NUREG-1838, Vol. 1

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
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NUREG-1838, Vol. 1

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 staff's 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 staff's 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 ................................ :.iii

Table of Contents . v

Abbreviations .xviii

1 Introduction and General Discussion . . . .1-1

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 . 1 .. .. 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; i.... 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 ReactorVessel ;. .. .... 2-30

2.3A.1.2 Reactor Vessel Intemals . . .2-32

2.3A.1.3 Reactor 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

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

2.3A.2.4 Shutdown Cooling System ........................ 2-41

2.3A.2.5 Spent Fuel Pool Cooling System ..... ............... 2-42

2.3A.3 Auxiliary Systems ................. ...................... 2-44

2.3A.3.1 Circulating Water System ......................... 2-45

2.3A.3.2 Screen Wash System ............................ 2-46

2.3A.3.3 Service Water System ............................ 2-48

2.3A.3.4 Sodium Hypochlorite System ...................... 2-50

2.3A.3.5 Reactor Building Closed Cooling Water System .... .... 2-51

2.3A.3.6 Chilled Water System ............................ 2-53

2.3A.3.7 Instrument Air System ............................ 2-56

2.3A.3.8 Nitrogen System ................................ 2-58

2.3A.3.9 Station Air System ............................... 2-59

2.3A.3.10 Hydrogen System ............................... 2-60

2.3A.3.11 Chemical and Volume Control System ..... ......... 2-61

2.3A.3.12 Sampling System .............................. 2-62

2.3A.3.13 Primary Makeup Water System ..... ............... 2-64

2.3A.3.14 Access Control Area Air Conditioning System .... .... 2-65

2.3A.3.15 Main Condensers Evacuation System ..... ......... 2-66

2.3A.3.16 Containment Air Recirculation and Cooling System .... 2-67

2.3A.3.17 Containment and Enclosure Building Purge System .... 2-68

2.3A.3.18 Containment Penetration Cooling System ..... ....... 2-69

2.3A.3.19 Containment Post-Accident Hydrogen Control System . 2-70

2.3A.3.20 Control Room Air Conditioning System ..... ........ 2-71

2.3A.3.21 Control Element Drive Mechanism Cooling System .... 2-73

2.3A.3.22 Diesel Generator Ventilation System ..... .......... 2-74

2.3A.3.23 ESF Room Air Recirculation System ..... .......... 2-75

2.3A.3.24 Enclosure Building Filtration System ..... ........... 2-76

2.3A.3.25 Fuel Handling Area Ventilation System ..... ......... 2-78

2.3A.3.26 Main Exhaust Ventilation System ..... ............. 2-79

2.3A.3.27 Non-Radioactive Area Ventilation System .... ........ 2-80

2.3A.3.28 Process and Area Radiation Monitoring System .... ... 2-81

2.3A.3.29 Radwaste Area Ventilation System ..... ........... 2-83

2.3A.3.30 Turbine Building Ventilation System ..... ........... 2-84

2.3A.3.31 Vital Switchgear Ventilation System ..... ........... 2-85

2.3A.3.32 Unit 2 Fire Protection System ...... ............... 2-86

2.3A.3.33 Unit 3 Fire Protection System ..................... 2-89

2.3A.3.34 Domestic Water System ......... ................ 2-90

2.3A.3.35 Diesel Generator System .......................... 2-92

2.3A.3.36 Diesel Generator Fuel Oil System ...... ............ 2-94

2.3A.3.37 Station Blackout Diesel Generator System ..... ...... 2-96

2.3A.3.38 Security System .............. ................. 2-98

2.3A.3.39 Clean Liquid Waste Processing System ....... ....... 2-99

2.3A.3.40 Gaseous Waste Processing System ............... 2-101

2.3A.3.41 Post-Accident Sampling System ...... ............ 2-102

2.3A.3.42 Station Sumps and Drains System ... :............ 2-104

2.3A.3.43 Aerated Liquid Radwaste System ......... ......... 2-105

2.3A.3.44 Solid Waste Processing System ....... ........... 2-106

vi
.

2.3A.3.45 Turbinbe Building Closed Cooling Water System

2.3A.3.46 Water Box Priming System ................ 2.3A.4 Steam and Power Conversion Systems ............... 2.3A.4.1 Main Steam System .....

2.3A.4.2 Extraction Steam System ..................

2.3A.4.3 Feedwater System .......................

2.3A.4.4 Condensate System. .................... 2.3A.4.5 Condensate Storage and Transfer System ..... 2.3A.4.6 Condensate Demin Mixed Bed System ........ 2.3A.4.7 Auxiliary Feedwater System ................

2.3A.4.8 Feedwater Heater Vents 'and Drains System .... 2.3A.4.9 'Moisture Separation and Reheat System ......

. . .

. . .

. . .

. . .

. . .

. . .

. . .

. . .

. . .

. . .

. . .

. . .

... 2-107

... 2-109

... 2-110

... 2-110

... 2-112

... 2-113

... 2-114

... 2-116

... 2-118

... 2-119

... 2-120

... 2-121

... 2-122

... 2-124

... 2-125

System

... 2-126

- I 2.3A.4.10

' 2.3A.4.11

2.3A.4.12

2.3A.4.1 3

Plant Heating and Condensate Recovery System

Secondary.Chemical Feed System ............. Turbine Gland Sealing System ................

Auxiliary Steam Reboiler and Deaerating Feedwater ,..........................................

2.3A.4.14 Exciter Air Cooler System ....................... 2-128 - 2.3A.4.15 Stator Liquid Cooler System ..... 2.3A.4.16 Turbine Lube Oil System ........................

2.3A.4.17 Electro Hydraulic Control System .................

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

2.3B.1 Reactor Coolant System ................................

2.38.1.1 ReactorVessel`'! .............

2.3B.1.2 Reactor Vessel Internals ........................

2.3B.1.3 Reactor Coolant System ........................

2.38.1.4 Steam Generator ....................... ; .

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

2.38.2.1 Containment Recirculation System .................

2.38.2.2 Quench Spray System ............................ 2.3B.2.3 Safety Injection System ..........................

2.38.2.4 Residual Heat Removal System ...................

2.38.2.5 Fuel Pool Cooling'ahd Purification System ........... 2.38.3 Auxiliary Systems ................... 2.38.3.1 Circulating Water System ........................

2.38.3.2 Service WaterSystemr..........................

2.3B.3.3 Sodium Hypochlorite System ..................... 2.3B.3.4 Reactor Plant Component Cooling System ........... 2.3B.3.5 Turbine Plant Component Cooling Water System ......

2.38.3.6 Chilled Water System ...........................

2.38.3.7 Charging Pumps Cooling System ................. 2.38.3.8 Safety Injection Pumps Cooling System ............. 2.38.3.9 Neutron Shield Tank Cooling System .. 2.38.3.10 Containment Atmosphere Monitoring System ........ 2.38.3.11 Containment Instrument Air System ...............

2.38.3.12. Instrument Air System ....................... :.'.;.

2.3B.3.13 Nitrogen System .. . ...

2.38.3.14 Service Air System . - - .- 2.3B.3.15 Chemical and Volume Control System .............

2-129

2-130

2-131

2-132

2-132

2-133

2-134

2-135

2-138

2-139

2-139

2-141

2-142

2-143

2-145

2-147

2-148

2-149

2-152

2-153

2-155

2-157

2-158

2-159

2-161

2-162

2-163

2-164

2-165

2-165

2-167

vii -
.SL'

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

2.3B.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

2.3B.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 ................

2.3B.4.5 Auxiliary Feedwater System .....................

2.3B.4.6 Auxiliary Steam System ......................... 2.3B.4.7 Auxiliary, Boiler Condensate and Feedwater System ....

2.3B.4.8 Hot Water Heating System ....................... 2.3B.4.9 Hot Water Pre-heating System .................... 2.3B.4.10 Steam Generator Chemical Addition System ........

2-221

2-223

2-224

2-225

2-227

2-228

2-230

2.3B.4.11 Turbine Plant Miscellaneous Drains System ......... 2.4 Scoping and Screening Results - Structures ..................' 2.4A Unit 2 Scoping and Screening Results --Structures .................. 2.4A.1 Containment ....................... - .'

2.4A.1.1 Summary of Technical Information in the Application ...

2.4A.1.2 Staff Evaluation .................. '

2.4A.1.3 Conclusion ................... - . 2.4A.2 Structures and Component Supports ....................... 2.4A.2.1 Unit 2 Containment Enclosure Building .............. 2.4A.2.2 Unit 2 Auxiliary Building .......................... 2.4A.2.3 Unit 2 Warehouse Building .......................

2.4A.2.4 Unit 2 Turbine Building .......................... 2.4A.2.5 Unit 1 Turbine Building ............................

2-231

2-232

2-249

2-249

2-249

2-250

2-251

2-251

2-252

2-253

2-255

2-256

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 . ,.I..2-262 ............. ......... at-'........... 2 - 2 62..

2.4A.2.10 Unit 2 Condensate Polishing Facility and Warehouse No. 5 ............ ........-. ,.' ; 2-263 e1 A A 1 4 4 r,%! - - -I ,-- !.6tA'.4!.-I IOeLUWILy LJI:bt UtnedaUI EncloUUre . .........

2.4A.2.12 Stack Monitoring Equipment Building ;;........

2.4A.2.13 Millstone Stack :.........................

2.4A.2.14 Switchyard Control House . 2.4A.2.15 Retaining Wall ...........................

2.4A.2.16 Switchyard, 345kV ........................

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

2.4A.2.18 Sea Walls ..............................

2.4A.2.19 Unit 2 Discharge Tunnel and Discharge Structure

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

2.4A.2.21 Tank Foundations ........................ 2.4A.2.22 Yard Structures .;.. .

..... 2-264 ..... .2-265 ..... .2-266 ..... .2-267 ..... .2-268 ..... .2-268 ..... .2-269 ..... .2-272 ..... .2-274 ..... .2-275 ..... .2-276 ..... .2-277

2.4A.3 NSSS Equipment Supports ...............................

2.4A.3.1 Summary of Technical Information in the Application ...

2.4A.3.2 Staff Evaluation ....................'

2.4A.3.3 Conclusion ................... ' 2.4A.4 General Structural Supports-.

2.4A.4.1 Summary of Technical Information'in the Application ...

2.4A.4.2 -Staff Evaluation.

2.4A.4.3 Conclusionr. ............... ' ;

2.4A.5 Miscellaneous Structural Commodities .....................

2.4A.5.1 Summary of Technical Information in the Application ...

2-278

2-278

2-279

2-279

2-279

2-279

2-280

2-280

2-280

2-280

ix:
___________________- I 

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

2.48.2.4 Unit 3 Fuel Building ............................. 2-295

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

2.48.2.6 Unit 3 Hydrogen Recombiner Building ............... 2-298

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

2.4B.2.8 Unit 3 Main Steam Valve Building ..... ............. 2-300

2.48.2.9 Unit 3 Emergency Generator Enclosure and Fuel Oil Tank Vault

........................ 2-301

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

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

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

2.48.2.13 Unit 3 Turbine Building ....... .................. 2-306

2.4B.2.14 Unit 3 Auxiliary Boiler Enclosure ..... ............. 2-307

2.4B.2.15 Unit 3 Technical Support Center ..... ............. 2-308

2.4B.2.16 Unit 3 Maintenance Shop ...... ................. 2-309

2.4B.2.17 Unit 3 Waste Disposal Building ................... 2-310

2.48.2.18 SBO Diesel Generator Enclosure and Fuel Oil Tank Vault

... .......................................... 2-311

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

2.4B.2.20 Unit 2 Condensate Polishing Facility and Warehouse No. 5

.............................................. 2-313

2.4B.2.21 Security Diesel Generator Enclosure ..... .......... 2-314

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

2.48.2.23 Millstone Stack ......... ...................... 2-316

2.48.2.24 Switchyard Control House ...... ................. 2-317

2.4B.2.25 Switchyard, 345kV ........ ..................... 2-318

2.4B.2.26 Unit 3 Circulating and Service Water Pumphouse ..... 2-319

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

2.48.2.28 Sea Wall ........... ......................... 2-323

2.4B.2.29 Unit 3 Circulating Water Discharge Tunnel and Discharge

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

2.48.2.30 Unit 3 Recirculation Tempering Line ..... .......... 2-325

2.48.2.31 Vacuum Priming Pumphouse ..... ............... 2-327

2.48.2.32 Tank Foundations ........ ..................... 2-328

2.4B.2.33 Yard Structures ........ ....................... 2-329

L

I

I

I

I

Ii

I

I

I I

x
-

2.48.3 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

2.48.3.3 Conclusion .2-331

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

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

2.4B.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

2.48.5.2 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

2.4B.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. ................................................... 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 .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 1 . . . .3-3

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

3.0.2 Staffs Review Process . . . 3-4

3.0.2.1 ReviewofAMPs .. . . . 3-5

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

3.0.2I ........ . . ............. 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 Consis'tent with the GALL Report with Exceptions

or Enhancem'ents .-. ; 3-24

3.0.3.3 AMPs that are Not Consistent with or Not Addressed in the GALL

.................... .3-99 . ' .. .. 3 - 9 9 .. .. . 3.0.4 Quality Assurance Program Attributes Integral to Aging Management

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

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

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

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

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

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

3.1A 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

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

3.1 A.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

3.1A.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

3.1B.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 ......................... 3-217

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

3.28.1 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

3.28.3 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 ....... ................................ 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

3.3B.2.1 AMR Results That Are Consistent with the GALL Report, for

Which Further Evaluation is Not Recommended ... 3-311

3.3B.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 . . .............. 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

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

Which Further Evaluation is Not Recommended ........ . 3-406

3.48.2.2 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 3-42...........7. 

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

Which Further Evaluation is Not Recommended ..... .... 3-432

xiii
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 .........................

4.2.4.1 Summary of Technical Information ini the Application A -- A -- Cl..n ._1..-: ..

..... 4-18

..... .4-18

A -^ 4.4.14.1 uaI vauau n .................... - .; 4-1 U

4.2.4.3 FSAR Supplement .. 4-19

4.2.4.4 Conclusion .......... .... 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 ofTechnical 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 ................................. 4-48

4.7A.3.3 FSAR Supplement .............................. 4-50

4.7A.3.4 Conclusion .................................... 4-50

4.7A.4 Leak-Before-Break ......... ............................ 4-50

4.7A.4.1 Summary of Technical Information in the Application .... 4-50

4.7A.4.2 Staff Evaluation ................................. 4-51

4.7A.4.3 FSAR Supplement .............................. 4-53

4.7A.4.4 Conclusion .................................... 4-54

4.7B Unit 3 Other Plant-Specific Time-Limited Aging Analyses .... ........... 4-54

4.7B.1 Crane Load Cycle Limit .................................. 4-54

4.7B.1.1 Summary of Technical Information in the Application .... 4-54

4.7B.1.2 Staff Evaluation ................................. 4-54

4.7B.1.3 FSAR Supplement .............................. 4-55

4.7B.1.4 Conclusion .................................... 4-55

4.7B.2 Reactor Coolant Pump Flywheel ........................... 4-56

4.7B.2.1 Summary of Technical Information in the Application .... 4-56

4.76.2.2 Staff Evaluation ................................. 4-56

4.78.2.3 FSAR Supplement .............................. 4-57

4.7B.2.4 Conclusion .................................... 4-57

4.7B.3 Leak-Before-Break ........ ............... .............. 4-57

4.71.3.1 Summary of Technical Information in the Application .... 4-57

4.7B.3.2 Staff Evaluation ................................. 4-58

4.7B.3.3 FSAR Supplement .............................. 4-59

4.7B.3.4 Conclusion .................................... 4-60

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

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

2.3B-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-1 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

3.3B-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

CMM 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 -

Ax
11: 

-

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

NDE

NEI

NEPA

NFPA

NPRDS

NRC

NSAC

NSR

NS>SR

NSSS

OBE

ODSCC

OE

01

PAID

PB

PCM

PDT

PLL

PM

PMMS

PNNL

PPB

PPM

PRA

P-T

PTS

PVC

PWR

PWSCC

QA

QAP

QC

QDR

RAI

RBCCW

RCCA

RCD

RCP

RCPB

RCS

RFO

RHR

RPCC

RI-ISI

RG

RPV

RSST

nuclear component fatigue management

non-destructive examination

Nuclear Energy Institute

National Environmental Policy Act

National Fire Protection Association

nuclear plant reliability data system

U.S. Nuclear Regulatory Commission

Nuclear Safety Analysis Center

non-safety-related :

non-safety-related affecting safety-related

nuclear steam supply system

operating basis earthquake

outside diameter stress corrosion cracking

operating experience

open item

piping and instrumentation diagram

pressure boundary

personnel contamination monitor

primary drain tank

predicted lower limit

preventive maintenance

production maintenance management system

Pacific Northwest National Laboratory

parts per billion

parts per million

probabilistic risk assessment

pressure-temperature

pressurized thermal shock

polyvinyl chloride

pressurized water reactor

primary water stress corrosion cracking

quality assurance

quality assurance program

quality control

qualification document review

request for additional information

reactor building closed cooling water system

rod cluster control assembly regulatory commitment database

reactor coolant pump

reactor coolant pressure boundary

reactor coolant system

refueling outage

residual heat removal

reactor plant component cooling

risk informed - inservice inspection;:

regulatory guide

reactor pressure vessel

reserve station service transformer
- -

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

xxii
SECTION 1

INTRODUCTION AND-GENERAL DISCUSSION

1.1 Introduction ,

This document is a safety evaluation report (SER) on the applications for license renewal for

the Millstone Power Station (MPS), as filed by the Dominion Nuclear Connecticut, Inc.

(Dominion or the applicant). By letter dated January 20, 2004, Dominion submitted its

applications to the U.S. Nuclear Regulatory Commission (NRC or the Commission) for renewal

of the MPS operating licenses for an additional 20 years. The NRC staff (the staff) prepared

this report, which summarizes the results of its safety review of the renewal applications for

compliance with the requirements of Title 10, Part 54; of the Code of Federal Regulations,

(10 CFR Part 54), "Requirements for Renewal of Operating Licenses for Nuclear Power Plants."

The NRC license renewal project manager for the MPS license renewal review is Johnny Eads.

Mr. Eads can be contacted by telephone at 301-415-1471 or electronic mail at jhe@nrc.gov.

Altematively, written correspondence may be sent to the following address:

License Renewal and Environmental Impacts Program

U.S. Nuclear Regulatory Commission , :

Washington, D.C. 20555-0001

Attention: Johnny Eads, Mail Stop 0-11 F1

In its January 20, 2004, submittal letter, the applicant requested renewal of the operating

licenses issued under Section 104b (Operating License No. DPR-65) and Section 103

(Operating License No. NPF-49) of the Atomic Energy Act of 1954, as amended, for MPS Units

2 and 3, respectively, for a period of 20 years beyond the current license expiration dates of

midnight, July 31, 2015, for Unit 2 and 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 permit for Unit 2 on December 11, 1970,

and for Unit 3 on August 9,1974. The NRC issued the operating license for Unit 2 on

September 26,1975, and for Unit 3 on January 31,,1986. MPS Unit 2 consists of a two-steamgenerator, four-coolant-loop, pressurized-light-water-reactor, with a nuclear steam supply

system supplied by Combustion Engineering, Inc. and a turbine generator fumished 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. Unit 3 operates at a licensed power output of 3411 MWt, with a gross electrical

output of approximately 1195 MWe. The final safety analysis report (FSAR) contains details

concerning the plant and the site.

1-1.
The license renewal process consists of two concurrent reviews-a technical review of safety

issues and an environmental review. The NRC regulations found in 10 CFR Parts 54 and 51,

respectively, set forth the requirements for these reviews. The safety review for the MPS

license renewal is based on the applicant's license renewal applications (LRAs) and on the

responses to the staffs requests for additional information (RAls). The applicant supplemented

and clarified its responses to the LRA and RAls in audits, meetings, and docketed

correspondence. Unless otherwise noted, the staff reviewed and considered information

submitted through July 22, 2005. The staff reviewed information received after that date on a

case-by-case basis, depending on the stage of the safety review and the volume and

complexity of the information. The public may review the LRA and all pertinent information and

materials, including the FSAR mentioned above at the NRC Public Document Room, located in

One White Flint North, 11555 Rockville Pike (first floor), Rockville, MD 20852-2738 (301-415-

4737/800-397-4209), and at the Waterford Public Library, 49 Rope Ferry Road, Waterford, CT

06385-2806, and at the Three Rivers Community College, Thames River Campus, 574 New

London Turnpike, Norwich, CT 06360. In addition, the public may find the MPS Units 2 and 3

LRAs, as well as materials related to the license renewal review, on the NRC website at

www.nrc.gov.

This SER summarizes the results of the staffs safety review of the MPS LRA and describes the

technical details considered in evaluating the safety aspects of the units' proposed operation for

an additional 20 years beyond the term of the current operating licenses. The staff reviewed the

LRA in accordance with NRC regulations and the guidance provided in NUREG-1800,

"Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants,"

(SRP-LR), dated July 2001.

Sections 2 through 4 of this SER address the staff's review and evaluation of license renewal

issues that it has considered during the review of the application. Section 5 is reserved for the

report of the Advisory Committee on Reactor Safeguards (ACRS). The conclusions of this

report are in Section 6.

Appendix A to this SER is a table that identifies the applicant's commitments associated with

the renewal of the operating licenses. Appendix B provides a chronology of the principal

correspondence between the NRC and the applicant related to the review of the application.

Appendix C is a list of principal contributors to the SER. Appendix D is a bibliography of the

references used in support of the review.

In accordance with 10 CFR Part 51, the staff prepared a plant-specific supplement to the

Generic Environmental Impact Statement (GEIS). This supplement discusses the

environmental considerations related to renewing the licenses for MPS Units 2 and 3. The NRC

staff issued 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," on July 18, 2005.

1.2 License Renewal Background

Pursuant to the Atomic Energy Act of 1954, as amended, and NRC regulations, operating

licenses for commercial power reactors are issued for 40 years. These licenses can be

renewed for up to 20 additional years. The original 40-year license term was selected on the

basis of economic and antitrust considerations, rather than on technical limitations. However,

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some individual plant and equipment designs may have been engineered on the basis of an

expected 40-year service life.

In 1982, the NRC anticipated interest in license renewal and held a workshop on nuclear power

plant aging. This workshop led the NRC to establish'a comprehensive program plan for nuclear,

plant aging research. On the basis of the results of that research, a technical review group

concluded that many aging phenomena are readily manageable and do not pose technical

issues thatwould preclude-life extension for nuclear power plants.'In 1986, the NRC published

a request for comment on a policy statementthat would address major policy, technical, and

procedural issues related to license renewal for nuclear power plants.

In 1991, the NRC published the license renewal rule in 10 CFR Part 54 (the Rule). The NRC

participated in an industry-sponsored demonstration program to apply the Rule to a pilot plant

and to gain experience necessary to develop implementation guidance. To establish a scope of

review for license renewal, the Rule defined age-related degradation unique to license renewal.

However, during the demonstration program,'the'NRC found that many aging mechanisms";

occur and are managed during the period of initial license. In addition, the NRC found that the

scope of the review did riot allow sufficient credit for existing programs, particularly the

implementation of the Maintenance Rule, which also manages plant'agin'g'phenomena: As a

result, the NRC amended the license renewal rule in 1995. The amended 10 CFR Part 54

established a regulatory process'that is simpler, more stable, and more predictable than the

previous license renewal rule. In particular, the NRC amended 10 CFR Part 54 to focus on

managing the adverse effects of aging rather than on identifying age-related degradation

unique to license renewal. The NRC initiated these rule changes to ensure that important

systems, structures, and components (SSCs) will continue to perform their intended functions

during the period of extended operation. In addition, the revised Rule clarified and simplified the

integrated plant assessment (IPA) process to be consistent with the revised focus on passive,

long-lived structures and components (SCs). - -

In parallel with these efforts, the NRC pursued a separate rulemaking effort and developed an

amendment to 10 CFR Part 51 to focus the scope of the review of environmental impacts of

license renewal and fulfill the NRC's responsibilities under the National Environmental Policy

Act of 1969 (NEPA).

1.2.1 Safety Review -

License renewal requirements for power reactors are based on two key principles:

-(1) The regulatory process is adequate to ensure that the licensing bases of all

currently operating plants pr6vide and maintain an acceptable level of safety,-

with the possible exception of the detrimental effects of aging on the functionality

of certain SSCs during the period-of extended operation, as well as a few other

issues related to safety during the period of extended operation.

(2) The plant-specific licensing' basis must be maintained during the renewal term in

the same manner and to the same extent as during' the original licensing term.

In implementing these two principles, 10 CFR 54.4'defines the scope of license renewal as

including those SSCs (1) that are safety-related;'(2) whose failure could affect safety-related

functions; and (3) that are relied on to demonstrate compliance with the NRC's regulations for

1-3
-

fire protection (FP), environmental qualification (EQ), pressurized thermal shock (PTS),

anticipated transient without scram (ATWS), and station blackout (SBO).

Pursuant to 10 CFR 54.21 (a), an applicant for a renewed license must review all SSCs that are

within the scope of the Rule to identify SCs that are subject to an aging management review

(AMR). Those SCs that are subject to an AMR perform an intended function without moving

parts or without a change in configuration or properties, and are not subject to replacement

based on qualified life or specified time period. As required by 1 0 CFR 54.21 (a), an applicant

for a renewed license must demonstrate that the effects of aging will be managed in such a way

that the intended function or functions of those SCs will be maintained, consistent with the

current licensing basis (CLB), for the period of extended operation. Active equipment, however,

is considered to be adequately monitored and maintained by existing programs. In other words,

the detrimental effects of aging that may affect active equipment are more readily detectable

and can be identified and corrected through routine surveillance, performance monitoring, and

maintenance activities. The surveillance and maintenance activities programs for active

equipment, as well as other aspects of maintaining the plant design and licensing basis, are

required throughout the period of extended operation.

Pursuant to 10 CFR 54.21 (d), each LRA is required to include a supplement to the FSAR. This

FSAR supplement must contain a summary description of the applicant's programs and

activities for managing the effects of aging and the evaluation of time-limited aging analyses

(TLAAs) for the period of extended operation.

License renewal also requires the identification and updating of the TLAAs. During the design

phase for a plant, certain assumptions are made about the length of time the plant can operate.

These assumptions are incorporated into design calculations for several of the plant's SSCs. In

accordance with 10 CFR 54.21 (c)(1), the applicant must either show that these calculations will

remain valid for the period of extended operation, project the analyses to the end of the period

of extended operation, or demonstrate that the effects of aging on these SSCs can be

adequately managed for the period of extended operation.

In 2001, the NRC developed and issued Regulatory Guide (RG) 1.188, 'Standard Format and

Content for Applications to Renew Nuclear Power Plant Operating Licenses." This RG endorses

NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The

License Renewal Rule," which was issued in March 2001 by the Nuclear Energy Institute (NEI).

NEI 95-10 details an acceptable method of implementing the license renewal rule. The NRC

also used the SRP-LR to review this application.

In the LRA, MPS fully utilizes the process defined in NUREG-1 801, 'Generic Aging Lessons

Learned (GALL) Report," issued in July 2001. The GALL Report provides the staff with a

summary of staff-approved aging management programs (AMPs) for the aging of many SCs

that are subject to an AMR. If an applicant commits to implementing these staff-approved

AMPs, the time, effort, and resources used to review an applicant's LRA can be greatly

reduced, thereby improving the efficiency and effectiveness of the license renewal review

process. The GALL Report summarizes the aging management evaluations, programs, and

activities credited for managing aging for most of the SCs used throughout the industry. The

report also serves as a reference for both applicants and staff reviewers to quickly identify

those AMPs and activities that the staff has determined can provide adequate aging

management during the period of extended operation.

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1.2.2 Environmental Review

In December 1996, the staff revised the environmental protection regulations to facilitate the

environmental review for license renewal. The staff prepared a 'Generic Environmental Impact

Statement (GEIS) for License Renewal of Nuclear Plants" (NUREG-1437, Revision 1) to -

document its evaluation of the possible environmental impacts associated with renewing

licenses of nuclear power plants.:For certain types of environmental impacts, the GEIS

establishes generic findings that are applicable to all nuclear power plants.;These generic

findings are codified in Appendix B to Subpart A of ;10 CFR Part 51. Pursuant to

10 CFR 51.53(c)(3)(i), an applicant for license renewal may incorporate these generic findings

in its environmental report. In accordance with 10 CFR 51.53(c)(3)(ii), an environmental report

must also include analyses of those environmental impacts that must be evaluated on a plantspecific basis (i.e., Category.2 issues).

In accordance with NEPA'and the requirements of 10 CFR Part 51, the NRC performed a plantspecific review of the environmental impacts of license renewal, including whether new and

significant information existed that the GEIS did not consider. As part of its scoping process, the

NRC held a public meeting on May 18, 2004, in Waterford, CT, to identify environmental issues

specific to the plant. The NRC held another public meeting on January 11, 2005, in Waterford,

CT, to discuss the draft plant-specific Supplement 22 to the MPS Units'2 and 3, GEIS. The

NRC's plant-specific Supplement 22 to the MPS Units 2 and 3, GEIS, which was issued on

July 18, 2005, documents the results of the environmental review and includes a

recommendation with respect to the license renewal action.

1.3 Principal Review Matters

Title 10, Part 54, of the Code of Federal Regulations describes the requirements for renewing

operating'licenses for nuclear power plants. The staff performed its technical review of the MPS

LRA in accordance with Commission guidance and the requirements of 10 CFR Part 54.

Title 10, Sectionr 54.29 of the Code of Federal Regulations sets forth the standards for renewing

a license. This SER describes the results of the staffs safety review.

In 10 CFR 54.19(a), the Commission requires a license renewal applicant to submit general

information. The applicant provided this general information in Sectioh' 1 of its LRA for MPS

Units 2 and 3, which it"submitted to the NRC by-letter dated January 20, 2004. The staff

reviewed Section 1 and finds that the applicant has submitted the information required by

10 CFR 54.19(a).

In 10 CFR 54.19(b), the Commission requires that each LRA include 'conforming changes to

the standard indemnity agreement, 10,CFR 140.92, Appendix'B, to account for the expiration

term of the proposed renewed license." The applicant stated the following in each LRA

regarding this issue: '

The current indemnity agreement for the unit does not contain a specific expiration'term

for the operating licenses. Therefore, conforming changes to account for the expiration

term of the proposed renewed licenses are not necessary, unless the license numbers

are changed upon issuance of the renewed licenses.

1-5**
-it'.

The staff intends to maintain the original license numbers upon issuance of the renewed

licenses. Therefore, conforming changes to the indemnity agreement do not need to be made,

and the requirements of 10 CFR 54.19(b) have been met.

In 10 CFR 54.21, the Commission requires that each LRA must contain (a) an IPA, (b) a

description of any CLB changes that occurred during staff review of the LRA, (c) an evaluation

of TLAAs, and (d) an FSAR supplement. Sections 3 and 4 and Appendix B to the LRA address

the license renewal requirements of 1 0 CFR 54.21 (a), (b), and (c). Appendix A to the LRA

contains the license renewal requirements of 10 CFR 54.21(d).

In 10 CFR 54.21 (b), the Commission requires that each year following submission of the LRA,

and at least 3 months before the scheduled completion of the staffs review, the applicant must

submit an amendment to the renewal application that identifies any changes to the CLB of the

facility that materially affect the contents of the LRA, including the FSAR supplement. The

applicant submitted an update to the LRA by letter dated January 12, 2005, which summarized

the changes to the CLB that have occurred at MPS Units 2 and 3, during the staff's review of

the LRA. This submission satisfies the requirements of 10 CFR 54.21 (b) and is still under staff

review.

In accordance with 10 CFR 54.22, an applicant's LRA must include changes or additions to the

technical specifications (TS) that are necessary to manage the effects of aging during the

period of extended operation. In Appendix D to the LRA, the applicant stated that it had not

identified any TS changes necessary to support issuance of the renewed operating licenses for

MPS Units 2 and 3. This adequately addresses the requirement specified in 10 CFR 54.22.

The staff evaluated the technical information required by 10 CFR 54.21 and 10 CFR 54.22 in

accordance with NRC regulations and the guidance provided by the SRP-LR. Sections 2, 3, and

4 of this SER document the staffs evaluation of the technical information contained in the LRA.

The staffs evaluation of the environmental information required by 10 CFR 54.23 is contained

in the final plant-specific supplement to the GEIS which states the considerations related to

renewing the licenses for MPS Units 2 and 3. This supplement was prepared by the staff

separate from this SER. As required by 10 CFR 54.25, the ACRS issued a report to document

its evaluation of the staffs LRA review and associated SER. Section 5 of this SER incorporates

the ACRS report. The findings required by 10 CFR 54.29 can be found in Section 6 of this SER.

1.4 Interim Staff Guidance

The license renewal program is a living program. The NRC staff, industry, and other interested

stakeholders gain experience and develop lessons learned with each renewed license. The

lessons learned address the NRC's performance goals of maintaining safety, improving

effectiveness and efficiency, reducing regulatory burden, and increasing public confidence.

Interim staff guidance (ISG) is documented for use by the NRC staff, industry, and other

interested stakeholders until it is incorporated into the license renewal guidance documents

such as the SRP-LR and GALL report.

The following table provides the current set of ISGs issued by the staff, as well as the SER

sections in which the staff addresses ISG issues.

1-6
ISGlIssue - :-[9'a+~|Put= s-;--: ~:SEl; ecloh .-" -(Approved ISG No.) .- ER tion

GALL report presents one This ISG clarifies that the GALL N/A

acceptable way to manage aging report contains one acceptable

effects way, but not the only way, to

(ISG-1) manage aging for license

renewal.

SBO Scoping The license renewal rule 2.1.3.1.1

(ISG-2) 10 CFR 54.4(a)(3) includes

10 CFR 50.63(a)(1)-SBO.

The SBO rule requires that a

plant must withstand and recover

from an SBO event. The

recovery time for offsite power is

much faster than that of EDGs.

The offsite power system should

be included within the scope of

license renewal.

Concrete AMP Lessons leamed from the GALL 3.5A.2.2.1.1

(ISG-3) dernonisfration project indicated 3.5B.2.2.1.1

that GALL is not clear on whether

concrete requires an AMP.

1-7
-

- -

ISG Issue Purpose | SER Section

(Approved ISG No.)

FP System Piping This ISG clarifies the staff 3.0.3.2.7

(ISG-4) position for wall-thinning of the

FP piping system in GALL AMPs

XL.M26 and XL.M27.

The staff's new position is that

there is no need to disassemble

FP piping, as disassembly can

introduce oxygen to FP piping,

which can accelerate corrosion.

Instead, use a non-intrusive

method, such as volumetric

inspection.

Testing of sprinkler heads should

be performed at year 50 of

sprinkler system service life, and

every 10 years thereafter.

This ISG eliminates the

Halon/carbon dioxide system

inspections for charging

pressure, valve line-ups, and the

automatic mode of operation test

from GALL; the staff considers

these test verifications to be

operational activities.

1-8
ISG Issue ' Purpose " SER Section

(Approved ISG No.)

Identification and Treatment of This ISG includes electrical fuse 2.1.3.2.3

Electrical Fuse Holders holders AMR and AMP (i.e., 3.0.3.2.5

(ISG-5) ' same as termirial blocks and

other electrical connections).

The position includes only fuse

holders that are not inside the

enclosbre of active components'

(e:g., inside of switchgears and

inverters).

Operating experience finds that

metallic clamps (spring-loaded

clips) have a history of agerelated failures from aging

stressors such as vibration,

themnal cycling, mechanical

stress, corrosion, and chemical

contamination.

The staff finds that visual

inspection of fuse clips is not

suffi6ient to detect the aging

effects from fatigue, mechanical

stress, and vibration.

The ISG Process This ISG provides clarification' N/A

(ISG-8) and update to the ISG process

on Improved License Renewal

Guidance Documents.

Standardized Format for License The purpose of this ISG is to N/A

Renewal Applications provide a standardized license

(ISG-10) renewal application format for

applicants. -

1.5 Summary of Open Items

As a result of its review of the LRA for MPS Units 2 and 3, including additional information

submitted to the NRC through February 15, 2005, the staff identified six open issues that

remained open at the time the SER with Open Iterris was published. An issue was considered

open if the applicant had not presented a sufficient basis for resolution. Each open item (01)

had been assigned a unique identifying number. By letters dated April 1, 2005,' June 2, 2005,

July 14, 2005, and July 21, 2005, the applicant responded to these open items. The staff

.1-9
reviewed these responses and has closed out each of the open items. The basis for closing the

open items is as follows:

01-2.1.3-1 (Section 2.1.3.1.1 - Application of the Scoping Criteria in 10 CFR 54.4(a))

In RAI 2.1-1, the staff requested additional information regarding the scoping methodology

associated with the 10 CFR 54.4(a)(2) evaluation. The staff requested that the applicant define

the term "first equivalent anchor point" as it relates to the evaluation of NSR piping attached to

SR piping and describe the methodology of its application. Additionally, in cases where plant

equipment credited with providing support to NSR piping within the scope of license renewal

may be equivalent to an associated piping anchor as described in NUREG-1 800, the staff

requested that the applicant provide justification for not including this plant equipment within the

scope of license renewal. The applicant's November 9, 2004, response to the RAI stated that

for the purpose of license renewal, the first equivalent anchor is defined as when the piping has

been restrained in each of the three orthogonal directions. The response also recognized that,

in some cases, plant equipment may be credited as providing restraint in one or more directions

in the piping system seismic evaluation. Dominion stated that in these cases, the credited

components are also included within the scope of license renewal. The applicant applied the six

criteria in the determination of the license renewal boundary endpoints for NSR piping attached

to SR piping. However, the staff had concerns with the criteria's consistency with the CLB and

whether the criteria established by the applicant would conservatively bound the equivalent

anchor. This was identified as Open Item 2.1.3-1.

In response to Open Item 2.1.3-1, the applicant provided additional information to the staff on

April 1, 2005, regarding the basis of the six bounding criteria used in the determination of the

license renewal boundary endpoints for NSR piping attached to SR piping. The applicant stated

that the bounding criteria provided assurance that the license renewal scoping boundary would

envelop the scope of the NS piping system included in the design basis seismic analysis,

consistent with the CLB, and in some cases, the bounding approach resulted in an overly

conservative license renewal boundary determination. The applicant also provided the staff with

a revised definition of an equivalent anchor to be used for the purposes of identifying the NS

piping in the scope of license renewal during the case-by-case reviews. The revised definition

was changed from one restraint in each of the three orthogonal directions to two restraints. A

review was performed by the applicant to apply this equivalent anchor definition to the cases

where the LR boundary endpoint was previously determined through piping analysis/isometric

drawing review or plant walkdown. The applicant stated that as a result, the LR boundary was

extended where necessary to include additional supports and portions of piping systems;

however, there were no additional component types as a result of these boundary extensions.

Based on the above discussion, the staff concludes that the applicant has supplied sufficient

information to demonstrate that SSCs, that meet the scoping requirements of

10 CFR 54.4(a)(2), have been identified as being within the scope of license renewal.

Therefore, Open Item 2.1.3-1 is considered closed.

01-3.0.3.2.18-1 (Section 3.0.3.2.18 - Bolting Integrity Program)

The applicant states that the bolting integrity program is consistent with the aging management

program described in GALL AMP XI.M1 8, with the following exception related to loss of preload.

The applicant states that the operating temperature for all other in scope bolted connections are

well below the threshold temperature at which stress relaxation of pressure boundary bolting

1-10
would occur. The staff found that other factors such as vibration can contribute to loss of

preload. The applicant needed to address other factors which can contribute to loss of preload

and justify if loss of preload is an aging effect requiring management for all bolting within the

scope of license renewal. This was identified as Open Item 3.0.3.2.18-1.

In response to Open Item 3.0.3.2.18-1, dated June 29, 2005, the applicant stated the Millstone

bolting integrity AMP has now been revised to manage loss of preload as an applicable aging'

effect for all in-scope bolting. Based on this change to the bolting integrity AMP, Open Item

3.0.3.2.18-1 is closed.

01-3.0.3.2.18-2 (Section 3.0.3.2.18 - Bolting Integrity Program)

The procedures for ensuring bolting integrity at Millstone identify inspection'requirements and

general practices for in scope bolting that are 'consistent with the bolting' recommendations

identified in Section XLI.M18, but do not directly reference EPRI NP-5769 or NUREG-1339 as

applicable source documents for these recommendations. Howevedr,' the Millstone procedures

do reference and incorporate the good bolting practices identified in EPRI NP-5067. EPRI NP5769 and EPRI NP-5067 are very closely'related documents that cross-reference one another

and reference NUREG-1339. The staff requested clarification on how the guidance in EPRI NP5067 and EPRI NP-104213 meets the intent of EPRI NP-5769 and NUREG-1339 as identified

in GALL AMP XI.M18. This was identified as Open Item 3.0.3.2.18-2.

By letter dated April 1, 2005, the applicant provided a comparison of EPRI NP-5769 and EPRI

NP-5067 as they relate to the bolting integrity program at Millstone. In summary, the Millstone

bolting integrity program is-consistent with the' recommendations in NUREG-1801,

Section'XI.M18. The comparison provided by the'applicant demonstrates that EPRI NP-5067

provides adequate guidance for addressing the bolting integrity for Millstone' Units 2 and 3.

Therefore, Open Item 3.0.3.2.18-2 is closed.

01-3.1.2-6 (Section 4.1.2.4.2 - Reactor Vess66 Internals)

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 does not constitute'the reactor coolant

system (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 applicant determined that 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 of this position 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

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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 valve 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

01-4.7.3-1 (a) (Section 4.7.3 - Reactor Coolant Pump 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 endpoint 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 Vin, based on the staff's letter

to NEI, dated May 19, 2000, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel

Components," the staff determined that the time 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).

01-4.7.4-1 (Section 4.7.4 - Reactor coolant system piping leak-before-break)

For Millstone Unit 2, the applicant reviewed and found the number and characteristics of cycles identified in the leak-before-break (LBB) topical report (CEN-367-A) to be acceptable for the

period of extended operation for the RCS piping. 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

1-12
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'

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 componentswere evaluated for the period of extended operation. The discussion for the reactor coolant loop

piping is intended to envelop 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

staff's 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

envelops 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

B2.1.18. 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 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.

By letter dated February 8, 2005, the applicant provided additional information to address Open

Item 4.7.4-1 for Millstone Unit 3. The applicant stated that for Millstone Unit 3, the reactor

coolant system loop piping (hot leg, cold leg and c'rossover 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 all6ys'.' '

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

decrease in fracture toughness is proportionia t 'the level of ferrite in the material. Thermial

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 analysesi 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

envelop ali 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

1-13,
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 staff's 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 envelops 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 B2.1.18. 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.

Based on the discussion above, the staff concludes that Open Item 4.7.4.1 is closed.

