinstalled and verified as leak tight to

establish the containment boundary. :

The staff finds the response to RAI 3.5-2 acceptable, as the leak rate testing provisions will

adequately ensure the integrity of the Millstone 3 containment penetration bellows.

Cracking due to cyclic loading of the liner plate and penetrations is a TLAA which is evaluated

and addressed in Section 4.6 of this SER.

On the basis of its audit and review, the staff finds that the applicant appropriately evaluated

AMR results involving management of cracking due to SCC for containment components, as

recommended in the GALL Report. Since the applicant's AMR results are otherwise consistent

with the GALL Report, the staff finds that the applicant has demonstrated that the effects of

aging will be adequately managed so that the intended functions will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

3-513
3.5B.2.2.2 Class 1 Structures.

The staff reviewed LRA Section 3.5.2.2.2 against the criteria in SRP-LR Section 3.5.2.2.2, which

addresses several areas discussed below.

Aging of Structures Not Covered by Structures Monitoring Proqram. The staff reviewed LRA

Section 3.5.2.2.2.1 against the criteria in SRP-LR Section 3.5.2.2.2.1. In LRA

Section 3.5.2.2.2.1, the applicant addressed aging of Class 1 structures not covered by the

structures monitoring program.

SRP-LR Section 3.5.2.2.2.1 states that the GALL Report recommends further evaluation of

certain structure/aging effect combinations if they are not covered by the structures monitoring

program. This is described in GALL Report Chapter III and includes (1) scaling, cracking, and

spalling due to repeated freeze-thaw for Groups 1-3, and 5, and 7-9 structures; (2) scaling,

cracking, spalling and increase in porosity and permeability due to leaching of calcium hydroxide

and aggressive chemical attack for Groups 1-5 and 7-9 structures;; (3) expansion and cracking

due to reaction with aggregates for Groups 1-5 and 7-9 structures, (4) cracking, spalling, loss of

bond, and loss of material due to corrosion of embedded steel for Groups 1-5 and 7-9

structures; (5) cracks, distortion, and increase in component stress level due to settlement for

Groups 1-3, 5,and 7-9 structures; (6) reduction of foundation strength due to erosion of porous

concrete subfoundations for Groups 1-3, 5-9 structures; (7) loss of material due to corrosion of

structural steel components for Groups 1-5 and 7-8 structures; (8) loss of strength and modulus

of concrete structures due to elevated temperatures for Groups 1-5; and (9) crack initiation and

growth due to SCC and loss of material due to crevice corrosion of stainless steel liner for

Groups 7 and 8 structures. Further evaluation is necessary only for structure/aging effect

combinations not covered by the structures monitoring program.

Also, technical details of the aging management issue are presented in SRP-LR

Subsection 3.5.2.2.1.2 for structure/aging effect combinations Items (5) and (6) and SRP-LR

Subsection 3.5.2.2.1.3 for Item (8), above.

In LRA Table 3.5.1, Item 3.5.1-20 (page 3-502), the applicant credits MPS AMP B2.1.23,

"Structures Monitoring Program" for all types of aging effects and all component groups except

Group 6 of accessible interior and exterior concrete and steel components of Class 1 structures.

The staff reviewed the structure monitoring program and its evaluation is documented

Section 3.0.3.2.16 of this SER. Additional discussion of specific structure/aging effect

combinations follows.

(1) Freeze-thaw - SRP-LR Section 3.5.2.2.2.1 addresses freeze-thaw as an aging

mechanism for Class 1 structures. ISG-3 clarifies the staff position that further evaluation

is appropriate if the applicant's facility is subject to moderate to severe weathering

conditions unless the concrete meets certain specifications and subsequent inspections

have confirmed that the aging mechanism has not caused degradation of the concrete.

Unit 3 is located in a region considered to be subject to severe weather conditions. In the

LRA, the applicant stated that Unit 3 structures are designed in accordance with

specification ACI 318-63, which results in low permeability and resistance to aggressive

chemical solutions by requiring the following:

3-514
* high cement content

* low water-to-cement ratio

* proper curing

* adequate air entrainment

In addition to ACI 318-63, the applicant stated that Unit 3 concrete also meets criteria of

the guideline of ACI 201.2R-77. ACI 318-63 and ACI 201.2R-77 use the same ASTM

standards for selection, application and testing of concrete.

The staff interviewed members of the applicant's technical staff and reviewed relevant

operating experience to confirm that loss of material from freeze-thaw has not been

observed through MPS AMP B2.1.23, 'Structures Monitoring Program." The staff

reviewed the structures monitoring program and its evaluation is documented in Section

3.0.3.2.16 of this SER. -

On the basis that concrete that satisfies the criteria of ACI 318-63 will meet the

guidelines of ISG-3, and on the basis of an audit of operating experience evaluated

under the structures monitoring program, the-staff finds that loss of material and cracking

due to freeze-thaw will be adequately managed by the structures monitoring program.

(2a) Leach's of calcium hydroxide - SRP-LR Section 3.5.2.2.2.1 states that cracking, spalling,

and increases in porosity and permeability due to leaching of calcium hydroxide could

occur in Class 1 structures. The GALL Report recommends a plant-specific AMP for

inaccessible areas, unless the criteria of ACI 201.2R-77 for Class -1 structural concrete

are met.

The GALL Report states that leaching of calcium hydroxide becomes significant only if

the concrete is exposed to flowing water.'Even if reinforced concrete is exposed to

flowing water, such leaching is not significant if the concrete is constructed to ensure that

it is dense, well-cured, has low permeability, and that cracking is well controlled.

In the LRA, the applicant stated that Unit 3 concrete structures are designed in

accordance with specification ACI 318-63 and meet the criteria of guideline

ACI 201.2R-77.

The staff finds that because ACI 318 provides assurance that the criteria of the GALL

Report and ISG-3 are met, leaching of calcium hydroxide is not significant at Unit 3, and

therefore concludes that the structures monitoring program will be sufficient for --

management of increases in porosity and permeability from this aging mechanism. A,

plant-specific AMP is not required to address this aging effect.

(2b) Aggressive chemical attack- SRP-LR Section 3.5.2.2.2.1 states that cracking, spalling,

and increases in porosity and permeability due to aggressive chemical attack could occur

in inaccessible areas of Class I structures. The GALL Report recommends further

evaluation of plant-specific programs to manage the aging effects for inaccessible areas

if specific criteria defined in the GALL Report and updated in ISG-3 cannot be satisfied.

The GALL Report, as updated by ISG-3, states that aggressive chemical attack is not

significant unless pH is less than 5.5, chlorides are greater than 500 ppm, or sulfates are

3-515
greater than 1,500 ppm. ISG-3 also states that a plant-specific program is required to

examine representative samples of below-grade concrete when excavated for any

reason.

In the LRA, the applicant stated that the below-grade environment is not aggressive (pH is greater than 5.5, chlorides are less than 500 ppm, and sulfates are less than

1,500 ppm). In addition, the staff noted that the applicant used the structures monitoring

program for the examination of below-grade concrete when it is exposed by excavation.

On the basis of its review of the information provided in the LRA and the guidelines provided in the SRP-LR, the GALL Report, and ISG-3, the staff finds that increases in

porosity and permeability, loss of material (spalling, scaling) and cracking due to

aggressive chemical attack are not significant for concrete in inaccessible areas. The

staff finds that an appropriate AMP for examination of below-grade concrete (specifically,

an enhancement to the structures monitoring program) has been identified.

(3) Reaction with aggregates - SRP-LR Section 3.5.2.2.2.1 addresses reaction with

aggregates as an aging mechanism for Class 1 structures. ISG-3 clarifies the staff

position that further evaluation is appropriate if investigations, tests, or examinations

have demonstrated that the aggregates are reactive.

In the LRA, the applicant stated that Unit 3 concrete structures are designed in

accordance with specification ACI 318-63 and meets the requirements of guideline

ACI 201.2R-77. The ACI standards call for the testing of aggregates at the time of

construction.

On the basis of interviews with the applicant's technical staff, the staff confirmed that the

results of those tests showed that the aggregates used for concrete Class 1 structures at

Unit 3 are not reactive. However, the applicant stated that it will manage cracking as a

potential aging effect on concrete structures. In the LRA, the applicant stated that change of material properties and cracking due to alkali (cement)-aggregate reaction of concrete

in various environments is managed by MPS AMP B2.1.23, 'Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER.

(4) Corrosion of embedded steel - SRP-LR Section 3.5.2.2.2.1 states that cracking, spalling, loss of bond, and loss of material due to corrosion of embedded steel could occur in

inaccessible areas of Class 1 structures. The GALL Report (updated in ISG-3)

recommends further evaluation of plant-specific programs to manage the aging effects

for inaccessible areas if specific criteria defined in the GALL Report cannot be satisfied.

Also, for cracking, loss of bond, and loss of material (spalling, scaling) due to corrosion of

embedded steel, the GALL Report states that a plant-specific program is only

recommended if the below-grade environment is aggressive. ISG-3 also states that a

plant-specific program is recommended to examine representative samples of

below-grade concrete when excavated for any reason.

The staff finds that, in accordance with the criteria of the GALL Report, these aging

effects are not significant and are adequately managed by MPS AMP B2.1.23 "Structures

I

3-516
Monitoring Program." The staff reviewed the structures monitoring program and its

evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also finds an

enhancement to the structures monitoring program for examination of below-grade

concrete to be acceptable. ". -.

(5) Settlement - SRP-LR Section 3.5.2.2.2.1 refers to Section 3.5.2.2.1.2 for discussion of

settlement. SRP-LR Section 3.5.2.2.1.2 states that cracking, distortion, and increase in

component stress level due to settlement could occur in Class 1 structures. Some plants

may rely on a de-watering system to lower the site ground water level. If the plant's CLB

credits a de-watering system, the GALL Report recommends verification of the continued

functionality of the de-watering system during the period of extended operation. The

GALL Report recommends no further evaluation if this activity is included in the scope of

the applicant's structures monitoring program.

The applicant stated, in the LRA, that aging effects (cracking, distortion, and increase in

component stress level) due to settlement; and reduction of foundation strength due to

erosion of porous concrete subfoundations are not expected at Unit 3 for Class I -

structures. The applicant stated that Unit 3 Class I structures are'founded on bedrock,

well-consolidated in-situ material, or compacted fill. Also,'no'Class 1 structures utilize

porous concrete subfoundations, other than a portion of the ESF building, which is on

bedrock. In addition, the'applicant stated that Unit 3 has a dewatering system under'

some Class 1 structures which is monitored by MPS AMP B2.1.23, "Structures

Monitoring Program." The staff reviewed the structures monitoring program and its

evaluation is documented in Section 3.0.3.2.16 of this SER.

On the basis of its review, the staff concludes that foundation settlement is not an aging

mechanism at Unit 3.

On the basis of its audit and review, the staff finds that the applicant appropriately

evaluated AMR results involving management of settlement, as recommended in the

GALL Report. Since the applicant's AMR results are otherwise consistent with the GALL

Report, the staff finds that the applicant has demonstrated that the effects of aging will

be adequately managed so that the intended functions will be maintained consistent with

the CLB for the period of extended operation, as'required by 10 CFR 54.21 (a)(3).

(6) Erosion of porous concrete subfoundation - SRP-LR Section 3.5.2.2.2.1 refers to

Section 3.5.2.2.1.2 for discussion of erosion of porous concrete subfoundation. SRP-LR

Section 3.5.2.2.1.2 states that reduction of foundation strength due to erosion of porous

concrete subfoundations could occur in all types of Class 1 structures. Some plants may

rely on a de-watering system to lower the site ground water level. If the plant's CLB

credits a de-watering system, the GALL Report recommends verification of the continued

functionality of the de-watering system during the period of extended operation. The

GALL Report recommends no further evaluation if this activity is included in the scope of

the applicant's structures monitoring program.

The applicant stated, in the LRA, that aging effects (cracking, distortion, and increase in

component stress level) due to settlement; and reduction of foundation strength due to

erosion of porous concrete subfoundations are not expected at Unit 3 for Class 1

structures. The applicant stated that Unit 3 Class 1 structures are founded on bedrock,

3-517.
well-consolidated in-situ material, or compacted fill. No structures utilize porous concrete

subfoundations, other than a portion of the ESF building, which is on bedrock. In

addition, the applicant stated that Unit 3 has a dewatering system under some Class 1

structures which is monitored by MPS AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is documented in

Section 3.0.3.2.16 of this SER.

Based on the fact that no Unit 3 structures utilize porous concrete subfoundations, other

than a portion of the ESF building which is on bedrock and that Unit 3 has a dewatering

system under some Class 1 structures, the staff concludes that foundation settlement is

not an aging mechanism at Unit 3.

On the basis of its audit and review, the staff finds that the applicant appropriately

evaluated AMR results involving management of erosion of porous concrete

subfoundation, as recommended in the GALL Report. Since the applicant's AMR results

are otherwise consistent with the GALL Report, the staff finds that the applicant has*

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation,

as required by 10 CFR 54.21 (a)(3).

(7) Corrosion of structural steel components - The SRP-LR Section 3.5.2.2.2.1 states that

corrosion of structural steel components for Groups 1-5 and 7-8 could occur and that

further evaluation is necessary only for structure/aging effect combinations not covered

by the structures monitoring program.

In LRA Section 3.5.2.2.2.1, the applicant stated that the aging effects associated with

structures are managed by MPS AMP B2.1.23, "Structures Monitoring Program." However, aging effects for infrequently accessed portions of the structure are managed

by MPS AMP B2.1.15, "Infrequently Accessed Areas Inspection Program."

The staff reviewed the AMR results involving management of aging effects resulting from

corrosion of structural steel components and confirmed that MPS AMP B2.1.23,

"Structures Monitoring Program" and MPS AMP B2.1.15, "Infrequently Accessed Areas

Inspection Program" address each of the affected Structures and components. The staff

reviewed these programs and its evaluation of these programs is documented in

Sections 3.0.3.2.16 and 3.0.3.3.3 of this SER, respectively.

On the basis of its audit and review, the staff finds that the applicant has appropriately evaluated AMR results involving this aging effect and that corrosion of structural steel

components is adequately managed by the structures monitoring program and

infrequently accessed area's inspection program.

(8) Elevated temperatures - SRP-LR Section 3.5.2.2.2.1 refers to Section 3.5.2.2.1.3 for

discussion of elevated temperatures. SRP-LR Section 3.5.2.2.1.3 states that reduction of

strength and modulus of elasticity due to elevated temperatures could occur in Class 1

structures in Groups 1-5. The GALL Report calls for a plant-specific aging management

program and recommends further evaluation if any portion of the concrete component exceeds specified temperature limits (i.e., general area temperature 660C (1500F) and

local area temperature 930C (2000F)).

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In LRA Section 3.5.2.2.1.3, the applicant stated that during normal operation, all general

concrete areas in Class 1 structures remain below 150*F and local area temperatures

remain below 200'F. Therefore, change in material properties due to elevated

temperature is an aging effect not requiring management for Unit 3 Class 1 structures.

On the basis of its review, the staff concurs with the applicant and concludes that change

in material properties due to elevated temperature is an aging effect not requiring

management for the Unit 3 Class 1 structures.

(9) Aging effects for stainless steel liners for tanks - The SRP-LR Section 3.5.2.2.2.1 states

that crack initiation and growth due to SCC and loss of material due to crevice corrosion

of stainless steel liners for Group 7 and 8 structures could occur and further evaluation is

necessary only for structurelaging combinations not covered by the structures monitoring

program.

In LRA Table 3.5.1, Item 3.5.1-28 (page 3-505), the applicant stated that there are no

steel-lined concrete tanks at Unit 3 in GALL Structures Group 7, requiring aging

management. The applicant also stated that all other tanks (steel tanks, Structures

Group 8) are evaluated as part of the associated plant system. During the audit and*

review, the staff noted that, for sump liner of stainless steel material in LRA

Table 3.5.2-5 (page 3-538) and Unit 3 Table 3.5.2-8 (page 3-549), the applicant

references Item 3.5.1-28. It appears that the applicant does not evaluate all steel tanks

as part of the associated plant system. During the audit, the staff asked the applicant to

explain why further evaluation is not provided.

The applicant responded that the Unit 3 Table 3.5.2-5 and Unit 3 Table 3.5.2-8 for sump

liner of stainless steel material roll up to LRA Table 3.5.1, Item 3.5.1-28; however, the

discussion column only stated that there are no steel lined concrete tanks. The applicant

stated that the discussion column should be revised to indicate that loss of material for

stainless steel sump liners is managed by MPS AMP B2.1.25, "Work Control Process."

In an LRA supplement dated July 7, 2004, the applicant stated that LRA Table 3.5.1,

Item 3.5.1-28, the "Discussion" column, should have included a statement that loss of

material of steel lined concrete sumps is managed by the work control process program.

In addition, a "further evaluation recommended discussion" should have been included in

LRA Section 3.5.2.2 as follows:

There are no in-scope steel lined concrete tanks at MPS. Loss of material for

steel lined concrete sumps is managed by the Work Control Process AMP.

The applicant initiated a document change to revise the Unit 3 technical report for SRP

items recommended for further evaluation, to add a discussion in LRA Section 3.5.2.2.

On the basis of its review, the staff finds the applicant's response acceptable.

Aging Management of Inaccessible Areas. The staff reviewed LRA Section 3.5.2.2.2.2 against

the criteria in SRP-LR Section 3.5.2.2.2.2.

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In LRA Section 3.5.2.2.2.2, the applicant addressed aging of inaccessible areas of Class 1

structures.

SRP-LR Section 3.5.2.2.2.2 states that cracking, spalling, and increases in porosity and

permeability due to aggressive chemical attack and cracking, spalling, loss of bond, and loss of

material due to corrosion of embedded steel could occur in below-grade inaccessible concrete

areas. The GALL Report recommends further evaluation to manage these aging effects in

inaccessible areas of Groups 1-3, 5, and 7-9 structures, if an aggressive below-grade

environment exists. ISG-3 identifies additional guidance.

The GALL Report, as updated by ISG-3, states that aggressive chemical attack and corrosion of

embedded steel is not significant unless pH is less than 5.5, chlorides are greater than 500 ppm,

or sulfates are greater than 1,500 ppm. ISG-3 also states that a plant-specific program is

required to examine representative samples of below-grade concrete when excavated for any

reason.

In LRA Section 3.5.2.2.2.2, the applicant stated that the below-grade environment is not

aggressive (pH is greater than 5.5, chlorides are less than 500 ppm, and sulfates are less

than 1,500 ppm). The applicant stated in the LRA that it used the enhanced MPS AMP B2.1.23,

"Structures Monitoring Program" to examine below-grade concrete when it is exposed by

excavation. The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 in this SER. The staff finds that the structures monitoring

program, as enhanced, is an appropriate program for examination of below-grade concrete

when it becomes accessible.

The applicant stated, in the LRA, that inspections of accessible concrete have not revealed

degradation from aggressive chemical attack or corrosion of embedded steel.

On the basis that the below-grade environment is not aggressive with periodic groundwater

monitoring considering seasonal variations and that excavated concrete has been and willcontinue to be monitored, the staff finds that increases in porosity and permeability, loss of

material (spalling, scaling) and cracking due to aggressive chemical attack and cracking,

spalling, loss of bond, and loss of material due to corrosion of embedded steel are adequately

managed for concrete in inaccessible areas.

On the basis of its audit and review, the staff finds that the applicant appropriately evaluated

AMR results involving management of inaccessible areas, as recommended in the GALL Report.

Since the applicant's AMR results are otherwise consistent with the GALL Report, the staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.5B.2.2.3 Component Supports

The staff reviewed LRA Section 3.5.2.2.3 against the criteria in SRP-LR Section 3.5.2.2.3, which

addresses two areas discussed below.

Aging of Supports Not Covered by Structures Monitoring Program. The staff reviewed LRA

Section 3.5.2.2.3.1 against the criteria in SRP-LR Section 3.5.2.2.3.1.

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In LRA Section 3.5.2.2.3.1, the applicant addressed aging of component supports that are not

managed by the structures monitoring program.

SRP-LR Section 3.5.2.2.3.1 states that the GALL Report recommends further evaluation of

certain component support/aging effect combinations if they are not covered by the structures

monitoring program. This includes (1) reduction in concrete anchor capacity due to degradation

of the surrounding concrete, for Groups B1-B5 supports; (2) loss of material due to

environmental corrosion, for Groups B2-B5 supports; and (3) reduction/loss of isolation function

due to degradation of vibration isolation elements, for Group B4 supports. Further evaluation is

necessary only for structure/aging effect combinations not covered by the structures monitoring

program.

The applicant, in the LRA, has included the GALL Report AMP under the applicant's general

MPS AMP B2.1.23, -Structures Monitoring Program." However, this program is not consistent

with the GALL Report since the component groups are not completely within the scope of the

applicant's structures monitoring program, thus requiring further evaluation. The applicant

stated, in LRA Section 3.5.2.2.3.1, that the structures monitoring program only manages aging

effects associated with large equipment supports. The applicant also stated that MPS AMP

B2.1.13, "General Condition Monitoring" is used to manage aging effects for supports for other

components and piping and MPS AMP B2.1.1, "Battery Rack Inspections," is used to manage

age-related degradation specific to battery supports. The aging effects for supports in

infrequently accessed areas are managed by MPS AMP B2.1.15, "Infrequently Accessed Areas

Inspection Program." The staff reviewed these programs and its evaluation is documented in

Sections 3.0.3.3.2, 3.0.3.3.1, and 3.0.3.3.3 in the SER, respectively. The staff finds the

structures monitoring program acceptable, in conjunction with the other three programs, for

managing aging of component supports for all GALL Report component support groups.

Cumulative Fatigue Damage Due to Cyclic Loading. As stated in the SRP-LR, fatigue is a TLAA,

as defined in 10 CFR 54.3. Applicants must evaluate TLAAs in accordance with

10 CFR 54.21 (c)(1). Section 4.3 of this SER documents the staffs review of the applicant's

evaluation of this TLAA. In performing this review, the staff followed the guidance in Section 4.3

of the SRP-LR.

3.5B.2.2.4 Quality Assurance for Aging Management of Non-Safety-Related Components

Section 3.0.4 of this SER provides a separate evaluation of the applicant's quality assurance

program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for.

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determines that (1) those attributes or features

for which the applicant claimed consistency with the GALL Report were indeed consistent and

(2) the applicant adequately addressed the issues that were further evaluated. The staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21(a)(3).

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3.5B.2.3 AMR Results That Are Not Consistent With or Not Addressed in the GALL

Report

Summary of Technical Information in the Application. In Tables 3.5.2-1 through 3.5.2-38 of the

LRA, the staff reviewed additional details of the results of the AMRs for material, environment,

aging effects requiring management, and AMP combinations that are not consistent with the

GALL Report or are not addressed in the GALL Report.

In Tables 3.5.2-1 through 3.5.2-38, the applicant indicated, via Note F through J, that neither the

identified component nor the material and environment combination is evaluated in the GALL

Report and provided information concerning how the aging effects requiring management will be

managed.

Staff Evaluation. For component type, material and environment combinations that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine whether

the applicant had demonstrated that the effects of aging will be adequately managed so that the

intended function will be maintained consistent with the CLB during the period of extended

operation.

The staff evaluation is discussed below.

3.5B.2.3.1 Unit 3 Containment - Aging Management Evaluation - Table 3.5.2-1

The staff reviewed Table 3.5.2-1 of the LRA, which summarizes the results of AMR evaluations

for the Unit 3 containment system component groups. The staff interviewed the applicant's technical staff and reviewed the Unit 3 technical report for containment.

In the LRA, the applicant identified no aging effects for stainless steel components exposed to

air, including fuel transfer tube gate valve, containment sump screen, neutron shield tank,

reactor cavity seal ring, refueling cavity liner, pipe, valve bodies, fuel transfer tube, expansion bellows and fuel transfer tube penetration component types. Air is not identified in the GALL

Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Without the presence of an aggressive environment, stainless steel components will experience insignificant amounts of corrosion, and

no aging effects are applicable to this component/commodity group. Therefore, the staff finds

that there are no aging effects requiring management for metal in an air environment.

The applicant stated, in the LRA, that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that, based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. However, the applicant stated that it

will manage change of material properties as a potential aging effect on concrete structures.

The applicant stated, in the LRA, that change of material properties for equipment pads/grout, jet impingement barriers, and structural reinforced concrete (beams, columns, floor slabs,

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foundation mat slabs, pedestals, walls) due to alkali (cement)-aggregate reaction of concrete in

a protected air environment is managed by MPS AMP B2.1.23, "Structures Monitoring Program."

The staff reviewed the structures monitoring program and its evaluation is documented in

Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR.

On the basis of its review, the staff finds this program acceptable for managing the aging

effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in a protected air environment.

The applicant stated, in the LRA, that change of material properties for containment shell

(cylindrical wall and dome), due to alkali (cement)-aggregate reaction of concrete in a protected

air environment is managed by.MPS AMP B2.1.16, "Inservice Inspection Program: Containment

Inspections," with exceptions. The staff reviewed the inservice inspection program: containment

inspections program and its evaluation is documented in Section 3.0.3.2.11 of this SER.; The

staff also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff

finds this program acceptable for managing the aging effects, for the above components, of

change in material properties due to alkali (cement)-aggregate reaction of concrete in an air

environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 containment concrete

structures-in infrequently accessed areas. The applicant stated, in the LRA, that change of

material properties for structural reinforced concrete (beams, columns, floor slabs, foundation

mat slabs, pedestals, walls) in an air environment is managed by MPS AMP B2.1.15,

Infrequently Accessed Areas Inspection Program,"-which is a plant-specific program. The staff

reviewed the infrequently accessed area inspection program and its evaluation is documented in

Section 3.0.3.3.3 of this SER. The staff also reviewed this program with respect to the SRP-LR.

On the basis of its review, the staff finds this program acceptable for managing the aging

effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in a protected air environment for infrequently

accessed areas.

In RAI 3.5-1, the staff requested the following information:

For item numbers 3.5.1-03 to 3.5.1-06 (Table 3.5.1) of the LRA, the applicant cited

Containment ISI and Containment leak rate test as the aging management programs. A

review of AMP B2.1.6 indicates that the Appendix J leak rate testing is part the ISI

Program: Containment Inspections. in Appendix J program, the applicant takes credit for

only Type A tests to measure the overall primary containment leakage rates. This is a

major deviation from NUREG-1 801, Section XL.S4 program. Also, the review indicated

that the applicant istaking credit for the 1998 Edition of Subsections IWE of Section Xi of

the ASME Code, without citing compliance with the limitations and modifications

associated with this Edition of the Code in 10 CFR 50.55a (67 FR 60520). This was a

major deviation from NUREG-1801 Section XI.S1 program and requirements of the

regulation. In view of these deviations, and the fact that the Type A leak rate testing may

occur every 10 to 15 years, the applicant~was requested to provide information as to how

it plans to monitor the aging and leak-tightness of the components covered by item

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numbers 3.5.1-03 to 3.5.1-06. The applicant was requested to address seals and gaskets associated with equipment hatches, air locks, and, electrical and mechanical

penetrations.

By letter dated November 9, 2004, the applicant stated:

This item was identified as Audit Item 47 during the AMP/AMR Audit conducted the week

of May 3, 2004. Dominion provided a supplemental response to Audit Item 47 as

documented in the Dominion, letter (Serial Number 04-320) dated July 7,' 2004. In this

letter, it was stated that the Millstone LRA has been supplemented to additionally credit'

Type B Local Leak Rate Tests (in accordance with rIO CFR 50, Appendix J) as part of the

Containment ISI Aging Management Program.' Type B1 Local Leak Rate Testing will

ensure that the Containment pressure boundary function associated with the seals and

gaskets for equipment hatches, air-locks, and, electrical and mechanical'penetrations will

be maintained during the period of extended operation.

The typical frequency for performing Type B Local Leak Rate tests is every four refueling

outages (approximately every six years). Twenty-five percent of Type B electrical

penetrations are performed on-line just prior to or following each refueling outage (approximately every 1 1/2 years).

The staff finds the response to RAI 3.5-1 acceptable as the implementation of the revised

process will assure the integrity of the containment pressure boundary penetrations during the

period of extended operation.

In RAI 3.5-4, the staff inquired -about the means of monitoring the temperatures of the

containment concrete (around the high energy lines) and that of the concrete structures inside

the containments, and the operating experience related to their degradation, as follows:

In addressing item 3.5.1-27, for the reinforced concrete structures subjected to elevated

temperatures (e.g., primary shield walls, pressurizer and steam generator enclosures,-

reactor vessel supports, and the containment concrete around high energy-penetrations)

the applicant stated: "NUREG-1801 is not applicable." Items IlAI.1-h and lll.A4-lc of

NUREG-1801 are directly applicable to Group 4 structural concrete. For these structures,

the applicant was requested to provide the following information:

1. The method(s) of monitoring the concrete'temperatures in these structures.

2. If the primary shield wall concrete, the containment concrete, or any other

structural components within Millstone 2 and 3 containments are kept below the

threshold temperature (i.e., 150 "F) by means of air cooling,' provide the operating experience related to the performance of the cooling system.

3. The results of the latest inspection of these structures, in terms of cracking,

spalling, and condition of reactor vessel support structures, etc.

By letter dated November 9, 2004, the applicant stated:

1. For Millstone Unit 2, the temperature of the primary shield wall concrete in the

area of the reactor vessel supports'is'monitored and an alarm is provided in the

control room if the temperature exceeds 150 "F. Embedded cooling coils are

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provided at these locations to remove heat from the concrete. Although not

directly measured, the temperature of the concrete in other areas of the Unit 2

containment, and in the Unit 3 containment, is maintained below threshold values

by the design of ventilation systems. The containment ventilation systems

maintain average containment internal air temperature below 120 OF in

accordance with Technical Specification requirements. Local ambient air

temperatures in areas such as the steam generator cubicles and the pressurizer

cubicle are maintained well below 150¶F. The localized concrete temperature in

the vicinity of high energy piping containment penetrations is maintained below

the threshold value by the containment penetration cooling system, which

consists of a ventilation system in Unit 2 (the Containment Penetration Cooling

System described in LRA Section 2.3.3.18) and a water cooling system in Unit 3

(as part of the Reactor Plant Component Cooling System described in LRA

Section 2.3.3.6).

2. The containment ventilation systems operate consistently in order to provide

compliance with Technical Specification containment average temperature limit of

120 "F. Failures of these systems to provide adequate cooling requires plant

shutdown and, therefore, the threshold values for concrete temperature would not

be exceeded. The containment concrete in the area of the Unit 2 high energy

piping penetrations is cooled by the containment penetration cooling system. A

review of plant operating experience has indicated that this system also operates

consistently and there are no identified failures that would have resulted in local

concrete temperatures exceeding threshold values.

3. The latest inspections of the containment structure were performed in March

2001 and October 2003 for Unit 2 and in September 2002 for Unit 3. These

inspections did not identify instances of significant cracking or spalling in the

primary shield wall, pressurizer and steam generator enclosures, reactor vessel

support concrete, or the containment concrete around high-energy penetrations.

These inspection results provide further assurance that elevated temperature of

containment concrete was not a significant concern for Millstone Unit 2 and Unit 3

containments.

The staff finds the response acceptable, as the response indicates that the applicant employs

positive means to control temperatures around the high energy containment penetrations as well

as around the areas likely to be subjected to elevated temperatures in the concrete.

In RAI 3.5-14 (Audit Item AFI-1), the staff requested information on the operating experience

related to corrosion of steel liner for Millstone Units 2 and 3, as follows:

In discussion of Item 3.5.1-12 in Section 3.5.2.2.1.4, the applicant notes that the moisture

barrier is monitored under containment inspection program for aging degradation. The

industry experience indicates that the moisture barrier degrades with time, and any

moisture accumulation in the degraded barrier corrodes the steel liner. The applicant is

requested to provide information regarding the operating experience related to the

degradation of moisture barrier and the containment liner plate at Millstone 2 and 3. The

applicant is requested to include a discussion of acceptable liner plate corrosion before it

is reinstated to the nominal thickness.

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In response, the applicant provided the following information:

The containment ISI program conforms to ASME XI Subsection IWE (1998 Edition) for

monitoring the effects of aging associated with both the moisture barrier and the steel

liner. The inspection of moisture barriers is intended to prevent undetected intrusion of

moisture to inaccessible areas of the pressure retaining liner. Subsection IWE identifies

the moisture barrier examination method (visual), and the examination extent and

frequency (100% each inspection period). By Subsection IWE requirements, the

acceptance standards are "owner defined." Millstone Units 2 and 3 have defined the

general and detailed visual acceptance criteria in plant-specific procedures. For

augmented examinations of the liner that involve Ultrasonic Testing (UT), ASME Section

Xl, Subparagraph IWE-3511.3 requires that loss of material in a local area projected to

exceed 10% of the nominal wall thickness prior to the next examination shall be

documented. Such areas are entered into the corrective action program and either

accepted by engineering evaluation or corrected by performance of repair/replacement

activities.

For Millstone Units 2 and 3, various examples of Operating Experience associated with

the moisture barrier and the liner (such as the results of baseline examinations

performed under the containment ISI program) are available for review at the station. The

extent of the visual examinations and the necessity of additional volumetric examinations

have been as specified in the IWE Inspection Schedule. Examples of Containment

operating experience for Millstone Units 2 and 3 are provided in the License Renewal

Application Appendix B (Section B2.1.16).

Millstone Unit 2

The moisture barrier for the Unit 2 Containment liner was inspected in 2000 as part of the

ASME Section Xl, Subsection IWE examinations. The inspection revealed indications,

which upon evaluation required that the moisture barrier material be removed, a detailed

IWE examination of the liner be performed, the liner be recoated, and the moisture

barrier be replaced. The work scope was completed in two phases, approximately 50% of

the locations in outage 2R13 and the remainder in outage 2R15. During the examination,

some pitting of the liner was observed and determined to be acceptable by engineering

evaluation and the requirements of Subsection IWE of ASME Section Xl and acceptable

for continued service.

Millstone Unit 3

In 2000 the moisture barrier for the Unit 3 Containment liner was inspected as part of the

ASME Section Xl, Subsection IWE examinations. The inspection revealed unacceptable

results where, for specific areas, the moisture barrier had not been installed. These areas

were documented and repaired in accordance with Subsection IWE requirements.

Detailed visual examinations of the moisture barrier are performed as directed by IWE

requirements and the Millstone containment ISI program. The liner surface for the depth

of the exposed joint was acceptable and required no further supplemental examination.

Recognizing the susceptibility of the below grade portion of the containment liners to corrosion,

in a follow-up request, the staff requested the applicant to provide information regarding

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corrosion of the liners above the bottom floor levels. By letter dated December 3, 2004, the

applicant provided detailed descriptions of the liner corrosion, and the results of UT

measurements taken for Unit 2 in April 2000, May 2000, March 2002, and in November 2003 for

Unit 2, and in February 2001 for Unit 3. A typical evaluation of liner corrosion consisted of the

following approach:

Specifically, the UT examination results indicated that the area in question had a liner

wall thickness of 0.239 inches. The design nominal thickness of the liner is 0.250 inches.

In accordance with ASME Section Xl, Subparagraph IWE 3122.3, local areas exhibiting

-less than 10% wall loss are acceptable for continued service. The reading of 0.239

inches was greater than the 0.225 inches minimum wall thickness allowable (for 10 %

wall loss), and therefore, met the acceptance standards of ASME Section Xl.

The description also included examples where the liner thickness was found to be more than

10% of the nominal thickness allowed by Subsection IWE of Section Xl of the ASME Code. In

those cases the applicant performed engineering analysis to demonstrate that the liner could

perform its intended function.

The above description clearly indicates that the below grade portions of the liner plate have been

subjected to corrosion, and the applicant was taking appropriate actions to monitor and control

the future instances of corrosion. The staff believes that an appropriate implementation of AMP

B.2.1.16, "Inservice Inspection Program: Containment Inspection," including its containment leak

rate testing program will monitor and control corrosion of liner plates during the period of

extended operation, and therefore, finds the process used by the applicant acceptable.

3.5B.2.3.2 Unit 3 Containment Enclosure Building - Aging Management Evaluation - Table

3.5.2-2

The staff reviewed Table 3.5.2-2 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 containment enclosure building component groups. The staff interviewed the

applicant's technical staff and reviewed the Unit 3 technical report for Class 1 structures.

The applicant stated, in the LRA, that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concem. However, the applicant stated that it

will manage change of material properties as a potential aging effect on Unit 3 Class 1 concrete

structures. In the LRA, the applicant stated that change of material properties for structural

reinforced concrete (grade beams, slabs on grade) due to alkali (cement)-aggregate reaction of

concrete in an air environment is managed by MPS AMPtB2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)aggregate reaction of concrete in an air environment.

The applicant stated, in the LRA, that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant also stated that based on tests conducted on

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the aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not

a significant concern; The applicant stated that the use of high-density, low-permeability

concrete, and proper arrangement and distribution of reinforcement to control cracking, prevents the leaching of calcium hydroxide from Class 1 structures' concrete to be of concern. Therefore, the applicant stated that it will manage change of material properties as a potential aging effect

on Unit 3 Class 1 concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (grade beams, slabs' on grade) due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an atmosphere/weather environment is managed by MPS

AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this

program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an atmosphere/weather environment.

Tables 3.5.2-2 of Units 2 and 3 are related to the aging management of the enclosure buildings surrounding the containments. For Unit 2, the applicant has incorporated the aging management of blow-off panels. This is not the case for Unit 3. The applicant was requested to discuss the

reasons for the difference.

By letter dated December 3, 2004, the applicant provided the following response:

The main steam lines for Millstone Unit 2 go through the enclosure building, and the

potential exists for'excessive pressure to build-up inside this building during a main

steam line leak. For this reason blow-off panels were incorporated into the Unit 2

enclosure building design, and the aging management of these blow-off panels has been

included for License Renewal.

The main steam lines for Millstone Unit 3 go through the main steam valve building, and

not the enclosure building. For this reason blow-off panels are installed in the main steam

valve building, and the aging management of these blow-off panels has been included for

License Renewal. Because the main steam lines for Millstone Unit 3 do not go through the enclosure building, the potential for excessive pressure to build-up inside this building does not exist, and blow-off panels were not installed.

The staff finds the clarification acceptable.

3.5B.2.3.3 Unit 3 Auxiliary Building - Aging Management Evaluation - Table 3.5.2-3

The staff reviewed Table 3.5.2-3 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 auxiliary building component groups. The staff interviewed the applicant's technical

staff and reviewed the Unit 3 technical report for Class 1 structures.

In the LRA, the applicant stated that the GALL Report does not include stainless steel sump liners in a raw water environment. The applicant stated that loss of material due to crevice

corrosion/under deposit attack of stainless steel is possible in a raw water environment. The

sump liners have either the necessary geometry or the material deposits and oxygen greater

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than.100 ppb, which are required to support crevice corrosion/under deposit attack. The

applicant concludes crevice corrosion/under-deposit attack is a potential aging mechanism. On

the basis of it review, the staff agrees with the applicant's conclusion. -

The applicant stated, in the LRA, that sump liners are exposed to an aqueous environment with

temperatures less than 2100F and a pH of less than 10. Therefore, the applicant concludes that

MIC is a potential aging mechanism. The applicant stated, in the LRA, that the sump liners are

exposed to low flow conditions with an aggressive environment. Therefore, the applicant

concludes that pitting corrosion is a potential aging mechanism. On the basis of its review, the

staff agrees with the app!icant's conclusion.

In the LRA, the applicant stated that loss of material for sump liners due to crevice

corrosion/under-deposit attack, MIC, and pitting corrosion of stainless steel in a raw water

environment is managed by MPS AMP B2.1.25,"Work Control Process," which is a

plant-specific program. The staff reviewed the work control process program and its evaluation

is documented in Section 3.0.3.3.4 of this SER. The staff finds that the work control process

program credits visual inspection for the detection ofloss of material in structures. On the basis

of its review, the staff finds this program acceptable for, managing the aging effects, for the

above components, of loss of material due to crevice corrosion/under-deposit attack, MIC, and

pitting corrosion of stainless steel in a raw water environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concem. The applicant stated that it will manage

change of material properties as a potential aging effect on Unit 3 Class 1 concrete structures.

In the LRA, the applicant stated that change of material properties for flood/spill barriers,

including curbs, dikes, toe plates, and stop logs; hatches, missile barriers, structural reinforced

concrete (beams, columns, floor slabs, foundation mat slabs, roof slabs, walls) and tunnel due to

alkali (cement)-aggregate reaction of concrete in an air environment is managed by MPS AMP

B2.1 23, "Structures Monitoring Program." The staff reviewed the structures monitoring program

and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this

program with respect to the SRP-LR. On the basis of its review, the staff finds this program

acceptable for managing the aging effects, for the above components,- of change in material

properties due to alkali (cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of caicium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concem. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from Class 1 -Structures' concrete. The applicant will

manage change of material properties as a potential aging effect on Unit 3 Class 1 concrete.

structures. In the LRA, the applicant stated that change of material properties for structural

reinforced concrete (beams, columns, floor slabsfoundation mat slabs, roof slabs), hatches,

and missile barriers due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment is managed by MPS AMP B2.1.23,

wStructures Monitoring Program." The staff reviewed the structures monitoring program and its

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evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this program acceptable'for managing the aging effects, for the above components, for change in material properties 'due to

alkali (cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage change of material properties as a potential aging effect on Unit 3 Class 1 concrete structures in infrequently accessed areas. In the LRA, the applicant stated-that change of material properties for structural reinforced concrete (beams, columns, floor slabs, foundation mat slabs, roof slabs, walls) and tunnel in an air environment is managed by MPS AMP B2.1.15, uInfrequently Accessed Areas Inspection Program," which is a plant-specific program. The staff reviewed the

infrequently accessed area inspection program and its evaluation is documented in Section

3.0.3.3.3 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the

basis of its review, the staff finds this program acceptable for managing the aging effects, for the

above components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment for infrequently accessed areas.

3.5B.2.3.4 Unit 3 Control Building - Aging Management Evaluation - Table 3.5.2-4

The staff reviewed Table 3.5.2-4 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 control building component groups. The staff interviewed the applicant's technical

staff and reviewed the Unit 3 technical report for Class 1 structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali - (cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage change of material properties as a potential aging effect on Unit 3 Class 1 concrete structures.

In the LRA, the applicant stated that change of material properties for flood/spill barriers, including curbs, dikes, toe plates, and stop logs; structural reinforced concrete (floor slabs, foundation mat slabs, roof slabs, walls) and hatches due to alkali (cement)-aggregate reaction of

concrete in an air environment is managed by MPS AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cemrent)aggregate reaction is not a significant concern. The applicant stated that the use of high-density, low-permeability concrete, and proper arrangement and distribution of reinforcement to control cracking-, prevents significant leaching of calcium hydroxide from Class I structures' concrete. The applicant will,

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manage change of material properties as a potential aging effect on Unit 3 Class 1 concrete

structures. In the LRA, the applicant stated that change of material properties for structural

reinforced concrete (floor slabs, foundation mat slabs, roof slabs, walls), hatches, and missile

barriers due to alkali (cement)aggregate reaction and leaching of calcium hydroxide of concrete

in an atmosphere/weather environment is managed by MPS AMP B2.1.23, "Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

In the LRA, the applicant identified no aging effects for carbon steel components exposed to air,

including control room ceiling support component types. Air is not identified in the GALL Report

as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Significant corrosion of carbon steel

requires an electrolytic environment, and a simultaneous presence of oxygen and moisture.

Without the presence of the aggressive environment, carbon steel components will experience

insignificant amounts of corrosion, and no aging effects are applicable to this

component/commodity group. Therefore, the staff finds that there are no aging effects requiring

management for metal in an air environment.

3.58.2.3.5 Unit 3 Fuel Building - Aging Management Evaluation - Table 3.5.2-5

The staff reviewed Table 3.5.2-5 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 fuel building component groups. The staff interviewed the applicant's technical

staff and reviewed the Unit 3 technical report for Class 1 structures.

In the LRA, the applicant stated that loss of material for stainless steel spent fuel storage racks

exposed to treated water is managed using MPS AMP B2.1.5, "Chemistry Control for Primary

Systems Program." The staff reviewed the chemistry control for primary systems program and

its evaluation is documented in Section 3.0.3.2.2 of this SER. The staff finds this program is

consistent which is consistent with GALL AMP XI.M2, "Water Chemistry," with an acceptable

exception. On the basis of its review, the staff finds this line item acceptable since this program

is consistent with the GALL Report recommendation for other components with the same

material, environment, and aging effect.

In the LRA, the applicant identified no aging effects for stainless steel components exposed to

air, including miscellaneous steel (embedded steel-exposed surfaces, shapes, plates, unistrut,

etc., ladders, platforms and grating, stairs), cask wash pit liner and new fuel storage rack

component types. Air is not identified in the GALL Report as an environment for these

components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

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operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Without the presence of the aggressive

environment, stainless steel components will experience insignificant amounts of corrosion, and

no aging effects are applicable to this component/commodity group. Therefore, the staff finds

that there are no aging effects requiring management for metal in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at MPS, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 Class I concrete

structures. In the LRA, the applicant stated that change of material properties for flood/spill

barriers, including curbs, dikes, toe plates, and stop logs; hatches, structural reinforced concrete

(beams, columns, floor slabs, foundation mat slabs, roof slabs, walls) and hatches due to alkali

(cement)-aggregate reaction of concrete in an air environment is managed by MPS AMP

B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring program

and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this

program with respect to the SRP-LR. On the basis of its review, the staff finds this program

acceptable for managing the aging effects, for the above components, of change in material

properties due to alkali (cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from Class 1 structures' concrete. The applicant will

manage change of material properties as a potential aging effect on Unit 3 Class 1 concrete

structures. In the LRA, the applicant stated that change of material properties for structural

reinforced concrete (beams, columns, floor slabs, foundation mat slabs, roof slabs, walls), and

hatches due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of concrete

in an atmosphere/weather environment is managed by MPS AMP B2.1.23, "Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 Class 1 concrete

structures in infrequently accessed areas. In the LRA, the applicant stated that change of

material properties for tunnel in an air environment is managed by MPS AMP B2.1.15,

"Infrequently Accessed Areas Inspection Program," which is a plant-specific program. The staff

reviewed the infrequently accessed area inspection program and its evaluation is documented in

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Section 3.0.3.3.3 of this SER. The staff also reviewed this program with respect to the SRP-LR.

On the basis of its review, the staff finds this program acceptable for managing the aging

effects, for the above components, of change in'material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment for infrequently accessed areas.

3.5B.2.3.6 Railroad Canopy - Aging Management Evaluation - Table 3.5.2-6

The staff reviewed Table 3.5.2-6 of the LRA, which summarized the results of AMR evaluations

for the railroad canopy component groups. The staff interviewed the applicant's technical staff

and reviewed the Unit 3 technical report for Class l'structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 Class 1 concrete

structures. In the LRA, the applicant stated that change of material properties for structural

reinforced concrete (foundation mat slabs, roof slabs, walls) due to alkali (cement)-aggregate

reaction of concrete in an air environment is managed by MPS AMP B2.1.23, "Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at MPS, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from Class I structures' concrete. The applicant will

manage change of material properties as a potential aging effect on Unit 3 Class 1 concrete

structures. In the LRA, the applicant stated that change of material properties for structural

reinforced concrete (foundation mat slabs, roof slabs, walls) due to alkali (cement)aggregate

reaction and leaching of calcium hydroxide of concrete in an atmosphere/weather environment is

managed by MPS AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16. The staff

has reviewed this program with respect to the SRP-LR and found it acceptable. For these

components, the staff finds this program acceptable for managing the aging effects of change in

material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment.

3.5B.2.3.7 Unit 3 Hydrogen Recombiner Building - Aging Management Evaluation - Table

3.5.2-7

The staff reviewed Table 3.5.2-7 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 hydrogen recombiner building component groups. The staff interviewed the

applicant's technical staff and reviewed the Unit 3 technical report for Class 1 structures.

3-533
In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 Class 1 concrete

structures. In the LRA, the applicant stated that change of material properties for structural

reinforced concrete (beams, floor slabs, foundation mat slabs, roof slabs) and hatches due to

alkali (cement)-aggregate reaction of concrete in an air environment is managed by MPS AMP

B2.1.23, 'Structures Monitoring Program." The staff reviewed the structures monitoring program

and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this

program with respect to the SRP-LR. On the basis of its review, the staff finds this program

acceptable for managing the aging effects, for the above components, of change in material

properties due to alkali (cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmospheretweather environment.-The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from Class I structures' concrete. The applicant will

manage change of material properties as a potential aging effect on MPS Unit 3 Class 1

concrete structures. In the LRA, the applicant stated that change of material properties for

structural reinforced concrete (beams, floor slabs, foundation mat slabs, roof slabs), missile

barriers and hatches due to alkali (cement)-aggregate reaction and leaching of calcium

hydroxide of concrete in an atmospheretweather environment is managed by MPS AMP

B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring program

and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this

program with respect to the SRP-LR. On the basis of its review, the staff finds this program

acceptable for managing the aging effects, for the above components, of change in material

properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of

concrete in an atmosphere/weather environment.

3.5B.2.3.8 Unit 3 Engineered Safety Features Building - Aging Management Evaluation - Table

3.5.2-8

The staff reviewed Table 3.5.2-8 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 engineered safety features building component groups. The staff interviewed the

applicant's technical staff and reviewed the Unit 3 technical report for Class 1 structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on Unit 3 Class I concrete structures.

In the LRA, the applicant stated that change of material properties for flood/spill barriers

including curbs, dikes, toe plates and stop logs, hatches, and structural reinforced concrete

(beams, floor slabs, foundation mat slabs, roof slabs, walls) due to alkali (cement)-aggregate

reaction of concrete in an air environment is managed by MPS AMP B2.1.23, "Structures

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Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR.'On the basis of its review, the staff finds this program acceptable for managing:

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3,'alkali (cement)-aggregate reaction is not a

significant concem. The applicant stated that the use'of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from Class 1 structures' concrete. The applicant will

manage change of material properties as a potential aging effect on MPS Unit 3 Class 1

concrete structures. In the LRA, the applicant stated that change of material properties for

hatches, and structural reinforced concrete (beams, floor slabs, foundation mat slabs, roof slabs,

walls) due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of concrete in

an atmosphere/weather environment is managed by MPS AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER.-The staff also reviewed this 'program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

3.5B.2.3.9 Unit 3 Main Steam Valve Building - Aging Management Evaluation - Table 3.5.2-9

The staff reviewed Table 3.5.2-9 of the LRA, which summarized the results of AMR evaluations

for the MPS Unit 3 main steam valve building component groups. The staff interviewed the -

applicant's technical staff and reviewed the Unit 3 technical report for Class 1 structures.'

In the LRA, the applicant stated that change of material properties due to alkali .

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)aggregate reaction is not a significant concem. The applicant stated that it will manage.

change of material properties as a potential aging effect on Unit 3 Class 1 concrete structures.

In the LRA, the applicant stated that change of material properties for flood/spill barriers

including curbs, dikes, toe plates and stop logs,-and structural reinforced concrete (floor slabs,

foundation mat slabs, roof slabs, walls) due to alkali (cement)-aggregate reaction of concrete in

an air environment is managed by MPS AMP B2.1.23,'"Structures Monitoring Program." The

staff reviewed the structures monitoring program and its evaluation is documented in Section

3.0.3.2.16 of this SER.-The staff also reviewed this program with respect to the SRP-LR. On the

basis of its review, the staff finds this program'acceptable for managing the aging effects, for the

above components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

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aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from Class 1 structures' concrete. The applicant will

manage change of material properties as a potential aging effect on Unit 3 Class 1 concrete

structures. In the LRA, the applicant stated that change of material properties for structural

reinforced concrete (floor slabs, foundation mat slabs, roof slabs, walls) and missile barriers' due

to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment is managed by MPS AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali'

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

3.5B.2.3.10 Unit 3 Emergency Generator Enclosure and Fuel Oil Tank Vault - Aging

Management Evaluation - Table 3.5.2-10

The staff reviewed Table 3.5.2-10 of the LRA, which summarized the results'of AMR evaluations

for the MPS Unit 3 emergency generator enclosure and fuel oil tank vault component groups.

The staff interviewed the applicant's technical staff and reviewed the Unit 3 technical report for

Class 1 structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 Class I concrete

structures. In the LRA, the applicant stated that change of material properties for flood/spill

barriers, including curbs, dikes, toe plates, and stop logs; fuel oil tank vault, structural reinforced

concrete (beams, floor slabs, footing, foundation mat slabs, roof slabs, slabs on grade walls) due

to alkali (cement)-aggregate reaction of concrete in an air environment is managed by MPS

AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring.

program and its evaluation is documented in Section 3.0.3.2.16 of this SER; The staff also

reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this

program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the'

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents :

significant leaching of calcium hydroxide from Class 1 structures' concrete. The applicant will

manage change of material properties as a potential aging effect on MPS Unit 3 Class 1

concrete structures. In the LRA, the applicant stated that change of material properties for

structural reinforced concrete (beams, floor slabs, footing, foundation mat slabs, roof slabs,

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slabs on grade walls), and hatches due to alkali (cement)-aggregate reaction and leaching of

calcium hydroxide of concrete in an atmospherelweather environment is managed by MPS AMP

B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring program

and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this

program with respect to the SRP-LR. On the basis of its review, the staff finds this program

acceptable for managing the aging effects, for the above components, of change in material

properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of

concrete in an atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 Class 1 concrete

structures in infrequently accessed areas. In the LRA,-the applicant stated that change of

material properties for structural reinforced concrete (beams, floor slabs, footing, foundation mat

slabs, roof slabs, slabs on grade walls), and hatches in an air environment is managed by MPS

AMP B2.1.15, "Infrequently Accessed Areas Inspection Program," which is a plant-specific

program. The staff reviewed the infrequently accessed area inspection program and its

evaluation is documented in Section 3.0.3.3.3 of this SER. The staff also reviewed this program

with respect to the SRP-LR. On the basis of its review, the staff finds this program acceptable for

managing the aging effects, for the above components, of change in material properties due to

alkali (cement)-aggregate reaction of concrete in an air environment for infrequently accessed

areas.

3.5B.2.3.1 IUnit 2 Fire Pumphouse - Aging Management Evaluation - Table 3.5.2-11

The staff reviewed Table 3.5.2-11 of the Unit 3LRA, which summarized the results of AMR

evaluations for the Unit 2 fire pumphouse component groups. The staff interviewed the

applicant's technical staff and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The'applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3,- alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on Unit 3 concrete structures. In the

LRA, the applicant stated that change of material properties for structural reinforced concrete

(foundation mat slabs, roof slabs) due to alkali (cement)-aggregate reaction of concrete in an air

environment is managed by MPS AMP B2.1.23, Structures Monitoring Program." The staff

reviewed the structures monitoring program and its evaluation is documented in Section

3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the

basis of its review, the staff finds this program acceptable for managing the aging effects, for the

above components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment.-

In the LRA, the applicant stated that cracking for concrete component types (masonry block

walls) exposed to an atmosphere/weather environment is managed using MPS AMP B2.1.23,

uStructures Monitoring Program." The applicant stated that cracking of masonry block walls due

to long term creep and variation in stiffness, dry shrinkage of concrete, and expansion or

3-537 .
contraction, is possible in an atmosphere/weather environment. Masonry block walls are subject

to all of these aging mechanisms which require aging management. The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of concrete cracking due to long term creep and variation in stiffness, dry

shrinkage of concrete, and expansion or contraction in this environment.

3.5B.2.3.12 Unit 3 Fire Pumphouse - Aging Management Evaluation - Table 3.5.2-12

The staff reviewed Table 3.5.2-12 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 fire pumphouse component groups. The staff interviewed the applicant's technical

staff and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concem. The applicant stated that it will marnige

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(foundation mat slabs, roof slabs) due to alkali (cement)-aggregate reaction of concrete in an air

environment is managed by MPS AMP B2.1.23, "Structures Monitoring Program." The staff

reviewed the structures monitoring program and its evaluation is documented in Section

3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the

basis of its review, the staff finds this program acceptable for managing the aging effects, for the

above components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment.

In the LRA, the applicant stated that cracking for concrete component types (masonry block

walls) exposed to an atmospheretweather environment is managed using MPS AMP B2.1.23,

"Structures Monitoring Program." The applicant stated that cracking of masonry block walls due

to long term creep and variation in stiffness, dry shrinkage of concrete, and expansion or

contraction, is possible in an atmosphere/weather environment. Masonry block walls are subject

to all of these aging mechanisms which require aging management. The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of concrete cracking due to long term creep and variation in stiffness, dry

shrinkage of concrete, and expansion or contraction in this environment.

3.5B.2.3.13 Unit 3 Service Building - Aging Management Evaluation - Table 3.5.2-13

The staff reviewed Table 3.5.2-13 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 service building component groups. The staff interviewed the applicant's technical

staff and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

I

I

I

I

3-538
(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated change of material properties for structural reinforced concrete

(beams, columns, floor slabs, footing, foundation mat'slabs, walls) due to alkali

(cement)-aggregate reaction of concrete in an air environment is managed by MPS AMP

B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring program

and its evaluation is documented in Section 3.0.3:2.16 of this SER. The staff also reviewed this,

program with respect to the SRP-LR. On the basis of its review, the staff finds this program

acceptable for managing the aging effects, for the above components, of change in material

properties due to alkali (cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement-aggregate reaction is not a

significant concern. The applicant stated that the use'of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, floor slabs, footing, foundation mat slabs, walls) due to alkali (cement)-aggregate

reaction and leaching of calcium hydroxide of concrete in an atmosphere/weather environment is

managed by MPS AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment.

3.5B.2.3.14 Unit 3 Turbine Building - Aging Management Evaluation - Table 3.5.2-14

The staff reviewed Table 3.5.2-14 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 turbine building component groups. The staff interviewed the applicant's technical

staff and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for flood/spill barriers including

curbs, dikes, toe plates and stop logs, structural reinforced concrete (beams, columns, floor

slabs, footing, and grade beams, walls) and turbine pedestal due to alkali (cement)-aggregate

reaction of concrete in an air environment is managed by MPS AMP B2.1.23, "Structures

Monitoring Program." The staff reviewed the structures monitoring'program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds 'this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment.

3-539
In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, columns, floor slabs, footing, and grade beams, walls) due to alkali (cement)-aggregate

reaction and leaching of calcium hydroxide of concrete in an atmosphere/weather environment is

managed by MPS AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment.

3.5B.2.3.15 Unit 3 Auxiliary Boiler Enclosure - Aging Management Evaluation - Table 3.5.2-15

The staff reviewed Table 3.5.2-15 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 auxiliary boiler enclosure component groups. The staff interviewed the applicant's

technical staff and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(floor slabs, foundation mat slabs, walls) due to alkali (cement-aggregate reaction of concrete in

an air environment is managed by MPS AMP B2.1.23, "Structures Monitoring Program." The

staff reviewed the structures monitoring program and its evaluation is documented in Section

3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the

basis of its review, the staff finds this program acceptable for managing the aging effects, for the

above components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement-aggregate reaction is not a

significant concem. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(floor slabs, foundation mat slabs, walls) due to alkali (cement)-aggregate reaction and leaching

of calcium hydroxide of concrete in an atmosphere/weather environment is managed by MPS

I

3-540
AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this

program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment.

3.58.2.3.16 Unit 3 Technical Support Center - Aging Management Evaluation - Table 3.5.2-16

The staff reviewed Table 3.5.2-16 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 technical support center component groups. The staff interviewed the applicant's

technical staff and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, columns, floor slabs, footing, roof slabs, walls) due to alkali (cement)-aggregate

reaction of concrete in an air environment is managed by MPS AMP B2.1.23, 'Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concem. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures.-The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, columns, floor slabs, footing, roof slabs, walls) due to alkali (cement)-aggregate

reaction and leaching of calcium hydroxide of concrete in an atmosphere/weather environment is

managed by MPS AMP B2.1.23, Structures Monitoring Program." The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment.

3-541
I - -

3.5B.2.3.17 Unit 3 Maintenance Shop - Aging Management Evaluation - Table 3.5.2-17

The staff reviewed Table 3.5.2-17 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 maintenance shop component groups. The staff interviewed the applicant's

technical staff and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, floor slabs, spread footings, walls) due to alkali (cementyaggregate reaction of

concrete in an air environment is managed by MPS AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on Unit 3 concrete structures. In the

LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, floor slabs, spread footings, walls) due to alkali (cement)aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment is managed by

MPS AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures

monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff

also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds

this program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment.

3.56.2.3.18 Unit 3 Waste Disposal Building - Aging Management Evaluation - Table 3.5.2-18

The staff reviewed Table 3.5.2-18 of the LRA, which summarized the results of AMR evaluations

for the MPS Unit 3 waste disposal building component groups. The staff interviewed the

applicant's technical staff and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

3-542
the LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, floor slabs, spread footings, slabs on grade, walls) due to alkali (cement)-aggregate

reaction of concrete in an air environment is managed by MPS AMP B2.1.23, 'Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concem. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, floor slabs, spread footings, slabs on grade, walls) due to alkali (cement)-aggregate

reaction and leaching of calcium hydroxide of concrete in an atmosphere/weather environment is

managed by MPS AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the*

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an'atmosphere/weather environment.

In the LRA, the applicant stated that cracking for concrete component types (masonry block

walls) exposed to an atmosphere/weather environment is managed using MPS AMP B2.1.23,

"Structures Monitoring Program." The applicant stated that cracking of masonry block walls due

to long term creep and variation in stiffness, dry shrinkage of concrete, and expansion or

contraction, is possible in an atmosphere/weather environment. Masonry block walls are subject

to all of these aging mechanisms which require aging management. The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of concrete cracking due to long term creep and variation in stiffness, dry

shrinkage of concrete, and expansion or contraction in this environment.

3.51B.2.3.19 SBO Diesel Generator Enclosure and Fuel Oil Tank Vault'- Aging Management

Evaluation - Table 3.5.2-19

The staff reviewed Table 3.5.2-19 of the LRA, which summarized the results of AMR evaluations

for the SBO diesel generator enclosure and fuel oil tank vault component groups. The staff

interviewed the applicant's technical staff and reviewed the Unit 3 technical report for

miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

3-543
that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(foundation, mat slabs) due to alkali (cement)-aggregate reaction of concrete in an air

environment is managed by MPS AMP B2.1.23, "Structures Monitoring Program." The staff

reviewed the structures monitoring program and its evaluation is documented in Section

3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the

basis of its review, the staff finds this program acceptable for managing the aging effects, for the

above components, of change in material properties due to alkali (cement-aggregate reaction of

concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(foundation, mat slabs) due to alkali (cement)-aggregate reaction and leaching of calcium

hydroxide of concrete in an atmosphere/weather environment is managed by MPS

AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this

program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment.,

In the LRA, the applicant identified no aging effects for aluminum components exposed to air,

including roofing and siding component types. The GALL Report does not include this material

for these components.

The applicant concludes, as documented in the staff's MPS audit and review report for the AMR

for the Unit 3 miscellaneous structures, for aluminum in an air or an atmosphere/weather

environment, that there are no potential aging mechanisms for this aluminum and environment

combination. The applicant stated in the MAER that for aluminum material in an air or

atmosphere/weather environment, there are no potential aging mechanisms for this material and

environment combination at Unit 3. This conclusion is based on engineering text references that

indicate that aluminum and its alloys resist attack to a wide range of environments and many

chemical compounds. On the basis of its review of the applicant's documentation, the staff

concurs with the applicant and finds that there are no aging effects requiring management for

aluminum in an air environment.

In the LRA, the applicant also identified no aging effects for aluminum components exposed to

an atmosphere/weather environment, including roofing and siding component types. The GALL

Report does not include this material for these components.

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3-544
The applicant concludes, as documented in the staff's MPS audit and review report for the AMR

for the Unit 3 miscellaneous structures, for aluminum in an air or an atmosphere/weather

environment, that there are no potential aging mechanisms for this aluminum and environment

combination. The applicant stated in' the MAER that for aluminum material in an air or

atmosphere/weather environment, there are no 'potential aging mechanisms for this material and

environment combination at Unit 3. This conclusion is based on engineering text references that

indicate that aluminum and its alloys resist attack to a wide range of environments and many

chemical compounds. On the basis of its review of the applicant's documentation, the staff

concurs with the applicant and finds-that there are no aging effects requiring management for

aluminum in an atmosphere/weather environment.

3.5B.2.3.20 Unit 3 Condensate Polishing Enclosure - Aging Management Evaluation - Table

3.5.2-20

The staff reviewed Table 3.5.2-20 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 condensate polishing enclosure component groups. The staff interviewed the

applicant's technical staff and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, columns, floor slabs, spread footing, walls) due to alkali (cement)-aggregate reaction of

concrete in an air environment is managed by MPS AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, columns, floor slabs, spread footing, walls) due to alkali (cement)-aggregate reactionand leaching of calcium hydroxide of concrete in an atmosphere/weather environment is

managed by MPS AMP B2.1.23, uStructures Monitoring Program." The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment.

3-545:
3.5B.2.3.21 Unit 2 Condensate Polishing Facility and Warehouse No. 5 - Aging Management

Evaluation - Table 3.5.2-21

The staff reviewed Table 3.5.2-21 of the LRA, which summarized the results of AMR evaluations

for the Unit 2 condensate polishing facility and warehouse No. 5 component groups. The staff

interviewed the applicant's technical staff and reviewed the Unit 3 technical report for

miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, columns, floor slabs, foundation mat slabs, walls) due to alkali (cement)-aggregate

reaction of concrete in an air environment is managed by MPS AMP B2. 1.23, "Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmospheretweather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3,'alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, columns, floor slabs, foundation mat slabs, walls) due to alkali (cement)-aggregate

reaction and leaching of calcium hydroxide of concrete in an atmosphere/weather environment is

managed by MPS AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment.

3.5B.2.3.22 Security Diesel Generator Enclosure - Aging Management Evaluation - Table

3.5.2-22

The staff reviewed Table 3.5.2-22 of the LRA, which summarized the results of AMR evaluations

for the security diesel generator enclosure component groups. The staff interviewed the

applicant's technical staff and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

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atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking' prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will managechange of material properties as a potential aging effect on MPS Unit 3'concrete structures: In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(foundation mat slabs) due to alkali (cement}.aggregate reaction and leaching of calcium

hydroxide of concrete in an atmosphere/weather environment is managed by MPS AMP

B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring program

and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this

program with respect to the SRP-LR. On the basis of its review, the staff finds this program

acceptable for managing the aging effects, forthe above components, of change in material

properties due to alkali (cement)aggregate reaction and leaching of calcium hydroxide of

concrete in an atmosphere/weather environment.-:

In the LRA, the applicant identified no aging effects for aluminum components exposed to air,

including roofing, siding and structural framing component types. The GALL Report does not

include this material for these components.

The applicant concludes, as documented in the staffs MPS audit and review report for the Unit 3

miscellaneous structures, for aluminum in an air or an atmosphere/weather environment, that

there are no potential aging mechanisms for this aluminum and environment combination. The

applicant stated in the MAER that for aluminum material in an air or atmosphere/weather

environment there are no potential aging mechanisms for this material and environment

combination at Unit 3. This conclusion is based on engineering text references that indicate that

aluminum and its alloys resist attack to a wide range of environments and many chemical

compounds. On the basis of its review of the applicant's documentation, the staff concurs with

the applicant and finds that there are no aging effects requiring management for aluminum in an

air environment.

In the LRA,'the applicant identified no aging effects for aluminum components exposed to an

atmosphere/weather environment, including roofing and siding component types. The GALL

Report does not include this material for these components.

The applicant concludes, as documented in the staff's MPS audit and review report for the AMR

for Unit 3 miscellaneous structures, for aluminum in an air or an atmosphere/weather

environment, that there are no potential aging mechanisms for this aluminum and environment

combination. The applicant stated in the MAER that for aluminum material in an air or

atmosphere/weather environment there are no potential aging mechanisms for this material and

environment combination at Unit 3. This conclusion is based on engineering text references that

indicate that aluminum and its alloys resist attack to a wide range of environments and many

chemical compounds. On the basis of its review of the applicant's documentation, the staff

concurs with the applicant and finds that there are no aging effects requiring management for

aluminum in an atmosphere/weather environment.

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3.5B.2.3.23 Stack Monitoring Equipment Building - Aging Management Evaluation - Table

3.5.2-23 -

The staff reviewed Table 3.5.2-23 of the LRA, which summarized the results of AMR evaluations

for the stack monitoring equipment building component groups. The staff interviewed the

applicant's technical staff and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(roof slabs, slabs on grade, spread footing, walls) due to alkali (cement)-aggregate reaction of

concrete in an air environment is managed by MPS AMP B2.1.23, uStructures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(roof slabs, slabs on grade, spread footing, walls) due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment is managed by

MPS AMP B2.1.23, -Structures Monitoring Program." The staff reviewed the structures

monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff

also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds

this program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment.

In the LRA, the applicant stated that cracking for concrete component types (masonry blockwalls) exposed to an atmosphere/weather environment is managed using MPS AMP B2.1.23,

"Structures Monitoring Program." The applicant stated that cracking of masonry block walls due

to long term creep and variation in stiffness, dry shrinkage of concrete, and expansion or

contraction, is possible in an atmosphere/weather environment: Masonry block walls are subject

to all of these aging mechanisms which require aging management. The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

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components, of concrete cracking due to long term creep and variation in stiffness, dry

shrinkage of concrete, and expansion or contraction in this environment.

3.5B.2.3.24 Unit 3 Stack - Aging Management Evaluation - Table 3.5.2-24

The staff reviewed Table 3.5.2-24 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 stack component groups. The staff interviewed the applicant's technical staff and

reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali,

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(floor slabs, foundation mat, slabs, walls) due to alkali (cement)-aggregate reaction of concrete

in an air environment is managed by MPS AMP B2.1.23, Structures Monitoring Program." The

staff reviewed the structures monitoring program and its evaluation is documented in Section

3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the

basis of its review, the staff finds this program acceptable for managing the aging effects, for the

above components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3,-alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(floor slabs, foundation mat, slabs, walls) due to alkali (cement)-aggregate reaction and leaching

of calcium hydroxide of concrete in an atmosphere/weather environment is managed by MPS

AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this

program acceptable for managing the aging effects, for.the above components, of change in

material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures in

infrequently accessed areas. in the LRA, the applicant stated that change of material properties

for structural reinforced concrete (floor slabs, foundation mat, slabs, walls) in an air environment

is managed by MPS AMP B2.1.15, "Infrequently Accessed Areas Inspection Program," a

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plant-specific program. The staff reviewed the infrequently accessed area inspection program

and its evaluation is documented in Section 3.0.3.3.3 of this SER. The staff also reviewed this

program with respect to the SRP-LR. On the basis of its review, the staff finds this program

acceptable for managing the aging effects, for the above components, of change in material

properties due to alkali (cement)-aggregate reaction of concrete in an air environment for

infrequently accessed areas.

3.5B.2.3.25 Switchyard Control House - Aging Management Evaluation - Table 3.5.2-25

The staff reviewed Table 3.5.2-25 of the LRA, which summarized the results of AMR evaluations

for the switchyard control house component groups. The staff interviewed the applicant's

technical staff and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

due to alkali (cement)-aggregate reaction of concrete in an air environment is managed by MPS

AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the structures monitoring

program and its evaluation is documented in Section 3.0.3.3.16 of this SER. The staff also

reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds this

program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment is managed by MPS-AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

In the LRA, the applicant stated that cracking for concrete component types (masonry block

walls) exposed to an atmospheretweather environment is managed using MPS AMP B2.1.23,

uStructures Monitoring Program." The applicant stated that cracking of masonry block walls due

to long term creep and variation in stiffness, dry shrinkage of concrete, and expansion or

contraction, is possible in an atmosphere/weather environment. Masonry block walls are subject

I

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to all of these aging mechanisms which require aging management. The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of concrete cracking due to long term creep and variation in stiffness, dry

shrinkage of concrete, and expansion or contraction in this environment.

3.5B.2.3.26 345kV Switchyard - Aging Management Evaluation - Table 3.5.2-26

The staff reviewed Table 3.5.2-26 of the LRA, which summarized the results of AMR evaluations

for the 345 kV switchyard component groups. The staff interviewed the applicant's technical staff

and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concem. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents -

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated change of material properties for structural reinforced concrete due

to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment is managed by MPS AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is*

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

3.5B.2.3.27 Unit 3 Circulating and Service Water Pumphouse - Aging Management Evaluation -

Table 3.5.2-27

The staff reviewed Table 3.5.2-27 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 circulating and service water pumphouse component groups. The staff interviewed

the applicant's technical staff and reviewed the Unit 3 technical report for intake and discharge

structures.

In the LRA, the applicant identified no aging effects for aluminum components exposed to an air

environment, including miscellaneous aluminum (embedded aluminum exposed surfaces)

(shapes, plates, unistrut, etc. ladders, platforms and grading) component types. The GALL

Report does not include this material for these components.

The applicant concludes, as documented in the staff's MPS audit and review report for the AMR

for Unit 3 intake and discharge structures, for aluminum in an air or an air environment, that

there are no potential aging mechanisms for this aluminum and environment combination. The

applicant stated in the MAER that for aluminum material in an air or atmosphere/weather

environment there are no potential aging mechanisms for this material and environment

3-551
combination at Unit 3. This conclusion is based on engineering text references that indicate that

aluminum and its alloys resist attack to a wide range of environments and many chemical

compounds. On the basis of its review of the applicant's documentation, the staff concurs with

the applicant and finds that there are no aging effects requiring management for aluminum in an

air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for flood/spill barriers including

curbs, dikes, toe plates, and stop logs; structural reinforced concrete (beams, columns, floor

slabs, foundation mat slabs, roof slabs, walls) and hatches due to alkali (cement-aggregate

reaction of concrete in an air environment is managed by MPS AMP B2.1.23, "Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, columns, floor slabs, foundation mat slabs, roof slabs, walls) and hatches due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment is managed by MPS AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)aggregate reaction of concrete is possible in a sea water environment. The applicant

stated that based on tests conducted on the aggregate and the low-alkali cement used at

MPS Unit 3, alkali (cement-aggregate reaction is not a significant concern. The applicant stated

that it will manage change of material properties as a potential aging effect on MPS Unit 3

concrete structures. In the LRA; the applicant stated that change of material properties for

structural reinforced concrete (beams, columns, floor slabs, foundation mat slabs, roof slabs,

walls) due to alkali (cement)-aggregate reaction of concrete in a sea water environment is

managed by MPS AMP B2.1.23, uStructures Monitoring Program." The staff reviewed the

. I

3-552
structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in a sea water environment.

Structures monitoring program and infrequently accessed area inspection program were listed

as AMPs for structural reinforced concrete (beams, columns, floor slabs, foundation mat slabs,

roof slabs, walls) under column "Structural Member" and under column "Notes" H, 20 in Tables

3.5.2-18 for Unit 2 and H, 23 in Table 3.5.2-27 for Unit 3. In RAI 3.5-7, the applicant was

requested to identify the structural components, such as beams and walls that are managed by

either program or by both programs and provide basis for the selection of the program.

By letter dated November 9, 2004, the applicant stated that the structural member "Structural

Reinforced Concrete" in Unit 2 LRA Table 3.5.2-18 and Unit 3 LRA Table 3.5.2-27 includes

beams, columns, floor slabs, foundation mat slabs, roof slabs, and walls. The structural

reinforced concrete components associated with the table line item with Note H,'20 (Unit'2) or H,

23 (Unit 3) are only the floor slabs, foundation mat slabs; and walls. As indicated in Note 20 in

the Unit 2 LRA table (or Note 23 in the Unit 3 LRA table), the infrequently accessed area

inspection program manages the effects of aging for'structural members/components in the

intake structure water bays between the waterline and the bottom of the intake structure

operating deck since this area is infrequently accessed as described in LRA Appendix B, Section

B2.1.15. The structures monitoring program manages the effects of aging for structural

members/components in the water bay below the waterline since this area is inspected by the

structures monitoring program AMP. The effects of aging for the walls are managed by both the

infrequently accessed areas inspection program (above the waterline) and the structures

monitoring program (below the waterline). The infrequently accessed area inspection program

manages the effects of aging for the floor slabs (underside of the operating deck) and the

structures monitoring program manages the effects of aging for the foundation mat slabs.

The staff finds the applicant's response acceptable because it identifies each component and its

associated AMP.

3.5B.2.3.28 Unit 3 West Retaining Rail - Aging Management Evaluation - Table 3.5.2-28

The staff reviewed Table 3.5.2-28 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 west retaining rail component groups.-The staff interviewed the applicant's

technical staff and reviewed the Unit 3 technical report for intake and discharge structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement-aggregate reaction is not a

significant concem. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(footings, walls) due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of

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concrete in an atmosphere/weather environment is managed by MPS AMP B2.1.23, "Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in a sea water environment. The applicant

stated that based on tests conducted on the aggregate and the low-alkali cement used at

MPS Unit 3, alkali (cement)-aggregate reaction is not a significant concern. The applicant stated

that it will manage change of material properties as a potential aging effect on MPS Unit 3

concrete structures. In the LRA, the applicant stated that change of material properties for

structural reinforced concrete (footing, walls) due to alkali (cement)-aggregate reaction of

concrete in a sea water environment is managed by MPS AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is**

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in a sea water environment.

3.5B.2.3.29 Sea Wall - Aging Management Evaluation - Table 3.5.2-29

The staff reviewed Table 3.5.2-29 of the LRA, which summarized the results of AMR evaluations

for the sea wall component groups. The staff interviewed the applicant's technical staff and

reviewed the Unit 3 technical report for intake and discharge structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on MPS Unit 3 concrete structures. In

the LRA, the applicant stated that change of material properties for structural reinforced concrete

(footings, walls) due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of

concrete in an atmosphere/weather environment is managed by MPS AMP B2.1.23, "Structures

Monitoring Program. The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER.' The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in a sea water environment. The applicant

stated that based on tests conducted on the aggregate and the low-alkali cement used at

I

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MPS Unit 3, alkali (cement-aggregate reaction is not a significant concern. The applicant stated

that it will manage change of material properties as a potential aging effect on MPS Unit 3

concrete structures. In the LRA, the applicant stated that change of material properties for

structural reinforced concrete (footing, walls) due to alkali (cement)-aggregate reaction of

concrete in a sea water environment is managed by MPS AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER; The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction of concrete in a sea water environment.

3.5B.2.3.30 Unit 3 Circulating Water Discharge Tunnel and Discharge Structure - Aging

Managem6nt Evaluation - Table 3.5.2-30

The staff reviewed Table 3.5.2-30 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 circulating water discharge tunnel and discharge structure component groups. The'-

staff interviewed the applicant's technical staff and reviewed the Unit 3 technical report for intake

and discharge structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on Unit 3 concrete structures. In the

LRA, the applicant stated that change of material properties for structural reinforced concrete

(floor slabs, roof slabs, walls) due to alkali (cement)-aggregate reaction and leaching of calcium

hydroxide of concrete in an atmosphere/weather environment is managed by MPS AMP

B2.1.23, Structures Monitoring Program." The staff reviewed the structures monitoring program

and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this

program with respect to the SRP-LR. On the basis of its review, the staff finds this program

acceptable for managing the aging effects, for the above components, of change in material

properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of

concrete in an atmosphere/weather environment. -

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in a sea water environment. The applicant

stated that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3,

alkali (cement)-aggregate reaction is not a significant concern. The applicant stated that it will

manage change of material properties as a potential aging effect on Unit 3 concrete structures.

In the LRA, the applicant stated that change of material properties for structural reinforced

concrete (floor slabs, roof slabs, walls) due to alkali (cement)-aggregate reaction of concrete in a

sea water environment is managed by MPS AMP B2.1.23, "Structures Monitoring Program." The

staff reviewed the structures monitoring program-and its evaluation is documented in Section

3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the

basis of its review, the staff finds this program acceptable for managing the aging effects, for the

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above components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in a sea water environment.

3.5B.2.3.31 Unit 3 Recirculation Tempering Line - Aging Management Evaluation - Table

3.5.2-31

The staff reviewed Table 3.5.2-31 of the LRA, which summarized the results of AMR evaluations

for the Unit 3 recirculation tempering line component groups.

In RAI 3.5-13, the staff requested a clarification as to the reason of listing infrequently accessed

area inspection program three times as the AMP for concrete pipes.

By letter dated November 9, 2004, the applicant stated Each line item for concrete pipe in Unit 2

LRA Table 3.5.2-21 on page 3-507 and in Unit 3 Table 3.5.2-31 on page 3-613 is a unique line

item with a corresponding NUREG-1801 Volume 2 Item and/or a note. As a result, some table

data (such as the AMP) is repeated multiple times for these lines. For example, for the lines in

the tables associated with the change of material properties aging effect for the concrete pipe,

the first line is associated with NUREG-1801 item IlI.A6.1-b for the leaching of calcium hydroxide

aging mechanism. The second line is associated with NUREG-1801 item IlI.A6.1-e for the

aggressive chemical attack aging mechanism. Finally, the third line is not associated with a

NUREG-1 801 item since the alkali-aggregate reaction aging mechanism leading to a change of

material properties is not included in NUREG-1801, although Dominion has conservatively

included this aging mechanism as discussed in LRA Appendix C, Section C3.2.2. For each of

these aging mechanisms that result in the change of material properties aging effect for the

concrete pipe, the infrequently accessed areas inspection program AMP manages the identified

aging effect.

The staff finds the applicant's response acceptable.

3.5B.2.3.32 Vacuum Priming Pumphouse - Aging Management Evaluation - Table 3.5.2-32

The staff reviewed Table 3.5.2-32 of the LRA, which summarized the results of AMR evaluations

for the vacuum priming pumphouse component groups. The staff interviewed the applicant's

technical staff and reviewed the Unit 3 technical report for intake and discharge structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concem. The applicant stated that it will manage

change of material properties as a potential aging effect on Unit 3 concrete structures. In the

LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, foundation mat slabs, roof slabs, walls) due to alkali (cement)-aggregate reaction of

concrete in an air environment is managed by MPS AMP B2.1.23, "Structures Monitoring

Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)aggregate reaction of concrete in an air environment.

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In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on Unit 3 concrete structures. In the

LRA, the applicant stated that change of material properties for structural reinforced concrete

(beams, foundation mat slabs, roof slabs, walls) due to alkali (cement)-aggregate reaction'and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment is managed by

MPS AMP B2.1.23, 'Structures Monitoring Program." The staff reviewed the structures

monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff

also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds

this program acceptable for managing the aging effects, for the above components, of change' in

material properties due to alkali (cement-aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment.

3.5B.2.3.33 Tank Foundations - Aging Management Evaluation - Table 3.5.2-33

The staff reviewed Table 3.5.2-33 of the LRA, which summarized the results of AMR evaluations

for the tank foundations component groups. The staff interviewed the applicant's technical staff

and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on Unit 3 concrete structures. In the

LRA, the applicant stated that change of material properties for the structural reinforced concrete

(foundation mat slabs, walls) (Unit 3 Boron Recovery Tanks and Enclosure) due to alkali -

(cement)-aggregate reaction of concrete in an air environment is managed by MPS AMP

B2.1.23, Structures Monitoring Program." The staff reviewed the structures monitoring program

and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this

program with respect to the SRP-LR. On the basis of its review, the staff finds this program

acceptable for managing the aging effects, for the above components, of change in material

properties due to alkali (cement)-aggregate reaction of concrete in an air environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on Unit 3 concrete structures. In the

LRA, the applicant stated that change of material properties for structural reinforced concrete

(foundation mat slabs) (condensate storage tank foundation); structural reinforced concrete

(footing) (fire water tanks 1 and 2 foundations); structural reinforced concrete (foundation mat

3-557
slabs) (refueling water storage tank foundation); structural reinforced concrete (foundation mat

slabs) (SBO diesel fuel oil storage tank foundation); structural reinforced concrete (foundation

mat slabs, roof slabs, walls) (demineralized water storage tank foundation and enclosure);

structural reinforced concrete (foundation mat slabs) (carbon dioxide tank foundation); and

structural reinforced concrete (foundation mat slabs, walls) (boron recovery tank foundation and

enclosure) due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide of

concrete in an atmosphere/weather environment is managed by MPS AMP B2.1.23, "Structures

Monitoring Program." The staff reviewed the structures monitoring program and its evaluation is

documented in Section 3.0.3.2.16 of this SER. The staff also reviewed this program with respect

to the SRP-LR. On the basis of its review, the staff finds this program acceptable for managing

the aging effects, for the above components, of change in material properties due to alkali

(cement)-aggregate reaction and leaching of calcium hydroxide of concrete in an

atmosphere/weather environment.

3.5B.2.3.34 Yard Structures - Aging Management Evaluation - Table 3.5.2-34

The staff reviewed Table 3.5.2-34 of the LRA, which summarized the results of AMR evaluations

for the yard structures component groups. The staff interviewed the applicant's technical staff

and reviewed the Unit 3 technical report for miscellaneous structures.

In the LRA, the applicant identified no aging effects for aluminum components exposed to an

atmosphere/weather environment, including lighting pole component types. The GALL Report

does not include this material for these components.

The applicant concludes, as documented in the Unit 3 technical report for miscellaneous

structures, for aluminum in an air or an air environment, that there are no potential aging

mechanisms for this aluminum and environment combination. The applicant stated in the MAER

that for aluminum material in an air or atmosphere/weather environment there are no potential

aging mechanisms for this material and environment combination at Unit 3. This conclusion is

based on engineering text references that indicate that aluminum and its alloys resist attack to a

wide range of environments and many chemical compounds. On the basis of its review of the

applicant's documentation, the staff concurs with the applicant and finds that there are no aging

effects requiring management for aluminum in an atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concern. The applicant stated that it will manage

change of material properties as a potential aging effect on Unit 3 concrete structures. In the

LRA, the applicant stated that change of material properties for the access covers (yard valve

pits and enclosure); structural reinforced concrete (foundation mat slabs, roof slabs, walls) (yard

valve pits and enclosure); structural reinforced concrete (foundation mat slabs, roof slabs, walls)

(pipe tunnel); and structural reinforced concrete (foundation mat slabs, roof slabs, walls)

(manholes) due to alkali (cement)-aggregate reaction of concrete in an air environment is

managed by MPS AMP B2.1.23, "Structures Monitoring Program." The staff reviewed the

structures monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this

SER. The staff also reviewed this program with respect to the SRP-LR. On the basis of its

review, the staff finds this program acceptable for managing the aging effects, for the above

I

I

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components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment. -

* .; i. : -,

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction and leaching 'of calcium hydroxide of concrete is possible in an

atmosphere/weather environment. The applicant stated that based on tests conducted on the

aggregate and the low-alkali cement used at Unit 3, alkali (cement)-aggregate reaction is' not a

significant concern. The applicant stated that the use of high-density, low-permeability concrete,

and proper arrangement and distribution of reinforcement to control cracking, prevents

significant leaching of calcium hydroxide from concrete structures. The applicant will manage

change of material properties as a potential aging effect on Unit 3 concrete structures. In thei

LRA, the applicant stated that change of material properties for structural reinforced concrete

(footing, walls) (transformer.firewalls and dikes); access'covers (yard valve pits and enclosure);

structural reinforced concrete (foundation mat slabs, roof slabs, walls) (yard valve pits and -

enclosure); structural reinforced concrete (foundation mat slabs, roof slabs, walls) (Pipe Tunnel);

structural reinforced concrete (foundation mat slabs, roof slabs, walls) (Manholes); duct banks;

structural reinforced concrete (security lighting supports); and structural reinforced concrete

(footing,, walls) (technical support building) due to alkali (cement)-aggregate reaction and

leaching of calcium hydroxide of concrete in an atmosphere/weather environment is managed by

MPS AMP B2.1.23,'.Structures Monitoring Program." The staff reviewed the 'structures

monitoring program and its evaluation is documented in Section 3.0.3.2.16 of this SER. The staff

also reviewed this program with respect to the SRP-LR. On the basis of its review, the staff finds

this program acceptable for managing the aging effects, for the above components, of change in

material properties due to alkali (cement)-aggregate reaction and leaching of calcium hydroxide

of concrete in an atmosphere/weather environment.

In the LRA, the applicant stated that change of material properties due to alkali

(cement)-aggregate reaction of concrete is possible in an air environment. The applicant stated

that based on tests conducted on the aggregate and the low-alkali cement used at Unit 3, alkali

(cement)-aggregate reaction is not a significant concem. The applicant stated that it will manage

change of material properties as a potential aging effect on Unit 3 concrete structures in

infrequently accessed areas. In the LRA, the applicant stated that change of material properties

for structural reinforced concrete (foundation mat slabs, roof slabs, walls) (yard valve pits and

enclosure) in an air environment is managed by MPS AMP B2.1.15, Oinfrequently Accessed

Areas Inspection Program," which is a plant-specific program. The staff reviewed the

infrequently accessed area inspection programrand its evaluation is' documented in Section

3.0.3.3.3 of this SER. The staff also reviewed this program with respect to the SRP-LR. On the'

basis of its review, the staff finds this program'acceptable for managing the aging effects, for the

above components, of change in material properties due to alkali (cement)-aggregate reaction of

concrete in an air environment for infrequently accessed areas.

3.5B.2.3.35 NSSS Equipment Supports - Aging Management Evaluation - Table 3.5.2-35

The staff reviewed Table 3.5.2-35 of the LRA, which summarized the results of AMR evaluations'

for the NSSS equipment supports component groups. The staff interviewed the applicant's

technical staff and reviewed the Unit 3 technical report for NSSS equipment supports.

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In the LRA, the applicant identified no aging effects for stainless steel components exposed to

air, including pressurizer support: bolting component types. Air is not identified in the GALL

Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Without the presence of the aggressive

environment, stainless steel components will experience insignificant amounts of corrosion, and

no aging effects are applicable to this component/commodity group. Therefore, the staff finds

that there are no aging effects requiring management for metal in an air environment.

In the LRA, the applicant stated that the GALL Report does not include a borated water leakage

environment for reactor vessel support: sliding support plate of copper alloy material.

The applicant identifies, in the Unit 3 technical report for NSSS equipment supports, for copper

alloys in a borated water leakage environment, that boric acid corrosion as an aging mechanism

for loss of material. The applicant stated that these components do not exceed the temperature.

threshold of 350 OF. Therefore; boric acid corrosion is a potential aging mechanism for copper

alloys. On the basis of its review of the applicant's document, the staff concurs with the applicant

and finds that boric acid corrosion is a potential aging mechanism for copper alloys.

In the LRA, the applicant stated that loss of material for copper alloy reactor vessel support:

sliding support plate in a borated water leakage environment is managed by MPS AMP B2.1.13,

"General Condition Monitoring." The staff reviewed the general condition monitoring program

and its evaluation is documented in Section 3.0.3.3.2 of this SER. The general condition

monitoring program, manages these aging effects by visual inspections for evidence of'

degradation or adverse conditions and includes heath physics inspections of radiologically

controlled areas, system walkdowns by system engineering, and daily inspections of accessible

areas of the plant by plant operators. Evidence of boron precipitation and active radioactive

system leaks is identified during area observations made by health physics technicians while

performing radiologically controlled area surveys. On the basis of its review, the staff finds the

general condition monitoring program acceptable for managing the aging effect of loss of

material for copper alloys for this component.

In the discussion section of LRA Table 3.5.1, Item 3.5.1-33, the applicant stated, for Group B1.1:

high strength low-alloy bolts in structures and component support systems, that cracking due to

SCC is not an aging effect requiring management for NSSS equipment support bolting.

During the review, the staff noted that SRP-LR Table 3.5-1 recommended GALL AMP Xi.M18,

"Bolting Integrity," for managing high strength bolting for NSSS components supports for crack

initiation and growth due to SCC.

By letter dated January 11, 2005, the applicant stated:

For NSSS component supports, bolting material with estimated maximum yield strength

that marginally exceeds 150 ksi is used in limited applications. This bolting is located

inside the Containment in areas where the environment is typically dry and not subject to

high levels of contaminants, such as halogens and sulfur compounds, that result in the

3-560
potential for SCC. Leakage within the Containment is monitored and strictly controlled

during plant operation and is investigated and corrected such that the potential for

wetting of NSSS component support bolting is minimal. Based on the marginally

susceptible bolting materials and a dry, non-conducive (benign) service environment,

cracking due to SCC is not an aging effect requiring management for this bolting.

As identified in Millstone Power Station Unit 2 LRA Table 3.5.2-24 and Millstone Power

Station Unit 3 LRA Table 3.5.2-35, loss of material is conservatively considered an aging

effect requiring management for NSSS component support bolting and is managed by

the Inservice Inspection Program: Systems, Components and Supports AMP (which

includes the elements of the ASME Section Xl, Subsection IWF requirements as

described in LRA Appendix B2.1.18). In addition, loss of material due to the potential for

borated water leakage from nearby components is managed by the Boric Acid Corrosion

and General Condition Monitoring AMPs.

Since the boric acid corrosion and general condition monitoring programs ensure a dry, nonconducive (benign) service environment and the bolting material is managed by the inservice

inspection program, the staff finds this acceptable.

3.5B.2.3.36 General Structural Supports - Aging Management Evaluation - Table 3.5.2-36

The staff reviewed Table 3.5.2-36 of the LRA, which summarized the results of AMR evaluations

for the general structural supports component groups; The staff interviewed the applicant's

technical staff and reviewed the Unit 3 technical report for general structural supports.

The GALL Report does not include this material for these components. The applicant

concluded, as documented in the staff's MPS audit and review report for the AMR for the Unit 3

miscellaneous structures, for aluminum in an air or an air environment, that there are no

potential aging mechanisms for this aluminum and environment combination. The applicant

stated in the MAER that for aluminum material in an air or atmosphere/weather environment

there are no potential aging mechanisms for this material and environment combination at Unit

3. This conclusion is based on engineering text references that indicate that aluminum and its

alloys resist attack to a wide range of environments and many chemical compounds. On the

basis of its review of the applicant's documentation, the staff concurs with the applicant and

concludes that there are no aging effects requiring management for aluminum in an

atmosphere/weather environment.

In the LRA, the applicant has identified no aging effects for aluminum components exposed to

an air environment, including electrical conduit and cable tray component types. The GALL

Report does not include this material for these components. The applicant concludes, as

documented in the Unit 3 technical report for miscellaneous structures, for aluminum in an air or

an air environment, the applicant concludes that there are no potential aging mechanisms for

this aluminum and environment combination. The applicant stated in the MAER that for

aluminum material in an air or atmosphere/weather environment there are no potential aging

mechanisms for this material and environment combination at Unit 3. This conclusion is based

on engineering text references that indicate that aluminum and its alloys resist attack to a wide

range of environments and many chemical compounds. On the basis of its review of the

applicant's documentation, the staff concurs with the applicant and concludes that there are no

aging effects requiring management for aluminum in an air environment.

3-561
In the LRA, the applicant identified no aging effects for stainless steel components exposed to

air, including sliding support bearing and sliding surfaces, structural support components (plate

structural shapes, etc.) and vendor supplied specialty items (spring hangers, struts, clamps,

vibration isolators, etc.) component types.

During the audit and review, the staff asked the applicant why the MPS AMP B.2.1.18, 'Inservice

Inspection Program: Systems, Components and Supports," was not credited to mange loss of

mechanical function, as described in the GALL Report. By letter dated January 11, 2005, the

applicant stated that the inspection requirements for these supports associated with ASME Xl

IWF that are part of the CLB will carry forward to the period of extended operation.

On the basis of its review, the staff concurred with the applicant concerning the adequacy of

inspections in accordance with ASME Xl IWF.

In the LRA, the applicant stated that the GALL Report does not include a borated water leakage

environment for sliding support bearing and sliding surfaces of copper alloy material.

The applicant identified, as documented in Unit 3 Technical Report, MP-LR-4651, "General

Structural Supports," Revision 2, for copper alloys in a borated water leakage environment, that

boric acid corrosion as an aging 'mechanism for loss of material. The applicant stated that these

components do not exceed the temperature threshold of 350 OF. Therefore, boric acid corrosion

is a potential aging mechanism for copper alloys. On the basis of its review of the applicant's

document, the staff concurred with the applicant and concluded that boric acid corrosion is a

potential aging mechanism for copper alloys. In the LRA; the applicant stated that loss of

material for copper alloy reactor vessel support: sliding support plate in a borated water leakage

environment is managed by MPS AMP B2.1.13, "General Condition Monitoring." The staff

reviewed the general condition monitoring program and its evaluation is documented in Section

3.0.3.3.2 of this SER. The general condition monitoring program, managed these aging effects

by visual inspections for evidence of degradation or adverse conditions and included heath

physics inspections of radiologically controlled areas, system walkdowns by system engineering,

and daily inspections of accessible areas of the plant by plant operators. Evidence of boron

precipitation and active radioactive system leaks is identified during area observations made by

health physics technicians while performing radiologically controlled area surveys. On the basis

of its review, the staff finds the general condition monitoring program acceptable for managing

the aging effect of loss of material for copper alloys for this component.