1.6 Summary of ConfirmatorV Items

As a result of its review of the LRA for MPS Units 2 and 3, including additional information and

clarifications submitted to the NRC through February 15, 2005, the staff identified the following

confirmatory items. An issue was considered confirmatory if the staff and the applicant had

reached a satisfactory resolution, but the resolution had not yet been formally submitted to the

staff. Each confirmatory item (CI) had been assigned a unique identifying number. By letters

dated April 1, 2005, June 2, 2005, July 14, 2005, and July 21, 2005, the applicant responded to

these confirmatory items. The staff reviewed these responses and has closed out each of the

confirmatory items. The basis for closing the confirmatory items is as follows:

CI-3.0.3.2.1 8-1

The staff found that the resolution of Open Items 3.0.3.2.18-1 and 3.0.3.2.18-2 may warrant a

modification to the FSAR. This issue was identified as Confirmatory Item 3.0.3.2.18-1. By letter

dated July 14, 2005, the applicant provided the revised FSAR sections to reflect resolution of

Open Items related to the bolting integrity program. Based on these FSAR changes,

Confirmatory Item 3.0.3.2.18-1 is closed.

CI-3.1.3-3 (Section 3.1 B.2.2.7 - Crack Initiation and Growth Due to Stress Corrosion Cracking

(SCC) or Primary Water Stress Corrosion Cracking (PWSCC))

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 staff's letter to NEI, dated May 19, 2000, should be used when

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- S -

analyzing'the pressurizer spray head through'the bxtended 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-1 801, 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 compone'ntstwith 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 6ould 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 inservice inspection program: systems, components and supports aging management

program, in accordance with 10 CFR 54.21 (a)(1)(iii).-The applicant also stated that this

program is consistent with NUREG-1 801, Section XI.M1 2, 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-1 801, Section XI.M12. The staff finds the applicant's management

of thermal aging embrittlement through inspection in-accordance with10 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-1801, Section XL.M12

is an acceptable alternative to the volumetric examination in accordance with NUREG-1 801.

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.

CI-3.6-1 (Section 3.6.2.3 --AMR Results That Are Not Consistent With or Are Not Addressed In

the GALL Report) --

In its letter dated November 9, 2004, the applicant confirmed that it treats splices as an integral

part of the cable and that non-EQ splices are included in commodity groups,- "Conductors," and,

"Insulation," in LRA Table 2.5.1-1. The associated aging management review results are

included in Table 3.6.2-1. This commodity includes non-EQ cables installed in raw water or

damp soil. The staff requested clarification of the statement in the LRA that the external

environment would remain below 95OF and therefore would not require an AMP. The applicant

needed to provide clarification regarding the effects of ohmic heating on the cable insulation.

This was identified as'Confirmatory Item 3.6-1.

In response to Confirmatory Item 3.6-1, in a Ietter dated April 1, 2005, the applicant stated that.

the information requested in this confirmatory item, related to the effects of ohmic heating on

the cable insulation,'was' provided in' response to RAI 3.6-3 by letter dated January 11, 2005. 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

1:15'
period of operation. Therefore no aging management program is required. Based on the above,

Confirmatory Item 3.6-1 is closed.

CI-4.3-1 (Section 4.3 - Metal Fatigue)

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 cumulative usage

factor (CUF) 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 design cycles to evaluate the charging nozzle safe-end, the

applicant's fatigue monitoring program (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.

CI-4.7.4-1

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 reevaluated 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-10587 for the period of extended operation and how the fatiguecrack 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.

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.

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CI-B2.11.18-3 (Section B2.1.18c - Nickel Alloy Nozzles and Penetrations (XI.M1 1 of NUREG1801))

The applicant stated that Millstone Unit 2 will follow industry efforts investigating the aging

effects applicable to nickel-based alloys (i.e., PWSCC in Alloy 600 base metal and Alloy 82/182

weld metals) and identifying the appropriate aging management activities, and it will implement.

the appropriate recomnmendations' resulting from this'guidance. This commitment is identified in

Appendix A, Table A6.0-1 License Renewal Commitments, Item 14.

In RAI B2.1.1 8-1, the staff requested'that the applicant modify its commitment to state that the

aging management activities to monitor the aging effects 'of nickel-based alloys will be

submitted three years prior to th6 period of extended operation in order for the staff review and

approval to determine whether the program demonstrates the ability to manage the effects of

aging in nickel-based components pursuant to 10 CFR 54.21 (a)(3). In addition, the applicant

was requested to address how nickel-based components will be evaluated in terms of

susceptibility to PWSCC.

The applicant, by letter dated December 3, 2004, modified its commitment to submit its

program prior to the period of extended operation for staff review and approval. The applicant's

response did not meet with the staff's request to submit the program three years prior to the

period of extended operation to allow the staff time to review and approve the program. This

was identified as Confirmatory Item B2.1.18-3.

In response to Confirmatory Item B2.1.18-3, in a letter dated April 1, 2005, the applicant stated

that in LRA Appendix A "FSAR Supplement," Sections A2.1.1 8 and A2.1.22 for Unit 2 and

Sections A2.1.27 and A2.1.21 for Unit 3, the commitment to follow industry efforts regarding

nickel-based alloys has been modified to read:

The revised program description will be submitted at least two years prior to the period

of extended operation for staff review and approval to determine if the program

demonstrates the ability to manage the effects of aging in nickel-based components per

10 CFR 54.21 (a)(3).

Additionally, the schedule for Table A6.0-1, Commitment 14 (Unit 2) and 15 (Unit 3), in LRA

Appendix A will be changed to:

At Least Two Years Prior to the Period of Extended Operation.

Based on this revised commitment, Confirmatory Item B2.1.18-3 is closed.

1.7 Summary of Proposed License Conditions

As a result of the staff's review of the LRAs for MPS Units 2 and 3, including subsequent

information and clarifications provided by the applicant, the staff identified three proposed

license conditions.

The first license condition requires the applicant to include the FSAR supplement required by

10 CFR 54.21 (d) in the next FSAR update, as required by 10 CFR 50.71 (e), following the

issuance of the renewed licenses.

1 -17
The second license condition requires that the activities identified in Appendix A to this SER be

completed in accordance with the schedule in Appendix A.

The third license condition is as follows:

All capsules in the reactor vessel that are removed and tested must meet the test procedures

and reporting requirements of ASTM E 185-82 to the extent practicable for the configuration of

the specimens in the capsule. Any changes to the capsule withdrawal schedule, including spare

capsules, must be approved by the NRC prior to implementation. All capsules placed in storage

must be maintained for future insertion. Any changes to storage requirements must be

approved by the NRC, as required by 10 CFR Part 50, Appendix H.

1-18
a SECTION 2

STRUCTURES AND COMPONENTS SUBJECT TO AGING

MANAGEMENT REVIEW

2.1 Scopingland Screening Methodology"

2.1.1 Introduction

Title 10 of the Code of Federal Regulations, Part 54 (10 CFR Part 54 or the Rule),

'Requirements for Renewal of Operating Licenses for Nuclear Power Plants," Section 54.21,

'Contents of Application -Technical Information," requires that each application for license

renewal contain an integrated plant assessment (IPA). Furthermore, the IPA must list and

identify those structures and components (SCs) that are subject to an aging management

review (AMR) from the systems, structures, and components (SSCs) that are within the scope

of license renewal in accordance with 10 CFR 54.4. Sections 2.1.4 and 2.1.5 of the license

renewal application (LRA) describe the applicaht's-process for identifying these SCs and

provide the scoping and screening results for those components, subcomponents, structural

members, and commodity groups that are subject to an AMR per Section 3.0 of the LRA.

In LRA Section 2.1, "Scoping and Screening Methodology," the applicant described the scoping

and screening methodology used to identify SSCs at the Millstone Power Station (MPS) Units 2

and 3 within the scope of license renewal, and SCs that are subject to an AMR. The staff

* reviewed the applicant's scoping and screening methodology to determine if it meets the

scoping requirements stated in 10 CFR 54.4(a) and the screening requirements stated in

10 CFR 54.21.

In developing the scoping and screening methodology, the applicant considered the

requirements of the Rule, the Statements of Consideration (SOC) for-the Rule, and the

guidance presented by the Nuclear Energy Institute (NEI), "Industry Guideline for Implementingthe Requirements of 10 CFR Part 54 -The License Renewal Rule," Revision 3, March 2001,

(NEI 95-10). In addition, the applicant also considered the NRC staff's correspondence with

other applicants and with NEI in the development of this methodology. Scoping and screening

were performed as an integrated review at the system/structure level. Screening was performed

on a component-level basis, and the scoping results were reviewed and revised as required to

be consistent with the screening results. The short-lived passive components that could be

excluded from an AMR on the basis of a qualified life or a specified replacement time period,

were identified and screened out as part'of the AMR process.

2.1.2 Summary of Technical Information'infthe Application -

In Sections 2.0 and 3.0 of the LRA, the applicant provided the technical information required by

10 CFR 54.21 (a). In LRA Section 2.1, "Scoping and Screening Methodology," the applicant

describes the process used to identify the SSCs that meet the license renewal scoping criteria

2-1 ;-
.

under 10 CFR 54.4(a), as well as the process used to identify the SCs that are subject to an

AMR as required by 10 CFR 54.21(a)(1). Section 2.1.2 discusses the application of the

10 CFR 54.4(a) scoping criteria; Section 2.1.3 provides a discussion of the documentation that

was used to perform scoping and screening; and Sections 2.1.4 and 2.1.5 describe the scoping

and screening methodology.

Additionally, LRA Section 2.2, "Plant Level Scoping Results;" Section 2.3, "System Scoping and

Screening Results: Mechanical Systems;" Section 2.4, "Scoping and Screening Results:

Structures;" and Section 2.5, "Scoping and Screening Results: Electrical and Instrumentation

and Control Systems;" amplify the process the applicant used to identify the SCs that are

subject to an AMR. LRA Section 3, "Aging Management Review Results," contains the following

information:

* Section 3.1, "Aging Management of Reactor Vessel, Internals, and Reactor Coolant

System"

* Section 3.2, "Aging Management of Engineered Safety Features Systems"

* Section 3.3, uAging Management of Auxiliary Systems"

* Section 3.4, "Aging Management of Steam and Power Conversion Systems"

* Section 3.5, "Aging Management of Containment, Structures and Component Supports"

* Section 3.6, "Aging Management of Electrical and Instrumentation and Controls"

LRA Section 4, "Time-Limited Aging Analyses," contains the applicant's identification and

evaluation of time-limited aging analyses (TLAA).

2.1.2.1 Scoping Methodology

In Section 2.1 of the LRA, the applicant described the methodology used to scope systems and

structures pursuant to the requirements of 10 CFR 54.4(a). The applicant's scoping

methodology, as described in the LRA, is outlined in the sections below.

2.1.2.1.1 Application of the Scoping Criteria in 10 CFR 54.4(a)

The applicant described the general approach to scoping safety-related (SR), non-safetyrelated (NSR), and SSCs credited with demonstrating compliance with certain regulated events

in Section 2.1.2, "Application of the Scoping Criteria in 10 CFR 54.4(a)," of the LRA. The

scoping approaches specific to each of the three scoping criteria are described as follows:

(1) Application of the Scoping Criteria in 10 CFR 54.4(a)(1). In LRA Section 2.1.2.1,

"10 CFR 54.4(a)(1)," the applicant discussed the scoping methodology as it related to

SR criteria in accordance with 10 CFR 54.4(a)(1). With respect to the SR criteria, the

applicant stated that the SSCs within the scope of license renewal include SR SSCs that

are relied upon to remain functional during and following design-basis events as defined

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- - .

in 10 CFR 50.49(b)(1). The quality classifications established in the Production

Maintenance Management System (PMMS) for uniquely numbered plant components

are consistent with the -SR definitions presented in 10 CFR 50.49(b)(1) and are based

on reviews of plant accident analyses and'evaluations. PMMS, a multi-faceted program

encompassing, in part, an equipment information database and the plant work order

subsystem, also provides for the identification of relevant engineering and quality

classification information and specific component information. The applicant used these

quality classifications for the identification of components meeting the requirements of

'10 CFR 54.4(a)(1). License renewal information is also contained in the License

Renewal Information Management System (LRIMS), which is used to collect, process,

and report license renewal information.

The quality classification information includes the identification of quality assurance (QA)

Category 1 for SR and NSR componehis.- For components identified as QA Category I,

a safety function and safety function description are provided. In addition to identifying

SR components, the following four augmented QA classifications are identified as a

subset of NSR: (1) rad waste, (2) fire protection, (3) anticipated transient without scram,

and (4) station blackout. The PMMS database also indicated the applicability of 16

engineering programs. Examples of engineering programs that pertain to license

renewal intended functions are the electrical equipment qualification, Appendix R,

seismic, fire protection, high-energy line break, heavy loads, and station blackout

programs'. The use of PMMS during the scoping and screening process is discussed in

Sections 2.1.4 and 2.1.5'of the LRA. The classification and identification of plant

components within PMMS are discussed in' Section 2.1.3.4 of the LRA.

(2) ApDlication of the Scoping Criteria in 10 CFR 54.4(a)(2). In LRA Sections 2.1.2.2,

"10 CFR 54.4(a)(2) - Non Safety-Related Affecting Safety-Related;"'2.1.5, "Screening

Methodology;" 2.1.3.6, "10 CFR 54.4(a)(2) Report;" and 2.1.6.9, "Scoping Criteria

10 CFR 54.4(a)(2)," the applicant discussed the scoping methodology as it related to the

NSR criteria in accordance with 10 CFR 54.4(a)(2). The applicant stated that a review

has been performed to identify the NSR SSCs whose failure could prevent satisfactory

accomplishment of the SR intended functionis identified in 10 CFR 54.4(a)(1). The NSR

SSCs that are within the scope of license renewal for Units 2 and 3 fall into two

categories: (1) NSR SSCs that functionally support the operation of SR SSCs and (2) NSR SSCs whose failure could cause an interaction with SR SSCs that could potentially

result in the failure of the SR SSCs to perform their intended safety functions. With

respect to scoping of SSCs pursuant to 10 CFR 54.4(a)(2), the applicant performed a

review of the FSAR, plant-specific operating experience,'and CLB documentation to

provide -the guidelines and the sources of information to be used as input to scoping and

screening. This information was also augmented by plant walkdowns performed to

identify NSR components containing liquids or steam that are spatially oriented such

that their failure could prevent the satisfactory accomplishm ent of an SR function of an

SR SSC. , '

The applicant's review encompassed the design-basis earthquake (DBE) considered

within these documents. The NSR SSCs -already included within the'scope of license

renewal for 10 CFR 54.4(a)(3) were not identified for inclusion under 10 CFR 54.4(a)(2).

2-3
The NSR piping that is attached to SR piping, and that is required to be seismically

designed and supported up to the first equivalent anchor point beyond the SR/NSR

boundary, is included within the scope of license renewal. Although these NSR piping

segments are not uniquely identified during the screening process nor highlighted on

license renewal drawings, applicable aging effects for these piping segments are

managed by the applicant along with the adjoining SR piping. Supports for NSR SSCs

that could adversely interact with SR SSCs as a result of a seismic event (Seismic Il/I)

were not individually identified during the screening process. These supports were

identified on a commodity basis within areas that contain SR SSCs and were included

within the scope of license renewal regardless of whether they were directly associated

with the SR SSCs. The results of the applicant's review were incorporated into a

10 CFR 54.4(a)(2) report, which was used as input to the scoping and screening

process and is discussed in Section 2.1.3.6 of the LRA.

(3) Application of the Scoping Criteria in 10 CFR 54.4(a)(3). In LRA Sections 2.1.2.3,

"10 CFR 54.4(a)(3) - Regulated Events;" 2.1.6.2, "Scoping of Equipment Relied on to

Meet the Requirements of the Station Blackout Rule for License Renewal (ISG-02);"

2.1.6.4, "Fire Protection System Piping (ISG-04);" and 2.1.6.7, "Scoping of Fire

Protection Equipment for License Renewal (ISG-07);" the applicant discussed the

scoping methodology as it related to the regulated event criteria in accordance with

10 CFR 54.4(a)(3). With respect to the scoping criteria set forth in 10 CFR 54.4(a)(3),

the applicant evaluated all regulated events including fire protection, environmental

qualification, pressurized thermal shock, anticipated transient without scram, and station

blackout. For each event, the applicant identified the plant-specific licensing basis

documents applicable to each regulated event, such as the final safety analysis report,

safety evaluation reports (SERs), licensing correspondence, plant-controlled databases,

calculations, and analyses to establish the scoping determinations. SSCs relied upon in

safety analyses or plant evaluations to perform a function that demonstrates compliance

with the applicable regulations were initially included within the scope of license renewal.

2.1.2.1.2 Documentation Sources Used for Scoping and Screening

In LRA Section 2.1.3, "Documentation Sources Used for Scoping and Screening," the applicant

stated information derived from the following sources was reviewed during the license renewal

scoping and screening process:

* final safety analysis report

* current licensing basis. Information including technical specifications (TS) and docketed

licensing correspondence

* System Functional Requirements Manual (SFRM)

* technical position papers and reports prepared to support scoping evaluations of

10 CFR 54.4(a)(2) and the regulated events identified in 10 CFR 54.4(a)(3)

* Maintenance Rule summary reports and scoping tables

* design-basis summaries (DBSs)

* plant drawings and walkdowns

* PMMS, LRIMS, and the probabilistic risk assessment (PRA) model

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The applicant stated that this information was used to identify the functions performed by plant

systems and structures. These functions were then compared to the scoping 'criteria in

10 CFR 54.4(a)(1)-(3) to determine if the associated plant system or structure performed a

license renewal intended function. These sources were also used to develop the list of

structures and components subject to an AMR.

2.1.2.1.3 Plant and System-Level Scoping

In LRA Section 2.1.4, "Scoping Methodology," the applicant described the scoping methodology

for plant systems and structures that were safety-related, non safety-related, and equipment

relied upon to perform a function for the any of the five regulated events described in

10 CFR 54.4(a)(3).

The scoping for systems and structures was performed as two separate efforts. For system

scoping, systems presumed to be within the scope of license renewal were based on the

following criteria: any system containing a component whose safety classification in PMMS met - one of the scoping criteria; a system function taken from the Maintenance Rule documentation;

a DBS or SFRM with a license renewal intended function as defined by 10 CFR 54.4; system

functions meeting the criteria of 10 CFR 54.4(a)(2) or (3); and systems which performed one or

more intended functions. The preliminary scoping results were used as input to the screening

process. The results of the completed screening process were used as input for reviewing and

updating the system scoping results. The final system scoping results are presented in Section

2.2 of the LRA.

For structures, a structure was initially identified as being within the scope of license renewal if

one or more of the criteria of 10 CFR 54.4(a) were met as identified in the' FSAR (such as:

Class I structure designation), the 10 CFR 54.4(a)(2) report (LRA Section 2.1.3.6), or the

10 CFR 54.4(a)(3) regulated event reports (LRA Section 2.1.3.7). In some cases, MPS Unit 1

structures were included in scope for Units 2 and 3 since they provide an intended function.

After the screening process for mechanical and electrical -systems was completed, the lists of

in-scope structures was reviewed and validated to ensure that all structures supporting in-scope

systems or components were identified and included in scope. The final scoping results for

structures are presented in Section 2.2 of the LRA.

2.1.2.2 Screening Methodology

Following the determination of plant systems and structures that were candidates for inclusion

within the scope of license renewal,' the applicant implemented a process for determining which

passive components, structural members; and commodities that support a license renewal

intended function would then be subject to an AMR in accordance with the requirements of';

10 CFR 54.21(a)(1); This process is described in LRA Section 2.1.5, "Screening Methodology.":

The screening portion of the integrated license renewal plant assessment wa's divided by

engineering discipline into three primary areas: system (mechanical),- civil/structural, and

electrical/instrumentation and controls (I&C). . ,

The applicant also screened selected major components to identify the passive long-lived

subcomponents that require an AMR, as discussed in Section 2.1.5.2 and Appendix C,

Section C2.2, "Identification of In-scope Passive Subcomponents," of the LRA. Screening

identified NSR SSCs that provide a support function' (such as supplying instrument air, cooling

water, or heating and ventilation) required for in-scope SSCs to perform their intended

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functions. The NSR support SSCs were included within the scope of license renewal in

accordance with 10 CFR 54.4(a)(2) to a level necessary to provide satisfactory accomplishment

of the SR functions identified in 10 CFR 54.4(a)(1).

2.1.2.2.1 System (Mechanical) Screening

Following system-level scoping for mechanical systems, the applicant performed screening to

identify those mechanical components (pumps, valves, piping, etc.) that support the system

intended functions. The intended functions, developed utilizing the documentation sources

discussed previously in Section 2.1.2.1.2 of this report, were used as input to the screening

process to identify the passive components within the scope of license renewal. Passive

component determinations were made in accordance with 10 CFR 54.21 (a)(1)(i) and the

guidance in NEI 95-10, Revision 3. The license renewal boundaries for a mechanical system

flow path were typically extended to include the first normally closed valve (manual valve, check

valve, or automatic valve that receives a signal to close) that forms the flow path pressure

boundary.

Following completion of the screening review for a system, the annotated drawings were used

to generate a set of license renewal drawings which identified the in-scope passive mechanical

components. This included the passive components that were subsequently determined, during

the AMR process, to be short lived, as discussed in Appendix C, Section C2.3 of the LRA. The

system screening results are presented in LRA Section 2.3, "Scoping and Screening Results:

Mechanical Systems," for each mechanical system containing in-scope mechanical

components. The information includes the system description, FSAR references, license

renewal drawings, and the components subject to an AMR. A screening summary table lists the

component groups that require an AMR along with the associated intended functions. The

screening section also includes a reference to the AMR results table. Screening for major

components within the reactor coolant system (i.e., the reactor vessel, reactor vessel internals,

and steam generators) was performed separately from the remainder of the reactor coolant

system (RCS) components. Detailed screening was performed to identify subcomponents that

perform or support intended functions. The results of the major components screening are

presented in Section 2.3.1.1, Section 2.3.1.2, and Section 2.3.1.4 of the LRA.

2.1.2.2.2 Structural Screening

Screening was performed for each in-scope structure identified during the scoping process.

Structure screening identified the passive structural members (walls, beams, floors, grating,

block walls, missile shields, pads, liners, etc.) that support the intended functions of the

structure and, therefore, require an AMR. The structural members that require an AMR were

identified based on a review of the structural detail drawings. The screening process for nuclear

steam supply system equipment supports was similar to the process for structural screening.

The structural members of the support that require an AMR were identified based on a review

of detailed support drawings. Load-handling cranes and devices were evaluated based on a

review of the FSAR and the data in PMMS. Load-handling cranes and devices that were

seismically designed are within the scope of license renewal. Structural supports were

evaluated as a commodity grouping termed ugeneral structural supports." Other miscellaneous

items such as cable tray covers, barrier doors, penetration fire seals, cabinets, and panels were

evaluated as a commodity grouping termed "miscellaneous structural commodities." The

screening results are presented in LRA Section 2.4, 'Scoping and Screening Results:

Structures."

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2.1.2.2.3 Electrical/l&C Components Screening.;

The majority of electrical/l&C components (such as transmitters, switches, breakers, relays,

actuators, radiation monitors, recorders, isolators, signal conditioners, meters, batteries,

analyzers, chargers, motors, regulators, transformers; and fuses) are active components, in

accordance with 10 CFR 54.21 (a)(1)(i) and the'supplemental guidelines in NEI 95-10 and,

therefore, do not require an AMR. The'electricaUl&C components that are in scope only

because they perform a passive pressure boundary function were treated as mechanical

components and ideitified during the mechanical system screening process. An AMR

evaluation is'required for'component groups such as cables and connectors, electrical

penetrations, and bus ducts since they perform a passive function.' The electrical screening

results are presented in LRA Section 2.5, "Scoping and Screening Results: Electrical and

Instrumentation and Controls Systems."

2.1.2.2.4 Stored Equipment Screening

In response to a February 11, 1999, letter from Christopher I. Grimes, Nuclear Regulatory'

Commission (NRC), to Doug Walters, NEI, "Request for Additional Information Regarding'

Generic License Renewal Issue No. 98-0102,' Screening of Equipment that is Kept in Storage,'"

a review was'performed by the applicant to identify equipment that is m aintained in storage,

reserved for installation in the plant in response'to a design-basis accident or regulated event,

and requires an AMR. The equipment in storage that performs'an intended function and is

subject to an AMR includes hardware that is dedicated to the following intended functions:

* mitigates the effects of a fire

protects against flooding' of a service water pump motor

* provides temporary local valve operation'in an abnormal operating event

* protects against flooding of the fire pump houses

* protects against flooding of the turbine building and intake structure -

In addition to passive components, the review has also considered stored, active components

that are not routinely inspected, tested, and 'maintained.

2.1.3 Staff Evaluation ' - '

The staff evaluated the LRA scoping and screening methodology in accordance with the

guidance contained in-Section 2.1, "Scoping and Screening Methodology," of.NUREG-1 800,

"Standard Review Plan for Review of License Renewal Applications for Nuclear Power!Plants."

The acceptance criteria for the scoping and screening methodology review is based on the'

following regulations:

10 CFR 54.4(a), as it relates to the identification of plant SSCs within the scope of the

Rule , ;.

* 10 CFR 54.4(b), as it relates to the identification of the intended functions of plant SSCs

determined to be within the scope of the Rule

* 10 CFR 54.21 (a)(1) and (2), as they relate to the methods used by the applicant to

identify plant SCs subject to an AMR

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As part of the review of the applicant's scoping and screening methodology, the NRC staff

reviewed the activities described in the following sections of the LRA using the guidance

contained in NUREG-1800:

* Section 2.1, "Scoping and Screening Methodology," to ensure that the applicant

described a process for identifying SSCs that are within the scope of license renewal in

accordance with the requirements of 10 CFR 54.4(a)(1) - (3)

* Section 2.2, 'Plant Level Scoping Results;" Section 2.3, "System Scoping and Screening

Results: Mechanical Systems;" Section 2.4, uScoping and Screening Results:

Structures;" and Section 2.5, 'Scoping and Screening Results: Electrical and

Instrumentation and Control Systems;" to assure the applicant identified the

civil/structural, mechanical, and electrical/I&C components that are subject to an AMR in

accordance with the requirements of 10 CFR 54.21 (a)(1) and (2).

In addition, the staff conducted a scoping and screening methodology audit at the MPS in

Waterford, CT, from May 3 - 7, 2004. The focus of the audit was to ensure that the applicant

had developed and implemented adequate guidance to conduct the scoping and screening of

SSCs in accordance with the methodologies described in the application and the requirements

of the Rule. The staff reviewed implementation procedures and engineering reports which

describe the scoping and screening methodology implemented by the applicant. In addition, the

staff conducted detailed discussions with the applicant on the implementation and control of the

license renewal program and reviewed administrative control documentation and selected

design documentation used by the applicant during the scoping and screening process. The

staff further reviewed a sample of system scoping and screening results reports for the

chemical and volume control system (CVCS) to ensure the methodology outlined in the

administrative controls was appropriately implemented and the results were consistent with the

CLB.

2.1.3.1 Scoping Methodology

The staff reviewed MPS implementation procedures, technical bases documents and reports,

engineering reports, and project guidelines (GDLs) which describe the scoping and screening

methodology implemented by the applicant. The applicable guidelines included GDLs 101,

'Personnel Qualification and Training;" 201, "System and Structure Screening;" 401,

'Discrepancy Management;" 501, 'Quality Assurance Requirements and Document Control;"

and 601, 'LRIMS Users Guide." The staff found that the scoping and screening methodology

instructions were consistent with Section 2.1 of the LRA and were of sufficient detail to provide

the applicant's staff with concise guidance on the scoping and screening implementation

process to be followed during the LRA activities. In addition to the implementing procedures,

the staff reviewed supplemental design information including system functional descriptions,

system drawings, and selected licensing documentation, which were relied upon by the

applicant during the scoping and screening phases of the review. The staff found these design

documentation sources to be useful for ensuring that the initial scope of SSCs identified by the

applicant was consistent with the CLB of Units 2 and 3.

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2.1.3.1.1 Application of the Scoping Criteria in 10 CFR 54.4(a)

A1plication of the Scopina Criteria in 10 CFR 54.4(a)(1). Pursuant to 10 CFR 54.4(a)(1), the

applicant must consider all SR SSCs which are relied upon to remain functional during and

following DBE to ensure the following functions' (i) the integrity of the reactor coolant pressure

boundary; (ii)'the ability to shut down the reactor and maintain it in a safe shutdown condition;

or (iii) the capability to prevent or mitigate the consequences of accidents which could result in

potential offsite'exposures comparable to those referred to in 10 CFR 50.34(a)(1), -

10 CFR 50.67(b)(2), or 10 CFR Part 100.11 of the'Code of Federal Regulations, to be within'the'

scope of license renewal. The 'staff found that theX applicant appropriately incorporated the

pertinent SR SSCs into the scope of its license renewal program: The applicant relied on PMMS

as a starting point for identifying systems within the scope of the Rule.'Other document sources

included LRIMS, the FSAR, technical specifications, documents related to scoping for

implementation of 10 CFR 50.65, the Maintenance Rule, and documents related to the MPS

PRA model. Additional information sources included docketed licensing correspondence and

design information related to various plant systems and technical position papers.

MPS License Renewal Technical Report MP-LR-3000/4000, "System/Structure Scoping,"

provides guidance for the performance of scoping for mechanical and electrical systems and for

structures. The document describes the determination of intended functions for systems and

structures, identifies in-scope systems and structures based on the functions, and documents

the results in the scoping report. The determination of intended functions for systems is based

on the design and licensing basis documentation, license renewal technical reports for

10 CFR 54.4(a)(2) and (3) intended functions, and PMMS indicators used as input for intended

function determinations.

Structure intended functions were based on the same criteria established for systems. In

addition,-structures that provide support or shelter for in-scope SSCs and perform an intended

function are-considered in scope for license renewal. Scoping of MPS Unit 1 systems and.

structures was performed to identify any systems or structures that support Unit 2 or 3 intended

functions. As a result,- Unit 1 fire protection system components that must remain functional to

support Units 2 and 3.have been re-assigned to the appropriate unit. For structures, the Unit 1

turbine building flood wall and the control room/radwaste buildings have been included in

scope. As part of the review of the applicant's scoping methodology, the staff reviewed a

sample of the PMMS database, 10 CFR 54.4(a)(1) scoping results, a sample of the scoping

result reports to support these reviews, and held discussions with the applicant's technical staff.

Conclusion. The staff reviewed a sample of the license renewal database 10 CFR 54.4(a)(1)

scoping results and discussed the methodology and results with the applicant's license renewal

project personnel. The staff verified that the applicant had identified 'and used pertinent

engineering and licensing information to determine the SSCs required to be in scope in

accordance with the 10 CFR 54.4(a)(1) criteria.'Therefore, on the basis of this sample review,

discussions with the applicant, and review of the applicant's scoping process, the staff -

determined that the applicant's methodology for identifying systems and structures that meet

the scoping criteria of 10 CFR 54.4(a)(1) was adequate.

Application of the Sconina Criteria in 10 CFR 54.4(a)(2). Pursuant to 10 CFR 54.4(a)(2), the

applicant must consider all NSR SSCs whose failure could prevent satisfactory accomplishment

of any of the functions identified in paragraphs 1 0 CFR 54.4(a)(1)(i) - (iii), to be within the scope

of the license renewal. By letters dated December 3; 2001, and March 15,2002, the NRC

2-9 '
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issued a staff position to NEI which provided staff expectations for determining which SSCs

meet the 10 CFR 54.4(a)(2) criterion.

The December 3, 2001, letter provided specific examples of operating experience which

identified pipe failure events (summarized in NRC Information Notice (IN) 2001-09, 'Main

Feedwater System Degradation in Safety-Related ASME Code Class 2 Piping Inside the

Containment of a Pressurized Water Reactor") and the approaches the NRC considers

acceptable to determine which piping systems should be included in scope based on the

10 CFR 54.4(a)(2) criterion. The March 15, 2002, letter further described the staffs

expectations for the evaluation of non-piping SSCs to determine which additional NSR SSCs

are within scope. The position states that applicants should not consider hypothetical failures,

but rather should base their evaluation on the plant's CLB, engineering judgment and analyses,

and relevant operating experience. The paper further describes operating experience as all

documented plant-specific and industry-wide experience that can be used to determine the

plausibility of a failure. Documentation would include NRC generic communications and event

reports, plant-specific condition reports, industry reports, and engineering evaluations.

The applicant's methodology for performing 10 CFR 54.4(a)(2) scoping of NSR SSCs was

documented in MPS License Renewal Technical Report MP-LR-3007/4007, "10 CFR 54.4(a)(2)

Report." The document described the current regulation and the interim staff position regarding

scoping of SSCs with respect to the 10 CFR 54.4(a)(2) criterion, and the applicant's

methodology, discussions, and results regarding scoping in accordance with the Rule criteria. In

keeping with the NEI draft position on NSR SSCs that could adversely affect SR SSCs, the

applicant developed guidance for interpreting and applying the (a)(2) criterion including NSR

components spatially oriented near SR components, seismic 11/I components, NSR piping

attached to SR piping, flooding, missiles, and high-energy line break.

For non-fluid-containing components, the applicant identified neither spray or leakage concerns

nor any industry operating experience indicating a loss of structural integrity. Also, NSR nonfluid-containing components are not in scope for 10 CFR 54.4(a)(2) unless related to NSR

attached to SR or to a seismic 11/I concern for system components not located in a sheltered

environment. For fluid-containing components, the applicant considered greater than 275 PSIG

or greater than 200'F as high energy and used the spaces approach, which considered

everything within the structure in scope for license renewal. For low energy, a spatial approach

was used based on plant walkdowns by MPS staff. Air and gas systems were excluded from

consideration. The applicant provided a list of systems in the 10 CFR 54.4(a)(2) report that

contain NSR components spatially oriented such that failure could affect the function of SR

components.

During the staff's review of LRA Section 2.1.3.6, "10 CFR 54.4(a)(2) Report," and the

applicant's technical report prepared to address the issue, the applicant stated that NSR piping

that is attached to SR piping, and that is seismically designed and supported up to the first

equivalent anchor point beyond the SRINSR boundary, is included within the scope of license

renewal. However Section 2.1.3.1.2 of NUREG-1800 states that the scoping methodology

includes both the NSR piping and the associated piping anchors as being within the scope of

license renewal pursuant to 10 CFR 54.4(a)(2).

In RAI 2.1-1, the staff requested additional information regarding the scoping methodology

associated with the 10 CFR 54.4(a)(2) evaluation. The staff requested that the applicant define

the term "first equivalent anchor point" as it relates to the evaluation of NSR piping attached to

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SR piping and describe the methodology of its application. Additionally, in cases where plant

equipment credited with providing support to NSR piping within the scope of license renewal

may be equivalent to an associated piping anchor as described in NUREG-1 800, the staff

requested that the applicant provide justification for not including this plant equipment within the

scope of license renewal. The staff also requested that the applicant describe the methodology

and documentation sources used to perform walkdowns associated with the review of NSR

fluid-containing components located near SR'components (spatial interaction); and for lowenergy, fluid-containing NSR components, describe the extent to which engineering judgment

was used to identify NSR components that may affect SR components.

The applicant's November 9, 2004, response to the RAI stated that for the purpose of license

renewal, the first equivalent anchor is defined as .when the piping has been restrained in each

of the three orthogonal directions.: The response also recognized that, in some cases, plant

equipment may be credited as providing restraint in one or more directions in the'piping system

seismic evaluation. Dominion stated that in these cases,the credited components are also

included within the scope of license renewal. The applicant applied the following six criteria in

the determination of the license renewal boundary endpoints for NSR piping attached to SR

piping: -'

(1) The NSR piping terminates at plant equipment that is mounted to a baseplate supported

by a structure or mounted to a foundation (base-mounted component). In this instance,

the base-mounted component and supporting structure are included within the scope of

license renewal.

(2) The NSR piping is attached to an SR piping run or component, constituting an endpoint

for the purpose of this' evaluation, since the attached SR piping would have been

included in scope per 10 CFR54.4(a)(1). "''

(3) A flexible connection in the NSR piping segment such as an expansion joint, flexible

hose, or other component that effectively decouples the piping system.

(4) In the case of an NSR piping segment that has transitioned'below-ground, a point where

the buried NSR 'piping segment exits the ground. '

(5) The NSR piping run transitions to small diameter branch piping, where the area moment

of inertia ratio of the larger diameter piping to the smaller diameter piping is greater than

or equal to 10.

(6) The end of the NSR piping run, such as a drain pipe that ends at an open floor drain.

The applicant stated that these conservtive 'criteria provide assurance that the first equivalent

anchor is' included within the license renewal boundary. Dominion stated that in some cases,

this bounding approach'resulted in an overly conservative license renewal boundary determination. In cases where it was deemed appropriate to limit the additional scope for a

specific piping system, specific piping anchors (or equivalent anchors) were identified via the

review of isometric piping drawings. In a limited number of instances where isometric drawings

were not available, plant walkdowns were'performed to determine the'location of the piping''

anchors (or equivalent anchors). This methodology'provided for'the determination of licenserenewal boundary endpoints that are'at or beyond the location of the first equivalent anchor

point for NSR piping that is'attached to'SR piping. Dominion stated that the associated piping

supports anrd plant equipment, 'up'to and iicluding the license renewal boundary.endpoints, are

included within the scope of license renewal. However, the staff had concerns with the criteria's.

2-.11
consistency with the CLB and whether the criteria established by the applicant would

conservatively bound the equivalent anchor. This was identified as Open Item 2.1.3-1.

In response to Open Item 2.1.3-1, the applicant provided additional information to the staff on

April 1, 2005, regarding the basis of the six bounding criteria used in the determination of the

license renewal boundary endpoints for NSR piping attached to SR piping. The applicant stated

that the bounding criteria provided assurance that the license renewal scoping boundary would

envelop the scope of the NS piping system included in the design basis seismic analysis,

consistent with the CLB, and in some cases, the bounding approach resulted in an overly

conservative license renewal boundary determination. The applicant also provided the staff with

a revised definition of an equivalent anchor to be used for the purposes of identifying the NS

piping in the scope of license renewal during the case-by-case reviews. The revised definition

was changed from one restraint in each of the three orthogonal directions to two restraints. A

review was performed by the applicant to apply this equivalent anchor definition to the cases

where the LR boundary endpoint was previously determined through piping analysis/isometric

drawing review or plant walkdown. The applicant stated that as a result, the LR boundary was

extended where necessary to include additional supports and portions of piping systems;

however, there were no additional component types as a result of these boundary extensions.

Based on the above discussion, the staff concludes that the applicant has supplied sufficient

information to demonstrate that SSCs, that meet the scoping requirements of

10 CFR 54.4(a)(2), have been identified as being within the scope of license renewal.

Therefore, Open Item 2.1.3-1 is considered closed.

As described in LRA Section 2.1.3.6, NSR fluid-containing components that are spatially

oriented such that their failure could prevent the satisfactory accomplishment of an SR function

of an SR SSC, are included within the scope of license renewal. The applicant stated that

identification of these NSR components was based on knowledge-based reviews of the facility

configuration and were conducted by experienced plant personnel, supplemented by facility

walkdowns, as needed. NSR fluid-containing components in low-energy systems that could

affect the function of SR SSCs due to their spatial orientation were determined based on the

judgment of the evaluator. Considerations included collapse envelope, fluid leakage, spray, and

flood potential. Dominion developed more comprehensive guidelines to limit the use of

judgment in the determination of these in-scope NSR components.

Dominion's revised spatial orientation guidelines also considered whether the fluid contents

from an NSR component could flow from the area through doorways, grating, or floor

penetrations, and then drip on SR components in an adjacent area. As such, credit may be

taken for mitigating features such as curbing, dikes, and floor drains which are also included

within scope of license renewal. These revised criteria provide comprehensive guidance for the

determination of the NSR components in low-energy systems that could affect SR SSC

functions due to their spatial orientation.

Dominion stated that implementation of these revised methodologies has resulted in the

addition of eight Unit 2 systems. Also, the implementation of the spatial and/or NSR-attachedto-SR piping methodologies caused many systems, previously within the scope of license

renewal, to have expanded license renewal boundaries. Additionally, as a result of the revised

methodology regarding NSR-attached-to-SR piping, the Unit 3 groundwater underdrains

storage tank and the foundation of the primary water storage tank (previously listed in LRA

Table 2.2-4 as not in scope for Unit 2), were also added to the scope of license renewal.

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For seismic 11/1, the applicant stated that Unit 2 was designed to meet the seismic criteria stated

in FSAR Section 5.8.4, while Unit 3 was designed tocomply with USNRC Regulatory Guide

(RG) 1.29, "Seismic Design Classification,", Revision 3, dated September,1978. The applicant

performed a walkdown of the components on the Unit 2 safe'shutdown equipment list

developed for NRC Unresolved Safety Issue A-46 in response to NRC Generic Letter (GL) 87-

02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating

Reactors," USNRC, dated February 19,1987. During the walkdown, potential seismic system

interactions that could physically impact safe shutdown equipment were reviewed to ensure that

equipment within the scope of the review was not affected by the failure or displacement of

adjacent structures, piping, or equipment due to physical impact. Particular attention was given

to NSR equipment affecting SR equipment. In the screening process, the applicant used a

spaces approach to accommodate seismic 11/I supports and a commodity approach to evaluate

them. 0'

For NSR fluid-containing components located near SR components (spatial orientation), the

applicant queried the PMMS database to determine the structures that contain SR components

and the fluid-containing NSR components in the structures that contain SR components. These

components are relied on to maintain their limited structural integrity (LSI) and pressure

boundary to ensure that the SR components in the vicinity can perform their intended

function(s). The applicant used the term LSI to define sufficient structural integrity to preclude

detrimental effects on SR components and applied the term to fluid-containing components that

may experience loss of LSI from intemal- or external-related degradation. The applicant

provided a list of systems containing NSR fluid-containing components in Attachments 1 and 2

of its 10 CFR 54.4(a)(2) report.

Conclusion. As part of the review of the applicant's scoping methodology, the staff also

reviewed a sample of the license renewal database scoping results to determine if the

methodology adequately identified NSR SSCs meeting the 10 CFR 54.4(a)(2) scoping criteria.

Based on this review, and as described above, the applicant's methodology for scoping NSR

equipment adequately identified those NSR'SSCs whose failures are considered in the CLB

and could prevent the satisfactory accomplishment of the SR functions identified under

10 CFR 54.4(a)(1). Therefore, the staff determined that the applicant's methodology for

identifying systems and structures meeting the scoping criteria of 10 CFR 54.4(a)(2) was

adequate. -,

On the basis of the staff's review of the LRA, the staff's audit of the applicant's scoping and

screening methodology, the staff's review of the applicant's response to the RAI, and the'

applicant's review and evaluation of relevant operating experience, the staff concludes that the

applicant supplied sufficient information to demonstrate that all SSCs meeting the

10 CFR 54.4(a)(2) scoping requirements have been identified as being within the scope of

license renewal. -

Apolication of the Scooina Criteria in 10 CFR 54.4(a)L(3. Pursuant to 10 CFR 54.4(a)(3), the

applicant must consider all SSCs relied on in safety analyses or plant evaluations which

perform a function that demonstrates compliance with the Commission's regulations for fire

protection (10 CFR 50.48), environmental qualification (10 CFR 50.49), pressurized thermal

shock (10 CFR 50.61), anticipated transients without scram (10 CFR 50.62), and station'

blackout (10 CFR 50.63) to be within the scope of the license renewal. The applicant's

methodology for performing the scoping of SSCs in accordance with .10 .CFR 54.4(a)(3) was

documented in MPS License Renewal Project Technical Reports MP-LR-3002/4002 through

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3006/4006 developed by the applicant for each regulated event applicable to MPS Units 2 and

3. The applicant performed the initial scoping for regulated events by evaluating CLB

information relevant to each regulated event to identify if the structure or system met the

scoping criteria of 10 CFR 54.4(a)(3). For each event, the applicant developed a technical

report which described the following: the relevant rule requirements; a functional description of

the implementation of that requirement at the MPS Units 2 and 3; specific information regarding

systems and components credited for the event; the process to identify the scoping boundaries

associated with the systems credited; the intended functions applicable to the requirement; a

list of CLB information sources used for the analysis; and a list of systems and components

determined to be within scope for the given regulated event.