In the LRA, the applicant identified no aging effects for galvanized steel components exposed to

air, including electrical conduit and cable tray component types. Air is not identified in the GALL

Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Significant corrosion'of carbon (galvanized,

steel) and low-alloy steel requires an electrolytic'environment, and a simultaneous presence of'

oxygen and moisture. Without the presence of the aggressive environment, low-alloy steel

components will experience insignificant amounts of corrosion, and no aging effects are I

applicable to this component/commodity group. Therefore, the staff concluded that there are no

aging effects requiring management for metal in an air environment.

I

I

3-562
- - -

Table 3.5.2-25 of Unit 2 and Table 3.5.2-36 of Unit 3 list boric acid corrosion as an AMP for

galvanized steel electrical conduit and cable trays. The staff did not find that galvanized steel

was included in the boric acid corrosion program as described in B2.1.3. In RAI 3.5-12, the staff

requested the applicant to address this discrepancy.

By letter dated November 9, 2004, the applicant provided the following response:

The electrical conduit and cable trays listed in Unit 2 LRA Table 3.5.2-25 and Unit 3

LRA Table 3.5.2-36 are fabricated from carbon steel material that was galvanized for

corrosion protection, and has been termed "galvanized steel" in the tables. Since no

credit has been taken for the galvanized coating as described in LRA Appendix C,

Section C2.4, the electrical conduit and cable trays loss of material aging effect due to

boric acid corrosion is managed with the Boric Acid Corrosion program. Accordingly,

this material is in the category of materials termed "carbon and low alloy steel" in the

Boric Acid Corrosion program as described in B2.1.3.

The staff finds the applicant's response acceptable.

3.5B.2.3.37 Miscellaneous Structural Commodities - Aging Management Evaluation -

Table 3.5.2-37

The staff reviewed Table 3.5.2-37 of the LRA, which summarized the results of AMR evaluations

for the miscellaneous structural commodities component groups. The staff interviewed the

applicant's technical staff and reviewed the Unit 3 technical report for miscellaneous structural

commodities.

In the LRA, the applicant stated that the GALL Report does not include Pyrocrete for fire

resistant coating in an air environment. The applicant identified, as documented in the staffs

MPS audit and review report for the AMR for the Unit 3 miscellaneous structural commodities,

for Pyrocrete in an air environment, irradiation as an aging mechanism for change of material

properties. The applicant stated that fire resistant coating material may be exposed to ionizing

radiation values greater than the threshold radiation of 1 OE6 Rads. On the basis of its review of

the applicant's documentation, the staff concurs with the applicant and finds that irradiation is a

potential aging mechanism for Pyrocrete. In the LRA, the applicant stated that change of

material properties for fire resistant coatings in an air environment is managed by MPS AMP

B2.1.10, 'Fire Protection Program,".with exception. The staff reviewed the fire protection

program and its evaluation is documented in Section 3.0.3.2.7 of this SER. The staff also

reviewed this program with respect to the SRP-LR. The staff finds that the fire protection

program, with an exception, manages, through periodic inspection and tests, the aging effects

on penetration seals, fire barrier walls, ceilings, floors, and all fire rated doors that perform a fire

barrier intended function. Qualified personnel perform periodic inspections to identify any

changes in the condition such as change in material properties. On the basis of its review, the

staff finds this program acceptable for managing the aging effects, for the above components, of

change in material properties due to irradiation of Pyrocrete in an air environment.

In the LRA, the applicant stated that the GALL Report does not include Pyrocrete for fire

resistant coating in an air environment. The applicant identified, as documented in the staffs

MPS audit and review report for the AMR for Unit 3 miscellaneous structural commodities, for

Pyrocreter in an air environment, differential movement, shrinkage, and vibration as an aging

3-563
mechanisms for cracking. The applicant stated that fire resistant coating materials are subject to cracking due to differential movement, shrinkage, and vibration. On the basis of its review of the

applicant's documentation, the staff concurs with the applicant and finds that differentialmovement, shrinkage, and vibration are potential aging mechanisms for Pyrocrete. In the Unit 3 LRA, the applicant stated that cracking for fire resistant coatings in an air environment is

managed by MPS AMP B2.1.10, "Fire Protection Program," with exception. The staff reviewed

the fire protection program and its evaluation is documented in Section 3.0.3.2.7 of this SER.

The staff also reviewed this program with respect to the SRP-LR. The staff finds that the fire

protection program, with an exception, manages, through periodic inspection and tests, the aging effects on penetration seals, fire barrier walls, ceilings, floors, and all fire rated doors that perform a fire barrier intended function. Qualified personnel perform periodic inspections to

identify any changes in the condition such as change in material properties. On the basis of its review, the staff finds this program acceptable for managing the aging effects, for the above

components, of cracking due to differential movement, shrinkage, and vibration of Pyrocrete in

an air environment.

In the LRA, the applicant stated that there are no aging effects for ceramic fire/equipment qualification barrier penetration seals and concludes that no AMPs are required. The applicant stated that its AMR conclusion for the material is consistent with the GALL Report, which only calls for aging management of ceramic fire barrier penetration seals that are exposed to an

outdoor environment. On the basis of its review of the applicant's documentation and that the ceramic materials are exposed only to indoor environments, the staff concurs with the applicant and finds that ceramic fire/equipment qualification barrier penetration seals do not require aging management for the period of extended operation.

In the LRA, the applicant identified no aging effects for carbon steel components exposed to air, including cable tray cover and assembly; junction, terminal, and pull boxes; bus duct enclosures; panels and cabinets; switchgear enclosures; and electrical component supports within cabinets

and panels component types. Air is not identified in the GALL Report as an environment for these components and materials.

On the basis of its review of current industry research and operating experience, the staff finds that air on metal will not result in aging that will be of concern during the period of extended

operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Significant corrosion of carbon and

low-alloy steel requires an electrolytic environment, and a simultaneous presence of oxygen and moisture. Without the presence of the aggressive environment, low-alloy steel components will

experience insignificant amounts of corrosion, and no aging effects are applicable to this component/commodity group. Therefore, the staff finds that there are no aging effects requiring management for metal in an air environment.

In the LRA, the applicant stated that the GALL Report does not include cracking of rubber for flood prevention plugs in an air environment. The applicant identifies, in the Unit 3 technical

report for miscellaneous structural commodities, f6r rubber in an air environment, thermal

exposure as an aging mechanism for cracking. The applicant stated that rubber for flood

prevention plugs may be exposed to temperatures greater than the threshold of 95 OF. On the

basis of its review of the applicant's documentation, the staff concurs with the applicant and finds that thermal exposure is a potential aging mechanism for rubber.

3-564
In the LRA, the applicant also stated that cracking for rubber flood prevention plugs in an air

environment is managed by MPS AMP B2.1.23, tStructures Monitoring Program." The staff

reviewed the structures monitoring program and its'evaluation is documented in Section

3.0.3.2.16 of this SER. The staff also reviewed this program with respect to the SRP-LR. The

staff finds that structural monitoring activities are intended to assess the overall integrity and

condition of structures, components, support systems and specified architectural details.

Qualified personnel perform periodic inspections to identify any changes in the condition such as

cracking. On the basis of its review, the staff finds this program acceptable for managing the

aging effects, for the above components, of cracking due to thermal exposure of rubber in an air

environment.

In the LRA, the applicant identified no aging effects for aluminum components exposed to an

atmosphere/weather environment, including bus duct enclosure component types. The GALL

Report does not include this material for these components. In the Unit 3 technical report for

miscellaneous structural commodities, for aluminum in an air environment, the applicant

concludes that there are no potential aging mechanisms for this aluminum and environment

combination., The applicant stated in the MAER that for aluminum material in an air or

atmosphere/weather environment there are no potential aging mechanisms for this material and

environment combination at Unit 3. This conclusion is based on engineering text references that

indicate that aluminum and its alloys resist attack to a wide range of environments and many

chemical compounds. On the basis of its review of the applicant's documentation, the staff

concurs with the applicant and finds that there are noaging effects requiring management for

aluminum in an atmosphere/weather environment.-.

In the LRA, the applicant identified no aging effects for aluminum components exposed to an air

environment, including cable tray cover assemblies and bus duct enclosure component types.

The GALL Report does not include this material for these components. The applicant concludes,

in the Unit 3 technical report for miscellaneous structural commodities, for aluminum mn'an air

environment, that there are no potential aging mechanisms for this aluminum and environment

combination. The applicant stated in the MAER that for aluminum material in an air or

atmosphere/weather environment there are no potential aging mechanisms for this material and

environment combination at Unit 3. This conclusion is based on engineering text references that

indicate that aluminum and its alloys resist attack to a wide range of environments and many

chemical compounds. On the basis of its review of the applicant's documentation, the staff

concurs with the applicant and finds that there are no aging effects requiring management for

aluminum in an air environment. ;.

The applicant stated, as documented in the 'IMiscellaneous Structural Commodities" section of

the Unit 3 technical report for miscellaneous structural commodities, as follows:

The MAER includes an evaluation of aluminum material in an air or an

atmosphere/weather environment, and concludes that there are no potential

aging mechanisms for these materiaVenvironment combinations.

During the audit and review, the staff asked the applicant to explain why the evaluation is not in

the MAER and provide the basis for its conclusions. The applicant that the MAER addressed

aluminum material in an air or atmosphere/weather environment, and concluded that there are

no potential aging mechanisms for these material/environment combinations at Unit 3. The

applicant stated that this conclusion is based on engineering test references, "Handbook of

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Corrosion Data" and "Uhlig's Corrosion Handbook." The Handbook of Corrosion Data indicates

that aluminum and its alloys resist attack by a wide range of environments and many chemical

compounds. Consequently, aluminum is one of the metals most thought of by the public and

engineering community when lower temperature corrosion resistance is considered. Uhlig's

Corrosion Handbook indicates that aluminum-based alloys as a class are highly resistant to

normal outdoor exposure conditions. This conclusion in the MAER is also based on other

nuclear power stations license renewal safety evaluation reports (SERs) (i.e., Turkey Point, St.

Lucie, and Surry) that have environments, particular as outdoor environments, similar to Unit 3.

Further, this conclusion is also supported by a review of Unit 3 plant-specific operating

experience, which identifies no instances of loss of material for aluminum in an air or

atmosphere/weather environment. The applicant also stated that the conclusions in the LRA

remain valid and unchanged. However, the applicant initiated a change request to revise the

MAER technical report document to include these references in the aluminum/air and

aluminum/atmosphere/weather sections. On the basis of its review, the staff finds the applicant's

response acceptable.

The applicant stated, as documented in the staff's MPS audit and review report for the Unit 3

miscellaneous structural commodities, that the information for fire/EQ barrier penetration seals

(including ceramic damming material) indicated "Not Applicable" for the evaluation group. During

the audit and review, the staff asked the applicant to explain how the ceramic dammirig material

was evaluated for aging effects. The applicant stated that ceramic materials are similar to the

glass and porcelain that are described in the MAER as having no aging effects. As documented

in the staff's MPS audit and review report, the applicant stated that it does not properly

document this conclusion and the MAER does not specifically address ceramics. The applicant

stated that the conclusions in the LRA remain valid and unchanged. However, the applicant has

initiated a change request to revise the MAER technical report to include ceramic along with

glass and porcelain as having no aging effects that require evaluation for any application or

environment to which it is exposed. In addition, the applicant initiated change requests to revise

the Unit 3 miscellaneous structural commodities to indicate that the MAER indicates no potential

aging effects and no aging management required for ceramics; therefore, the AMR does not

evaluate aging mechanisms for the ceramic blanket or ceramic board in an air environment. On

the basis of its review, the staff finds the applicant's response acceptable.

The polyethylene form used for expansion joint/seismic gap material between adjacent

buildings/structures in the atmosphere/weather environment is listed as no aging effect requiring

management in Table 3.5.2-37 of Unit 3. In RAI 3.5-8, the applicant was requested to provide

technical data to show that the polyethylene form material will not degrade in the

atmosphere/weather environment and the plant operating experience to substantiate it.

By letter dated November 9, 2004, the applicant responded that The polyethylene foam material

used for seismic gap filler is covered by a flashing and not exposed to rain, wind, or sun. There

should not have been an Expansion joint/Seismic gap material line item in LRA Table 3.5.2-37

with an atmosphere/weather environment. As indicated in Table 3.5.2-37, aging effects for the

polyethylene foam are managed by the structures monitoring program.

The staff finds the applicant's response acceptable.

Table 3.5.2-37 of Unit 3 lists structures monitoring program as the AMP for neoprene

used for flood gate gasket, roof hatch seals, and watertight door gasket, but lists Work

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Control Process as the AMP for neoprene used for gaskets in junction, terminal, and

pull boxes. In RAI 3.5-9, the applicant was requested to explain the need for using different

AMPs for the same material.

By letter dated November 9, 2004, the applicant responded that the structures monitoring .

program AMP manages the aging effects for flood gates, roof hatches, and watertight doors,

which are considered to be structural members, and includes inspection of the associated flood

gate gasket, roof hatch seals, and watertight door gaskets. The structures monitoring program

AMP does not include inspection of junction, terminal,- and pull boxes since these items are not

considered to be structural members. Therefore, the work control process AMP is credited for

managing aging effects associated with gaskets in junction, terminal and pull boxes.

The staff finds the applicant's response acceptable.

Table 3.5.2-37 listed no aging effect requiring management for carbon steel junction,

terminal, and pull boxes in air environment. In RAI 3.5-10, the applicant was requested to

provide data to show that the carbon steel will not rust in the air that may contain moisture and

the plant operating experience to substantiate it.

By letter dated November 9, 2004, the applicant stated that as described in note 35 for the

carbon steel junction, terminal, and pull boxes in LRA Table 3.5.2-37, loss of material is not an

applicable aging effect since these components are not exposed to an intermittent wetted

environment.

This conclusion is consistent with the North Anna and Surry License Renewal SER concurrence

that carbon steel components have not experienced corrosion degradation that would affect the

intended function of components due to humidity in the absence of cyclic or intermittent wetting

(North Anna Power Station Units 1 and 2, and Surry Power Station, Units 1 and 2, NUREG1766, Section 3.8.5.2.1, Page 3-230). Further, this conclusion is supported by a review of

Millstone plant-specific operating experience, which identifies no instances of loss of material

due to corrosion of the junction, terminal, and pull boxes in an air environment.

The staff finds the applicant's response acceptable.

3.5B.2.3.38 Load Handling Cranes and Devices - Aging Management Evaluation - Table 3.5.2-38

The staff reviewed Table 3.5.2-38 of the LRA, which summarized the results of AMR evaluations

for the load handling cranes and devices component groups. The staff interviewed the

applicant's technical staff and reviewed the Unit 3 technical report for load handling cranes and

devices.

In the LRA, the applicant has identified no aging effects for stainless steel components exposed

to air, including fuel transfer system support members (structural base supports, tracks and

anchorage) component types. Air is not identified in the GALL Report as an environment for

these components and materials. ' ;

On the basis of its review of current industry research and operating experience, the staff finds

that air on metal will not result in aging that will be of concern during the period of extended

3-567
operation. The external environments being referred to are typical of ambient air (e.g., under a

shelter, indoor, or air-conditioned enclosure or room). Without the presence of the aggressive

environment, stainless steel components will experience insignificant amounts of corrosion, and

no aging effects are applicable to this component/commodity group. Therefore, the staff finds

that there are no aging effects requiring management for metal in an air environment.

Conclusion. On the basis of its review, the staff finds that the applicant appropriately evaluated

AMR results involving material, environment, aging effect requiring management, and AMP

combinations that are not evaluated in the GALL Report. The staff finds that the applicant has

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21 (a)(3).

3.5B.3 Conclusion

On the basis of its review, the staff concludes that the applicant has demonstrated that the aging

effects associated with the containment, structures and component supports systems

components will be adequately managed so that the intended functions will be maintained

consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

The staff also reviewed the applicable FSAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the containment,

structures and component supports systems, as required by 10 CFR 54.21(d).

3.6 Aging Management of Electrical and Instrumentation and Controls

This section of the SER documents the staff's review of the applicant's AMR results for the

electrical and instrumentation and controls components and component groups associated with

the following systems:

* cable and connectors

* electrical penetrations

* bus duct

3.6.1 Summary of Technical Information In the Application

In LRA Section 3.6, the applicant provided AMR results for electrical and instrumentation and

controls components and component groups. In LRA Table 3.6.1, NSummary of Aging

Management Evaluations in Chapter VI of NUREG-1801 for Electrical Components," the

applicant provided a summary comparison of its AMRs with the AMRs evaluated in the GALL

Report for the electrical and instrumentation and controls components and component groups.

In LRA Tables 3.6.2-1 through 3.6.2-3, the applicant provided a summary comparison of the

Millstone aging management activities with the aging management activities evaluated in

NUREG-1801 for the electrical component groups Cables and Connectors, Electrical

Penetrations and Bus Duct. In these tables, the applicant also provided a summary of materials

of construction, service environments, aging effects requiring management, and credited aging

management program for each electrical component group.

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The applicant's AMRs incorporated applicable operating experience in the determination of

AERMs. These reviews included evaluation of plant-specific and industry operating experience.

The plant-specific evaluation included reviews of condition reports and discussions with

appropriate site personnel to identify AERMs. The applicant's review of industry operating

experience included a review of the GALL Report and operating experience issues identified

since the issuance of the GALL Report.

3.6.2 Staff Evaluation

The staff reviewed LRA Section 3.6 to determine if the applicant provided sufficient information

to demonstrate that the effects of aging for the electrical and instrumentation and controls

system components that are within the scope of license renewal and subject to an AMR will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21 (a)(3).

Also, the staff performed an onsite audit of AMRs to confirm the applicant's claim that certain

identified AMRs were consistent with the GALL Report. The staff did not repeat its review of the

matters described in the GALL Report. However, the staff did verify that the material presented

in the LRA was applicable and that the applicant had identified the appropriate GALL AMPs. The

staffs evaluations of the AMPs are documented in Section 3.0.3 of this SER. .Details of the

staffs audit evaluation are documented in the staffs MPS audit and review report and

summarized in Section 3.6.2.1 of this SER.

The staff also performed an onsite audit of those AMRs that were consistent with the GALL

Report and for which further evaluation is recommended. During the audit, the staff verified that

the applicant's further evaluations were consistent with the acceptance criteria in Section 3.6.2.2

of NUREG-1800, "Standard Review Plan for Review of License Renewal Applications for

Nuclear Power Plants," dated July 2001. The staffs audit evaluations are documented in the

staffs MPS audit and review report and summarized in Section 3.6.2.2 of this SER.

The staff performed an onsite audit and conducted a technical review of the remaining AMRs

that were not consistent with or not addressed in the GALL Report. The audit and technical.

review included evaluating whether all plausible aging effects were identified and the aging

effects listed were appropriate for the combination of materials and environments specified. The

staff's audit evaluations are documented in the staff's MPS audit and review report and

summarized in Section 3.6.2.3 of this SER. The staffs evaluation of its technical review is also

documented in Section 3.6.2.3 of this SER.

Finally, the staff reviewed the AMP summary descriptions in the FSAR supplement to ensure

that they provided an adequate description of the programs credited with managing or

monitoring aging for the electrical and instrumentation and controls system components.

Table 3.6-1 below provides a summary of the staffs evaluation of components, aging

effects/mechanisms, and AMPs listed in LRA Section 3.6 that are addressed in the GALL

Report.

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Table 3.6-1 Staff Evaluation for Electrical and Instrumentation and Controls in the GALL

Report

C n roiz3 'Aging Effectlj-A: Mln'GALL2:. <-- AMP A ff Evat O- :tme. Gr.u- .nMh L im ti-r- f~~ ;. i- ]s-.:..1- . In u;;o 'Mecanlim-'. e'rt,'--.-

Electrical equipment Degradation due to Environmental TLAA This TLAA is

subject various aging qualification of evaluated in Section

tolO CFR 50.49 EQ mechanisms electrical 4.4.

requirements components (Item Number

3.6.1-01)

Electrical cables Embrittlement, Aging management Electrical cables Consistent with

and connections not cracking, melting, program for and connectors not GALL, which

subject to discoloration, electrical cables and subject to recommends no

10 CFR 50.49 EQ swelling, or loss of connections not 10 CFR 50.49 further evaluation

requirements dielectric strength subject to 10 CFR environmental (See Section

(Item Number leading to reduced 50.49 EQ qualification 3.6.2.1)

3.6.1-02) IR; electrical failure requirements requirements

caused by thermal/ (B2.1.8) thermoxidative

degradation of

organics, radiolysis

and photolysis (UV sensitive materials

only) of organics; radiation-induced

oxidation; moisture

Intrusion

Electrical cables Embrittlement, Aging management Electrical cables not Consistent with

used In cracking, melting, programs for subject to GALL, which

instrumentation discoloration, electrical cables 10 CFR 50.49 recommends no

circuits not subject swelling, or loss of used in environmental further evaluation

to 10 CFR 50.49 EQ dielectric strength Instrumentation qualification (See Section

requirements that leading to reduced circuits not subject requirements used 3.6.2.1)

are sensitive to IR; electrical failure to 10 CFR 50.49 EQ in instrumentation

reduction in caused by thermall requirements circuits (B2.1.9)

conductor Insulation thermoxidative

resistance degradation of

(Item Number organics; radiation3.6.1-03) induced oxidation;

moisture intrusion

Inaccessible Formation of water Aging management Inaccessible Consistent with

medium-voltage (2 trees; localized program for medium-voltage GALL, which

kV to 15 kV) cables damage leading to inaccessible cables not subject recommends no

not subject to electrical failure medium-voltage to 10 CFR 50.49 further evaluation

10 CFR 50.49 EQ (breakdown of cables not subject environmental (See Section

requirements Insulation) caused to 10 CFR 50.49 EQ qualification 3.6.2.1)

(Item Number by moisture requirements requirements

3.6.1-04) intrusion and water (B2.1.14)

trees

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-Aing Amg Effe6CI §-.-., ' in AL-t 1 AM In LR -, -Sta aEvaluation'ln

-MeochanIsm 4-T' t'epot:,; - o.>` - -'

Electrical Corrosion of Boric acid corrosion Not applicable (See

connectors not connector contact Section 3.6.2.1)

subject to 10 CFR surfaces caused by

50A9 EQ intrusion of borated

requirements that water

are exposed to

borated water

leakage

(Item Number

3.6.1-05) . . .

The staff's review of the MPS electrical and instrumentation and controls and associated

components followed one of several approaches. One`approach, documented in Section 3.6.2.1,

involves the staff's review of the AMR results for components in the electrical and

instrumentation and controls'that the applicant indicated are consistent with the GALL Report

and do not require further evaluation. Another approach, documented in Section 3.6.2.2,

involves the'staff's review of the AMR results for components in the electrical and

instrumentation and controls that the applicant indicated are consistent with the GALL Report

and for which further evaluation is recommended. A third approach, documented in Section

3.6.2.3, involves the staffs review of the AMR results for components in the electrical and

instrumentation and controls that the applicant indicated are not consistent with the GALL Report

or are not addressed in the GALL Report. The staff's review of AMPs that are credited to

manage or monitor aging effects of the electrical and instrumentation and controls components*

is documented in Section 3.0.3 of this SER.

3.6.2.1 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Not Recommended

Summary of Technical Information in the ADDlication. In Section 3.6.2.1 of the LRA, the applicant

identified the materials, environments, and AERMs. The applicant identified 'the following

programs that manage aging effects related to the electrical and instrumentation and control

components:

* Electrical Cables and Connectors Not Subject to' 10 CFR 50.49 Environmental

,Qualification Requirements Program

* Electrical Cables'Not Subject to 10 CFR 50.49'Environmental Qualification Requirements

Used in Instrumentation Circuits Program

* Inaccessible Medium-Voltage Cables Not'Subject to 10 CFR 50.49 Environmental

Qualification Requirements Program

Staff Evaluation. In LRA Tables 3.6.2-1 through 3.6.2-3,'the applicant provided a summary of

AMRs for the electrical and instrumentation an'd control components-and identified which AMRs

it considered to be consistent with the GALL Report.

For component groups evaluated in the'GALL Report for which the applicant has claimed

consistency with the GALL Report, and for which the'GALL'Report does not recommend further

evaluation, the staff performed an audit and review to determine whether the plant-specific

3-571-;-
components contained in these GALL Report component groups were bounded by the GALL

Report evaluation.

The applicant provided a note for each AMR line item. The notes described how the information

in the tables aligns with the information in the GALL Report. The staff audited those AMRs with

Notes A through E, which indicated the AMR was consistent with the GALL Report.

Note A indicated that the AMR line item is consistent with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP is consistent with the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report and the validity of the AMR for the site-specific conditions.

Note B indicated that the AMR line item is consistent.with the GALL Report for component,

material, environment, and aging effect. In addition, the AMP takes some exceptions to the AMP

identified in the GALL Report. The staff audited these line items to verify consistency with the

GALL Report. The staff verified that the identified exceptions to the GALL AMPs had been

reviewed and accepted by the staff. The staff also determined whether the AMP identified by the

applicant was consistent with the AMP identified in the GALL Report and whether the AMR was

valid for the site-specific conditions.

Note C indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP is consistent

with the AMP identified by the GALL Report. This note indicates that the applicant was unable to

find a listing of some system components in the GALL Report. However, the applicant identified

a different component in the GALL Report that had the same material, environment, aging

effect, and AMP as the component that was under review. The staff audited these line items to

verify consistency with the GALL Report. The staff also determined whether the AMR line item of

the different component was applicable to the component under review and whether the AMR

was valid for the site-specific conditions.

Note D indicated that the component for the AMR line item is different from, but consistent with

the GALL Report for material, environment, and aging effect. In addition, the AMP takes some

exceptions to the AMP identified in the GALL Report. The staff audited these line items to verify

consistency with the GALL Report. The staff verified whether the AMR line item of the different

component was applicable to the component under review. The staff verified whether the

identified exceptions to the GALL AMPs had been reviewed and accepted by the staff. The staff

also determined whether the AMP identified by the applicant was consistent with the AMP

identified in the GALL Report and whether the AMR was valid for the site-specific conditions.

Note E indicated that the AMR line item is consistent with the GALL Report for material,

environment, and aging effect, but a different aging management program is credited. The staff

audited these line items to verify consistency with the GALL Report. The staff also determined

whether the identified AMP would manage the aging effect consistent with the AMP identified by

the GALL Report and whether the AMR was valid for the site-specific conditions.

The staff conducted an audit and review of the information provided in the LRA, as documented

in its MPS audit and review report. The staff did not repeat its review of the matters described in

the GALL Report. However, the staff did verify that the material presented in the LRA was

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3-572
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applicable and that the applicant had identified the appropriate GALL Report AMRs. The staff

evaluation is discussed below.

Conclusion. The staff has evaluated the applicant's claim of consistency with GALL Report. The

staff also has reviewed information pertaining to the applicant's consideration of recent operating

experience and proposals for managing associated aging effects. On the basis of its review, the

staff finds that the AMR results, which the applicant claimed to be consistent with the GALL

Report, are consistent with the AMRs in the GALL Report. Therefore, the staff finds that the

applicant has demonstrated that the effects of aging for these components will be adequately

managed so that their intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3).

3.6.2.2 AMR Results That Are Consistent with the GALL Report, for Which Further

Evaluation is Recommended

Summary of Technical Information in the Ar22lication. In LRA Section 3.6.2.2, the applicant

provided further evaluation of aging management as recommended by the GALL Report for

electrical components. The applicant provided information concerning how it will manage the*

aging effects of electrical equipment subject to environmental qualification.

The applicant stated that environmental qualification is a TLAA as defined in 10 CFR 54.3.

TLAAs are required to be evaluated in accordance with 10 CFR 54.21 (c)(1). The evaluation of

this TLAA is addressed separately in LRA Section 4.4, Environmental Qualification of Electric

Equipment and LRA Appendix B, Section B3;1, Electrical Equipment Qualification.

Staff Evaluation. For component groups evaluated in the GALL Report for which the applicant

has claimed consistency with the GALL Report, and for which the GALL Report recommends

further evaluation, the staff reviewed the applicant's evaluation to determine whether it

adequately addressed the issues that were further evaluated.

The GALL Report indicates that further evaluation should be performed for the aging effects

described in the following sections.

3.6.2.2.1 Electrical Equipment Subject to Environmental Qualification

As stated in the SRP-LR, environmental qualification is a TLAA, as defined in 10 CFR 54.3.

Applicants must evaluate TLAAs in accordance with 10 CFR 54.21 (c)(1). Section 4.4 of this SER

documents the staffs review of the applicant's evaluation of this TLAA. In performing this review,

the staff followed the guidance in Section 4.4 of the SRP-LR.

3.6.2.2.2 Quality Assurance for Aging Managemenit of Non-Safety-Related Components

Section 3.0.4 of this SER provides the staff's evaluation of the applicant's quality assurance

program.

Conclusion. On the basis of its review, for component groups evaluated in the GALL Report for

which the applicant has claimed consistency with the GALL Report, and for which the GALL

Report recommends further evaluation, the staff determines that (1) those attributes or features

for which the applicant claimed consistency with the GALL Report were indeed consistent and

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(2) the applicant adequately addressed the issues that were further evaluated. The staff finds

that the applicant has demonstrated that the effects of aging will be adequately managed so that

the intended functions will be maintained consistent with the CLB for the period of extended

operation, as required by 10 CFR 54.21 (a)(3).

3.6.2.3 AMR Results That Are Not Consistent With or are Not Addressed in the GALL

Report

Summary of Technical Information in the ApDlication. The applicant did 'not address the AMR

results of electrical components which are not addressed in the GALL Report.

Staff Evaluation. For component type, material and environment combination that are not

evaluated in the GALL Report, the staff reviewed the applicant's evaluation to determine whether'

the applicant had demonstrated that the effects of aging will be adequately managed so that the

intended function will be maintained consistent with the CLB during the period of extended

operation.

The applicant identified three commodities which indicated would cover all electrical components

within the scope of licensee renewal. These commodities were identified as:

(1) Cable and Connectors. In its letter dated November 9, 2004, the applicant confirmed that

it treats splices as an integral part of the cable; Non-EQ splices are included in

commodity groups "Conductors" and uInsulation" in LRA Table 2.5.1-1 and the aging

management review results are included in Table 3.6.2-1. This commodity includes nonEQ cables installed in raw water or damp soil. The staff requested clarification of the

statement in the LRA that the thermal exposure of elastomers would remain below 95 0F

and therefore would not require an AMP. In its response dated January 11, 2005, the

applicant confirmed that the referenced temperature was the ambient temperature and

when the effects of ohmic heating on the cable insulation is included, sufficient margin

exists below the 60 year analyzed temperature limit for the extended period of operation.

Therefore no aging management program is required.

(2) Containment Electrical Penetrations. The staff requested clarification on the following two

items.

1. The LRA stated that the pressure boundary of the electrical containment

penetrations contain non-metallic components such as Polysulfone and Vitron.

Clarify why there is no aging management program required for those materials

that maintain containment integrity or identify the AMP that does cover this

function.

2. The LRA stated that the electrical conduction and insulation functions of the

electrical containment penetrations contain electrical connectors, insulation and

insulators. Clarify why there is no aging management program required for those

materials that maintain electrical conductivity and insulation or identify the AMP

that does cover these functions.

In its response dated November 9, 2004, the applicant stated that the non-EQ

penetrations were qualified to the same requirements as the EQ penetrations. The

applicant stated the life expectancy of the electrical penetrations exceed 60 years and

therefore was not a concern for the extended period of operation.

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(3) Bus Duct. The staff requested clarification on two items.

1. The LRA did not address an aging management program for the high-voltage

cables and connectors from the pbrtions of the 345 kV switchyard to the reserve

station seice transformer (RSST) and the medium-voltag'e cables (including any

cable bus or bus duct) and connectors from the RSST to the Class 1 E switchgear

that are used to recover offsite power following a station blackout (SBO).

2. The applicant responded in its response dated December 3, 2004, that the SBO

path within the scope of licensee renewal included the 345 kV switchyard and the

high-voltage bus from the switchyard to the RSSTs. The applicant also stated that

the aluminum conductor steel reinforced (ACSR) high-voltage conductor and the

tubular aluminum high-voltage bus were not insulated and experience has

demonstrated no corrosion of the conductors that could cause a loss of intended

function.

The applicant stated in its response dated December 3, 2004, that the medium-voltage

connection from the Unit 2 RSST to the safety-related bus was by cable and the

connection from the Unit 3 RSST to the safety-related bus was by cable and bus duct.

The staff review of the SBO path for license renewal is documented below in three parts in the

following sections.

* high voltage insulators (Section 3.6.2.3.2)

* non-segregated bus duct (Section 3.6.2.3.3): - * switchyard bus (Section 3.6.2.3.4)

3.6.2.3.1 Electrical Connectors not Subject to 10 CFR 50.49 EQ Requirements That Are

Exposed to Borated Water Leakage

Summary of Technical Information in the ADplication. The applicant identified the following aging

effects associated with electrical components subjected to exposure to borated water require

management:

* reduced insulation resistance caused by corrosion.

* loss of material caused by corrosion.

In LRA Table 3.6.1, "Summary of Aging Management Evaluations for Electrical Components in

Chapter VI of NUREG-1 801," the applicant indicated in item 3.6.1-05 that the borated water

leakage environment was considered for electrical connectors. However, connectors at Millstone

are protected from borated water leakage by their location within protective enclosures and by

design features which seal the enclosures along with associated conduit and cable entrances

and corrosion of connector contact surfaces caused by intrusion of borated water is not an aging effect requiring management. -

In LRA Table 3.6.1, "Summary of Aging Management Evaluations for Electrical Components in

Chapter VI of NUREG-1 801," the applicant stated that an aging management program was not

required.

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In LRA Section B2.1.3, uBoric Acid Corrosion," the applicant stated that the Millstone boric acid

corrosion program addresses industry experience in. response to Nuclear Regulatory

Commission (NRC) Generic Letter (GL) 88-05 and Bulletins 2002-01 and 2002-02. The Millstone

boric acid corrosion program manages loss of material in areas where there are carbon steel

and low-alloy steel structures or components on which borated reactor water might leak.

Staff Evaluation. The staff agreed that LRA correctly identified the aging effects associated with

electrical components exposed to boric acid. The staff also agreed that there is no need for an

aging management program for electrical connections exposed to borated water because the

design at Millstone inhibits the ingress of borated water into electrical connections and the boric

acid corrosion program will address any observed borated water leakage.

The staff concluded that the applicant adequately addressed the aging threat to electrical

connections from borated water by design of the connection enclosures supplemented by their

borated water leakage assessment program and no separate aging management program for

connectors exposed to borated water was required.

3.6.2.3.2 High Voltage Insulators

Summary of Technical Information in the Application. Section 2.1.3.7.5, Station Blackout,

includes the following components in scope for offsite power restoration following a SBO: 1) the

345 kV bus to the RSST and the associated disconnect switch, 2) the overhead conductors from

the Connecticut Light & Power (CL&P) switchyard, 3) the North Bus (Unit 2), the South Bus (Unit

3) and their associated disconnect switches, and 4) the support structures associated with these

in-scope components. Section 2.5.3, Bus Ducts, describes the high-voltage bus duct connection

between the switchyard and the RSST and identifies the high-voltage insulators non-porous

translucent porcelain ceramic covered with an oven-baked glaze. The high-voltage insulators are

used to insulate the high-voltage components (cable and bus) from the grounded support

structures. No aging effects were discussed.

Table 2.5.3-1, Bus Duct, lists bus support insulator as part of the commodity group with an

intended function to insulate and provide structural support. Table 3.6.2-3, Electrical

Components - Bus Duct - Aging Management Evaluation, indicates there is no aging effect

requiring management for the bus support insulator. In Table 3.6.2-3, Electrical Components -

Bus Duct - Aging Management Evaluation, the applicant stated that there was no aging

management program for bus support insulators of porcelain material because there was no

aging effect that required management.

Staff Evaluation. In Table 3.6.2-3, Electrical Components - Bus Duct - Aging Management

Evaluation, the applicant stated that there was no aging effect that required management.

The staff concluded that the applicant adequately addressed the aging management for highvoltage insulators and agreed that no aging management program was required for high-voltage

insulators.

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- - -

3.6.2.3.3 Non-segregated Bus DuctSummary of Technical Information in the Application. Section 2.1.3.7.5, Station Blackout,

includes the bus duct from the RSST to the safety-related buses in-scope for license renewal.

Section 2.5.3, Bus Duct, describes the high-voltage bus'duct connection between (1) the -

switchyard and the RSST and (2) the medium-voltage non-segregated bus duct from the RSST

to the safety buses. No aging effects were discussed.

Table 2.5.3-1, Bus Duct, fails to include any'description for the medium-voltage bus duct

components.

Table 3.6.2-3, Electrical Components - Bus Duct Aging Management Evaluation, identifies the

insulation system material for the (medium-voltage non-segregated) bus duct conductors in Unit

3 as Noryl. (Noryl is the General Electric trademark name for a plastic type electrical insulation

material.) The table indicates there is no aging"effect requiring management for the Noryl

insulating material.

In its response to RAI 3.6-2 dated December 3, 2004, the applicant stated that there were no

bus ducts between the RSST and the safety-related buses in Unit 2. For Unit 3, round, aluminum

bus ducts are located outdoors between the RSST and the service building wall penetration.

Inside the service building, the bus ducts are bolted, insulated aluminum bus bar. The

applicant's letter indicated the bus ducts were normally loaded to 67 percent of their rating so

that thermal cycling would be minimum and splice bolting torque relaxation is not expected to

occur.

However, the Millstone-3 FSAR, Section 8.3.1.1.2, Class 1 E AC Power, states:

During normal operation, power is supplied through the normal station service

transformier A from the unit generator via the isolated phase bus duct, with the generator

breaker closed,. normal station service transformer A supplies power to emergency 4.16

kV buses 34C (Train A) and 34D (Train B),'via normal buses 34A and 34B, respectively.

In the event of loss of the normal offsite power source, the alternate offsite power source

supplies power through the reserve station service transformer A from the 345 kV

switchyard. reserve station service transformer A supplies power to emergency 4.16 kV

buses 34C (Train A) and 34D (Train B).

The applicant stated that no AMP is required for the'bus ducts in the SBO recovery path

because the bus has no aging effects requiring management.

Staff Evaluation. In its response dated December 3, 2004, to RAI 3.6-2, the applicant stated that,

for Unit 3, round, aluminum bus ducts are located outdoors between the RSST and the building

wall penetration, are welded, non-ventilated with ino joints or fasteners. Inside the service

building, the bus ducts are bolted, insulated aluminum bus bar and are vented by means of

down-turned elbow fittings with screens. The LRA identifies the insulating material used on the

Unit 3 medium-voltage, non-segregated bus duct in the service building as Noryl. Industry

experience has identified an aging effect for Noryl-insulated, non-segregated bus duct as

insulation cracking.

3-577 :
Aging effects for the non-segregated phase bus ducts requiring evaluation are those associated

with moisture/debris intrusion and bolt loosening due to thermal cycling.

The bus ducts are located both inside and outside. Bus duct enclosures located outside are nonvented. The vented bus duct does not provide protection for moisture.

Entry of debris into the vented bus duct is restricted by down-turned elbow fittings with screens.

Therefore, debris intrusion is not an aging effect requiring management. The metal bus duct

enclosures provide protection for the enclosed bus duct against weather and debris.

Industry experience has shown that bus ducts exposed to appreciable ohmic or ambient heating

during operation may experience loosening of bolted connections related to the repeated cycling

of connected loads or the ambient temperature environment. This phenomenon can occur in

heavily loaded circuits (i.e., those exposed to appreciable ohmic heating or ambient heating) that

are routinely cycled. The Millstone FSAR indicates that the normal path for power to the safetyrelated buses is from the NSST. The bus duct from the RSST to the safety-related bus is not

normally loaded. Therefore it appears that the bus duct is normally not loaded and may be

subject to thermal cycling.

Industry operating experience was reviewed for problems associated with bus ducts. The

following items were selected for further review and dispositioned:

In its response the applicant also indicated that the following generic communication were

reviewed as part of its aging management review and determined to be not applicable to

Millstone Unit 3.

* Information Notice 89-64, "Electrical Bus Bar Failures," was issued to address Norylinsulated medium-voltage bus bar failures that occurred at several nuclear facilities. The

failures identified in Information Notice 89-64 were attributed to cracking of the Noryl bus

bar insulation in combination with the accumulation of moisture or debris in the bus duct

housings that provided a tracking path to ground.

* Information Notice 98-36, "Inadequate or Poorly Controlled, Non-Safety Related

Maintenance Activities Unnecessarily Challenged Safety Systems," notified licensees of

various inadequate maintenance activities (e.g., failure to install gaskets or caulking of

outdoor components) in the industry which resulted in moisture intrusion and challenges

to safety-related systems.

* Information Notice 2000-14, "Non-Vital Bus fault Leads to Fire and Loss of Offsite

Power," informed licensees of a transient at Diablo Canyon nuclear plant caused by a

failure of a bus bar due to overheating at a splice joint. Potential causes of the failure

include inconsistent silver plating of aluminum bus bars, currents approaching bus

capacity, undersized splice plates, torque relaxation of connecting bolts, and undetected

damage from a 1995 explosion of Auxiliary Transformer 1-1.

Non-segregated phase bus duct is characterized'as all three phases contained in a single

enclosure. This could be exposed conductors (ie. tube,' bar, channel, etc.) insulated from the

enclosure or it could be insulated cable. The problems documented in Information Notices

89-64, 98-36, and 2000-14, apply to bus duct with exposed bar conductors. The failure

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mechanisms identified in Information Notices 89-64 and 98-36 are not applicable to Millstone 2

because Unit 2 does not have bus ducts with exposed conductors.

Some of the potential causes of the bus bar failure addressed in Information Notice 2000-14

could apply to other-types of bus duct designs. These mechanisms include currents approaching

bus capacity and torque relaxation of connecting bolts. The Millstone non-segregated phase bus

ducts are designed to carry the output of the start-up'auxiliary transformers. The worst-case

loading on any portion of the cable bus duct for either unit is approximately 67 percent. No

description of the connections from bus to equipment was provided. Therefore, currents

approaching bus capacity and torque relaxation have not been ruled out as an aging

mechanisms for the non-segregated phase bus ducts at Millstone.

In its response dated February 8, 2005, the applicant indicated that a review conducted by an

independent consultant concluded that the aging of the specific Noryl compound used in at

Millstone would not degrade over the period of extended operation. The same response also

indicated that the bolted connections were joined using Beliville spring washers that would

further reduce the probability of torque relaxation from thermal cycling.

The staff agrees that the LRA, together with the supplement information in the responses dated

December 3,2004, and February 8, 2005, adequately identified the aging effects associated

with metal-enclosed (non-segregated) bus ducts.

The staff concluded that the applicant adequately addressed the aging effects for Norylinsulated, non-segregated bus duct in Unit 3 and adequately documented its conclusion that no

separate aging management program for non-segregated bus duct was required.

3.6.2.3.4 Switchyard Bus

Summary of Technical Information in the Aoolication. Section 2.1.3.7.5, Station Blackout,

includes the following components within the scope of license renewal for offsite power

restoration following a SBO: (1) the 345 kV bus to the RSST and the associated disconnect

switch, (2) the overhead conductors from the CL&P switchyard, (3) the Switchyard North Bus

(Unit 2), the Switchyard South Bus (Unit 3), and their associated disconnect switches, and (4)

the support structures associated with these in-scope components. Section 2.5.3, Bus Ducts,

describes the high-voltage switchyard bus as'tubular conductors.

Table 2.5.3-1, Bus Duct, includes a description forbus duct and identifies the intended function

for the bus duct (conductors) to conduct electricity. The table does not differentiate between the

high-voltage switchyard bus duct and medium-voltage bus duct.

Table 3.6.2-3, Electrical Components - Bus Duct - Aging Management Evaluation, identifies the

high-voltage bus duct and switchyard bus components as metal conductors with porcelain

insulators. The table indicates that there are no components with aging effects that require

management and no aging management programs were identified.

Staff Evaluation. The high-voltage switchyard buses are composed of bare aluminum tubes. The

staff agrees that there is no aging effect that requires management. Based on the tube materials

used in the high-voltage switchyard buses, the staff also agrees that no aging management

program for high-voltage switchyard bus was required.

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I.7The staff concludes that the applicant adequately addressed the aging effects for highvoltage switchyard bus and concludes that no separate aging management program for highvoltage switchyard bus was required.

Conclusion. On the basis of its review, the staff finds that the applicant appropriately evaluated

AMR results involving material, environment, aging effect requiring management, and AMP

combinations that are not evaluated in the GALL Report or not addressed in the GALL Report.

The staff finds that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the period

of extended operation, as required by 10 CFR 54.21 (a)(3).

On the basis of its review of the AMR results, the staff concludes that actions have been

identified and have been or will be taken to manage the effects of aging during the period of

extended operation on the functionality of structures and components subject to an AMR such

that there is reasonable assurance that the activities authorized by a renewed license will

continue to be conducted in accordance with the CLB for the period of extended operation, as

required by 10 CFR 54.29(a).

3.6.3 Conclusion

On the basis of its review, the staff concludes that the applicant has demonstrated that the aging

effects associated with the electrical and instrumentation and controls systems components will

be adequately managed so that the intended functions will be maintained consistent with the

CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

The staff also reviewed the applicable FSAR supplement program summaries and concludes

that they adequately describe the AMPs credited for managing aging of the electrical and

instrumentation and controls systems, as required by 10 CFR 54.21(d).

3.7 Conclusion for Aging Management

The staff has reviewed the information in LRA Section 3, "Aging Management Review Results,"

and Appendix B, "Aging Management Programs and Activities." On' the basis of its review of the

AMR results and AMPs, the staff concludes that the applicant has demonstrated that the aging - effects will be adequately managed so that the intended functions will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff

also reviewed the applicable FSAR supplement program summaries and concludes that the

FSAR supplement adequately describes the AMPs credited for managing aging as required by

10 CFR 54.21 (d).

With regard to these matters, the NRC staff has concluded that there is reasonable assurance

that the activities authorized by the renewed license will continue to be conducted in accordance

with the current licensing basis, and that any changes made to the MPS current licerising basis

in order to comply with 10 CFR 54.21 (a)(3) are in accord with the Atomic Energy Act of 1954, as

amended, and NRC regulations.

3-580
SECTION 4

TIME-LIMITED AGING ANALYSES

4.1 Identification of Time-Limited Aging Analyses

This section addresses the identification of time-limited aging analyses (TLAAs). Dominion

Nuclear Connecticut, Inc. (Dominion or the applicant) discusses the TLAAs in Sections 4.2

through 4.7 of its license renewal applications (LRAs). Sections 4.2 through 4.8 of this safety

evaluation report (SER) document the review of the TLAAs conducted by the staff of the U.S.

Nuclear Regulatory Commission (NRC or the staff).

The TLAAs are certain plant-specific safety analyses that are based on an explicitly assumed

40-year plant life. Pursuant to Title 10, Section 54;21 (c)(1), of the Code of Federal Regulations

[10 CFR 54.21 (c)(1)], the applicant for license renewal must provide a list of TLAAs, as defined

in 10 CFR 54.3.

In addition, pursuant to 10 CFR 54.21 (c)(2), an applicant must provide a list of plant-specific

exemptions granted under 10 CFR 50.12 that are based on TLAAs. For' any such exemptions,

the applicant must provide an evaluation that justifies the continuation of the exemptions for the

period of extended operation.

4.1.1 Summary of Technical Information In the Application

To identify the TLAAs, the applicant evaluated calculations for the Millstone Power Station

(MPS) against the six criteria specified in 10 CFR 54.3. The applicant indicated that it had

identified the calculations that met the six criteria by searching the current licensing basis (CLB).

The CLB includes the final safety analysis report (FSAR), engineering calculations, technical.

reports, engineering work requests, licensing correspondence, and applicable vendor reports.