Station Blackout. MPS License Renewal Project Technical Report MP-LR-3006/4006, Revision

3, provided the plant design information for MPS Units 2 and 3 pertaining to the SBO system.

All plant systems were reviewed to determine which SSCs were required to achieve and

maintain a reactor coolant system temperature equal or below the TS limit for a hot standby

condition, assuming an SBO. The technical report stated that all SSCs that performed a

function that supported compliance with 10 CFR 50.63 were within the scope of license

renewal.

In an April 1, 2002, letter from D. Matthews (NRC) to A. Nelson (NEI) and D. Lochbaum (Union

of Concerned Scientists), the staff provided guidance on the scoping of equipment relied on to

meet the requirements of the SBO rule. In this letter, the staff noted that, consistent with the

requirements specified in 10 CFR 54.4(a)(3) and 10 CFR 50.63(a)(1), the plant system portion

of the offsite power system that is used to connect the plant to the offsite power source should

be included within the scope of the Rule. In LRA Section 2.1.3.7.5, the applicant stated that the

SBO scoping effort identified SCs of the offsite power system for each plant required to restore

power from the onsite switchyard down to the SR busses in the plant. Furthermore, the

applicant stated that the plant offsite power system and these SCs, which were classified as

satisfying 10 CFR 54.4(a)(3), were included within the scope of license renewal. The staff

determined that the applicant's approach to scoping SSCs relied on to demonstrate compliance

with 10 CFR 50.63 was consistent with the staff's April 1, 2002, interim guidance.

Environmental Qualification. MPS License Renewal Project Technical Report MP-LR3002/4002, Revision 2, provided the plant design information for MPS Units 2 and 3 pertaining

to the EQ program. The EQ program had three major elements for compliance that were

reviewed by the staff: design basis, design verification, and implementation. Section 2.1.3.7.2 of

the LRA described how the program was developed to maintain compliance with 10 CFR 50.49.

The electrical components that fell within the scope of the program were identified in the

environmental qualification master list (EQML) and the PMMS. The staff reviewed a sample of

components in the EQML and PMMS and determined that they were appropriately classified as

within the scope of the Rule. Additionally, the staff found that components such as doors,

penetrations, seals, and dampers that provide a barrier between mild and harsh areas of the

plants were also included within the scope of license renewal.

Anticipated Transient Without Scram. MPS License Renewal Project Technical Report MP-LR3003/4003, Revision 2, provided the plant design information pertaining to the ATWS systems

at MPS Units 2 and 3. The staff reviewed the report which described how the requirements of

10 CFR 50.62 were fulfilled at MPS Unit 2 by the diverse scram system (DSS) and the ATWS

mitigating system actuating circuitry (AMSAC). At Millstone Unit 3, the requirements of

10 CFR 50.62 were fulfilled by AMSAC as validated by the Westinghouse AMSAC generic

2-14
design. The staff reviewed Section 2.1.3.7.4 of the LRA for each unit, which further discussed

the AMSAC and DSS systems. The technical report concluded that all SSCs that perform a

function which supports compliance with 10 CFR 50.62 were within the scope of license

renewal.

Fire Protection. MPS License Renewal Project Technical Report MP-LR-3005/4005, Revision 4,

provided the plant design information pertaining to the fire protection systems and fire safe -.

shutdown systems for MPS Units 2 and 3. The staff reviewed the report that described the fire

protection and fire safe shutdown equipment as it related to SSCs that are required by

10 CFR 50.48 and included within the scope of license renewal. The report also described the

basis for excluding some fire-protection SSCs'from the scope of license renewal. The staff also

reviewed LRA Section 2.1.3.7.1 for each unit that described the review performed to identify

specific SSCs that fell within the scope of license renewal for fire protection including those

relied upon in the fire hazard analysis. -

Pressurized Thermal Shock. MPS License Renewal Project Technical Report MP-LR3004/4004, Revision 0, provided the plant design information pertaining to PTS for MPS Units 2

and 3. The staff reviewed the report that stated that all SSCs performing a function that

supported compliance with 10 CFR 50.61 were within the scope of license renewal. The report

also stated that an engineering calculation (95-SDS-1007MG) was performed to determine

reactor vessel material nil-ductility transition temperature values for the 20-year renewal term

and compared to the screening criteria of 10 CFR 50.61. The results indicated both units would

remain compliant with the regulation screening criteria for the 20-year renewal term without any

additional compensatory actions. The staff also reviewed Section 2.1.3.7.3 of the LRA, which -

briefly described the contents of the report noted previously in this paragraph. The evaluation of

reactor pressure vessel material was further described in Section 4.2 of the LRA.

Conclusion.; As part of the review of the applicant's scoping methodology, the staff reviewed a

sample of the license renewal database 10 CFR 54.4(a)(3) scoping results, reviewed a sample

of the analyses and documentation to support these reviews, and discussed the methodology

and results with the applicant's personnel responsible for these evaluations. The staff verified

that the applicant had identified and used pertinent engineering and licensing information to

determine the SSCs required to be in scope in accordance with 10 CFR 54.4(a)(3). Based on

this sampling review and discussions with the applicant, the staff determined that the

applicant's methodology for identifying systems and structures meeting the scoping criteria of

10 CFR 54.4(a)(3) was adequate. ;. ' .C

2.1.3.1.2 Plant System and StructureScoping * . ~~ . . . . . ~ , I 

The applicant's methodology for performing the scoping of systems and structures in

accordance with 10 CFR 54.4(a) was documented in MPS License Renewal Project Technical

Report MP-LR-3000/4000, Revision-7,."System/Structure Scoping Millstone Power Station."

The approach used by the applicant for system and structure scoping was consistent with the

methodology described in Section 2.1.4 of the IRA. Specifically, MP-LR-3000/4000 stated that

personnel performing license renewal scoping use CLB documents and list all functions that the

system or structure is required to accomplish. .Sources of information regarding the CLB for

systems and structures included the FSAR, DBS, system descriptions, PMMS database,

Maintenance Rule information, plant drawings,-and the SERMs. The applicant utilized a twostep process for system/structure scoping. After the preliminary identification of potential inscope systems/structures, the screening process then reviewed each potential in-scope

2-15
system/structure in detail to confirm, supplement, or refute the preliminary determinations made

during the scoping process. The applicant first identified all plant systems using PMMS, then

evaluated them against the scoping criterion of 10 CFR 54.4(a)(1)-(3) to identify those systems

that perform one or more intended functions.

A system or structure was presumed to be within the scope of license renewal if it performed

one or more SR functions or met other scoping criteria per the Rule as determined by CLB

review and walkdown by technical personnel. Identified system or structure functions were then

compared to a list of scoping and screening questions to determine the functions that met the

scoping criteria of 10 CFR 54.4(a). The applicant documented the results of the scoping

process in accordance with MPS MP-LR-3000/4000, Attachments A through E, "MPS Unit 2/3

Database Scoping Matrix." The scoping matrix included a description of the structure or system,

the 10 CFR 54.4(a) scoping criteria met by the system or structure, and references. Due to

design differences between the units, separate lists identifying the in-scope structures and

systems for each unit were developed. During the scoping methodology audit, the NRC staff

reviewed a sampling of the applicant's scoping documentation and concluded that it contained

an appropriate level of detail to document the scoping process.

Conclusion. Based on a review of the LRA, the scoping and screening implementation

procedures, and a sampling review of system and structure scoping results during the

methodology audit, the staff concluded that the applicant's scoping methodology for systems

and structures was adequate. In particular, the staff determined that the applicant's

methodology reasonably identified systems and structures within the scope of license renewal

and their associated intended functions.

2.1.3.2 Screening Methodology

The staff reviewed the screening methodology used by the applicant to determine if mechanical

systems, structures, and electrical/l&C components within the scope of license renewal would

be subject to an AMR. The applicant described its screening process in Section 2.1.5 of the

LRA. The initial scoping effort described in LRA Section 2.1.4 identified the plant systems and

structures that were candidates for inclusion within the scope of license renewal. Screening was

performed in accordance with the guidance provided in NEI 95-10, Revision 3, and applicable

NRC interim staff guidance.

MPS License Renewal Project Guideline GDL 201, System and Structure Screening," was

used by the applicant during the screening process. The document provides guidance to

determine intended functions, develop license renewal drawings and component groups, and

identify passive components and structural members subject to an AMR. For each of those

systems and structures, screening was performed to identify the passive components,

structural members, and commodities that support an intended function and subject to further

AMR. The components that are short-lived (and therefore did not require an AMR) were

identified as part of the AMR process, as discussed in LRA Section C2.3, "Identification of

Short-lived Components and Consumables." Screening was divided by engineering discipline

into three primary areas: system (mechanical), civil/structural, and electrical/l&C. The screening

results were used to validate the initial lists of systems and structures within the scope of

license renewal. Scoping results were updated as necessary to reflect the screening results.

The screening processes for these areas are described in LRA Sections 2.1.5.1, 2.1.5.3, and

2.1.5.4. Section 2.1.5.5 summarizes the screening review performed for stored equipment. The

staff evaluated the applicant's screening methodology against the criteria contained in

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10 CFR 54.21 (a)(1) and (2) using the review guidance contained in NUREG-1 800,

Section 2.1.3.2, "Screening."

Pursuant to 10 CFR 54.21(a)(1), the applicant's integrated plant assessment (IPA) must identify

and list those SCs subject to an AMR. The criterion also requires that SCs subject to an AMR

shall encompass those that (i) perform an intended function, as described in 1 0 CFR 54.4,

without moving parts or a change in configuration or properties; and (ii) are not subject to

replacement based on a qualified life or specified time period. In accordance with.'

1 0 CFR 54.21 (a)(2), the applicant is also required to describe and justify the methods used to

comply with 10 CFR 54.21 (a)(1). The staff evaluation of the applicant's screening approach for

each of these disciplines is described in Sections 2.1.3.2.1, 2.1.3.2.2, and 2.1.3.2.3.

2.1.3.2.1 System (Mechanical) Screening

The staff reviewed the methodology used by the applicant to determine if mechanical systems,

identified within the scope of license renewal, were screened to determine the in-scope

boundary and the passive components that would be subject to further AMR. For mechanical

components, a screening process was applied to each mechanical system determined to be in

scope in order to determine the types of mechanical component commodities within the

systems and the various materials and environments to be considered in the AMR. Evaluation

boundaries were established for the various plant mechanical systems, as discussed previously

in Section 2.1.2.2.1, in order to further identify individual mechanical components for review..

Information sources included design and licensing basis documents, plant drawings, technical

reports, and discussions with licensed senior reactor operators and system engineers. The

listing of mechanical components was facilitated by grouping these items into component

groups from a review of specific in-scope passive equipment. Component-level functions were

determined on a component-group basis. Screening reports were developed to document the

results of the screening process. License renewal boundary drawings were developed to show

the in-scope, passive equipment. These groups were placed into the license renewal database

and evaluated in accordance with the screening criteria described in GDL 201. The applicant

provided the staff with a detailed discussion of the process and provided screening report

information from the license renewal database that described the screening methodology as

well as a sample of the screening results reports for a selected group of SR and NSR systems.

The staff determined that the screening methodology was consistent with the requirements of

the Rule and that implementation of the methodology will identify SCs that meet the screening

criteria of 10 CFR 54.21(a)(1). - -

The staff reviewed the methodology used by the 'applicant to identify and list the mechanical

components and commodities subject to an AMR, as well as the applicant's technical

justification for this methodology, and discussed the results with the applicant's cognizant

engineers and license renewal staff. The staff also examined the applicant's screening results

from the implementation of this methodology by reviewing the MPS Units 2 and 3 CVCSs which

were identified as being within the scope of license renewal. The system was selected because

it met all three criteria of 10CFR 54.4(a)(1-(3): The system meets 10 CFR 54.4(a)(1) since it

provides a borated water flow path to the reactor coolant system for reactivity control and for

make-up water in the event of an accident; 10 CFR 54.4(a)(2) because the system contains

NSR components credited for mitigating the effects of a high-energy line break, and the spatial

interaction associated with 10 CFR 54.4(a)(1) components; and 10 CFR 54.4(a)(3) because it

contains environmentally qualified equipment and supports FP and SBO. The staff reviewed the

DBS for Unit 2 (DBS-2304) and Unit 3 (CVC-3304), evaluation boundaries"referenced in license

2-17'
renewal drawings for the system, resultant screened-in components and commodities, the

corresponding component-level intended functions, regulated event evaluations, and the

resulting list of mechanical components and commodity groups subject to an AMR. The staff

also reviewed CVCS Screening Report MP-LR-31 11, Revision 3, which provided function

descriptions and associated scoping criteria classifications. The report lists several categories

including component type (if an AMR was required), and a comment section. The staff also

discussed the process and results with the cognizant engineers who performed the review and

also reviewed the MPS License Renewal Tagging Record, dated February 23, 2004, which

listed passive mechanical components tagged as in scope for CVCS.

During the staffs audit of the applicant's scoping and screening methodology, the staff

questioned the exclusion of the Unit 3 boric acid batch tank from within the CVCS evaluation

boundary. Further review by the applicant determined that the tank in question should have

been included within the evaluation boundary and, therefore, potentially subject to AMR. The

staff verified, through discussion with the applicant, that an extent-of-condition review was

performed to assure that no other similar commodities were excluded from evaluation

boundaries, for other in-scope SSCs, and that the tank would be screened for AMR. The

applicant stated that the exclusion of the tank from the AMR screening process would be

resolved through the use of MPS License Renewal Project Guideline MP-LRP-GDL 401,

Revision 2, 'Discrepancy Management."

Conclusion. The staff determined that the applicant's mechanical component screening

methodology was consistent with the guidance contained in NUREG-1800 and was capable of

identifying those passive, long-lived components within the scope of license renewal that are

subject to an AMR.

2.1.3.2.2 Structural Components Screening

The staff reviewed the methodology used by the applicant to determine if structural components

and commodities within the scope of license renewal would be subject to an AMR. For civil

structures and component supports, a screening process was applied to buildings and civil

structures determined to be in scope to determine the types of structural elements utilized and

the various materials and environments to be considered in the AMR. The staff discussed the

methodology and results with the applicant's technical staff. The staff also examined the

applicant's results from the implementation of this methodology by reviewing a sample of the

plant structures identified as being within the scope of license renewal. The review included the

evaluation boundaries, resultant in-scope components, the corresponding component-level

intended functions, and the resulting list of structural components and structural commodity

groups subject to an AMR. The staff reviewed several LRIMS reports which listed a breakdown

of the structural components within scope of license renewal. Each report listed several

categories including component type and material. Evaluation boundaries were established for

the various plant structures within the scope of license renewal.

In general, the boundary for a building or structure was the entire building, including the

structural members and components that support equipment, piping, ductwork, foundations,

walls, beams, and equipments slabs. The various types of structural elements, materials, and

environments that make up the buildings and structures were identified and listed. The listing of

structural elements was facilitated by grouping these items into commodity groups. A list of

structural commodity groups and components was also developed for each civil/structural

evaluation boundary. The staff reviewed GDL 201 which described the screening methodology,

2-18
including the attachments which described the g'uldelines for identifying passive component

groups requiring an AMR, and MPS License Renewal Technical Reports MP-LR-3728/4728,:

Revision 3, "Structures Monitoring Program," which'described the condition monitoring program

used for in-scope structures.

Conclusion. 'The staff concluded that the screening'methodology was consistent with the

requirements of the Rule; that implementation of the methodology will identify civil/structural

components that meet the screening criteria of 10 CFR 54.21 (a)(1); that the applicant's -

structural component screening methodology was consistent with the guidance contained in

NUREG-1 800; and that the methodology was'capable of identifying those passive, long-lived

components within the scope of license renewal that are subject to an AMR.

2.1.3.2.3 Electrical/l&C Components Screening

The staff reviewed the methodology used by the applicant to determine if electrical/l&C

components within the scope of license renewal would be subject to an AMR. As stated in the

LRA, the'applicant had used the guidelines of NEI 95-10, Revision 3, Appendix B, "Typical

Structure, Components, and Commodity Groupings and Active/Passive Determinations for the

Integrated Plant Assessment," and applied the commodity approach to scoping and screening

of electrical/l&C components. The applicant determined that the following electricalll&C

component groups perform a passive function and require an AMR: cables and connectors,

electrical penetrations, and bus ducts. The screening activities were documented in the

following MPS License Renewal Technical Reports: MP-LR-3655/4655, "License Renewal

Project Aging Management Review Cables and Connectors;" MP-LR-3656/4656, 'License

Renewal Project Aging Management Review Bus Ducts;" and MP-LR-3657, 'License Renewal

Project Aging Management Review Electrical Penetrations."

The staff discussed the'methodology and results with the applicant and reviewed the results

from the implementation of the'methodology by reviewing several electrical/I&C commodity

samples. The review verified that the applicant's staff had consistently applied the screening

criteria to identify those electrical/I&C commodity groups subject to an AMR. The staff also

determined that the electrical screening process was consistent with 10 CFR 54.21 (a)(1)(ii) and

excluded those components or commodity groups that are subject to equipment qualification

requirements. The staff did not identify any discrepancies between the methodology

documented and the implementation results.n-*" - i'

The staff also reviewed the applicant's approach to scoping and screening of electrical fuse

holders. In ISG-5, 'Identificationland Treatment of Electrical Fuse Holders for License

Renewal," dated March 10, 2003,- the staff stated that consistent with the requirements

specified in 10 CFR 54.4(a), fuse holders (including fuse clips and fuse blocks) are considered

passive electrical components. Fuse holders would be scoped, screened, and included in the

AMR in the same manner as terminal blocks and other types of electrical connections that are

currently being treated in the process. .This staff position only applies to fuse holders that are

not part of a larger assembly, but support SR and NSR functions in which the failure of a fuse

precludes a safety function from being accomplished. The applicant stated in MPS License

Renewal.Technical Report MP-LR-3903/4903,-"Interim Staff Guidance," that fuse holders

(including metallic clamps for the fuse clips, insulation material, and fuse blocks) meeting these

requirements will be evaluated before the beginning of the period of extended operation for

possible aging effects requiring management. The fuse holders will either be replaced, modified

to remove the aging effects, or a program will be implemented to manage the aging effects as

2-19
documented in MPS License Renewal Technical Report MP-LR-3731/4731, 'Electrical Cables

and Connectors Not Subject to 10 CFR 50.49 Environmental Qualification Requirements." The

staff determined that this was consistent with the ISG.

Conclusion. The staff concluded that the applicant's electrical/l&C screening methodology was

consistent with the requirements of the Rule; that implementation of the methodology will

identify electrical/l&C components that meet the screening criteria of 10 CFR 54.21(a)(1); that

the applicant's electrical/l&C components screening methodology was consistent with the

guidance contained in NUREG-1800 and the staff's interim guidance, and capable of identifying

passive, long-lived components within the scope of license renewal that are subject to an AMR.

2.1.3.2.4 Stored Equipment Screening

In LRA Section 2.1.5.5, 'Screening of Stored Equipment," the applicant stated that a review had

been performed to identify equipment that is maintained in storage, reserved for installation in

the plant in response to a design-basis accident or regulated event, and requires an AMR. The

LRA stated that the applicant had identified certain equipment maintained in storage which

supported the intended functions of systems within scope of license renewal and indicated that

the identified equipment was subject to an AMR. In addition to passive components, the review

has also considered stored active components that are not routinely inspected, tested, and

maintained.

The staff also reviewed MPS License Renewal Technical Report MP-LR-3920/4920, License

Renewal Project Position Paper, 'Review of Stored Equipment Millstone Power Station," which

documented the applicant's activities regarding the screening of equipment that is stored either

in a warehouse or in staged locations throughout the station. The screening was applicable for

equipment that is normally not in service but is in storage and reserved for use in an application

where it would perform a license renewal intended function when installed. Equipment in

storage included equipment stored in a warehouse, as well as equipment staged within the

plant at locations designated to facilitate its timely use.

To determine if the equipment in storage required an AMR, the applicant had identified stored

equipment that was reserved for installation in a specific location where it performs an intended

function for a system within scope of license renewal in accordance with 10 CFR 54.4(a)(1)-(3).

The intended functions were documented in Section 5 of the MPS Technical Report. Passive

stored equipment and active stored equipment (if not periodically tested) were also subject to

an AMR. Determination of short-lived and long-lived stored equipment was addressed in the

AMR for the respective system. Stored equipment not designated for use exclusively in such

locations was excluded from further consideration (e.g., crimping tools, wrenches, screwdrivers,

propane cylinders/cutter, test meters, flashlights, etc.).

Conclusion. The staff determined that the applicant's approach to scoping and screening of

stored equipment is consistent with 10 CFR 54.4 and will identify stored equipment that meets

the screening criteria of 10 CFR 54.21 (a)(1). Specifically, the staff concluded that the applicant

had appropriately considered equipment maintained in storage which supported the intended

functions of systems within scope of license renewal and indicated that the identified equipment

was subject to an AMR. In addition to passive components, the applicant had also considered

stored active components that are not routinely inspected, tested, and maintained.

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2.1.4 Evaluation Findings

The staff review of the information presented in Section 2.1 of the LRA, the supporting

information in the scoping and screening implementation procedures and reports, the

information presented during the scoping and screening methodology audit, and the applicant's

responses to the staff's RAls, formed the basis of the staffs safety determination. The staff

verified that the applicant's scoping and screening methodology was consistent with the

requirements of the Rule and the staff's position on the treatment of NSR SSCs. On the basis

of this review, the staff concludes that there is reasonable assurance that the applicant's

methodology for identifying SSCs within the scope of license renewal and SCs requiring an

AMR is consistent with the requirements of 10 CFR 54.4 and 10 CFR 54.21 (a)(1).

2.2 Plant-Level Scoping Results - -

In license renewal application (LRA) Section 2.1, the applicant described the methodology for

identifying the SSCs within the scope of license renewal. In LRA Section 2.2, the applicant used

the scoping methodology to determine which of the SSCs are required or not required to be

included within the scope of license renewal. The staff reviewed the plant-level scoping results

to determine whether the applicant had properly identified all plant-level systems and structures

relied upon to mitigate design-basis earthquakes (DBEs), as required by 10 CFR 54.4(a)(1), or

whose failure could prevent satisfactory accomplishment of any of the safety-related functions,

as required by 10 CFR 54.4(a)(2), as well as the systems and structures relied on in safety

analysis or plant evaluations to perform a function required by one of the regulations referenced

in 10 CFR 54.4(a)(3).

2.2A Unit 2 Plant-Level Scoping Results

2.2A.1 Summary of Technical Information In the Application

In LRA Tables 2.2-1 and 2.2-3, the applicant provided a list of the plant systems and structures,

respectively, that are within the scope of license renewal. In LRA Tables 2.2-2 and 2.2-4, the

applicant provided a list of the plant systems and structures, respectively, that are not within the

scope of license renewal. Based on the desigii-basis events considered in the plant's CLB,

other CLB information relating to NSR systenis'and structures, certain regulated events, the

applicant identified those plant-level systems and structures within the scope of license renewal

as defined in 10 CFR 54.4.

In response to RAI 2.1-1 (described in Section 2.1 of this SER), the applicant changed the

methodology used for determining the NSR SSCs that are within the scope of license renewal

in accordance with the requirements of 10 CFR 54.4(a)(2). The applicant's response to

RAI 2.1-1 and supplemental information related to implementation of the revised scoping

methodology are documented in the applicant's response dated November 9, 2004. As a result

of the implementation of the scoping methodology changes, the applicant added to the scope of

license renewal the following, previously excluded, NSR systems:

* aerated liquid radwaste

* solid waste processing

* turbine building closed cooling water

* water box priming

2-21 ,
- l

* auxiliary steam reboiler and deaerating feedwater

* exciter air cooler

* stator liquid cooler

* turbine lube oil

2.2A.2 Staff Evaluation

In LRA Section 2.1, the applicant described its methodology for identifying the structures and

systems that are within the scope of license renewal and subject to an AMR. The staff reviewed

the scoping and screening methodology and provided its evaluation of the methodology in

Section 2.1 of this SER. To verify that the applicant properly implemented its methodology, the

staff focused its review on the implementation results as shown in LRA Sections 2.2-1, 2.2-2,

2.2-3, and 2.2-4, and added systems due to the changed scoping methodologies to confirm that

there was no omission of plant-level systems and structures within the scope of license

renewal.

The staff determined whether the applicant properly identified the structures and systems within

the scope of license renewal in accordance with 10 CFR 54.4. The staff reviewed selected

structures and systems that the applicant did not identify as falling within the scope of license

renewal to verify whether the structures and systems have any intended functions that would

require their inclusion within the scope of license renewal. The staff's review of the applicant's

implementation was conducted in accordance with the guidance described in Standard Review

Plan for License Renewal (SRP-LR) (NUREG-1 800) Section 2.2, "Plant-Level Scoping Results."

The staff sampled the contents of the FSAR based on the listing of systems and structures in

LRA Sections 2.2-1, 2.2-2, 2.2-3, and 2.2-4 to determine whether there were systems or

structures that may have intended functions as defined by 10 CFR 54.4, but were omitted from

the scope of license renewal. The staff review did not identify any omissions.

2.2A.3 Conclusion

The staff reviewed LRA Section 2.2, the applicant's November 9, 2004, RAI response, including

Attachment 1, "Request for Additional Information Responses," and the supporting information

in the FSAR to determine whether any structures or systems within the scope of license

renewal had not been identified by the applicant. The staffs review did not identify any

omissions. On the basis of this review, the staff concludes that the applicant has appropriately

identified the structures and systems that are within the scope of license renewal in accordance

with 10 CFR 54.4.

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2.2B Unit 3 Plant-Level Scoping Results

2.2B.1 Summary of Technical Information In the Application

In LRA Table 2.2-1 and Table 2.2-3, the applicant provided a list of the plant systems and

structures, respectively, that are within the scope of license renewal. In LRA-Table 2.2-2 and

Table 2.2-4, the applicant provided a list of the plant systems and structures, respectively, that

are not within the scope of license renewal. Based on the design-basis events considered in the

plant's CLB, other CLB information relating to NSR systems and structures, and certain

regulated events, the applicant identified those plant-level systems and structures within the

scope of license renewal, as defined in 10 CFR 54.4.

In response to RAI 2.1-1 (described in Section 2.1 of this SER), the applicant changed the

methodology used for determining the NSR SSCs that are within the scope of license renewal

in accordance with 10 CFR 54.4(a)(2). The applicant's response to RAI 2.1-1 and supplemental

information related to implementation of the revised scoping methodology are documented in

the applicant's response dated November 9, 2004. No new systems were added due to the

NSR piping interaction with the safety-related piping methodology changes.

2.2B.2 Staff Evaluation

In LRA Section 2.1, the applicant described its methodologyfor identifying the structures and

systems that are within the scope of license renewal and subject to an AMR. The staff reviewed

the scoping and screening methodology and provided its evaluation of the methodology in

Section 2.1 of this SER. To verify that the applicant properly implemented its methodology, the

staff focused its review on the implementation results as shown in LRA Sections 2.2-1, 2.2-2,

2.2-3, and 2.2-4, and in the November 9, 2004, response to confirm that there was no omission

of plant-level systemsand structures within the scope of license renewal.

* ~ ~~ ~ ~ - .; .

The staff determined whether the applicant properly identified the structures and systems within

the scope of license renewal in accordance with 10 CFR 54.4. The staff reviewed selected

structures and systems that the applicant did not identify as falling within the scope of license

renewal to verify whether the structures and systems have any intended functions that would

require their inclusion within the scope of license renewal. The staff's review of the applicant's

implementation was conducted in accordance with the guidance described in SRP-LR Section

2.2."

The staff sampled the contents of the FSAR based on the listing of systems and structures in

LRA Tables 2.2-1, 2.2-2, 2.2-3, and 2.2-4 to determine whether there were systems or

structures that may have intended functions as defined by. 10 CFR 54.4, but were not included

within the scope of license renewal. The staff ,review .did not identify any omissions.

t- - i -

2-23-
2.2B.3 Conclusion

The staff reviewed LRA Section 2.2, the applicant's November 9, 2004, RAI response, including

Attachment 1, "Request for Addition Information Responses," and the supporting information in

the FSAR to determine whether any structures or systems within the scope of license renewal

had not been identified by the applicant. The staff's review did not identify any omissions. On

the basis of this review, the staff concludes that the applicant has appropriately identified the

structures and systems that are within the scope of license renewal in accordance with

10 CFR 54.4.

2.3 System Scoping and Screening Results - Mechanical Systems

This section documents the staffs review of the applicant's scoping and screening results for

mechanical systems. Specifically, this section discusses the following mechanical systems:

* reactor coolant system

* engineered safety features systems

* auxiliary systems

* steam and power conversion systems

In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant must identify and list

passive, long-lived mechanical systems and components that are within the scope of license

renewal and subject to an AMR. To verify that the applicant properly implemented its

methodology, the staff focused its review on the implementation results. This approach allowed

the staff to confirm that there were no omissions of mechanical system components that meet

the scoping criteria and are subject to an AMR.

Staff Evaluation Methodology. The staff's evaluation of the information provided in the LRA was

performed in the same manner for all mechanical systems. The objective of the review was to

determine if the components and supporting structures for a specific mechanical system that

appeared to meet the scoping criteria specified in the rule were identified by the applicant as

within the scope of license renewal in accordance with 10 CFR 54.4. Similarly, the staff

evaluated the applicant's screening results to verify that all long-lived, passive components

were subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

Scoping. To perform its evaluation, the staff reviewed the applicable LRA section and

associated component drawings, focusing its review on components that had not been

identified as within the scope of renewal. The staff reviewed relevant licensing basis

documents, including the FSAR, for each mechanical system component to determine if the

applicant had omitted components with intended functions delineated in 10 CFR 54.4(a) from

the scope of license renewal. The staff also reviewed the licensing basis documents to

determine if all intended functions delineated in 10 CFR 54.4(a) were specified in the LRA. If

omissions were identified, the staff requested additional information to resolve the discrepancy.

2-24
Screening. Once the staff completed its review of the scoping results, the staff evaluated the

applicant's screening results. For those structures and components with intended functions, the

staff sought to determine if the functions are performed with moving parts or a change in

configuration or properties, or if they are subject to replacement based on a qualified life or

specified time period, as described in 10 CFR 54.21 (a)(1). For those that did not meet either of

these criteria, the staff sought to confirm that these mechanical system components were

subject to an AMR as required by 10 CFR 54.21 (a)(1). If discrepancies were identified, the staff

requested additional information to resolve them.'

The staff reviewed LRA Section 2.3 using the evaluation methodology described above in this

section of the SER. The staff conducted its review in accordance with the guidance described in

SRP-LR Section 2.3, "Scoping and Screening Results ' Mechanical Systems."

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 1 0 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal -any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed those components that the

applicant identified as being within the scope of license renewal to verify that the applicant did

not omit any passive and long-lived components that should be subject to an AMR in

accordance with the requirements of 10 CFR 54.21(a)(1).

In reviewing LRA Section 2.3, the staff identified areas in which additional information was

necessary to complete the evaluation of the applicant's scoping and screening results.

Therefore, by letter to the applicant dated June 9, 2004,' the staff issued RAls concerning the

specific issues to determine whether the applicant properly applied the scoping criteria of ^

10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21 (a)(1). The following discussion

describes the staffs RAls and the applicant's related responses.

On March 3,-2004, the staff held a teleconference with the applicant to discuss RAI 2.3-1 and to

clarify whether the LRA boundary drawings highlight only those components that are subject to

an AMR, or all systems that are within the scope of license renewal because they meet one or

more of the 10 CFR 54.4(a) criteria. The applicant stated:

The LRA drawings are boundary drawings-and show the portions of the system

that perform 10 CFR 54.4 intended functions! Components that are not subject

to AMR because they are short-lived or active have been screened out and are

not highlighted on the license renewal draWings. However, the system

boundaries were not changed in this process. Therefore, the license renewal

drawings can be used for purposes of the scoping review (i.e.,' determining

whether those portions of a system that perform intended functions according to

10 CFR 54.4 were included within the scope of license renewal). In other words,

they are AMR drawings, but they show the boundaries of the systems that

include the components necessary to perform the intended functions: Dominion

will submit under oath, a statement to confirm that the AMR drawings are also

license renewal boundary drawings because the boundaries were not changed

when the original license renewal drawings were converted to AMR drawings.

The staff requested the applicant to confirm that the AMR drawings -are also license renewal

boundary drawings because the boundaries were not changed when the original license

renewal drawings were converted to AMR drawings.

2-25-
l

In its response to RAI 2.3-1, dated July 26, 2004, the applicant stated that the quotation of its

statements made during the referenced teleconference is generally accurate with the following

clarifications:

The license renewal drawings were produced during the scoping and screening

process and only passive, in-scope components were highlighted. The

highlighted components are those that are subject to AMR, except for the

components later determined to be short-lived in the AMR process, which were

screened out, as stated in LRA Section 2.1.3.1.

Since active components were never highlighted on the license renewal

drawings, these drawings were not converted from one form to another (i.e.,

from original license renewal drawings to AMR drawings), as is implied in RAI

2.3-1.

The license renewal drawings were produced in order to identify components that require

evaluation during the AMR process. However, since the AMR evaluation boundary shown on

the drawings corresponds to the scoping boundary for the system, these drawings may also

serve to indicate the in-scope portion of the system. The applicant further stated that in

accordance with LRA Section 2.1.3.6, NSR piping out to the first equivalent seismic anchor

point beyond the safety-related interface was not uniquely highlighted on the license renewal

drawings.

Based on its review, the staff finds the applicant's response to RAI 2.3-1 acceptable, because,

with the exception of short-lived components, the scoping boundaries depicted on the license

renewal drawings represent the in-scope portion of the system. Therefore, the staffs concern

described in RAI 2.3-1 is resolved.

On March 3, 2004, the staff held a teleconference with the applicant to discuss RAI 2.3-2 and to

clarify that the license renewal drawings indicate by highlighting, those NSR components that

are within the scope of license renewal solely because they have the potential for interactions

with safety-related components due to their spatial orientation (i.e., 10 CFR 54.4(a)(2)). Further

clarification was also requested as to whether these components were indicated differently on

the license renewal drawings from those meeting the criteria of 10 CFR 54.4(a)(1). In response,

the applicant stated: Portions of systems with 10 CFR 54.4(a)(2) intended functions are

highlighted on the license renewal drawing. These segments are always included in the aging

management program (AMP) along with the adjoining safety-related piping.

The applicant further stated that there is no distinction made on the license renewal drawings

indicating those components meeting criteria 10 CFR 54.4(a)(1) and those within scope solely

because they meet the criteria of 10 CFR 54.4(a)(2). They are both indicated by highlighting.

The staff requested that the applicant confirm this verbal response and clarify that all

components of NSR systems capable of spatial interactions with safety-related systems (i.e.,

located within the same room or space) were included within the scope of license renewal and

highlighted in the licensing renewal boundary drawings.

In its response to RAI 2.3-2, dated July 26, 2004, the applicant stated that its statements made

during the referenced teleconference were generally accurate with the following clarifications:

2-26
Components that have been determined to be within the scope of license renewal solely

because they are NSR components that are spatially oriented near safety-related structures,

systems and components (SSCs) are highlighted on the license renewal drawings. These

components, along with passive components meeting any of the other criteria of

10 CFR 54.4(a), are highlighted on the license renewal drawings in the'same manner. There is

no highlighting distinction made among the scooing criteria. The NSR components that are

spatially oriented near safety-related SSCs have been determined to be within the scope of

license renewal in accordance with the methodology described in LRA Section 2.1.

Based on its review, the staff finds the applicant's response to RAI 2.3-2 acceptable, because

adequate explanation is given that NSR components that are spatially oriented near safetyrelated SSCs have been determined to be within the scope of license renewal in accordance

with 10 CFR 54.4(a)(2) and shown on license renewal drawings by highlighting. Therefore, the

staff's concern described in RAI 2.3-2 is resolved.

The applicant responded to RAI 2.1-1 in its respon'se dated November 9,2004, Attachment 1,

'Request for Additional Information Responses.; In response to this RAI, the applicant revised

the scoping methodology for 1) the NSR piping that is attached to safety-related piping, and 2)

the NSR fluid-containing components that spatially oriented such that its failure could prevent

the satisfactory accomplishment of a safety-related function 'of an SSC.

As a result of the implementation of the revised spatial methodology, the applicant added 'the

following NSR systems, that were previously excluded from scope, to the Unit 2 scope of

license renewal: aerated liquid radwaste; solid waste processing; water box priming; turbine

building closed cooling water to the auxiliary systems, and auxiliary steam reboiler and

deaerating feedwater; exciter air cooler; stator air cooler; and turbine lube oil to the steam and

power conversion systems. In the November 9, 2004, response, the applicant stated that no

new Millstone Unit 2 system was added due to the NSR piping attached to safety-related piping

methodology changes. No new Millstone Unit'3 systems were added due to the NSR piping

interaction to safety-related piping methodology changes.

By response dated December 3, 2004, the applicant provided a list of component types, with

their associated intended functions, that were added 'to the scope of license renewal'for the

in-scope systems as a result of the response to RAI 2.1-1. Resulting from the methodology

changes discussed above, the applicant expa'nded the license renewal boundaries of the

following Unit 2 systems that were previously determined to be within the scope of license

renewal:

Engineered Safety Features Systems:

* refueling water storage'tank and containment sump (LRA Table 2.3.2-3).

* spent fuel pool cooling (LRA Table 2.3.2-5)

Auxiliary Systems:

* access control area air conditionriig (LRA Table 2.3.3-13)

* chilled water (LRA Table 2.3.3-6) ''

* clean liquid waste processing (LRA Table 2.3.3-38)

* domestic water (LRA Table 2.3.3.33) ' - '

* instrument air (LRA Table 2.3.3-7)

2-27'
___ U '

* main condensers evacuation (LRA Table 2.3.3-14)

* nitrogen (LRA Table 2.3.3-8)

* primary makeup water (LRA Table 2.3.3-12)

* sampling (LRA Table 2.3.3-11)

* station air (LRA Table 2.3.3-9)

* station sumps and drains (LRA Table 2.3.3-41)

Steam and Power Conversion Systems:

* electro hydraulic control (This system is included in Unit 2 LRA Table 2.2-1 as an

in-scope system, but previously had no passive mechanical components subject to

aging management review. Therefore, there is no existing LRA screening results table.)

* main steam (LRA Table 2.3.4-1)

Resulting from the methodology changes discussed above, the applicant expanded the license

renewal boundaries of the following Unit 3 systems that were previously determined to be within

the scope of license renewal:

Engineered Safety Features Systems:

* fuel pool cooling and purification (LRA Table 2.3.2-5)

* quench spray (LRA Table 2.3.2-2)

* safety injection (LRA Table 2.3.2-3)

Auxiliary Systems:

* boron recovery (LRA Table 2.3.3-43)

* chemical and volume control (LRA Table 2.3.3-15)

* containment vacuum (LRA Table 2.3.3-23)

* radioactive gaseous waste (LRA Table 2.3.3-45)

* radioactive liquid waste processing (LRA Table 2.3.3-44)

* reactor plant aerated drains (LRA Table 2.3.3-48)

* reactor plant component cooling (LRA Table 2.3.3-4)

* reactor plant gaseous drains (LRA Table 2.3.3-49)

* reactor plant sampling (LRA Table 2.3.3-16)

* service air (LRA Table 2.3.3-14)

Steam and Power Conversion Systems:

* auxiliary boiler condensate and feedwater (LRA Table 2.3.4-7)

* auxiliary feedwater (LRA Table 2.3.4-5)

* steam generator blowdown (LRA Table 2.3.4-4)

In response to RAI 2.1-1 dated December 3, 2004, the applicant stated that the intended

function limited structural integrity (LSI) applies to components within the scope of license

renewal for 10 CFR 54.4(a)(2) due to either spatial orientation or non-safety attached to

safety-related piping intended functions. The LSI function is combined with the pressure

boundary (PB) function for components within the scope of license renewal for spatial

orientation. In the November 9, 2004, response to RAI 2.1-1, Attachment 1, Table 5, 'Steam

2-28
and Power Conversion System - Auxiliary. Steam Reboiler and Deaerating Feedwater," the

applicant identified component types with the intended function of LSI only. These are within the

scope of license renewal as non-safety attached to safety-related piping components. Table 5

also contains a component which is within the scope of license renewal due to implementation

of the enhanced spatial orientation methodology and has the intended function of LSI and PB.

Therefore, the eight new Unit 2 systems identified in the original RAI 2.1-1 response were

added to the scope of license renewal based on the enhanced spatial orientation methodology.

Although the steam and power conversion system - auxiliary steam reboiler and deaerating

feedwater contains components with the intended function of non-safety attached to

safety-related piping, no new system was added to the scope of license renewal solely for the

non-safety attached to safety-related piping intended function.

None of the filtration systems nor heating ventilation and air conditioning (HVAC) systems in the

Millstone 3 LRA included duct sealants or wall sealants in the applicable tables, nor were

sealants indicated on LRA drawings. The staff requested in RAI SPSB-3 that the applicant

clarify whether sealants were within the scope of license renewal in accordance with

10 CFR 54.4(a), and subject to aging management review in accordance with

10 CFR 54.21 (a)(1). If sealants were within the scope of license renewal, the applicant was

requested to update the LRA by providing the applicable information in the appropriate LRA

tables. If sealants are excluded from the scope of license renewal and not subject to an AMR,

the applicant was requested to provide justification for the exclusion.

In its response dated November 9, 2004, the applicant stated that duct sealants should have

been included within the scope of license renewal for the Unit 3 auxiliary building ventilation

system, control building ventilation system, and supplementary leak collection-and-release

system and shown in LRA Table 2.3.3-18, 2.3.3-24, and 2.3.3-33, respectively. Wall sealants

were evaluated as part of buildings and structures in LRA Section 2.4.2 as metal sidingcaulking and were included in LRA Table 2.4.2-1. The applicant stated that sealants were not

specifically identified on plant drawings.

The applicant also stated that the aforementioned ductwork joint seals perform a pressure

boundary function and are subject to aging management review (AMR). The sealant is an

elastomeric material and is subject to cracking and change of material properties in an air

environment. The aging effects will be managed with the general condition monitoring aging

management program. The staff finds this acceptable.