The applicant listed the following applicable TLAAs in LRA Table 4.1-1, 'Time-Limited Aging

Analysis Categories:"

* reactor vessel neutron embrittlement

* metal fatigue

* environmental qualification (EQ) of electrical equipment

* concrete containment tendon prestress

* containment liner plate and penetrations

* crane load cycle limit

* reactor coolant pump flywheel

* reactor coolant pump Code Case N-481

* leak before break

Pursuant to 10 CFR 54.21 (c)(2), the applicant stated that it did not identify any exemptions

granted under 10 CFR 50.12 that were based on a TLAA, as defined in 10 CFR 54.3.

4-1
4.1.2 Staff Evaluation

In Section 4.1 of each LRA, the applicant identified the TLAAs applicable to MPS. The staff

reviewed the information to determine whether the applicant had provided adequate information

to meet the requirements of 10 CFR 54.21 (c)(1) and 10 CFR 54.21 (c)(2).

As defined in 10 CFR 54.3, TLAAs are analyses that meet the following six criteria:

(1) involve systems, structures, and components within the scope of license renewal, as

delineated in 10 CFR 54.4(a)

(2) consider the effects of aging

(3) involve time-limited assumptions defined by the current operating term (40 years)

(4) are determined to be relevant by the applicant in making a safety determination

(5) involve conclusions, or provide the basis for conclusions, related to the capability of the

system, structure, and component to perform its intended functions, as delineated in

10 CFR 54.4(b)

(6) are contained or incorporated by reference in the current licensing basis

The applicant provided a list of common TLAAs from NUREG-1800, "Standard Review Plan for

Review of License Renewal Applications for Nuclear Power Plant," dated July 2001. The

applicant listed those TLAAs that are applicable to MPS in each Table 4.1-2 of the LRAs, which

provided a comparison to TLAAs from NUREG-1800.

As required by 10 CFR 54.21 (c)(2), an applicant must provide a list of all exemptions granted

under 10 CFR 50.12 that are based on a TLAA and evaluated and justified for continuation

through the period of extended operation. In its LRA, the applicant stated that each active

exemption was reviewed to determine whether the exemption was based on a TLAA. The

applicant did not identify any TLAA-based exemptions. On the basis of the information provided

by the applicant with regard to the process used to identify TLAA-based exemptions, as well as

the results of the applicant's search, the staff finds that the applicant identified no TLAA-based

exemptions that are justified for continuation through the period of extended operation, in

accordance with 10 CFR 54.21 (c)(2).

4.1.3 Conclusion

On the basis of its review, the staff concludes that the applicant has provided an acceptable list

of TLAAs, as required by 10 CFR 54.21 (c)(1), and has confirmed that no exemptions to

10 CFR 50.12 have been granted on the basis of a TLAA, as required by 10 CFR 54.21(c)(2).

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4-2
4.2 Reactor Vessel Neutron Embrittlement

The NRC uses two parameters as a measure of the fracture toughness of ferritic steels (i.e.,

either carbon steel or low-alloy steel) used to fabricate the reactor vessels (RVs) in light-water

reactors:

* a reference temperature for nil-ductility transition (RTNDT), which is a measure of the

material's ability to resist cleavage failure,' and

* the upper-shelf energy (USE) value for the rnaterial, which is a measure of the material's

ability to resist ductile failure.

During plant service, neutron radiation reduces the fracture toughness of the RV materials by

causing the RTNDT to increase and the USE to decrease. The base' metal materials and weld

materials in the region of the vessel immediately adjacent to the reactor core (i.e., in the' beltline

region of the RV) are most susceptible to these effects' because they are exposed to neutron

fluences in excess of 1.0 x 10" neutrons/cm2 (1.0'x 1017 n/cm2

(1. ... 10 )(E>1.0 MeV).

The staff performs the following three reviews to ensure that the beltline materials in PWR RVs

have adequate fracture toughness during normal and off-normal operating conditions:

(1) assessments for pressurized thermal shock '(PTS), as required by 10 CFR 50.61

(2) assessments for calculating the pressure-temperature (P-T) limit curves for heatups,

cooldowns, and pressure tests of the RVs, as required by 10 CFR Part 50, Appendix G,

Section IV.A.2

(3) assessments for USE, as required by 10 CFR Part 50, Appendix G, Section IV.A.1.

Since these assessments are related to the amount of neutron radiation 'absorbed over time,

they must be treated as TLAAs for the materials in'the.beltline of the RV. The staff evaluates

these TLAAs in the following subsections to SER Chapter 4.2:

* SER Section 4.2.2 - TLAA for USE (the analogous LRA section is LRA Section 4.2.2)

* SER Section 4.2.3 - TLAA for PTS (the analogous LRA section is LRA Section 4.2.3)

* SER Section 4.2.4 - TLAA for calculation of the P-T limit curves (the analogous LRA

section is LRA Section 4.2.4) "

Section 4.2.1 of the LRA for Millstone Units 2 and 3rdes6ribes the neutronfluence calculations to'.

support the above TLAAs for USE, PTS, and P-T limit curves. Therefore, the neudron'fluence

calculations will be evaluated in Section 4.2.1 of this SER in order to support the evaluation of

the above TLAAs. - -

4.2.1 Neutron Fluence

4.2.1.1 Summary of Technical Information In the Application

In Section 4.2.1 of the LRA for Millstone Unit 2, the applicant summarizes the analytical

evaluation of the neutron fluence calculations fdr'the period of extended operation. In this

4-3
section of the LRA, the applicant provided the following assessment for the neutron fluence

calculations and the fluence values (Table 4.2-1 and 4.2-2 of the LRA) through the period of

extended operation:

The analytical calculation of the space and energy dependent neutron flux in the

reactor vessel is performed with the two-dimensional discrete ordinates transport

code DOTIV, (Reference 4.8-42). The calculations employ an angular quadrature

of 48 sectors (S8), a third-order LeGendre [Legendre] polynomial scattering

approximation (P3), the BUGLE cross section set (Reference 4.8-43) with 47

neutron energy groups, and a fixed distribution source corresponding to the time

weighted average power distribution for the applicable irradiation period.

The transition temperature shift for the base metal employing the neutron flux

calculated using this methodology is in good agreement with the predicted value

employing Regulatory Guide 1.99, Revision 2 guidance. The transition

temperature shift for the weld metal employing the 4 neutron flux calculated using

this methodology is conservative compared with the predicted shift using

Regulatory Guide 1.99, Revision 2 guidance (Reference 4.8-44).

For Millstone Unit 3, the description of the neutron fluence evaluation in the LRA is limited to the

statement that the neutron fluence is calculated using a discrete-ordinates transport method

consistent with draft NRC Regulatory Guide (DG)-1 053. The neutron fluence values were

provided in Tables 4.2-1 and 4.2-2 of the Millstone Unit 3 LRA.

In LRA Section 4.2.1 for Unit 2, the applicant stated that the analytical calculation of the space

and energy-dependent neutron flux in the reactor vessel is performed with the two-dimensional

discrete ordinates transport code DOT-IV. The calculations employ an angular quadrature of 48

sectors (S8), a third-order LeGendre polynomial scattering approximation (P3), the BUGLE

cross-section set with 47 neutron energy gr6ups, and'a fixed distribution source corresponding

to the time-weighted average power distribution for the applicable irradiation period.

4.2.1.2 Staff Evaluation

The staff issued RG.1.190, "Calculational and Dosimetry Methods for Determining Pressure

Vessel Neutron Fluence," in March 2001. The RG provides guidance regarding acceptable

methods for the benchmarking of RV fluence methodologies based on the requirements of

General Design Criterion (GDC) 31 and, in part, on GDC 14 and 30. Therefore, the staff based

its review of the RV fluence evaluation for Millstone Units 2 and 3 on the adherence of the

calculational method to the guidance in RG 1.190.

To evaluate the fluence values for Millstone Unit 2, the staff requested the applicant to specify

whether the fluence calculations met the guidance in RG 1.190. In addition, several other

requests for additional information were asked, such as the derivation of the neutron sources,

what assumption were made for core loading, and the consideration of the effect of plutonium in

the calculations. These requests were identified by the staff as RAI 4.2.1-1 (a) through (e).

In response to RAI 4.2.1-1 (a) through (e), the applicant stated that the methodology used for the

calculation of the vessel neutron fluence to the end of the renewed license (54 effective fullI

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power years (EFPYs) of operation) does not fully conform to the guidance in RG 1.190. In

addition, the transport cross sections are derived from the ENDF/B-IV file, which is not allowed

in RG 1.1 90. Although the methodology does not meet the guidance of RG 1.190, the applicant

stated that the fluence calculation is sufficiently documented to determine the impact of neutron

fluence on radiation embrittlement.

In Table 4.2-2 of the submittal, the applicant indicated that for RTpTs the'critical element is the

Lower Shell Plate C-506-1 with an estimated RTpTs equal to 190.5°F at 54 EFPYs and a peak

inside surface fluence of 4.05x10'9 n/cm2 '(E > 1.0 MeV). The staff has concluded from

experience that fluence values calculated using methods not in compliance with the guidance in

RG 1.190 could differ by as much as 40 percent from fluence values calculated by methods' that

adhere to RG 1.190 guidance. Assuming that the above fluence value is underestimated by 40

percent, the value would be 5.67x1019 n/cm2. Using equation 2 in RG 1.99 with the chemistry

factor (CF) of 110 *F and an initial RTNDT value of 7.0 0F from Table 4.2-2, the RTpTs is equal to

197.9 "F. This value is well within the screening criterion of 270 "F of 10 CFR 50.61. Therefore,

the staff concludes that the material properties are well within the safety limits. Similar results

are obtained with the USE and are discussed in Section 4.2.2.2 of this SER.

However, the applicant is planning to submit pressure-temperature (P-T) limit curves for 54

EFPYs at least two years prior to the period of extended operation. -In response to RAI 4.2.1-3,

the applicant stated that the FSAR supplement will be modified to reflect revised vessel fluence

methodologies that follow the guidance in RG 1.190. (See Section 4.2.1.3 of this SER.) This

resolves RAI 4.2.1-1 (a) through (e).

In addition, the staff requested the applicant to confirm that the neutron fluence methodology

used for Millstone Unit 3 adheres to the guidance of RG 1.190. Several other requests for

additional information were made by the staff to evaluate the fluence calculations, such as what

approximations were used, what assumptions regarding fuel loading were made, and what

consideration of plutonium was made in the fluence calculations. These requests'were identified

by the staff as RAI 4.2.1-2(a) through (e).

In its response to RAI 4.2.1-2(a) through (e), the applicant stated that the vessel fluence for Unit

3 was calculated using a discrete ordinates method using DOORS 3.1, "RSICC Computer Code

Collection CCC-650, 'DOORS 3.1, Two- and Three-Dimensional Discrete Ordinates

Neutron/Photon Transport Code System," dated August, 1996, which followed the guidance in

RG 1.190. Specifically, the transport cross sections were derived from BUGLE-96, RSICC Data

Library Collection DLC-185 "BUGLE-96 Coupled 47 Neutron, 20 Gamma-Ray Group Cross

Section Library Derived from ENDF/B-VI for LWR Shielding and Pressure Vessel Dosimetry

Applications," dated March, 1996, which is based on the ENDF/B-VI file recommended in RG

1.190. Similarly, the anisotropic scattering was'approximated with a P3 LeGendre expansion

polynomial and the angular discretization' with a'S8 order of angular quadrature. Energy- and

space-dependent power distributions were derived from cycle-specific calculations. Projections

to 54 EFPYs were based on the low leakage loadings for cycles four to six. The bumup

dependent effects of the neutron source account for the spatial variation of the neutron source

as well as the spectral effects introduced by the derivative fissioning isotopes of Pu-239 and Pu241. In summary, the staff finds that the proposed value of the vessel fluence in Table 4.2-1 for

54 EFPYs for E > 1.0 MeV is acceptable because the methodology follows the guidance in RG

1.190. This resolves RAI 4.2.1-2(a) through (e).

4-5.
42.1.3 FSARSupplement

The staff recognizes that the applicant calculated fluence values to 54 EFPYs (i.e., the end of

the period of extended operation) in each LRA Section 4.2.1, which contains the evaluations of

TLAAs. However, the applicant did not specifically state that the calculations for neutron fluence

values are TLAAs. The staff considers that the calculations for neutron fluence values meet the

requirements of 10 CFR 54.3, in that they use time-limiting assumptions. Also, the operating

assumptions in these calculations could change, as for example, with the introduction of new

fuel, new material properties, etc. In such an instance, 10 'CFR 50.61 and other regulations

require recalculation of the fluence and reevaluation of the material properties. Pursuant to

10 CFR Part 54.21(d), the Millstone FSAR supplement for a facility LRA must contain a

summary description for each AMP and TLAA proposed for management of the effects of aging.

The staff determined that Appendix A of the LRAs (the FSAR supplement) did not include a

corresponding FSAR supplement summary description for the TLAA in Section 4.2.1, uNeutron

Fluence," of the LRAs. Therefore it is necessary to capture this information in the FSAR

supplements. Pursuant to 10 CFR 54.21 (d), the staff requested that a corresponding FSAR

supplement summary description for each LRA Section 4.2.1 be included in the FSAR

supplements. This request was identified by the staff as RAI 4.2.1-3.

In response to RAI 4.2.1-3, in a letter dated December 3, 2004, the applicant updated Section

A3.1.3 of the Millstone Units 2 and 3, FSAR supplements to incorporate a summary description

on the current methodology of calculating neutron fluence and the use of RG 1.190 in

developing fluence values for the period of extended operation. This includes a statement in the

proposed FSAR supplements that when developing the Millstone Units 2 and 3 P-T limit curves

for the period of extended operation, fluence values will be developed in accordance with RG

1.190 requirements. Millstone Unit 3 uses a fluence methodology in accordance with DG-1053,

and the specific methodology applied to the calculation followed the guidance of RG 1.190.

DG-1 053 is the draft version of RG 1.190 and provides similar conservatism when calculating

the reactor vessel fluence values. Therefore for Millstone Unit 3, the fluence values meet the

guidelines of RG 1.190 and are acceptable to the staff.

However, Millstone Unit 2 does not use a fluence methodology in accordance with RG 1.190,

and therefore the methodology may be less conservative. The staff has concluded from

experience that fluence values calculated using methods not in compliance with the guidance in

RG 1.190 could differ by as much as 40 percent from fluence values calculated by methods that

adhere to RG 1.190 guidance. Since the applicant will be providing new P-T limit curves for

54 EFPY, the staff requested that the applicant commit to submit the reactor vessel fluence

calculations using a methodology in accordance with RG 1.190,- which will also support the P-T

limit curve submittal, to the NRC along with the 54 EFPY P-T limit curves in 2005. The applicant

needed to add to its list of commitments the submittal of a re-evaluation of the USE and RTP. to

update the licensing basis to be consistent with the fluence values used in the P-T limit curves.

In response to supplemental RAI 4.2.1-3 in a letter dated February 8, 2005, the applicant

committed to update the USE, RTpTs and P-T limit curves based on fluence values developed in

accordance with RG 1.190 requirements, through the period of extended operation. The

applicant will provide these updated evaluations at least two years prior to the period of

extended operation and is documented as Commitment Item 37 in the Millstone Unit 2 FSAR

supplement, Appendix A, Table A6.0-1. This resolves RAI 4.2.1-3.

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4.2.1.4 Conclusion

The staff has reviewed the applicant's evaluation on neutron fluence, as summarized in Section

4.2.1 of the LRAs, and has determined that the applicant's calculation of the neutron fluence

values, as projected through the expiration of the periods of extended operation for the Millstone

units, is acceptable to use in the evaluation of the'TLAAs for the USE, PTS, and P-T limit

curves. The neutron fluence values are acceptable because Millstone Unit 3 meets the

guidelines of RG 1.190, and because the staff added a conservative factor to the Millstone Unit 2

methodology based on past evaluations. The staff also concludes that the Millstone FSAR

supplements contain appropriate summary descriptio'ns of the TLAA on neutron fluence for the

period of extended operation, as required by 10 CFR 54.21(d).

4.2.2 Upper-Shelf Energy

4.2.21 Summary of Technical Information In the Application

In each LRA Section 4.2.2, the applicant summarizes the requirements of 10 CFR Part 50,

Appendix G, for end-of-license USE values and identifies that the calculation of the USE values

is a TLAA for the applications. In this section of the LRAs, the applicant provided the following

assessment for the USE values through the expiration of the periods of extended operation for

the units:

Upper shelf energy values have been calculated per 10 CFR 50.61 using the

most recent reactor pressure vessel material property information, including the

best estimate copper and nickel values for each of the beltline plates and welds,'

unirradiated drop weight'and Charpy data,'and reactor vessel surveillance

capsule examination results. This information, developed for 32 effective full

power years (EFPY), was used in part to respond to NRC Generic Letter 92-01

Revision 1, Supplement 1 which requested that addressees identify, collect and

report any new information pertaining to the analysis of reactor vessel structural'

integrity. Thirty-two EFPY would be reached at the end of the currently licensed

40-year period of operation assuming aiTapacity factor of 80%. Similarly, 54

EFPY would be reached at the end of the period of extended operation (60 years)

assuming a capacity factor of 90%. The calculated upper shelf energy values

were then used in conjunction with NRC RG 1.99, Revision'2 requirements to

predict those material changes due to irradiation.

The 54 EFPY upper shelf energy values for the reactor pressure vessel beltline

materials were calculated using Figure 2 in RG 1.99,' Revision 2, Position 1.

Capsule data has been considered and determined to result in values less

conservative than obtained from using RG 1.99, Revision 2, Position 1. As shown

in Table 4.2-1, acceptable upper shelf ene'rgy values have' been'demonstrated for

reactor pressure vessel beltline'plate and weld materials through the 54 EFPY

period of extended operation. Since all reactor pressure vessel beltline plate and

weld materials have upper shelf energy values greater than 50 ft-lbs, no

equivalent margins analysis was performed.' '

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Acceptable upper shelf energy values have been calculated in accordance with

Regulatory Guide 1.99, Revision 2 to the end of the period of extended operation

per 10 CFR 54.21 (c)(1)(ii). Calculated upper shelf energy values for the most

limiting reactor pressure vessel beltline plate and weld materials remain greater

than 50 ft-lbs.

In each LRA Section 4.2.2, the applicant described the screening criteria that establish limits on

how far the USE values for a reactor pressure vessel (RPV) material' may be allowed to drop due

to neutron radiation exposure. The applicant stated that regulation 10 CFR Part 50, Appendix G.

Section IV.A.1 requires the initial USE value to be greater than 75 ft-lb in the unirradiated

condition and for the value to be greater than 50 ft-lb in the fully irradiated condition as

determined by Charpy V-notch specimen testing throughout the licensed life of the plant. USE

values of less than 50 ft-lb may be acceptable to the NRC if it can be demonstrated that these

lower values will provide margins of safety against brittle fracture equivalent to those required by

ASME Section Xl, Appendix G.

USE values have been calculated per 10 CFR 50.61 using the most recent RPV material

property information, including the best estimate copper and nickel values for each of the beltline

plates and welds, unirradiated drop weight and Charpy data, and reactor vessel surveillance

capsule examination results.

This information, developed for 32 effective full power years (EFPY), was used in part to

respond to NRC Generic Letter (GL) 92-01 Revision 1, Supplement 1, which requested that

addressees identify, collect, and report any new information pertaining to the analysis of reactor

vessel structural integrity. Thirty-two EFPY would be reached at the end of the currently licensed

40-year period of operation, assuming a capacity factor of 80 percent. Similarly, 54 EFPY would

be reached at the end of the period of extended operation (60 years) assuming a capacity factor

of 90 percent. The calculated USE values were then used in conjunction with NRC RG 1.99,

Revision 2 requirements to predict those material changes due to irradiation.

The 54 EFPY USE values for the RPV beltline materials were calculated using Figure 2 in RG

1.99, Revision 2, Position 1. Capsule data have been considered and determined to result in

values less conservative than obtained from using RG 1.99, Revision 2, Position 1. As shown in

Table 4.2-1, acceptable USE values have been demonstrated for RPV beltline plate and weld

materials through the 54 EFPY period of extended operation. Since all RPV beltline plate and

weld materials have USE values greater than 50 ft-lb, no equivalent margins analysis was

performed.

A comparison of copper content and initial upper-shelf energy for Millstone Unit 2 beltline

materials listed in Table 4.2-1 to the values listed in NRC reactor vessel integrity database

(RVID2 version 2.0.5 updated June 9, 1999) indicates slight differences for selected materials.

The most significant discrepancies are relative to initial USE for weld seam 9-203, fabricated

with weld wire heats 90136 and 10137, and Linde 0091 flux. The value of USE documented in

Table 4.2-1 is 2.2 ft-lb greater than the value provided by the RVID2. The Table 4.2-1 value is

derived from surveillance weld material representative of this weld (same consumables) and

constitutes a mean of all data at 100 percent shear. Similarly, the weld seams 2-203A/B/C and

3-203A/B/C fabricated with weld wire heat A8746 and Linde flux 124 have a USE 10.5 ft-lb

greater than the RVID2 value. The Table 4.2-1 value is based on a generic value for Linde 124

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welds provided in Combustion Engineering Owners Group report CEN-622-A. This report has

been reviewed and approved by the NRC.

A comparison of copper content, nickel content,. and initial USE for Millstone Unit 2 beltline

materials listed in Table 4.2-1 to the values submitted to the NRC in response to GL 92-01

indicate only differences for weld 9-203, heat 90136. initial USE for weld 9-203, heat 90136

listed in Table 4.2-1 is 21.2 ft-lb greater than the GL 92-01 value. These updated values are

based on surveillance data that were identified subsequent to the issuance of the Millstone

licensee response to GL 92-01.

The applicant states that acceptable USE values have been calculated in accordance with RG

1.99, Revision 2 to the end of the period of extended operation per 10 CFR 54.21 (c)(1)(ii).

Calculated USE values for the most limiting RPV beltline plate and weld materials remain greater

than 50 ft-lb.

4.2.2.2 Staff Evaluation

Section IV.A.1 to 10 CFR Part 50, Appendix G, provides requirements for demonstrating that

reactor vessels (RV) in U.S. pressurized water reactor (PWR) light-water reactor facilities will

have ductility throughout their service lives. The Rule requires RV beltline materials to have USE

values equal to or above 75 ft-lb initially, and equal to or above 50 ft-lb throughout the life of the

vessel. RG 1.99, Revision 2 provides an expanded discussion regarding the calculations of USE

values and describes two methods for determining USE values for RV beltline materials,

depending on whether or not a given RV beltline material is represented in the plant's Reactor

Vessel Material Surveillance Program.,

The applicant provided its USE assessments for the RV beltline materials of Millstone Units 2

and 3 in Table 4.2-1 of the applications. However, for Millstone Unit 2, one weld (upper/

intermediate shell circumferential weld 8-203, heats 10137 and 33A277) was not included in the

USE evaluation. This weld is in the NRC staffs RVID. In RAI 4.2.2-1, the staff requested the

applicant to. provide a USE evaluation for this weld, or provide justification for not including it in

the evaluation.

In response to RAI 4.2.2-1, in a letter dated December 3, 2004, the applicant provided a USE

evaluation for the Millstone Unit 2 RPV upper/intermediate shell circumferential weld 8-203. The

evaluation provided a USE value for weld 8-203 of 72.2 ft-lb for heat 33A277 and 77.3 ft-lb for

heat 10137. The staff confirmed these values and determined that they are conservative and

that a USE value of 72.2 ft-lb for weld 8-203 is acceptable. However, the applicant stated in its

response that this weld does not meet the definition of beltline region'in Appendix G to

10 CFR Part 50, because it is above the active core. However, 10 CFR Part 50 Appendix G,

paragraph IL.F also defines the beltline region to include adjacent regions of the RV that are

predicted to experience sufficient neutron radiation damage to be considered in the selection of

the most limited material with regard to radiation damage. In addition, 10 CFR Part 50, Appendix

H specifies that material exposed to peak neutron fluence that exceeds 10'7 n/cm2 must be

monitored by a surveillance program complying with ASTM E 185. Also; RG 1.99,' Revision 2,

sets forth criteria for evaluating the USE and PTS for material exceeding this fluence value. The

applicant determined the inner surface fluence value for this weld to be 2.43x1 018 n/cm2.

Therefore, the applicant was requested to update the FSAR supplement for Millstone Unit 2 by

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adding weld 8-203 and the corresponding USE value to Table 1 of the Millstone Unit 2 FSAR

supplement

In response to supplemental RAI 4.2.2-1 in a letter dated February 8, 2005, the applicant

provided the USE evaluation for the Millstone Unit 2 reactor pressure vessel upper/intermediate

circumferential weld (weld No. 8-203) manufactured from which used weld wire heats 33A277

and 10137. The evaluation is documented in Table 3.1.1-3-1 to Dominion's supplemental

response to RAI 3.1.1-3. The applicant calculated the USE values for these materials in

accordance with 10 CFR Part 50, Appendix G through the extended period of operation. The

results of the USE evaluations on these expanded beltline regions had no effect on the limiting

material. The staff confirmed that the limiting material previously identified in the LRA is still

bounding. Therefore, since the applicant evaluated all materials that were determined to exceed

the 1 .Oxl 0'7 n/cm2 (E>1.0 MeV) boundary and identified that the limiting material specified in the

LRA is still bounding, the staff finds this response acceptable. In addition, the level of detail

described in the FSAR supplement follows the recommendations of NUREG-1800, Table 4.2-1.

This resolves RAI 4.2.2-1.

The USE assessments were based on the 1/4t neutron fluence values listed in LRAs Table

4.2-1. These neutron fluence values are based on the projected values at the end of the periods

of extended operation (i.e., 54 EFPY). Section 4.2.3.1 of this SER sets forth the staff's

evaluation of the fluence methodologies.

The staff performed independent calculations of the USE values for the RV beltline materials

through the period of extended operation for Millstone Units 2 and 3. The staff applied the 1/4t

neutron fluence values listed in LRA Table 4.2-1 for the Millstone Unit 3 RV as its basis for its

independent calculations since the fluence methodologies were consistent with RG 1.190. For

Millstone Unit 2, the staff used both the 1/4t neutron fluence values listed in the LRA Table 4.2-1

and fluence values that were increased by a factor of 40 percent to estimate the variance in the

fluence methodologies providing a conservative estimate of the fluence values that would bound

the values expected if a RG 1.190-compliant analysis was performed. The staff applied the

calculational methods in RG 1.99, Revision 2, as its methodology for'performing the independent

USE calculations. RG 1.99, Revision 2 requires that all available plant-specific surveillance data

be used in determining the USE. The staff's calculations included the use of the surveillance

capsule values provide in the RVID. RVID is a database maintained by the staff. It contains a

summary of all of the relevant materials data submitted by all applicants in their evaluations of -

reactor vessel integrity. While performing the independent USE calculations, the staff calculated

a USE value for the lower shell plate C-506-1 that differed from the value specified in Table 4.2-

1 of the application for 54 EFPY. This difference can be attributed to the applicant performing

the evaluation consistent with Position 1.1 of RG 1.99, Revision 2, for material that has no

surveillance data available. In RAI 4.2.2-2, the staff requested the applicant to provide the'

calculated USE value for the lower shell plate C-506-1, heat C5667-1 using all available

surveillance data as required by RG 1.99, Revision 2.

In response to RAI 4.2.2-2, in a letter dated December 3, 2004, the applicant provided a USE

evaluation for the Millstone Unit 2 RPV lower shell plate C-506-1, heat C5667-1, using all

available surveillance data as recommended by RG 1.99, Revision 2. The evaluation provided a

USE value for shell plate C-506-1, heat C5667-1, of 54.5 ft-lb, using surveillance capsule W-97.

The staff confirmed this value and determined that it is conservative-and acceptable. However;

the applicant did not include this revised USE value of 54.5 ft-lb in the Millstone Unit 2 FSAR

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supplement. Therefore, the applicant was requested to update the FSAR supplement for

Millstone Unit 2 by revising the USE value from 76.1 ft-lb to 54.5 ft-lb for shell plate C-506-1,

heat C5667-1, in Table 1 of Section A3.1.1 to the Millstone Unit 2 FSAR supplement.

In response to supplemental RAI 4.2.2-2 in a letter dated February 8, 2005, the applicant stated

that the calculated USE value for Millstone Unit 2 lower shell plate C-506-1, heat number C5667-

1 is 65.3 ft-lbs, not the 54.5 ft-lbs originally identified in Table 1 of Dominion's December 3,

2004, response to RAI 4.2.2-2. The 65.3 ft-lbs value represents the reactor pressure vessel

lower shell plate C-506-1, heat number C5667-1 USE value developed using all available

surveillance data. The USE value of 54.5 ft-lbs previously presented in the RAI response is more

conservative than the actual USE value of 65.3 ft-lbs. The staff notes that the value of 54.5 ft-lbs

was deemed conservative based on the staff's calculated value of 61 ft-lbs. In either case, the

USE value is above the 50 ft-lbs required by 10 CFR Part 50, Appendix G. This also confirms

that this subcomponent of the reactor pressure vessel is not the limiting material. The limiting

material is discussed below. In addition, the level of detail described in the FSAR supplement

follows the recommendations of NUREG-1800, Table 4.2-1. This resolves RAI 4.2.2-2.

In Section 4.2.2 of the Millstone Unit 2 LRA, the applicant stated that there is a difference

between the unirradiated USE value presented in Table 4.2-1 of the application and RVID values',

for the mid-circumferential weld (weld 9-203) fabricated with weld wire heats 90136 and 10137

with Linde 0091 flux. The value of the unirradiated (initial) USE documented in Table 4.2-1 is 2.2

ft-lb greater than the value provided in RVID. The applicant stated that the value in the LRA was

based on the mean of all surveillance weld material representative of this weld (same

consumables) at 100 percent shear. In RAI 4.2.2-3, the staff requested the applicant to provide

all relevant surveillance weld data for each of the weld wire heats (90136 and 10137) which were

used to calculate the mean unirradiated USE values for each weld wire heat. -

In response to RAI 4.2.2-3, in a letter dated December 3, 2004, the applicant provided all'

relevant surveillance weld data for each of the weld wire heats (90136 and 10137) which were

used to calculate the mean unirradiated USE values for each weld wire heat. Based on the

surveillance data results submitted by the applicant, the staff confirmed that the mean

unirradiated (initial) USE value for weld 9-203 is 132.2 ft-lb and is acceptable in determining the

54 EFPY USE value for this weld. This resolves RAI 4.2.2-3.

Table 4.2-1 of the Millstone Unit 2 application also stated that the unirradiated USE values for

the lower and intermediate axial welds 2-203A; B, and C; and weld 3-203A (heat A8746) using

Linde 124 flux was based on the generic value provided in Combustion Engineering Owners

Group report CEN-622-A. This report was approved by the NRC in a letter dated September 25,

1996. Previously, the unirradiated USE value was 73 ft-lb, based on Charpy impact data tested

at 10 OF. The staff considers this value of 73 ft-lb to be in the transition range of the material, not

the upper-shelf range; therefore, the actual unirradiated USE value would be much higher, and

the use of the generic value of 83.5 ft-lb based on data in the upper-shelf region is appropriate

for the unirradiated USE value for these welds using Linde 124 flux.

The staff determined that at Millstone Unit 2 the lower and intermediate shell axial welds 2-203A,

B, and C; and weld 3-203A (heat A8746) are the limiting beltline materials for USE. The staff

calculated a USE value of 55.2 ft-lb for these welds at 54 EFPY using the LRAs fluence value.

This USE value is in agreement with the 54 EFPY USE value calculated by the applicant for

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these welds (54.3 ft-lb). In addition, the staff applied a 40 percent increase in fluence to estimate

values that would bound fluence values performed in accordance with the guidelines of RG

1.190, yielding an estimated fluence of 4.606x1019 n/cm2 for the limiting lower shell axial welds

2-203A, B, and C; and weld 3-203A. Using this estimated fluence value, the staff calculated a

limiting USE value of 52.9 ft-lb. Both of these values meet the acceptance criterion in

10 CFR Part 50, Appendix G, for maintaining the USE values of the RV beltline materials above

50 ft-lb throughout the period of extended operation. The staff confirmed that the updates to the

surveillance data (copper content and unirradiated USE values) for Millstone Unit 2, as reported

in Section 4.2.2 of the application, did not change the limiting USE material for Millstone Unit 2.

The updates include the unirradiated USE values for welds 9-203; 2-203A, B, C; and 3-203A,

discussed in the previous paragraphs, which were found acceptable. In addition, the chemistry

values for weld 9-203 had different copper contents than what was previously submitted in

response to GL 92-01. However, these best-estimate chemistry values were previously approved

by SER dated August 30, 1999, and incorporated into RVID; and are therefore acceptable.

The staff determined that, at Millstone Unit 3, lower shell plate B9820-2 (heat D1 242-2) is the

limiting beltline material for USE. The staff calculated a USE value of 59.0 ft-lb for this plate at

54 EFPY. This value is in agreement with the 54 EFPY USE value calculated by the'applicant for

this material (58.8 ft-lb). Both of these values meet the acceptance criterion in 10 CFR Part 50,

Appendix G, for maintaining the USE values of the RV beltline materials above 50 ft-lb

throughout the period of extended operation.

Based on these assessments, the staff has determined that the RVs at Millstone Units 2 and 3

will maintain an acceptable level of USE throughout the units' periods of extended operation;

The staff therefore concludes that the applicant's TLAA for USE, as' given in Section 4.2.2 of the

LRAs, is in compliance with requirements of 10 CFR Part 50, Appendix G.

42.2.3 FSAR Supplement

Section A.3.1.1 of each LRA includes the following FSAR supplement summary description for

the TLAA on USE:

10 CFR 50, Appendix G contains screening criteria that establish limits on how far

the upper shelf energy values for a reactor pressure vessel material may be

allowed to drop due to neutron irradiation exposure. The regulation requires the

initial upper shelf energy value to be greater than 75 ft-lbs in the unirradiated

condition and for the value to be greater than 50 ft-lbs in the fully irradiated

condition as determined by Charpy V-notch specimen testing throughout the

licensed life of the plant. Upper shelf energy values of less than 50 ft-lbs may be

acceptable to the NRC if it can be demonstrated that these lower values will

provide margins of safety against brittle fracture equivalent to those required by

ASME Section Xl, Appendix G.

Acceptable upper shelf energy values have been calculated in accordance with

Regulatory Guide 1.99, Revision 2 to the end of the period of extended operation.

Calculated upper shelf energy values for the most limiting reactor pressure vessel

beltline plate and weld materials remain greater than 50 ft-lbs.

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The applicant's FSAR supplement summary description does not specify how the RV beltline

materials at Millstone Units 2 and 3 will be in compliance with the applicable requirements in

10 CFR Part 50, Appendix G, as projected through the period of extended operation.

Specifically, the applicant has not stated which materials are limiting; nor has it stated the

materials' USE values. In RAI 4.2.2-4, the staff requested the applicant to provide this

information in the FSAR supplements.

In its response to RAI 4.2.2-4, dated December 3, 2004, the applicant provided information,

including the beltline USE values, that will be incorporated into Section A3.1.1 of the Millstone

Units 2 and 3 FSAR supplements concerning the limiting beltline material and stated that they

are in compliance with the applicable requirements in 10 CFR Part 50, Appendix G. The staff

has reviewed this information and requests the following supplemental information. The

applicant stated that the USE values for the limiting beltline materials have been calculated in

accordance with 10 CFR 50.61 and demonstrate acceptable USE values through the period of

extended operation. The staff requested that the applicant confirm that the USE analysis was

performed in accordance with 10 CFR Part 50, Appendix G, and not 10 CFR 50.61 (which is

used for PTS evaluation). The confirmed information should be incorporated into the FSAR

supplements accordingly.

In its response to supplemental RAI 4.2.2-4, dated February 8, 2005, the applicant confirmed

that the Millstone Units 2 and 3 USE evaluations were performed using 10 CFR Part 50,

Appendix G, and not 10 CFR 50.61. The applicant had erroneously cited 10 CFR 50.61 in its

response to RAI 4.2.2-4. The applicant also stated that the applicable FSAR supplements

reference 10 CFR Part 50, Appendix G. This resolves RAI 4.2.2-4.

The applicant's Millstone FSAR supplements summary descriptions are consistent with the staff

analysis for the TLAA on USE in Section 4.2.2.2 of this SER. The FSAR supplements summary

descriptions summarize the applicable USE requirements that must be met to ensure continued

compliance with 10 CFR Part 50, Appendix G,.and demonstrates why the RV beltline materials

at Millstone Units 2 and 3 will be in compliance with the applicable requirements in

10 CFR Part 50, Appendix G' as projected through the extended periods of operation for the

units. The staff therefore concludes that FSAR supplements summary description for the TLAA

on USE is acceptable.

4.2.2.4 Conclusion

The staff has reviewed the applicant's TLAA on USE, as summarized in each LRA Section 4.2.2,

and has determined that the RV beltline materials at Millstone Units 2 and 3 will continue to

comply with the staff's USE requirements of 10 CFR Part 50, Appendix G, throughout the

extended periods of operation for the Millstone' units. The staff therefore concludes that the

applicant's TLAA for USE is in compliance with the staffs acceptance criterion for TLAAs in

10 CFR 54.21 (c)(1)(ii) and that the safety margins established and maintained during the current

operating term will be maintained during the periods of extended operation as required by

10 CFR 54.21 (c)(1). The staff also concludes that the FSAR supplements contain an appropriate

summary description of the TLAA on USE for the period of extended operation, as required by

10 CFR 54.21 (d).

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4.2.3 Pressurized Thermal Shock

4.2.3.1 Summary of Technical Information in the Application

In each LRA Section 4.2.3, the applicant summarizes the PTS requirements of 10 CFR 50.61 and identifies that the calculation of the adjusted reference temperature values for PTS (i.e., RTpTs values) is a TLAA for the applications. In this section of the LRAs, the applicant provided the following assessment for the RTpTs values for the RV beltline materials at Millstone through the period of extended operation for the units:

Reactor pressure vessel beltline fluence is one of the factors used in determining the margin of acceptability of the reactor pressure vessel to pressurized thermal shock as a result of radiation embrittlement. The margin is the difference between the maximum nil ductility reference temperature in the limiting beltline material (RTpTs) and the screening criteria established in accordance with

10 CFR 50.61(b)(2). The screening criteria for the limiting reactor vessel materials

are 270 OF for beltline plates, forging and axial weld materials, and 300 0F for beltline circumferential weld materials. The 54 EFPY RTpTs values for the reactor

pressure vessel beltline materials are summarized within Table 4.2-2. The RTPTs screening criteria have been met in all cases.

Acceptable RTpTs values have been calculated in accordance with Regulatory Guide 1.99, Revision 2 requirements to the end of the period of extended

operation per 10 CFR 54.21 (c)(1)(ii).

RPV beltline fluence is. one of the factors used in determining the margin of acceptability of the RPV to pressurized thermal shock as a result of radiation embrittlement. The margin is the difference between the maximum nil ductility reference temperature in the limiting beltline material (RTpTs ) and the screening criteria established in accordance with 10 CFR 50.61 (b)(2). The screening criteria for the limiting reactor vessel materials are 270 0F for beltline plates, forgings, and axial weld materials; and 300 °F for beltline circumferential weld materials.

The LRAs contain the applicant's description of the methodology it utilized in calculating RTpTS values. The applicant stated that the methodology is also consistent with RG 1.99, Revision 2 requirements. The 54 EFPY RTpTs values for the RPV beltline materials are summarized within LRAs Table 4.2-2. The RTpTs screening criteria have been met in all cases.

A comparison of copper content, nickel content, and initial RTNDT Millstone Unit 2 beltline materials listed in LRA Table 4.2-2 to the values listed in NRC reactor vessel integrity database (RVID2 version 2.0.5, updated June 9, 1999) identified no differences.

A comparison of copper content, nickel content, initial RTNDT for Millstone Unit 2 beltline materials listed in LRA Table 4.2-2 to the values submitted to the NRC in response to GL 92-01 indicate slight differences for selected materials. The applicant stated that the most significant discrepancies are relative to initial RTNDT for shell plate C-506-2 and shell plate C-506-3. For shell plate C-506-2 the initial RTNDT listed in Table 4.2-2 is 15.4°F lower than the GL 92-01 value. Similarly, for shell plate C-506-3 the initial RTNDT listed in Table 4.2-2 is 32.0 °F lower than the GL 92-01 value. These updated values are based on original qualification data that were identified subsequent to the issuance of the Millstone response to GL 92-01.

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Acceptable RTm values have been calculated in'accordance with RG 1.99, Revision 2

requirements to the end of the period of extended operation pursuant to 10 CFR 54.21 (c)(1)(ii).

4.2.3.2 Staff Evaluation - '

The staff's requirements for ensuring that the RV beltline materials of pressurized light-water

reactors will have adequate protection against the consequences of PTS events are set forth in ''

10 CFR 50.61. The Rule' requires applicants to calculate 'an adjusted reference temperature

value for PTS (i.e., RTpTs values) for each base metal and weld material located in the beltline

region of their RVs. The Rule sets a screening limit of 270 0F for RTpTs values that are calculated

for plates, forging, and axial weld materials; and a screening limit of 300 'F for RT., values thatare calculated for circumferential weld materials; The Rule also provides an expanded:'

discussion regarding how the calculations of RTprs values should be performed and describes '

two methods for determining RTpTs values for RV beltline materials, depending'on whether or rnot

a given RV beltline material is represented in the plant's reactor vessel material surveillanice'

program. - - '

For the RV beltline materials of Millstone Units 2 and 3, the applicant provided its RTpTs value

assessments in Table 4.2-2 of the applications. However, for Millstone Unit 2, one weld

(upper/intermediate shell circumferential weld 8-203, heats 10137 and 33A277) was not included

in the RT~s-evaluation: In RAI 4.2.2-1, the staff requested the-applicant to provide a RTm8

evaluation for this weld, or provide justification for not including it in the evaluation. The

applicant's RTns value assessments for the Millstone units are based on fluence values listed in

LRAs Table 4.2-2 for the inner surface location of the RVs, as projected to the end of the

extended periods of operation (i.e., 54 EFPY).

In response to RAI 4.2.2-1, in a letter dated December 3, 2004, the applicant provided an RTpTS'

evaluation for the Millstone Unit 2 reactor pressure vessel upper/intermediate circumferential

weld 8-203 which used weld wire heats 33A277 an'd 10137. The evaluation provided a RTpTs

value for weld 8-203 of 97.9 OF for heat 33A277!and 73.9 0F for heat 10137. The staff confirmed

these values and determined that they are consiervative and therefore acceptable. However, the

applicant also stated in its response, that this weld does not meet the 10 CFR Part 50, Appendix

G definition of beltline region, since it is above the active core. However, 10 CFR Part 50, '

Appendix G, paragraph II.F, also defines the beltline region to include adjacent regions of the

reactor vessel that are predicted to'experience sufficient neutron radiation damage to be

considered in the selection of the most limited nmatendal with' regards to radiation damage. In

addition, 10 CFR Part 50, Appendix H specifies 'that material exposed to peak neutron fluence

that exceed 1017 nlcm2 must be monitored by a surveillance program complying with ASTM

E185. RG 1.99, Revision 2 sets forth criteria for evaluating the USE and RTis8 for material

exceeding this fluence value. The applicant determined that the inner surface fluence value for

this weld to be 2.43 xl 018 n/cm2. Therefore,'the a'pplicant was requested to update the FSAR

supplement for Millstone Unit 2 by adding weld 8-203 and the corresponding RTpTs value to

Table 1 of the FSAR supplement for Millstone Unit 2.

In response to supplemental RAI 4.2.2-1 in a letter dated February 8, 2005, the applicant

provided the PTS evaluation for the Millstone UrWit 2 reactor pressure vessel upper/intermediate

shell circumferential weld (weld No. 8-203) manufactured from weld wire heats '33A277 and

10137. The evaluation is documented in Table 3.1.1-3-2 to Dominion's supplemental response

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to RAI 3.1.1-3. The applicant calculated the PTS values for these materials in accordance with

10 CFR 50.61 through the extended period of operation. The results of the PTS evaluations on

these expanded beltline regions had no effect on the limiting material. The staff confirmed that

the limiting material previously identified in the LRA is still bounding. Therefore, since the

applicant performed the evaluations of all materials that were determined to exceed the 1.Ox1 017

n/cm2 (E>1.0 MeV) boundary and identified that the limiting material specified in the LRA is still

bounding, the staff finds this response acceptable. In addition, the level of detail described in the

FSAR supplement follows the recommendations of NUREG-1800, Table 4.2-1. This resolves

RAI 4.2.2-1.

To confirm the validity of the applicant's limiting 54 EFPY RTpTs value for the Millstone Unit 2 RV,

the staff performed independent calculations of the RTpTs values through the period of extended

operation. For Millstone Unit 2, the staff used both the inside diameter neutron fluence values

listed in LRA Table 4.2-1 and fluence values that were increased by a factor of 40 percent to

estimate the variance in the fluence methodologies providing a conservative estimate of the

fluence values that would bound the values expected if a RG 1.190-compliant analysis was

performed. The staff determined that for Millstone Unit 2, lower shell plate C-506-1 (heat C5667-

1) is the limiting RV beltline material for PTS. The staff calculated an RTPTSvalue of 190.5 0 F for

this material at 54 EFPY (using the LRA fluence value), which is in agreement with the

applicant's calculation. Applying the 40 percent increase in fluence to estimate values that would

bound fluence values performed with the guidelines of RG 1.190 yields an estimated fluence of

5.67x1019 n/cm2 for the limiting lower shell plate C-506-1 (heat C5667-1). Using this estimated

fluence value, the staff calculated a limiting RTp. value of 197.9 'F. Both of these values meet

the screening criteria of 270 F. The staff also notes that the copper content, nickel content, and

the initial RTNOT values listed in Table 4.2-2 of the LRA are consistent with the values in RVID.

Therefore, the staff concludes that the Millstone Unit 2 RV can meet the requirements of

10 CFR 50.61 through the period of extended operation for the unit.

To confirm the validity of the applicant's limiting 54 EFPY RT 3 value for the Millstone Unit 3 RV,

the staff performed independent calculations of the RTpTs values through the period of extended

operation. The staff determined that at Millstone Unit 3, intermediate shell plate B9805-1 (heat

C4039-2) is the limiting beltline material for PTS. The staff calculated an RTPTs value of 134.7 0F

for this plate material at 54 EFPY. This value is in agreement with the limiting material and RTpTs

value reported by the applicant. The staff also notes that the copper content, nickel content, and

the initial RTNDT values listed in Table 4.2-2 of the LRA are consistent with the values in RVID.

Therefore, the staff concludes that the Millstone Unit 3 RV can meet the requirements of

10 CFR 50.61 through the period of extended operation for the unit.

4.2.3.3 FSAR Supplement

Each LRA Section A.3.1.2 includes the following FSAR supplement summary description for the

TLAA on PTS:

Reactor pressure vessel beltline fluence is one of the factors used to determine

the margin to reactor pressure vessel pressurized thermal shock as a result of

radiation embrittlement. The margin is the difference between the maximum nil

ductility reference temperature in the limiting beltline material (RTP,) and the

screening criteria established in accordance with 10 CFR 50.61 (b)(2). The

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screening criteria for the limiting reactor vessel materials are 270 0F for beltline

plates, forging and axial weld materials, and 300 0F for beltline circumferential

weld materials.

Acceptable RTpTs values have been calculated in accordance with Regulatory Guide

1.99, Revision 2, requirements to the end of the period of extended operation.

The applicant's FSAR supplement summary description does not specify how the RV beltline

materials at Millstone Units 2 and 3 will be in compliance with the applicable requirements in

10 CFR 50.61, as projected through the periods of extended operation. Specifically, the

applicant has not stated which materials are limiting, and their corresponding RTp. values to

demonstrate that the applicable requirements were met. In RAI 4.2.3-1, the staff requested that

the applicant provide this information in the FSAR supplements.

In its response to RAI 4.2.3-1, dated December.3, 2004, the applicant provided information that

will be incorporated into Section A3.1.2 of the Millstone Units 2 and 3 FSAR supplements

concerning the limiting beltline material and further stated that they are in compliance with the

applicable requirements of 10 CFR Part 50.61. The staff reviewed this information and

requested additional supplemental information. The applicant stated that the RTpTs values for the

limiting beltline materials have been calculated in accordance with RG 1.99, Revision 2 through

the period of extended operation and demonstrate acceptable RTpTs values through the period of

extended operation. The applicant needed to confirm that the RTpTs analysis was performed in

accordance with 10 CFR 50.61. The confirmed information needed to be incorporated into the

FSAR supplements accordingly.

In its response to supplemental RAI 4.2.3-1. dated February 8, 2005, the applicant confirmed

that the Millstone Units 2 and 3 PTS evaluations were developed in accordance with 10 CFR

50.61, and not RG 1.99, Revision 2. The applicant had erroneously cited RG 1.99, Revision 2 in

its response to RAI 4.2.3-1. The applicant also stated that the applicable FSAR supplements

reference 10 CFR 50.61. This resolves RAI 4.2.3-1.

The applicant's FSAR supplements summary description is consistent with the staff analysis for

the TLAA on PTS in Section 4.2.3.2 of this SER. The FSAR supplements summary descriptions

summarize the applicable PTS requirements that must be met to ensure continued compliance

with 10 CFR 50.61 and discuss why the RV beltline materials at Millstone Units 2 and 3 are in

compliance with the applicable requirements of 10 CFR 50.61, as projected through the periods

of extended operation for the units. The staff therefore concludes that FSAR supplement

summary description for the TLAA on PTS is acceptable.

4.2.3.4 Conclusion

The staff has reviewed the applicant's TLAA on PTS, as summarized in Section 4.2.3 of the LRA

and has determined that the RV beltline materials at Millstone Units 2 and 3.will continue to

comply with the staffs requirements for PTS in 10,CFR 50.61 throughout the periods of

extended periods of operation for the Millstone units.-The staff therefore concludes that the

applicant's TLAA for PTS is in compliance with the staffs acceptance criterion for TLAAs in

10 CFR 54.21 (c)(1 )(ii) and that the safety margins established and maintained during the current

operating term can be maintained during the periods of extended operation as required by

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10 CFR 54.21 (c)(1). The staff also concludes that the FSAR supplement contains an appropriate

summary description of the TLAA on PTS for the period of extended operation, as required by

10 CFR 54.21(d).

4.2.4 Pressure-Temperature (P-T) Limits

4.2.4.1 Summary of Technical Information in the Application

In Section 4.2.4 of the LRAs, the applicant concluded that the P-T limits for Millstone Units 2 and

3 met the definition in 10 CFR 54.4 for TLAAs. The applicant concluded that the P-T limits for

the Millstone units were TLAAs that needed to be assessed against the acceptance criteria of

10 CFR 54.21 (c)(1). The applicant provided the following assessment for the TLAA on the P-T

limits:

10 CFR Part 50, Appendix G requires that heatup and cooldown of the reactor

pressure vessel be accomplished within established pressure-temperature limits.

These limits identify the maximum allowable pressure as a function of reactor

coolant temperature. As the pressure vessel becomes irradiated and its fracture

toughness is reduced, the allowable pressure at low temperatures is reduced.

Therefore, in order to heatup and cooldown, the reactor coolant temperature and

pressure must be maintained within the limits of Appendix G as defined by the

reactor pressure vessel fluence.

In accordance with 10 CFR 50, Appendix G, updated pressure-temperature limits

for the period of extended operation will be developed and implemented prior to

the period of extended operation.

Consistent with 10 CFR 54.21 (c)(1)(iii), acceptable pressure-temperature limits

will be developed and implemented in accordance with 10 CFR 50, Appendix G

prior to the period of extended operation.

The 10 CFR Part 50, Appendix G requires that heatup and cooldown of the reactor pressure

vessel be accomplished within established P-T limits. These limits identify the maximum

allowable pressure as a function of reactor coolant temperature.

As the pressure vessel becomes irradiated and its fracture toughness is reduced, the allowable

pressure at low temperatures is reduced. Therefore, in'order to heat up and cool down, the

reactor coolant temperature and pressure must be maintained within the limits of

10 CFR Part 50, Appendix G as defined by the reactor pressure vessel fluence.

Heat up and cool down limit curves have been calculated using the adjusted RTNDT

corresponding to the limiting beltline material of the reactor pressure vessel for the current

period of licensed operation. Current low temperature overpressure protection (LTOP) system

heat up and cool down limit curves were approved in license amendment 218. Current cold -

overpressure protection system (COPS) heat up and cool down limit curves were approved for

Millstone Unit 3 in license amendment 197.

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The applicant stated that, consistent with .10 CFR 54.21 (c)(1)(iii), acceptable P-T limits will be

developed and implemented in accordance with 10 CFR 50, Appendix G prior to the period of

extended operation.

4.2.4.2 Staff Evaluation

Paragraph IV.A.2 of 10 CFR Part 50, Appendix G, provides the requirements and criteria for

generating the P-T limits that are required for commercial U.S. light-water reactors. The

applicant plans to calculate vessel P-T limit curves for 60 years (54 EFPYs) and submit them to

the NRC for approval before the start of the period of extended operation. The LRA did not state

whether the fluence methodology would be in accordance with RG 1.190 when managing the PT limits, or where these P-T limit requirements will be documented. Therefore, in RAI 4.2.4-1,

the staff asked if the applicant will manage the P-T limits using approved fluence calculations in

conjunction with surveillance capsule results from the surveillance program. Also, the applicant

was requested to state if the technical specification would be updated upon calculating the P-T

limits for the period of extended operation. The applicant was asked to include this information in

the Millstone FSAR supplements to describe the management of the P-T limits.

In response to RAI 4.2.4-1, in a letter dated December 3, 2004, the applicant updated Section

A3.1.3 of the Millstone Units 2 and 3 FSAR supplements to incorporate a summary description

on the current methodology of calculating neutron fluence and the use of RG 1.190 in

developing fluence values for the P-T limit curves in the period of extended operation. This

includes a statement in the proposed Millstone FSAR supplements that when developing the

Millstone Units 2 and 3 P-T limit curves for the period of extended operation, fluence values will

be calculated in accordance with RG 1.190 recommendations. Millstone Unit 3 uses a fluence

methodology in accordance with DG-1053. This is the draft version of RG 1.190 and provides

similar conservatism when calculating the reactor vessel fluence values. However, Millstone Unit

2 does not use a fluence methodology in accordance with RG 1.190. In addition, the applicant is

planning to submit P-T limit curves for 54 EFPY to the NRC in 2005. Therefore, since the

applicant will be providing new P-T limit curves for 54 EFPY, the staff requests that the applicant

commit to submit the reactor vessel fluence calculations using a methodology in accordance

with RG 1.190, which will also support the P-T limit curve submittal, to the NRC along with the 54

EFPY P-T limit curves in 2005. The resolution of this issue is addressed in Section 4.2.1.3.

The staff finds the applicant's plan to manage the P-T limits acceptable because the change in

the P-T limits will be submitted to the NRC forapproval before the start of the period of extended

operation and implemented via the license amendment process (i.e., modifications of technical

specifications), thereby meeting the requirements of 10 CFR 50.60 and Appendix G to

10 CFR 50.

4.2.4.3 FSAR Supplement

Each Section A3.1.3 of the LRAs includes the following FSAR supplement summary description

for the TLAA on the Millstone P-T limits:

Millstone Unit 2

Heatup and cooldown limit curves have been calculated using the adjusted RTNDT

corresponding to the limiting beltline material of the reactor pressure vessel for

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the current period of licensed operation. Current low temperature overpressure protection (LTOP) system heatup and cooldown limit curves were approved in

license amendment 218.

In accordance with 10 CFR 50, Appendix G, updated pressure-temperature limits

for the period of extended operation will be developed and implemented prior to

the period of extended operation. Low temperature overpressure protection

system enable temperature requirements will be updated to ensure that the

pressure-temperature limits will not be exceeded for postulated plant transients

during the period of extended operation.

Millstone Unit 3

Heatup and cooldown limit curves have been calculated using the adjusted RTNDT

corresponding to the limiting beltline material of the reactor pressure vessel for

the current period of licensed operation. Current cold overpressure protection

system (COPS) heatup and cooldown limit curves were approved in license

amendment 197.

In accordance with 10 CFR 50, Appendix G, updated pressure-temperature limits

for the period of extended operation will be developed and implemented prior to

the period of extended operation. Cold overpressure protection system enable

temperature requirements will be updated to ensure that the pressuretemperature limits will not be exceeded for postulated plant transients during the

period of extended operation.

On the basis of the staff's evaluation described above, the summary description for the reactor

coolant system TLAA for reactor vessel P-T limits described in the FSAR supplements provides

an adequate description of this TLAA, as required by 10 CFR 54.21.

4.2.4.4 Conclusion

On the basis of its review, the staff concludes that the applicant has demonstrated, pursuant to

10 CFR 54.21 (c)(1)(ii) and 10 CFR 54.21 (c)(1)(iii), that the applicant can generate the P-T limits

for the periods of extended operation for Millstone Units 2 and 3 in accordance with the technical

specifications process. The staff will evaluate the end-of-extended-operating-term P-T limit

curves for Millstone upon submittal by the applicant. The staff's review of the period-of- extended-operation P-T limit curves, when submitted, will ensure that the reactor coolant system for Millstone Units 2 and 3 will be operated in a manner that ensures the integrity of the reactor

coolant system during the period of extended operation and that the curves, when submitted, will

satisfy the requirements of 10 CFR 54.21 (c)(1)(ii) for the period of extended operation. Because

evaluation of P-T limit curves is performed when the limits are updated through the technical

specification process, they need not be evaluated now. The technical specification process

provides a process for managing P-T limits, in accordance with 10 CFR 54.21 (c)(1)(iii).

4.3 Metal Fatigue

A metal component subjected to cyclic loading at loads less than the static design load may fail

due to fatigue. Metal fatigue of components may have been evaluated based on an assumed

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number of transients or cycles for the current operating term. The validity of such metal fatigue

analysis is reviewed for the period of extended operation.

4.3A Unit 2 Metal Fatigue

4.3A.1 Summary of Technical Information In the Application

The applicant discussed the design of reactor coolant pressure boundary (RCPB) components in

Section 4.3.1 of the LRA. Components of the RCPB were designed to the ASME Boiler and

Pressure Vessel Code, Section III requirements for Class 1 components and the requirements

for ANSI 831.7 Class 1 piping components. Table 4.3.2 lists the transients and number of

transient cycles used in the design of ASME Class 1 components. Table 4.3.2 also lists the

estimated number of transient cycles for 60 years of plant operation. The applicant's estimate

indicates that the number of design cycles will remain bounding for the period of extended

operation. The applicant indicated that the significant design transients are tracked by a fatigue

monitoring program (FMP).

In addition to the design of Class 1 components using transient cycles listed in Table 4.3.2 of the

LRA, the applicant identified evaluations that were performed to address other specific issues.

These evaluations were performed for the surge line to address NRC Bulletin 88-11,

'Pressurizer Surge Line Thermal Stratification," and to address the potential for temperature

stratification and oscillations in unisolable sections of pipe in response to NRC Bulletin 88-08,

"Thermal Stresses in Piping Connected to Reactor Coolant Systems." The applicant indicated

that the evaluations remain valid for the period of extended operation.

The applicant discussed the evaluation of ASME Class 2 and 3, ANSI B31.7 Class 2 and 3, and

ANSI B31.1 components in Section 4.3.2 of the LRA. The codes and standards for ASME Class

2 and 3, ANSI B31.7 Class 2 and 3, and ANSI B31.1 components require that a stress-reduction

factor be applied to the allowable thermal bending stress range if the number of full-range cycles

exceeds 7,000. The applicant identified three piping systems within the scope of license renewal

that have been projected to exceed 7,000 full-temperature cycles during the period of extended

operation. The applicant evaluated these piping systems for the number of expected cycles and

found them acceptable for the period of extended operation in accordance with

10 CFR 54.21 (c)(1 )(ii).

The applicant discussed the evaluation of environmentally-assisted fatigue of RCPB components

in Section 4.3.3 of the LRA. The applicant provided the results of an evaluation of the

environmental effects on the components listed in NUREG/CR-6260, 'Application of

NUREG/CR-5999 Interim Fatigue Curves to Selected Nuclear Power Plant Components." The

applicant indicated that the environmental fatigue correlations in NUREG/CR-6583, 'Effects of

LWR Coolant Environments on Fatigue:Design Curves of Carbon and Low-Alloy Steels," and

NUREG/CR-5704, 'Effects of LWR Coolant Environments on Fatigue Design Curves of

Austenitic Stainless Steels," were used in the evaluations. The applicant's evaluation indicated

that all components had acceptable fatigue usage for the period of extended operation.

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4.3A.2 Staff Evaluation

As discussed previously, RCPB components were designed to the Class 1 requirements of the

ASME Code and the Class 1 requirements of ANSI B31.7. These requirements contain explicit criteria for the fatigue analysis of components. Consequently, the applicant identified the fatigue analysis of these components as TLAAs. The staff reviewed the applicant's evaluation of the

RCPB components for compliance with the provisions of 10 CFR 54.21 (c)(1).

The specific design criterion for fatigue analysis of RCPB components involves calculating the

cumulative usage factor (CUF). The fatigue damage in the component caused by each thermal.

or pressure transient depends on the magnitude of the stresses caused by the transient. The

CUF sums the fatigue damage resulting from each transient. The design criterion requires that

the CUF not exceed 1.0.

Table 4.3-2 of the LRA provides the current cycle counts and estimated cycle counts at 60 years of plant operation for transients used in the design of ASME Class 1 components. The staff

compared the list of monitored transients with those listed in Millstone FSAR Section 4.2.1. The

applicant monitors all of the normal; upset, and test transients listed in FSAR Section 4.2.1 with

the exception of loading/unloading and step-load change cycles. The applicant indicated that

these cycles are not counted because the transients produce insignificant fatigue usage contributions to any Class I component. In RAI 4.3.1-2, the staff requested that the applicant indicate whether these transients contributed to the cumulative usage factors for the vessel

inlet/outlet nozzles reported in Table 4.3-3 of the LRA. The staff also requested that the

applicant provide a summary of the load pairs that contribute to the fatigue usage of the vessel

inlet/outlet nozzles and the corresponding fatigue usage for each load pair.

The applicant's December 3, 2004, response indicated that the loading/unloading and step- change transients are significant contributors to the' design fatigue usage factors for the reactor

vessel inlet/outlet nozzles. Even though these transients are significant contributors to the

design CUF for these nozzles, the design CUFs are well below the allowable limit of 1.0. In

addition, the applicant indicated that the number of design cycles assumed for plant loading/unloading and step-change transients is considered conservative based on plant operation. As a consequence, these transients are not expected to cause significant fatigue

usage in the inlet/outlet nozzles for the period of extended operation. The staff agrees with the

applicant that it is not necessary to track these transients. On the basis of the information

provided by the applicant, the staff finds that the FMP tracks the significant design transients

listed in FSAR Section 4.2.1.

The applicant stated in the LRA that an FMP monitors the significant design transients at

Millstone Unit 2. The applicant also indicated that FatiguePro software is used to monitor

significant transient cycles, and that stress-based fatigue monitoring is used at locations of high- fatigue usage. In RAI 4.3.1-1, the staff requested that the applicant list the locations where

stress-based fatigue monitoring is used. The staff also requested that the applicant indicate the

length of time the FatiguePro software has been used and describe how the number of transient

cycles and fatigue usage was determined prior to installation of the FatiguePro software.

The applicant's December 3, 2004, response indicated that stress-based fatigue monitoring is

used at the pressurizer surge nozzle and the reactor coolant system (RCS) hot-leg surge nozzle.

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The applicant indicated that the FatiguePro software was used to analyze process computer

data from 1996 to the present to obtain the fatigue usage for each transient. The applicant also

indicated that operator logs were used to identify transient occurrences prior to 1996. The

fatigue usage associated with the transient occurrences prior to 1996 was estimated using the

fatigue usage calculated from the FatiguePro software for the transients that occurred after

1996. The staff finds that the applicant's method of estimating the fatigue usage prior to 1996

reasonable and acceptable.

As discussed in Section 4.3A.1 of this SER, the applicant performed additional evaluations in

response to NRC Bulletins 88-08 and 88-11. The applicant's evaluation for NRC Bulletin 88-08 is

summarized in a September 20, 1988, letter to the NRC. The applicant indicated that no piping

sections susceptible to the concerns identified in NRC Bulletin 88-08 were discovered at

Millstone Unit 2. Therefore, no additional evaluation was required by the applicant for the period

of extended operation.

The applicant indicated that an additional evaluation of the pressurizer surge line was performed

in response to NRC Bulletin 88-11. The applicant referenced the generic analysis in Combustion

Engineering Owners Group Report CEN-387-P as bounding for Millstone Unit 2. The staff found

that CEN-387-P provided an acceptable evaluation of the pressurizer surge line thermal concern

in its safety evaluation dated July 6, 1993. As discussed previously, the applicant monitors

critical surge line locations using FatiguePro stress-based software. Therefore, the applicant's

FMP will assure that the pressurizer surge line evaluation remains valid for the period of

extended operation.

Section 4.3.2 of the LRA describes the evaluation of non-Class 1 components. The LRA

indicates that three piping systems may exceed 7,000 full-temperature thermal cycles during the

period of extended operation. The LRA also indicates that these systems were evaluated using

appropriate stress-range reduction factors and found acceptable for the period of extended

operation. In RAI 4.3.2-1 the staff requested that the applicant describe the criteria used to

obtain the stress-range reduction factors.

The applicant's November 9, 2004, response indicated that ASME Section 1I1, Subsection NC3600 was used for the re-analysis of the hot-leg sample line, the pressurizer steam space

sample line and the common hot-leg/pressurizer steam space sample line. The applicant

provided the results of the analysis in Table 1 of the response. Table 1 shows the calculated

stresses are well within the allowable stresses-for the number of thermal expansion cycles

expected for the period of extended operation. On the basis of the information provided by the

applicant, the staff finds that the applicant has performed an acceptable evaluation of the

sample lines for the period of extended operation in accordance with the requirements of

10 CFR 54.21 (c)(1)(ii).

The applicant indicates that the FMP will continue during the period of extended operation and

will assure that design cycle limits are not exceeded. The applicant's FMP tracks transients and

cycles of RCS components that have explicit design transient cycles to assure that these

components remain within their design basis. Generic Safety.Issue 166 (GSI-166), Adequacy of

the Fatigue Life of Metal Components," raised concerns regarding the conservatism of the

fatigue curves used in the design of the RCS components. Although GSI-166 was resolved for

the current 40-year design life of operating components, the staff identified GSI-190, "Fatigue

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Evaluation of Metal Components for 60-year Plant Life," to address license renewal. The NRC

closed GSI-1 90 in December 26, 1999 (see Appendix D, Reference 17), concluding:

The results of the probabilistic analyses, along with the sensitivity studies performed, the

iterations with industry (NEI and EPRI), and the different approaches available to the

applicants to mange the effects of aging, lead to the conclusion that no generic

regulatory action is required, and that GSI-190 is closed. This conclusion is based

primarily on the negligible calculated increases in core damage frequency in going from

40- to 60-year lives. 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, the staff concludes that, consistent with existing requirements

in 10 CFR 54.21, applicants should address the effects of coolant environment on

component fatigue life as aging management programs are formulated in support of

license renewal.

The applicant indicated that it evaluated six component locations equivalent to those identified in

NUREG/CR-6260 for a newer vintage Combustion Engineering plant. The staff finds these

acceptable locations for evaluating environmental fatigue. The applicant provided the design and

environmental usage factors in Table 4.3-3 of the LRA. All of the design and environmental

usage factors are less than the allowable limit of 1.0.

The staff compared the applicant's calculated fatigue usage factors with those listed in

NUREG/CR-6260. The applicant's calculated fatigue usage factors were less than those listed in

NUREG/CR-6260 for a newer vintage Combustion Engineering plant. However, the applicant's

reported usage factors are more in line with the values listed in NUREG/CR-6260 for an older

vintage Combustion Engineering plant. The staff notes that the NUREGICR-6260 evaluation for,

the newer vintage Combustion Engineering plant was for San Onofre Unit 2 and 3 components.

The San Onofre units have a greater thermal power level than Millstone Unit 2, which may

account, in part, for the difference in calculated usage factor. As an additional check, the staff

compared the usage factors with the usage factors provided by the applicant during the license

renewal review of St. Lucie Units 1 and 2. St. Lucie Units 1 and 2 are Combustion Engineering

plants that have thermal power levels comparable to Millstone Unit 2. The Millstone Unit 2 usage

factors are comparable to the St. Lucie Units 1 and 2 usage factors, with the exception of the

surge line. As indicated previously, the applicant uses stress-based fatigue monitoring for the

surge line and, as a consequence, the staff expects lower usage factors for the surge line

components. On the basis of the comparison of the reported usage factors with previous

Combustion Engineering plants of comparable power level, the'staff concludes the usage factors

provided by the applicant in Table 4.3-3 are reasonable.

The staff noted that the applicant provided usage factors for the low-alloy charging and safety

injection nozzles, whereas NUREG/CR-6260 indicates the highest environmental usage factors

for the newer vintage Combustion Engineering plant occurred in the nozzle safe-ends. In a

December 3, 2004, response, the applicant indicated that the highest design CUFs for the safety

injection and charging nozzles occurred in the low-alloy nozzles. However, the applicant also

indicated that, using worst case environmental factors for stainless steel, the calculated CUF for

the charging nozzle safe-end is greater than the low-alloy nozzle. The applicant indicated that

the environmental usage factor for the safe-end is less than 1.0 using the projected number of

cycles for 60 years of plant operation. Since the applicant used projected cycles instead of

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design cycles to evaluate the charging nozzle safe-end, the applicant's FMP should incorporate

these cycles in the program. This was identified as Confirmatory Item 4.3-1.

In response to Confirmatory Item 4.3-1, in a letter dated April 1, 2005, the applicant stated that

cycle counting has been incorporated in the Millstone FMP and the projected cycles versus

design cycles are now used in the evaluation of the charging nozzle safe-ends, with acceptable

results through the period of extended operation. Based on this response, Confirmatory

Item 4.3-1 is closed.

The applicant evaluated the effects of the reactor water environment on the fatigue-sensitive

locations and concluded that the resulting fatigue usage will be acceptable for the period of

extended operation. The staff finds that the applicant has performed an acceptable evaluation of

the environmental fatigue usage of the fatigue-sensitive locations identified in NUREG/CR-6260.

The staff also finds that the applicant's FMP provides additional assurance that the fatigue

usage at these locations will not exceed the allowable limit of 1.0 during the period of extended

operation.

4.3A.3 FSAR Supplement

The applicant provided a Millstone FSAR supplement description of the FMP in Section A4.2 of

the LRA and a description of its TLAA evaluation for metal fatigue analysis in Section A3.2 of the

LRA. On the basis of its review of the FSAR supplement, the staff concludes the summary

description of the applicant's actions to address metal fatigue of components is adequate.

4.3A.4 Conclusion

The staff has reviewed the applicant's metal fatigue TLAA and concludes the applicant's actions

and commitments satisfy the requirements of 10 CFR 54.21(c)(1).

The staff has also reviewed the Millstone FSAR supplement for the TLAA and finds that the

FSAR supplement contains an adequate description of the metal fatigue of components to

satisfy 10 CFR 54.21(d).

4.3B Unit 3 Metal Fatigue

4.3B.1 Summary of Technical Information In the Application

The applicant discussed the design of reactor coolant pressure boundary (RCPB) components in

Section 4.3.1 of the Unit 3 LRA. Components of the RCPB were designed to the ASME Boiler

and Pressure Vessel Code, Section 1II, requirements for Class 1 components. Table 4.3.2 lists

the transients and number of transient cycles used in the design of ASME Class 1 components.

Table 4.3.2 also lists the estimated number of transient cycles for 60 years of plant operation.

The applicant's estimate indicates that the number of design cycles will remain bounding for the

period of extended operation. The applicant indicated that the significant design transients are

tracked by an FMP.

In addition to the design of Class 1 components using transient cycles listed in Table 4.3.2 of the

LRA, the applicant identified evaluations that were performed to address other specific issues.

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These evaluations were performed for the surge line to address NRC Bulletin 88-11,

"Pressurizer Surge Line Thermal Stratification," and to address the potential for temperature

stratification and oscillations in unisolable sections of pipe in response to NRC Bulletin 88-08,

"Thermal Stresses in Piping Connected to Reactor Coolant Systems." The applicant indicated

that the evaluations remain valid for the period of extended operation.

The applicant discussed the evaluation of ASME Class 2 and 3, ANSI B31.7 Class 2 and 3, and

ANSI B31.1 components in Section 4.3.2 of the LRA. The codes and standards for ASME Class

2 and 3, ANSI 31.7 Class 2 and 3, and ANSI 631.1 components require that a stress-reduction

factor be applied to the allowable thermal bending stress range if the number of full-range cycles

exceeds 7,000. The applicant indicated that piping systems within the scope of license renewal

are bounded by the 7,000 cycles. Therefore, the applicant concluded that the existing pipe

stress calculations are valid for the period of extended operation in accordance with

10 CFR 54.21 (c)(1)(ii).

The applicant discussed the evaluation of environmentally-assisted fatigue of RCPB components

in Section 4.3.3 of the LRA. The applicant provided the results of an evaluation of the

environmental effects on the components listed in NUREG/CR-6260, "Application of

NUREG/CR-5999 Interim Fatigue Curves to Selected Nuclear Power Plant Components." The

applicant indicated that the environmental fatigue correlations in NUREG/CR-6583, 'Effects of

LWR Coolant Environments on Fatigue Design Curves of Carbon and Low-Alloy Steels," and

NUREG/CR-5704, "Effects of LWR Coolant Environments on Fatigue Design Curves of

Austenitic Stainless Steels," were used in the evaluations. The applicant's evaluation indicated

that four of the six components are projected to exceed a usage factor of 1.0 during the period

of extended operation when environmental effects are considered. The applicant proposed to

manage these four components in accordance with the requirements of 10 CFR 54.21 (c)(1)(iii).

4.3B.2 Staff Evaluation

As discussed previously, components of the RCPB were designed to the Class 1 requirements

of the ASME Code; These requirements contain explicit criteria for the fatigue analysis of

components. Consequently, the applicant identified the fatigue analysis of these components as

TLAAs. The staff reviewed the applicant's evaluation of the RCPB components for compliance

with the provisions of 10 CFR 54.21 (c)(1).

The specific design criterion for fatigue analysis of RCPB components involves calculating the

cumulative usage factor (CUF). The fatigue damage in the component caused by each thermal

or pressure transient depends on the magnitude of the stresses caused by the transient. The

CUF sums the fatigue damage resulting from each transient. The design criterion requires that

the CUF not exceed 1.0. The applicant indicated that the FMP monitors the design transients at

Millstone Unit 3. Table 4.3.2 of the LRA provides the current cycle counts and estimated cycle

counts at 60 years of plant operation for transients used in the design of ASME Class 1

components. The LRA indicates that FatiguePro software is used to monitor the number of

significant transient cycles and that stress-based fatigue monitoring is used at locations of high

fatigue usage. In RAI 4.3.1-1, the staff requested that the applicant list the locations where

stress-based fatigue monitoring is used. The staff also requested that the applicant indicate the

length of time the FatiguePro software has been used and describe how the number of transient

cycles and fatigue usage was determined prior to installation of the FatiguePro software.

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The applicant's December 3, 2004, response indicated that stress-based fatigue monitoring is

used at the pressurizer surge nozzle, pressurizer heater penetration, RCS hot-leg surge line

nozzle, charging nozzle, safety injection nozzle, and RHR tee. The applicant indicated that the

FatiguePro software was'used to analyze process computer data from 1996 to the present to

obtain the fatigue usage for each transient. The applicant also indicated that operator logs were

used to identify transient occurrences prior to 1996. The fatigue usage'associated with the

transient occurrences prior to 1996 was estimated using the fatigue usage calculated from the

FatiguePro software for the transients that occurred after 1996. The staff finds that the

applicant's method of estimating the fatigue usage prior to 1996 reasonable and acceptable.

The applicant also provided a list of the transients monitored by the FMP. The staff compared

the list of monitored transients with those listed in Millstone FSAR Table 3.9N-1. The applicant

indicated that a number of the normal and upset transients listed in FSAR Table 3.9N-1 are not

monitored because they produce insignificant fatigue usage; These transients include steadystate fluctuations,"step-load decrease with steam dump, feedwater cycling, loop-out-of-service

startup and shutdown, loading and unloading between 0 and 15 percent full power, boron

concentration equalization, refueling,'reduced-temperature return to power, turbine roll test,'

inadvertent reactor coolant depressurization, and inadvertent startup of inactive loop. The staff

reviewed the transients listed in NUREG/CR-6260 for the fatigue evaluation of components in a

newer-vintage Westinghouse PWR. The staff notes that the transients listed above did not

contribute significantly to the fatigue usage of the components evaluated in NUREG/CR-6260.

Therefore, the staff agrees with the applicant that it is not necessary to track these transients.

On the basis of the information provided by the applicant, the staff finds that the FMP tracks the

significant design transients listed in FSAR Table 3.9N-1.

The Westinghouse Owners Group issued topical report WCAP-14577, Revision 1-A, "Aging

Management for Reactor'Internals," to address the aging management of the' reactor vessel

internals (RVIs). The staffs review of WCAP-1 4577, Revision 1-A identified a number of issues

that should be addressed on a plant-specific basis; Renewal Applicant Action Item 11 specified

in WCAP-14577, Revision 1-A indicates that the fatigue TLAA of the RVI should be addressed

on a plant-specific basis. In RAI 4.3.1-3, the staff requested that the applicant discuss the design

basis for the components listed in Table 3-3 of WCAP-14577, Revision 1-A and indicate how

fatigue of these components is managed.

The applicant's November 9, 2004, response indicated that the RPV stress report does not

address fatigue of the RVI. Therefore, the applicant concluded that there is no fatigue TLAA

associated with the RVI. Section 3.9N.5.2 of the FSAR discusses the design-loading'conditions

for the RVI. The FSAR indicates that the RVI were evaluated using the thermal transients listed

in FSAR Table 3.9N.1. Since these are the same transients used in the fatigue evaluation of

RCS components, the staff requested that the applicant confirm that there is no TLAA

associated with the RVI. In a followup response (e-mail dated December 20, 2004, from W.

Watson (MPS) to J. Eads (NRC)), the applicant confirmed that its internal searches and external

searches by Westinghouse did not identify a TLAA associated with the RVI. As discussed

previously, the applicant estimates that numbernof significant design transient cycles listed in

FSAR Table 3.9N-1 remain bounding for the period of extended operation. The staff concludes

that, even if a TLAA associated with the RVI exists, it would remain valid for the period of

extended operation in accordance with 10 CFR 54.21 (c)(1)(i).

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The Westinghouse Owners Group issued Topical Report WCAP-14575-A, Aging Management

Evaluation for Class 1 Piping and Associated Pressure Boundary Components," to addressaging management of the RCS piping. Tables 3-2 through 3-16 of WCAP-14575-A list RCS

components where fatigue is considered significant. The staff review of WCAP-1 4575-A

identified a number of issues that should be addressed on a plant-specific basis. Renewal

Applicant Action Item 8 indicates that the applicant should address components labeled l-M and --

I-RA in Tables 3-2 through 3-16 of WCAP-14575-A. The applicant's FMP monitors the significant

plant design transients listed in FSAR Table 3.9N-1 that were used in the design of RCPB

components. The staff finds that the applicant's FMP, which monitors the significant plant design

transients, adequately addresses Renewal Applicant Action Item 8.

The Westinghouse Owners Group has issued the generic Topical Report WCAP-14574-A to

address aging management of pressurizers. The staffs review of WCAP-14574-A identified a

number of issues that should be addressed on a plant-specific basis. Renewal Applicant Action

Item I requests the applicant to demonstrate that the pressurizer subcomponent CUFs remain

below 1.0 for the period of extended operation. Table 2-10 of WCAP-1 4574-A indicates that the

ASME Section III Class 1 fatigue CUF criterion could be exceeded at several pressurizer

subcomponent locations during the period of extended operation. WCAP-14574-A also identified

recent unanticipated transients that were not considered in the original ASME Section III Class I

fatigue analyses, including inflow/oufflow thermal transients. In RAI 4.3.1-4, the staff requested

the applicant to provide the following information:

* Confirm that the additional transients discussed in WCAP-14574-A, not considered in the

original design, have been addressed at Millstone Unit 3.

* Show the ASME Section III Class 1 CLB CUFs for the applicable subcomponents of the

Millstone pressurizers specified in Table 2-10 of WCAP-1 4574-A and the corresponding

CUFs for the period of extended operation.

* Discuss the impact of the environmental fatigue correlations provided in NUREGICR6583, "Effects of LWR Coolant Environments on Fatigue Design Curves of Carbon and

Low-Alloy Steels," and NUREG/CR-5704, "Effects of LWR Coolant Environments on

Fatigue Design Curves of Austenitic Stainless Steels," on the above results.

The applicant's December 3, 2004, response indicated that the pressurizer lower head and

surge-line nozzle were evaluated for the additional transients discussed in WCAP-14574-A. The

applicant provided the CUFs for the period of extended operation for the subcomponents listed

in Table 2-10 of WCAP-14574-A. All CUFs are less than 1.0 for the period of extended

operation.

The applicant also discussed the impact of the environmental fatigue correlations on the,

pressurizer subcomponents. The applicant committed to use the pressurizer surge-line nozzle as

a leading indicator to address environmental fatigue of the pressurizer subcomponents during

the period of extended operation. The staff finds that the pressurizer surge-line nozzle is an*

acceptable sample component location for assessing the impact of environmental fatigue on the

pressurizer components. The staff accepted this position during its review of other license

renewal applications for Westinghouse plants.

As discussed in Section 4.3B.1 of this SER, the applicant performed an additional evaluation of

the pressurizer surge line in response to NRC Bulletin 88-11. The applicant's evaluation

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indicated that the usage factor, including environmental effects, will remain less than 1.0 for 60

years of plant operation for the surge line and pressurizer lower head. The applicant further

indicated that stress-based fatigue monitoring of the surge line and lower pressurizer will be

used to ensure that the fatigue usage of these components remains less than 1.0. The staff

finds that the applicant has adequately addressed Renewal Applicant Action Item I of WCAP

14574-A, by evaluating the fatigue-sensitive subcomponents for insurge/outsurge transients,

considering the effects of the reactor water environment, and assuring that the thermal

transients that are significant contributors to the design fatigue usage of RCS components will

be monitored by the FMP.

The applicant indicated that components other than the RCBP were designed to ASME Class 2

and 3, ANSI B31.7 Class 2 and 3, and ANSI B31.1. The codes and standards for ASME Class 2

and 3, ANSI B31.7 Class 2 and 3, and ANSI B31.1 components require that a stress-reduction

factor be applied to the allowable thermal bending stress range if the number of full-range cycles

exceeds 7,000. The applicant indicated that piping systems within the scope of license renewal

are bounded by the 7,000 cycles for 60 years of plant operation. On the basis of the information

provided by the applicant, the staff finds that these analyses remain valid for the period of

extended operation in accordance with 54.21(c)(1)(i).

The applicant indicates that the FMP will continue during the period of extended operation and

will assure that the design cycle limits are not exceeded. The applicant's FMP tracks design

transients and cycles that are significant contributors to the fatigue usage of RCS components to

assure that these components remain within their design basis. GSI-166, "Adequacy of the

Fatigue Life of Metal Components," raised concerns regarding the conservatism of the fatigue

curves used in the design of the RCS components. Although GSI-166 was resolved for the

current 40-year design life of operating components,-the staff identified GSI-190, 'Fatigue

Evaluation of Metal Components for 60-year Plant Life," to address license renewal. The NRC

closed GSI-190 in December 25, 1999 (see Appendix D,, Reference 17), concluding:

The results of the probabilistic analyses, along with the sensitivity studies performed, the

iterations with industry (NEI and EPRI), and the different approaches available to the

applicants to mange the effects of aging, lead to the conclusion that no generic

regulatory action is required, and that GSI-190 is closed. This conclusion is based

primarily on the negligible calculated increases in core damage frequency in going from

40- to 60-year lives. 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, the staff concludes that; consistent with existing requirements

in 10 CFR 54.21, applicants should address the effects of coolant environment on

component fatigue life as aging management programs are formulated in support of

license renewal.

The applicant indicated that it evaluated the effects of the reactor water environment on the

fatigue life of six component locations. These six component locations are equivalent to the

component locations identified in NUREG/CR-6260 for a newer vintage Westinghouse plant.

The staff finds these acceptable locations for evaluating the effects of the reactor water

environment on the fatigue life of components.

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The results of the applicant's evaluation are presented in Table 4.3-3 of the LRA. The staff

compared the applicant's calculated fatigue usage factors with those listed in NUREG/CR-6260

for a newer vintage Westinghouse reactor. The applicant's calculated fatigue usage factors were

comparable to those listed in NUREG/CR-6260 with the exception of the surge line. The

applicant's design usage factor is much lower than the usage factor reported in NUREG/CR6260.

The applicant submitted the results of an evaluation of the surge line to the NRC in response to

NRC Bulletin 88-11 (reference 4.8-36 of the LRA). The submittal indicated that the maximum

calculated fatigue usage for the surge line at the RCS hot-leg nozzle was 0.434. This usage factor is more in line with the design value listed in NUREG/CR-6260. However, Table 4.3-3 of

the LRA indicates that the maximum design fatigue usage for the surge line is 0.0796. In RAI

4.3.1-2, the staff requested the applicant provide the basis for the usage factor report in Table

4.3-3 of the LRA.

The applicant's December 3, 2004, response indicated that the original CUF for the hot-leg nozzle, based on the number of design cycles, was 0.434. The applicant indicated that the value

listed in LRA Table 4.3-3 is the projected 60-year fatigue usage based on an evaluation using the data obtained from stress-based fatigue monitoring at Millstone Unit 3. The staff finds that

the applicant's response adequately clarifies the basis for the CUF reported in Table 4.3-3 of the

LRA.

The applicant's evaluation indicated that the calculated usage factors may exceed 1.0 for four

components: the surge line, the charging nozzle, the safety injection nozzle, and the RHR

piping. The applicant committed to manage the fatigue of these components with the FMP for

the period of extended operation in accordance with 10 CFR 54.21 (c)(1)(iii).

The applicant's FMP is discussed in the LRA. The applicant indicated that the program is

consistent with the aging management program (AMP) provided in NUREG-1801, Section X.M1, "Metal Fatigue of the Reactor Coolant Pressure Boundary." The AMP requires that the usage factor, including environmental effects, be maintained below 1.0 during the period of extended

operation. The program requires that corrective actions be taken to prevent the usage factor

from exceeding 1.0 during the period of extended operation. Acceptable corrective actions

include the following:

* further refinement of the fatigue analysis * repair of the affected locations

* replacement of the affected locations

The program also requires that additional component locations be reviewed if the usage factor is

projected to exceed 1.0. The staff finds that the applicant's FMP, which is consistent with

NUREG-1 801, provides an acceptable approach to address environmental fatigue of the surge line, the charging nozzle, the safety injection nozzle, and the RHR line for the period of extended

operation in accordance with 10 CFR 54.21 (c)(1).

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4.3B.3 FSAR Supplement

The applicant provided an FSAR supplement description of the FMP in Section A4.2 of the LRA

and a description of its TLAA'evaluation for metal fatigue analysis in Section A3.2 of the LRA.

On the basis of its review of the FSAR supplement, the staff concludes the summary description

of the applicant's actions to address metal fatigue of components is adequate.

4.36.4 Conclusion

The staff has reviewed the applicant's metal fatigue TLAA and concludes that the applicant's

actions and commitments satisfy the requirements of 10 CFR 54.21 (c)(1).

The staff has also reviewed the Millstone FSAR supplement for the TLAA and finds that the

FSAR supplement contains an adequate description of the metal fatigue of components to

satisfy 10 CFR 54.21 (d).

4.4 Environmental Qualification

The 10 CFR 50.49 environmental qualification (EQ) program has been identified as a TLAA for

the purposes of license renewal. The TLAA of EQ electrical components includes all long-lived,

passive and active electrical components and instrumentation and controls (I&C) components

that are important to safety and located in a harsh environment. The harsh environments of the

plant are those areas that are subjected to environmental effects by a loss-of-coolant accident

(LOCA) or a high-energy line break (HELB). The EQ equipment comprises safety-related and Qlist equipment; non-safety-related (NSR) equipment, the failure of which could prevent

satisfactory accomplishment of any safety-related function; and necessary post-accident

monitoring equipment.

As required by 10 CFR 54.21 (c)(1), the applicant must provide a list of EQ TLAAs in the LRA.

The applicant shall demonstrate that one of the following is true for each type of EQ equipment

(i) the analyses remain valid for the period of extended operation, (ii) the analyses have been

projected to the end of the period of extended operation, or (iii) the effect of aging on the

intended function(s) will be adequately managed for the period of extended operation.

4.4.1 Summary of Technical Information In the Application

The applicant provided in LRA Section 4.4, 'Environmental Qualification of Electric Equipment,"

the following information:

The electrical equipment qualification (EEQ) program is an integral part of the design,

construction, and operation of nuclear power generating stations. A description of this program

and a comparison of the program to the guidance of NUREG-1801 is provided in each LRA

Appendix B, Section B3.1, Electrical Equipment'Qualification.

Part 50 of 10 CFR requires that certain categories of systems, structures and components

(SSCs) be designed to accommodate the effects of both normal and accident environmental

conditions, and that design control measures be employed to ensure the adequacy of these

designs. Specific requirements pertaining to the environmental qualification (EQ) of these

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categories of electrical equipment are embodied in 10 CFR 50.49. The categories include safetyrelated (Class I E) electrical equipment, non-safety-related electrical equipment whose failure

could prevent the satisfactory accomplishment of a safety function by safety-related equipment,

and certain post-accident monitoring equipment. As required by 10 CFR 50.49, electrical

equipment not qualified for the current license term is to be refurbished, replaced, or have its

qualification extended prior to reaching the aging limits established in the evaluation. Aging

evaluations for electrical equipment that specify a qualification of 40 years or greater are

considered to represent a TLAA. Unit modifications, such as the installation or removal of

equipment, systems, or non-identical replacement of existing components, are evaluated to

ensure compliance with 10 CFR 50.49. Changes to system geometry (e.g., a piping addition or

rerouting), system and equipment operational changes, environmental changes (e.g., baseline

changes in temperature or radiation levels), and setpoint changes can affect the continued

acceptability of existing aging evaluations. These changes are evaluated through the design

control process. Electrical equipment aging evaluations contain sufficient conservatism to

account for most environmental changes occurring due to plant modifications and events. When

unexpectedly adverse or harsh conditions are identified (e.g., during normal operation or

maintenance activities) that could affect the qualification of a component, the affected

component is evaluated and appropriate corrective actions taken (e.g., addition of shielding,

equipment qualification zone changes, or changes to the qualification bases). Plant modification

and events that impacted temperature and radiation values that were used in the underlying

assumptions in the equipment qualification calculations have been reviewed in the Operating

Experience section of each LRA Appendix B. Section B3.1, Electrical Equipment Qualification.

4.4.2 Staff Evaluation

The staff reviewed the information in Section 4.4 and Appendix B, Section B3.1 of each LRA to

determine whether the applicant has demonstrated that the effects of aging on the intended

function(s) of electrical components will be adequately managed through the MPS EQ program,

together with other plant programs/processes, during the period of extended operation as

required by 10 CFR 54.21 (c)(1)(iii). Based on the applicant's statement that the EQ program is

consistent with Section X.E1 of the GALL report, the staff concludes that the MPS EQ program

will adequately manage the effects of aging on the intended function(s) of electrical components

for the period of extended operation in accordance with 10 CFR 54.21 (c)(1 )(iii).

Millstone uses the value of greater than 104 rads to define a harsh radiological environment for

equipment qualification purposes. The fact that certain areas of the B train auxiliary feedwater

pump room could exceed 105 rads means that this room must be considered to be a harsh

radiological environment for the purpose of equipment qualification, unless certain areas can be

expected to experience local doses of less than or equal to 104 rads. In that case, the room can

be considered to be a generally harsh environment, with locally mild environments. Whatever the

radiation field is at any location within the room, the equipment in that room must be designed to

withstand the environment that it is expected to experience, such that it will perform its intended

function during and following a design-basis accident (as specified in the FSAR).

In the case of theTarget Rock valve controllers, it was demonstrated, through analysis, that the

area in which they are located is not expected to exceed the 4.2 X 103, rads assumed for their

qualification. Therefore, even though the room is deemed to be a generally harsh environment,

since the Target Rock valve controllers are expected to be in a locally mild environment of s4.2

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X 103 rads, they are expected to be able to perform their intended function during and following

a design-basis accident.

Sections A3.3 and A4.1 of Appendix A to the LRA contain the applicant's FSAR supplement for

the EQ program as an AMP and TLAA for license renewal. The staff reviewed this section and

finds that the program description is consistent with the material contained in Sections 4.4 and

B3.1 of the LRA. The staff finds that the FSAR supplement provides an adequate summary of

the program activities as required by 10 CFR 54.21 (d).

4.4.3 Conclusion

The staff has reviewed the information in each Section 4.4 and Appendix B, Section B3.1 of the

LRAs. On the basis of this review, the staff concludes that the applicant has demonstrated that it

can adequately manage the effects of aging on the intended function(s) of electrical components

that meet the definition for TLAA; as defined in 10 CFR 54.3, during the period of extended

operation, as required by 10 CFR 54.21 (c)(1)(iii). In addition, the staff concluded that the FSAR

supplement contains an adequate summary description of the programs and activities for the

evaluation of TLAAs for the period of extended operation, as required by 10 CFR 54.21 (d).

4.5 Concrete Containment Tendon Prestress

4.5.1 Summary of Information In the Application

The Millstone Unit 2 containment consists of a pre-stressed, reinforced concrete cylinder and

dome, and a flat, reinforced concrete mat foundation supported on unweathered bedrock. The

cylindrical portion of the containment is prestressed by a post-tensioning system composed of

horizontal and vertical tendons, with the horizontal tendons placed in three 240-degree systems

that use three buttresses as support for the anchorages. The dome has a three-way post

tensioning system. Prestress on the containment tendons is expected to decrease over the life

of the unit as a result of such factors as elastic deformation, creep and shrinkage of concrete,

anchorage seating losses, tendon wire friction, stress relaxation, and corrosion.

The applicant stated that the evaluation of containment tendon examination and surveillance test

results involved the use of time-limited assumptions such as corrosion rates, losses of tendon

prestress, and changes in material properties. Regression analysis incorporating the most recent

25-year containment tendon surveillance results are provided in Tables 4.5-1, 4.5-2, and 4.5-3.

These results and projections beyond 25 years are'compared to design minimum requirements

and the bounding 60-year, 95-percent confidence value in Figure 4.5-1. Confidence values were

developed using a standard deviation that had beeh derived from the appropriate dome,

horizontal, and vertical tendon data set. The'applicant indicated that the containment tendon

examinations are performed in accordance with Millstone Unit 2 technical specification

requirements, and that its evaluation meets the requirements of 10 CFR 54.3. As such, the

applicant concludes that the evaluation represents a TLAA.

Based on the above discussion, the applicant concluded that consistent with

10 CFR 54.21 (c)(1)(ii), acceptable losses in containment tendon prestress have been projected

to the end of the period of extended operation.

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The Unit 3 LRA states that the Millstone Unit 3 containment is a subatmospheric cylindrical

reinforced concrete structure designed without the use of prestressed tendons. Therefore, loss

of prestress is not applicable to this containment.

4.5.2 Staff Evaluation

The design of the Unit 3 containment does not use prestressed tendons so this TLAA section is

not applicable to Unit 3. The applicant provided the results of its regression analysis from the

measured data and smooth projected curves for each group of tendons in Unit 2. However, the

methodology used to arrive at the trends appears to be quite different from the method used by

other applicants. To obtain clarification on the various steps involved in arriving at the projected

trend lines, the staff requested the following information:

In RAI 4.5-1, the staff noted that the TLAA description included a number of time-limited

assumptions, such as corrosion rates, losses of tendon prestress, and changes in material

properties that have been utilized in performing the analysis. The applicant was requested to

provide a quantitative summary of the corrosion rates, factors contributing to tendon prestress

loss (e.g., creep, shrinkage, and relaxation of prestressing steel) and a factor related to change

in material properties used in performing the analysis.

In response to RAI 4.5-1, in its letter of November 9, 2004, the applicant provided the following

information:

The evaluation of containment tendon examination and surveillance test results involves

the use of time-limited assumptions. The Millstone Unit 2 tendon surveillance program

consists of periodically inspecting the physical condition of a randomly selected group of

tendons identified in accordance with Regulatory Guide 1.35. Visual and quantitative

examinations are performed of the tendon sheathing filler material, anchorages,

measurements of tendon liftoff forces (plus a visual assessment of stressing washers,

shims, bearing plates), tensile testing of wire samples and corrosion assessments.