In the LRA for both Units 2 and 3, none of the air intake or exhaust structures included screens

within the scope of license renewal. The staff requested in RAI SPSB-4 that the applicant clarify

whether screens for air intake and exhaust structures were within the scope of license renewal

in accordance with 10 CFR 54.4(a), and subject to aging management review in accordance

with 10 CFR 54.21 (a)(1). If it determined that screens for intake and exhaust structures were

within the scope of license renewal, the applicant was requested to update the LRA by

providing the applicable information in the appropriate tables. If it determined that screens for

intake and exhaust structures were excluded from the scope of license renewal and not subject

to an AMR, the applicant was requested to provide justification for the exclusion.

In its response dated November 9, 2004, the applicant stated that screens are installed over

wall openings in plant structures that serve as ventilation intake or exhaust points. These

screens are installed for maintenance purposes to aid in maintaining the associated ductwork

free from nesting materials and debris from birds and other wildlife. Although the build-up of

2-29
-

debris in the ventilation intakes and exhausts is not expected to affect the function of the plant

ventilation systems regardless of the condition of the screens, the applicant stated that screens

are not conservatively included within the scope of license renewal. The applicant further stated

that screens will be included with the structural member "Miscellaneous Steel" in the LRA

screening results tables for the Unit 2 auxiliary building and turbine building and the Unit 3

auxiliary building, control building, hydrogen recombiner building, engineered safety features

building, main steam valve building, emergency generator enclosure and fuel oil tank vault, and

circulating and service water pumphouse. The carbon steel screens are exposed to an

atmosphere/weather environment. The aging effect of loss of material will be managed by the

structures monitoring program. The staff found this acceptable.

2.3A Unit 2 System Scoping and Screening Results

2.3A.1 Reactor Coolant System

In LRA Section 2.3.1, the applicant identified the structures and components of the reactor

coolant system (RCS) and major RCS components that are subject to an AMR for license

renewal.

The applicant described the supporting structures and components of the reactor coolant

system and RCS in the following sections of the LRA:

* 2.3.1.1 reactor vessel

* 2.3.1.2 reactor vessel internals

* 2.3.1.3 reactor coolant system

* 2.3.1.4 steam generator

The corresponding subsections of this SER (2.3A.1.1 - 2.3A.1.4, respectively) present the

staffs related review findings.

2.3A.1.1 Reactor Vessel

2.3A.1.1.1 Summary of Technical Information in the Application

In LRA Section 2.3.1.1, the applicant described the reactor vessel. The reactor vessel is a

Combustion Engineering-designed, two-loop pressure vessel consisting of a cylindrical shell

with a welded, hemispherical bottom head and a flanged hemispherical closure head. The

reactor vessel provides a container for the reactor core and the primary coolant in which the

core is submerged.

The reactor vessel directly maintains the RCS pressure boundary and supports and contains

the reactor core and core support structures. Additionally, the applicant stated that the reactor

vessel provides a function that supports pressurized thermal shock.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides structural and/or functional support related to mechanical components

* provides for flow distribution

2-30
In LRA Table 2.3.1-1, the applicant identified the following reactor vessel component types that

are within the scope of license renewal and subject to an AMR: bottom head; control element

drive mechanism (CEDM), head penetration nozzle; CEDM head penetration nozzle flange;

CEDM pressure housings; closure head dome; closure head flange; closure head lifting lugs;

closure head stud assembly; core stabilizing lugs and core stop lugs; flow skirt, flow baffle;'-

head vent pipe; instrument tube flange and studs/nuts/washers; instrument tubes; intermediate

and lower shell; primary nozzle and safe end;surveillance capsule holders; upper shell; and

vessel flange and core support ledge. -

2.3A.1.1.2 Staff Evaluation

The staff reviewed LRA Section 2.3.1.1, Millstone FSAR Sections 3.3.3.2 and 4.3.1, and FSAR

Tables 4.3-1, 4.5-2 and 4.6-1 through 4.6-13.-The staffs review, using the evaluation

methodology described in Section 2.3 of this SER, was conducted in accordance with the

guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.1.1 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs request for additional information (RAI) as discussed below.

In RAI 2.3.1.1-1 (a), the staff requested the applicant to verify whether vessel support pads,

which are located below the primary nozzles'and provide support for the reactor vessel, were

included within the scope of license renewal and are subject to an AMR, or to provide an -

explanation for the exclusion. In response, the applicant stated the vessel support pads are

welded to three of the six primary nozzles and are within the scope of license renewal. The :

vessel support pads were included in the 'Primary Nozzle and Safe End" subcomponent in LRA

Table 2.3.1-1. Based on the inclusion of the above component, the staff finds the applicant's'

response acceptable. - - : - - . - '

2.3A.1.1.3 Conclusion -.-

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the reactor vessel

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the reactor.vessel components that are subject to,

an AMR, as required by 10 CFR,54.21(a)(1): -* 

._: -- , , , ,

,, , ,.,;',i'

2-31'
2.3A.1.2 Reactor Vessel Internals

2.3A.1.2.1 Summary of Technical Information in the Application

In LRA Section 2.3.1.2, the applicant described the reactor vessel internals (RVls). The RVIs

are designed to support and orient the reactor core fuel assemblies and control element

assemblies, absorb the control element assembly (CEA) dynamic loads and transmit these

loads to the reactor vessel flange, guide the in-core instrumentation assemblies, and provide

flow paths for the reactor coolant through the reactor vessel.

The RVIs support the reactor core in a coolable geometry and provide a CEA insertion path.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support related to mechanical components

* provides for flow distribution

In LRA Table 2.3.1-2, the applicant identified the following RVIs component types that are

within the scope of license renewal and subject to an AMR: CEA shroud bolts; 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.

2.3A.1.2.2 Staff Evaluation

The staff reviewed LRA Section 2.3.1.2, Millstone FSAR Sections 3.3.2 and 7.5.4, and FSAR

Figures 3.3-9 through 3.3-14. The staffs review, using the evaluation methodology described in

Section 2.3 of this SER, was conducted in accordance with the guidance described in Section

2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.1.2 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

The Millstone FSAR states that ICI assemblies are inserted into the core through

instrumentation nozzles in the top closure head of the reactor vessel. Each assembly is guided

into position in the center of the fuel assembly via a fixed guide tube and instrument thimble

assembly and a flange-type seal forms a pressure boundary for each assembly at the

instrument nozzle. In RAI 2.3.1.2-1, the staff requested the applicant to verify whether

instrument nozzles and instrument thimble assemblies, which provide a pressure boundary and

2-32
structural support for in-scope equipment, were included within the scope of license renewal

and subject to an AMR, or to provide an explanation for the exclusion. In a response dated

November 9, 2004, the applicant confirmed that instrument nozzles are within the scope of

license renewal and are included in the subcomponent instrument Tubes" and "Instrument

Tube Flange and Studs/Nuts/Washers" in LRA Table 2.3.1-1. The applicant also stated that

instrument thimble assemblies are within scope of license renewal and are included in the

subcomponent 'ICI Support Plate and Guide Tubes" in LRA Table 2.3.1-2. Based on the

inclusion of the above components, the staff finds the applicant's response acceptable.

2.3A.1.2.3 Conclusion_ -- I, ~ ~~~ -, . '- a-(- :,, -

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant.'No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the reactor vessel internals

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the reactor vessel internals components that are

subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.1.3 Reactor Coolant System

2.3A.1.3.1 Summary of Technical Information in the Application

In LRA Section 2.3.1.3, the applicant described the reactor coolant system (RCS). The RCS is

designed to contain pressurized treated waterand transfer heat produced in the reactor core to

the steam generators. Borated treated water is circulated through the core at a' flow rate and'

temperature consistent with achieving the desired reactor core thermal-hydraulic performance.

The RCS provides a pressure boundary for containing the primary coolant, serves to confine

radioactive material, and limits the uncontrolled release of radioactive material.

The safety-related intended functions of the RCS are to provide a closed pressure b6undary for

containing the primary coolant, transfer heat from the reactor core to the steam generator,

provide system over-pressure protection, provide Regulatory Guide (RG) 1.97 safety-related

indications, ensure containment pressure boundary integrity, provide'a reactor building closed,.

cooling water system pressure boundary, and provide a means of venting non-condensable

gases from system high points after an accident. The RCS contains NSR components credited

for mitigating a high-energy line break and NSR components spatially oriented such that a

failure could prevent the satisfactory accomplishment of a safety-related (SR) function of an SR

system, structure or component. The RCS also contains environmental qualification

components and supports fire protection, station blackout, and pressurized thermal shock.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity ;

* provides a pressure boundary.: .- '::

* restricts flow ,

* - provides a spray pattern -

* provides structural and/or functional support related to mechanical components

2-33
W ,

limits thermal cycling

In LRA Table 2.3.1-3, the applicant identified the following RCS component types that are within

the scope of license renewal and subject to an AMR: bolting; flow orifices; pipe; pressurizer;

pressurizer heaters; quench tank; reactor coolant pump (RCP) motor lower lube oil coolers;

RCP seal coolers; RCP thermal barriers; RCP motor upper lube oil coolers; RCPs; rupture

disks; thermal sleeves; tubing; and valves.

2.3A.1.3.2 Staff Evaluation

The staff reviewed LRA Section 2.3.1.3, Millstone FSAR Chapter 4, and FSAR Figures 4.1-1

through 4.1-3 and 4.3-7. The staff's review, using the evaluation methodology described in

Section 2.3 of this SER, was conducted in accordance with the guidance described in Section

2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.1.3 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAls as discussed below.

In RAI 2.3.1.3-1, the staff requested the applicant to verify whether the pressurizer components

set forth in Table 2.3A-1 were included within the scope of license renewal and require an AMR

or, alternatively, to provide an explanation for their exclusion.

Table 2.3A-1 Pressurizer Components that Require Additional Scoping Status

Information

Subcomponent Intended Function

Pressurizer - Nozzles (Surge, Spray, Safety, Pressure Boundary

Relief, Instrument)

Pressurizer - Nozzle Safe Ends Pressure Boundary

Pressurizer - Heater Sheath Pressure Boundary

Pressurizer - Manway and Cover Pressure Boundary

Pressurizer - Surge Line Pressure Boundary

Pressurizer - Spray Head Assembly Spray Pattern

Pressurizer - Support Lugs Structural Support

Pressurizer - Support Skirt and Flange Structural Support

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In a response dated November 9, 2004, the applicant confirmed that the pressurizer, including

all subcomponents that perform intended functions, is included within the scope of license

renewal and is subject to an AMR. The applicant further stated that the pressurizer was

-evaluated as part of the RCS and is not considered a major component. Therefore, pressurizer

subcomponents are not listed separately in LRA Table 2.3.1-3. The applicant stated that the

subcomponents listed in the table above are 'included in the component types 'Pressurizer" and

"Pressurizer Heaters" in LRA Table .2.3.1-3.-Subcomponents of the pressurizer are set forth in

LRA Table 3.1.2-3. Based on the inclusion of the above components, the staff finds the:

applicant's response acceptable.

In RAI 2.3.1.3-2(a), the staff requested the applicant to verify whether the RCP. casing and

driver mount, which provide a reactor building closed-cooling-water-system pressure boundary,

are within the scope of license renewal and subject to an AMR. The RCP casing, cover

(including the thermal barrier), inner tubes of the seal cooler, closure bolting, and driver mount

are considered part of the RCS pressure boundary. The upper and lower reactor coolant pump

motor lube oil coolers and the outer tubes of the seal cooler provide a reactor building closedcooling-water-system pressure boundary. In a response dated November 9, 2004, the applicant

confirmed the RCP casing and driver mount are within the scope of license renewal and subject

to an AMR. The applicant stated that these items are considered subcomponents of the RCP

and are included in the component type "Reactor Coolant Pump" in LRA Table 2.3.1-3. These

components are identified uniquely in LRA Table 3.1.2-3 as "Reactor Coolant Pumps (Casing)"

and "Reactor Coolant Pumps (Driver Mount Assembly)," respectively. Based on the inclusion of

the above components, the staff finds the applicant's response acceptable.,

In RAI 2.3.1.3-3, the staff requested the applicant to verify whether the RCS welds, which are

included in the evaluation boundary for the RCS, are within the scope of license renewal and,

subject to an AMR. In a response dated November 9, 2004, the applicant confirmed that the

RCS welds are within the scope of license renewal and require an AMR. Welds are considered

a part of the host component (e.g., pipe, nozzle) and are not uniquely identified in LRA Table

2.3.1-3. Based on the inclusion of the above component, the staff finds the applicant's response

acceptable.

2.3A.1.3.3 Conclusion

The staff reviewed the LRA and RAI responses described above to determine whether any

SSCs that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the reactor coolant system

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the reactor coolant system components that are

subject to an AMR, as required by 10 CFR 54.21 (a)(1). -

2.3A.1.4 Steam Generator

2.3A.1.4.1 Summary of Technical Information in the Application

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I

In LRA Section 2.3.1.4, the applicant described the steam generator. The nuclear steam supply

system (NSSS) utilizes two steam generators to transfer the heat generated in the RCS to the

secondary system and produce steam at the warranted steam pressure and quality.

The steam generator directly maintains the RCS pressure boundary, supports the capability to

shut down the reactor and maintain it in a safe shutdown condition, and supports the capability

to prevent or mitigate the discharge of radioactive coolant into the secondary cycle. Additionally,

the steam generator provides for core heat removal in support of station blackout and fire

protection.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support related to mechanical components

* provides for flow distribution

* provides a pressure boundary

* limits thermal cycling

* restricts flow

In LRA Table 2.3.1-4, the applicant identified the following steam generator component types

that are within the scope of license renewal and subject to an AMR: base support and flange;

support brackets and lugs; divider plate; feedwater inlet ring and support; feedwater nozzle and

safe end; feedwater nozzle thermal sleeve; lower head; nozzle dams and holddown rings;

primary instrument nozzles; primary manway bolting; primary manway cover and diaphragm;

primary nozzle and safe end; secondary manway and handhole bolting; secondary manway and

handhole covers; secondary side nozzles (except steam and feedwater); shroud; steam nozzle

and safe end; steam nozzle flow restrictor; top head; transition cone; tube plugs; tube support

lattice bars; tube support lattice support rings; tubes; tubesheet; and upper and lower shell.

2.3A.1.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.1.4, Millstone FSAR Section 4.3.2, and FSAR Figure 4.3-2.

The staff's review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staff's review of LRA Section 2.3.1.4 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAI as discussed below.

In RAI 2.3.1.4-1, the staff requested the applicant to verify whether the bearing plates, which

provide structural support for the steam generator and allow lateral motion due to thermal

expansion of the reactor coolant piping, are within the scope of license renewal and subject to

an AMR. In a response dated November 9, 2004, the applicant stated that structural supports

for major RCS components are evaluated separately from the component and its integral parts

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as NSSS equipment supports, as described in LRA Section 2.1.5.3, Structural Screening. The

applicant stated that the steam generator support structure, including the bearing plates, is

included within the scope of license renewal and is described in LRA'Section 2.4.3, NSSS

Equipment Supports. Based on the inclusion of the above component, the staff finds the

applicant's response acceptable.

2.3A.1.4.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the steam generator

components that are within the scope of license renewal, as required by.10 CFR 54.4(a), and

that the applicant has adequately identified the steam generator components that are subject to

an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.2 Engineered Safety Features Systems.,

In LRA Section 2.3.2, the applicant identified the structures and components of the engineered

safety features (ESF) systems that are subject to an AMR for license renewal.

The applicant described the supporting structures and components of the ESF systems in the

following sections of the LRA:

* 2.3.2.1 containment spray system

* 2.3.2.2 safety injection system.

* 2.3.2.3 refueling water storage'tank and containment sump system

* 2.3.2.4 shutdown cooling system

* 2.3.2.5 spent fuel pool cooling system

The corresponding subsections of this SER (2.3A.2.1 - 2.3A.2.5, respectively) present the

staff's related review findings.

2.3A.2.1 Containment Spray System

2.3A.2.1.1 Summary of Technical Information in the Application

In LRA Section 2.3.2.1, the applicant described the containment spray system.The

containment spray system, in conjunction with the containment air recirculation and cooling

system,' removes heat from the containment atmosphere following a major primary or -

secondary pipe rupture inside containment. Heat is transferred to the reactor building closed

cooling water system via the shutdown cooling heat exchangers. ;

The containment spray system provides heat removal from containment, RG 1.97 safety-related

indications, and containment pressure boundary integrity. The containment spray system also

contains environmental qualification components and supports fire protection.

2-37 .
Al I

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* restricts flow

* provides a spray pattern

In LRA Table 2.3.2-1, the applicant identified the following containment spray system

component types that are within the scope of license renewal and subject to an AMR: bolting;

CS pump seal coolers; flow orifices; pipe; pumps; spray nozzles; tubing; and valves.

2.3A.2.1.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.1 and Millstone FSAR Section 6.4. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.2. 1.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the containment spray system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

containment spray system components that are subject to an AMR, as required by

10 CFR 54.21 (a)(1).

2.3A.2.2 Safety Injection System

2.3A.2.2.1 Summary of Technical Information in the Application

In LRA Section 2.3.2.2, the applicant described the safety injection system. The purpose of the

safety injection system is to provide a source of borated water to the RCS to ensure that the

reactor is shutdown and to cool the core in the event of a design-basis accident. The safety

injection system consists of the high-pressure safety injection subsystem, the low-pressure

safety injection subsystem, and the safety injection tanks.

The safety injection system provides injection of borated water into the RCS following an

accident, for control of reactor core boron precipitation during long-term loss-of-coolant accident

(LOCA) recovery, reactor decay heat removal during shutdown conditions, refueling water

storage tank (RWST) isolation, RCS pressure-boundary integrity, containment pressure

boundary integrity, and an RG 1.97 safety-related indications. The safety injection system

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contains NSR components credited for mitigating the effects of a high-energy line break. The

safety injection system contains environmental qualification components and supports fire'.

protection and station blackout:

Intended functions within the scope of license renewal include the following:

* -provides a pressure boundary

* restricts flow

In LRA Table 2.3.2-2, the applicant identified the following safety injection system component

types that are within the scope of license renewal and subject to an AMR: bolting; flow

elements; flow orifices; high pressure safety injection (HPSI) pump seal coolers; low-pressure

safety injection (LPSI) pump seal coolers; pipe; pumps; safety injection tanks; tubing; and

valves.

2.3A.2.2.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.2 and Millstone'FSAR Section 6.3. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components' with intended,

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then , reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.2.2.3 Conclusion

The staff reviewed the LRA-to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the safety injection system components that are within the'scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicarit has adequately identified the safety

injection system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.2.3 Refueling Water Storage Tank and Containment Sump Systemi

2.3A.2.3.1 Summary of Technical Information in the Application -

In LRA-Section 2.3.2.3, the applicant described the refueling water storage tafnk-and

containment sump system. The refueling water storage tank (RWST) provides the initial source

of borated water for the safety injection and containment spray pumps.-'The containment sump

collects water following a LOCA for recirculation after the RWST has emptied. Vortex breakers

are installed in the safety injection and containment spray pumps suction from the RWST and

from the containment sump to prevent pump suction air entrainment. The RWST and

containment sump system also includes an encapsulation feature provided for the sump

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recirculation lines and isolation valves outside of the containment. The encapsulation feature

limits the potential fluid releases from the recirculation piping and valves at the containment wall

penetration. Containment sump water pH level is controlled by baskets of dissolvable trisodium

phosphate dodecahydrate (TSP).

The RWST and containment sump system provides a source of water to the safety injection

and containment spray pumps, sump water pH control, RG 1.97 safety-related indications, and

containment pressure boundary integrity. The system also supports RCS inventory and

reactivity control, decay heat removal make-up, and spent fuel pool inventory control during

shutdown conditions. The RWST and containment sump system contains NSR components

credited for mitigating the effects of a high-energy line break. The RWST and containment

sump system also contains environmental qualification components and supports fire protection

and station blackout.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides structural and/or functional support related to mechanical components

* provides for vortex suppression

In LRA Table 2.3.2-3, the applicant identified the following RWST and containment sump

system component types that are within the scope of license renewal and subject to an AMR:

bolting; circulating pump; encapsulation piping; encapsulation valves; expansion joints; heat

exchanger; pipe; refueling water storage tank; rupture disks; TSP baskets; tubing; valves; and

vortex breakers.

2.3A.2.3.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.3 and Millstone FSAR Section 6.2. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.2.3 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAI as discussed below.

The Millstone FSAR states the containment sump is protected from clogging by the sump

screens. Sump screens are normally used in the containment sump which provides water for

the RWST recirculation phase and one of the intended functions is to protect the pumps from

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debris and cavitation due to harmful vortex following a LOCA. In RAI 2.3.2.3-1, the staff

requested the applicant to verify whether sump screens are within the scope of license' renewal

and subject to an AMR. In a response dated November 9, 2004, the applicant confirmed that

* the containment sump screens are within the scope of license renewal and subject to an AMR.

The applicant further stated that the sump screens are identified LRA Table 2.4.1-1. Based on

the inclusion of the above component, the staff finds the applicant's response acceptable.

2.3A.2.3.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the'applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the refueling water storage

tank and containment sump system components that are within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the refueling

water storage tank and containment sump system components that are subject to an AMR, as

required by 10 CFR 54.21(a)(1). -

2.3A.2.4 Shutdown Cooling System

2.3A.2.4.1 Summary of Technical Information in the Application

In LRA Section 2.3.2.4, the applicant described the shutdown cooling system. The shutdown

cooling system transfers heat from the RCS to the reactor building closed cooling water system,

via the shutdown cooling system heat exchangers, during plant cooldown operations. The

shutdown cooling system also provides heat removal from recirculated containment sump water

during the recirculation phase of accident recovery.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides filtration - -

* restricts flow -: ,

In LRA Table 2.3.2-4, the applicant identified the following shutdown cooling system component

types that are within the scope of license renewal and subject to an AMR: bolting; carry-over

tank; filter/strainers; flexible hoses; flow elements, pipe; restricting orifices; shutdown cooling

heat exchangers; tubing; vacuum flask; vacuum pump; and valves.

2.3A.2.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.4 and Millstone FSAR Section 9.3. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.:-

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

2-41
- - .1 a'

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3A.2.4.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the shutdown cooling system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

shutdown cooling system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3A.2.5 Spent Fuel Pool Cooling System

2.3A.2.5.1 Summary of Technical Information in the Application

In LRA Section 2.3.2.5, the applicant described the spent fuel pool cooling system. The spent

fuel pool cooling system removes decay heat generated by spent fuel assemblies stored in the

spent fuel pool. Heat is transferred from the pool water to the reactor building closed cooling

water system.

The spent fuel pool cooling system provides heat removal from the spent fuel pool and

containment pressure boundary integrity. The evaluation boundary includes the spent fuel pool

cooling system components that provide cooling for the spent fuel pool.

The system's intended function, within the scope of license renewal, is to provide a pressure

boundary.

In LRA Table 2.3.2-5, the applicant identified the following spent fuel pool cooling system

component types that are within the scope of license renewal and subject to an AMR: bolting;

expansion joints; flow elements; pipe; pumps; spent fuel pool heat exchangers; tubing; and

valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the spent fuel pool cooling system. In its December 23,

2004, RAI response, the applicant identified the following component types that were added to

the scope of the spent fuel pool cooling system:

* filters

* mixing tank

2.3A.2.5.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.5 and Millstone FSAR Section 9.5. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

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In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that theapplicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passiveor long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staff's review of LRA Section 2.3.2.5 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAI as discussed below. -

The Millstone FSAR states that in the event that a serious leak develops in the spent fuel pool

liner, makeup water is supplied to the pool from the primary makeup water system by manual

initiation from the 14-foot 6-inch level of the auxiliary building, and that should the leakage

exceed the 50-GPM normal makeup capability, additional makeup is available from the RWST

via the refueling water purification system and the fire protection system by temporary hose

connections. The license renewal drawing for the spent fuel pool cooling system shows only the

portions of the primary makeup water system and RWST that have a certain specification as

subject to an AMR. It appeared to the staff that these makeup paths are required or relied upon

to provide makeup capability to the spent fuel pool. In RAI 2.3.2.5-1A, dated June 9, 2004, the

staff requested the applicant to explain the apparent exclusion of the additional sources of fuel

pool makeup from the primary makeup water system and from the RWST from the scope of

license renewal.

In its response, dated July 26,-2004, the applicant stated that the spent fuel pool is a missileprotected, seismically-designed reinforced concrete structure with a stainless steel liner. As

stated in Millstone FSAR Section 9.5.3.3, failure of the structure is not considered credible. All

connections to the spent fuel pool penetrate the pool walls near the normal operating level, or

are provided with anti-siphon devices, to prevent gravity draining of the pool due to system

leaks. The applicant stated that the spent fuel pool liner is within the scope of license renewal

and is managed for the effects of aging, as described in LRA Section 2.4.2.2, such that

significant leakage is not expected. The loss of inventory from the spent fuel pool is not

analyzed as an accident for the plant. The FSAR discusses the possibility of spent fuel pool

inventory loss and lists several sources of make-up water for completeness. The RWST has

been identified with the intended function to provide spent fuel inventory control in LRA Section

2.3.2.3. Additionally, the components that comprise the make-up flow path from the refueling

water storage tank via the safety injection pumps and the shutdown cooling system, as

discussed in Millstone FSAR Section 9.5.3.3, are included within the scope of license renewal.

Other sources of make-up water are available but are not assigned spent fuel pool make-up as

an intended function. Consequently, the spent fuel pool make-up flow paths from the primary

makeup water system and from the RWST via the refueling water purification system are not

within the scope for their spent fuel pool make-up capability..- !

The staff finds the applicant's response to RAI 2.3.2.5-IA acceptable, because the applicant

explained that a source of make-up to the fuel pool from the refueling water storage tank is

credited for this purpose in the FSAR and is within the scope of license renewal. Therefore, the

staff's concern described in RAI 2.3.2.5-.1A is resolved.

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

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- l

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

spent fuel pool cooling system is acceptable.

2.3A.2.5.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the spent fuel pool cooling system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the spent fuel pool

cooling system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.3 Auxiliary Systems

In LRA Section 2.3.3, the applicant identified the structures and components (SCs) of the

auxiliary systems that are subject to an AMR for license renewal.

The applicant described the supporting SCs of the auxiliary systems in the following sections of

the LRA:

* 2.3.3.1

* 2.3.3.2

* 2.3.3.3

* 2.3.3.4

* 2.3.3.5

* 2.3.3.6

* 2.3.3.7

* 2.3.3.8

* 2.3.3.9

* 2.3.3.10

* 2.3.3.11

* 2.3.3.12

* 2.3.3.13

* 2.3.3.14

* 2.3.3.15

* 2.3.3.16

* 2.3.3.17

* 2.3.3.18

* 2.3.3.19

* 2.3.3.20

* 2.3.3.21

* 2.3.3.22

* 2.3.3.23

circulating water system

screen wash system

service water system

sodium hypochlorite system

reactor building closed cooling water system

chilled water system

instrument air system

nitrogen system

station air system

hydrogen 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

containment post-accident hydrogen control

control room air conditioning system

control element drive mechanism cooling system

diesel generator ventilation system

ESF room air recirculation system

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* 2.3.3.24 enclosure building filtration system

* 2.3.3.25 fuel handling area ventilation system

* . 2.3.3.26 main exhaust ventilation system

* 2.3.3.27 non-radioactive area ventilation system

* 2.3.3.28 process and area radiation' monitoring system

* 2.3.3.29 radwaste area ventilation system

* 2.3.3.30:_ turbine building ventilation system,

* 2.3.3.31 vital switchgear ventilation system

* 2.3.3.32 Unit 2 fire protection system

2.3.3.33 *Unit 3 fire protection system

* 2.3.3.34 domestic water system ; '

* 2.3.3.35 diesel generator system :

* 2.3.3.36 diesel generator fuel oil system

* 2.3.3.37 station blackout diesel generator system

* 2.3.3.38 security system

* 2.3.3.39 :- clean liquid waste processing

* 2.3.3.40 -ogaseous waste processing system

2.3.3.41 post-accident sampling system.

* 2.3.3.42 station sumps and drains system -

The corresponding subsections of this SER (2.3A.3.1 - 2.3A.3.42, respectively) present the,

staff's review findings. --- ,'

2.3A.3.1 Circulating Water System

2.3A.3.1.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.1, the applicant described the circulating water system. The circulating

water system provides a supply of cooling water to the main condenser via four one-fourth

capacity vertical wet-pit pumps, which circulate water from the intake structure through the main

condenser to the discharge structure. The circulating water pumps take suction on Long Island

Sound. A warm water recirculation flowpath is provided to circulate condenser outlet water to

the intake structure to reduce ice formation. v

The circulating water system provides warm water recirculation to the intake structure for deicing to ensure service water system availability and contains level switches that are used to

shut down the circulating water pumps to prevent flooding in the turbine building. The system

also contains NSR components that are spatially oriented such that their failure could prevent

the satisfactory accomplishment of a safety-related function associated with a safety-related

SSC. -

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary * provides limited structural integrity

In LRA Table 2.3.3-1, the applicant identified the following circulating water system component

types that are within the scope of license'renewal and subject to an AMR: expansion joints;

pipe; and valves. - : - , ;-

2445?.
2.3A.3.1.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.1 and Millstone FSAR Section 9.7.1. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.3.1.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the circulating water system components that are within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the circulating

water system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.3.2 Screen Wash System

2.3A.3.2.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.2, the applicant described the screen wash system. The screen wash

system provides a source of water to clear debris from the traveling water screens at the intake

structure. The system is comprised of two screen wash pumps, strainers, piping, and valves.

The screen wash system contains NSR components that are spatially oriented such that their

failure could prevent the satisfactory accomplishment of a safety-related function associated

with a safety-related SSC.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-2, the applicant identified the following screen wash system component

types that are within the scope of license renewal and subject to an AMR: pipe; pumps;

strainers; tubing; and valves.

2.3A.3.2.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.2 and Millstone FSAR Section 9.7.1. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

2-46
In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with10 CFR 54.21(a)(1). - .

The staff's review of LRA Section 2.3.2.2 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review the staff noted that a license renewal drawing showed screen wash pump casing

drain lines outside the scope of license renewal and excluded from being subject to an AMR.

The drain lines serve a pressure boundary intended function, and are passive and long-lived

and should be within scope for license renewal and subject to an AMR. In RAI 2.3.3.2-1A, the

staff requested the applicant to clarify that these components are within the scope of license

renewal and subject to an AMR, or explain their exclusion. -

In its response,-dated July 26, 2004, the applicant concluded that the pump casing drain lines

shown on the license renewal drawing are pump shaft packing leak-off lines and are normally

dry and not pressurized. Upon further review, the applicant concluded that these lines should be

included within the scope of license renewal for 10 CFR 54.4(a)(2) and revised Table 2.3.3-2 to

include the lines. The applicant stated that the aging effect of loss of material (external) will be

managed with the general condition monitoring AMP and the aging effect of loss of material

(internal) will be managed with the work control process AMP.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.2-1A acceptable,

because the pump casing drain lines are included in the scope of license renewal and will be

managed appropriately. Therefore, the staff's concern described in RAI 2.3.3.2-1A is resolved.

2.3A.3.2.3 Conclusion - ;

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI response described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review,-the

staff concludes that there is reasonable assurance that the applicant has'adequately identified

the screen wash water system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the screen wash

water system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2-47:
2.3A.3.3 Service Water System

2.3A.3.3.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.3, the applicant described the service water (SW) system. The purpose of

the SW system is to provide a dependable flow of cooling water to the following safety-related

and NSR loads:

* reactor building closed cooling water heat exchangers

* turbine building closed cooling water heat exchangers

* emergency diesel generator heat exchangers

* vital AC switchgear room cooling coils

* DC switchgear room vital chillers

The SW system provides cooling water flow to safety-related heat loads to transfer rejected

heat to the ultimate heat sink and isolation of NSR heat loads in the event of a design basis

accident. The SW system contains NSR components that are spatially oriented such that their

failure could prevent the satisfactory accomplishment of a safety-related function associated

with a safety-related SSC. The system also contains NSR components credited for mitigating a

high-energy line break (HELB) accident. The SW system contains environmental qualification

equipment and supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides filtration

* provides limited structural integrity

* restricts flow

In LRA Table 2.3.3-3, the applicant identified the following SW system component types that

are within the scope of license renewal and subject to an AMR: expansion joints; filter/strainers;

flow elements; flow indicators; flow orifices; pipe; pumps; restricting orifices; SW pump motor

protective tank; tubing; and valves.

2.3A.3.3.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.3 and Millstone FSAR Sections 6.1.2.1, 8.2.3.3, 8.3.2.2,

9.4.3.1, 9.7.2, and 14.8.2.2.3. The staffs review, using the evaluation methodology described in

Section 2.3 of this SER, was conducted in accordance with the guidance described in Section

2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

2-48
- - -

The staff's review of LRA Section 2.3.3.3 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that a license renewal drawing shows the SW strainer overflow

lines outside the scope of license renewal and excluded from being subject to an AMR.' Failure

of the overflow line may cause the SW to flow to the outside of the strainer and on safety-;

related components in the intake structure. In-RAI 2.3.3.3-1A, dated June 9, 2004, the staff

requested the applicant to explain the apparent exclusion of these drain lines from the scope of

license renewal and from being subject to an AMR.'

In its response, dated July 26, 2004, the applicant stated that the overflow lines are the service

water strainers' packing leakoff lines, which direct strainer shaft leakage to a floor drain. These.

lines are in a normally dry condition. However, if a packing leak does occur, moisture will be

present, creating the potential to wet safety-related components. The applicant concluded that

these lines should. be included within the scope of license renewal and revised LRA Table 2.3.3-

3 to include the packing leakoff lines. The applicant stated that the aging effect of loss of

material (external) will be managed with the general 'condition monitoring AMP and the aging

effect of loss of material (internal) will be managed with the service water system (Open-Cycle

Cooling) AMP.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.3-1A acceptable,

because the strainer leakoff lines are included within the scope of license renewal and will be

managed appropriately. Therefore, the staffs concern described in RAI 2.3.3.3-1A is resolved.

Table 2.3.3-3 lists "SW Pump Motor Protective Tank" as a component type within the scope of

license renewal and subject to an AMR. This stored component protects the SW pumps or

other safety-related components from failing to perform their intended functions. In

RAI 2.3.3.3-2A dated June 9, 2004, the applicant was asked to provide drawings or descriptive

information that would allow the staff to determine whether the subcomponents of the "SW

Pump Motor Protective Tank," were adequately identified in Table 2.3.3-3.

In its response, dated July 26, 2004, the applicant stated that the SW pump motor is protected

from flooding by shrouding the motor with a fiberglass tank "can" that fits over the vertical

motor. The SW pump motor protective tank is a stored piece of equipment that is designed to

protect one SW pump motor from damage-due to flooding during a postulated maximum

hurricane. The fiberglass tank is equipped with a steel lifting rig to facilitate installation of the

tank. The fiberglass tank provides the flood protection intended function. The lifting rig is not

required to prevent flooding damage to the SW pump motor and is not within the scope of

license renewal. ,

The staff finds the applicant's response to RAI 2.3.3.3-2A acceptable, because it adequately

describes the SW pump motor protective tank and its use. The description allows the staff to

conclude that this component was correctly identified within the scope of license renewal and

subject to an AMR. Therefore, the staffs concern described in RAI 2.3.3.3-2A is resolved.

2-49 -.
-

2.3A.3.3.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the SW system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the SW system components

that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.4 Sodium Hypochlorite System

2.3A.3.4.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.4, the applicant described the sodium hypochlorite system. The sodium

hypochlorite system provides a source of sodium hypochlorite to minimize marine growth in the

SW system and the circulating water system.

The sodium hypochlorite system contains NSR components that are spatially oriented such that

their failure could prevent the satisfactory accomplishment of a safety-related function

associated with a safety-related SSC.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-4, the applicant identified the following sodium hypochlorite system

component types that are within the scope of license renewal and subject to an AMR: pipe and

valves.

2.3A.3.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.4 and Millstone FSAR Section 9.7.1. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2-50
2.3A.3.4.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis' of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the sodium hypochlorite system components that are within the s66pe of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

sodium hypochlorite system components that'are subject to an AMR, as required by

10 CFR 54.21(a)(1)..,~f -;.

2.3A.3.5 Reactor Building Closed Cooling Water System

2.3A.3.5.1 Summary of Technical Information in' the 'Application

In LRA Section 2.3.3.5, the applicant described the reactor building closed cooling water

(RBCCW) system. The RBCCW system is a closed loop cooling system that transfers heat

from reactor auxiliaries to the service water system during plant operation and accident

conditions.

The RBCCW system transfers heat from safety-related heat loads to the ultimate heat sink,

providing automatic and manual isolation of non-essential heat loads in the event of a design

basis accident, and providing containment pressure boundary integrity. The reactor building

closed cooling water system contains NSR components that are spatially oriented such that

their failure could prevent the satisfactory accomplishment of a safety-related function

associated with a safety-related SSC. The system contains environmental qualification

equipment and supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* restricts flow

* provides limited structural integrity

* provides for heat transfer

In LRA Table 2.3.3-5, the applicant identified the following reactor building closed cooling water

system component types that are within the scope of license renewal and siubject to an AMR:

flow elements; flow indicators; flow orifices; flow switches; pipe; pumps; RBCCW heat

exchangers; RBCCW surge tank; reactor vessel support concrete cooling coils; tubing; and

valves.

2.3A.3.5.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.5 and Millstone FSAR Sections 9.2.2.2, 9.3.2.2,' 9.4,

9.7.2.1.1, 9.9.1.2.1, and 9.10.6.2. The staffs review, using the evaluation methodology

described in Section 2.3 of this SER, was conducted in accordance with the guidance described

in Section 2.3 of NUREG-1800.

2-51i
_J_!

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.3.5 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

One of the license renewal drawings reviewed by the staff shows flexible hoses and a sample

cooler within the RBCCW system within the scope of license renewal and subject to an AMR.

However, these components were not listed in LRA Table 2.3.3-5 as a component type subject

to an AMR. In RAI 2.3.3.5-A, dated June 9, 2004, the staff requested the applicant to explain

whether these components were included with another component type or to explain their

exclusion from the scope of license renewal.

In its response, dated July 26, 2004, the applicant stated that flexible hoses are within the

scope of license renewal, but have been determined to be short-lived components. As

described in LRA Section 2.1 5.1, short-lived components are shown on the license renewal

drawings. However, the applicant stated that these short-lived components are not subject to an

AMR and are not included in the screening results tables provided in Section 2 of the LRA. The

applicant further stated that modified preventive maintenance program procedures will require

the periodic replacement of the flexible hoses based on a specified time frequency. Also, the

applicant stated that the sample cooler is within the scope of license renewal and is included in

the component type "Sample Coolers" in LRA Table 2.3.4-10, which is within the plant heating

and condensate recovery system.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-1A acceptable

because the applicant clarified that the flexible hoses and sample cooler are within the scope of

license renewal in accordance with the requirements of 10 CFR 54.4(a) and the flexible hoses

will be replaced by preventive maintenance program procedures that have been modified such

that the replacement is performed at a specified time frequency. Also, the applicant clarified

that the sample cooler is included in the component type "Sample Coolers" in LRA Table 2.3.4-

10 subject to an AMR. Based upon the applicant's response, the components discussed in this

RAI adequately meet the requirements of 10 CFR 54.21(a)(1). Therefore, the staffs concern

described in RAI 2.3.3.5-1A is resolved.

Another license renewal drawing showed lines to several temperature indicating controllers

(TICs) within the RBCCW system, that appeared to fall within the scope of license renewal and

subject to an AMR. The lines provide a temperature signal to the controls of several

temperature control valves. These lines appear to be electrical wires. In RAI 2.3.3.5-2A dated

June 9, 2004, the staff requested the applicant to clarify whether the lines have been correctly

included within the scope of license renewal.

2-52
-

In its response, dated July 26, 2004, the applicant stated that the temperature sensing lines

highlighted between the RBCCW system piping and the respective temperature control valves

are capillary tubing. The capillary tubing performs its function without penetrating the RBCCW

piping. The lines highlighted between the control circuits of the temperature control valves and

the temperature indicating controllers are pneumatic signal tubing. Failure of neither the

capillary tubing, the temperature control valve positioners, nor the pneumatic circuits affect the

ability of the RBCCW system from performing its intended functions and are therefore not

within the scope of license renewal. The applicant explained that the capillary tubing and

pneumatic signal tubing were inadvertently highlighted on the license renewal drawings.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.5-2A acceptable

because it provided adequate explanation of the capillary and pneumatic tubing functions and

how it was inadvertently highlighted on the license renewal drawing. The staff concludes that

the tubing was scoped in accordance with the requirements of 10 CFR 54.4(a) and screened in

accordance with the requirements of 10 CFR 54.21(a)(1). Therefore, the staffs concern

described in RAI 2.3.3.5-2A is resolved.

2.3A.3.5.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the RBCCW components that are within the scope of license renewal, as required by --

10 CFR 54.4(a), and that the applicant has adequately identified the RBCCW components that

are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.6 Chilled Water System

2.3A.3.6.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.6, the applicant described the chilled water system.'The chilled water

system consists of the auxiliary chilled water subsystem that functions during normal operation

and the vital chilled water subsystem that is normally in stand-by for use in the event of an

accident. The chilled water system is a closed-loop system that provides cooling water for the

vital switchgear ventilation system and various NSR plant cooling requirements. The auxiliary

chilled water subsystem automatically isolates from the vital chilled water subsystem in an

emergency, and the vital chilled watersubsystem supplies the vital switchgear ventilation

system.

The chilled water system provides chilled waterto the vital switchgear ventilation system and

isolation of the NSR portion of the system during an accident. The chilled water system

contains NSR components that are spatially oriented such that their failure could prevent the

satisfactory accomplishment of a safety-related function associated with a safety-related SSC.

The system supports fire protection.

2-53'
-U'

Intended functions within the scope of license renewal include the following:

* provides for heat transfer

* provides a pressure boundary

* provides filtration

* provides limited structural integrity

In LRA Table 2.3.3-6, the applicant identified the following chilled water system component

types that are within the scope of license renewal and subject to an AMR: chilled water chillers;

chilled water evaporators; chilled water surge tank; compressor casings; filter/strainers; flow

elements; level indicators; moisture indicators; pipe; pumps; tubing; and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the chilled water system. In its December 3, 2004, RAI

response, the applicant identified the non-vital chiller component type that was added to the

scope of the chilled water system.

2.3A.3.6.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.6 and Millstone FSAR Sections 9.7.2.1.1, 9.9.16, and

9.9.17. The staff's review, using the evaluation methodology described in Section 2.3 of this

SER, was conducted in accordance with the guidance described in Section 2.3 of NUREG1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.3.6 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAls as discussed below.

In its review, the staff noted that a license renewal drawing for the chilled water system showed

a symbol representing components that is not identified on the license renewal drawing legend.

Therefore, the staff was not able to ensure that LRA Table 2.3.3-6 is complete. In

RAI 2.3.3.6-1A, dated June 9, 2004, the staff requested the applicant to define the symbol for

these components and to clarify whether they penetrate the chilled water system piping

pressure boundary.