Comparison of liftoff forces from the most recent tendon examinations to original

installation lock-off forces provides direct evidence of potential system degradation.

Containment tendon examination and surveillance test results can be found in the

responses to RAI 4.5-5 (Figures 1, 2 and 3), RAI 4.5-6 (Tables 1, 2 and 3) and in RAI

4.5-7 (Table 1). These figures and tables include such quantitative tendon examination

results as the actual and projected decreases in tendon group lock-off force, the

presence or absence of free water, corrosion assessments, tensile testing results, and

sheathing filler chemical analysis results. These inspection results reveal that the

Millstone Unit 2 containment post tensioning system has experienced no abnormal

degradation. Tendon lock off-force values were found to remain constant with projected

lock-off forces (Millstone Unit 2 LRA, Section 4 - Figure 4.5-1) remaining above minimum

requirements over the period of extended operation.

The applicant provided a description of examinations it performed and the factors it considered

in performing the TLAA. As this response is associated with the responses to RAls 4.5-5, 4.5-6,

and 4.5-7, the staff position regarding the TLAA adequacy is discussed in the staffs evaluation

of these RAls.

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In RAI 4.5-2, the staff requested a clarification of the prestressing force values provided in the

second column of Tables 4.5-1, 4.5-2, and 4.5-3. The staff noted that the lowest required

prestressing force for each group of tendons was established based on the computations of the

minimum requirement to counteract the tension produced due to specified internal pressure. The

tendon spacing is typically based on the tendon lock-off forces minus the estimates of losses

due to anchorage take-up, elastic shortening, time dependent losses, and losses due to friction.

The staff questioned whether it is feasible to account for all these factors and end up with the

same minimum required tendon force (1308 kips) at tendon anchorages for hoop, vertical, and

dome tendons. The applicant was requested to provide the basis for establishing the minimum

required forces along with a comparison against the measured prestressing forces.

In its letter dated December 3, 2004, the applicant provided the following information in response

to RAI 4.5-2:

The Millstone Unit 2 containment is pre-stressed by a post-tensioning system composed

of dome, vertical and horizontal (hoop) tendon groups.

Each tendon consists of approximately 186 stabilized, low relaxation 0.250-inch diameter

wires, each having a tensile strength of 240,000 psi. The design of the post tensioning

system takes into consideration a number of factors including tendon spacing, steel

relaxation, stress losses due to concrete creep, steel elasticity, number of tendon wires

and variability in same tendon load readings. Taking these variables into consideration,

Dominion originally used a value of 1308 kips for the minimum pre-stress forces

(Millstone Unit 2 LRA, Section 4 - Tables 4.5-1, -2 and -3, and Figure 4.5-1) as a

nominal value considered to represent a bounding pre-stress force for all three tendon

groups. However, based on a conversation with the reviewer, Dominion decided to

determine the actual values for the Millstone Unit 2 containment dome, vertical and

horizontal (hoop) tendon groups, which are 1343 kips, 1339 kips and 1325 kips

respectively.

As presented in the responses to RAI 4.5-4 (Figures 1, 2 and 3) and RAI 4.5-5 (Figures

1, 2 and 3), projected lockoff forces (Millstone Unit 2 LRA, Section 4 - Figure 4.5-1)

remain above minimum requirements over the period of extended operation.

In view of the magnitudes of tendon forces in dome, vertical, and hoop directions, the staff

considers the revised values provided for the minimum required prestress forces acceptable.

In RAI 4.5-4, the staff noted that the number of tendons sampled (i.e., 4 percent and 2 percent

of the population of the group of tendons) during each tendon inspection is small, and that the

sample size is not amenable to statistical analysis for establishing confidence levels (column 3 of

Tables 4.5-1,4.5-2, and 4.5-3) during each inspection based on the measured results. The staff

also pointed out that, as the sample size of each tendon inspection is small, Attachment 3 of

NRC Information Notice 99-10, Revision 1, recommended regression analysis of the measured

tendon forces without averaging or any statistical calculation. The applicant was requested to

provide more information about the values in column three of the identified tables and an

explanation of measured tendon force values used in the regression analysis.

In its January 11, 2005 response, the applicant removed the tables provided in the LRA, and

substituted new tables showing measured prestressing forces during tendon inspections for

4-35
each group of tendons. In response to the staffs follow-up question as to why 3-, 5-, and 10-

year data are missing from the tables, the applicant stated that as these tendons went through repeated tensioning and detensioning, the data were not reliable. The measurements taken

during the 1-, 15-, 20-, and 25-year inspections were used for developing the trend lines. In

Figures 1, 2, and 3 of the revised response (dated January, 11 2005), the applicant provided the

trend lines and the measured tendon force data. Figure A, showing the trend line related to

horizontal tendons, is reproduced below:

i

i

I

i

.I

.i

I

I

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Figure A: Trend Line Relationship with Horizontal Tendons

Millstone Power Station Unit 2

Horizontal Tendon Data

1750

1700

1650

1600

e. 1550

Y. 1500

2 1450

1400

1350

1300

1250

4Raw Data l l__ l l _. _O _ _ _-inRn

--- De--.M~n

_ _ _ _ = _Tmd U.t

as -_ _ _AI 1 1 _DELI1 7

I

1 10 100

I Time in Years I

In RAI 4.5-5, the staff noted that the process used by license renewal applicants with respect to

prestressed concrete containments is to assume that the tendon force varies with the logarithm

of time (as discussed in RG 1.35.1). The staff indicated that it was not apparent in Figure 4.5-1

what functional relationship had been assumed between the two variables. The applicant was

requested to provide additional information regarding the process used in arriving at the trending

curves shown in Figure 4.5-1.

In its response, in a letter dated January 11, 2005, the applicant confirmed that it is usingprocedures for monitoring and trending prestressing force consistent with the recommendations

in RG 1.35.1 and NRC Information Notice 99-10. Therefore, the staff finds the process

acceptable, as the use of RG 1.35.1 for estimating the target prestressing forces, and

Information Notice 99-10 for projecting the actual measured prestressing forces (as illustrated in

the figure above), provides the elements needed for an adequate TLAA.

In RAI 4.5-6, the staff noted that Section 5.9.3.3.4 of the Millstone Unit 2 FSAR indicates that 16

(below grade) horizontal tendons were identified to have ground water intrusion. The FSAR also

indicates that the corrosion protection medium is continuously supplied to these tendons at a

pressure slightly above the hydrostatic pressure to prevent intrusion of ground water. The staff

also noted that Appendix 5F of the FSAR indicates that the below-grade portions of about 70

vertical tendons have been subjected to ground water intrusion. Appendix 5F also describes the

attempts made to reduce the potential of corrosion of the components of these tendons.

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The staff indicated that, due to the unusual maintenance conditions of these tendons, they are

likely to experience greater age-related degradation (corrosion of wires, corrosion of anchorage

components, etc.) than other tendons. The applicant was requested to provide the following

information related to these tendons:

* During periodic inspections, are the samples from these tendons selected for special

inspection and lift-off testing?

* Which tendons are included in the samples used in Tables 4.5-2 and 4.5-3?

* For the affected tendons, please provide a summary of the results of inspections

performed in accordance with IWL-2523.

In its November 9, 2004, response, the applicant stated that it was using Section Xi Inservice

Inspection Program (Subsection IWL), and that it had not selected special tendons from the

tendons subjected to ground water intrusion in the inspection samples. The applicant provided

tables of tendons selected for examinations during various inspections, and conditions of the

tendon hardware, sampled wires, chemical properties of corrosion protection medium (e.g.,

chlorides, nitrates, sulfides), and amount of free water in the grease samples tested. Three hoop

tendons and one vertical tendon which had experienced water intrusion were included for

examinations. The anchor heads and bearing plates of these tendons indicated visible oxide

during 15, 20, and 25 years of inspections. The amount of free water increased from 15 to 20

years. However, during the 25-year inspection, the free water content decreased from 62 oz to

22 oz. The wire samples tested from these tendons indicated no difference in their strengths and

percentage elongation compared to other tendons.

The staff finds that though the applicant is not including specific tendons that are subjected to

ground water intrusion in its inspection samples, its random sample process incorporates these

tendons, and it is monitoring the condition of suspect tendons during subsequent examinations.

The TLAA is based on the force measurements taken on the randomly selected tendons.

Therefore, the staff finds the applicant's approach in monitoring the conditions of the affected

tendons acceptable.

In RAI 4.5-7, the staff noted that Section A3.4 of the Millstone 2 FSAR supplement provides only

a general summary of the TLAA. Table 4.5-1 of NUREG-1800 recommends a discussion of

trend lines and predicted lower limit (PLL) in the FSAR supplement In order for the summary to

be meaningful, the applicant was requested to provide a table showing the minimum required

prestressing forces and the projected (to 60 years) prestressing forces for each group of

tendons. The staff indicated that the tabulated values will confirm the validity of the analysis

results based on the inspections conducted during the period of extended operation. The

applicant was requested to supplement this information in Section A3.4 of the FSAR

supplement.

In its response dated January 11, 2005, the applicant proposed to incorporate Table I (as

reproduced below), in Millstone Unit 2 FSAR supplement.

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Table I Millstone Power Station Unit 2 Containment Tendon Prestress

-inspebo~n- Y.'.D e ~Dome ueda ' .*ertiAl- i ~ta Ii Hor<i- onztai

' Years' Tendow : BMinimurn '~Te~don Minimiim : -Mne'ou' Te"i'--dn 

; oi ePrdjete'd ' Value' Projeted C-Value' .* kps--r (kip kiip- j -ki (k ikip s)

40 1453 1343 -1521 1339 1467 1325

60 1435 1343 1509 1339 1449 1325

With the inclusion of this table, the staff finds the information in Section A3.4 of the FSAR

supplement acceptable, as the table provides the necessary information for comparing the

results of the inspections that will be performed during the period of extended operation.

4.5.3 Conclusion

On the basis of the review of this section of the LRAs and RAI responses, the staff concludes

that the TLAA performed in accordance with 10 CFR 54.21 (c)(1)(ii) is acceptable, and there is a

reasonable assurance that in conjunction with the aging management of the containment

structure to be performed in accordance with the aging management program described in LRA

Appendix B, Section B2.1 .16, the Millstone 2 containment will be able to perform its intended

function during the period of extended operation:

4.6 Containment Liner Plate and Penetration Fatigue Analyses

4.6A Unit 2 Containment Liner Plate and Penetration Fatigue Analyses

The interior surface of the concrete containment structure is lined with thin metallic plates to

provide a leak-tight barrier against the uncontrolled release of radioactivity to the environment,

as required by 10 CFR Part 50. The thickness of the liner plates is generally between 1/4 inch

(6.2 mm) and 3/8 inch (9.5 mm). The liner plates are attached to the concrete containment wall

by stud anchors or structural rolled shapes, or both. The design process assumes that the liner

plates do not carry loads. However,- normal loads, such as from con crete shrinkage, creep, and

thermal changes, imposed on the concrete containment structure, are transferred to the liner

plates through the anchorage system.'Intemal'pressure and temperature loads are directly

applied to the liner plates. Thus, under design-basis'conditions, the liner plates could experience

significant strains.

Fatigue of the liner plates may be considered in the design based on an assumed number of

loading cycles for the current operating term. The cyclic loads include reactor building interior

temperature variation during the heatup and cooldown of the reactor coolant system, a loss-ofcoolant accident (LOCA), annual outdoor temperature variations, thermal loads due to highenergy containment penetration piping linesl(such as steam and feedwater lines), seismic loads,

and pressurization due to periodic Type-A integrated leak rate tests.

4-39
The containment liner plates, penetration sleeves (including dissimilar metal welds), and - i - penetration bellows may be designed in accordance with the requirements of Section I I of the

ASME Boiler and Pressure Vessel Code. If a plant's code of record requires a fatigue analysis, then this analysis may be a TLAA and must be evaluated in accordance with 10 CFR 54.21 (c)(1) to ensure that the effects of aging on the intended functions will be adequately managed for the

period of extended operation.

The adequacy of the fatigue analyses of the containment liner plates (including welded joints), penetration sleeves, dissimilar metal welds, and penetration bellows is reviewed for the period of

extended operation. The fatigue analyses of the pressure boundary of process piping are

reviewed in Section 4.3A of this SER, following the guidance in Section 4.3 of the SRP-LR.

4.6A.1 Summary of Technical Information In the Application

The applicant discussed the evaluation of the containment liner in Section 4.6.1 of the LRA. The

applicant indicated that the following loads were considered in the design of the liner plate:

* 40 cycles of outdoor temperature variation

* 500 cycles of temperature variation due to startups and shutdowns

* 1 design-basis accident thermal cycle

The applicant discussed the evaluation of the containment penetrations in Section 4.6.2 of the

LRA. The applicant indicated that the containment penetrations were fabricated, installed, -

inspected, and tested in accordance with Section III of the ASME Code and ANSI B31.7. The

applicant indicated that the number of cycles used for the design of the containment liner plate penetrations was evaluated and found to be acceptable for the period of extended operation.

The applicant concluded that the fatigue analysis of the containment liner plate and penetrations have been projected to the end of the period of extended operation in accordance with

10 CFR 54.21(c)(1)(ii).

4.6A.2 Staff Evaluation

The design of the liner plate is discussed in Section 5.2.4 of the FSAR. The FSAR indicates that

the analysis of the liner plate was performed in accordance with the criteria specified in Section

IlIl of the ASME Code, 1968 edition. The staff confirmed that the design cycles identified by the

applicant in Section 4.6.1 of the LRA are the same as those specified in FSAR Section 5.2.4 for

the fatigue analysis of the liner plate. In a followup response (e-mail dated December 20, 2004; from W. Watson (MPS) to J. Eads (NRC)), the applicant indicated that the number of design cycles was multiplied by 1.5 to demonstrate that the fatigue design of the liner is acceptable for, 60 years of operation. Table 4.3-2 of the LRA indicates that the 500 heatup and cooldown cycles assumed for the fatigue design of RCS components should be bounding for the period of

extended operation; therefore, the applicant used a conservative estimate for the number of

startup and shutdown cycles. The staff concludes that the applicant's use of the 1.5 factor to

extrapolate the number of design load cycles from .40 to 60 years of plant operation is

acceptable. The staff finds the applicant has performed an acceptable assessment regarding the

fatigue life of the liner plate for the period of extended operation, pursuant to

10 CFR 54.21 (c)(1)(ii).

I

. I

4-40
The design of the containment penetrations is discussed in Section 5.2.7 of the FSAR. The

FSAR indicates that the penetrations were fabricated, installed, inspected, and tested in

accordance with Section III of the ASME Code and ANSI B31.7 as indicated by the applicant.

The applicant indicated that the number of cycles used in the design of the containment

penetrations was found acceptable for the period of extended operation. The staff finds the ' applicant has performed an acceptable assessment regarding the fatigue life of the containment

penetrations for the period of extended operation, pursuant to 10 CFR 54.21 (c)(1 )(i).

4.6A.3 FSAR Supplement

The applicant provided an FSAR supplement description of its TLAA evaluation for containment

liner plate and penetration fatigue analyses in Section A3.5 of the LRA. On the basis of its

review of the FSAR supplement, the staff concludes the summary description of the applicant's

actions to address metal fatigue of components is adequate.

4.6A.4 Conclusion

The staff has reviewed the applicant's TLAA of the containment liner and penetrations and

concludes the applicant's actions satisfy the requirements of 10 CFR 54.21 (c)(1).

The staff has also reviewed the FSAR supplement for the TLAA and finds that the FSAR

supplement contains an adequate description of the -applicant's actions to address fatigue of the

containment liner plate and penetrations to satisfy 10 CFR 54.21 (d).

4.6B Unit 3 Containment Liner Plate and Penetration Fatigue Analyses

The interior surface of the concrete containment structure is lined with thin metallic plates'to'

provide a leak-tight barrier against the uncontrolled release of radioactivity to the environment,

as required by 10 CFR Part 50. The thickness of the liner plates is generally between 1/2 inch

(12.7 mm) and 3/8 inch (9.5 mm). The liner plates are attached to the concrete containment wall

by stud anchors or structural rolled shapes, or both. The design process assumes that the liner

plates do not carry loads. However, normal loads, such as from concrete shrinkage, creep, and

thermal changes, imposed on the concrete containment structure, are transferred to the liner

plates through the anchorage system. Internal pressure and temperature loads are directly

applied to the liner plates. Thus, under design-basis conditions, the liner plates could experience

significant strains.

Fatigue of the liner plates may be considered in the design based on an assumed number of

loading cycles for the current operating term. The cyclic loads include reactor building interior

temperature variation during the heatup and cooldown of the reactor coolant system, a LOCA,

annual outdoor temperature variations, thermal loads due to high-energy containment

penetration piping lines (such as steam and feedwater lines), seismic loads, and pressurization

due to periodic Type-A integrated leak-rate tests.,!

The containment liner plates, penetration sleeves (including dissimilar metal welds), and

penetration bellows may be designed in accordance with the requirements of Section III of the

ASME Boiler and Pressure Vessel Code. If a'plant's code of record requires a fatigue analysis,

then this analysis may be a TLAA and must be evaluated in accordance with 10 CFR 54.21 (c)(1)

4-41
to ensure that the effects of aging on the intended functions will be adequately managed for the

period of extended operation.

The adequacy of the fatigue analyses of the containment liner plates (including welded joints),

penetration sleeves, dissimilar metal welds, and penetration bellows is reviewed for the period of

extended operation. The fatigue analyses of the pressure boundary of process piping are

reviewed in Section 4.3B of this SER, following the guidance in Section 4.3 of the SRP-LR.

4.6B.1 Summary of Technical Information In the Application

The applicant discussed the evaluation of the containment liner in Section 4.6.1 of the LRA. The

applicant indicated that ASME Section III and Section VIII, 1971 Edition were used in the design

of the Millstone Unit 3 containment liner. The applicant indicated that the analysis of the

containment liner plate has been projected to the period of extended operation in accordance

with 10 CFR 54.21 (c)(1)(ii).

The applicant discussed the evaluation of the containment penetrations in Section 4.6.2 of the

LRA. The applicant indicated that Millstone Unit 3 penetrations consist of both sleeved and'

unsleeved piping penetrations, electrical penetrations, a fuel transfer tube, a personnel air lock,:

and the equipment hatch. The applicant stated there were no applicable codes for the design of

concrete containment liners at the beginning of construction of Millstone Unit 3. The applicant

indicated that ASME Section 1II, Division 1 and 2, and ASME Section Vil were used as guides.

The applicant indicated that the containment liner plate and access openings, including the fuel

transfer tube assembly, were designed for the following loads:

* 400 cycles of thermal expansions

* 100 cycles of differential pressure

* 100 cycles of 1/2-safe shutdown earthquake

The applicant stated that the analysis of the containment liner plate penetrations has been

projected to the end of the period of extended operation in accordance with

10 CFR 54.21 (c)(1)(ii).

4.6B.2 Staff Evaluation

The design of the liner plate is discussed in Section 3.8.1 of the Millstone Unit 3 FSAR. The

FSAR indicates that the analysis of the liner plate conforms with the criteria specified in Section

IlIl of the ASME Code, 1971 edition through the 1973 summer addendum. The staff confirmed

that the design cycles identified by the applicant in Section 4.6.1 of the LRA are the same as

those specified in FSAR Table 3.8 for the fatigue analysis of the liner plate. In response (e-mail

dated November 10, 2004, from W. Watson (MPS) to J. Eads (NRC)) to a staff question during

an October 12, 2004, teleconference, the applicant indicated that the number of design cycles

was multiplied by 1.5 to demonstrate that the fatigue design of the liner is acceptable for 60

years of operation. Table 4.3-2 of the LRA indicates that the 400 thermal cycles (heatup and

cooldown cycles) should be bounding for the period of extended operation. The staff also finds

the applicant's estimate of the number of cycles for differential pressure conservative based on

the projected number of startup and shutdown cycles. Therefore, the staff concludes that the

applicant used a conservative estimate of the number of load cycles for the period of extended

I

4-42
-

operation. The staff finds the applicant has performed an acceptable assessment regarding the

fatigue life of the liner plate for the period of extended operation, pursuant to

10 CFR 54.21 (c)(1 )(ii).

The design of the containment penetrations is also discussed in Section 3.8.1 of the Millstone

Unit 3 FSAR. Table 3.8-2 of the FSAR indicates that the'penetrations were evaluated using Section III, Class-1 or Class-2 criteria. The applicant indicated that the number of cycles used in

the design of the containment penetrations was found acceptable for the period of extended

operation. As discussed previously, the number of thermal and pressure cycles used in the

evaluation of the containment penetrations should be bounding for the period of extended

operation based on the information provided in LRA Table 4.3-2. Therefore, the staff finds the

applicant has performed an acceptable assessment regarding the fatigue life of the containment

penetrations for the period of extended operation, pursuant to 10 CFR 54.21 (c)(1 )(i).

4.6B.3 FSAR Supplement

The applicant provided an FSAR supplement description of its TLAA evaluation for containment

liner plate and penetration fatigue analyses in Section A3.4 of the LRA.

4.6B.4 Conclusion

The staff has reviewed the applicant's TLAA of the containment liner and penetrations and

concludes the applicant's actions and commitments satisfy the requirements of

10 CFR 54.21 (c)(1).

The staff has also reviewed the FSAR supplement for the TLAA and finds that the FSAR

supplement contains an adequate description of.the applicant's actions to address fatigue of the

containment liner plate and penetrations to satisfy 10 CFR 54.21(d).

4.7 Other Plant-Specific Time-Limited Ag Ing Analyses

4.7A Unit 2 Other Plant-Specific Time-Limited Agina Analyses

4.7A.1 Crane Load Cycle Limit --

4.7A.1.1 Summary of Technical Information in the Application

In LRA Section 4.7.1, the applicant identified the following examples of the types of cranes

determined to be within the scope of license renewal. These cranes were designed in

accordance with, or reconciled to, the guidancecontained in NUREG-0612, "Control of Heavy

Loads in Nuclear Power Plants.'

* containment polar crane

* spent fuel crane'

* monorails

NUREG-0612 requires that the design of heavy-load, overhead handling systems meets the

intent of Crane Manufacturers Association of America, In'c., Specification No. 70 (CMAA-70).

4-43
Overhead cranes designed to CMAA-70 have an implicit fatigue design basis, equivalent to a

limiting number of 100,000 load cycles. The Millstone Unit 2 polar crane was originally designed

to the requirements of the Electric Overhead Crane (EOC) Institute Specification No. 61. This

design was subsequently reconciled to the guidance contained in NUREG-0612.

As noted by the applicant, the most frequently used crane is the spent fuel crane. The spent fuel

crane is expected to experience approximately 17,500 load cycles over a 60-year period for the

movement of spent fuel from the reactor to the spent fuel pool. In addition, the crane is used in

support of other activities including fuel shuffles and inspections. In supporting these uses, the

spent fuel crane is expected to conservatively experience a total of 35,000 load cycles over a 60-

year period. This number is well below the 100,000 load cycles allowed in CMAA-70.

4.7A.1.2 Staff Evaluation

The containment polar crane in Unit 2 was originally designed to the requirements of Electric

Overhead Crane Institute Specification No. 61. Since this specification does not contain

guidelines for fatigue evaluation, the applicant was requested in RAI 4.7.1-1 to explain how the

crane was reconciled to the fatigue design basis of 100,000 load cycles as required by the

CMAA-70.

In its response dated November 9, 2004, the applicant stated:

In accordance with NUREG-0612, the load carrying parts of the polar crane, except for

structural members and hoisting ropes, were designed such that the calculated static

stress in the material, based on rated load, will not exceed 20% of the assumed average

ultimate strength of the material. The Millstone Unit 2 polar crane was designed for a

load of 578 tons (NRC to Northeast Nuclear Energy Company, Summary of Meeting of

March 20, 1991, With Representatives of Northeast Utilities Concerning the Construction

Aspects of the Millstone Unit 2 Steam Generator Replacement Project, Letter A09459

dated April 4, 1991), but the largest typical load, the pressure vessel head (including the

associated weight of the lifting rig, CEDMs and CEDM coolers), is nominally 140 tons.

The Millstone Unit 2 polar crane is used primarily during refueling outages. Assuming

four load cycles per year (pressure vessel head removal and replacement plus other

miscellaneous uses such as RCP motor movement) for a 60-year period of time, the

polar crane would only experience a nominal 240 load cycles through the current and

extended periods of operation. This number is significantly less than the 100,000 design

load cycles (Millstone Unit 2 LRA Section 4.7.1).

The staff finds the applicant's response reasonable and acceptable because the applicant has

provided a satisfactory explanation for reconciling the design of the polar crane to the

requirements of CMAA-70.

As noted by the applicant, the most frequently used crane is the spent fuel crane. This crane is

projected to lift 35,000 load cycles over a 60-year period for Unit 2. The staff requested the

applicant to provide the basis for arriving at this projected figure of 35,000 load cycles.

I

-1

4-44
In its supplemental response to RAI 4.7.1 -1 dated January 11, 2005, the applicant stated:

The Millstone Unit 2 spent fuel pool crane is the most frequently used crane of those

cranes within the scope of license renewal. As such, the spent fuel pool crane would

experience the highest number of load cycles over the period of extended operation. The

capacity of the Unit 2 spent fuel crane is 2,000 pounds. A fuel assembly with its

associated rigging weighs approximately 1,500 pounds.

Assuming full-core off-loads and subsequent reloading of the 217 fuel assemblies every

1.5 years, the spent fuel pool crane is expected to experience 17,360 lifts (or load cycles)

over a 60-year period.

217 X 2 lifts/cycle X 1 cycle/1.5 years X 60 years = 17,360 lifts

The crane is also used to support other activities including fuel shuffles and inspections.

Considering all of these uses, the spent fuel pool crane is expected to conservatively

experience a total of 35,000 lifts (i.e., 17,360 lifts X 2) over a 60-year period. This

number is well below the allowable number of 100,000."

The staff finds the applicant's response reasonable and acceptable because the applicant has

provided a satisfactory basis for determining the projected number of lifts.

Considering all the uses, the spent fuel crane is likely to experience a total of 35,000 load cycles

over a 60-year period. This number is well below the design load cycles of 100,000, and

therefore acceptable. A similar conclusion based on projected load cycles being well below the

number of design load cycles is applicable for the other cranes within the scope of license

renewal.

4.7A.1.3 FSAR Supplement

In Appendix A, Section A3.6.1 of the application, the applicant provided a summary description

of the evaluation of the crane load cycle limit. The applicant stated that the load cycles for these

cranes were evaluated for the period of extended operation. For each crane, the projected load

cycles through the period of extended operation will be less than the design load cycles and,

therefore, all cranes in the scope of license renewal will continue to perform their intended

function throughout the period of extended operation. On the basis of staffs review, the staff

concludes that the applicant's description is sufficient to satisfy the requirements of 54.21 (d).

4.7A.1.4 Conclusion .

The staff has reviewed the information in LRA Section 4.7.1 and Appendix A, Section A3.6.1, as

well as the additional information provided in the applicant's responses to staffs request for

additional information. On the basis of the review discussed above, the staff concludes that the

applicant has provided adequate information to meet the requirements of 10 CFR 54.21 (c)(1),

option (ii) related to the TLAA for the crane load cycle limits.

4-45
4.7A.2 Reactor Coolant Pump Flywheel

4.7A.2.1 Summary of Technical Information in the Application

In Section 4.7.2 of the Millstone Unit 2 LRA, the applicant addresses its analysis of fatigue-crack initiation and growth for the reactor coolant pump (RCP) flywheel.

The RCP motors are provided with flywheels to increase rotational inertia, thus prolonging pump coast-down and assuring a more gradual loss of primary coolant flow to the core in the event

that pump power is lost. During normal operation, the RCP flywheels develop sufficient kinetic

energy to produce high-energy missiles in the event of failure. Conditions that may result in

overspeed of the pump increase both the potential for failure and the kinetic energy of the

flywheel. These concerns led the NRC to issue RG 1.14, "Reactor Coolant Flywheel Integrity," Revision 1, August 1975. One of the recommendations of RG 1.14 is to volumetrically inspect the flywheels at 3- and 10-year intervals.

The applicant stated that an evaluation was performed of the likelihood of flywheel failure over a

60-year period of operation, and a justification' was developed for the relaxation of RG 1.14, Revision 1, Regulatory Position C.4.b(2). The NRC has reviewed and accepted the topical report SIR-94-080-A developed by Structural Integrity Associates, In'c., subject to certain conditions, for

referencing in license applications. Using this evaluation, the NRC issued Amendment Number

264 for the Millstone Unit 2 RCP flywheel inspection frequency. The amendment allows Millstone Unit 2 to examine each reactor coolant pump flywheel at least once every 10 years, coinciding with the ASME Section Xl inservice inspection program.

The applicant concluded that the evaluation of the reactor coolant pump flywheels represents a

time-limited aging analysis per 10 CFR 54.3 since it involves the use of time limited assumptions such as thermal cycles and crack growth rates. Consistent with 10 CFR 54.21 (c)(1)(iii), the

applicant concluded that the RCP flywheel fatigue will be adequately managed by the Inservice

Inspection Program: Systems, Components and Supports for the period of extended operation.

4.7A.22 Staff Evaluation

In Section 4.7.2 of the Millstone Unit 2 LRA, the applicant describes an analysis of fatigue-crack initiation and growth for the RCP flywheel. The staff reviewed this section to determine whether

the applicant provided adequate information to meet the requirements of 10 CFR 54.21 (c)(1), as

the information relates to the TLAA for the RCP flywheel.

To reduce the RCP flywheel inspection frequency, Millstone Unit 2 submitted an amendment to its TS in a letter dated April 26, 2001. The amendment justification referenced the topical report SIR-94-080A, 'Relaxation of Reactor Coolant Pump Flywheel Inspection Requirements," which

was approved by the NRC with certain conditions. The conditions are specified in the NRC's

SER dated May 21,1997. The crack growth calculations were based on an assumed 4,000 cycles of RCP startups and shutdowns rather than a specific time period of operation. The LRA

states that the number of cycles from actual plant operating conditions through the end of the

period of extended operation is expected to be much less that the assumed 4,000 cycles.

. 11

4-46
In RAI 4.7.2-1, the staff requested that the applicant discuss how crack growth rates and the

number of start/stop cycles used in SIR-94-080A are applicable to the period of extended

operation. In the applicant's response to RAI 4.7.2-1, dated December 3, 2004, the applicant

states that a flaw tolerance evaluation using linear elastic fracture mechanics principles was

performed using lower bound fracture toughness values at the most highly stressed locations. A

crack growth evaluation was performed using the ASME Section Xl crack growth law for ferritic

steel in an air environment with an assumed initial flaw size of 0.25 inches (ultrasonic testing

detection uncertainty). The crack growth after 4000 startup/shutdown cycles (this value is

significantly more than expected for the period of extended operation) was found to be minimal

(0.0035 inches) resulting in a final flaw size of 0.2535 inches. This final flaw size is significantly

below the calculated ASME Section Xl, paragraph IWB-3610 allowable flaw size of 1.64 inches

for normal operating speed and 2.0 inches for accident speed conditions. Millstone Unit 2 is

expected to experience a total of 300 RCP startup/shutdown cycles, including the period of

extended operation.

The applicant's fatigue-crack growth analysis for the RCP flywheels demonstrates that the

postulated flaw is not expected to grow in excess of the critical crack-size, even when the

flywheels have been subjected to the change in the stress-intensity factor for the flywheels

associated with 4,000 RCP startup/shutdown cycles. Since this bounds the number of RCP

startups/shutdown cycles assumed for both the current operating period and the proposed

period of extended operation, the staff concludes that the fatigue-crack growth analysis for the

RCP flywheels meets the acceptance criterion for TLAAs in 10 CFR 54.21 (c)(1 )(ii), in that the

analysis remains bounding for the period of extended operation.

4.7A.2.3 FSAR Supplement

Section A3.6.2 of Appendix A to the LRA provides the applicant's FSAR supplement regarding

RCP flywheel consistent with the staff's evaluation discussed in Section 4.7.2.2 of this SER. The

FSAR supplement summary description for the TLAA on the RCP Flywheel is therefore

acceptable to the staff, and satisfies the criterion for FSAR supplement summriiy descriptions in

10 CFR 54.21(d).

4.7A.2.4 Conclusion

Based on its review, the staff concludes that the applicant has provided an acceptable

demonstration pursuant to 10 CFR 54.21 (c)(1)(ii)'that,'for the TLAA on the RCP flywheel, the

analysis remains valid for the period of extended 6peration.

The staff also concludes that the FSAR supplement contains an adequate summary description

of this TLAA evaluation for the period of exterided operation, a's required by 10 CFR 54.21(d).

4.7A.3 Reactor Coolant Pump Code Case N-481

4.7A.3.1 Summary of Technical Information In the Application

In Section 4.7.3 of the Millstone LRA, the applicant concluded that the use of ASME Code Case

N-481 for Millstone Units 2 and 3 for evaluating the reactor coolant pump'(RCP) casing met the

definition in 10 CFR 54.3 for a TLAA, since it involves the use of time-limiting assumptions such

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as thermal cycles and crack growth rates. The applicant concluded that the use of ASME Code

Case N-481 for the RCP casing welds at the Millstone units were TLAAs that needed to be

assessed against the acceptance criteria of 10 CFR 54.21 (c)(1). The applicant provided the

following assessment for the TLAA on the ASME Code Case N-481:

Millstone. Unit 2

ASME Boiler and Pressure Vessel Code, Section Xi, specifies that a volumetric

inspection of the reactor coolant pump casing welds and a visual inspection of

pump casing internal surfaces be performed on a reactor coolant pump within

each 1 0-year inspection period. These 1 0-year volumetric inspections are

significant because the reactor coolant pumps have already been welded to the

piping and the pumps must be disassembled in order to gain access to the inside

surface of the cast stainless steel casings. In recognition of these difficulties, ASME Code Case N-481, Alternative Examination Requirements for Cast

Austenitic Pump Casings, was developed to allow for the replacement of

volumetric examinations with [a] fracture mechanics, based evaluation and

supplemented by specific visual inspections. The NRC, with no supplemental requirements or conditions, has approved Code Case N481 for use at Millstone

Unit 2.

The evaluation of reactor coolant pump casings represents a time-limited aging analysis per 10 CFR 54.3 since it involves the use of time limited assumptions such as thermal cycles, and crack growth rates. Consistent with- - 10 CFR 54.21 (c)(1 )(iii), acceptable reactor coolant pump casing will be managed by the Inservice Inspection Program: Systems, Components and Supports for the

period of extended operation.

Millstone. Unit 3

The Millstone Unit 3 Mode 93A-1 reactor coolant pump casings are single castings, which contain no welds. Therefore, Code Case N-481, Alternative

Examination Requirements for Cast Austenitic Pump Casings, is not applicable.

4.7A.3.2 Staff Evaluation

Cast austenitic stainless steel (CASS) RCP casings are subject to thermal aging. Thermal aging refers to the gradual change in the microstructure and properties of a susceptible material due to

its exposure to elevated temperatures for an extended period of time. Thermal aging may result in a reduction of the fracture toughness of a susceptible material such as CASS, since the

thermal aging embrittlement effect (loss of fracture toughness) is a time-dependent phenomena. The associated aging effect requires a TLAA to ensure that it will be adequately managed through the period of extended operation.

ASME Code Case N-481 was approved by the NRC staff in RG 1.147, Revision 13, "Inservice

Inspection Code Case Acceptability, ASME Section Xl, Division 1," to allow the use of visual

inspections and a postulated flaw evaluation in lieu of the volumetric examinations of the cast

austenitic RCP casings welds as required by Table IWB-2500-1, Examination Category B-L-1, Item B12.10 of the ASME Code, Section Xl. The purpose of the flaw analysis is to support the

application of ASME Code Case N-481 for the inservice inspection (ISI) examination of the RCP

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casing welds. The requirements of Table IWB-2500-1, Examination Category B-L-2, Item B12.20

of the ASME Code, Section Xl to perform internal visual inspections of the internals of the pump

casing still apply.

Since the Millstone Unit 3 RCP casings are single castings, which contain no welds, ASME Code

Case N-481 does not apply. Therefore, this is not a TLAA for Millstone Unit 3, and no further

evaluation for Millstone Unit 3 is necessary.

For Millstone Unit 2, the RCP casings have welds, and therefore the use of ASME Code Case

N-481 applies and is required to be evaluated as a TLAA since it uses time limiting assumptions

such as thermal cycles and crack growth rates. However, the applicant did not provide the

postulated flaw analysis required by the code case for the period of extended operation. In

RAI 4.7.3-1 (a), the staff requested the applicant to submit this fracture mechanics evaluation for

the period of extended operation. In addition, the applicant was requested to compare the crack

growth for the extended period to that originally predicted for the current operating period,-and

provide the basis for concluding that this additional crack growth still allows the continued

application of ASME Code Case N-481.

In response to RAI 4.7.3-1 (a), in a letter dated December 3, 2004, the applicant stated that a

fracture mechanics evaluation, performed as a part of a Combustion Engineering Owners'Group

CEN-412, Revision 2, Supplement 2 activity, has been performed for the Millstone Unit 2 reactor

coolant pumps. The applicant also stated that for Millstone Unit 2, the limiting end-point crack

size is 0.39t, significantly greater than the 1/4t flaw postulated in ASME Code Case N-481. The

time for the Millstone Unit 2 reactor coolant pump casing to reach the limiting end-point crack

size is 103 years. To confirm the methodology and fracture mechanics results, the staff

requested that the applicant provide the fracture mechanics evaluation for staff review. This was

identified as Open Item 4.7.3-1 (a).

In response to RAI 4.7.3-1(a), dated February 8, 2005, the applicant provided CEN-412,

Revision 2, Supplement 2. The staff reviewed the report and found the evaluation used a nonconservative fracture toughness value of 150.4 ksi Vin. Using the methodology in the report,

along with the staff established fracture toughness value of 82 ksi /in, based on the staffs letter

to NEI, dated May 19,' 2000, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel

Components," the staff determined that the timie required to reach the limiting end-point crack

size is 87 years, instead of 103 years. Since this bounds the extended period of operation, the

staff finds that the Millstone, Unit 2 reactor coolant pump casing to have adequate toughness for

the extended period of operation based on CEN-412, Revision 2, Supplement 2 and the staff's

letter dated May 19, 2000. The applicant also submitted an additional supplemental response in

a letter dated June 2, 2005, to clarify how it intends to manage the aging of its RCP casings

through the period of extended operation. In the June 2, 2005, letter, the applicant stated that

the RCP casings will be managed through inspections performed under the aging management

program, "Inservice Inspection Program: Systems, Components and Supports," in accordance

with 10 CFR 54.21(c)(1)(iii). The staff finds the applicant's management of thermal aging

embrittlement using the ASME Code Case N-481 inspection requirements, which consist of a

visual inspection, acceptable. This resolves Open Item 4.7.3-1 (a).

ASME Code Case N-481 requires an inspectionland a fracture mechanics evaluation. The LRA

states that the RCP casing will be managed by the inservice inspection program for the period of

extended operation consistent with 10 CFR 54.21 (c)(1)(iii). In RAI 4.7.3-1(b) the applicant was

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requested to determine which option of 10 CFR 54.21 (c)(1), (Options (i) or (ii)), applies for the fracture mechanics evaluation required by the code case, in addition to Option (iii) for the

management by inspection.

In response to RAI 4.7.3-1 (b), in a letter dated December 3, 2004, the applicant confirmed that the acceptable reactor coolant pump casing flaw sizes have been projected through the period of extended operation, consistent with 10 CFR 54.21 (c)(1 )(ii). This is acceptable to the staff

since the RCP casing will be managed by the inservice inspection program and justified the use of a postulated flaw evaluation in lieu of the volumetric examinations of the cast austenitic RCP casings welds. This resolves RAI 4.7.3-1 (b).

4.7A.3.3 FSAR Supplement

LRA Section A3.6.3 for Millstone Unit 2 provides a FSAR supplement summary description for the TLAA on the use of ASME Code Case N-481. In RAI 4.7.3-1(c), the staff requested the applicant to confirm that Section A3.6.3 of the LRA applies to the pump casing welds, not the

pump casing as a whole, to be consistent with the code case. In response to RAI 4.7.3-1(c), in a letter dated December 3, 2004, the applicant confirmed that the use of ASME Code Case N-481 applies to the RCP casing welds and that the requirements of Table IWB-2500-1, Examination Category B-L-2, Item B12.20 of the ASME Code, Section Xl apply. This resolves RAI 4.7.3-1(c).

On the basis of the staff's evaluation, the summary description for the reactor coolant system TLAA for the use of ASME Code Case N-481 described in the FSAR supplement (LRA, Appendix A) provides an adequate description of this TLAA, as required by 10 CFR 54.21(d).

4.7A.3.4 Conclusion

On the basis of its review, the staff concludes that the applicant has demonstrated, pursuant to 10 CFR 54.21 (c)(1 )(ii) and 10 CFR'54.21 (c)(11)(iii), that for the TLAA on the use of ASME Code Case N-481 on the CASS RCP pump casing welds, the analysis remains valid through the period of extended operation for Millstone Unit 2. The staff also concludes that the Millstone Unit 2 FSAR supplement contains an adequate summary description' of the TLAA on the use of ASME Code Case N-481 for the period of extended operation, as required by 10 CFR 54.21 (d). The staff also concludes that the use of ASME Code Case N-481 is not a TLAA for Millstone

Unit 3 since there are no welds in the pump casings. Therefore, the staff has reasonable

assurance that the safety margins established'and maintained during the current operating term for the cast austenitic RCP casings will be maintained through the period of extended operation for the Millstone units.

4.7A.4 Leak-Before-Break

4.7A.4.1 Summary of Technical Information in the Application

The applicant stated that a leak-before-break (LBB) analysis has been performed for the Millstone 2 reactor coolant system (RCS) primary loop. The analyses' considered the thermal

aging of cast austenitic stainless steel piping and the fatigue transients that drive the flaw growth over the operating life of the plant.

I

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- .

The fundamental premise of LBB is that the materials used in nuclear power plant piping are

sufficiently tough that even a large through-wall crack would remain stable and not result in a

double-ended pipe rupture.

The NRC modified 10 CFR Part 50 General Design Criterion (GDC) 4, Environmental and

Missile Design Bases," in 1987. This change allows applicants to eliminate the dynamic effects

of postulated ruptures in primary coolant loop piping in the design of PWRs if LBB criteria are

met. In 1990, an LBB analysis was performed for CE-designed nuclear steam supply systems

and documented in topical report CEN-367. This analysis demonstrated that plant monitoring

systems can detect potential leaks in the RCS primary loop piping before a postulated crack

causing the leak would grow to unstable proportions during the 40-year plant life. The NRC

approved this analysis in its'safety evaluation (SE)'dated October 30, 1990. The original design

basis for the Millstone Unit 2 RCS considered postulated breaks for the purposes of evaluating

protection from the dynamic and environmental effects of the main coolant line (MCL) breaks.

The changes to GDC 4 allowed the application of LBB criteria for the selection of MCL breaks.

The NRC approved the criteria for use at Millstone Unit 2 through its SE dated September 1,

1992. This application of LBB has eliminated the requirement to consider postulated breaks on

the MCL in evaluating the dynamic effects on the RCS. The applicant's original LBB analysis

was updated by letter dated June 25, 1998 due'to the replacement of the steam generators. The

re-analysis was needed to demonstrate that the conclusions of the original analysis-remain valid

or have been effectively addressed by the'revised evaluations. The staff reviewed and approved

the updated analysis in a letter dated November'11, 1998.

4.7A.4.2 Staff Evaluation

The applicant describes its LBB analysis in Section 4.7.4 of the LRA for RCS piping. The staff

reviewed this section to determine whether the applicant provided adequate information to meet

the requirements contained in 10 CFR 54.21(c) related to the TLAA for LBB for Millstone Unit 2.

The staff confirmed that the NRC generically approved the LBB applications for the primary loop

piping for Combustion Engineering Owners Group (CEOG) plants on October 30,1990, and

specifically for Millstone 2 on November 9, 1998. The CEOG provides this genheric LBB

evaluation in CEN-367-A. There are two time-limited considerations for LBB analysis, crack

growth and thermal aging. The material properties'of cast austenitic stainless steel (CASS)'can

change over time. Thermal aging causes an elevation' in the yield strength of the material and a

degradation of the fracture toughness, with the degree of degradation being a function of the

level of ferrite in the material. Thermal aging in CASS will continue until a saturated or fully aged

point is reached.

The assessment in CEN-367-A uses the fracture toughness values of the SA-515 Grade 70

carbon steel weld in the LBB analysis, which are the lowest among all base and weld materials

in the primary loop piping system. The staff has compared the' fracture toughness values in

CEN-367-A with the more recent information in NUREG-6177, TAssessment of Thermal

Embrittlement of Cast Stainless Steels," and found that the fracture toughness data in CEN-367-

A are more conservative than the NUREG-6177 lower-bound fracture toughness curve.

Therefore, because the original analysis supporting LBB bounds fully aged CASS, the analysis

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does not have a material property time dependency that requires further evaluation for license

renewal.

In response to RAI 4.7.4-1, the applicant stated that the LBB fatigue-crack growth analysis

reported in CEN-367-A is based on 40-year design limits for RCS fatigue transient cycles. In

CEN-367-A, the applicant performed a fatigue-crack growth analysis to show that fatigue will not

cause degradation of the pressure boundary integrity. In the fatigue-crack growth analysis, the

normal and upset cyclical loadings cause postulated flaws to grow. These cyclical loadings are

based on reactor coolant design transient cycles. As described in Section 4.3.1 of the LRA, the

number of transient cycles assumed in the original design for 40 years was found acceptable for

60 years of operation. Therefore, the postulated flaw growth in CEN-367-A (based on the RCS

original design transient cycles) is unchanged for 60 years of operation. The staff finds the

response acceptable and considers this issue closed.

In addition, the applicant has the "Metal Fatigue of the Reactor Coolant Pressure Boundary

Program" to ensure that the accumulation of the applicable fatigue transient cycles over time will

not invalidate the fatigue flaw growth analysis that it performed as part of the approved Millstone

Unit 2 LBB analyses. With this program in place, which calls for constant review of the .

accumulation of applicable fatigue transient cycles, the applicant concluded that the continued

implementation of the "Metal Fatigue of the Reactor Coolant Pressure Boundary Program" will

provide reasonable assurance that the RCS components within the scope of license renewal will

continue to perform their intended function(s) consistent with the CLB for the period of extended

operation. The staff reviewed the "Metal Fatigue of Reactor Coolant Pressure Boundary

Program" and determined that the program is adequate to monitor the applicable set of

transients and their limits, and to count the actual thermal cycle transients to ensure that it is

within the allowable limits of the defined transients. In the event that design cycle limits are

approached, the applicant will review the analysis and determine appropriate actions.

Based on the above evaluation, the staff finds that the continued implementation of the !Metal

Fatigue of the Reactor Coolant Pressure Boundary Program" provides reasonable assurance

that thermal fatigue for the primary loop piping and components will be adequately managed,

and therefore the analyses for this TLAA remain valid for the period of extended operation, in

accordance with 10 CFR 54.21 (c)(1)(ii).

The applicant reviewed and found the number and characteristics of cycles identified in CEN367-A to be acceptable for the period of extended operation for the RCS piping at Millstone Unit

2. The applicant needed to identify all other systems or sections of piping that are covered by

LBB analyses and if the analyses are applicable for the period of extended operation. The

applicant needed to provide documented justification that the LBB analyses for systems covered

by LBB analyses remain valid for the period of extended operation. The applicant needed to also

provide justification that the analyses have been projected to the end of the period of extended

operation, or that the effects of aging on the intended functions of the systems covered by LBB

analyses will be adequately managed for the period of extended operation. The applicant

needed to also update the FSAR supplement as appropriate. This was identified as Open

Item 4.7.4-1.

By letter dated February 8, 2005, the applicant provided additional information to address Open

Item 4.7.4-1. For Millstone Unit 2, the systems and components that have been analyzed for

LBB include the reactor coolant loop piping (hot leg, cold leg, and crossover piping), the

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pressurizer surge line, and portions of the safety injection and shutdown cooling systems. The

applicant stated that each of the LBB analyses associated with these systems and components

were evaluated for the period of extended operation. The discussion for the reactor coolant loop

piping is intended to envelope all of the current design basis LBB analyses. The materials

evaluated for the subject components include carbon and low alloy steels, stainless steel

(including cast austenitic stainless steel (CASS)) and nickel-based alloys. For each LBB

analysis, the inputs to the evaluation were reviewed to identify time-limited assumptions.

Thermal aging of CASS materials and fatigue crack growth calculations were determined to be

time-based inputs as defined in 10 CFR 54.3 and required evaluation for the period of extended

operation. The TLAA evaluations of metal fatigue are discussed in LRA Section 4.3.1 and the

staffs evaluation is provided in Section 4.3 of this report. The metal fatigue TLAA evaluations

conclude that design basis limits are not exceeded for ASME Class 1 components (which

envelopes the components evaluated for LBB) through the period of extended operation.

Thermal aging of CASS materials for components that have been evaluated for LBB has been

evaluated for its effect on fracture toughness. The applicant's review concluded that the analysis

used fully aged values for fracture toughness. Corrosion of nickel-based alloys was also

considered. Cracking due to PWSCC of nickel-based alloys is managed by the Inservice

Inspection Program: Systems, Components, and Supports AMP described in LRA Section

82.1.18. Millstone Unit 2 has committed to follow the industry recommendations related to

nickel-based alloys. This commitment is identified in Appendix A, Table A6.0-1, License Renewal

commitments, Item 14. The staff finds that the applicant has provided an adequate

demonstration that the TLAA for LBB evaluations for the subject components remain valid or

have been projected to the end of the period of extended operation. Therefore, the staff

concludes that Open Item 4.7.4.1 is closed.

Since the V.C. Summer Nuclear Station main coolant loop weld cracking event involving Alloy

82/182 weld material, the staff has considered the effect of primary water stress-corrosion

cracking on Alloy 82/182 piping welds as an operating plant issue affecting all piping with or

without approved LBB applications. To resolve this issue, the industry has taken the initiative to

(1) develop overall inspection and evaluation guidance, (2) assess the current inspection

technology, and (3) assess the current repair and mitigation technology. An interim industry

report, MP.WR Materials Reliability Project Interim Alloy 600 Safety Assessment for US PWR

Plants (MRP-44), Part 1. Alloy 821182 Pipe Butt Welds,"-was published in April 2001 to justify the

continued operation of PWRs while the industry completes the development of the final report.

The staff accepted this interim report in an SE dated June 14, 2001, stating that, "Should the

industry not be timely in resolving inspection capabilities to identify PWSCC in Alloy 600 welds,

regulatory action may result."

4.7A.4.3 FSAR Supplement

Section A3.6.4 of Appendix A to the LRA provides the applicant's FSAR supplement regarding

LBB for RCS piping. The plant design cycles in the applicant's LBB analysis are consistent with

those used in the fatigue-crack growth analysis, and they bound the period of extended

operation. In addition, the applicant's appropriate c66sideration of thermal aging of the CASS

material constitutes the basis for the staffs acceptance of the applicant's evaluation of the LBB

TLAA for the period of extended operation. On the basis of its review of the FSAR supplements,

the staff concludes that the summary description of the applicant's TLAA evaluation to address

LBB for the period of extended operation is adequate and satisfies 10 CFR 54.21 (d).

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4.7A.4.4 Conclusion

The staff concludes that, pursuant to 10 CFR 54.21 (c)(1 )(ii), the applicant has provided an

acceptable demonstration that, for the TLAA on LBB of the RCS main-loop piping, the analysis

will remain valid for the period of extended operation, and the applicant can adequately manage

the effects of aging on the pressure boundary function for the period of extended operation. The

staff also concludes that the FSAR supplements contain an adequate summary description of

the evaluation of the TLAA for LBB, as required by 10 CFR 54.21(d). The applicant reviewed

and found the number and characteristics of cycles identified in' CEN-367-A to be acceptable for

the period of extended operation for the RCS piping at Millstone Unit 2.

4.7B Unit 3 Other Plant-Soecific Time-Limited Aging Analyses

4.7B.1 Crane Load Cycle Limit

4.7B.1.1 Summary of Technical Information in the Application

In LRA Section 4.7.1, the applicant identified the following examples of the types of cranes

determined to be within the scope of license renewal. These cranes'were designed in

accordance with the guidance contained in NUREG-0612 'Control of Heavy Loads in Nuclear

Power Plants."

* containment polar crane

* spent fuel crane

* monorails

* jib cranes

NUREG-0612 requires that the design of heavy-load, overhead handling systems meets the

intent of CMAA-70. Overhead cranes designed to CMAA-70 have an implicit fatigue design

basis, equivalent to a limiting number of 100,000 load cycles.

The most frequently used crane is the spent fuel crane. The spent fuel crane is expected to

experience approximately 15,500 load cycles over a 60-year period for the movement of spent'

fuel from the reactor to the spent fuel pool. In addition, the crane is used in support of other

activities including fuel shuffles, and' inspections. In supporting these uses, the spent fuel crane

is expected to conservatively experience a total of 31,000 load cycles over a 60-year period.

This number is well below the 100,000 load cycles allowed in CMAA-70.

4.7B.1.2 Staff Evaluation

The most frequently used'crane is the spent fuel crane. This crane is projected to lift 31,000 load

cycles over a 60-year period for Unit 3. In RAI 4.7.1-1 the staff requested the applicant to

provide the basis for arriving 'at this projected figure of 31,000 cycles.

In its supplemental response dated January 11, 2005, the applicant stated:

"The Millstone Unit 3 spent fuel pool crane is the most frequently used crane of those

cranes within the scope of license renewal. As such, the spent fuel pool crane would

.11

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experience the highest number of load cycles over the period of extended operation. The

capacity of the Unit 3 spent fuel pool crane is 6,000 pounds. A fuel assembly with its

associated rigging weighs approximately 2,000 pounds.

Assuming full-core off-loads and subsequent reloading of the 193 fuel assemblies every

1.5 years, the spent fuel pool crane will experience 15,440 lifts (or load cycles) over a

60-year period.

193 X 2 lifts/cycle X I cycle/1.5 years X 60 years = 15,440 lifts

The spent fuel pool crane is also used to support other activities including fuel shuffles

and inspections. Considering all of these uses, the spent fuel pool crane is expected to

conservatively experience a total of 31,000 lifts (i.e., 15,440 lifts X 2) over a 60-year

period. This number is well below the allowable number of 100,000."

The staff finds the applicant's response reasonable and acceptable because the applicant has

provided a satisfactory basis for determining the projected number of lifts.

Considering all the uses, the spent fuel crane is likely to experience a total of 31,000 load cycles

over a 60-year period. This number is well below the design load cycles of 100,000, and

therefore acceptable. A similar conclusion based on projected load cycles being well below the

number of design load cycles is applicable for the other cranes within the scope of license

renewal.

4.7B.1.3 FSAR Supplement

In Appendix A, Section A3.5.1 of the application, the applicant provided a summary description'

of the evaluation of the crane load cycle limit. The applicant stated that the load cycles for these

cranes were evaluated for the period of extended operation. For each crane, the projected load

cycles through the period of extended operation will be less than the design load cycles and,

therefore, all cranes in the scope of license renewal will continue to perform their intended

function throughout the period of extended operation. On the basis of staff's review, the staff

concludes that the applicant's description is sufficient to satisfy the requirements of 54.21 (d).

4.7B.1.4 Conclusion

The staff has reviewed the information in Section 4.7.1 and Appendix A, Section A3.5.1 of the

LRA, as well as the additional information discussed by the applicant in its response to staff's

request for additional information. On the basis of the review discussed above, the staff

concludes that the applicant has provided adequate'information to meet the 'requirements of

10 CFR 54.21 (c)(1), option (ii) related to the TLA for-the crane load cycle limits.

. .

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4.7B.2 Reactor Coolant Pump Flywheel

4.7B.2.1 Summary of Technical Information in the Application

In Section 4.7.2 of the Millstone Unit 3 LRA, the applicant addresses its analysis of fatigue-crack initiation and growth for the reactor coolant pump (RCP) flywheel.

The RCP motors are provided with flywheels to increase rotational inertia, thus prolonging pump coast-down and assuring a more gradual loss of primary coolant flow to the core in the event

that pump power is lost. During normal operation, the RCP flywheels develop sufficient kinetic

energy to produce high-energy missiles in the event of failure. Conditions that may result in

overspeed of the pump increase both the potential for failure and the kinetic energy of the flywheel. These concerns led the NRC to issue RG 1.14, "Reactor Coolant Flywheel Integrity," Revision 1, August 1975. One of the recommendations of RG 1.14 is to volumetrically inspect the flywheels at 3- and 10-year intervals.

An evaluation was performed of the likelihood of flywheel failure over a 60-year period of operation and a justification was developed for the relaxation of RG 1.14, Revision 1, Regulatory Position C.4.b(2). The NRC has reviewed and accepted the topical report WCAP-14535-A, subject to certain conditions, for referencing in license applications. Using this evaluation, the NRC issued Amendment Number 169 for the Millstone Unit 3 RCP flywheel inspection frequency. The amendment allows Millstone Unit 3 to examine each of the RCP flywheels at least once every 10 years, coinciding with the ASME Section Xl inservice inspection program.

The applicant concluded that the evaluation of the RCP flywheels represents a TLAA per 10 CFR 54.3 since it involves the use of time limited assumptions such as thermal cycles and

crack growth rates. Consistent with 10 CFR 54.21 (c)(1)(iii), the applicant concluded that the RCP flywheel fatigue will be adequately managed by the Inservice Inspection Program: Systems, Components and Supports for the period of extended operation.

4.7B.2.2 Staff Evaluation

In Section 4.7.2 of the Millstone Unit 3 LRA, the applicant describes an analysis of fatigue-crack initiation and growth for the RCP flywheel. The staff reviewed this section to determine whether

the applicant provided adequate information to meet the requirements of 10 CFR 54.21 (c)(1), as the information relates to the TLAA for the RCP flywheel.

To reduce the RCP flywheel inspection frequency, Millstone Unit 3 submitted an amendment to its TS in a letter dated February 10, 1999. The amendment justification referenced the

Westinghouse Topical Report WCAP-14535-A, "Topical Report on Reactor Coolant Pump Flywheel Inspection Elimination," which was approved by the NRC with certain conditions. The

conditions are specified in the NRC's SER dated September 12, 1996. The crack growth calculations were based on an assumed 6,000 cycles of RCP startups and shutdowns for a

60-year plant life. The LRA states that the number of cycles from actual plant operating conditions through the end of the period of extended operation is expected to be much less that

the assumed 6,000 cycles.

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In the applicant's response to RAI 4.7.2, dated December 3, 2004, the applicant stated that the

RCP is expected to experience a total of 272 startup/shutdown cycles including the period of

extended operation. The 6,000 cycles are considered to represent a conservative number of

RCP startups/shutdowns for a 60-year period of operation. Assuming the presence of a large

initial crack, additional crack growth after 6,000 startup/shutdown cycles of 0.08 inches is

considered small.

The applicant's fatigue-crack growth analysis for the RCP flywheels demonstrates that the

postulated flaw in the analysis is not expected to grow in excess of the critical crack size, even

when the flywheels have been subjected to the change in the stress-intensity factor for the

flywheels associated with 6,000 RCP startup/shutdown cycles. Since this bounds the number of

RCP startups/shutdown cycles assumed for both the current operating period and the proposed

period of extended operation, the staff concludes that the fatigue-crack growth analysis for the

RCP flywheels meets the acceptance criterion for TLAAs in 10 CFR 54.21 (c)(1)(ii), in that the

analysis remains bounding for the period of extended operation.

4.7B.2.3 FSAR Supplement

Section A3.5.2 of Appendix A to the LRA provides the applicant's FSAR supplement regarding RCP flywheel provides a summary description consistent with the staff's evaluation discussed in

Section 4.7.2.2 of this SER. The FSAR supplement summary description for the TLAA on the

RCP flywheel is therefore acceptable to the staff, and satisfies the criterion for FSAR

supplement summary descriptions in 10 CFR 54.21 (d).

4.7B.2.4 Conclusion

The staff concludes that the applicant has provided an acceptable demonstration pursuant to

10 CFR 54.21 (c)(1)(ii) that, for the TLAA on the RCP flywheel, the analysis remains valid for the

period of extended operation and consistent with 10 CFR 54.21 (c)(1)(iii), RCP flywheel fatigue

cracking can be adequately managed by the Inservice Inspection Program: Systems, Components and Supports for the period of extended operation.

The staff also concludes that the FSAR supplement contains an adequate summary description

of this TLAA evaluation for the period of extended operation, as required by 10 CFR 54.21 (d).

4.7B.3 Leak-Before-Break

4.7B.3.1 Summary of Technical Information In the Application

The applicant stated that a LBB analysis has been performed for Millstone Unit 3 RCS primary

loop. The'analyses for Millstone Unit 3 is documented within topical report WCAP-1 0587, June

1984.

The fundamental premise of LBB is that the materials used in nuclear power plant piping are

sufficiently tough that even a large through-wall crack would remain stable and not result in a

double-ended pipe rupture.

4-57
The NRC modified 10 CFR Part 50 General Design Criterion (GDC) 4, uEnvironmental and Missile Design Bases," in 1987. This change allows applicants to exclude the dynamic effects of postulated ruptures in primary coolant loop piping in the design of PWRs if LBB criteria are met. The methodology and criteria developed by the NRC for preparing LBB analyses are described in NUREG-1061, Volume 3, and summarized within the Draft Standard Review Plan, Section

3.6.3, Leak-Before-Break Evaluation Procedures.

The applicant stated that consistent with 10 CFR 54.21 (c)(1)(ii), acceptable LBB evaluations have been projected to the end of the period of extended operation.

4.7B.3.2 Staff Evaluation

The applicant completed an evaluation of the RCS primary loop piping LBB analyses. The

evaluation is documented in WCAP-10587, "Technical Bases for Eliminating Large Primary Loop Pipe Ruptures as the Structural Design Basis for Millstone Unit 3."

WCAP-10587 provides a plant-specific LBB analysis for RCS piping at Millstone Unit 3 based on

a 40-year life of the nuclear power plant. The applicant stated that WCAP-1 0587 was reviewed and found acceptable for the period of extended operation. The staff review of WCAP-10587 found that additional information was needed to come to this conclusion. The applicant stated that "Millstone Unit 3 loads, material properties, transients and primary system geometry are enveloped by the parameters identified in WCAP-9558 and WCAP-1 0456." The staff review of these documents confirmed that they are based on a 40-year life of a nuclear power plant.

As such, the applicant needed to provide its LBB evaluations projected to the end of the period of extended operation. In accordance with GDC 4 and 10 CFR 54.21 (c)(1)(ii), the applicant must demonstrate that the analyses have been projected to the end of the period of extended operation. In addition, if other piping, other than the RCS primary loop piping, was covered by LBB analyses, the applicant needed to address the analyses in accordance with

10 CFR 54.21(c)(1). This was identified as Open Item 4.7.4-1. These analyses needed to be reviewed and approved by the staff pursuant to the acceptance criteria in Section 4.7.3.1.2 of NUREG-1800, which states that the documented results of the revised analyses are to be reviewed to verify that their period of evaluation is extended such that they are valid for the period of extended operation. The analyses needed to include the thermal aging on the material properties of cast austenitic stainless steel and the effects on the fatigue crack growth analysis. The methodology and criteria developed by the NRC for preparing LBB analyses are described

in NUREG-1061, Volume 3, and NUREG-0800, Standard Review Plan, Section 3.6.3, Leak- Before-Break Evaluation Procedures which were established after the applicant's topical report WCAP-10587.

By letter dated February 8, 2005, the applicant provided additional information to address Open Item 4.7.4-1. The applicant stated that for Millstone Unit 3, the reactor coolant system loop piping (hot leg, cold leg and crossover piping) has been evaluated for LBB. The materials

evaluated for these components include carbon and low alloy steels, stainless steel (including CASS), and nickel-based alloys.

CASS used in the RCS are subject to thermal aging during service. Thermal aging causes an elevation in the yield strength of the material and a decrease in the fracture toughness. The

4-58
decrease in fracture toughness is proportional to the level of ferrite in the material. Thermal

aging in these stainless steels will continue until a saturation or fully aged point is reached. The

applicant needed to address how fatigue will be evaluated or monitored to assure that the

number of cycle counts for a transient set do not exceed its cycle limits which could invalidate

the fatigue crack growth analysis. By letter dated February 8, 2005, the applicant provided

information to address the LBB analyses for Millstone Unit 3. The applicant stated that each of

the LBB analyses associated with these systems and components were evaluated for the period

of extended operation. The discussion for the reactor coolant loop piping is intended to envelope

all of the current design basis LBB analyses. The materials evaluated for the subject

components include carbon and low alloy steels, stainless steel (including cast austenitic

stainless steel (CASS)) and nickel-based alloys. For each LBB analysis, the inputs to the -

evaluation were reviewed to identify time-limited assumptions. Thermal aging of CASS materials

and fatigue crack growth calculations were determined to be time-based inputs as defined in 10

CFR 54.3 and required evaluation for the period of extended operation. The TLAA evaluations of

metal fatigue are discussed in LRA Section 4.3.1 and the staffs evaluation is provided in

Section 4.3 of this report. The metal fatigue TLAA evaluations conclude that design basis limits

are not exceeded for ASME Class 1 components (which envelopes the components evaluated

for LBB) through the period of extended operation. Thermal aging of CASS materials for

components that have been evaluated for LBB has been evaluated for its effect on fracture

toughness. The applicant's review concluded that the analysis used fully aged values for fracture

toughness. Corrosion of nickel-based alloys was also considered. Cracking due to PWSCC of

nickel-based alloys is managed by the Inservice Inspection Program: Systems, Components,

and Supports AMP described in LRA Section B2.1 .1 8. Millstone Unit 3 has committed to follow

the industry recommendations related to nickel-based alloys. This commitment is identified in

Appendix A, Table A6.0-1, License Renewal commitments, Item 15. The staff finds that the

applicant has provided an adequate demonstration that the TLAA for LBB evaluations for the

subject components remain valid or have been projected to the end of the period of extended

operation. Therefore, the staff concludes that Open Item 4.7.4.1 is closed.

4.7B.3.3 FSAR Supplement

Section A3.5.3 of Appendix A to the LRA provides the applicant's FSAR supplement regarding

LBB for RCS piping. The FSAR supplement states, "The acceptability of eliminating Reactor

Coolant System pipe LBB considerations for Millstone Unit 3 is contained within Westinghouse

Topical Report WCAP-1 0587. The report has been re-evaluated and to be applicable for the

period of extended operation." This paragraph was not clear on how the report was re-evaluated

and why it is acceptable for the period of extended operation. In addition, the statement was not

clear on what considerations are acceptable to be eliminated. The applicant needed to include in

the summary how the report was re-evaluated and why it is applicable for the period of extended

operation. The applicant also needed to address how thermal aging of CASS is supported in

WCAP-1 0587 for the period of extended operation and how the fatigue-crack growth analysis is

acceptable for the period of extended operation. On the basis of its review of the FSAR

supplements, the staff concluded that the summary description of the applicant's TLAA

evaluation to address LBB for the RCS piping for the period of extended operation required

additional clarification to satisfy 10 CFR 54.21(d). This was identified as Confirmatory

Item 4.7.4-1.

4-59 .-
By letter dated April 1, 2005, the applicant provided the requested update to Section A3.5.3 of- Appendix A to provide a summary description of the evaluation of the TLAA for LBB. The staff reviewed the revised summary description and finds that the revised summary description of the applicant's TLAA evaluation to address LBB for the period of extended operation is now adequate and satisfies 10 CFR 54.21(d). Based on the above, Confirmatory Item 4.7.4-1 is closed.

4.7B.3.4 Conclusion

The staff concludes that, pursuant to 10 CFR 54.211(c)(1), the applicant has provided an acceptable demonstration that, for the TLAA on LBB, will remain valid for the period of extended operation, and that the applicant will adequately manage the effects of aging on the pressure - boundary function for the period of extended operation. The staff also concludes that the FSAR supplement contains an adequate summary description of the evaluation of the TLAA for LBB, as required by 10 CFR 54.21(d).

4.8 Conclusion for Time-Limited Aging Analyses

The staff has reviewed the information in LRA Section 4, "Time-Limited Aging Analysis." On the basis of its review, the staff concludes that the applicant has provided an adequate list of TLAAs, as defined in 10 CFR 54.3. Further, the staff concludes that the applicant has demonstrated that (1) the TLAAs will remain valid for the period of extended operation, as required by 10 CFR 54.21 (c)(1)(i), (2) the TLAAs have been projected to the end of the period of extended operation, as required by 10 CFR 54.21(c)(1)(ii), or (3) that the aging effects will be adequately managed for the period of extended operation, as required by 10 CFR 54.21 (c)(1)(iii). The staff has also reviewed the FSAR supplement for the TLAAs and finds that the FSAR supplement contains descriptions of the TLAAs sufficient to satisfy the requirements of 10 CFR 54.21(d). In addition, the staff concludes that no plant-specific exemptions are in effect that are based on TLAAs, as required by 10 CFR 54.21(c)(2).

With regard to these matters, the NRC staff has concluded that there is reasonable assurance that the activities authorized by the renewed licenses will continue to be conducted in accordance with the current licensing basis, and that any changes made to the MPS current licensing basis in order to comply with 10 CFR 54.29(a) are in accord with the Act and the Commission's regulations. t

I

4-60
5. REVIEW BY THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS

The NRC staff issued its Safety Evaluation Report (SER) with Open Items related to the renewal

of operating licenses for the Millstone Power Station (MPS), Units 2 and 3, on

February 24, 2005. On April 6, 2005, the applicant presented its license renewal applications,

and the staff presented it review findings to the Advisory Committee on Reactor Safeguards

(ACRS) Plant License Renewal Subcommittee. The staff reviewed the applicant's comments on

the SER with Open Items and completed its review of the license renewal applications.- The

staffs evaluation is documented in an SER that was issued by letter dated August 1, 2005.

During the 524th meeting of the ACRS, September 8-10, 2005, the ACRS completed its review of

the MPS license renewal application and the NRC staff's SER. The ACRS documented its

findings in a letter to the Commission dated September 22, 2005. A copy of this letter is

provided on the following pages of this SER Section.

5-1
ACRSR-2150

September 22, 2005

The Honorable Nils J. Diaz

Chairman

U. S. Nuclear Regulatory Commission

Washington, DC 20555-0001

SUBJECT: REPORT ON THE SAFETY ASPECTS OF THE LICENSE RENEWAL

APPLICATIONS FOR THE MILLSTONE POWER STATION, UNITS 2 AND 3

Dear Chairman Diaz:

During the 5256h meeting of the Advisory Committee on Reactor Safeguards (ACRS), September 8-10, 2005, we completed our review of the license renewal applications for the Millstone Power Station (MPS), Units 2 and 3 and the final Safety Evaluation Report (SER) prepared by the NRC staff. Our Plant License Renewal Subcommittee also reviewed this matter during a meeting on April 6, 2005. During these reviews, we had the benefit of discussions with the staff, Dominion Nuclear Connecticut, Inc. (DNC), and a member of the public representing the Connecticut Coalition Against Millstone. We also had the benefit of the documents referenced. This report fulfills the requirements of 10 CFR 54.25, which requires that the ACRS review and report on all license renewal applications.

CONCLUSION AND RECOMMENDATION

(1) The programs committed to and established by the applicant to manage age-related degradation provide reasonable assurance that MPS, Units 2 and 3 can be operated in accordance with their current licensing basis for the period of extended operation without undue risk to the health and safety of the public.

(2) DNC's applications for renewal of the operating licenses for MPS, Units 2 and 3 should be approved.

BACKGROUND AND DISCUSSION

Millstone Power Station consists of three nuclear units on a 500-acre site on the north shore of Long Island Sound in the town of Waterford, Connecticut. Each of the three Millstone units was supplied by a different nudear steam supply system vendor. Unit 1, a Mark 1 boiling water reactor which was shut down in the late 1990s, is not the subject of the license renewal applications being considered here. Unit 2 is a 2700 MWt (895 MWe) 4-loop (two steam generators) Combustion Engineering pressurized water reactor (PWR). Unit 3 is a 3411 MWt (1195 MWe) 4-loop Westinghouse PWR. The applicant has requested renewal of the current operating licenses for Units 2 and 3 for an additional 20 years beyond their current terms, which expire on July 31, 2015, and November 25, 2025, respectively.

I1

5-2
Those long-lived passive structures, systems, and components (SSCs) from Unit 1 that service

Units 2 and 3 fall within the scope of this license renewal. Although DNC submitted separate

license renewal applications for Unit 2 and Unit 3, the staff consolidated its SER to address both

applications. Since the applicant will apply identical aging management programs (AMPs) to

both units, the staff's consolidation of the SER is appropriate.

In the final SER, the staff documented its review of the DNC's license renewal applications and

other information submitted by the applicant or obtained during the staff's audits and inspections

at the plant site. The staff reviewed the completeness of the applicant's identification of SSCs

that are within the scope of license renewal; the integrated plant assessment process; the

applicant's identification of plausible aging mechanisms associated with passive, long-lived

components; the adequacy of the applicant's aging management programs; and the

identification and assessment of time-limited aging analyses (TLAAs).

The DNC applications demonstrate consistency with, or justify deviations from, the approaches

specified in the Generic Aging Lessons Learned Report.

In its draft SER the staff identified a number of issues requiring further definition, analysis, or

modification by the applicant to satisfy the requirements of the license renewal rule. Among

these issues were the following:

The staff questioned the applicant's definition of the "first equivalent anchor point" for

determining the endpoint of nonsafety-related piping attached to safety-related systems

to be included within the scope of the rule. The applicant resolved this issue by changing

the definition of the "first equivalent anchor point. to be consistent with the current

licensing basis.

The staff questioned the applicant's neglect of effects other than thermal cycling, such as

vibration, that could lead to age-related loss of preload of bolting. The applicant modified

its Bolting Integrity Program to reflect such aging effects.

The staff questioned the exclusion of the reactor vessel flange leak detection lines in

Units 2 and 3 from the scope of license renewal. The applicant initially argued that the

break flow through a failed leak detection line would be limited by a restriction in the'

reactor vessel flange geometry to a flow less than the makeup capability of the chemical

and volume control system. However, the applicant finally decided to include the reactor

vessel flange leak detection lines within the scope of aging management, satisfying the

staffs concern.

The staff questioned the adequacy of the leak-before-break (LBB) analyses for Units 2

and 3 for the period of extended operation. The applicant submitted additional

information on the methods and assumptions used to update these analyses for the

period of extended operation. The current LBB analyses are for the reactor coolant

system loop piping and components, the pressurizer surge line, and portions of the

safety injection and shutdown cooling lines of Unit 2, and for the reactor coolant system

loop piping and components of Unit 3. The analyzed systems and components were

constructed of carbon and low-alloy steel, stainless steel [including cast austenitic

stainless steel (CASS)], and nickel-based alloys. TLAAs were performed that account for

fatigue crack growth, the thermal aging of CASS, and the corrosion of nickel-based

alloys. DNC demonstrated that the analyses for fatigue crack growth and thermal aging

of CASS, assuming fully aged materials, are adequate for the period of extended

5-3
operation. The corrosion of nickel-based alloys will be managed by the use of the

Inservice Inspection Program. In addition, DNC has committed to follow the industry

recommendations regarding the aging effects and appropriate aging management of

nickel-based alloys for Units 2 and 3 and to submit an aging management program at

least 24 months prior to entering the period of extended operation. These commitments

are documented in the SER.

Analyses of reactor vessel neutron embrittlement (upper shelf energy, pressurized thermal

shock screening criterion, and pressure-temperature limits) performed by the applicant and

independently verified by the staff demonstrate that the limiting reactor vessel beltline welds and

plate materials will satisfy the acceptance criteria for the period of extended operation. Both the

applicant and the staff chose to use a conservative lifetime capacity factor of 90 percent for

determining neutron fluence. We agree.

The staff requested confirmatory analyses or other technically justifiable responses to six

confirmatory issues. DNC has supplied information regarding these confirmatory items and the

staff has determined that the applicant's responses are satisfactory to close these confirmatory

items.

We agree with the resolution of all open items identified in the draft SER. DNC has made

appropriate commitments to carry out the tasks identified by the staff and agreed to by DNC to

satisfy outstanding issues related to these applications. The staff has included appropriate

license conditions in the SER to satisfy remaining documentation issues and action items.

DNC's applications for renewal of the licenses for MPS, Units 2 and 3 are of high quality and

DNC's responses to the staffs requests for additional information are thorough, timely, and

complete. The staffs evaluation is technically comprehensive and well documented in the SER.

The inspections and audits performed by the NRC staff for evaluating the applicant's proposed

and existing programs and analyses are effective. They reduce the amount of paperwork and

staff and applicant time needed to prepare and respond to written requests for additional

information.

No issues related to the matters described in 10 CFR 54.29(a)(1) and (a)(2) preclude renewal of

the operating licenses for MPS, Units 2 and 3. The programs committed to and established by

the applicant provide reasonable assurance that MPS, Units 2 and 3 can be operated in

accordance with their current licensing basis for the period of extended operation without undue

risk to the health and safety of the public. The applications for renewal of the operating licenses

for MPS, Units 2 and 3 should be approved.

Drs. Mario Bonaca and George Apostolakis did not participate in the Committee's deliberations

regarding this matter.

Sincerely,

IRAI

Graham B. Wallis

Chairman

11

5-4
References:

(1) U.S. Nuclear Regulatory Commission, "Safety Evaluation Report Related to the License

Renewal of the Millstone Power Station, Units 2 and 3," August 2005

(2) U.S. Nuclear Regulatory Commission, "Safety Evaluation Report with Open Items

Related to the License Renewal of the Millstone Power Station, Units 2 and 3,"

February 2005

(3) Dominion Nuclear Connecticut, Inc., "Millstone Power Station Unit 2 Application for

Renewed Operating License Technical and Administrative Information," January 2004

(4) Dominion Nuclear Connecticut, Inc., 'Millstone Power Station Unit 3 Application for

Renewed Operating License Technical and Administrative Information," January 2004

(5) U.S. Nuclear Regulatory Commission, "Millstone Power Station Unit 2 and Unit 3 -

License Renewal Application Inspection Report Nos. 05000336/2004009,

05000423/2004009," December 3, 2004

(6) U.S. Nuclear Regulatory Commission, 'Millstone Power Station Unit 2 and Unit 3 -

License Renewal Application Inspection Report Nos. 05000336/2004010,

05000423/2004010," December 3, 2004

(7) Information Systems Laboratories, Inc., "Audit and Review Report for Plant Aging

Management Reviews and Programs, Millstone Power Station - Units 2 & 3," February 2,

2005

(8) Letter to Graham Wallis, Chairman, Advisory Committee on Reactor Safeguards, from

Nancy Burton, Connecticut Coalition Against Millstone, Subject: Millstone Nuclear Power

Station, September 7, 2005

(9) Letter to the Advisory Committee on Reactor Safeguards from Nancy Burton,

Connecticut Coalition Against Millstone, Subject: Millstone Nuclear Power Station

Application for License Renewal, April 5, 2005

(10) Letter to Paul G. Kroh, Chief Inspector, Region I, U.S. Nuclear Regulatory Commission,

from Nancy Burton, Connecticut Coalition Against Millstone, Subject: Millstone Nuclear

Power Station, April 1, 2005

5-5
-

6. CONCLUSIONS

The staff of the U.S. Nuclear Regulatory Commission (NRC or the Commission) reviewed the

license renewal applications for the Millstone Power Station, Units 2 and 3, in accordance with

Commission regulations and NUREG-1800, 'Standard Review Plan for Review of License

Renewal Applications for Nuclear Power Plants," dated July 2001. Title 10, Section 54.29, of the

Code of Federal Regulations (10 CFR 54.29) provides the standards for issuance of a renewed

license.

On the basis of its evaluation of the license renewal applications, the NRC staff concludes that

the requirements of 10 CFR 54.29(a) have been met and all open items and confirmatory items

of the safety evaluation report have been resolved.

The staff notes that any requirements of Subpart A of 10 CFR Part 51 are documented in

Supplement 22 to NUREG-1437 "Generic Environmental Impact Statement for License Renewal

of Nuclear Plants: Regarding Millstone Power Station, Units 2 and 3 Final Report," dated

July 18, 2005.

6-1
APPENDIX A: COMMITMENTS FOR LICENSE RENEWALS OF

MPS Units 2 and 3

During the review of the Millstone Power Station, Units 2 and 3, LRAs by the NRC staff, the

applicant made commitments related to aging management programs (AMPs) to manage aging

effects of structures and components (SCs) prior to the periods of extended operation. The

following tables list these commitments, along with the implementation schedules and the

sources of the commitment.