In its response, dated July 26, 2004, the applicant stated that the unidentified components are

moisture filters and that they are part of the chilled water system pressure boundary. The

applicant stated that the components are within the scope of license renewal and are included

in the component type "Filters/Strainers" in LRA Table 2.3.3-6.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.6-1A acceptable

because the moisture filters were identified and properly placed within the scope of license

renewal. The staff concludes that the moisture filters were scoped in accordance with the

2-54
requirements of 10 CFR 54.4(a) and screened in accordance with the requirements of

10 CFR 54.21(a)(1). Therefore, the staffs concern described in RAI 2.3.3.6-1A is resolved.

LRA Table 2.3.3-6 listed "Chilled Water Chillers" and 'Chilled Water Evaporators" as

component types subject to an AMR. During its review, the staff determined that evaporator and

chiller shells, shown on a license renewal drawing for the chilled water system, perform a'

pressure boundary intended function and are within the scope of license renewal and subject to

an AMR. In RAI 2.3.3.6-2A, dated June 9, 2004, the staff requested the applicant to confirm

that the evaporator and chiller shells are included with the components listed in LRA Table

2.3.3-6.

In its response, dated July 26, 2004, the applicant stated that the component types "Chilled

Water Chillers" and "Chilled Water Evaporators" include the chiller and evaporator shells in

LRA Table 2.3.3-6. The tubing and shell of the chilled water chillers and chilled waterevaporators are identified as individual components for aging management in LRA

Table 3.3.2-6.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.6-2A acceptable

because the shells of the chillers and evaporators were considered to be part of the

components in the chilled water system. The staff concludes that the shells were scoped in

accordance with the requirements of 10 CFR 54.4(a) and screened in accordance with the,-

requirements of 10 CFR 54.21(a)(1). Therefore, the staff's concern described in RAI 2.3.3.6-2A

is resolved.

In its review, the staff noted that a license renewal drawing for the chilled water system showed

that the lower half of the chilled water surge tank is divided into two equal sections by a vertical

weir. The surge tank weir was not shown to be within the scope of license renewal and was

excluded from being subject to an AMR. The vertical weir in the surge tank assures that chilled

water will be available to supply vital portions of the system, if one of the two independent

supply lines ruptures. In RAI 2.3.3.6-3A, dated June 9, 2004, the staff requested the applicant

to explain the apparent exclusion of the vertical weir from the scope of license renewal.

In its response, dated July 26, 2004, the applicant stated that the vertical weir located inside of

the chilled water surge tank was inadvertently not highlighted, but is within the scope of license

renewal. The applicant stated that the vertical weir was evaluated as an 'integral part of the

component type, "Chilled Water Surge Tank" shown in LRA Table 2.3.3-6.- - -

Based on its review, the staff finds the applicant's response to RAI 2.3.3.6-3A acceptable

because the vertical weir within the chilled water surge tank was considered as a component in

the chilled water system. The staff concludes that the vertical weir was scoped in accordance

with the requirements of 10 CFR 54.4(a) and screened in accordance with the requirements of

1 0 CFR 54.21 (a)(1). Therefore, the staffs concern described in RAI 2.3.3.6-3A is resolved.

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The .staff finds the -expanded scope of mechanical components identified in

the December 3, 2004, response acceptable,'because the applicant adequately included NSR.

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

2-55'.
applicant's December 3, 2004, response related to the scoping and screening results of the

chilled water system is acceptable.

2.3A.3.6.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the chilled water system components that are within the scope of license renewal, as required

by 10 CFR 54.4(a), and that the applicant has adequately identified chilled water system

components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.3.7 Instrument Air System

2.3A.3.7.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.7, the applicant described the instrument air system. The instrument air

system provides a reliable source of clean, dry, oil-free compressed air at the proper pressure

to supply air-operated valves, instruments, and other miscellaneous components in the plant.

The instrument air system is cross-connected with the station air system.

The instrument air system provides containment pressure boundary integrity and backup

compressed air for operation of certain safety-related components. The instrument air system

also includes environmental qualification equipment and supports fire protection.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-7, the applicant identified the following instrument air system component

types that are within the scope of license renewal and subject to an AMR: accumulators; hoses;

pipe; regulators; tubing; and valves. In addition, as a result of the scoping methodology

changes in response to RAI 2.1-1, described in the November 9, 2004, response, the applicant

expanded the system boundaries for the instrument air system. Specifically, in its December 3,

2004, response, the applicant identified the following component types that were added to the

scope of the instrument air system:

* compressors

* compressor aftercoolers

* containment instrument air receiver tank

2.3A.3.7.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.7 and Millstone FSAR Sections 5.2 and 9.1.1. The staffs

review, using the evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1800.

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In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staff's review of LRA Section 2.3.3.7 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAI as discussed below.

LRA Section 2.3.3.7 states that the instrument air system is within the scope of license renewal

because it provides containment pressure boundary integrity and backup compressed air for

the operation of certain safety-related components. Where required, the backup compressed

air source is supplied from an installed accumulator. The Millstone FSAR references a list of all

safety-related pneumatically actuated valves including ,those with an air accumulator. In RAI

2.3.3.7-1A, the staff requested additional information to complete its review:

* The staff requested the applicant to identify those listed valves that have accumulators.

* The accumulator and associated tubing was shown in the application to be subject to an

AMR for eight valves not identified in the list. The staff requested the applicant to verify

the accuracy of the list. - stf r

* A license renewal drawing for the instrument air system showed accumulators and

associated tubing leading to a note stating, "TO 2-MS-64A and "TO 2-MS-64B." The

staff took the position that these valves are provided with backup air accumulators and

should be identified with within the scope of license renewal in accordance with the

requirements of 10 CFR 54.4(a). However, the instrument air line to these valves was

not shown to be subject to an AMR. The staff requested the applicant to explain the-_

apparent exclusion of the instrument air line from the scope of license renewal.

In its response, dated July 26, 2004, the applicant stated:

(1) The valves listed are the safety-related pneumatic actuated valves necessary for safe

shutdown. The applicant reviewed the list of values and determined that there are no

additional valves with air accumulators other than those listed in the RAI.

(2) The eight valves identified in the RAI that have air accumulators and tubing subject to

AMR, but are not identified in the list represented a discrepancy that has been

documented in the plant Corrective Action System. -*~:. .$;-O-\I -- . .- . -.. - . '--

(3) The pneumatic lines shown on an instrument air license renewal drawing are an

extension of "test lines" that originate on another drawing that is not a license renewal

drawing. The applicant stated that these "test lines" do not perform an intended function

and are not within the scope of license renewal.

The staff finds the applicant's response to RAI 2.3.3.7-1A acceptable because the questions

arising from the comparison of the list of air operated valves and those found on license

renewal drawings were adequately resolved bythe applicant. The staff concludes that the

components in the instrument air system were scoped in accordance with the requirements of

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10 CFR 54.4(a) and screened in accordance with the requirements of 10 CFR 54.21 (a)(1).

Therefore, the staffs concerns described in RAI 2.3.3.7-1A are resolved.

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

instrument air system is acceptable.

2.3A.3.7.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the instrument air system components that are within the scope of license renewal, as required

by 10 CFR 54.4(a), and that the applicant has adequately identified the instrument air system

components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.3.8 Nitrogen System

2.3A.3.8.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.8, the applicant described the nitrogen system. The nitrogen system

provides clean, dry gas that is utilized in multiple applications throughout the plant. The nitrogen

system provides a pressure boundary for the safety injection system.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-8, the applicant identified the following nitrogen system component types

that are within the scope of license renewal and subject to an AMR: pipe and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the nitrogen system. In its December 3, 2004, RAI

response, the applicant identified the flow indicators component type that was added to the

scope of the nitrogen system.

2.3A.3.8.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.8 and Millstone FSAR Section 6.3.2. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

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In conducting its review, the staffievaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1). - f '

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable,' because the applicant adequately included NSR

components with the configurations that meet the'scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

nitrogen system is acceptable. -

2.3A.3.8.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that'there is

reasonable assurance that the applicant has adequately identified the nitrogen system

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the nitrogen system components that are subject to

an AMR; as required by 10 CFR 54.21(a)(1).;E

2.3A.3.9 Station Air System

2.3A.3.9.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.9, the applicant described the station air system. The station air system

provides a source of clean, oil-free compressed air at the proper pressure to support the

operation of air-operated tools and other devices. The station air system can be used as a

source of compressed air to the instrument air system. The station air system also provides air

pressure to support dry pipe fire protection sprinkler systems.'

The station air system provides a containment pressure boundary integrity. The station air

system also provides a pressure boundary for the fire protection water suppression system.

The intended function within the scope of license renewal includes providing pressure

boundary.

In LRA Table 2.3.3-9, the applicant identified the following station air system component types

that are within the scope-of license renewal and subject to an AMR: pipe and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the station air system. In its December 3, 2004, RAI

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response, the applicant identified the following component types that were added to the scope

of the station air system:

* compressors a

* air compressor aftercoolers

* air compressor intercoolers

2.3A.3.9.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.9 and Millstone FSAR Section 9.1.1. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

station air system is acceptable.

2.3A.3.9.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No.

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the station air system

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the station air system components that are subject

to an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.3.10 Hydrogen System

2.3A.3.10.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.10, the applicant described the hydrogen system. The hydrogen system

provides a source of hydrogen gas for the main generator and volume control tank. The system

is comprised of primary and reserve gas cylinders located outside of the turbine building on the

hydrogen bulk storage skid. An excess flow valve, located outside of the turbine building,

2-60
isolates hydrogen flow in the event of a line failure within the turbine building in order to mitigate

the spread of fire.

The hydrogen system provides for fire mitigation.,

The applicant identified no component groups that require aging management review.

2.3A.3.10.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.10 and Millstone FSAR Section 10.2.5. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54A(a). The staff did not identify'any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3A.3.10.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No'omissions were identified. In'addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant adequately

identified that the hydrogen system is within the scope of license renewal, as required by

10 CFR 54.4(a), but there are no components subject to an AMR, as required by

10 CFR 54.21 (a)(1).

2.3A.3.11 Chemical and Volume Control System.

2.3A.3.11.1 Summary of Technical Information'in the Application

In LRA Section 2.3.3.11, the applicant described the CVCS. The CVCS provides a method for

controlling the inventory and chemistry of the RCS.'!During normal operation', reactor coolant

letdown flow is cooled; conditioned via ion exchangers, filters, and chemical addition; heated;

and returned to the RCS. The system also provides the capability to adjust reactor coolant

soluble boron concentration in order to effect reactivity changes within the reactor core. During

emergency conditions, the CVCS provides a high-pressure source of borated water injection to

the RCS.

The CVCS provides a borated water flowpath to the RCS for reactivity control and for make-up

in the event of an accident. The system also provides an RCS pressure boundary at system

interfaces; safety-related RG 1.97 indications; and containment penetration pressure boundary

integrity. The CVCS contains NSR components credited for mitigating the effects of a highenergy line break and NSR components spatially oriented such that a failure could prevent the

satisfactory accomplishment of a safety-related function of a safety-related SSC. The CVCS

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also contains environmental qualification equipment and supports fire protection and station

blackout.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-10, the applicant identified the following CVCS component types that are

within the scope of license renewal and subject to an AMR: bolting; boric acid tanks;

filter/strainers; flow elements; flow indicators; letdown heat exchanger, level indicators; lube oil

reservoirs; pipe; pulsation dampeners; pumps; regenerative heat exchanger, suction stabilizers;

sump tanks; tubing; valves; and volume control tank.

2.3A.3.11.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.11 and Millstone FSAR Section 9.2. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.3.11.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the CVCS components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the CVCS components that

are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.3.12 Sampling System

2.3A.3.12.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.12, the applicant described the sampling system. The sampling system

provides the means for determining chemical and radiological conditions of plant processes and

environments.

The sampling system provides the capability to obtain post-accident samples, providing a

pressure boundary at interfaces with safety-related systems, and providing safety-related RG

1.97 indications. The sampling system contains NSR components spatially oriented such that a

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failure could prevent the satisfactory accomplishment of a safety-related function of a safetyrelated SSC. The sampling system also contains environmental qualification equipment.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-11, the applicant identified the following sampling system component types

that are within the scope of license renewal and subject to an AMR: bolting; pipe, sample

coolers; tubing; and valves.:

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the sampling system. In its December 3, 2004, RAI

response, the applicant identified the following component types that were added to the scope

of the sampling system:

* sample chiller

* secondary sample station/sink

2.3A.3.12.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.12 and Millstone FSAR Section 9.6. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached.piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

sampling system is acceptable. - -

2.3A.3.12.3 Conclusion - ->: -

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition; the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the sampling system

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components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the sampling system components that are subject to

an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.3.13 Primary Makeup Water System

2.3A.13.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.13, the applicant described the primary makeup water system. The

primary makeup water system, which is part of the water treatment system, provides

demineralized water for use in primary and auxiliary systems in the plant.

The primary makeup water system provides containment penetration pressure boundary

integrity and safety-related RG 1.97 indications. The primary makeup water system contains

NSR components spatially oriented such that a failure could prevent the satisfactory

accomplishment of a safety-related function of a safety-related SSC. The primary makeup

water system also contains environmental qualification equipment.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-12, the applicant identified the following primary makeup water system

component types that are within the scope of license renewal and subject to an AMR: bolting;

flow elements; pipe; primary water head tank; pumps; tubing; and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the primary makeup water system. In its December 3,

2004, RAI response, the applicant identified the following component types that were added to

the scope of the primary makeup water system:

* makeup water vacuum dearator

* primary water storage tank

* dearator water transfer pump

2.3A.3.13.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.13 and Millstone FSAR Section 9.12. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

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The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

primary makeup water system is acceptable.

2.3A.3.13.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff.performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the primary makeup water

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the primary makeup water components that are

subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.14 Access Control Area Air Conditioning System

2.3A.3.14.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.14, the applicant described the access control area air conditioning

system. The access control area air conditioning system provides for heating and cooling of

office spaces. The system contains fire dampers to prevent the spread of fire. Therefore, the

access control area air conditioning system supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a pressure boundary

In LRA Table 2.3.3-13, the applicant identified the following access control area air conditioning

system component type that is within the scope' of license renewal and subject to an AMR:

damper housings.

2.3A.3.14.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.14 and Millstone FSAR Section 9.9.13. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Sectioni 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

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functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.3.14.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the access control area air conditioning system components that are within the scope

of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the access control area air conditioning system components that are subject to an

AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.15 Main Condensers Evacuation System

2.3A.3.15.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.15, the applicant described the main condensers evacuation system. The

main condensers evacuation system includes two steam-jet air ejector units, complete with

inter- and after-condensers, which remove air and noncondensable gases from the main

condenser. A mechanical vacuum pump is provided for use during startup. Air ejector

condenser cooling is provided by condensate flow. Air in-leakage and noncondensable gases

are removed from the condenser and discharged to the stack, which is continuously monitored

for radioactivity.

The main condensers evacuation system contains NSR components that are spatially oriented

such that their failure could prevent the satisfactory accomplishment of a safety-related function

associated with a safety-related SSC.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-14, the applicant identified the following main condensers evacuation

system component types that are within the scope of license renewal and subject to an AMR:

damper housings; ductwork; fan/blower housings; and pipe and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the main condensers evacuation system. In its

December 3, 2004, RAI response, the applicant identified the following component types that

were added to the scope of the main condensers evacuation system:

* flow orifices

* flow switches

* filter/strainers

* steam jet air ejector vent condenser

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2.3A.3.15.2 Staff Evaluation

The staff reviewed LRA Section. 2.3.3.15 and Millstone FSAR Section 10.4.2. The staffs

review, using the evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended'

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1). _

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

containment air recirculation and cooling system is acceptable.

2.3A.3.15.3 Conclusion

The staff reviewed the LRA and RAI response'described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified.. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the main condensers

evacuation system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the main condensers

evacuation system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.16 Containment Air Recirculation and Cooling System

2.3A.3.16.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.16, the applicant described the containment air recirculation and cooling

system. The function of the containment air recirculation and cooling system is to remove heat

from the containment atmosphere during normal operation and after an accident. In the event

of a LOCA or MSLB accident, ,the system provides a means of cooling the containment

atmosphere to reduce containment pressure, which minimizes the potential for leakage of

airborne particulate and gaseous radioactivity from containment.

The containment air recirculation and cooling system provides heat removal from the

containment after an accident, providing containment pressure boundary integrity, and RG 1.97

safety-related indications and signals. The containment air recirculation and cooling system

also contains environmental qualification equipment and supports fire protection.

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The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-15, the applicant identified the following containment air recirculation' and

cooling system component types that are within the scope of license renewal and subject to an

AMR: containment air recirculation cooling unit coils; containment air recirculation cooling unit

housings; damper housings; ductwork; fan/blower housings; flow elements; pipe; tubing; and

valves.

2.3A.3.16.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.16 and Millstone FSAR Section 6.5. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3A.3.16.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable'assurance that the applicant has adequately

identified the containment air recirculation and cooling system components' that are within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the containment air recirculation and cooling system components that are subject to

an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.17 Containment and Enclosure Building Purge System

2.3A3.17.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.17, the applicant described the containment and enclosure building purge

system. The containment and enclosure building purge system functions to maintain a suitable

environment for personnel access into the containment and enclosure building. The purge

system provides fresh air ventilation, and heating when required; and it is balanced to maintain

a negative pressure in the area being purged. The system contains fire dampers to mitigate a

fire.

The containment and enclosure building purge system provides automatic isolation and

alignment of the system on an actuation signal and provides containment pressure boundary

integrity. The containment and enclosure building purge system also contains environmental

qualification equipment and supports fire protection.

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Intended functions within the scope of licenserenewal include the following:

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a pressure boundary

In LRA Table 2.3.3-16, the applicant identified' the following containment and enclosure building

purge system component types that are within the7 scope of license renewal and subject to anAMR: damper housings; ductwork; ductwork jointtseals; flex connections; pipe; and valves.

2.3A.3.17.2 Staff Evaluation

The staff reviewed LRA'Section 2.3.3.17 and Milistone'FSAR Section 9.9.2. The staffs review,

using the evaluation methodology described in' Secti6n 2.3 of this SER, was conducted in

accordance with the guidance described in Secti6n 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated thed'ystem functions described in the LRA and'

Millstone FSAR in accordance with the requirements of 10 CFR 54A4(a) to verify that the

applicant did not omit from'the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The'staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.3.17.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of'

license renewal were not identified by the applicarnt.No omissions were identified. In addition,

the staff performed a review to determine wheth6er any components that should be subject toan

AMR were not identified by the applicant. No -missions were identified. On the' basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the containment and enclosure building purge system components that are within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the containment and enclosure building purge system components that are subject to

an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.3.18 Containment Penetration Cooling System2.3A.3.18.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.18, the applicant described the containment penetration cooling system.

The containment penetration cooling system'functions to limit the temperature of containment

structure concrete to 150 *F in the vicinity 'of h6t iiping penetrations. The system consists of two

vane-axial fans and the associated syster ductWork and dampers. The system contains fire

dampers to prevent the spread of a fire. ;H -'-

The containment penetration cooling system provides cooling air to the concrete area

surrounding the containment piping pehetrati6ns'-The containment penetration'cooling system

also supports fire protection.

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Intended functions within the scope of license renewal include the following:

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a pressure boundary

In LRA Table 2.3.3-17, the applicant identified the following containment penetration cooling

system component types that are within the scope of license renewal and subject to an AMR:

damper housings; ductwork; ductwork joint seals; fan/blower housings; and flex connections.

2.3A.3.18.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.18 and Millstone FSAR Section 9.9.4. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3A.3.18.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the containment penetration cooling system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the containment penetration cooling system components that are subject to an AMR,

as required by 10 CFR 54.21(a)(1).

2.3A.3.19 Containment Post-Accident Hydrogen Control System

2.3A.3.19.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.19, the applicant described the containment post-accident hydrogen

control system. The containment post-accident hydrogen control system includes independent,

fully redundant subsystems to mix, monitor, and reduce the hydrogen concentration in

containment following a loss-of-coolant accident (LOCA). The system functions to maintain the

concentration of hydrogen in the containment below the lower flammability limit following a

LOCA.

The containment post-accident hydrogen control system is within the scope of license renewal

because the system controls the concentration of hydrogen in containment after an accident to

below the lower flammability limit following a LOCA, provides containment pressure boundary

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integrity, and provides RG 1.97 safety-related indications'and signals. The containment postaccident hydrogen control system also contains environmental qualification equipment.

The intended function within the scope of license-renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-18, the applicant identified the following containment post-accident

hydrogen control system component types that are within the scope of license renewal and

subject to an AMR: detection chambers; fan/blower housings; flexible hoses;' flow elements;

flow orifices; hydrogen recombiner housings; pipe; tubing; and valves.

2.3A.3.19.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.19 and Millstone FSAR Section 6.6. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2:3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 544(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.3.19.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant.' No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the containment post-accident hydrogen control system components that are within

the scope of license renewal,,as required by 10 CFR 54.4(a), and that the applicant has

adequately identified the containment post-accident hydrogen control system components that

are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.20 Control Room Air Conditioning System

2.3A.3.20.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.20, the applicant described the control room air conditioning system. The

control room air conditioning system functions to maintain a suitable environment for personnel

and for safety-related control and electrical equipment during normal and accident operations.

The control room air conditioning system consists of two full-capacity, independent air-handling

and mechanical refrigeration systems. The system'contains fire dampers to prevent the spread

of fire. ; . ,; - .

The control room air conditioriing system'provides heat removal from the control room envelope

for equipment cooling and personnel habitability, provides'radiological control of the control

room envelope for personnel habitability in'the event of an accident, and provides RG 1.97

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safety-related indications. The control room air conditioning system also supports station}

blackout and fire protection.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides filtration

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.3.3-19, the applicant identified the following control room air conditioning

system component types that are within the scope of license renewal and subject to an AMR:

control room air handling units, control room filter banks, compressor casings; damper

housings; ductwork; ductwork joint seals; fan/blower housings; filter dryer, moisture indicators;

mufflers; pipe; tubing; and valves.

2.3A.3.20.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.20 and Millstone FSAR Sections 9.9.10, 14.8.4.1 and

14.8.4.3. The staff's review, using the evaluation methodology described in Section 2.3 of this

SER, was conducted in accordance with the guidance described in Section 2.3 of

NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.3.20 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAI as discussed below.

For the control room air conditioning system, described on LRA drawing 25203-LR26027, sheet

3, at CA4 and D-4, items X-42A and X-42B include co6ling coils but no heating coils. Neither

cooling nor heating coils are included in Table 2.3.3-19. In RAI SPSB-1, the applicant was

requested to clarify whether these heating and cooling coils and the associated housings are

within the scope of license renewal in accordance with 10 CFR 54.4(a), and subject to aging

management review in accordance with 10 CFR 54.21(a)(1). If they are, they should be

included in Table 2.3.3-19.

In a response dated November 9, 2004, the applicant stated that items X-42A and X-42B on

license renewal drawing 25203-LR26207, sheet 3, at CA4 and D-4 were the control room air

conditioning system, air-handling units cooling coils. The air-handling units are not equipped

with heating coils. The applicant further stated that cooling coil performs a pressure boundary

intended function and is included in the component type "Control Room Air Handling Units" in

LRA Table 2.3.3-19. The housing and coil are evaluated separately in LRA Table 3.3.2-19 as

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"Control Room Air Handling Units (Housing)" and "Control Room Air Handling Units (Coils)."

The staff finds this acceptable.

2.3A.3.20.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and the RAI

response described above to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the control room air conditioning system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequatelyidentified the control room air conditioning system components that are subject to an AMR, as

required by 10 CFR 54.21(a)(1).

2.3A.3.21 Control Element Drive Mechanism Cooling System

2.3A.3.21.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.21, the applicant described the control element drive mechanism cooling

system. The control element drive mechanism (CEDM) cooling system consists of three fan-coil

units that draw containment air across finned-tube cooling coils and supply the cooled air to the

CEDM shroud. The cooling coils are cooled by the reactor building closed cooling water system.

The control element drive mechanism cooling system provides a pressure boundary for the

reactor building closed cooling water system.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-20, the applicant identified th'e CEDM cooling coils within the scope of,

license' renewal and subject to an AMR.

2.3A.3.21.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.21 and Millstone FSAR Section 9.9.1. The staffs review,

using the evaluation methodology described in'Sectiori 2.3 of this SER, was conducted in

accordance with the guidance described in Se6tionr2.3 of NUREG-1800. . , * - *n. I

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requir6ments of 10 CFR 54.4(a) to verify that the

applicant did not omit from' the scope of licen;ise renewal any components with intended

functions delineated 'in' 10 CFR 54.4(a). The staff did not identify any omissions; The staff then

reviewed the LRA to verify that passive or lon'g-lived components were not omitted from being

subject to an AMR in 'accordance with 10 CFR 54.21 (a)(1).

2.3A.3.21.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

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the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the CEDM cooling system components that are within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the CEDM

cooling system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.3.22 Diesel Generator Ventilation System

2.3A.3.22.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.22, the applicant described the diesel generator ventilation system. The

diesel generator ventilation system maintains a suitable environment for equipment and

personnel during emergency diesel generator operation. The diesel generator ventilation

system consists of a direct drive, in-line, vane-axial fan for each diesel generator room. The

system contains fire dampers to prevent the spread of fire.

The diesel generator ventilation system provides heat removal to maintain a suitable

environment for the operation of the emergency diesel generators. The diesel generator

ventilation system contains NSR components used to mitigate the effects of a high-energy line

break (HELB). The diesel generator ventilation system also supports fire protection and station

blackout.

Intended functions within the scope of license renewal include the following:

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a pressure boundary

In LRA Table 2.3.3-21, the applicant identified the following diesel generator ventilation system

component types that are within the scope of license renewal and subject to an AMR: damper

housings; ductwork; ductwork joint seals; fan/blower housings; and flex connections.

2.3A.3.22.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.22 and Millstone FSAR Section 9.9.11. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

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2.3A.3.22.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the diesel generator ventilation system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a); and that the applicant has adequately

identified the diesel generator ventilation system components that are subject to an AMR, as

required by 10 CFR 54.21(a)(1).

2.3A.3.23 ESF Room Air Recirculation System

2.3A.3.23.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.23, the applicant described the ESF room air recirculation system. The

ESF room air recirculation system functions to'maintain a suitable environment for operation of

the safety injection and containment spray pumps. The ESF room air recirculation system

consists of two redundant, independent subsystems, each capable of maintaining the required

temperature in their associated ESF pump room. Each ESF pump room contains one full

capacity ESF room air recirculation system fan and cooling coil. The third pump room is served -

by both fans and coil units. The system contains fire dampers to prevent the spread of fire.

The ESF room air recirculation system provides heat removal from the ESF room atmosphere

for ESF equipment cooling. The ESF room air recirculation system also contains environmental

qualification equipment and supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant -- -

* provides a pressure boundary -

In LRA Table 2.3.3-22, the applicant identified the following ESF room air recirculation system

component types that are within the'scope of license renewal and subject toah AMR: damper

housings; ductwork; ductwork joint seals; ESF 'room air recirculation unit cooling coils; ESF

room air recirculation unit housings; fan/blower housings; flex connections' and pipe.

2.3A.3.23.2 Staff Evaluation

. .etoi' *r.ev.i..w. n AR 7 Th stff 

The staff reviewed LRA Section 2.3.3.23 and Millstone FSAR Section 9.9.7. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

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reviewed the LRA to verify that passive or long-lived components were not omitted from being subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3A.3.23.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of license renewal were not identified by the applicant. No omissions were identified. In addition, the staff performed a review to determine whether any components that should be subject to an AMR were not identified by the applicant. No omissions were identified. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the ESF room air recirculation system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the ESF room air recirculation system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.3.24 Enclosure Building Filtration System

2.3A.3.24.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.24, the applicant described the enclosure building filtration system. The functions of the enclosure building filtration system are to collect and process any radioactivity released to the enclosure building filtration region from the containment after a LOCA, or from the auxiliary building after a fuel handling accident in the spent fuel pool.

The enclosure building filtration region includes the region between the penetration rooms, the ESF equipment rooms, and the containment and the enclosure building. The system may be used in conjunction with the backup hydrogen purge to process containment air in order to reduce airborne activity, reduce hydrogen concentration, or reduce pressure in containment by either venting or purging the containment. The system exhausts to either the unit vent stack or the stack.

The enclosure building filtration system provides for the collection and filtration of radioactive effluents from the enclosure building filtration region or the spent fuel pool area during radiological events in order to maintain releases to the environment below 10 CFR 100 limits, provides a negative pressure in the enclosure building filtration region in the event of a LOCA or rod ejection accident, and provides a flowpath for backup hydrogen purge to the stack. The enclosure building filtration system also contains environmental qualification equipment and supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent areas of the plant

* provides a pressure boundary

* provides filtration

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In LRA Table 2.3.3-23, the applicant identified the following enclosure building filtration system

component types that are within the scope of license renewal and subject to an AMR: damper

housings; ductwork; ductwork joint seals; enclosure building filtration filter bank housings;

fan/blower housings; flex connections; flow elements; pipe; tubing; and valves.

2.3A.3.24.2 Staff Evaluation -

The staff reviewed LRA Section 2.3.3.24 and Millstone FSAR Sections 5.2.1, 5.2.8.4.1, 5.3.4,

6.7, 9.9.5.4.1, 9.9.8.3.2, 9.9.10.2.1, and 14.8.4.1. The staffs review, using the evaluation

methodology described in Section 2.3 of this SER, was conducted in accordance with the

guidance described in Section 2.3 of NUREG-1800.'

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.3.24 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

For the enclosure building filtration system, described'on LRA drawing 25203-LR26028, sheet

5, at J-10 and F-10; items X-61A and X-61B include heating and cooling coils that are not listed

in LRA table 2.3.3-23. In RAI SPSB-2, dated June 25, 2004, the applicant was requested to

clarify whether these heating and cooling coils and the associated housings are within the

scope of license renewal in accordance with 10 CFR 54.4(a), and subject to aging management

review in accordance with 10 CFR 54.21 (a)(1).lf they are excluded from the scope of license

renewal and not subject to an AMR, provide justification for the exclusion.

In a response dated November 9, 2004, the applicant stated that items X-61A and X-61B

shown on license renewal drawing 25203-LR26028, sheet 5, at J10 and F-10 are the enclosure

building filtration system filter bank dehumidifier heaters. There are no cooling coils associated

with these filter banks. The electric dehumidifier heaters are designed to maintain the relative

humidity of the air stream entering the charcoal filters at less than 90 percent. As stated in

FSAR Section 6.7.2.1, an analysis has been performed that shows the relative humidity of the

entering air stream will remain less than 90 percent regardless of heater operation. Therefore,

the applicant concluded that the dehumidifier electric heaters are not within the scope of license

renewal. The housings'associated with'the filterbanks are'within the'scop6 of license renewal

and are identified as uEnclosu-re Building Filtratio n' Filter Bank Housing" in LRA Table 2.3.3-23.

The staff finds this acceptable.'

On the basis of its review and resolution of RAI SPSB-2, the staff found that the applicant has

identified those portions of the enclosure building filtration system that meet the scoping

requirements'of 10 CFR 54.4and has inclu'de'd themrwithin the scope of license renewal in LRA

Section 2.3.3.24. The applicant has also-iri1luded enclosure building filtration system

components that are subject to an AMR in accordance with 10 CFR 54.4(a) and

10 CFR 54.21 (a)(1) in LRA Table 2.3.3-23 "Enclosure Building Filtration."

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2.3A.3.24.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified,

the enclosure building filtration system components that are within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the enclosure

building filtration system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3A.3.25 Fuel Handling Area Ventilation System

2.3A 3.25.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.25, the applicant described the fuel handling area ventilation system. The

fuel handling area ventilation system provides a suitable environment for equipment and fresh

air ventilation for personnel within the fuel handling area of the auxiliary building, while

preventing cross-contamination with surrounding areas. The fuel handling area ventilation

system is balanced to maintain a negative pressure in the area. Before irradiated fuel is -

handled, the fuel handling area ventilation system exhaust air is diverted through the enclosure

building filtration system. In the event of a fuel handling accident, the enclosure building.

filtration system processes the fuel handling area exhaust to ensure that accident doses at the

site boundary are well below 10 CFR 100 guidelines. The fuel handling area ventilation system

also contains fire dampers to prevent the spread of fire.

The fuel handling area ventilation system provides an enclosure building filtration system flow

path from the fuel handling area in the event of a fuel handling accident. The fuel handling area

ventilation system also contains components that support fire protection.

Intended functions within the scope of license renewal include the following:

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a pressure boundary

In LRA Table 2.3.3-24, the applicant identified the following fuel handling area ventilation

system component types that are within the scope of license renewal and subject to an AMR:

damper housings; ductwork; ductwork joint seals; flow elements; pipe; and valves.

2.3A.3.25.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.25 and Millstone FSAR Section 9.9.8. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

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In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements'of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.3.25.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the fuel handling area ventilation system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately -

identified the fuel handling area ventilation system components that are subject to an AMR, as

required by 10 CFR 54.21(a)(1).

2.3A.3.26 Main Exhaust Ventilation System,

2.3A.3.26.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.26, the applicant described the main exhaust ventilation system. The main

exhaust ventilation system is designed to exhaust air from areas of the auxiliary building and

provide a clean-up and exhaust flowpath for the containment and enclosure building purge

system. The system contains fire dampers to prevent the spread of a fire.

The main exhaust ventilation system provides system isolation upon receipt of a containment

isolation signal and RG 1.97 safety-related indications. The main exhaust ventilation system

also supports fire protection.

Intended functions within the scope of license renewal include the following: .

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant -' x , --

* provides a pressure boundary

In LRA Table 2.3.3-25, the applicant identified the following main exhaust ventilation system

component types that are within the scope of license renewal and subject to an AMR: damper

housings; ductwork; filter bank housinig; pipe;' tubing; and valves.

2.3A.3.26.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.26 and Millstone FSAR Section 9.9.9. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was'conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

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In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3A.3.26.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review-to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the main exhaust ventilation system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

main exhaust ventilation system components that are subject to an AMR, as required by

10 CFR 54.21 (a)(1).

2.3A.3.27 Non-Radioactive Area Ventilation System

2.3A.3.27.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.27, the applicant described the non-radioactive area ventilation system.

The non-radioactive area ventilation system provides a suitable environment for equipment and

fresh air ventilation for personnel within the clean areas of the auxiliary building, including the

east and west turbine building cable vaults and the battery rooms. The system contains fire

dampers to prevent the spread of a fire.

The non-radioactive area ventilation system contains NSR components that are used to

mitigate the effects of a HELB, and the system contains NSR components that are spatially

oriented such that their failure could prevent the satisfactory accomplishment of a safety-related

function associated with a safety-related SSC. The non-radioactive area ventilation system also

supports station blackout and fire protection.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.3.3-26, the applicant identified the following non-radioactive area ventilation

system component types that are within the scope of license renewal and subject to an AMR:

cable vault recirculation unit cooling coils; damper housings; ductwork; and fan/blower

housings.

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2.3A.3.27.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.27 and Millstone FSAR Section 9.9.6. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license-renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify-any omissions: The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3A.3.27.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of -

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the non-radioactive area ventilation system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a); and that the applicant has adequately -

identified the non-radioactive area ventilation system components that are subject to an AMR,

as required by 10 CFR 54.21(a)(1).

2.3A.3.28 Process and Area Radiation Monitoring System

2.3A.3.28.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.28, the applicant described the'process and area radiation monitoring

system. The process and area radiation monitoring system provides radioactivity monitoring for

liquid and gaseous process fluids and plant areas. The system is designed to detect and - ' measure radiation conditions in the plant for personnel protection and to prevent releases in -

excess of allowable limits..,

The process and area radiation monitoring system provides a pressure boundary for interfacing

systems, providing containment pressure boundary integrity, an actuation of certain systems or

components in response to detected radiation conditions, and RG 1.97 safety-related -'

indications. The process and area radiation monitoring system also contains environmental

qualification equipment and supports station blackout.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-27, the applicant identified the following -process and area radiation

monitoring system component types that are within the scope of license renewal and subject to

an AMR: bolting; pipe; tubing; and valves: a .

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2.3A.3.28.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.28 and Millstone FSAR Section 7.5.6. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staff's review of LRA Section 2.3.3.28 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In particular, LRA Section 2.3.3.28 states that this system is within the scope of license renewal

because it meets the requirements of 10 CFR 54.4(a)(1) by providing "actuation of certain

systems or components in response to detected radiation conditions." In order to perform this

function, a section of piping connecting the radiation detectors to the system being monitored is

required to serve as a pressure boundary. This section of piping was not shown on license

renewal drawings for the process area and radiation monitoring systems as being within the

scope of license renewal. In RAI 2.3.3.28-1A, dated June 9, 2004, the staff requested the

applicant to explain how the system-level intended function is performed without this section of

piping included within the scope of license renewal and subject to an AMR in accordance with

the requirements of 10 CFR 54.4(a) and 10 CFR 54.21(a)(1).

In its response, dated July 26, 2004, the applicant stated that this specific section of piping and

components was omitted from inclusion within the scope of license renewal. The applicant

stated that these components support the radiation monitor actuation function to secure

containment purge flow in the event of a fuel handling accident within the containment and,

therefore, are within the scope of license renewal. The applicant stated that it updated the

process and area radiation monitoring system screening results and AMR results to include the

additional component types.

The staff did not find the applicant's response to RAI 2.3.3.28-1A adequate because the

updated LRA Table 2.3.3.27, including additional in-scope component types, was not provided

in the July 26, 2004, RAI response for the staff to review. Therefore, during a teleconference

between the staff and the applicant on November 1, 2004, the staff requested that the applicant

provide the updated Table 2.3.3.27 with the information related to the added components in

response to RAI 2.3.3.28-1 A.

In its response dated December 3, 2004, the applicant stated that the necessary additions to

the LRA table were included in a supplement to the application dated July 7, 2004, that included

additions to Table 3.3.2-27. The added component types were the fan/blower housing, filter

housings, and radiation detectors, with a pressure boundary intended function.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.28-1A acceptable

because (1) the applicant agreed that the specific section of piping connecting the radiation

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detectors to the system being monitored, with its associated components, supports the radiation

monitor actuation function to secure containment purge flow within the containment in the event

of a fuel handling accident, and is within the scope of license renewal; and (2) the applicant

adequately ideritified the'component types that were added to the LRA table in accordance with

the requirements of 10 CFR 54.4(a) and 10 CFR 54.21(a)(1). Therefore, the staff's concern

described in RAI 2.3.3.28-1A is resolved.

2.3A.3.28.3 Conclusion

The staff reviewed the LRA; the accompanying scoping boundary drawings, and the RAI

response'described above to determine whether any'SSCs that should be within the scope of

license renewal were not identified by the applicant. No omission's were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the process and area radiation rohnitoning system components that are within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the'process and area radiation'm1nitoring system components that are subject to an

AMR, as required by 10 CFR 54.21(a)(1).

2.3A.3.29 Radwaste Area Ventilation System

2.3A.3.29.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.29, the applicant described the radwaste area ventilation system. The

radwaste area ventilation system provides a suitable environment for equipment and fresh air

ventilation for personnel within the potentially radioactive areas of the auxiliary building. These.

areas are maintained at a slightly negative pressure and air flow is maintained in the direction of

areas with potentially higher radioactivity. The system contains fire dampers to prevent the

spread of a fire.

The radwaste area ventilation'system isolates'norm'al ventilation from the engineered safety

features pump rooms on an enclosure building filtration system actuation signal. The radwaste

area ventilation system also contains environmental qualification equipment and supports fire

protection. -

Intended functions within the scope of license renewal include the following:,

* provides a rated fire barrier to confine or retard a fire frdfm' spreading to or from'adjacent

areas of the plant

* provides a pressure boundary

In LRA Table 2.3.3-28, the applicant identified the following radwaste ar6ea ventilation system

component types that are within the scope of license renewal and subject to an AMR: damper

housings; ductwork; and ductwork joint seals. .'

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2.3A.3.29.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.29 and Millstone FSAR Section 9.9.5. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.3.29.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the radwaste area ventilation system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

radwaste area ventilation system components that are subject to an AMR, as required by

10 CFR 54.21 (a)(1).

2.3A.3.30 Turbine Building Ventilation System

2.3A.3.30.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.30, the applicant described the turbine building ventilation system. The

turbine building ventilation system provides a suitable environment for the equipment and

personnel within the turbine building. The turbine building ventilation system contains fire

dampers to prevent the spread of fire.

The turbine building ventilation system provides an automatic trip of the steam-driven auxiliary

feedwater pump room exhaust fan in the event of a steam line break in the room. The turbine

building ventilation system also supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a pressure boundary

In LRA Table 2.3.3-29, the applicant identified the following turbine building ventilation system

component type that is within the scope of license renewal and subject to an AMR: damper

housings.

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2.3A.3.30.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.30 and Millstone FSAR Section 9.9.12. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review,-the staff evaluated the system functions described in the LRA and -

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit fromrthe scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3A.3.30.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the turbine building ventilation system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

turbine building ventilation system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3A.3.31. Vital Switchgear Ventilation System

2.3A.3.31.1 Summary of Technical !nformation in the Application

In LRA Section 2.3.3.31, the applicant described the vital switchgear ventilation system. The

vital switchgear ventilation system functions to maintain a suitable environment for safetyrelated equipment during normal operation, loss of offsite power, and post-accident conditions.

This system consists of independent subsystems, each capable of removing 100 percent of the

heat generated in the' associated vital electrical equipment room. The east and west vital DC

switchgear rooms are provided with closed-cycle air subsystems utilizing mechanical

refrigeration to maintain the ambient conditions within these areas. The motor control center

(MCC) B51 and B61 enclosures are provided with self-contained air conditioning units. The

4160V switchgear rooms and east and west 480V switchgear rooms are cooled by water-to-air

cooling units. The vital switchgear ventilatio'n systenm contains fire dampers to prevent the

spread of a fire. - ;

The vital switchgear ventilation system provides cooling to maintain a suitable environment for

the operation of safety-reiated electrical equipment. The vital switchgear ventilation system also

contains environmental qualification equipmerht and supports station blackout and fire.

protection.

Intended functions within the scope of license renewal include the following:

provides a rated fire'barier to confine or retard a fire from spreading to or from adjacent

areas of the plant

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* provides a pressure boundary

* provides for heat transfer

In LRA Table 2.3.3-30, the applicant identified the following vital switchgear ventilation system component types that are within the scope of license renewal and subject to an AMR: damper housings; DC switchgear (SWGR) air conditioning unit cooling coils; DC SWGR air conditioning unit housings; ductwork; ductwork joint seals; fan/blower housings; MCC air conditioning units; | pipe; tubing; valves; vital SWGR cooling unit coils; vital SWGR cooling unit housings; west 480V LCR cooling unit coils; and west 480V LCR cooling unit housings.

2.3A.3.31.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.31 and Millstone FSAR Section 9.7.2, 9.9.15 and 9.9.17. The staffs review, using the evaluation methodology described in Section 2.3 of this SER, was conducted in accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then reviewed the LRA to verify that passive or long-lived components were not omitted from being subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.3.31.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of license renewal were not identified by the applicant. No omissions were identified. In addition, the staff performed a review to determine whether any components that should be subject to an AMR were not identified by the applicant. No omissions were identified. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the vital switchgear ventilation system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the vital switchgear ventilation system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.32 Unit 2 Fire Protection System

2.3A.3.32.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.32, the applicant described the fire protection system. The MPS fire protection system is a shared system that provides intended functions for both Millstone Unit 2 and Millstone Unit 3. This section addresses those portions of the fire protection system that

are specifically designated as Unit 2 components. Since this is a shared system, this section is duplicated in the Millstone Unit 3 license renewal application.

The Unit 2 fire protection system provides containment pressure boundary integrity. The fire protection system also provides fire detection and suppression capability to protect safe shutdown or safety-related equipment, provides oil collection for the prevention of an oil fire

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around the reactor coolant pumps, supports station blackout, provides emergency lighting, and

provides backup cooling water to the emergency diesel generators in response to a fire event.

Intended functions within the scope of license renewal include the following:

* provides enclosure, shelter, or protection for in-scope equipment (including radiation

shielding and pipe whip restraint) *A,

* provides a pressure boundary

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant -

* restricts flow -

* provides a spray pattern

In LRA Table 2.3.3-31, the applicant provided the screening results for the fire protection

system components, identifying those components that require aging management review.

Similarly, LRA Table 2.4.2-25 provides the screening results for the miscellaneous structural

commodities. Table 2.4.2-25 includes fire barrier penetration seals and fire doors.

In LRA Table 2.3.3.31; the applicant identified the following fire protection system component

types that are within the scope of license renewal and subject to an AMR: drip pans; fire

hydrants; flame arrestors; flex connections; flow indicators; flow orifices; nozzles; pipe; pumps;

RCP oil collection tanks; retard chambers; sprinkler heads; strainers; tubing; valves; and water*

motor gongs.

2.3A.3.32.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.32 and Millstone FSAR Section 9.10.The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the.

applicant did not omit from the scope of license renewal any components with intendedfunctions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.3.32 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The staff

noted that virtually all fire protection subsystems, including those protecting NSR areas, were

identified on the fire protection system piping and instrumentation diagrams as being within

scope of license renewal. However, systems for Warehouse #9, the craft assembly building and

the maintenance shop were indicated as not being within the scope of license renewal.

In RAI 2.3.3.32-2, the staff requested an explanation for why these structures were excluded

from the scope of license renewal. In its response dated November 9, 2004, the applicant

stated that the excluded systems are not part of the plant fire protection licensing basis. The

staff finds the applicant's response to RAI 2.3.3.32-2 acceptable because protection of these

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areas is not required by regulation. Therefore, the staffs concern described in RAI 2.3.3.32-2 is

resolved.

Drawing 25203-LR2601 1, sheet 1 of 6, shows an automatic suppression system for STG

governor housing and oil lines identified as a preaction type system, but does not show an air

supply for system monitoring. The suppression system is indicated as being within the scope of

license renewal. In RAI 2.3.3.32-3 the NRC requested that the applicant explain the omission of

the air supply for this system from the scope of license renewal. (The air supply to other inscope preaction suppression systems are included within scope of license renewal.)

In its response, dated November 9, 2004, the applicant stated that this preaction suppression

system is not an air supervised system. Based on its review, the staff finds the applicant's

response to RAI 2.3.3.32-3 is acceptable, because air supervision of this suppression system is

not required by regulation. Therefore, the staff's concern described in RAI 2.3.3.32-3 is

resolved.

In RAI 2.3.3.32-4, the NRC requested information on the applicant's program to ensure

continued access to an adequate supply of Halon for the extended life of the plant and/or plans

to convert or replace the systems when a supply is no longer available.

In its response dated November 9, 2004, the applicant noted that there is no established

program credited for license renewal to ensure the continued access to an adequate supply of

Halon for the gaseous suppression systems. The applicant noted that in the event that the

supply of Halon becomes inadequate during the period of extended operation, appropriate

actions would be initiated to maintain compliance with the fire protection licensing basis. Based

on its review, the staff finds the applicant's response to RAI 2.3.3.324 is acceptable, because

an established program to address a possible inadequate supply of Halon is not required by

NRC regulation. The staff recommends that the applicant make provisions to ensure continuous

protection for areas protected by Halon extinguishing systems. However, this issue is

considered closed with respect to the license renewal application.

2.3A.3.32.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the MPS fire protection system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the MPS fire

protection system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

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2.3A.3.33 Unit 3 Fire Protection System

2.3A.3.33.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.33, the applicant described the' Unit 3 fire pr'otection system. The MPS fire'

protection system is a shared system that provides intended functions for both Millstone Unit 2

and Millstone Unit 3. This section addresses those portions of the fire protection system that

are specifically designated as Unit 3 components; Since this is a shared system, this section is

duplicated in the Millstone Unit 2 license renewal application.

The Unit 3 fire protection system provides containment pressure boundary integrity, RG 1.97

safety-related indications, and pressure relief for tornado protection in the cable spreading area.

The Unit 3 fire protection system also provides fire detection and suppression capability to

protect safe shutdown or safety-related equipment, provides oil collection for the prevention of

an oil fire around the RCPs, supports station blackout, and contains environmental qualification

components.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides for heat transfer

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides enclosure, shelter, or protection for in-scope equipment (including radiation

shielding and pipe whip' restraint).

** provides filtration

* provides a spray pattern

* restricts flow

* provides for vortex suppression

In LRA Table 2.3.3-32, the applicant provided'the' screening results for Unit 3 fire protection

system components (shared with Unit 2), identifying those components that require an AMR.

Similarly, LRA Table 2.4.2-8 provides the screening results for the Unit 3 fire pump house.

In LRA Table 2.3.3-32, the'applicant identified the following Unit 3 fire protection system

component types that are within the sc6pe of license renewal and subject to an AMR: C02

storage tank; C02 tank cooling coils; coolant heat exchanger; damper housings; diesel fuel

storage tank; drip pans; ductwork; exhaust silencer, expansion tank overflow container,

fan/blower housings; filter/strainers; fire hydrants; fire protection RCP oil collection tanks; fire

water storage tank; flame arrestors; flex connecti6ns; flexible hoses;flbw switches; heater unit;'

hydropneumatic tank; instrument snubbers; level indicators; lube oil; nozzles; odorizers; oil mist

recovery unit; 'oil reservoirs, pipe; pumps; restricting orifices; sprinkler heads,'tubing; vacuum

limiter; valves; vortex breaker,assembly; water cooled exhaust maniifold;.water mianifold; pipe;

and valves.

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2.3A.3.33.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.33 and Millstone FSAR Section 9.10. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.3.33 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

The staff noted that while, in general, wall hydrants are included within scope of license

renewal, the wall hydrant at elevation 24 feet 6 inches of the control building is not included

within scope according to piping and instrumentation diagram No. 25212-LR26946, sheet 4. In

RAI 2.3.3.33-1, the NRC requested the basis for not including this hydrant.

In its response, by letter dated November 9, 2004, the applicant noted that the wall hydrant in

question was installed recently and is not permanently connected to a water supply. According

to the applicant, the hydrant does not perform a license renewal function. Based on its review,

the staff finds the applicant's response to RAI 2.3.3.33-1 is acceptable, because no protection

function is claimed for the hydrant.

2.3A.3.33.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the Unit 3 fire protection

system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the Unit 3 fire protection

system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.34 Domestic Water System

2.3A.3.34.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.34, the applicant described the domestic water system. The purpose of

the domestic water system is to provide potable water for various uses. The domestic water

system is supplied by the public water system from the town of Waterford, CT.

The domestic water system provides control room envelope pressure-boundary integrity. The

domestic water system contains NSR components spatially oriented such that their failure could

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prevent the satisfactory accomplishment of a safety-related function associated with a safetyrelated SSC.

Intended functions within the scope of license renewal include the following:

* ;provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-33, the applicant identified the following domestic water system component

types that are within the scope of license renewal and subject to an AMR:,pipe; and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the domestic water system. In its December 3, 2004, RAI

response, the applicant identified the domestic water hot water tank component type that was

added to the scope of the domestic water system.

2.3A.3.34.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.34 and Millstone FSAR Section 9.12. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verifythat the

applicant did not omit from the scope of license renewal any components with intended -

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passiveor long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1). : -

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) withspatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

Unit 3 fire protection system is acceptable.

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2.3A.3.34.3 ConclusionCThe staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is,

reasonable assurance that the applicant has adequately identified the domestic water system

components that are within the scope of license renewal, as required by 10.CFR 54.4(a), and

that the applicant has adequately identified the domestic water system components that are

subject to an AMR, as required by 10 CFR 54.21 (a)(1).

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2.3A.3.35 Diesel Generator System

2.3A.3.35.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.35, the applicant described the diesel generator system. The purpose of

the diesel generator system is to provide a dependable onsite AC power source capable of

automatically starting and supplying the loads necessary to safely shut down the plant and

maintain it in a safe shutdown condition.

The diesel generator system provides a reliable source of emergency power for the required

loads. The diesel generator system contains NSR components that are spatially oriented such

that their failure could prevent the satisfactory accomplishment of a safety-related function

associated with a safety-related SSC. The diesel generator system supports station blackout

and fire protection.-

Intended functions within the scope of license renewal include the following:

* provides for heat transfer

* provides a pressure boundary

* provides filtration

* restricts flow

* provides limited structural integrity

In LRA Table 2.3.3-34, the applicant identified the following diesel generator system component

types that are within the scope of license renewal and subject to an AMR: after-filter housings;

air cooling heat exchangers; air intercoolers; air start distributors; expansion joints;

filter/strainers; flow orifices; governor hydraulic oil; jacket water expansion tanks; jacket water

heat exchangers; level indicators; lube oil heat exchangers; lube oil heaters; oil pans; pipe;

pumps; silencers; stand-by jacket coolant heaters; starting air tanks; tubing; turbochargers; and

valves.

2.3A.3.35.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.35 and Millstone FSAR Section 8.3. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.3.35 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that a license renewal drawing for the diesel generator system

shows that the governors are not subject to an AMR. Although the governor itself is an active

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component, its housing serves a pressure boundary intended function. The governor housing

was not, however, listed in LRA Tables 2.3.3-34.or,3.3.2-34 as a component within the scope of

license renewal. In RAI 2.3.3.35-1A, dated June 9, 2004, the staff requested the applicant to

explain the apparent exclusion of the diesel generator governor from the scope of license:-

renewal and from being subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that, consistent with the industry

guideline for implementing the requirements of 10 CFR 54 (NEI 95-10), the emergency diesel

generators are-considered active and do not meet the criteria of 10 CER 54.21(a)(1)(i).

Additionally, the emergency diesel generator.is considered a "complex assembly." The

governor actuator unit shown in the license renewal drawing is a component of the "complex

assembly." Thus, the applicant concluded that the governor actuator, including the housing,

falls within the scope of license renewal, but does not require an AMR since the governor is

considered an active component.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.35-1A acceptable,

because the staff agrees that the governors and their sub-components are 'complex

assemblies" and, although they meet the requirements of 10 CFR 54.4(a), they do not require

an AMR in accordance with 10 CFR 54.21(a)(1). Therefore, the staffs concern set forth in RAI

2.3.3.35-1A is resolved.

The staff also noted that a license renewal drawing for the diesel generator system shows level

glasses and sight glasses as being subject to an AMR. However, these components are not

listed in LRA Table 2.3.3-34. These components provide a pressure boundary intended!

function. In RAI 2.3.3.35-2A, dated June 9, 2004, the staff requested the applicant to confirm

that level glasses and sight glasses are included with the components listed in LRA Table 2.3.3-

34..- - .- :

In its response, dated July 26, 2004, the applicant stated that the subject level glasses and

sight glasses shown on license renewal drawings for the diesel generator system are within the,

scope of license renewal and included in the component type, "Level Indicators," in LRA Table

2.3.3-34. Additionally, the applicant described the documentation used to describe the aging

effects of glass and that no aging management for glass is required.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.35-2A acceptable. The

applicant states that level glasses and sight glasses were considered part of the component

type, "Level Indicators," in LRA Table 2.3.3-34. Further, the applicant describes the method for

evaluating the aging effects of glass and its aging management. Although glass is passive and

long-lived, it has no aging effects and is subject to an AMR in accordance with

10 CFR 54.21 (a)(1). The staffs concern described in RAI 2.3.3.35-2A is resolved.

A license renewal drawing for the diesel generator system has unidentified components that are

shown to be subject to an AMR. As such, the staff was not able to confirm whether LRA Table

2.3.3-34 is complete. In RAI 2.3.3.35-3A, 'dated Junie 9, 2004, the staff requested the applicant

to define the unidentified components and t'd in'dicate where they are listed in Table 2.3.3-34.

In its response, dated July 26, 2004, the applicant stated that the urnidentified components are

the in-line pilot air filters in the diesel air start system. The applicant further stated that they are

included in the component type, "Filter/strainers," in LRA Table 2.3.3-34 Diesel Generator.

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Based on its review, the staff finds the applicant's response to RAI 2.3.3.35-3A acceptable,

because the air filters were identified. The staff concludes that the air filters were scoped in

accordance with the requirements of 10 CFR 54.4(a) and screened in accordance with the

requirements of 10 CFR 54.21 (a)(1). Therefore, the staffs concern described in RAI

2.3.3.35-1A is resolved.

2.3A.3.35.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the diesel generator system components that are within the scope of license renewal, as

required by 10 CFJR 54.4(a), and that the applicant has adequately identified the diesel

generator system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.36 Diesel Generator Fuel Oil System

2.3A.3.36.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.36, the applicant described the diesel generator fuel oil system. The diesel

generator fuel oil system provides fuel oil to the diesel engine cylinders. The diesel generator

fuel oil system includes fuel oil tanks, transfer pumps, strainers, piping, and valves.

The diesel generator fuel oil system provides adequate fuel oil to support the safety function of

the diesel generators. The diesel generator fuel oil system contains an NSR fuel oil storage

tank and transfer system and contains NSR components that are spatially oriented such that

their failure could prevent the satisfactory accomplishment of a safety-related function

associated with a safety-related SSC. The diesel generator fuel oil system supports station

blackout and fire protection.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

* provides filtration

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.3.3-35, the applicant identified the following diesel generator fuel oil system

component types that are within the scope of license renewal and subject to an AMR: clean oil

storage tanks; diesel fuel oil storage tank; diesel oil supply tanks; filter/strainers; flame

arrestors; level indicators; pipe; pumps; tubing; and valves.

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2.3A.3.36.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.36 and Millstone FSAR Section 8.3. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with ,the requirements of.10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.3.36 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

During its review, the staff noted that a license renewal drawing shows flexible hoses that are

within the diesel generator fuel oil system to be within the scope of license renewal and subject

to an AMR. However, flexible hose was not included in LRA Table 2.3.3-35. In RAI 2.3.3.36-1A,

dated June 9, 2004. The staff requested the applicant to explain whether flexible hoses were

included with anrother component type or to explain their exclusion:.

In its response, dated July 26, 2004, the applicant stated that flexible hoses are within the"

scope of license renewal, but have been determined to be short-lived components. As

described in LRA Section 2.1.5.1, short-lived co mponents are shown on the license renewal'

drawings. However, these sh6rt-lived compoine'nts'are not subject to an AMR and are not'

included in the screening results tables provided in Section 2 of the LRA. The applicant further

stated that modified preventive maintenance program procedures will require the periodic

replacement of the flexible hoses based on a specified time frequency.

The staff finds the applicant's response to RAI 2.3.3.36-1A acceptable, because the flexible

hoses will be replaced by preventive maintenance program procedures that have been modified

such that the replacement is performed at asOecified timejfrequency. Therefore; the flexible

hoses in the diesel generator fuel oil system have been adequately evaluated in accdrdance

* with the criterion of 10 CFR 54.21(a)(1)(ii). The staffs concern described in RAI 2.3.3.36-1A is

resolved. -

2.3A.3.36.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No' onmissions were identified. On the basis of its review, the

staff concludes that there is reasonable a`ssiurance'that the applicant has adequately 'identified

the diesel generator fuel oil system components that are within the scope of license renewal, as

required by 10'CFR 54.4(a); and that the applicant has adequately identified the diesel

generator fuel oil system components that 're suibject to an AMR, as required by

10 CFR 54.21 (a)(1). ' -

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s2.3A.3.37 Station Blackout Diesel Generator System

2.3A.3.37.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.37, the applicant described the station blackout (SBO) diesel generator

system. The MPS SBO diesel generator system is a shared system that provides intended

functions for both Millstone Unit 2 and Millstone Unit 3. Since this is a shared system, this

section is duplicated in the Millstone Unit 3 license renewal application.

The S60 diesel generator system supports SBO and fire protection.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides filtration

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* restricts flow

In LRA Table 2.3.3-36, the applicant identified the following SBO diesel generator system

component types that are within the scope of license renewal and subject to an AMR:

aftercoolers; air receivers; aspirators; expansion joints; expansion tanks; filterlstrainers; flame

arrestors; flow indicators; fuel heaters; fuel oil day tanks; fuel oil storage tanks; immersion

heaters; injectors; lube oil coolers; lubricators; oil sumps; pipe; pulsation dampeners; pumps;

radiators; restricting orifices; silencers; tubing; turbo chargers; and valves.

2.3A.3.37.2 Staff Evaluation

The Millstone SBO diesel generator system is a shared system that provides intended functions

for both Millstone Unit 2 and Millstone Unit 3. The staff reviewed LRA Section 2.3.3.37,

Millstone Unit 2 FSAR Section 1.2.9, and Millstone Unit 3 FSAR Section 8.3.1. The staff's

review, using the' evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR54.21(a)(1).

The staff's review of LRA Section 2.3.3.37 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that a license renewal drawing for the station SBO generator

system shows a 28-inch exhaust rain cap to be subject to an AMR. The rain cap appears to

provide a pressure boundary. Unit 2 LRA Table 2.3.3-36 and Unit 3 LRA Table 2.3.3-41 do not

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list rain cap as a component type requiring an AMR. In RAI 2.3.3.37-1A, dated June 9, 2004,

the staff requested the applicant to explain whether the rain cap was included with another

component type or to explain its exclusion from the scope of license renewal.

In its response dated July 26, 2004, the applicant stated that the subject rain cap, shown on the

SBO diesel generator system license renewal drawing, is an integral part of the exhaust,

silencer. The exhaust silencer with the integral rain cap is within the scope of license renewal

and included in the component type, "Silencers," in Unit 2 LRA Table 2.3.3-36 and Unit 3 LRA

Table 2.3.3-41.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.37-1A acceptable,

because the rain cap was identified. The staff concludes that the rain cap was scoped in

accordance with the requirements of 10 CFR 54.4(a) and screened in accordance with the

requirements of 10 CFR 54.21 (a)(1). Therefore, the staff's concern described in RAI

2.3.3.37-1A is resolved.

The Millstone Unit 3 FSAR states that all safety-related lines or valves, which are subject to

freezing, are electrically heat-traced and insulated. A license renewal drawing for the SBO fuel

oil system shows a line going from the fuel oil storage tank to the fuel oil day tank that is within

the scope of license renewal. It appears that the line in question is insulated. Thermal insulation

is not listed as within the scope of license renewal and subject to an AMR for any Unit 2 or Unit

3 systems, nor is it discussed in the Unit 2 or Unit 3 LRA. In RAI 2.3.3.37-2A, dated June 9,

2004, the staff requested the applicant to explain the apparent exclusion of pipe insulation from

the scope of license renewal.

In its response dated July 26, 2004, the applicant stated that the subject fuel line is heat-traced

and thermally insulated. This insulation does not perform an intended function since the

effectiveness of the heat trace system on the fuel temperatures in the subject fuel line and fuel

tank is monitored. In the event of low fuel temperatures, a heat-trace trouble alarm is activated

in the control room. Insulation-related problems would be rapidly identified and repaired.:

Therefore, the applicant concluded that the thermal insulation is not within the scope of license.

renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.37-2A acceptable - based on operator actions to respond to a heat-trace trouble alarm and initiate the subsequent

corrective actions. The ability of the system's temperature monitoring instrumentation to localize

a low temperature along the length of the piping would allow differentiation between thermal'

insulation or heat-trace circuit problems. Therefore; the cause of the trouble alarm would be

localized such that identification and appropriate repair would be made before loss of systemlevel intended function would occur. Therefore, the staffs concern described in RAI 2.3.3.37-2A

is resolved.

2.3A.3.37.3 Conclusion

The staff reviewed the LRA and the accompanying scoping boundary drawings, and RAI

response described above to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

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identified the SBO diesel generator system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the SBO diesel generator system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.38 Security System

2.3A.3.38.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.38, the applicant described the security system. The Millstone security system is a shared system that provides intended functions for both Millstone Unit 2 and Millstone Unit 3. Since this is a shared system, this section is duplicated in the Millstone Unit 3 license renewal application.

The security system provides yard lighting, and backup electrical power for yard lighting, in support of fire protection.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary * provides filtration

In LRA Table 2.3.3-37, the applicant identified the following security system component types that are within the scope of license renewal and subject to an AMR: coolers; diesel fuel oil storage tank; fan/blower housings; filter/strainers; heaters; oil pans; pipe; pumps; radiators; tubing; and valves.

2.3A.3.38.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.38. The staffs review, using the evaluation methodology described in Section 2.3 of this SER, was conducted in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then reviewed the LRA to verify that passive or long-lived components were not omitted from being subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.3.38.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of license renewal were not identified by the applicant. No omissions were identified. In addition, the staff performed a review to determine whether any components that should be subject to an AMR were not identified by the applicant. No omissions were identified. On the basis of its' review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the security system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the security system components that are subject to an AMR, as required by 1 0 CFR 54.21 (a)(1).

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2.3A.3.39 Clean Liquid Waste Processing 'System

2.3A.3.39.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.39, the applicant described the clean liquid waste processing system. The

clean liquid waste processing system collects, stores,- processes, recycles, and disposes of

liquid radioactive waste. -

The clean liquid waste processing system provides pressure boundary integrity and isolation for

the containment and interfacing safety-related systems, and RG 1.97 safety-related indications.

The clean liquid waste processing system contains NSR components spatially oriented such

that their failure could prevent the satisfactory accomplishment of a safety-related function of a

safety-related SSC. The clean liquid waste processing system also contains environmental

qualification components.

Intended functions within the scope of license renewal include the following:

* 'provides a pressure boundary

* provides limited structural integrity

In LRA Table 2.3.3-38, the applicant identified the following clean liquid waste processing

system component types that are within the scope of license renewal and subject to an AMR:

degasifier after cooler; degasifier effluent cooler; degasifier preheater; flow elements; primary

drain tank and quench tank cooler; pipe; primary drain tank; pumps; strainers; tubing; and

valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant,

expanded the system boundaries for the clean liquid waste processing system. In its December

3, 2004, RAI response, the applicant identified the following component types that were added

to the scope of the clean liquid waste processing system:

*- - conductivity element .

* degasifiers : -

* degasifier vent condenser -

* equipment drain sump tank -

* flexible hose- - -

* flow indicator . ;

2.3A.3.39.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.39 and Millstone FSAR Section 11.1.3.- The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.-

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with10 CFR 54.21(a)(1). - - -

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The staff's review of LRA Section 2.3.3.39 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAI as discussed below.

In its review, the staff noted that a license renewal drawing for the clean liquid waste processing

system shows that the license renewal system boundary extends to another drawing that was

not provided in the LRA. The piping at this location is shown to extend to the pre-degasifier

filter. Degasifier components are listed in LRA Table 2.3.3-38 as being within the scope of

license renewal and subject to an AMR. In order for the staff to complete its review, more

information was necessary to ensure that all the components performing the system-level

intended functions were included within the scope of license renewal. In RAI 2.3.3.39-1A, dated

June 9, 2004, the staff requested the applicant to supply the drawing that contains the

remainder of the clean liquid waste processing system.

In its response, dated July 26, 2004, the applicant stated that the license renewal boundary of

the clean liquid waste processing system does not extend to other drawings. The highlighted

portion of the clean liquid waste processing system piping stops at a AT" junction before leaving

its license renewal drawing. The applicant further stated that this is consistent with the drawing

highlighting convention described in LRA Section 2.1.5.1 for identifying components for

inclusion within the scope of license renewal for 10 CFR 54.4(a)(2). The "P junction is an

identifiable component on the drawing that is known to be outside the area of concern for

spatially oriented NSR components near safety-related components.

!

The staff finds the applicant's response to RAI 2.3.3.39-1A acceptable, because the applicant

verified that all the components within the license renewal system evaluation boundary for the

clean liquid waste processing system have been shown on its license renewal drawing. The

staff concludes that all components of the clean liquid waste processing system were scoped in

accordance with the requirements of 10 CFR 54.4(a) and screened in accordance with the

requirements of 10 CFR 54.21 (a)(1). Therefore, the staff's concern described in RAI

2.3.3.39-1A is resolved.

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

clean liquid waste processing system is acceptable.

2.3A.3.39.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the clean liquid waste processing system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

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clean liquid waste processing system components that are subject to an AMR, as required by

10 CFR 54.21 (a)(1).

2.3A.3.40 Gaseous Waste Processing System

2.3A.3.40.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.40, the applicant described the gaseous waste processing system. The

gaseous waste processing system processes and controls the release of potentially radioactive

waste gases.

The gaseous waste processing system provides pressure boundary integrity and isolation for

the containment and interfacing safety-related systems, and provides RG 1.97 safety-related

indications. The gaseous waste processing system also contains environmental qualification

components.

Intended functions within the scope of license renewal include providing a pressure boundary.

In LRA Table 2.3.3-39, the applicant identified the following gaseous waste processing system

component types that are within the scope of license renewal and subject to an AMR:

aftercoolers; pipe; valves; and waste gas compressor seal coolers.

2.3A.3.40.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.40 and Millstone FSAR Section 11.1.4. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and -

Millstone FSAR in accordance with the' requirements'of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject toan AMR in accordance with 10 CFR,54.21(a)(1). * r . i;, or2.3A.3.40.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,-

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the gaseous waste processing system components that are'within' the scope of

license renewal, as required by 10 CFR.54.4(a), and that the applicant has adequately

identified the gaseous waste processing system components that are subject to an AMR, as

required by 10 CFR 54.21(a)(1). ' '-''

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- hAA

23A.3.41 Post-Accident Sampling System

2.3A.3.41.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.41, the applicant described the post-accident sampling system. The post- accident sampling system is designed to obtain samples of the reactor coolant, the containment

sump fluid, and the containment atmosphere under accident conditions.

The post-accident sampling system provides the capability to obtain a post-accident sample of

the containment atmosphere and the primary coolant. The post-accident sampling system contains NSR components essential for the operation of the system and components that are

spatially oriented such that their failure could prevent the satisfactory accomplishment of a

safety-related function of a safety-related SSC.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides limited structural integrity

* provides filtration

In LRA Table 2.3.3-40, the applicant identified the following post-accident sampling system component types that are within the scope of license renewal and subject to an AMR:

accumulators; bolting; filter/strainers; flow elements; pumps; reservoir; sample chambers;

tubing; and valves.

2.3A.3.41.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.41 and Millstone FSAR Section 9.6.2. The staff's review, using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.3.41 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAI as discussed below.

In its review, the staff noted that a license renewal drawing for the post-accident sampling

system shows pH probes, nitrogen gas bottles, nitrogen gas flasks, and other unidentified

components shown as being within the scope of license renewal and subject to an AMR. The

components do not appear as component types in LRA Table 2.3.3-40. Therefore the staff was

not able to ensure that LRA Table 2.3.3-40 is complete. In RAI 2.3.3.41-1A, dated June 9,

2004, the staff requested the applicant to define where these components are included in LRA

Table.

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In its response, dated July 26, 2004, the applicant supplied a table that defined each of the

unidentified components and stated where each was represented in the component types on

LRA Table 2.3.3-40. The applicant further stated that the some of the components are

penetration points and are included in the commodity group, "Panels and Cabinets," in LRA

Table 2A.2-25. Additionally, the gas bottle has been determined to be a short-lived component.

The staff finds the applicant's response to RAI 2.3.3.41-1A acceptable, because the

unidentified components were adequately identified and shown where they appeared in LRA

tables for screening results as applicable. The staff concludes that the post-accident sampling

system components in question were scoped in accordance with the requirements of

10 CFR 54.4(a) and screened in accordance with the requirements of 10 CFR 54.21(a)(1).'

Therefore, the staff's concern described in RAI 2.3.3.41-1A is resolved.

Another license renewal drawing for the post-accident sampling system depicts temperature r

measuring components. Sensing devices connected to these instruments denote either a

thermowell or a resistance bulb and head suitable for use with a secondary instrument,

indicating that the instruments form part of the pressure boundary for the post-accident,

sampling system. In RAI 2.3.3.41-2A, dated June 9, 2004, the staff requested the applicant to

explain the apparent exclusion of the pressure retaining components from the scope of license

renewal and from being subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that one type of temperature

measuring components in question is a surface-mounted temperature detector that does not

penetrate the system pressure boundary and is therefore not within the scope of license

renewal. However, another type of temperature measuring component is installed in a tubing**

tee-fitting which does provide a pressure boundary function and is therefore within the scope of

license renewal. The applicant further stated that tubing fittings are represented by the

component type, "Tubing," in LRA Table 2.3.3-40.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.41-2A acceptable,

because the applicant adequately identified the types of temperature measuring components in

the post-accident sampling system and specified how they were represented in LRA Table

2.3.3-40. The staff concludes that the post-accident sampling system temperature measuring

components were scoped in accordance with the requirements of 1 0 CFR 54.4(a) and screened

in accordance with the requirements of 10 CFR 54.21(a)(1). Therefore, the staff's concern

described in RAI 2.3.3.41-2A is resolved.

2.3A.3.41.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings; and RAI responses

described above to determine whether any.SSCs that should be within the'scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the post-accident sampling system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the post-accident

sampling system components that are subject to an AMR, as required by 1 0 CFR 54.21 (a)(1).

2-1 03
2.3A.3.42 Station Sumps and Drains System

2.3A.3.42.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.42, the applicant described the station sumps and drains system. The

station sumps and drains system removes wastewater from various buildings and locations via

floor drains, drain headers, and sump tanks. The system collects both radioactive and nonradioactive waste water and discharges directly to either the liquid waste system or to the yard

drainage system.

The station sumps and drains system provides containment pressure boundary integrity,

isolation between the emergency diesel generator rooms, and RG 1.97 safety-related

indications. The station sumps and drains system provides both flood protection for safetyrelated areas and provides loop seals to maintain ventilation zone separation. The system also

contains NSR components spatially oriented such that their failure could prevent the

satisfactory accomplishment of a safety-related function of a safety-related SSC. The station

sumps and drains system contains environmental qualification components.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

* provides a protective barrier for intemal/extemal flooding events

In LRA Table 2.3.341, the applicant identified the following station sumps and drains system

component types that are within the scope of license renewal and subject to an AMR: pipe;

pumps; tubing; and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the station sumps and drains system. In its December 3,

2004, RAI response, the applicant identified the following component types that were added to

the scope of the station sumps and drains system:

* collection section tank

* flow indicators

* filter

2.3A.3.42.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.42. The staffs review, using the evaluation methodology

described in Section 2.3 of this SER, was conducted in accordance with the guidance described

in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

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- -

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November.9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3;-2004, response acceptable, because the applicant adequately included NSR-'

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with.

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004,' response related to the scoping and screening results of the

aerated liquid radwaste system is acceptable.

2.3A.3.42.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition,'the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the station sumps and drains

system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the station sumps and drains

system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.43 Aerated Liquid Radwaste System

2.3A.3.43.1 Summary of Technical Information in the Application

The aerated liquid radwaste system is an NSR system that was previously excluded from the

scope of license renewal. As a result of the revised scoping methodology set forth in the

applicant's November 9, 2004, RAI response, the applicant added portions of the aerated liquid

radwaste system that could spatially interact with safety-related SSCs. The applicant provided

descriptions of the systems that were added to the scope of license renewal in response to RAI

2.1-1 in its December 3, 2004, RAI response. i,

The applicant stated that the aerated liquid radwaste system provides controlled handling,

processing, monitoring, and disposal of low-level radioactive liquids that are collected by open

drains in the plant. It is a non-safety, low-energy'system that contains components that have

been identified to affect a function of a safety-related system due to the proximity of this system

to the safety-related system. Additional details of the aerated liquid radwaste system can be

found in FSAR Section 11.1.3. , a

In accordance with the revised scoping methodology, the applicant identified the following

component types for the aerated liquid radwaste system as being within the scope of license

renewal and subject to an AMR: . 't.r ;

* conductivity element

* flow elements

* flow indicators - * .

• .. pipe -'~; ;'''"'~ '

* pumps

* tubing

* valves

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'II

2.3A.3.43.2 Staff Evaluation

The staff reviewed the information that the applicant provided in the November 9, 2004,

response along with the clarifications added in the December 3, 2004, response for the aerated

liquid radwaste system using the evaluation methodology described in Section 2.3 of this SER.

The staff conducted its review in accordance with guidance described in SRP-LR Section 2.3.

In conducting its review, the staff evaluated the system functions for the aerated liquid radwaste

system in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did

not omit from the scope of license renewal any components with intended functions delineated

in 10 CFR 54.4(a). The staff then reviewed those components that the applicant identified as

being within the scope of license renewal to verify that the applicant did not omit any passive

and long-lived components that should be subject to an AMR in accordance with the

requirements of 10 CFR 54.21 (a)(1).

2.3A.3.43.3 Conclusion

Based on its review of the RAI responses, FSAR Section 11.1.3, and licensing basis

information, the staff did not identify any omissions or discrepancies in the applicant's scoping

and screening results for the components of the aerated liquid radwaste system. Therefore, the

staff concludes that the applicant adequately identified the aerated liquid radwaste system

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant adequately identified the aerated liquid radwaste system components that are

subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.44 Solid Waste Processing System

2.3A.3.44.1 Summary of Technical Information in the Application

The solid waste processing system is an NSR system that was previously excluded from the

scope of license renewal. As a result of the revised scoping methodology set forth in the

applicant's November 9, 2004, RAI response, the applicant added portions of the solid waste

processing system that could spatially interact with safety-related SSCs. The applicant provided

descriptions of the systems that were added to the scope of license renewal in response to RAI

2.1-1 in its December 3, 2004, RAI response.

In its December 3, 2004, RAI response, the applicant stated that the solid waste processing

system provides controlled handling, processing, monitoring, and packaging of radioactivespent resins, from demineralizers and ion exchangers, and radioactive filter cartridges

generated during plant operation. The system contains NSR components spatially oriented

such that their failure could prevent the satisfactory accomplishment of a safety-related function

of a safety-related SCC. Additional details of the solid waste processing system can be found in

FSAR Section 11.1.5.

In accordance with the revised scoping methodology, the applicant identified the following

component types for the solid waste processing system as being within the scope of license

renewal and subject to an AMR:

* flow indicators

2-106
* pipe

* pumps -

* spent resin fill head tank

* tubing

* valves

2.3A.3.44.2 Staff Evaluation

The staff reviewed the information that the applicant provided in its RAI responses-dated

November 9, 2004, and December 3, 2004, for the solid waste processing system using the

evaluation methodology described in Section 2.3 of this SER. The staff conducted its review in

accordance with the guidance described in SRP-LR Section 2.3.

In conducting its review, the staff evaluated the system functions for the solid waste processing

system in accordance with the requirements of 10 CFR 54.4(a), to verify that the applicant did

not omit from the scope of license renewal any components with intended functions delineated

in 10 CFR 54.4(a). The staff then reviewed those components that the applicant identified as

within the scope of license renewal to verify that the applicant did not omit any passive and

long-lived components that should be subject to an AMR in accordance with the requirements

of 10 CFR 54.21 (a)(1).

2.3A.3.44.3 Conclusion

Based on its review of the information that the applicant provided in the responses dated

November 9,12004, and December 3, 2004, FSAR Section 11.1.5, and licensing basis

information, the staff did not identify any omissions or discrepancies in the applicant's scoping

and screening results for the components of the solid waste processing system. Therefore, the'

staff concludes that the applicant adequately identified the solid waste processing system

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant adequately identified the solid waste processing system components that are

subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.3.45. Turbine Building Closed Cooling Water System

2.3A.3.45.1 Summary of Technical Information in the Application

The turbine building closed cooling water system (TBCCW) is an NSR system that was

previously excluded from the scope of license renewal. As a result of the revised scoping

methodology set forth in the applicant's November 9, 2004, RAI response, the applicant added

portions of the TBCCW that could spatially-interact with safety-related SSCs. The applicant

provided descriptions of the systems that were added to the scope of license' renewal in

response to RAI 2.1-1 in its December 3, 2004, RAI response. * ,,: ,, -;. ;

The applicant stated that the TBCCW system is a'closed-loop cooling water system that

transfers heat from NSR turbine plant components and sample coolers' to the SW system, via

the TBCCW heat exchangers. The system contains NSR components spatially oriented such

that their failure could prevent the satisfactory accomplishment of a safety-related function of a

safety-related SCC. Additional details of the TBCCW system can be found in FSAR Section

9.7.3.

2-107 ':
In accordance with the revised scoping methodology, the applicant in Attachment 1 identified

the following component types for the TBCCW system as being within the scope of license

renewal and subject to an AMR:

* chemical addition tank

* chiller condensers tubes

* exciter air coolers tubes

* flexible hoses

* flow elements

* flow indicators

* flow orifices

* pipe

* TBCCW pumps

* spent fuel pool area supplemental cooling heat exchangers tubes

* TBCCW heat exchangers channel heads

* TBCCW heat exchangers shell

* TBCCW heat exchangers tubes

* TBCCW heat exchangers tubesheet

* tubing

* valves

2.3A.3.45.2 Staff Evaluation

The staff reviewed the information that the applicant provided in the November 9, 2004, and

December 3, 2004, RAI responses for the TBCCW system using the evaluation methodology

described in Section 2.3 of this SER. The staff conducted its review in accordance with the

guidance described in SRP-LR Section 2.3.

In conducting its review, the staff evaluated the system functions for the TBCCW water system

in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit

from the scope of license renewal any components with intended functions delineated in

10 CFR 54.4(a). The staff then reviewed those components that the applicant identified as

being within the scope of license renewal to verify that the applicant did not omit any passive

and long-lived components that should be subject to an AMR in accordance with the

requirements of 10 CFR 54.21(a)(1).

2.3A.3.45.3 Conclusion

Based on its review of the information that the applicant provided in the responses dated

November 9, 2004, and December 3, 2004, FSAR Section 9.7.3, and licensing basis

information, the staff did not identify any omissions or discrepancies in the applicant's scoping

and screening results for the components of the TBCCW system. Therefore, the staff

concludes that the applicant adequately identified the TBCCW system components that are

within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant

adequately identified the TBCCW system components that are subject to an AMR, as required

by 10 CFR 54.21(a)(1).

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2.3A.3.46 Water Box Priming System t

2.3A.3.46.1 Summary of Technical Information in the Application

The water box priming system is an NSR system that was previously excluded from the scope

of license renewal; As a result of the revised scoping methodology set forth in the applicant's

November 9, 2004, RAI response, the applicant added portions of the water box priming system

that could spatially interact with safety-related SSCs. The applicant provided descriptions of the

systems that were added to the scope of license renewal in response to RAI 2.1-1 in its

December 3, 2004, RAI response.

The applicant stated that the water box priming system provides a vacuum source for priming

the condenser water boxes in order to keep the condenser tubes full of water. The system

contains NSR components spatially oriented such that their failure could prevent the

satisfactory accomplishment of a safety-related function of a safety-related SCC.

In accordance with the revised scoping methodology, the applicant identified the following

component types for the water box priming system as being within the scope of license renewal

and subject to an AMR:

* filters/strainers

* flow orifices

* flow switches

* pipe

* valves ,

2.3A.3.46.2 Staff Evaluation

The staff reviewed the information that the applicant provided in the November 9, 2004, and

December 3, 2004, RAI responses for the water box priming system using the evaluation

methodology described in Section 2.3 of this SER. The staff conducted its review in accordance

with the guidance described in SRP-LR Section 2.3.

In conducting its review, the staff evaluated the system functions described in the November 9,-

2004, RAI response, along with the clarifications added in the December 3, 2004, RAI response

for the water box priming system in accordance with the requirements of 10 CFR 54.4(a) to

verify that the applicant did not omit from the scope of license renewal any components with

intended functions delineated in 10 CFR 54.4(a). The staff then reviewed those components

that the applicant identified as being within the scope of license renewal to verify that the

applicant did not omit any passive and long-lived components that should be subject to an AMR

in accordance with the requirements of 10 CFR 54.21(a)(1).

2.3A.3.46.3 Conclusion -

During its review of the information that the applicant provided in the responses dated

November 9, 2004, and December 3, 2004, and licensing basis information; the staff did not

identify any omissions or discrepancies in the applicant's scoping and screening results for the

components of the water box priming system.-Therefore, the staff concludes that the applicant

adequately identified the water box priming system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant adequately identified the

2-109
water box priming system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3A.4 Steam and Power Conversion Systems

In LRA Section 2.3.4, the applicant identified the components of the steam and power

conversion systems that are subject to an AMR for license renewal.

The applicant described the supporting structures and components of the steam and power

conversion systems in the following sections of the LRA:

* 2.3.4.1 main steam system

* 2.3.4.2 extraction steam system

* 2.3.4.3 feedwater system

* 2.3.4.4 condensate system

* 2.3.4.5 condensate storage and transfer system

* 2.3.4.6 condensate demin mixed bed system

* 2.3.4.7 auxiliary feedwater system

* 2.3.4.8 feedwater heater vents and drains system

* 2.3.4.9 moisture separation and reheat system

* 2.3.4.10 plant heating and condensate recovery system

* 2.3.4.11 secondary chemical feed system

* 2.3.4.12 turbine gland sealing system

The corresponding subsections of this SER (2.3A.4.1 - 2.3A.4.12, respectively) present the

staff's related review findings.

2.3A.4.1 Main Steam System

2.3A.4.1.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.1, the applicant described the main steam system. The main steam

system transports steam from the steam generators to the turbine-generator. This system also

provides a means of controlled heat release from the nuclear steam supply system during

periods of station electrical load rejection or when the condenser is not available. The system

provides steam for various auxiliary services including the steam generator auxiliary feedwater

pump turbine, turbine gland sealing, and auxiliary steam.

The main steam system provides a steam flow path to remove heat from the reactor coolant

system (RCS), overpressure protection for the steam generators, steam to the steam generator

auxiliary feedwater pump turbine, isolation at system interfaces, containment pressure

boundary integrity, and RG 1.97 safety-related indications. The main steam system also

prevents uncontrolled blowdown of more than one steam generator following a main steam line

break (MSLB), limits the maximum steam flow rate from a faulted steam generator, and

provides steam generator isolation. The main steam system contains NSR components that are

spatially oriented such that their failure could prevent the satisfactory accomplishment of a

safety-related function associated with a safety-related SSC and NSR components credited for

mitigating a HELB outside containment. The system also provides environmental qualification

components and supports fire protection and station blackout.