A-1
~~~~ ~~APPENIiXA~:COMMIll~TMENTS FOR LICENSE: RENJEWJJAL. OJF IVPS.,UNIT 2.;!;si:If1.;«,:

4 - , i Co'5 mm~mei t<,'; i1.;, ~' :E -ic r4a A;;pindix A srnleenia: w So1urc i N-A' i nL -m

.... ...... Sched

1 The existing inspection program will be A2.1.1, Battery Prior to Period of LRA Appendix B,

modified to include those battery racks Rack Inspection Extended Section B2.1.1

that require monitoring for license Operation

renewal, but are not already included in

the program.

2 Implementing procedures will be modified to include A2.1.1, Battery Prior to Period of LRA Appendix B,

loss of material as a potential aging effect and to Rack Inspection Extended Section B2.1.1

provide guidance on the inspection of items (such as Operation

anchorages, bracing and supports, side and end rails,

and spacers), which contribute to battery rack

integrity or seismic design of the battery racks.

3 A baseline inspection of the in-scope buried piping A2.1.4, Buried Prior to Period of LRA Appendix B,

located in a damp soil environment will be performed Pipe Inspection Extended Section B2.1.4

for a representative sample of each combination of Program Operation

material and protective measures. July 7, 2004, LRA

Supplement

Inspection for the loss of material due to selective Attachment 1,

leaching will be performed by visual, and mechanical Page 12

or other appropriate methods.

A-3
.1., ;'APPENDIX A."'CAMMITMENTS FOR LICENSE~RN S!UNjT2;vir .. .. .WA...M ,.... UNIT- - l- ..

Item t A i ; Commitment LRA-- Appendix A Implemed n Sorc No. 1 1 .*,~Schedule

4 The maintenance and work control procedures will be A2.1.4, Buried Prior to Period of LRA Appendix B,

revised to ensure that inspections of buried piping are Pipe Inspection Extended Section B2.1.4

performed when the piping is excavated during Program Operation

maintenance or for any other reason. July 7, 2004, LRA

Supplement These procedures will include the inspection for the Attachment 1,

loss of material due to selective leaching which will be Page 12

performed by visual, and mechanical or other

appropriate methods.

5 The Electrical Cables and Connections A2.1.8, Electrical Prior to Period of LRA Appendix B,

Not Subject to 10 CFR 50.49 Cables and Extended Section B2.1.8

Environmental Qualification Connectors Not Operation

Requirements program will be Subject to 10

established. CFR 50.49

Environmental

Qualification

Requirements

6 Fuse holders meeting the requirements will be A2.1.8, Electrical Prior to Period of LRA Appendix B,

evaluated prior to the period of extended operation for Cables and Extended Section B2.11.8

possible aging effects requiring management. The Connectors Not Operation

fuse holder will either be replaced, modified Subject to 10 February 15,

to minimize the aging effects, or this program will CFR 50.49 Completed 2005 Letter

manage the aging effects. The program (if needed for Environmental Attachment, Page

fuse holders) will consider the aging stressors for the Qualification 4

metallic clips. Requirements

A-4
i, '"""'i'PPENDIXA FR ROMMiTMENT LiCENSE RENEWAL OF2MPS UNIT 2- - i i Ki1 f.

i tj1v -, . i.,.'..S ..~ LRA. hed ie . -r.

ComitAntAppend xX A ImplemenaIonSuc

7 Procedures will be developed to employ an alternate A2.1.9, Electrical Prior to Period of LRA Appendix B,

testing methodology to confirm the condition of cables Cables Not Extended Section B2.1.9

and connectors in circuits that have sensitive, low Subject to 10 CFR Operation

level signals and where the instrumentation is not 50.49

calibrated in situ. - - Environmental Not to Exceed a 10

Qualification Year Frequency

Requirements Thereafter

Used in

Instrumentation

Circuits

8 A baseline visual inspection will be performed on a A2.1.10, Fire Prior to Period of LRA Appendix B,

representative sample'of the buried fire protection Protection Extended Section B2.1.10

pipinig and components, whose internal surfaces are Program Operation

exposed to raw water, to 'confirm'there is no

degradation. :'' ' '_.

9 Testing a representative sample'of fire protection A2.1.10, Fire Prior to the Sprinkler LRA Appendix B,

sprinkler heads or replacing those that have been in Protection Heads Achieving 50 Section B2.1.10

service for 50 years will be included in the Fire Program Years of Service Life

Protection Program. July 7, 2004, LRA

Not to Exceed a 10 Supplement

Year Frequency Attachment 1,

Thereafter Page 1

A-5
AP, PENDIX.r-A-c.COMMITME'*' EWL01A- WT'Z

Commitment 7 t jwj- t ~~~~~~~- .,; 4; i4.i > 1 e ;' ; ,'

v; LRA Akppendix*.A

:' . .. -... . : ;'. ' . ': a:' . . :'. ; . :

-.. ,'-' .,. - ... .... :' _.. _.:.....-.,,,, ,mplemntation i . Schedule'. ' ',

", ! Source;6.i,

' ; ;, ', . '.j',' 4?J,>

4 I 4.

The procedures and training for personnel performing

General Condition Monitoring inspections and

walkdowns will be enhanced to provide expectations

that identify the requirements for the inspection of

aging effects.

A2.1.13, General

Condition

Monitoring

Prior to Period of

Extended

Operation

LRA Appendix B,

Section B2.1.13

I I In-scope cable found to be submerged will be subject

to an engineering evaluation and corrective action.

The evaluation of cables having significant voltage

found to be submerged in standing water for an

extended period of time will be based on appropriate

testing (using available technology consistent with

NRC positions) of cables that are determined to be

wetted for a significant period of time. The

Engineering evaluation will also address the

appropriate testing requirements for the

corresponding ten-year intervals during the period of

extended operation. The test will use a proven

methodology for detecting deterioration of the

insulation system due to wetting. Examples of such

tests include power factor, partial discharge, or

polarization index, as described in EPRI TR-103834-

P1-2, Effects of Moisture on the Life of Power Plant

Cables, or other appropriate testing. Testing will have

acceptance criteria defined in accordance with the

specific test identified. Occurrence of degradation that

is adverse to quality is entered into the Corrective

Action Program.

A2.1.14,

Inaccessible

Medium-Voltage

Cables Not

Subject to 10 CFR

50.49

Environmental

Qualification

Requirements

Prior to Period of

Extended

Operation

During the

Corresponding

10 Year Interval

(If Applicable)

July 7, 2004

LRA Supplement

Attachment 1,

Page 17

_

A-6

---
' '.';':'.:',:.';''' '; ';.APPENDIX A: COPRIITENTS FOR LICENSE RENEWAL OF, MP&SUNIT2:,j ; ; ''.'i ' ".

Itet'i , . M -''`RA Le Appendix-' AIIImplemenitto I' if: --, ,- Source; ..; -, .... 'ii" . . . Se e .

12 The Infrequently Accessed Areas A2.1.15, Prior to Period of LRA Appendix B,

Inspection Program will be established. Infrequently Extended Section B2.1.15

Accessed Areas Operation

. .Inspection

. .. ' Program

13 Millstone will follow the industry efforts on reactor A2.1.17, Inservice At Least Two Years LRA Appendix B,

vessel Internals regarding such issues as thermal or Inspection Prior to Period of Section B2.1.17

neutron irradiation embrittlement (loss of fracture Program: Reactor Extended

toughness), void swelling (change in dimensions), Vessel Internals Operation July 7, 2004, LRA

stress corrosion cracking (PWSCC and IASCC), and Supplement

loss of pre-load for baffle and former-assembly bolts Attachment 1,

and will implement the appropriate recommendations Page 1

resulting frotm this guidance.' - ' ''eb' ' ' 8, 2

''.February 8, 2005

-Th6'revised prograMndescription, including a-'' ' ' . . LRA Supplemeht'

comparison to the 10 program elements of the Attachment 2,

NUREG-1 801 program, will be submitted to the NRC Page 30

for approval.

A-7
.,PEDIX .OMMITENTS A. P

. ;' .'So' i re., .

I LR ppendix A- Impiemientation, Source#., ..W .: 4 ;;l .(

14 Millstone will follow the industry efforts investigating A2.1.18, Inservice At Least Two Years LRA Appendix B, the aging effects applicable to nickel-based alloys Inspection Prior to Period of Section B2.1.18

(i.e., PWSCC in Alloy 600 base metal and Alloy Program: Extended

82/182 weld metals) and identifying the appropriate Systems, Operation April 1, 2005

aging management activities and will implement the Components and Attachment 2, appropriate recommendations resulting from this Supports Page 8

guidance. The revised program description will be

submitted prior to the period of extended operation for A2.1.22, Steam

staff review and approval to determine if the program Generator

demonstrates the ability to manage the effects of Structural Integrity

aging in nickel based components per

10 CFR 50.54.21(a)(3).

15 The existing inspection program will be modified to A2.1.19, Prior to Period of LRA Appendix B, include those lifting devices that require monitoring for Inspection Extended Section B2.1.19

license renewal, but are not already included in'the Activities: Load Operation

program. Handling Cranes

and Devices

16 Implementing procedures and documentation will be A2.1.19, Prior to Period of LRA Appendix B,

modified to include visual inspections for the loss of Inspection Extended Section B2.1.19

material on the crane and trolley structural Activities: Load Operation

components and the rails in the scope of license Handling Cranes

renewal added in Commitment 15. and Devices

A-8
4, W'~-APPDIXfltA: . COMMITMENTS FO FRmaCNS ICE RENEWALF OFP NIT;2- , . i;

Itemi C Iomtmen2WKK L.,IAo Apendix A, ,lmhplemientatiolor' Surce

No,''' ,* '' Schedule1 ,!l

17 The implementing procedure will be modified to A2.1.23, Prior to Period of LRA Appendix B,

include American Concrete Institute (ACI) Standard Structures Extended Section B2.1.23

349.3R-96, "Evaluation of Existing Nuclear Safety Monitoring Operation

Related Concrete Structures," dated 1996, and Program

American Nuclear Standards Institute/American

Society of Civil Engineers (ANSI/ASCE) Standard

11-90, "Guideline for Structural Condition Assessment

of Existing Buildings," dated 1990, as references and

input documents for the inspection program.

18 The Structures Monitoring Program and Implementing A2.1.23, Prior to Period of LRA Appendix B,

procedures will be modified to include all In-scope Structures Extended Section B2.1.23

structures., . Monitoring Operation vxProgram

19 Groundwater samples will'be taken on a periodic' A2.1.23, Prior to Period of LRA Appendix B,

basis, considering seasonal variations, to ensure that Structures Extended Section B2.1.23.

the groundwater is not sufficiently aggressive to Monitoring Operation

cause the below-grade concrete to degrade. Program

20 The Structures Monitoring Program and implementing A2.1.23, Prior to Period of LRA Appendix B,

procedures will be modified to alert the appropriate Structures Extended Section B2.1.23

engineering organization if the structures Inspections Monitoring Operation

Identify that medium-voltage cables in the scope of Program

license renewal have been submerged.

A-9
:.2APE~lI~A.COMMITMENJTS FORICENSE~ RENEWAL-, OF IVMONIT 2.,...:

m ltomern0tm/nt:" Appendix Ai j',i Impementat*on 1

N 7 . Ig Schedule; -

21 The maintenance and work control procedures will be A2.1.23, Prior to Period of LRA Appendix B,

revised to ensure that inspections of inaccessible Structures Extended Section B2.1.23

areas are performed when the areas become Monitoring Operation

accessible by such means as excavation or Program installation of shielding during maintenance or for any

other reason.

22 Appropriate inspections of sealants and caulking used A2.1.24, Tank Prior to Period of LRA Appendix B,

for moisture intrusion prevention in and around Inspection Extended Section B2.1.24

aboveground tanks will be performed. Program Operation

23 Non-destructive volumetric examination of the A2.1.24, Tank Prior to Period of LRA Appendix B,

in-scope inaccessible locations, such as the external Inspection Extended Section B2.1.24

surfaces of tank bottoms, will be performed prior to Program Operation

the period of extended operation. Subsequent

inspections will be performed on a frequency A Frequency

consistent with scheduled tank internals inspection Consistent with

activities. Scheduled Tank

Internals Inspection

Activities

24 The security diesel fuel oil tank and diesel fire pump A2.1.24, Tank Prior to Period of LRA Appendix B,

fuel oil tank are in-scope for license renewal and will Inspection Extended Section B2.1.24

be included on the respective Tank Inspection Program Operation

Program inspection plan.

A-10
*P A:''I COMMIMENTSFOR LICENSERENEWAL OF MPPS UNIT 2;

Ite~i~ iriiiiiri , -... .. ,i, .. -I4

f " 1: RA Appendix A', Impennaln~ 'ource~t Schedule

25 Changes will be made to maintenance and work A2.1.25, Work Prior to Period of LRA Appendix B,

control procedures to ensure that inspections of plant Control Extended Section B2.1.25

components and plant commodities will be Process Operation

appropriately and consistently performed and

documented for aging effects during maintenance

activities.

26 Dominion actively participates in a comprehensive Environmental Prior to Period of Environmental

industry initiative, In response to NRC Generic Issue Report Extended Report - SAMA

23 (GI-23), uReactor Coolant Pump Seal Failure." Operation Analysis

Dominion is following the Industry efforts on this issue

and will implement the appropriate recommendations

resulting from this guidance prior to the period of

extended operation.' - ^ ' -

27 For potentially susceptible CASS materials, either A2.1.18, Inservice Prior to Period of July 7, 2004, LRA

enhanced volumetric examinations or a unit or Inspection Extended Supplement

component specific flaw tolerance evaluation Prograrri. Operation Attachment 1,

(considering reduced fracture toughness and unit Systems, Page 5

specific geometry and stress information) will be used Components and

to demonstrate that the thermally-embrittled material Supports

has adequate fracture toughness in accordance with

NUREG-1801 Section XI.M12.3.

A-1I
*<;.,~..J ~*..;z-:.t~n,:zf~~ ~ .sr APFEDI~-A:'OMMTMENS . FR FORL..IUJ....[SPS.... LIENSRENE JA1OF P.U

lte~ ;; : Commtme; ' -.;:". .?RA -,p l c A II; . ,,rc lem , aion 

1wt~~~s ~. ~., '.. rœ.oSi;hedule';q

28 Millstone will follow industry efforts that will provide A3.2.3 Prior to the Period of July 7, 2004, LRA

specific guidance to license renewal applicants for Environmentally Extended Operation Supplement evaluating the environmental effects of fatigue on Assisted Fatigue Attachment I

applicable locations, other than those identified in

NUREG/CR-6260. Millstone will also implement the

appropriate recommendations resulting from this

guidance. -

29 A baseline visual inspection will be performed of the A2.1.7, Closed- Prior to Period of July 7, 2004, LRA

accessible areas of the shell side (including Cycle Cooling Extended Supplement accessible portions of the exterior side of the tubes) Water System Operation Attachment 1,

of one: Page 6

* .Millstone Unit 2 Reactor Building Closed

Cooling Water heat exchanger,

* Millstone Unit 2 Emergency Diesel Generator

Jacket Cooling Water heat exchanger, and

* Millstone Unit 3 Emergency Diesel Generator

Jacket Cooling Water heat exchanger.

30 Using the Work Control Process, a baseline A2.1.25, Work Prior to Period of July 7, 2004, LRA

inspection for the loss of material due to selective Control Process Extended Supplement leaching will be performed on a representative sample Operation Attachment 1, of locations for susceptible materials by visual, and Page 14

mechanical or other appropriate methods

A-12

- - - - - - - - - -- a
fi -~~~OFMP UNT -. ~~~ ~ ~ . ........ .. - -urm . 1 A' 2 .. ,

Ite;d ,.m;.-tmAnt LRA Appenidix A Irnpeenain Suc

31 A review of the Work Control Process inspection A2.1.25, Work Prior to Period of July 7, 2004, LRA

opportunities for each material and environment Control Process Extended Supplement

group, supplemental to the initial review conducted Operation Attachment 1,

during the development of the LRA, will be performed. Page 20

Baseline inspections will be performed for the material

and environment combinations that have not been

inspected as part of the Work Control Process.

32 Calibration results for cable tested in situ will be A2.1.9, Electrical Prior to Period of December 3,

reviewed to detect severe aging degradation of the Cables Not - Extended 2004, LRA

cable insulation. The initial review will be completed Subject to 10 CFR Operation Supplement

prior to enteriig' the period of extended operation and 50.49 Attachment 3,

will include6at least 5 years of'sur'veillance test data Environmental Not to Exceed a 10 Page 1

fdr'd-kh'6cable1'rviewe'd. S'ubseq'u6nt revieWs will be Qualification Year Frequency

perf6rmed'on6a period not to'exceed 10 years. Requirements Thereafter

- *Used in

Instrumentation

Circuits

33 The in scope cables in Unit 3 duct lines # 929 (SBO A2.1.14, Prior to Period of December 3,

Diesel to Unit 3 4.16kV Normal Switchgear) and # 973 Inaccessible Extended Operation 2004, LRA

(RSST 3RTXXSR-B to 6.9kV Normal Switchgear Bus Medium-Voltage Supplement

35A, 35B, 35C and 35D) will be tested to demonstrate Cables Not Not to Exceed a 10 Attachment 3,

that water'treeing will not prevent the cables from Subject to 10 CFR Year Frequency Page 3

performing their intended function 50.49 Thereafter

Environmental

Qualification

Requirements

A-13
PEN~ADMfIX A.COMMITMENTS:FOR0 LICESiEEWI~ ~~AAL,0FMPSaUNIT-l.

-1eNo. Comtet LR'A di'A< ipIementation -, .Suc~

34 In addition to the testing specified in Commitment 33, A2.1.14, Prior to Period of January 11,

a representative sample of in-scope medium-voltage Inaccessible Extended 2005, Attachment

cables will be tested to demonstrate that water treeing Medium-Voltage Operation 3, Page 1

will not prevent the cables from performing their Cables Not

intended function. Subject to Not to Exceed a 10

10 CFR 50.49 Year Frequency

Environmental Thereafter

Qualification

Requirements

35 Complete the SAMA evaluation of the capability to Environmental Prior to Period of August 13, 2004,

flash the Diesel Generator field in the event of Report Extended Operation RAI Responses, extended loss of DC power with a loss of offsite Page 2

power. If this SAMA is cost beneficial (i.e., can be

accomplished without a hardware modification), a

Severe Accident Management Guideline (SAMG)

addressing this mitigation strategy will be developed.

36 Dominion will replace the Millstone Unit 2 pressurizer A2.1.18, Inservice Prior to Period of February 8, 2005,

using materials that are resistant to PWSCC. Inspection Extended Operation Attachment 2,

Program: Page 33

Systems,

Components and

Supports

A-14
APPENDIX A' COMMITMENT'FOR LIEN ENEWAL _ _ _ _ _ _ _ _ _ F _ MPS _ _ _ UNIT _ _ _ _ _ ; _ ;; 4 ;: .1Jilt. :

- te' 4 - ' >,ir,, 1 a ,.,..Ii :'. * Ie N. u lCe. , . . .RA 0, Appeiandhix' A' '"Imp"l S e"lemefntat'n 

37 Updated USE, RTpTS, and P-T limits based on fluence A3.1 Reactor At Least Two Years February 8, 2005,

values developed in accordance with Regulatory Vessel Neutron Prior to Period of Attachment 2,

Guide 1.190 requirements, as amended or Embrittlement Extended Operation Page 11

superseded by future regulatory guidance changes,

will be submitted to the NRC for review. .

A-15
DIXA: COMMITMENTS FORIENSE REEAL~ _ '.OF UMSUNT31~ Ma ;.

I-,,i l ', ,j .nitm ,''.-AiAA j;Ir-tan'' l i

I The existing inspection program will be modified to A2.1.1, Battery Prior to Period of LRA Appendix B, include those battery racks that require monitoring for Rack Inspection Extended Section B2.1.1

license renewal, but are not already included in the Operation

program.

2 Implementing procedures will be modified to include A2.1.1, Battery Prior to Period of LRA Appendix B, loss of material as a potential aging effect and to Rack Inspection Extended Section B2.1.1

provide guidance on the inspection of items (such as Operation anchorages, bracing and supports, side and end

rails, and spacers), which contribute to battery rack

integrity or seismic design of the battery racks.

3 A baseline inspection of the in-scope buried piping A2.1.3, Buried Prior to Period of LRA Appendix B, located in a damp soil environment will be performed Pipe Inspection Extended Section B2.1.4

for a representative sample of each combination of Program Operation material and protective measures. July 7, 2004, LRA

Supplement Inspection for the loss of material due to selective Attachment 1, leaching will be performed by visual, and mechanical Page 12

or other appropriate methods.

A-16
-A:'COMMITMENTS~FOR LIES EEA OFMPSIUNI

= 'APPED TX R'LICENS pRNEWAL, IT CommitdentA Filrmplernentat LM on`~-

4 The maintenance and work control procedures will be A2.1.3, Buried Prior to Period of LRA Appendix B,

revised to ensure that inspections of buried piping are Pipe Inspection Extended Section B2.1.4

performed when the piping is excavated during Program Operation

maintenance or for any other reason. July 7, 2004, LRA

Supplement

These procedures will include the Inspection for the Attachment 1,

loss of material due to selective leaching which will Page 12

be performed by visual, and mechanical or other

appropriate methods.

5 The Electrical Cables and Connections A2.1.7, Electrical Prior to Period of LRA Appendix B,

Not Subject to 10 CFR 50.49 Cables and Extended Section B2.1.8

Environmental Qualification Connectors Not Operation

Rejquireme nts prbogram will be'' Subject to 10

established. - CFR 56.49

Environmental

Qualification

Requirements

6 Fuse holders meeting the requirements will be A2.1.7, Electrical Prior to Period of LRA Appendix B,

evaluated prior to the period of extended operation Cables and Extended Section B2.1.8

for possible aging effects requiring management. The Connectors Not Operation

fuse holder will either be replaced, modified Subject to 10 February 15, 2005

to minimize the aging effects, or this program will CFR 50.49 Completed Letter

manage the aging effects. The program (if needed for Environmental Attachment,

fuse holders) will consider the aging stressors for the Qualification Page 4

metallic clips. Requirements

A-17
- .". ,-.,,

-:*4'I-,ulX~A:'COMMITMENTS iyRL LCNERrEu OF MPS: UIT 3-

Impentaio ~Sourc '.;~: Item .j o;~ ~ 2 -; 2'~: chedule R~~ <tmN.. ,3 -** LRA h -' -Cmimn Appendix n* i:,l; A iImlenaon;: ''i: ! Suc-; ;

7 Procedures will be developed to employ an alternate A2.1.8, Electrical Prior to Period of LRA Appendix B,

testing methodology to confirm the condition of Cables Not Extended Section B2.1.9

cables and connectors in circuits that have sensitive, Subject to 10 CFR Operation

low level signals and where the instrumentation is not 50.49

calibrated in situ. Environmental Not to Exceed a 10

Qualification Year Frequency

Requirements

Used in'~

Instrumentation

Circuits

8 A baseline visual inspection will be performed on a A2.1.9, Fire Prior to Period of LRA Appendix B,

representative sample of the buried fire protection Protection Extended Section B2.1.10

piping and components, whose internal surfaces are Program Operation

exposed to raw water, to confirm there is no

degradation.

9 Testing a representative sample of fire protection A2.1.9, Fire Prior to the LRA Appendix B.

sprinkler heads or replacing those that have been in Protection Sprinkler Heads Section B2.1.10

service for 50 years will be included in the Fire Program Achieving 50 Years

Protection Program. of Extended Life July 7, 2004, LRA

Supplement

Not to Exceed a 10 Attachment 1,

Year Interval Page 1

Thereafter

A-18
I) APPENDIX A::COMMITMENTS FOR LICENSE'RENE-WALOFMPS UNIT 3~..'.; ... ,.::~

~ ;',<Commimen j LRA'A006endlic Impnllemenacnm ~ ;l~ ~ <

!.I I -'':.Idi 

10 The procedures and training for personnel performing A2.1.12, General Prior to Period of LRA Appendix B,

General Condition Monitoring inspections and Condition Extended Section B2. 113

walkdowns will be enhanced to provide expectations Monitoring Operation

that identify the requirements for the inspection of

____ ____ aging'effects. _ _ _ _ _ _ _ _ _

11 In-scope cable found to be submerged will be subject A2. 1.13, Prior to Period of LRA Appendix B,

to an engineering evaluation and corrective action. Inaccessible Extended Section B2.1 .14

* The evaluation of cables having significant voltage Medium-Voltage Operation

found to be submerged in standing water for an Cables Not July 7, 2004,

extended period of time will be based on appropriate Subject to 1 0 CFR During the LRA Supplement

testing (using available techno~logy consistent with 50.49 Corresponding Attachment 1,

NRC positions) of cablesftiat "are determined to be Environmental 10 Year Interval Page. 17

weittd for a iignifican~t pli&Odd ofi tie'.'The Qualification (if Applicable)

Enginee'rin~g-evalua'tion will also address the Requirements

appropriate testing i646!rerments for the

crresponding ten~-y'e~ar int'e'rval during the period of

extended operation. The test will use a proven

methodology for detecting deterioration of the

insulation system due to wetting. Examples of such

tests. Include power factor, partial discharge, or

polarization index, as described In EPRI TR-1 03834-

* P1-2, Effects of Moisture on the Life of Power Plant

Cables, or other appropriate testing. Testing will have

acceptance criteria defined in accordance with the

specific test identified. Occurrence of degradation

that is adverse to quality is entered into the

Corrective Action Program. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

IA-19
. ..: Ii~i.,'APENDI'k-CO MIMET FR ICN ENVA.OFIPSU r3.:K1i * I

I ie'ffi N :.LR: endi X'~Y t.Implmentation 'Source- - SchItl i l ;pt.;.

12 The Infrequently Accessed Areas A2.1.14, Prior to Period of LRA Appendix B.

Inspection Program will be established. Infrequently Extended Section B2.1.15

Accessed Areas Operation

Inspection

Program

13 Millstone will follow the industry efforts on reactor A2.1.16, Inservice At Least Two LRA Appendix B, vessel internals regarding such issues as thermal or Inspection Years Prior to Section B2.1.17

neutron irradiation embrittlement (loss of fracture Program: Reactor Period of

toughness), void swelling (change in dimensions), Vessel Intemals Extended July 7, 2004, LRA

stress corrosion cracking (PWSCC and IASCC), and Operation Supplement loss of pre-load for baffle and former-assembly bolts Attachment 1, and will implement the appropriate recommendations Page 1

resulting from this guidance. The revised program

description, including a comparison to the 10 February 8, 2005

program elements of the NUREG-1801 program, will LRA Supplement be submitted to the NRC for approval. Attachment 2,

Page 30

14 Augmented inspections of the MPS Unit 3 core barrel A2.1.16. Inservice At Least Two LRA Appendix B, holddown spring will be performed. In particular, the Inspection Years Prior to Section B2.1.17

inspection will detect gross indication of loss of Program: Reactor Period of

preload as an aging effect. As an alternative to Vessel Intemals Extended

performing an augmented inspection, the holddown Operation

spring will be replaced.

A-20
APPENDIX A: COMMITMENTS FOR LICENSE RENEWAL OF MPS UNIT 3 , -t. ':'

. cofi itoe ,.. LFRA .'..... Apend'lx"A', ,' .XA . , ,, I m ri''~fientatIon, e____________________ 1~ Sure

15 Millstone will follow the industry efforts investigating A2.1.17, Inservice At Least Two LRA Appendix B,

the aging effects applicable to nickel-based alloys Inspection Years Prior to Section B2.1.18

(i.e., PWSCC in Alloy 600 base metal and Alloy Program: Period of Extended

82/182 weld metals) and identifying the appropriate Systems, Operation April 1, 2005,

aging management activities and will Implement the Components and Attachment 2,

appropriate recommendations resulting from this Supports Page 8

guidance. The revised program description will be

submitted prior to the period of extended operation A2.1.21, Steam

for the staff review and'approval to determine if the Generator

program denionstrates the ability to manage the Structural Integrity

effects of aging in nickel based components per 10

CFR 50.54.21 (a)(3). '

16 The existing Inspection program will be modified to A2.1.18, Prior to Period of LRA Appendix B,

include those lifting devices that require monitoring Inspection Extended Section B2.1.19

f6r licenhe renewal; but are riot already included In Activities: Load Operation

the 'rogram. - Handling Cranes

and Device's

17 Implementing procedures and documentation will be A2.1.18, Prior to Period of LRA Appendix B,

modified to include visual inspections for the loss of Inspection Extended Section B2.1.19

material on the crane and trolley structural Activities: Load Operation

components and the rails in the scope of license Handling Cranes

renewal added in Commitment 16. and Devices

A-21
.. APPENDlIXA. (C0VAlVITIVIETP~ p~ LICENSEREEWLOFMP UNIT3*... : *.

...... LRA:4' andix A- Amplementatidw!",' P urce.

18 The implementing procedures will be modified to A2.1.22, Prior to Period of LRA Appendix B,

include American Concrete Institute (ACI) Standard Structures Extended Section B2.1.23

349.3R-96, "Evaluation of Existing Nuclear Safety Monitoring Operation

Related Concrete Structures," dated 1996, and Program

American Nuclear Standards Institute/American

Society of Civil Engineers (ANSI/ASCE) Standard

11-90, 'Guideline for Structural Condition

Assessment of Existing Buildings," dated 1990, as

references and input documents for the inspection

program.

19 The Structures Monitoring Program and A2.1.22, Prior to Period of LRA Appendix B,

implementing procedures will be modified to include Structures Extended Section B2.1.23

all in-scope structures. Monitoring Operation

Program

20 Groundwater samples will be taken on a periodic A2.1.22, Prior to Period of LRA Appendix B,

basis,'considering seasonal variations, to ensure that Structures Extended Section B2.1.23

the groundwater is not sufficiently aggressive to Monitoring Operation

cause the below-grade concrete to degrade. Program

21 The structures monitoring program and implementing A2.1.22, Prior to Period of LRA Appendix B,

procedures will be modified to alert the appropriate Structures Extended Section B2.

engineering organization if the structures inspections Monitoring Operation

identify that medium-voltage cables in the'scope of Program

license renewal have been submerged.

A-22
" ~ .j;s! . :APPENDlXA: COMMITMENTS FOR LICENSE RENEWAL U i , ,

ommmenmj N o I IA r ppedix" A!,,: ;lMli intatio rh i

22 The maintenance and work control procedures will be A2.1.22, Prior to Period of LRA Appendix B,

revised to ensure that Inspections of inaccessible Structures Extended Section B2.1.23

areas are performed when the areas become Monitoring Operation

accessible by such means as excavation or Program

installation of shielding during maintenance or for any

other reason.

23 Appropriate inspections of sealants and caulking A2.1.23, Tank Prior to Period of LRA Appendix B,

used for moisture intrusion prevention in and around Inspection Extended Section B2.1.24

aboveground tanks will be performed. Program Operation

24 Non-destructive volumetric examination of the A2.1.23, Tank Prior to Period of LRA Appendix B,

in-scope inaccessible locations, such as the external Inspection Extended Section B2.1.24

surfaces of tank bottoms, will be performed prior to Program Operation

the period of extended operation. Subsequent ;

inspections will be performed on a frequency A Frequency

consistent with scheduled tank internals inspection Consistent with

activities. - Scheduled Tank

Internals

- Inspection

Activities.

25 The security diesel fuel oil tank and diesel fire pump A2.1.23, Tank Prior to Period of LRA Appendix B,

fuel oil tank are in-scope for license renewal and will Inspection Extended Section B2.1.24

be included on the respective Tank Inspection Program Operation

Program inspection plan.

A-23
.j:APPENDIXA: COMMITMENTSFOR LICENSE RENEWAL. OFQM UN!T3i.. -' ' . 4. ............ ,....(.I '. *'r'

-,.-:..,- Commitment .LRA-A 4n.. dix mpleentaion1ieor'.:T` I,. ieNo... . f t!:';'"'e ''I'i;, '4 - A ' J, 44H . . ia ; '.''".> ;. . .' t* '; ;, l.,''1j'PBl '9'-i;. 

26 Changes will be made to maintenance and work A2.1.24, Work Prior to Period of LRA Appendix B,

control procedures to ensure that inspections of plant Control Extended Section B2.1.25

components and plant commodities will be Process Operation appropriately and consistently performed and

documented for aging effects during maintenance

activities.

27 Consistent with 10 CFR 54.21 (c)(1), (iii), the effects Prior to Period of Environmental

of environmentally assisted fatigue for those specific Extended Assisted Fatigue locations with a CUF greater and 1.0 will be managed Operation TLAA

by the Metal Fatigue of Reactor Coolant Pressure

Boundary program. If the specific locations are not

repaired, replaced, or successfully re-analyzed, a

modified inspection program description, including a

comparison to the 10 program elements of NUREG1801 program, will be submitted to the NRC for

approval.

28 For potentially susceptible CASS materials, either A3.2.3 Prior to Period of July 7, 2004, LRA

enhanced volumetric examinations or a unit or Environmentally Extended Supplement component specific flaw tolerance evaluation Assisted Fatigue Operation Attachment 1, (considering reduced fracture toughness and unit Page 3

specific geometry and stress information) will be used

to demonstrate that the thermally-embrittled material December 12,

has adequate fracture toughness in accordance with 2004, LRA

NUREG-1801 Section XL.M12.3. Supplement,

Attachment 1,

Page 102

A-24
APPENDIX A COMMITMENTS OR LICENSE RENEWALOFIMPS UNIT 3.::, atIt-emf N. Aooef - d Irmp emenitaton Source,: , ; ,., ,. C mItmn > .; ; R Appe'diA ' <; '-l

; ' :- ?: - :,~ K: -,2 : ; .. , ; : ;; :. . ; :;h i d 

29 Millstone will follow industry efforts that will provide A3.2.3 Prior to Period of Environmental

specific guidance to license renewal applicants for Environmentally Extended Assisted Fatigue

evaluating the environmental effects of fatigue on Assisted Fatigue Operation TLAA

applicable locations, other than those identified in

NUREG/CR-6260. Millstone will also implement the July 7, 2004,

appropriate recommendations resulting from this LRA Supplement,

guidance. Until these recommendations are Attachment 1,

available, Millstone 3 commits to using the Page 3

pressurizer surge line nozzle as a leading indicator to

address environmental effects of fatigue on December 3, 2004,

pressurizer sub-components during the period of LRA Supplement,

extended operation. Attachment 1,

,:. ,Page 102

30 A baseline visual inspection Will be performed of the A2.1.6, Closed- Prior to Period of July 7, 2004, LRA

accessible areas of the shell side (includinig Cycle Cooling Extended Supplement

accessible portions of the exterior side of the tubes) Water System Operation Attachment 1,

of one: Page 6

* Millstone Unit 2 Reactor Building Closed

Cooling Water heat exchanger,

* Millstone Unit 2 Emergency Diesel Generator

Jacket Cooling Water heat exchanger, and

* Millstone Unit 3 Emergency Diesel Generator

Jacket Cooling Water heat exchanger.

A-25
,', ,','.> . A',, ';,",1' ',A PENDIX;A,.:COMWMITMENTS FOR LICENSE RENEWALOF, MPS' 3.: :, : :'- 3, '. it m; -3 .

Itm cLiCo o.i mtiment. .... SchedumlemnaoW: Source" - ''3U Ippendix us.uaawuu

31 Using the Work Control Process, a baseline A2.1.24, Work Prior to Period of July 7, 2004, LRA

inspection for the loss of material due to selective Control Process Extended Supplement

leaching will be performed on a representative Operation Attachment 1,

sample of locations for susceptible materials by Page 14

visual, and mechanical or other appropriate methods

32 A review of the Work Control Process inspection A2.1.24, Work Prior to Period of July 7, 2004, LRA

opportunities for each material and environment Control Process Extended Supplement

group, supplemental to the initial review conducted Operation Attachment 1,

during the development of the LRA, will be Page 20

performed. Baseline inspections will be performed for

the material and environment combinations that have

not been inspected as part of the Work Control

Process.

33 Calibration results for cable tested in situ will be A2.1.8, Electrical Prior to Period of December 3, 2004,

reviewed to detect severe aging degradation of the Cables Not Extended LRA Supplement

cable insulation. The initial review will be completed Subject to 10 CFR Operation Attachment 3,

prior to entering the period of extended operation and 50.49 Page 1

will include at least 5 years of surveillance test data Environmental Not to Exceed a 10

for each cable reviewed. Subsequent reviews will be Qualification Year Frequency

performed on a period not to exceed 10 years. Requirements Thereafter

Used in

Instrumentation

Circuits

A-26

---
•2 ;i , A ENMMITM .*;; N TFOLCENSE NW FMP!;;I.i . : .;

' i~\;, ' ;,,fi,,,, , iti!,en- Cotn* lie.RA i0ppen9"idIkx A Mr~Ple1OM( atb *S~ce- our: 

34 The in scope cables in Unit 3 duct lines #929 (SBO A2.1.13, Prior to Period of December 3, 2004,

Diesel to Unit 3 4.16kV Normal Switchgear) and # Inaccessible Extended LRA Supplement

973 (RSST 3RTXXSR-B to 6.9kV Normal Switchgear Medium-Voltage Operation Attachment 3,

Bus 35A, 35B, 35C and 35D) will be tested to Cables Not Page 3

demonstrate that water treeing will not prevent the Subject to 10 CFR Not to Exceed a

cables from performing their intended function 50.49 10 Year Frequency

Environmental Thereafter

Qualification

Requirements

35 In addition to the testing specified In Commitment 34, A2.1.13, Prior to Period of January 11, 2005,

a representative sample of in-scope medium-voltage Inaccessible Extended Attachment 3,

cables will be tested to demonstrate that water Medium-Voltage Operation Page 1

treeing will not prevent the cables from performing Cables Not

their intended function. Subject to Not to Exceed a 10

10 CFR 50.49 Year Frequency

Environmental Thereafter

Qualification

Requirements

36 Complete the SAMA evaluation of the ability to Environmental Prior to Period of August 13, 2004,

manually control the Turbine Driving Auxiliary Report Extended RAI Responses,

Feedwater Pump. If this SAMA is cost beneficial (i.e., Operation Page 2

can be accomplished without a hardware

rmfodification), a Severe Accident Management

Guideline (SAMG) addressing this mitigation strategy

will be developed.

A-27
ii~ I l A .2I'>1 *1 '''Av. ;e; :i .rinA- ''-. ok' ;" :.J! APPENDIX A: COMMITMENTS FOR LICENSE RENEWA 'OFMPS UNITM3L:4,. .:' ii e 1

-Item!No. ,<'I-. C mtent, IR pedxA~Ip entationY~<~~uc .~ ~*I.~ 'A; :. .:.,..... . Schedule . ,.*..~

37 The pressurizer spray head assembly will be either A2.1.17, Inservice Prior to Period of February 8, 2005, replaced or inspected utilizing the best currently Inspection Extended Attachment 2, available (at the time of inspection) techniques for Program: Operation Page 12

detecting cracking resulting from SCC. Systems,

Components and

Supports

A-28

---
APPENDIX B: CHRONOLOGY

This appendix contains a chronological listing of the routine licensing correspondence between

the U.S. Nuclear Regulatory Commission (NRC) staff and the Millstone Power Station (MPS),

and other correspondence regarding the NRC staff's reviews of the Millstone Power Station,

Units 2 and 3 (MPS), (under Docket Number 50-336 and 50-423 respectively) license renewal

application (LRA).

January 20, 2004

January 20, 2004

January 20, 2004

January 20, 2004

January 20, 2004

January 20, 2004

January 23, 2004

January 26, 2004

January 28, 2004

January 29,2004

Millstone Unit 2, Application for Renewed Operating License, Technical

and Administrative Information through Appendix D (Accession No.

ML040260101)

Millstone Unit 3, Application for Renewed Operating License, Technical

and Administrative Information through Appendix D (Accession No.

ML040260103)

Applicant's Environmental Report - Operating License Renewal Stage,

Millstone Power Station Units 2 and 3 (Accession No. ML040260098)

Letter from Dominion Nuclear Connecticut, Inc. (DNC) to the NRC

regarding Applications for Renewed Operating Licenses (Accession No.

ML040260070)

Letter from David A. Christian, Dominion Nuclear Connecticut, Inc., to the

NRC transmitting Applications for Renewed Operating Licenses -

Reference Drawings (Accession No. ML040260076)

Letter from Dominion to the NRC regarding Applications for Renewed

Operating Licenses, Withheld Reference Drawings (Accession No.

ML040260079)

Press Release-04-011 from NRC News: NRC Makes License Renewal

Application Available for the Millstone Nuclear Power Plant (Accession No.

ML040230280)

Memorandum from Russell Arrighi, NRC, to Samson S. Lee, NRC,

regarding the notice of a meeting between the NRC staff and Dominion

Nuclear Connecticut, Inc. to discuss the License Renewal Application for

Millstone Nuclear Power Station Units 2 and 3 (Accession No.

ML040260283)

Letter from Pao-Tsin Kuo, NRC to David A. Christian, Dominion Nuclear

Connecticut, Inc. acknowledging the receipt'and availability of the LRA for

the Millstone Power Station, Units 2 and 3 (Accession No. ML040280258)

Memorandum from Johnny Eads, NRC to Samson S. Lee, NRC regarding

a forthcoming meeting for the NRC to describe the license renewal

process (Accession No. ML040330844)

B-1
February 5, 2004

February 5, 2004

February 6, 2004

February 6, 2004

February 12, 2004

February 12, 2004

February 13, 2004

February 20, 2004

March 1, 2004

March 2, 2004

March 3, 2004

March 4, 2004

Letter from Richard L. Emch, Jr., NRC, to Judy Liskov, Waterford public

library regarding maintenence of referenced material for the Millstone

Power Station Units 2 and 3 License Renewal Application (Accession No.

ML040400209)

Letter from Richard L. Emch, Jr., NRC, to Mildred Hodge, Thames River

Campus regarding maintenance of referenced material for Millstone

Power Station Units 2 and 3 License Renewal Application (Accession No.

ML040400181)

Press Release-1-04-002 from NRC News announcing NRC to hold a

forthcoming public information meeting in Waterford, Connecticut

(Accession No. ML040370209)

Millstone License Renewal Application (LRA) Submittal Presentation

Handout and consistency with NUREG-1 801 Handout (Accession No.

ML040560327)

Certificate of Service of Petition to Intervene and Request for Hearing

(Accession No. ML040760946)

Petition to Intervene and Request for Hearing (Accession No.

ML041040332)

Letter from David R. Lewis, Shaw Pittman LLP, to Annette Vietti-Cook,

Secretary for the Commission, NRC, indicating that the Petition to

Intervene and Request for Hearing of The Coalition Against Millstone is

Premature (Accession No. ML040760954)

Memorandum from Russell J. Arrighi, NRC, summarizing the meeting

between the NRC and Dominion Nuclear Connecticut, Inc. to discuss

Millstone Power Station Units 2 and 2 License Renewal Application

(Accession No. ML040560319)

Letter from Nancy Burton, Attorney at Law, to the Office of the Secretary,

NRC in response to the letter of David R. Lewis of February 13, 2004,

(Accession No. ML040760958)

Letter from Paul B. Eccard, Town of Waterford, to Russell J. Arrighi, NRC,

requesting that NRC consider the Town of Waterford a party to all

preceedings for the re-licensing of Millstone Units 2 and 3 (Accession No.

ML040700550)

Annual Assessment Letter - Millstone Power Station (Report

05000336/2004001 and 05000423/2004001) (Accession No.

ML040630159)

Letter from David R. Lewis, Shaw Pittman LLP, to Annette Vietti-Cook,

Secretary for the Commission, NRC, objecting to the March 1, 2004,

Nancy Burton letter and emphasizing that the Burton Petition to Intervene

was still premature (Accession No. ML040760961)

I

B-2
March 4, 200

March 8, 200

March 10, 20

March 12, 20

March 16, 20

March 19, 20

March 22, 20

March 24, 20

March 30, 20

March 30, 20

April 1, 2004

)4

'4

Letter from the Secretary to 'Nancy Burton Returning Millstone Intervention

Petition (Accession No. ML040760940)

Determination of acceptability and sufficiency for docketing, proposed

review schedule, and opoortunity for a hearing regarding the applications

from Dominion Nuclear Connecticut, Inc. for renewal of the operating

licenses for the Millstone Power Station, Units 2 and 3 (TAC Nos. MC1 825

and MC1 826) (Accession No. ML040680968)

)04 Letter from Margaret J. Bupp and Catherine L. Marco, Office of General

Counsel, NRC, to Annette Vietti-Cook, Secretary for the Commission,

NRC,'stating that Connecticut Coalition Against Millstone's petition to

intervene and a request for hearing filed February 12, 2004, is premature

(Accession No. ML040830141)

)04 Press Release 04-033 from NRC News announcing opportunity for

hearing on application to renew Millstone Nuclear Plant, Units 2 and 3,

operating licenses (Accessioh No. ML040720480)

)04 Request for Party Status'arid Designation of Representative, per

Millstone, Units 2 and 3, Applications for Renewed Operating Licenses

(Accession No. ML040790721)

04 Request for Withholding Information From Public Disclosure From

Millstone Units 2 and 3, granted (Accession No. ML040820974)

'04 Motion to Vacate NRC Secretary Determination of Petition Prematurity

and to Accept Petition to Intervene and Request for Hearing as of Date of

Filing and to Apply 'Old' CFR Hearing Rules to Said Petition (Accession

No. ML041040339)

'04 Commission Order dated March 24, 2004 (Accession No. ML040850646)

04 March 8 and March 16, 2004, Telephone Summary Between the U.S.

Nuclear Regulatory Commission (NRC) Staff and Dominion Nuclear

Connecticut, Inc. Representatives to Discuss the Millstone Power Station,

Units 2 and 3 License Renewal Applications (Accession No.

ML040900525) --

)04 - March 3, 2004, Telephrie&Summary Between the U.S. Nuclear

Regulatory Commission (NRC) Staff and Dominion Nuclear Connecticut,

Inc. Representatives to Discuss the Millstone Power Station, Units 2 and 3

License Renewal Applications (Accession No. ML040900469)

Acknowledgment of Receipt of Letters from Paul Eccard, First Selectman,

Town of Waterford, Requesting Party Status and Designation of

Representatives Regarding the Re-Licensing of Millstone Power Station,

Units 2 and 3 (Accession No. ML040920601)

B-3
April 1, 2004

April 2, 2004

April 2, 2004

April 2, 2004

April 14, 2004

April 22, 2004

May 4, 2004

May 4, 2004

May 4, 2004

May 14, 2004

May 18, 2004

May 19, 2004

June 7, 2004

June 7, 2004

NRC Staff's Unopposed Motion for an Extension of Time to Respond to

Connecticut Coalition Against Millstone's Petition to Intervene and

Request for Hearing (Accession No. ML040930079)

Dominion's Answer to CCAM's Motion to Vacate Secretary Determination

(Accession No. ML040990158)

NRC Staff's Response to Connecticut Coalition Against Millstone's Motion

to Vacate and to Accept Petition to Intervene and Request for Hearing

(Accession No. ML040970522)

Letter from David R. Lewis, Shaw Pittman, LLP, to Chief Administrative

Judge Bollwerk re submission of Dominion's answer opposing CCAM's

motion to vacate (Accession No. ML040990178)

Summary of Telephone Conference on April 8, 2004, Between the U.S.

Nuclear Regulatory Commission and Dominion Nuclear Connecticut, Inc.,

Concerning Draft Requests for Additional Information Pertaining to the

Millstone Power Station, Units 2 and 3, License Renewal Applications

(Accession No. ML041050831)

Notice of May 7, 2004, Exit Meeting With Dominion Nuclear Connecticut,

Inc. On License Renewal Scoping and Screening Methodology Audit for

Millstone Power Station, Units 2 and 3 (Accession No; ML041130326)

SRM-M040504A - Affirmation Session: SECY-04-0066 - Dominion Nuclear

Connecticut (Millstone Nuclear Power Station, Units 2 and 3) (Rejection by

the Secretary of Petition to Intervene in License Renewal Proceedings as

Premature (Accession No. ML041250488)

M040504A - Affirmation Session: SECY-04-0066 - Dominion Nuclear

Connecticut (Millstone Nuclear Power Station, Units 2 and 3) (Rejection by

Secretary of Petition) (Accession No. ML041260073)

Commission Memorandum and Order (CLI-04-12) (Accession No.

ML041250232)

Motion for Reconsideration of CLI-04-12 (Accession No. ML041420177)

Commission Order denying CCAM's Motion for Reconsideration of CLI-04-

12 (Accession No. ML041390500)

Establishment of Atomic Safety and Licensing Board (Accession No.

ML041470149)

NRC Staff Answer to Petition to Intervene and Request for Hearing of

Connecticut Coalition Against Millstone (Accession No. ML041600187)

Dominion's Answer to CCAM's Petition to Intervene and Request for

Hearing (Accession No. ML041680556)

B-4
June 16, 200a

June 18, 2004

June 25, 200'

June 27, 200X

June 30, 2004

July 7, 2004

July 7, 2004

July 9, 2004

July 19, 2004

July 26, 2004

July 28, 2004

August 8, 200

August 9, 200

August 16, 20

August 18, 20

t

I.

I,

t

I.

Connecticut Coalition Against Millstone Motion for Leave to File Reply to

Licensee and NRC Staff Answers to Petition, Amended Petition and

Declarations of CCAM's Members NUNC PRO TUNC (Accession No.

ML041800056)

Notice of July 13, 2004, Exit Meeting With Dominion Nuclear Connecticut,

on License Renewal Audits of aging Management Programs and Reviews

for Millstone Power Station, Units 2 and 3 (Accession No. ML041700332)

Press Release 04-078 from NRC News announcing NRC Atomic Safety

and Licensing Board to Hold Prehearing Conference June 30 on Proposed

Millstone License Renewal (Accession No. ML041770406)

Connecticut Coalition Against Millstone Motion for Stay of Proceedings

(Accession No. ML041910373) -

Transcript of the Dominion Nuclear Connecticut Initial Prehearing

Conference held in New London, CT on June 30, 2004; pp. 1-182

(Accession No. ML041950013)

Dominion Nuclear Connecticut Additional Information in Support of

Applications for Renewed Operating Licenses (Accession No.

ML041900407)

Dominion Nuclear Connecticut Additional Information in Support of

Applications for Renewed Operating Licenses (Accession No.

ML041900370)

Notice of Appeal of the Connecitcut Coalition Against Millstone regarding

the decision of the Atomic Safety and Licensing Board Memorandum and

Order (Accession No. ML042300617)

Unopposed Motion of Dominion Nuclear Connecticut, Inc. To Intervene

(Accession No. ML042570109)

Dominion Nuclear Connecticut Response to Request for Additional

Information License Renewal Applications (Accession No. ML042080210)

Memorandum and Order (Ruling on Standing and Contentions) (LBP-04-

15) (Accession.No. ML042110313)

)4 Declaration of Ernest J. Sternglass (Accession No. ML042330247)

)4 Connecticut Coalition Against Millstone Motion for Reconsideration and

Request for Leave to Amend Petition (Accession No. ML042320548)

)04 Federal Respondents' Motion to Dismiss (Accession No. ML042570117)

)04 NRC Staff Response to Connecticut Coalition Against Millstone's Motion

for Reconsideration and Request for Leave to Amend Petition (Accession

No. ML042320500)

B-5
August 18, 2004

August 18, 2004

August 26, 2004

NRC Staff Answer to Notice of Appeal of Connecticut Coalition Against

Millstone (Accession No. ML042320445)

Letter from David R. Lewis, Shaw Pittman LLP, regarding Connecticut

Coalition Against Millstone's Notice of Appeal, dated August 9, 2004,

(Accession No. ML042390031)

Response by Dominion Nuclear in Support of Motion to Dismiss, dated

August 26, 2004, (Accession No. ML042610296)

September 3, 2004 Petitioner's Objection to Motion to Dismiss (Accession No. ML042610301)

September 9, 2004

September 10, 2004

September 20, 2004

September 20, 2004

October 8, 2004

October 15, 2004

October 18, 2004

October 18, 2004

October 19, 2004

October 27, 2004

Notice of September 22, 2004, Meeting with Dominion Nuclear

Connecticut Regarding License Renewal for the Millstone Power Station,

Units 2 and 3 (Accession No. ML042530373)

Federal Respondent's Reply to Petitioner's Objection to Motion to Dismiss

(Accession No. ML042610304)

Audit Trip Report Regarding the Dominion Nuclear Connecticut, Inc.,

License Renewal Application for the Millstone Power Station, Units 2 and

3, Dated January 22, 2004, (Accession No. ML042640548)

Memorandum and Order (Denying Motion for Reconsideration and

Request for Leave to Amend Petition) (Accession No. ML042640524)

Notice of October 20, 2004, Millstone Public Meeting with Dominion

Nuclear Connecticut, Inc. to discuss team inspection covering scoping and

aging management portions of Dominion's application for a renewed

license (Accession No. ML042820632)

Press Release 1-04-047 from NRC News announcing NRC, Dominion

Nuclear To Discuss Inspections on Millstone License Renewal on October

20 (Accession No. ML042890059)

NRC Staff's Brief in Opposition to Appeal by Connecticut Coalition Against

Millstone of LBP-04-15 and LBP-04-22 (Accession No. ML042930658)

Dominion Nuclear Connecticut's Brief in Opposition to the Appeals of

Connecticut Coalition Against Millstone (Accession No. ML043010494)

E-mail from Brooke Poole to Administrative Judges and Participants

regarding missing page 3 to Staff's Brief filed on October 18, 2004

(Accession No. ML043070098)

Audit and Review Plan for Plant Aging Management Reviews and

Programs - Millstone Power Station, Units 2 and 3 (Accession No.

ML043290430)

I

B-6
November 9, 2004

December 3, 2004

December 3, 2004

December 3, 2004

December 8, 2004

December 27, 2004

January 11,2005

January 12, 2005

February 2, 2005

February 8, 2005

February 15, 2005

February 24, 2005

April 1, 2005

April 19, 2005

Dominion Nuclear Connecticut Response to Request for Additional

Information for License Renewal Applications (Accession No.

ML043200606)

Dominion Nuclear-Connecticut Response to Request for Additional

Information for License Renewal Applications (Accession No.

ML043450341)

Millstone Power Station Unit 2 and Unit 3 - License Renewal Application

Inspection Report Nos. 05000336/2004010, 05000423/2004010

(Accession No. ML043410193)

Millstone Power Station Unit 2 and Unit 3 - License Renewal Application

Inspection Report Nos. 05000336/2004009, 05000423/2004009

(Accession No. ML043410201)

Commission Memorandum and Order (CLI-04-36) regarding Connecticut

Coalition Against Millstone intervenor status (Accession No.

ML043430498)

Letter from Annette Vietti-Cook, Secretary of the Commission, to Christine

Malafi, Esq. responding to the County of Suffolk's December 17, 2004,

Motion to Intervene (Accession No. ML043630023)

Dominion Nuclear Connecticut Response to Request for Additional

Information for License Renewal Applications (Accession No.

ML050190289)

Dominion Nuclear Connecticut Annual Update Information for License

Renewal Applications (Accession No. ML050210041)

Audit and Review Report for Plant Aging Management Reviews and

Programs for the Millstone Power Station - Units 2 & 3 Prepared by NRC

(Accession No. ML050330059)

Letter from Dominion to the NRC regarding additional information in

support of license renewal applications (Accession No. ML050460323)

Letter from Dominion to the NRC regarding additional information in

support of license renewal applications (Accession No. ML050550068)

Letter from NRC to Dominion transmitting the Safety Evaluation Report

with Open Items Related to License Renewal of MPS (Accession No.

ML050600172)

Letter from Dominion to NRC regarding response to SER with Open Items

(Accession No. ML051020128)

Letter from Dominion to NRC regarding license renewal comments on

SER with Open Items (Accession No. ML051100470)

B-7
June 2, 2005

July 14, 2005

July 21, 2005

Letter from Dominion to NRC regarding additional information in support

of license renewal applications (Accession No. ML051590137)

Letter from Dominion to NRC regarding additional information in support

of license renewal applications (Accession No. ML051960166)

Letter from Dominion to NRC regarding additional information in support

of license renewal applications (Accession No. ML052020434)

September 22, 2005 Letter from ACRS to Chairman, Nuclear Regulatory Commission providing

its conclusions and recommendations on the renewal of the operating

licenses for the Millstone Power Station, Units 2 and 3. (Accession No.

ML052650478)

.

B-8
APPENDIX C: PRINCIPAL CONTRIBUTORS

NAME RESPONSIBILITY

F. Akstulewicz

H. Ashar

R. Barret

W. Bateman

S. Black

B. Boger

J. Calvo

T. Chan

K. Chang

S. Coffin

K. Corp

R. Dennig

Y. Diaz-Castillo

J. Eads

J. Fair

T. Ford

G. Galletti

F. Gillespie

R. Goel

J. Hannon

J. Honcharik

K. Hsu

E. Imbro

N. Igbal

R. Jenkins

A. Keim

P. Kuo

S. Lee

C. Li

M. Li

Y. Li

L. Lois

L. Lund

J. Ma

K. Manoly

D. Matthews

R. McNally

J. Medoff

M. Modes

G. Morris

D. Nguyen

R. Pettis

B. Poole

T. Quay

Management Oversight

Structural Engineering

Management Oversight

Management Oversight

Management Oversight

Management Oversight

Management Oversight

Management Oversight

GALL Audit and Review

Management Oversight

Technical Support

Management Oversight

Material Engineering

Lead Project Manager

"Mechanical Engineering

Reactor Systems

Quality Assurance

Management Oversight

Containment Systems

Management Oversight

Material Engineering

GALL Audit and Review

Management Oversight

Plant Systems

Management Oversight

Material Engineering

Management Oversight

Management Oversight

Plant Systems

SER Support

Mechanical Engineering

Reactor Systems

Management Oversight

Mechanical Engineering

Management Oversight

Management Oversight

Mechanical Engineering

Materials Engineering

Region I Inspection

Electrical Engineering

Electrical Engineering

Quality Assurance

Legal Counsel

Management Oversight

C-1
B. Radlinski

J. Rajan

S. Saba

D. Shum

D. Solorio

J. Stmisha

R. Subbaratnam

D. Terao

D. Thatcher

L. Tran

N. Trehan

J. Uhle

H. Walker

S. Weerakkody

J. Wermiel

S. West

Plant Systems

Mechanical Engineering

Electrical Engineering

Plant Systems

Management Oversight

Mechanical Engineering

GALL Audit and Review

Management Oversight

Management Oversight

GALL Audit and Review

Electrical Engineering

Management Oversight

Containment Systems

Management Oversight

Management Oversight

Management Oversight

CONTRACTORS

CONTRACTOR TECHNICAL ARPA . _ . _ _ ....... . _ .I- I , 1....... .-.

Brookhaven National Laboratory

Information Systems Laboratories

Legin Group, Inc.

Containment Systems

GALL Audit/Plant Systems

SER Support

I

I

C-2
-

APPENDIX D: REFERENCES

This appendix contains a listing of references used in the preparation of the Safety Evaluation

Report prepared during the review of the license renewal application for Millstone Power Station,

Units 2 and 3, Docket Numbers 50-336 and 50-423, respectively.

(1) NUREG-1800, -Standard Review Plan for Review of License Renewal Applications for

Nuclear Power Plants," April 2001

(2) NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 -

The License Renewal Rule, Revision 3," August 2001

(3) NUREG-1 801, "Generic Aging Lessons Learned Report (GALL)," April 2001

; (4) Letter From NRC to Dominion Nuclear Connecticut, Inc., "Request For Additional

Information (RAI) Regarding The License Renewal Application For The Millstone Power

Station, Units 2 and 3"

(5) MPS License Renewal Technical Report MP-LR-3/4000, "System/Structure Scoping"

(6) MPS License Renewal Technical Report MP-LR-3/4002, "Fire Protection," Revision 2

(7) MPS License Renewal Technical Report MP-LR-3/4003, 'Anticipated Transient Without

Scram," Revision 2

(8) MPS License Renewal Technical Report MP-LR-314004, "Pressurized Thermal Shock,"

Revision 0

(9) MPS License Renewal Technical Report MP-LR-314005, "Fire Protection," Revision 4

(10) MPS License Renewal Technical Report MP-LR-3/4006, "Station Blackout," Revision 3

(11) MPS License Renewal Technical Report MP-LR-3/4901, "Treatment of Consumables"

(12) MPS License Renewal Technical Report MP-LR-3/4903, "Interim Staff Guidance"

(13) MPS License Renewal Technical Report MP-LR-3655/4655, "Aging Management Review

Cables and Connectors"

(14) MPS License Renewal Technical Report MP-LR-3656/4656, "Aging Management Review

Bus Ducts"

(15) MPS License Renewal Technical Report MP-LR-3657, "Aging Management Review

Electrical Penetrations"

(16) MPS License Renewal Technical Report MP-LR-392014920, "Review of Stored

Equipment Millstone Power Station"

D-1
(17) Letter from Ashok Thadani, Director of Nuclear Regulatory Research, To William

Travors, Executive Director of Operations, mCloseout of Generic Safety Issue 190,

(Fatigue Evaluation of Metal Components For 60 Year Plant Live)," December 1999

I

I

11

D-2
NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(9.2004) (Assigned by NRC, Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numnbers, H any.)

BIBLIOGRAPHIC DATA SHEET NUREG-1 838

(See kwstnx on the eveVol.2

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

Safety Evaluation Report Related to the License Renewal of the Millstone Power Station, Units MONTH YEAR

2and 3 2 October 2005

4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

' Johnny H. Eads

7. PERIOD COVERED (Indusive Dates)

8. PERFORMING ORGANIZATION -NAME AND ADDRESS (IfNRCprovideDivisien, Orceor Region, U.S. NudearRegulatotyCommsors, andmaVwadress;Mcontractor,

provie name and mafi'to address.)

Division of Regulatory Improvement Programs (DRIP)

Office of Nuclear Reactor Regulation

' U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

9. SPONSORING ORGANIZATION -NAME AND ADDRESS (ItNRC, type Sameassaove';contractor, provide NRCDMisiion. OteorReFon, U.S. NucdearRegulatoryrCommission,

' ardmnaddnrss )

Same as above

10. SUPPLEMENTARY NOTES

1 1. ABSTRACT 200 Iwds orless)

This safety evaluation report (SER) documents the technical review of the Millstone Power Station (MPS), Units 2 and 3,

license renewal applications (LRAs) by the staff of the U.S. Nuclear Regulatory Commission (NRC). By letter dated January 20,

2004, Dominion Nuclear Connecticut, Inc. submitted the LRAs for MPS in accordance with Title 10, Part 54, of the Code of

Federal Regulations. Dominion Is requesting renewal of the operating licenses for MPS Units 2 and 3, (Facility Operating

LUcense Numbers DPR-65 and NPF-49, respectively) for a period of 20 years beyond the current expiration dates of midnight

July 31,2015, and midnight November 25, 2025.

The MPS site is located in Waterford, CT, on the north shore of Long Island Sound. The NRC issued the construction permits

for MPS Units 2 and 3 on December 12, 1970, and August 9, 1974, respectively. The operating licenses were issued on

September 26, 1975, for Unit 2 and January 31, 1986, for Unit 3.

This SER presents the status of the staffs review of information submitted to the NRC in the applications. The staffs conclusion

of its review of the MPS LRAs can be found in Section 6 of this SER.

The NRC license renewal project manager is Mr. Johnny H. Eads. Mr. Eads may be reached at (301) 415-1471. Written

correspondence should be addressed to the U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.

12. KEY WORDSIDESCRIPTORS (Lis words orptrases out wit assist researchers In Axatkv V rport) 13. AVAILABILITY STATEMENT

license renewal, nuclear power unlimited

14. SECURMIY CLASSIFICATION

(This Page)

unclassified

.(Thi Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FOR _3_ _(_.2..04...INTE. ON R__CE P.__A ...___ER_ _._ NRIC FORM 335 (a-2004) MRINTED ON RECYCLED PAP^ER
;

Federal Recycling Program
- --

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

OFFICIAL BUSINESS