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Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides limited structural integrity

* provides structural and/or functional support related to mechanical components

* provides filtration -

In LRA Table 2.3.4-1, the applicant identified the following main steam system component types

that are within the scope of license renewal and subject to an AMR: condensing pots;

expansion joints; flexible hoses; flow elements; flow orifices; moisture separators/reheaters;

pipe; quench tank heat exchangers; silencers; steam traps; strainers; tubing; turbine casings;

and valves. - '

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant'

expanded the system boundaries for the main steam system. In its December 3, 2004, RAI

response, the applicant identified the steam generator blowdown tank component typethat was'

added to the scope of the main steam system.

2.3A.4.1.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.1 and Millstone FSAR Sections 7.2.3, 7.5.6, 10.3, 10.4.5,'

10.4.6, and 14.0. The staffs review, using the evaluation methodology described in Section 2.3

of this SER, was conducted in accordance with the guidance described in Section 2.3 of

NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are' described in the'applicant's responses dated November 9, 2004,' and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable,' because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

main steam system is acceptable. .

2.3A.4.1.3 Conclusion '

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the -scope of license renewal were not identified by the applicant. No ' omissions were identified. In addition, the -staff pOerformed a review to determine whether any'

components that should be subject to an AMR were not identified by the'applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the main steam system

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

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that the applicant has adequately identified the main steam system components that are

subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.4.2 Extraction Steam System

2.3A.4.2.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.2, the applicant described the extraction steam system. The extraction

steam system provides steam from the main steam system to the feedwater heaters to improve

plant efficiency.

The extraction steam system contains NSR components that are spatially oriented such that

their failure could prevent the satisfactory accomplishment of a safety-related function

associated with a safety-related SSC.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.4-2, the applicant identified the following extraction steam system component

types that are within the scope of license renewal and subject to an AMR: expansion joints;

pipe; steam traps; strainers; tubing; and valves.

2.3A.4.2.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.2 and Millstone FSAR Sections 10.1 and 10.2. The staffs

review, using the evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.4.2.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the extraction steam system components that are within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the extraction

steam system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

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2.3A.4.3 Feedwater System

2.3A.4.3.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.3, the applicant described the feedwater system. The feedwater system

heats and supplies condensate-quality water to the secondary-side of the steam generators to

support heat removal from the RCS. A portion of the system provides the flowpath for auxiliary

feedwater flow to the steam generators.

The feedwater system provides a flow path for auxiliary feedwater to the steam generators,

containment pressure boundary integrity, and RG 1.97 safety-related indications. The feedwater

system provides isolation of feed flow in the response to an MSLB and the system contains

NSR components that are spatially oriented such that their failure could prevent the satisfactory

accomplishment of a safety-related function associated with a safety-related SSC. The system

also contains NSR components credited with mitigating the effects of a HELB. The system

contains environmental qualification components and supports fire protection and station

blackout.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides limited structural integrity

In LRA Table 2.3.4-3, the applicant identified the following feedwater system component types that are within the scope of license renewal and subject to an AMR: flow elements; flow orifices;

heaters; pipe; pumps; tubing; and valves.

2.3A.4.3.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.3 and Millstone FSAR Sections.10.1, 10.4, and.

14.8.2.1.4. The staffs review, using the evaluation methodology described in Section 2.3 of this

SER, was conducted in accordance with the guidance described in Section 2.3 of NUREG1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with .10 CFR 54.21 (a)(1).

2.3A.4.3.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant No omissions were identified. In addition,

the staff performed a review to determine whether, any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the feedwater system components that are within the scope of license renewal, as

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required by 10 CFR 54.4(a), and that the applicant has adequately identified the feedwater

system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.4.4 Condensate System

2.3A.4.4.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.4, the applicant described the condensate system. The condensate

system provides condensate flow from the main condenser to the suction of the feedwater

pumps and provides feedwater heating to improve plant efficiency.

The condensate system contains NSR components that are spatially oriented such that their

failure could prevent the satisfactory accomplishment of a safety-related function associated

with a safety-related SSC.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.4-4, the applicant identified the following condensate system component types

that are within the scope of license renewal and subject to an AMR: condensers; drains coolers;

expansion joints; flow elements; flow orifices; heat exchanger steam jet air ejectors; heaters;

pipe; pumps; steam packing exhauster; tubing; and valves.

2.3A.4.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.4 and Millstone FSAR Sections 10.1, 10.4, and

14.8.2.1.4. The staff's review, using the evaluation methodology described in Section 2.3 of this

SER, was conducted in accordance with the guidance described in Section 2.3 of NUREG1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staff's review of LRA Section 2.3.4.4 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that a license renewal drawing for the condensate system shows

low-pressure main turbine exhaust hoods and the main condensers into which they exhaust as

within the scope of license renewal and subject to an AMR. However, LRA Table 2.3.4-4 did not

list exhaust hoods as a component type subject to an AMR. In RAI 2.3.4.4-1`A, dated June 9,

2004, the staff requested the applicant to confirm that the low-pressure main turbine exhaust

hoods are included with the components listed in LRA Table 2.3.4-4.

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In its response, dated July 26, 2004; the applicant-stated that the low-pressure main turbine

exhaust hoods shown on the license renewal drawing for the condensate system are included

in the component type, "Condensers," in'LRA Table 2.3.4-4.

The staff finds the applicant's response to RAI 2.3.4.4-1A acceptable, because the lowpressure main turbine exhaust hoods were considered part of the component type,

'Condensers," in LRA Table 2.3.4-4. The staff concludes that the low-pressure main turbine

exhaust hoods in the condensate system were scoped in accordance with the requirements of

10 CFR 54.4(a) and screened in accordance with the requirements of 10 CFR 54.21(a)(1).

Therefore, the-staff's concern described in RAl 2.3.4.4-1A is resolved.

Another license renewal drawing for the condensate system shows an analysis sample nozzle

as within the scope of license renewal and subject to an AMR. However, this component was

not listed in LRA Table 2.3.4-4 as a component type requiring an AMR. In RAI 2.3.4.4-2A,- dated

June 9, 2004, the staff requested the applicant to confirm that the analysis sample nozzle is

included with the-components listed in LRA-Section 2.3.4-4.

In its response, dated July 26, 2004, the applicant stated that the analysis sample nozzle shown

on license renewal drawing 25203-LR26005, sheet 1 (location B-9), for the condensate system

is included in the component type, "Pipe," in LRA Table 2.3.4-4.

The staff finds the applicant's response to RAI 2.3.4.4-2A acceptable, because the analysis

sample nozzle was considered part of the component type, "Pipe," in LRA Table 2.3.4-4. The

staff concludes that the analysis sample nozzle in the condensate system was scoped in

accordance with the requirements of 10 CFR 54.4(a) and screened in accordance with the

requirements of 10 CFR 54.21(a)(1). Therefore, the staff's concern described in RAI 2.3.4.4-2A

is resolved.

Another license renewal drawing for the condensate system shows a water trough as within the

scope of license renewal and subject to an AMR. However, this component was not listed in

LRA Table 2.3.4-4 as a component type requiring an AMR. In RAI 2.3.4.4-3A, dated June 9, -

2004, the staff requested the applicant to confirm that the "water trough" is included with the

components listed in LRA Table 2.3.4-4.

In its response, dated July 26, 2004, the applicant stated that the water trough shown on the

license renewal drawing for the condensate system was inadvertently highlighted and is not

within the scope of license renewal. Therefore, it is not listed in LRA Table 2.3.4-4.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.4-3A acceptable,

because the water trough was highlighted in error and is not within the scope of license renewal

and therefore does not need to appear in LRA Table 2.3.4-4. Therefore, the staff's concern

described in RAI 2.3.4.4-3A is resolved; ,

2.3A.4.4.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

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staff concludes that there is reasonable assurance that the applicant has adequately identified

the condensate system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the condensate system

components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.4.5 Condensate Storage and Transfer System

2.3A.4.5.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.5, the applicant described the condensate storage and transfer system.

The condensate storage and transfer system provides the missile-protected water source for

the auxiliary feedwater pumps.

The condensate storage and transfer system provides a protected water source for the auxiliary

feedwater pumps and RG 1.97 safety-related indications. The condensate storage and transfer

system contains NSR components credited with mitigating the effects of a HELB. The system

supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* restricts flow

In LRA Table 2.3.4-5, the applicant identified the following condensate storage and transfer

system component types that are within the scope of license renewal and subject to an AMR:

condensate storage tank; pipe; rupture disks; siphon breaker; tubing; and valves.

2.3A.4.5.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.5 and Millstone FSAR Sections 10.1 and 10.4.5. The

staffs review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staff's review of LRA Section 2.3.4.5 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAI as discussed below.

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The FSAR states that the condensate storage tank is equipped with a recirculation heating

subsystem to prevent freezing within the tank'during cold weather. The components of this

subsystem located outside the tank were shown to be outside the scope'of license renewal in a

license renewal drawing for the condensate storage and transfer system.'The condensate

storage tank is within the scope of license renewal because it provides a protected water

source for the auxiliary feedwater pumps. Since the presence of ice in the condensate storage

tank has the potential of hampering flow to the auxiliary feedwater pumps, the recirculation

heating subsystem should be within the scope of license renewal. In RAI 2.3.4.5-1A, dated

June'9, 2004, the staff requested the applicant to explain the apparent exclusion of the

recirculation heating subsystem components located outside the condensate storage tank from

the scope of license renewal and from being subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that although the condensate storage

tank is provided with a recirculation heating subsystem, the installed low-temperature alarm and

associated actions initiated in response to the alarm, together with the thermal inertia

associated with such a large tank, provide assurance that freezing of the tank contents will not

occur. Therefore, the applicant stated that the condensate storage tank recirculation heating

subsystem is not required for the tank to perform its intended function and it is not within the

scope of license renewal.

The staff finds the applicant's response to RAI 2.3.4.5-1A acceptable, because the applicant's

explanation of the condensate storage tank low-temperature alarm and associated actions to

ensure that condensate storage tank contents not freeze was adequate. Therefore, the staff

agrees that the recirculation heating subsystem is not within the scope of license renewal.

Therefore, the staff's concern described in RAI 2.3.4.5-1A is resolved.

The FSAR states that the condensate storage tank discharges are protected by screens that

will prevent the blockage of flow to the auxiliary feedwater pumps in the event of a postulated

free-falling fragment caused by a missile impacting the tank. However, the license renewal

drawing for the condensate storage and transfer system does not show the existence of

screens at the two condensate storage tank discharges, nor did LRA Table 2.3.4.5 include

screens as a component type subject to an AMR. These screens should be within the scope of

license renewal because they ensure unrestricted flow to the auxiliary feedwater pumps. In RAI

2.3.4.5-2A, dated June 9, 2004, the staff requested the applicant to explain the apparent ' exclusion of the screens located at the discharge piping in the condensate storage tank from

the scope of license renewal and from being subject to'an AMR:

In its response, dated July 26, 2004, the applicant'statedthat the internal screens described in

the FSAR are within the scope of license renewal. The screens were evaluated as an integral

part of the condensate storage tank and are not listed separately in LRA Table 2.3.4.5.

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The staff finds the applicant's response to RAI 2.3.4.5-2A acceptable, because the applicant's

explanation that the condensate storage tank discharge screens were within the scope of

license renewal and subject to an AMR was adequate. Therefore, the staffs concern described

in RAI 2.3.4.5-2A is resolved.

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In its review, the staff noted that the license renewal drawing for the condensate storage and transfer system shows a series of 1-inch pipes located inside the condensate storage tank. The piping is shown outside the scope of license renewal. However it is part of the nitrogen sparger system used to lower the oxygen concentration in the tank. A potential failure and possible fragmentation of this piping could introduce a source of flow blockage to the auxiliary feedwater

pumps and therefore should be within the scope of license renewal and subject to an AMR. In RAI 2.3.4.5-3A, dated June 9, 2004, the staff requested the applicant to explain the apparent exclusion of the nitrogen sparger piping located inside the condensate storage tank from the

scope of license renewal and from being subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that the nitrogen sparger lines internal

to the condensate storage tank are not within the scope of license renewal. The screens that

are within the scope of license renewal are installed to protect the tank discharge piping leading to the auxiliary feedwater pumps. Therefore, the applicant stated that failure of the internal

nitrogen piping will not impede the operation of the auxiliary feedwater pumps.

The staff finds the applicant's response to RAI 2.3.4.5-3A acceptable, because the applicant's explanation that the condensate storage tank discharge screens that are within the scope of license renewal protect the auxiliary feedwater pump suction from debris, including that caused by failure of nitrogen sparger piping, was adequate. Therefore, the staff's concern described in RAI 2.3.4.5-3A is resolved.

2.3A.4.5.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the condensate storage and transfer system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the condensate storage and transfer system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.4.6 Condensate Demin Mixed Bed System

2.3A.4.6.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.6, the applicant described the condensate demin mixed bed system. The condensate demin mixed bed system is used to maintain secondary system water chemistry.

The condensate demin mixed bed system contains NSR components that are spatially oriented such that their failure could prevent the satisfactory accomplishment of a safety-related function associated with a safety-related SSC.

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Intended functions within the scope of license renewal include the following:

* provides limited structural integrity -

a * provides a pressure boundary

In LRA Table 2.3.4-6, the applicant identified the following condensate demin mixed bed system

component types that are within the scope of license renewal and subject to an AMR: pipe;

tubing; and valves.

2.3A.4.6.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.6 and Millstone FSAR Sections,1 0.1 and 10.4.5. The

staffs review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to'verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3A.4.6.3- Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant.'No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the condensate demin mixed bed system components that are within'the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the condensate demin mixed bed system components that are subject to an AMR, as'

required by 10 CFR 54.21 (a)(1). c - -

2.3A.4.7 Auxiliary Feedwater System .

., , .;: . ; : . . . ;

2.3A.4.7.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.7, the applicant described the auxiliary feedwater system. The auxiliary

feedwater system provides a supply of feedwater to the secondary-side of the steam

generators for RCS heat removal if normal feedwater flow is unavailable. The system consists

of two motor-driven pumps powered from the emergency busses, and a steam turbine-driven

pump that provides feedwater flow upon a loss of all AC power. The normal source of water to

the auxiliary feedwater pumps is the condensate storage tank in the condensate storage' and

transfer system. The fire protection system can provide an alternate source of water to the

pumps. ;:it..-

The auxiliary feedwater system provides feedwater to the steam generators for removal of

sensible and decay heat from the RCS, isolation of auxiliary feedwater flow to a faulted or

ruptured steam generator, auxiliary feedwater flow limitation to prevent pump runout, and RG

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1.97 safety-related indications. The auxiliary feedwater system contains NSR components that

mitigate the effects of a HELB outside containment. The system provides environmental

qualification components and supports fire protection, anticipated transient without scram, and

station blackout.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* restricts flow

In LRA Table 2.3.4-7, the applicant identified the following auxiliary feedwater system

component types that are within the scope of license renewal and subject to an AMR: flow

elements; flow orifices; pipe; pumps; tubing; turbine casings; and valves.

2.3A.4.7.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.7 and Millstone FSAR Sections 7.9 and 10.4.5 The staff's

review, using the evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3A.4.7.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the auxiliary feedwater system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

auxiliary feedwater system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3A.4.8 Feedwater Heater Vents and Drains System

2.3A.4.8.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.8, the applicant described the feedwater heater vents and drains system.

The feedwater heater vents and drains system collects condensed extraction steam drains and

provides a flowpath to the condenser for steam vents from the shell-side of the feedwater

heaters.

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The feedwater heater vents and drains system contains NSR components that are spatially

oriented such that their failure could prevent the satisfactory accomplishment of a safety-related

function associated with a safety-related SSC.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.4-8, the applicant identified the following feedwater heater vents and drains

system component types that are within the scope of license renewal and subject to an AMR:

condensing pots; expansion joints; flow elements; flow orifices; gland seal'coolers; heaterdrains tank; level indicators; pipe; pumps; restricting orifices; tubing; and valves.

2.3A.4.8.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.8 and Millstone FSAR Sections 10.1 and 10.4.5. The

staffs review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1800..

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify 'that passive or long-lived components were not o mitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3A.4.8.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the feedwater heater vents and drains system components that are within'the scope

of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the feedwater heater vents and drains system components that are subject to an

AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.4.9 Moisture Separation and Reheat System

2.3A.4.9.1 Summary of Technical Information in the Application * - ;.! 1 :, .- ;

In LRA Section 2.3.4.9, the applicant described the moisture separation and reheat system. The

moisture separation and reheat system removes entrained moisture from the high-pressure

: turbine exhaust steam and provides superheated steam to the low-pressure turbine inlets.

The moisture separation and reheat system contains NSR components that are spatially

oriented such that their failure could prevent the satisfactory accomplishment of a safety-related

function associated with a safety-related SSC. .

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Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.4-9, the applicant identified the following moisture separation and reheat

system component types that are within the scope of license renewal and subject to an AMR:

condensing pots; drain pots; drain tanks; flow elements; pipe; tubing; and valves.

2.3A.4.9.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.9 and Millstone FSAR Sections 10.1, 10.2, and 10.4.5.

The staffs review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3A.4.9.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the moisture separation and reheat system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the moisture separation and reheat system components that are subject to an AMR,

as required by 10 CFR 54.21 (a)(1).

2.3A.4.10 Plant Heating and Condensate Recovery System

2.3A.4.10.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.10, the applicant described the plant heating and condensate recovery

system. The plant heating and condensate recovery system provides low-pressure steam for

various plant loads and collects the condensed steam drains for reprocessing.

The plant heating and condensate recovery system provides detection and isolation of a HELB

in the steam portion of the system and provides a pressure boundary for the reactor building

closed cooling water system. The plant heating and condensate recovery system contains NSR

components that are spatially oriented such that their failure could prevent the satisfactory

accomplishment of a safety-related function associated with a safety-related SSC. The system

contains environmental qualification components and supports fire protection.

Intended functions within the scope of license renewal include the following:

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* provides limited structural integrity.

* provides a pressure boundary

In LRA Table 2.3.4-1 0, the applicant identified the following plant heating and condensate

recovery system component types that are within the scope of license renewal and subject to

an AMR: heating and ventilation units; heating coils; pipe; reservoir; sample coolers; steam

traps; strainers; tubing; and valves.

2.3A.4.10.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.10 and Millstone FSAR Section 9.13.2. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of .10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended,

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.4.10 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that a license renewal drawing for the plant heating and

condensate recovery system does not show the refueling water storage tank (RWST) heat

exchanger and attached piping as part of the evaluation boundary. A potential leak in this heat

exchanger or the attached piping inside of the RWST could potentially reduce the boron

concentration in the tank and thereby impact the safe shutdown boric acid requirements.

Therefore, the staff concluded that this heat exchanger and the attached piping inside of the

RWST has a passive pressure boundary function.- In RAI 2.3.4.10-1A, dated June 9,2004, the

staff requested the applicant to explain the apparent exclusion of the RWST heating system -

from the scope of license renewal.

In its response, dated July 26, 2004, the applicant stated that the RWST fluid temperature is

maintained within requirements by the subject heat exchanger. RWST fluid is on the tube-side

of the heat exchanger and heating is provided by plant auxiliary steam on the shell-side. The

normal pressure of the shell-side of the heat exchanger is less than that of the RWST fluid on

the tube-side such that any tube leakage would be expected to be from the tubes into the shell.

Operating experience with past heat exchanger tube leakage confirms that leakage has been

from the tube-side to the shell-side of the heat exchanger. In the event that steam pressure

were to be higher than tube-side fluid pressure, the steam environment would result in limited

leakage of liquid volume into the RWST such that significant dilution of the greater than

420,000-gallon volume of borated water in the tank would not be expected. In addition,

drainage of the RWST below the minimum required volume, due to heat exchanger tube

leakage, is prevented by a siphon breaker in the supply.line internal to the tank. Therefore, the

applicant concluded that since the failure of the RWST heat exchanger cannot have a

significant effect on the boron concentration of its contents or the level of the tank, the heat

exchanger was not included within the scope of license renewal for boron dilution concems. In

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addition, the piping internal to the RWST and the siphon breaker are included within the scope

of RWST and are subject to an AMR.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.10-1A acceptable,

because the applicant's explanation that the RWST heating system could not result in a dilution

event or loss of inventory due to a piping failure was adequate. Further, the applicant explained

that piping and the siphon breaker internal to the RWST are within the scope of license renewal

and subject to an AMR. Therefore, the staff's concern described in RAI 2.3.4.10-1A is resolved.

2.3A.4.10.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the plant heating and condensate recovery system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the plant heating and condensate recovery system components that are subject to an

AMR, as required by 10 CFR 54.21(a)(1).

2.3A.4.11 Secondary Chemical Feed System

2.3A.4.11.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.11, the applicant described the secondary chemical feed system. The

secondary chemical feed system provides the capability to inject chemicals into the secondary

cycle flowstream to maintain water chemistry within desired limits.

The secondary chemical feed system contains NSR components that are spatially oriented

such that their failure could prevent the satisfactory accomplishment of a safety-related function

associated with a safety-related SSC.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.4-11, the applicant identified the following secondary chemical feed system

component types that are within the scope of license renewal and subject to an AMR: tubing;

and valves.

2.3A.4.11.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.11 and Millstone FSAR Section 10.4.5. The staffs review,

using the evaluation methodology described in Section 2.3 of this SERj was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

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In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54:21 (a)(1).

2.3A.4.11.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In'addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its'

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the secondary chemical feed system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

secondary chemical feed system components that are subject to an AMR, as required by

IO CFR 54.21 (a)(1).

2.3A.4.12 Turbine Gland Sealing System

2.3A.4.12.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.12, the applicant described the turbine gland sealing system. The turbine

gland sealing system provides low-pressure steam for sealing the turbine shaft casing

penetrations and valve stem packing glands from air in-leakage or steam out-leakage;'

The turbine gland sealing system contains NSR components that are spatially oriented such -

that their failure could prevent the satisfactory accomplishment of a safety-related function

associated with a safety-related SSC.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

provides a pressure boundary

In LRA Table 2.3.4-12, the applicant identified the following turbine gland sealing system

component types that are within the scope of license renewal and subject to an AMR: flow

orifices; pipe; tubing; valves; and water pot.

2.3A.4.12.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.12 and Millstone FSAR Sections 10.2 and 10.4.3. The

staff's review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

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or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.4.12 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

Specifically, the staff noted that the license renewal drawing shows two plugs as not being

within the scope of license renewal. The plugs are on the gland seal piping coming to the steam

packing exhauster. The staff determined that the piping to which the plugs are attached is

within the scope of renewal because it meets 10 CFR 54.4(a)(2). Failure of the plugs may have

the same effect as failure of the piping. Therefore, in RAI 2.3.4.12-1A, dated June 9, 2004, the

staff requested the applicant to explain the apparent exclusion of the plugs from the scope of

license renewal.

In its response, dated July 26, 2004, the applicant stated that the subject plugs on license

renewal drawing are considered pipe fittings and are within the scope of license renewal, but

were inadvertently not highlighted on the license renewal drawing. The applicant further stated

the plugs are included in the component type, "Pipe," in LRA Table 2.3.4-12 and are therefore

subject to an AMR.

The staff finds the applicant's response to RAI 2.3.4.12-1A acceptable, because the applicant

explained that the plugs were within the scope of license renewal and are included in LRA

Table 2.3.4-12. Therefore, the staffs concern described in RAI 2.3.4.12-1A is resolved.

2.3A.2.12.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the turbine gland sealing system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the turbine gland

sealing system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3A.4.13 Auxiliary Steam Reboiler and Deaerating Feedwater System

2.3A.4.13.1 Summary of Technical Information in the Application

The auxiliary steam reboiler and deaerating feedwater system is an NSR system that was

previously excluded from the scope of license renewal. As a result of the revised scoping

methodology set forth in the applicant's November 9, 2004, RAI response, the applicant added

portions of the auxiliary steam reboiler and deaerating feedwater system that could spatially

interact with safety-related SSCs. The applicant provided descriptions of the systems that were

added to the scope of license renewal in response to RAI 2. 1-1 in its December 3, 2004, RAI

response.

.'

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In the December 3, 2004, RAI response, the applicant stated that the auxiliary steam reboiler

and deaerating feedwater system provides a source of auxiliary steam for house heating loads.

It is a non-safety, low-energy system that contains components that have been identified to

affect a function of a safety-related system due to the proximity of this system to the

safety-related system and are attached to safety-related piping. Additional details of the

auxiliary steam reboiler and deaerating feedwater system can be found in FSAR Section

10.3.1.1.

In accordance with the revised scoping methodology,- the applicant identified the following

component types for the auxiliary steam reboiler and deaerating feedwater system as falling

within the scope of license renewal and subject to an AMR:

* auxiliary steam feedwater surge tank;-:

* pipe

* . sample coolers , .- - -

* valves .

2.3A.4.13.2 Staff Evaluation

The staff reviewed the information that the applicant provided its November 9, 2004, and

December 3, 2004, RAI responses for the auxiliary steam reboiler and deaerating feedwater

system using the evaluation methodology described in Section 2.3 of this SER. The staff

conducted its review in accordance with the guidance described in SRP-LR Section 2.3.

In conducting its review, the staff evaluated the system functions described in the November 9,

2004, and December 3, 2004, submittals for the auxiliary steam reboiler and deaerating

feedwater system in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed those components that the

applicant identified as being within the scope of license renewal to verify that the applicant did

not omit any passive and long-lived components that should be subject to an AMR in

accordance with the requirements of 10 CFR 54.21(a)(1).

2.3A.4.13.3 Conclusion - .

Based on its review of the supplemental information that the applicant provided in its responses

dated November 9, 2004, and December 3, 2004, FSAR Section 10.3.1.1 -and licensing basis

information; the staff did not identify any omissions or discrepancies in the applicant's scoping

and screening results for the components of the auxiliary steam reboiler and deaerating

feedwater system. Therefore, the staff concludes that the applicant adequately identified the

auxiliary steam reboiler and deaerating feedwater system components that are within the scope

of license renewal, as required by 10 CFR 54.4(a), and that the applicant adequately identified

the auxiliary steam reboiler and deaerating feedwater.system components that are subject to an

AMR, as required by 10 CFR 54.21 (a)(1). 1,; . .

, '*; . ' ' ,, - ;, s ' *-

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2.3A.4.14 ExciterAir Cooler System

2.3A.4.14.1 Summary of Technical Information in the Application

The exciter air cooler system is an NSR system that was previously excluded from the scope of

license renewal. As a result of the revised scoping methodology set forth in the'applicant's

November 9, 2004, RAI response, the applicant added portions of the exciter air cooler system

that could spatially interact with safety-related SSCs. The applicant provided descriptions of the

systems that were added to the scope of license renewal by response dated December 3,

2004.

In the December 3, 2004, RAI response, the applicant stated that the exciter air cooler system

provides air cooling to the main generator exciter and isophase bus duct. Turbine building

component cooling water serves as the heat sink for the system. Heat transfer occurs in the

isolated phase bus cooler. It is a non-safety, low-energy system that contains components that

have been identified to affect a function of a safety-related system due to the proximity of this

system to the safety-related system. Additional details of the exciter air cooler system can be

found in FSAR Sections 9.7.3.2.1 and 10.2.

In accordance with the revised scoping methodology, the applicant identified the main

transformer and generator isophase bus duct cooling exchangers coils as the one component

type for the exciter air cooler system as being within the scope of license renewal and subject to

an AMR.

2.3A.4.14.2 Staff Evaluation

The staff reviewed the information that the applicant provided in the November 9, 2004, and

December 3, 2004, RAI responses for the exciter air cooler system using the evaluation

methodology described in Section 2.3 of this SER. The staff conducted its review in accordance

with the guidance described in SRP-LR Section 2.3.

In conducting its review, the staff evaluated the system functions described in the November 9,

2004, and December 3, 2004, RAI responses for the exciter air cooler system in accordance

with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope

of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff then reviewed those components that the applicant identified as being within the scope of

license renewal to verify that the applicant did not omit any passive and long-lived components

that should be subject to an AMR in accordance with the requirements of

10 CFR 54.21(a)(1).

2.3A.4.14.3 Conclusion

Based on its review of the supplemental information that the applicant provided in the

responses dated November 9, 2004, and December 3, 2004, FSAR Sections 9.7.3.2.1 and

10.2, and licensing basis information; the staff did not identify any omissions or discrepancies in

the applicant's scoping and screening results for the components of the exciter air cooler

system. Therefore, the staff concludes that the applicant adequately identified the exciter air

cooler system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant adequately identified the exciter air cooler system

components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

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2.3A.4.15 Stator Liquid Cooler System

2.3A.4.15.1 Summary of Technical Information in the Application

The stator liquid cooler system is an NSR system that was previously excluded from the scope

of license renewal. As a result of the revised scoping methodology set forth in the applicant's

November 9, 2004, RAI response, the applicant added portions of the stator liquid cooler

system that could spatially interact with safety-related SSCs. The applicant provided

descriptions of the systems that were added to the scope of license renewal by response dated

December 3, 2004. ;,

In the December 3, 2004, response, the applicant stated that the stator liquid cooler system)

provides a source of cooling to the main generator stator. Turbine building component cooling

water serves as the heat sink for the system.-ft is a non-safety, low-energy system that contains

components that have been identified to affect a function of a safety-related system due to the

proximity of this system to the safety-related system. Additional details of the stator liquid cooler

system can be found in FSAR Sections 9.7.3.2.1 and 10.2. -.. v . a . --**

In accordance with the revised scoping methodology, the applicant, in its November 9, 2004,

RAI response, identified the following component types for the stator liquid cooler system as

being within the scope of license renewal and subject to an AMR:

* deionizer , * filter/strainers -

* flow indicators-

* flow orifices

* level indicators - -

* pipe

* pumps - *i a

* stator liquid coolers (channel head).

* stator liquid coolers (shell)

* stator liquid coolers (tube sheet)

* stator liquid cooling water storage tank

* tubing

* valves

2.3A.4.15.2 Staff Evaluation

The staff reviewed the information that the applicant provided in the November 9, 2004, and

December 3, 2004, responses for the stator liquid cooler system using the evaluation

methodology described in Section 2.3 of this SER. The staff conducted its review in accordance

with the guidance described in SRP-LR Section 2.3.

In conducting its review, the staff evaluated the system functions described in the November 9,

2004, and December 3, 2004, responses for the stator liquid cooler system in accordance with

the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The -

staff then reviewed those components that the applicant identified as being within the scope of

license renewal to verify that the applicant did not omit any passive and long-lived components

that should be subject to an AMR in accordance with the requirements of 10 CFR 54.21 (a)(1).

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2.3A.4.15.3 Conclusion

Based on its review of the information that the applicant provided in its responses dated November 9, 2004, and December 3, 2004, FSAR Sections 9.7.3.2.1 and 10.2, and licensing basis information; the staff did not identify any omissions or discrepancies in the applicant's scoping and screening results for the components of the stator liquid cooler system. Therefore, the 

components 

staff concludes 

that 

that the applicant adequately identified the stator liquid cooler system pa are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant adequately identified the stator liquid cooler system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3A.4.16 Turbine Lube Oil System

2.3A.4.16.1 Summary of Technical Information in the Application

The turbine lube oil system is an NSR system that was previously excluded from the scope of license renewal. As a result of the revised scoping methodology set forth in the applicant's November 9, 2004, RAI response, the applicant added portions of the turbine lube oil system that could spatially interact with safety-related SSCs. The applicant provided descriptions of the systems that were added to the scope of license renewal in response to RAI 2.1-1 in its December 3, 2004, RAI response.

In the December 3, 2004, response, the applicant stated that the turbine lube oil system provides lubricating oil to the main turbine generator bearings. It is a non-safety, low-energy system that contains components that have been identified to affect a function of a safety-related system due to the proximity of this system to the safety-related system. Additional details of the turbine lube oil system can be found in FSAR Section 10.2.

In accordance with the revised scoping methodology, the applicant, in its November 9, 2004, RAI response, identified the following component types for the turbine lube oil system as being within the scope of license renewal and subject to an AMR:

* filter/strainers

* flow indicators

* flow orifices

* level indicators

* pipe

* steam generator feedwater pump lube oil cooler shell * SGFP turbine lube oil reservoir

* tubing

* valves

2.3A.4.16.2 Staff Evaluation

The staff reviewed the information that the applicant provided in the November 9, 2004, and December 3, 2004, RAI responses for the turbine lube oil system using the evaluation methodology described in Section 2.3 of this SER. The staff conducted its review in accordance with the guidance described in SRP-LR Section 2.3.

i

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In conducting its review, the staff evaluated the system functions described in the November 9

and December 3, 2004, RAI responses for the turbine lube oil system in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of'

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff then reviewed those components that the applicant identified as being within the scope of

license renewal to verify that the applicant did not omit any passive and long-lived components

that should be subject to an AMR in accordance with the requirements of 10 CFR 54.21 (a)(1).

2.3A.4.16.3 Conclusion - - -

Based on its review of the supplemental information that the applicant provided in its responses

dated November 9, 2004, and December 3, 2004, FSAR Section 10.2, and licensing basis'

information; the staff did not identify any omissions or discrepancies in the applicant's scoping

and screening results for the components of the turbine lube oil system. Therefore, the staffl

concludes that the applicant adequately identified the turbine lube oil system components that

are within the scope of license renewal, as required by 10 CFR 54.4(a), "and that the applicant

adequately identified the turbine lube oil system components that are subject to an AMR,-as.

required by 10 CFR 54.21(a)(1).

2.3A.4.17 Electro Hydraulic Control System -

2.3A.4.17.1 Summary of Technical Information in the Application

The electro hydraulic control system is included in LRA Table 2.2-1 as within the scope of

license renewal.:However, the applicant under Note 1 to the Table 2.2-1-stated that this system

does not contain any mechanical components that require an AMR. Therefore, there was no

screening results table and system description for this system in the LRA. Resulting from the

revised scoping methodology described in the November 9, 2004, RAI response, the applicant

added portions of the electro hydraulic control system that could spatially interact with safetyrelated SSCs. - -:

The applicant provided the electro hydraulic control systems description and a list of mechanical

component types that wereadded to the scope of license renewal for electro hydraulic control

system in its RAI 2.1-1 response, dated December 3, 2004. The applicant stated that the

electro hydraulic control system provides high-pressure hydraulic fluid for the operation of the

main turbine valves. The electro hydraulic control system provides signals to trip the turbine and

provides a signal, which is based on turbine first-stage pressure, to the reactor regulating

system as a load reference. It provides turbine-trip signal input to the reactor protection system

and is a non-safety, low energy system that contains components that have been identified to

affect a function of a safety-related system due to the proximity of this system to the safetyrelated system. Additional details of the electro hydraulic control system can be found in FSAR

Section 10.2.

In the December 3, 2004, response, the applicant identified the following component types that

were added to the scope of the electro hydraulic control system due to the changed scoping

methodologies:

* filters/strainers i-

* flexible hoses

a flow indicators

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* pipe

* pumps <

* tubing

* hydraulic fluid coolers

* valves

2.3A.4.17.2 Staff Evaluation

The staff reviewed the supplemental information that the applicant provided in the November 9,

2004, and December 3, 2004, RAI responses for the electro hydraulic control system using the

evaluation methodology described in Section 2.3 of this SER. The staff conducted its review in

accordance with the guidance described in SRP-LR Section 2.3.

In conducting its review, the staff evaluated the system functions described in the November 9

and December 3, 2004, responses for the electro hydraulic control system in accordance with

the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff then reviewed those components that the applicant identified as being within the scope of

license renewal to verify that the applicant did not omit any passive and long-lived components

that should be subject to an AMR in accordance with the requirements of 10 CFR 54.21 (a)(1).

2.3A.4.17.3 Conclusion

Based on its review of the information that the applicant provided in its responses dated

November 9, 2004, and December 3, 2004, FSAR Section 10.2, and licensing basis

information; the staff did not identify any omissions or discrepancies in the applicant's scoping

and screening results for the components of the electro hydraulic control system. Therefore, the

staff concludes that the applicant adequately identified the electro hydraulic control system

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant adequately identified the electro hydraulic control system components that

are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B Unit 3 System ScoDing and Screenina Results - Mechanical Systems

2.3B.1 Reactor Coolant System

In LRA Section 2.3B.1, the applicant identified the structures and components of the reactor

coolant system (RCS) that are subject to an AMR for license renewal.

The applicant described the supporting structures and components of the reactor coolant

system in the following sections of the LRA:

* 2.3.1.1 reactor vessel

* 2.3.1.2 reactor vessel internals

* 2.3.1.3 reactor coolant system

* 2.3.1.4 steam generator

The corresponding subsections of this SER (2.3B.1.1 - 2.3B.1.4, respectively) present the

staffs related review findings.

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2.3B.1.1 Reactor Vessel

2.38.1.1.1 Summary of Technical Information in the'Application

In LRA Section 2.3.1.1, the applicant described the reactor vessel. The reactor vessel is a

Westinghouse-designed, four-loop pressure vessel consisting of a cylindrical shell with a

welded, hemispherical lower head and a flanged,- hemispherical upper head. The reactor vessel

provides a container for the -reactor core and the'primary coolant in which the core is

submerged. -

The reactor vessel directly maintains the RCS pressure boundary and supports and contains

the reactor core and core support structures: Additionally, the reactor vessel provides a function

that supports pressurized thermal shock.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides structural and/or functional support related to mechanical components

In LRA Table 2.3.1-1 the applicant identified the following reactor vessel component types that

are within the scope of license renewal and subject'to'an AMR: bottom-mounted' '

instrumentation (BMI) flux thimble tubes; BMI guide tubes; bottom head; closure head dome;

closure head flange; closure head lifting lugs; closure head stud assembly; core support pads;

control rod drive mechanism (CRDM) head penetration nozzle; CRDM head penetration nozzle

flange; CRDM pressure housings; head vent pipe; instrument tubes; instrument tubes

extension; instrumentation tubes (bottom head); intermediate and l6oer shell; primary nozzles;

primary nozzle safe end; seal table and fittings; upper shell; vessel flange and core support

ledge.

2.38.1.1.2 Staff Evaluation

The staff reviewed LRA Section 2.3.1.1 and Millstone'FSAR Sections 3.9N.4, 4.5.1, 5.1,'5.2,

and 5.3. The staffs review, using the evaluation methodology described in Section 2.3 of this

SER, was conducted in accordance with the guidance described in Section 2.3 of NUREG1800. -

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.1.1 identified areas in which additional'information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below. * '' - '' '; . i '- ' d !

In RAI 2.3.1.1-1 (b), the staff requested the applicant to verify whether nozzle support pads,

which are located below the primary nozzles and provide support for the reactor vessel, were

included within the scope of license renewal and subject to an AMR, or to provide an

2:133':
Al

explanation for the exclusion. In response, the applicant stated the reactor nozzle support pads

are integral with four of the eight primary nozzles and are within the scope of license renewal

and subject to aging management review. The nozzle support pads are included in the "Primary

Nozzles' subcomponents in LRA Table 2.3.1-1. Based on the inclusion of the above

components, the staff finds the applicant's response acceptable.

In RAI 2.3.1.1-3, the staff requested the applicant to verify whether the lower internals

assembly, which hangs from the core's support ledge and provides structural support for inscope components, has been included within the scope of license renewal and is subject to an

AMR, or to provide an explanation for the exclusion. In response, the applicant stated the

reactor vessel lower internals assembly is included within the scope of license renewal and

subject to an AMR. The components of the lower internals assembly are included in LRA

Section 2.3.1-2, "Reactor Vessel Internals." Based on the inclusion of the above component,

the staff finds the applicant's response acceptable.

2.3B.1.1.3 Conclusion

The staff reviewed the LRA and RAI responses described above to determine whether any

SSCs that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the reactor vessel

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the reactor vessel components that are subject to

an AMR, as required by 10 CFR 54.21(a)(1).

2.3B.1.2 Reactor Vessel Intemals

2.3B.1.2.1 Summary of Technical Information in the Application

In LRA Section 2.3.1.2, the applicant described the reactor vessel internals (RVIs). The RVIs

are designed to provide a passageway for the distribution of reactor coolant flow to the reactor

core; support and orientation of the reactor core; support, orientation, guidance, and protection

of the rod cluster control assemblies (RCCAs); gamma and neutron shielding for the reactor

vessel; a passageway for support, guidance, and protection of incore instrumentation; and a

secondary support structure for limiting the core support structure downward displacement.

The RVIs support the reactor core in a coolable geometry and provide a RCCA insertion path.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support related to mechanical components

* provides for flow distribution

In LRA Table 2.3.1-2, the applicant identified the following RVI component types that are within

the scope of license renewal and subject to an AMR: baffle/former bolts; baffle/former plates;

BMI columns; clevis insert bolts; clevis inserts; core barrel; core barrel flange; core barrel outlet

nozzles; head and vessel alignment pins; head cooling spray nozzles; hold-down spring; lower

core plate; lower fuel alignment pins; lower support forging; lower support plate column bolts;

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lower support plate columns; neutron panels; radial; RCCA guide tube bolts; 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 bolts; upper support columns; and upper support plate.

2.3B.1.2.2 Staff Evaluation

The staff reviewed LRA Section 2.3.1.2, Millstone FSAR Sections 3.9N.5 and 4.5.2, FSAR

Table 5.2-3,- and FSAR Figures 3.9N-8 through 3.9N-12. The staffs review, using the

evaluation methodology described in Section 2.3 of this SER, was conducted in accordance

with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.1.2 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In RAI 2.3.1.2-2, the staff requested the applicant to verify whether the core support, which is

welded to the core barrel and provides structural support for in-scope equipment, is within the

scope of license renewal and subject to an AMR or to provide an explanation for its exclusion.

The applicant confirmed the core support is within the scope of license renewal and identified

as the "Lower support forging" in LRA Table 2.3.1-2. Based on the inclusion of the above

component, the staff finds the applicant's response acceptable.

2.3B.1.2.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No -

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the RVI components that are

within the scope of license renewallas required by 0 CFR 54.4(a), and that the applicant has

adequately identified the RVI components that are subject to an AMR, as required by

10.CFR 54.21(a)(1). . -, -

2.3B.1.3 Reactor Coolant System

2.3B.1.3.1 Summary of-Technical Information in the Application

In LRA Section 2.3.1.3, the applicant described the RCS. The RCS is designed to contain

pressurized treated water and transfer heat produced in the reactor core to the steam

generators. Borated treated water is circulated through the core at a flow rate and temperature

consistent with achieving the desired reactor core thermal-hydraulic performance. The RCS

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provides a pressure boundary for containing the primary coolant, serves to confine radioactive

material, and limits the uncontrolled release of radioactive material.

The safety-related intended functions of the RCS are to provide a closed pressure boundary for

containing the primary coolant, transfer heat from the reactor core to the steam generator,

provide system over-pressure protection, provide RG 1.97 safety-related indications, provide a

reactor plant component cooling system pressure boundary, provide a letdown path via the

head vent system under post-accident conditions, and provide a means of venting noncondensable gases from system high points after an accident. The RCS contains NSR

components credited for mitigating a high-energy line break (HELB) and NSR components

spatially oriented such that a failure could prevent the satisfactory accomplishment of a safetyrelated function of a safety-related SSC. The RCS contains environmental qualification

components and supports fire protection, station blackout, and pressurized thermal shock.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

* restricts flow

* provides a spray pattern

* provides structural and/or functional support related to mechanical components

* limits thermal cycling

In LRA Table 2.3.1-3, the applicant identified the following RCS component types that are within

the scope of license renewal and subject to an AMR: bolting; flow elements; flow indicators;

flow orifices; pipe; pressurizer; pressurizer heaters; reactor coolant pump (RCP) motor lower

lube oil coolers; RCP motor stator coolers; RCP thermal barriers; RCP motor upper lube oil

coolers; reactor coolant pressurizer relief tank; RCPs; rupture discs; thermal sleeves; tubing;

and valves.

2.3B.1.3.2 Staff Evaluation

The staff reviewed LRA Section 2.3.1.3, Millstone FSAR Chapter 5, and FSAR Figures 5.1-1,

5.1-2, 5.2-3, and 5.4-1. The staffs review, using the evaluation methodology described in

Section 2.3 of this SER, was conducted in accordance with the guidance described in Section

2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.1.3 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

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In RAI 2.3.1.3-1, the staff requested the applicant to'verify whether the following pressurizer

components set forth in Table 2.3B-1 were included within the scope of license renewal and

require an AMR or, alternately, to provide an explanation for their exclusion.

Table 2.3B-1 Pressurizer Components that Require Additional Scoping Status

Information

-Subcomponent rjX- ' .; ntended Functio <

Pressurizer - Nozzles (Surge', Spray, Safety,7 `' Pressure Boundary

Relief, Instrument)

Pressurizer - Nozzle Safe Ends Pressure Boundary

Pressurizer -' Heater Sheath Pressure Boundary.

Pressurizer - Manway and Cover Pressure Boundary

Pressurizer - Surge Line Pressure Boundary

Pressurizer - Spray Head Assembly Spray Pattern

Pressurizer - Support Lugs 'Structural Support

Pressurizer - Support Skirt and Flange '0 Structural Support

In a response dated November 9, 2004, the applicant confirmed that the pressurizer, including

all subcomponents that perform intended functions, is included within the scope of license

renewal and is subject to an AMR. The applicant further stated that the pressurizer was

evaluated as part of the RCS and is not considered a major component. Therefore, pressurizer

subcomponents are not listed separately in LRA Table 2.3.1-3. The applicant stated that the

subcomponents listed in the table above are included in the component types "Pressurizer" and'

'Pressurizer Heaters" in LRA Table 2.3.1-3: Subcomponents of the pressurizer are set forth in

LRA Table 3.1.2-3. Based on the inclusion of the above components, the staff finds the

applicant's response acceptable.

In RAI 2.3.1.3-2(b), the staff requested the applicant to verify whether the pump casing and

main flange, which provide a RBCCW'system pressure boundary, are within the scope of

license renewal and subject to an AMR. The RCP casing, cover (main flange), thermal barrier

(including the integral heat exchanger) and closure bolting are considered part of the RCS

boundary. The upper and lower reactor coolant pump motor lube oil coolers and the outer tubes

of the seal cooler provide a reactor building closed-cooling-water-system pressure boundary. In

response dated November 9, 2004, the applicant c6nifirrned the RCP casing and main flange

are within the scope of license renewal and subject to Ian AMR. The applicant stated that these

items are considered subcomponents of the RCP and are included in the component type,

"Reactor Coolant Pump," in LRA Table 2.3:1-3. The pump casing is identified in LRA Table'

3.1.2-3 as uReactor Coolant Pumps (Casing)." The RCP cover (main flange) and thermal barrier

are a riintegral part and are identified as "RCP Thermal Barriers" in Table 3.1.2-3

In RAI 2.3.1.3-3, the staff requested the applicant to verify whether the RCS welds, which are

included in the evaluation boundary for the RCS, are within the scope of license renewal and

subject to an AMR. In a response dated July 26, 2004, the applicant confirmed that the RCS

2-1 37:.:
welds are within the scope of license renewal and require an AMR. Welds are considered a part

of the host component (e.g., pipe, nozzle) and are not uniquely identified in LRA Table 2.3.1-3.

Based on the inclusion of the above component, the staff finds the applicant's response

acceptable.

2.3B.1.3.3 Conclusion

The staff reviewed the LRA and RAI responses described above to determine whether any

SSCs that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the RCS components that

are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant

has adequately identified the RCS components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3B.1.4 Steam Generator

2.3B.1.4.1 Summary of Technical Information in the Application

In LRA Section 2.3.1.4, the applicant described the steam generator. The nuclear steam supply

system (NSSS) utilizes four Westinghouse Model F steam generators to transfer the heat

generated in the RCS to the secondary system and produce steam at the warranted steam

pressure and quality.

The steam generator directly maintains the RCS pressure boundary, supports the capability to

shut down the reactor and maintain it in a safe shutdown condition, and supports the capability

to prevent or mitigate the discharge of radioactive coolant into the secondary cycle. Additionally,

the steam generator provides for core heat removal in support of station blackout and fire

protection.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support related to mechanical components

* provides for flow distribution

* provides a pressure boundary

* restricts flow

In LRA Table 2.3.1-4, the applicant identified the following steam generator component types

that are within the scope of license renewal and subject to an AMR: anti-vibration bars; divider

plate; feedwater inlet ring and support; feedwater nozzle and safe end; lower head; lower head

drain nozzle; primary manway bolting; primary manway cover and diaphragm; primary nozzle

and safe end; secondary-manway and handhole bolting; secondary manway and handhole

covers; secondary-side nozzles (except steam and feedwater); stay rods; steam nozzle and

safe end; steam nozzle flow restrictor, top head; transition cone; tube plugs; tube support

plates; tubes; tubesheet; upper and lower shell; upper support trunnions; and wrapper.

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2.3B.1.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.1.4, Millstone FSAR Section 5.4.2, and FSAR Figure 5.4-3. -

The staffs review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1 800. .

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.38.1.4.3 Conclusion

The staff reviewed the LRA to'determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the steam generator components that are within the scope of license renewal,- as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the steam'

generator components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.2 Engineered Safety Features Systems

In LRA Section 2.3.2,-the applicant identified the'structures and components of the engineered

safety features (ESF) systems that are subject to an AMR for license renewal.

The applicant described the supporting structures and components of the ESF systems in the

following'sections of the LRA: . . . -

* 2.3.2.1 containment recirculation system

* 2.3.2.2 quench spray system a ' '

* 2.3.2.3 safety injection system'' . ;- '

* 2.3.2.4 residual heat removal system

* 2.3.2.5 fuel pool cooling and purification system

The corresponding subsections of this SER (2.38.2 1-'- 2.3B.2.5, respectively) present the

staffs related review findings. .; - ' - . -

, C , , *-I:. I ,

2.3B.2.1 Containment Recirculation System.* .:

2.38.2.1.1 -Summary of Technical Information in the Application

In LRA Section 2.3.2.1, the applicant described the containment recirculation system.:The

containment recirculation system, in conjunction with the quench spray system,' removes heat

from the containment atmosphere following a major primary or secondary pipe rupture inside

the containment. Heat is transferred to the service water (SW) system via the containment

recirculation system coolers.

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The containment recirculation system provides heat removal from the containment, a source of

water to the safety injection pumps and charging pumps during the recirculation phase, sump

water pH control, RG 1.97 safety-related indications, and containment pressure boundary

integrity. The containment recirculation system contains NSR components that are spatially

oriented such that their failure could prevent the satisfactory accomplishment of a safety-related

function associated with a safety-related SSC. The containment recirculation system also

contains environmental qualification components and supports fire protection and station

blackout.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

* provides a spray pattern

* restricts flow

* provides structural and/or functional support related to mechanical components

In LRA Table 2.3.2-1, the applicant identified the following containment recirculation system

component types that are within the scope of license renewal and subject to an AMR: bolting;

containment recirculation coolers; expansion joints; flow elements; flow indicators; hoses; pipe;

pump seal coolers; pump seal head tanks; pumps; restricting orifices; spray nozzles; TSP

baskets; tubing; and valves.

2.3B.2.1.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.1 and Millstone FSAR Section 6.2.2. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.2.1.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the containment spray system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

containment spray system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

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2.3B.22 Quench Spray System

2.3B.2.2.1 Summary of Technical Information in the Application

In LRA Section 2.3.2.2., the applicant described the quench spray systemn; The quench spray

system, in conjunction with the containment recirculation system, removes heat from the -

containment atmosphere during the injection phase following a major primary or secondary pipe

rupture in containment. The quench spray system pumps cooled water from the refueling water

storage tank (RWST) through the spray nozzles within the containment. The spray nozzles

direct cooled, borated water spray downward from the upper regions of the containment to cool

and depressurize the containment. The RWST includes an internal weir to prevent debris from

entering the quench spray system pumps suction and a vortex breaker to prevent pump suction

air entrainment at low-RWST water levels.

The quench spray system provides heat removal from containment; removal of fission products

from the post-accident containment atmosphere via spray; and a source of borated water from

the RWST to the residual heat removal pumps, the safety injection pumps, and the charging

pump. Also, the system provides RG 1.97 safety-related indications and containment pressure

boundary integrity. The quench spray system contains NSR components that are spatially

oriented such that their failure could prevent the satisfactory accomplishment of 'a safety-related

function associated with a safety-related SSC.'-The'quench spray system also contains

environmental qualification components and supports'fire protection and station blackout.

Intended functions within the scope of license'renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

* provides for vortex suppression

* restricts flow

* provides a spray pattern

In LRA Table 2.3.2-2, the applicant identified the following quench spray system component

types that are within the scope of license renewal and subject to an AMR: bolting; flow

elements; pipe; pumps; RWST; restricting orifices; spray nozzles; tubing; and valves.,

2.3B.2.2.2 Staff Evaluation ; I-;: .

The staff reviewed LRA Section 2.3.2.2'and Millstone FSAR Section 6.2.2. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and."

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with'intended ' functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA'to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1). : - * ..

. ! :.. ,'cS.i, ._

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The staff's review of LRA Section 2.3.2.2 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In RAI SPSB-5, the staff requested the applicant to verify whether the refueling water coolers

3-QSS-EIA and EIB in the quench spray system, described on LRA drawing 25212-LR26915

sheet 1, refueling water recirculating pumps, have been included in the scope of license

renewal and subject to an AMR, or to provide an explanation for their exclusion. In its response

dated November 9, 2004, the applicant stated that the NSR RWST coolers shown on LR

drawing 25212-LR26915, sheet 1, were not originally included within the scope of license

renewal because the RWST temperature is maintained within limits in accordance with TS

requirements. However, these coolers and associated piping and valves, were added to scope

as NSR components spatially oriented such that their failure could prevent the function of

safety-related SSCs. The stainless steel RWST cooler channel heads, piping, and valves are

subject to loss of material in a treated water internal environment and in an

atmosphere/weather external environment. This aging effect is managed by the chemistry

control for primary systems program internally and the general condition monitoring AMP

externally. The cooler shell, and cooling water piping, and valves, are carbon steel and are

subject to loss of material in the treated water internal environment and in the

atmospherelweather external environment. The loss of material of internal surfaces is managed

by the closed-cycle cooling water system AMP and external aging is managed by the general

condition monitoring AMP. The staff finds this acceptable.

The staff found the applicant's response to RAI SPSB-5 acceptable, and the refueling water

coolers and associated components are within the scope of license renewal. Therefore, the

staff considers its concern described in RAI SPSB-5 resolved.

2.3B.2.2.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the quench spray system components that are within the scope of license renewal, as required

by 10 CFR 54.4(a), and that the applicant has adequately identified the quench spray system

components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.2.3 Safety Injection System

2.3B.2.3.1 Summary of Technical Information in the Application

In LRA Section 2.3.2.3, the applicant described the safety injection (SI) system. The purpose of

the SI system is to provide a source of borated water to the RCS to ensure that the reactor is

shutdown and to cool the core in the event of a design-basis accident. The SI system consists

of the SI pumps, accumulators, and associated piping and components. The centrifugal

charging pumps, described In LRA Section 2.3.3.15 Chemical and Volume Control System; and

the residual heat removal pumps, described In LRA Section 2.3.2.4 Residual Heat Removal

System, also provide SI flow to the RCS.

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The Si system provides injection of borated water.into the RCS following an accident, control of

reactor core boron precipitation during long-term LOCA recovery,-RCS press'ure boundary

integrity, containment pressure boundary integrity, and RG 1.97 safety-related indications. The

Sl system contains NSR components that are spatially oriented such that their failure could

prevent the satisfactory accomplishment of a safety-related function associated with a safetyrelated SSC. The Si system also contains environmental qualification components and'supportsfire protection and station blackout. --

Intended functions within the scope of license renewal include the following:

* ~provides limited structural integrity

* provides a pressure boundary

* restricts flow

In LRA Table 2.3.2-3, the applicant identified the following SI system component types that are

within the scope of license renewal and subject to an AMR: bolting; filter/strainers; flow

elements; pipe; pumps; restricting orifices; SI accumulator tanks; SI pump lube oil coolers; Si

pump lube oil reservoirs; tubing; and valves.

2.3B.2.3.2 Staff Evaluation .

The staff reviewed LRA Section 2.3.2.3 and Millstone FSAR Section 6.3. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.2.3.3 Conclusion -. .:

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the safety injection system components that are within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the safety

injection system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1)."

2.3B.2.4 Residual Heat Removal System -

2.B3.2.4.1 Summary of Technical Information in the Application

In LRA Section 2.3.2.4, the applicant described the residual heat removal system. The residual

heat removal system transfers heat from the RCS to the reactor plant component cooling

system via the residual heat removal system heat exchangers during plant cooldown and cold

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shutdown operations. The residual heat removal system pumps also provide low-pressure SI

flow from the RWST in response to a major primary system pipe rupture within the containment.

The residual heat removal system provides SI flow following a LOCA, a flow path for cold-leg

and hot-leg recirculation during long-term accident recovery, heat removal from the RCS for

plant cooldown, overpressure protection for the RCS during shutdown conditions, RG 1.97

safety-related indications, RCS pressure boundary integrity, and containment pressure

boundary integrity. The residual heat removal system contains NSR components that are

spatially oriented such that their failure could prevent the satisfactory accomplishment of a

safety-related function associated with a safety-related SSC. The residual heat removal system

also contains environmental qualification components and supports fire protection and station

blackout.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.2-4, the applicant identified the following residual heat removal system

component types that are within the scope of license renewal and subject to an AMR: bolting;

flow elements; pipe; pump seal coolers; pumps; residual heat removal heat exchangers; tubing;

and valves.

2.3B.2.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.4 and Millstone FSAR Section 5.4.7. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.2.4.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the residual heat removal system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

residual heat removal system components that are subject to an AMR, as required by

10 CFR 54.21 (a)(1).

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2.3B.2.5 Fuel Pool Cooling and Purification System

2.3B.2.5.1 Summary of Technical Information in the Application

In LRA Section 2.3.2.5, the applicant described the fuel pool cooling and purification system.

The fuel pool cooling and purification system removes decay heat generated by spent fuel

assemblies stored in the spent fuel pool. Heat is transferred from the pool water to the reactor

plant component cooling system. -

The fuel pool cooling and purification system provides heat removal from the spent fuel pool,

containment pressure boundary integrity, and RG 1.97 safety-related indications. The fuel pool

cooling and purification system contains NSR components that are spatially oriented such that

theirfailure could prevent the satisfactory accomplishment of a safety-related function:

associated with a safety-related SSC. The fuel pool cooling and purification system also

contains environmental qualification components and supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity . -

* provides a pressure boundary

* -. provides for vortex suppression

In LRA Table 2.3.2-5, the applicant identified the following fuel pool cooling and purification

system component types that are within the scope of license renewal and subject to an AMR:

bolting; flow elements; fuel pool coolers; pipe; pumps; tubing; valves; and vortex suppressor.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the fuel 'pool cooling and purification system. In'its:,

December.3, 2004, RAI'response, the applicant identified the following component types that

were added to the scope of the fuel pool cooling and purification system:

* fuel pool demineralizer

* fuel pool post filter

* strainers

2.3B.2.5.2 Staff Evaluation l

The staff reviewed LRA Section 2.3.2.5 and Millstone FSAR Section 9.1.3. The staffs review,

using the evaluation methodology'described inSection 2.3 of this SER,-was conducted in'

accordance with the guidance described in Section 2.3 of NUREGI1800.

In conducting its review, the staff evaluated the system functions' described in the LRA-and

Millstone FSAR in accordance with the requirements' of l -CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

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-4-N

The staff's review of LRA Section 2.3.2.5 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

The Millstone FSAR states that water from the safety-related SW system can be used as an

emergency supply to the spent fuel pool. In addition, water from the fire protection system and

borated water from the refueling water storage tank, a Seismic Category-I tank, is available. A

license renewal drawing shows the portion of the SW system as within the scope of license

renewal and subject to an AMR. However, only a portion of the quench spray from the refueling

water storage tank is shown to be within the scope of license renewal and subject to an AMR.

The piping and valves that lead to the fuel pool from this location are not shown to be within the

scope of license renewal and subject to an AMR. In RAI 2.3.2.5-1 B, dated June 9, 2004, the

staff requested the applicant to explain the apparent exclusion of the sources of make-up water

to the fuel pool from the various sources from the scope of license renewal and from being

subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that, as stated in the Millstone Unit 3

FSAR, the spent fuel pool is a missile-protected, seismically-designed, reinforced concrete

structure with a stainless steel liner. Each pipe that enters the fuel pool has an anti-siphoning

device or terminates at an elevation above the minimum fuel pool water level to prevent

siphoning the fuel pool water and uncovering the spent fuel. The combination of these design

features makes significant loss of fuel pool water extremely unlikely. In addition, the spent fuel

pool liner is within the scope of license renewal and is managed for the effects of aging, as

described in the Section 2.4.2.4, such that significant leakage is not expected. FSAR Section

9.1.3.2 discusses each of the sources of make-up water to the spent fuel pool for

completeness. The safety-related SW system has been identified with the intended function to

provide an emergency supply of fuel pool make-up in the LRA Section 2.3.3.2. Other fuel pool

make-up sources discussed in the FSAR are available but are not assigned a fuel pool makeup intended function. Consequently, the applicant concluded that the fuel pool make-up flow

path from the refueling water storage tank via quench spray is not within the scope of license

renewal for. its fuel pool make-up capability.

The staff finds the applicant's response to RAI 2.3.2.5-1 B acceptable, because adequate

explanation that a source of make-up water to the fuel pool from the SW system is credited for

this purpose in the Millstone FSAR and is within the scope of license renewal. Therefore, the

staffs concern described in RAI 2.3.2.5-1 B is resolved.

The staff also reviewed the results of the scoping methodology changes, due to response to

RAI 2.1-1 that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the fuel pool cooling and purification system expanded

scope of mechanical components identified in the December 3, 2004, response acceptable,

because the applicant adequately included the NSR components with the configurations that

meet the scoping criterion of 10 CFR 54.4(a)(2) with spatial and/or attached piping interaction

with safety-related SSCs. The staff concluded that the applicant's December 3, 2004, response

related to the scoping and screening results of the fuel pool cooling and purification system is

acceptable.

2-146
2.3B.2.5.3 Conclusion -

The staff reviewed the LRA, the accompanying scoping boundary drawing, and RAI responses

described above to determine whether any.SSCs that should be within the scope of license

renewal were not identified by the applicant; No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the fuel pool cooling and purification system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

fuel pool cooling and purification system components that are subject to an AMR,'as required

by 10 CFR 54.21 (a)(1).

2.3B.3 Auxiliary Systems

In LRA Section 2.3.3, the applicant identified the structures and components of the auxiliary

systems that are subject to an AMR for license renewal.,

The applicant described the supporting structures and components of the auxiliary systems in

the following sections of the LRA:

* 2.3.3.1

* 2.3.3.2

* 2.3.3.3

* 2.3.3.4

* 2.3.3.5

* 2.3.3.6

* 2.3.3.7

* 2.3.3.8

* 2.3.3.9

* 2.3.3.10

* 2.3.3.11

* 2.3.3.12

* 2.3.3.13

* 2.3.3.14

* - - 2.3.3.15

* 2.3.3.16

* 2.3.3.17

* 2.3.3.18

* 2.3.3.19

* 2.3.3.20

* 2.3.3.21

* 2.3.3.22

* 2.3.3.23

* 2.3.3.24

* 2.3.3.25

* 2.3.3.26-

* 2.3.3.27

* 2.3.3.28

* 2.3.3.29

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 I

primary grade water system

auxiliary building ventilation system

circulating and service water pumphouse ventilation system

containment air filtration system

containment air recirculation system

containment purge air system -

containment leakage monitoring system

containment vacuum system

control building ventilation system

CRDM ventilation and cooling system

emergency generator enclosure ventilation system

engineered safety features building ventilation system

fuel building ventilation system

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.LM

* 2.3.3.30 hydrogen recombiner and hydrogen recombiner building HVAC system

* 2.3.3.31 main steam valve building ventilation system

* 2.3.3.32 process, effluent and airborne radiation monitoring system

* 2.3.3.33 service building ventilation and air-conditioning system

* 2.3.3.34 station blackout diesel generator building ventilation system

* 2.3.3.35 supplementary leak collection-and-release system

* 2.3.3.36 technical support center HVAC and filtration system

* 2.3.3.37 turbine building area ventilation system

* 2.3.3.38 waste disposal building ventilation system

* 2.3.3.39 Unit 2 fire protection system

* 2.3.3.40 Unit 3 fire protection system

* 2.3.3.41 domestic water system

* 2.3.3.42 emergency diesel generator system

* 2.3.3.43 emergency diesel generator fuel oil system

* 2.3.3.44 station blackout diesel generator system

* 2.3.3.45 security system

* 2.3.3.46 boron recovery system

* 2.3.3.47 radioactive liquid waste processing system

* 2.3.3.48 radioactive gaseous waste system

* 2.3.3.49 post-accident sampling system

* 2.3.3.50 radioactive solid waste system

* 2.3.3.51 reactor plant aerated drains system

* 2.3.3.52 reactor plant gaseous drains system

* 2.3.3.53 sanitary water system

The corresponding subsections of this SER (2.3B.3.1 - 2.3B.3.53, respectively) present the

staff's related review findings.

2.3B.3.1 Circulating Water System

2.3B.3.1.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.1, the applicant described the circulating water system. The circulating

water system provides a supply of cooling water to the main condenser via six vertical wet-pit

pumps, which circulate water from the intake structure through the main condenser to the

discharge structure. The circulating water pumps take suction on Long Island Sound. A warm

water recirculation flowpath is provided to circulate condenser outlet water to the intake

structure to reduce ice formation.

The circulating water system provides warm water recirculation to the intake structure for deicing to ensure service water system availability.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-1, the applicant identified the following circulating water system component

types that are within the scope of license renewal and subject to an AMR: expansion joints;

pipe; and valves.

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2.3B.3.1.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.1 and Millstone FSAR Sections 2.4.11.6, 9.2.5, and

10.4.5. The staffs review, using the evaluation methodology described in Section 2.3 of this

SER, was conducted in accordance with the guidance described in Section 2.3 of

NUREG-180OIn conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.38.3.1.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the circulating water system components that are within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the circulating

water system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3B.3.2 Service Water System

2.38.3.2.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.2, the applicant described the service water (SW) system. The purpose of

the SW system is to provide a dependable flow of cooling water to the following safety-related

and NSR loads: -

* reactor plant component cooling heat exchangers

* turbine plant component cooling heat exchangers

* emergency generator diesel engine coolers

* containment recirculation coolers -

* control building HVAC condensers

* containment recirculation pump ventilation units:

* residual heat removal pump ventilation units

* charging pump coolers

* safety injection pump coolers - -

* post-accident liquid sample cooler I

* motor controller center and rod control area ventilation units

The system also provides a source of lubrication water for the circulating water pump bearings.

The SW system also provides a back-up water source for spent fuel pool make-up, auxiliary feedwater pump suction, and control building chilled water.

2-149 -
The SW system provides cooling water flow to safety-related heat loads to transfer rejected

heat to the ultimate heat sink; isolating NSR heat loads in the event of a design-basis accident;

providing a back-up source of water for control building chilled water, spent fuel pool make-up,

and auxiliary feedwater; and providing RG 1.97 safety-related indications. The SW system

contains NSR components that are spatially oriented such that their failure could prevent the

satisfactory accomplishment of a safety-related function associated with a safety-related SSC.

The SW system also provides environmental qualification equipment and supports station

blackout and fire protection.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

* provides filtration

* restricts flow

In LRA Table 2.3.3-2, the applicant identified the following SW system component types that

are within the scope of license renewal and subject to an AMR: expansion joints; filter/strainers;

flow elements; pipe; pumps; restricting orifices; spool piece; tubing; and valves.

2.31B.3.2.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.2 and Millstone FSAR Sections 6.2.2, 7.3.1.1, 8.3.1,

9.1.3, 9.2.1, 9.2.2, and 9.2.5. The staffs review, using the evaluation methodology described in

Section 2.3 of this SER, was conducted in accordance with the guidance described in Section

2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.3.2 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that a license renewal drawing for the SW system shows an in-line

flow indicator within the scope of license renewal and subject to an AMR. However, this

component is not listed in LRA Table 2.3.3-2 as a component type subject to an AMR. In-line

flow indicators serve a pressure boundary intended function, and are passive and long-lived

components. In RAI 2.3.3.2-1 B, dated June 9, 2004, the staff requested the applicant to confirm

that the in-line flow indicator is included with the components listed in LRA Table 2.3.3-2.

In its response, dated July 26, 2004, the applicant stated that the flow indicator incorporates a

straight piece of pipe with a pilot tube for measuring differential pressure and is included in the

component type, "Pipe," in LRA Table 2.3.3-2.

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The staff finds the applicant's response to RAI 2:3.3.2-1 B acceptable, because the flow

indicator was adequately identified and shown where it appeared in LRA Table 2.3.3-2. The

staff concludes that the in-line flow indicator in-the SW system was scoped in accordance withthe requirements of 10 CFR 54.4(a) and screened in accordance with the requirements of

10 CFR 54.21(a)(1). Therefore, the staff's concern described in RAI 2.3.3.2-1B is resolved.

In its review, the staff also noted that a license renewal drawing for the SW system shows

thermowells excluded from the scope of license renewal and from being subject to an AMR.

Thermowells normally penetrate the piping pressure boundary and therefore serve a pressure

boundary intended function. Thermowells are also passive and long-lived components and

should be subject to an AMR. In RAI 2.3.3.2-2B, dated June 9, 2004, the staff requested the

applicant to confirm that the thermowells are included with the components listed in LRA Table'

2.3.3-2.

In its response, dated July 26, 2004, the applicant stated that thermowells are within the scope

of license renewal and are included in component type,M"Pipe," in LRA Table 2.3.3-2.

The staff finds the applicant's response to RAI 2.3.3.2-2B acceptable, because thermowells

were adequately identified and specified how they were represented in LRA Table 2.3.3-2. The

staff concludes that thermowells in the SW system were scoped in accordance with the

requirements of 10 CFR 54.4(a) and screened in accordance with the requirements of

10 CFR 54.21 (a)(1). Therefore, the staff's concern described in RAI 2.3.3.2-2B is resolved.

Another license renewal drawing for the SW system indicates that a portion of the system that

extends to the plant drainage system is within' the scope 'of license renewal and subject to an

AMR. The portion of the SW system that appears on the plant drainage system drawing is not

included in the LRA. In RAI 2.3.3.2-3B, dated June 9, 2004, the staff requested the applicant to

supply the drawing that contains the remainder of the SW system.

In its response, dated July 26, 2004, the applicant stated that the drawing for the plant drainage

system shows only miscellaneous floor drains, none of which are within the scope of license

renewal. The drainage lines shown on the SW system license renewal drawing are not

continued on the plant drainage drawing because the drain lines are open-ended lines that

discharge to, but are not connected to,-the associated floor area drains. Therefore, the license

renewal boundary'terminates at the discharge of the 'drain line.

The staff finds the applicant's response to RAI 2.3.3.2-3B acceptable, because the applicant

verified that all the components within the license renewal system evaluation boundary for the

service water system have been shown on thOliCen~&_reniewal drawings. The staff concludes

that all the components of the SW system were scoped in accordance with the requirements of

10 CFR 54.4(a) and screened in accordance with the requirements of 10 CFR 54.21(a)(1).

Therefore, the staff's concern described in RAI 2.3.3.3-3B is resolved.

2.3B.3.2.3 Conclusion i: E ' 4 .,:.:.' ''

The staff reviewed the LRA, the accompanying scoping boundary drawings; and RAI -responses

described above to determine whether any SSCs that should be within the scope of licenserenewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should 'be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

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staff concludes that there is reasonable assurance that the applicant has adequately identified

the SW system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the SW system components

that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3B.3.3 Sodium Hypochlorite System

2.38.3.3.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.3, the applicant described the sodium hypochlorite system. The sodium

hypochlorite system provides a source of sodium hypochlorite to minimize marine growth in the

SW system and the circulating water system.

The sodium hypochlorite system provides a safety-related pressure boundary for the SW

system and provides RG 1.97 safety-related indications. The sodium hypochlorite system

contains NSR components that are spatially oriented such that their failure could prevent the

satisfactory accomplishment of a safety-related function associated with a safety-related SSC.

The sodium hypochlorite system also supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-3, the applicant identified the following sodium hypochlorite system

component types within the scope of license renewal and subject to an AMR: pipe and valves.

2.38.3.3.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.3 and Millstone FSAR Sections 9.2.1 and 9.2.4. The

staffs review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.38.3.3.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the sodium hypochlorite system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

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sodium hypochlorite system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3B.3.4 Reactor Plant Component Cooling System

2.3B.3.4.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.4, the applicant described the reactor plant component cooling (RPCC)'

system. The RPCC system is a closed-loop cooling system that transfers'heat from reactor

auxiliaries to the SW system during plant operation and accident conditions. The RPCC system

also provides make-up water to various cooling subsystems.

The RPCC system transfers heat from safety-related heat loads to the ultimate heat sink,

providing automatic isolation of non-essential heat loads in the evefit of a design-basis

accident, providing a source of make-up water to essential systems, providing RG 1.97 safetyrelated indications, preventing an over-temperature condition at the residual heat removal heat

exchanger outlet, and providing containment pressure-boundary integrity. The RPCC system

contains NSR components that are spatially oriented such that their failure could prevent the

satisfactory accomplishment of a safety-related function associated with a safety-related SSC.

The system contains environmental qualification equipment and supports fire protection and

station blackout.

Intended functions within the scope of license renewal include the following:

provides limited structural integrity

* provides a pressure boundary -

* provides for heat transfer

In LRA Table 2.3.3-4, the applicant identified the following RPCC system component types that

are within the scope of license renewal and subject to an AMR: flow'elements; flow totalizer;

hoses; penetration coolers; pipe; pumps; RPCC chemical addition tank; RPCC heat

exchangers; RPCC surge tank; tubing; and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the RPCC system. In its December 3, 2004, RAI

response, the applicant identified the radiation detectors component type that was added to the

scope of the RPCC system. -

2.3B.3.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.4 and Millstone FSAR Section 9.2.2.4. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section' 2.3 of NUREG-1800.

In conducting its review,-the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended,-

functions delineated in 10 CFR 54.4(a).-The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1). - -

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I U

The staffs review of LRA Section 2.3.3.4 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that a license renewal drawing for the RPCC system shows a line

that ends at a relief valve. It appears that this relief valve is used to protect the in-scope piping

and components from over-pressurization. Although the line is shown within the scope of

license renewal, the relief valve is shown as outside the scope of license renewal. Relief valves

provide pipeline isolation and serve a pressure boundary function. In RAI 2.3.3.4-1 B, dated

June 9, 2004, the staff requested the applicant to explain why the relief valve is not included

within the scope of license renewal and subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that the relief valve is within the scope

of license renewal but was inadvertently not highlighted on the license renewal drawing. This

relief valve is included in the component type, "Valves," in LRA Table 2.3.3-4.

The staff finds the applicant's response to RAI 2.3.3.4-1 B acceptable based on inclusion of the

component.

The staff also noted that a license renewal drawing for the RPCC system shows auxiliary

condensate heat exchanger shells within the scope of license renewal and subject to an AMR.

However, these heat exchanger shells are not listed in LRA Table 2.3.3-4 as a component type

subject to an AMR. In RAI 2.3.3.4-2B, dated June 9, 2004, the staff requested the applicant to

explain whether these components were included with another component type or to explain

their exclusion from the scope of license renewal and from being subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that the auxiliary condensate heat

exchanger shells are coolers shown on the license renewal drawing and are within the scope of

license renewal and subject to AMR. These coolers are part of the auxiliary boiler condensate

and feedwater system and are indicated as "Sample Coolers" in LRA Table 2.3.4-7. The

sample coolers were inadvertently highlighted as part of the RPCC system.

The staff finds the applicant's response to RAI 2.3.3.4-2B acceptable, because the applicant

adequately explained that the auxiliary condensate heat exchanger shells are within the scope

of license renewal in accordance with the requirements of 10 CFR 54.4(a). The applicant

further identified where the auxiliary condensate heat exchanger shells are represented in the

LRA. Therefore, the staff's concern described in RAI 2.3.3.4-2B is resolved.

In RAI 2.3.3.4-3B, the staff noted that in Millstone LRA Section 2.1.5.1 states that "a normallyopen manual valve may be used as a license renewal boundary in those instances where a

failure downstream of the valve can be quickly detected and the valve can be easily closed by

operators to establish the pressure boundary."

Another license renewal drawing for the RPCC system shows many normally open valves that

are used as license renewal system boundaries. In order for the staff to complete its review to

ensure that the system evaluation boundaries chosen for the RPCC system would permit

successful performance of its system-level intended functions more information is needed. In

RAI 2.3.3.4-2B, dated June 6, 2004, the staff requested the applicant to discuss procedures for

identifying the locations of breaks and for closing the valves, the amount of time required to

2-154
complete these actions, and the consequences on system inventory if the valves are not

closed. -

In its response, dated July 26, 2004, the applicant stated that the license renewal boundaries

ending at normally open valves on the license renewal drawings for the RPCC system were not

drawn using the convention from LRA Section 2.1.5.1. Instead, the components highlighted in

lines associated with these normally open valves are within the scope of license renewal

because they are NSR components spatially oriented near safety-related SSCs. The applicant

further stated that the conventions used in license renewal drawings to highlight how to end

boundaries at normally open valves is described in LRA Section 2.1 5.1. Normially open valves

outside the area containing safety-related SSCs were used to identify the license renewal

boundary, in accordance with the convention in LRA Section 2.1.5.1. Whether the valves are ian open or closed status is not relevant, because breaks beyond these normally open valves do

not have the potential to adversely impact safety-related SSCs.

The staff finds the applicant's response to RAI 2.3.3.4-3B acceptable, because the applicant

adequately explained that the normally-open valves chosen as license renewal boundaries are

within the scope of license renewal in accordance with the requirements of 10 CFR 54.4(a)(2)

for their potential spatial impact on safety-related equipment. The applicant further confirmed

that breaks beyond the normally open valves in the RPCC system would not functionally

prevent the satisfactory accomplishment of the system-level intended functions. Therefore, the

staff's concern described in RAI 2.3.3.4-3B is resolved.

The staff also reviewed the results of the scoping methodology changes, due to response to

RAI 2.1-1, that are described in the applicant's responses dated November 9,'2004, and

December 3, 2004. The staff finds the RPCC system expanded scope of mechanical

components identified in the December 3,-2004, response acceptable, because the applicant

included the'NSR components with the configurations that meet the scoping criteria of

10 CFR 54.4(a)(2) with spatial and/or attached piping interaction with safety-related SSCs. The

staff concluded that the applicant's December 3, 2004, response related to the scoping and

screening results of the RPCC system is acceptable. -

2.3B.3.4.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawing, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the RPCC system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the RPCC system components

that are subject to an AMR, as required by 10 CFR 54.21(a)(1). -

2.3B.3.5 Turbine Plant Component Cooling Water System

2.3B.3.5.1. Summary of Technical Information in the Application,

In LRA Section 2.3.3.5, the applicant described the turbine plant component cooling water

system. The turbine plant component cooling water system transfers heat from various turbine

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plant heat loads to the SW system. A portion of the system provides a flowpath for back-up

cooling water flow to the instrument air compressors from the domestic water system.

The turbine plant component cooling water system provides a cooling water flowpath for the

instrument air compressor that is credited for fire protection.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-5, the applicant identified the following turbine plant component cooling

water system component types that are within the scope of license renewal and subject to an

AMR: flow indicators; pipe; strainers; and valves.

2.3B.3.5.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.5 and Millstone FSAR Section 9.2.7. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.3.5 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that LRA Section 2.3.3.5 states that the turbine plant component

cooling water system provides a cooling water flow path for the instrument air compressor

needed for fire protection. In order for the staff to complete its review of the system evaluation

boundaries for the turbine plant component cooling water system more information about why

only instrument air compressor train B is shown within the scope of license renewal. In RAI

2.3.3.5-1 B, dated June 9, 2004, the staff requested the applicant to explain why the turbine

plant component cooling water system flow path to instrument air compressor train A is

excluded from the scope of license renewal and from being subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that the instrument air compressor

credited in the plant fire protection evaluations is compressor B. Compressor B is powered from

a Class 1 E power source. Instrument air compressor A has not been credited in the plant fire

protection evaluations. Therefore, instrument air compressor train A and the turbine plant

component cooling water to that compressor have not been included within the scope of license

renewal.

The staff concluded that the applicant's July 26, 2004, response related to the scoping and

screening results of the turbine plant component cooling water system is acceptable.

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2.3B.3.5.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the turbine plant component

cooling water system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the turbine plant component

cooling water system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3B.3.6 Chilled Water System

2.3B.3.6.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.6, the applicant described the chilled water system. The chilled water

system is a closed-loop system that provides cooling water for the RWST, service building airconditioning units, MCC and rod control area air conditioning units, containment air recirculation

cooling coils, and various components inside the containment. - -

The chilled water system provides a pressure boundary at interfaces with safety-related

systems, providing containment pressure boundary integrity, and providing RG 1.97 indications.

The chilled water system contains NSR components that are spatially oriented such that their

failure could prevent the satisfactory accomplishment of a safety-related function associated

with a safety-related SSC. The system contains environmental qualification equipment and

supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides limited structural integrity

In LRA Table 2.3.3-6, the applicant identified the following chilled water system component

types that are within the scope of license renewal and subject to an AMR: flow elements; flow

indicators; hoses; pipe; tubing; and valves.'

2.31B.3.6.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.6 and Millstone FSAR Section 9.2.2.2. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended - .

functions delineated in 10 CFR 54.4(a).JThe staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

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2.3B.3.6.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the chilled water system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the chilled water

system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.3.7 Charging Pumps Cooling System

2.3B.3.7.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.7, the applicant described the charging pumps cooling system. The

purpose of the charging pumps cooling system is to transfer heat from the charging pump

lubricating oil to the SW system.

The charging pumps cooling system provides cooling for the charging pump lubricating oil and

RG 1.97 safety-related indications. The charging pumps cooling system contains NSR

components that are spatially oriented such that their failure could prevent the satisfactory

accomplishment of a safety-related function associated with a safety-related SSC. The system

contains environmental qualification equipment and supports fire protection and station

blackout.

Intended functions within the scope of license renewal include the following:

* provides for heat transfer

* provides a pressure boundary

* provides limited structural integrity

In LRA Table 2.3.3-7, the applicant identified the following charging pumps cooling system

component types that are within the scope of license renewal and subject to an AMR: charging

pump coolers; charging pumps cooling surge tank; flow elements; pipe; pumps; tubing; and

valves.

2.3B.3.7.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.7 and Millstone FSAR Section 9.2.2.4. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

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The staffs review of LRA Section 2.3.3.7 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that the FSAR states that the charging pump's cooling system

surge tank is compartmented by an internal partition so that a rapid loss of water from one

compartment of the surge tank affects only one charging pump's cooling pump, leaving the

other charging pump's cooling system pump unaffected and fully capable of service. However,

the license renewal drawing shows the surge tank internal partition as outside the scope of

license renewal and not subject to an AMR. In RAI 2.3.3.7-1 B, dated June 9, 2004, the staff

requested the applicant to explain the apparent exclusion of the internal surge tank partition

from the scope of license renewal and from being subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that the internal surge tank partition

was inadvertently not highlighted, but is within the scope of license renewal. The partition was

evaluated as an integral part of the component type, "Charging Pump's Cooling Surge Tank,"

shown in LRA Table 2.3.3-7.

In its review, the staff finds the applicant's response to RAI 2.3.3.7-1 B acceptable based on

inclusion of the component.

2.3B.3.7.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawing, and RAI response

described above to determine whether any SSCs that should be within' the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has-adequately identified

the charging pumps cooling system components that are within the scope of license renewal,-

as required by10 CFR 54.4(a), and that the applicant has adequately identified'the charging

pumps cooling system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3B.3.8 Safety Injection Pumps Cooling System

2.36.3.8.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.8, the applicant described the safety injection'pumps cooling system. The

purpose of the SI pumps cooling system is to transfer heat from the SI pump bearing lubricating

oil to the SW system.

The SI pumps cooling system provides cooling for the SI pump lubricating oil and RG 1.97

safety-related indications. The SI pumps cooling system contains NSR components that are

spatially oriented such that their failure could prevent the satisfactory accomplishment of a

safety-related function associated with a safety-related SSC. The system contains

environmental qualification equipment and supports fire protection.

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Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides limited structural integrity

* restricts flow

* provides for heat transfer

In LRA Table 2.3.3-8, the applicant identified the following Si pumps cooling system component

types that are within the scope of license renewal and subject to an AMR: flow elements; pipe;

pumps; restricting orifices; SI pump coolers; SI pumps cooling surge tank; tubing; and valves.

2.3B.3.8.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.8 and Millstone FSAR Section 9.2.2.5. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.3.8 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that the FSAR states that the SI pumps cooling system surge tank

is compartmented by an internal partition so that a rapid loss of water from one compartment of

the surge tank affects only one Si cooling pump, leaving the other SI cooling system pump

unaffected and fully capable of service. However, a license renewal drawing for the SI pumps

cooling system shows the surge tank internal partition as outside the scope of license renewal

and not subject to an AMR. In RAI 2.3.3.8-1 B, dated June 9, 2004, the staff requested the

applicant to explain the apparent exclusion of the internal surge tank partition from the scope of

license renewal and from being subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that the internal surge tank partition

was inadvertently not highlighted, but is within the scope of license renewal. The partition was

evaluated as an integral part of the component type, 'Safety Injection Pump's Cooling Surge

Tank," shown in LRA Table 2.3.3-8.

The staff concluded that the applicant's July 26, 2004, response related to the scoping results

of the safety injection pumps cooling system is acceptable.

2.3B.3.8.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawing, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

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performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assuradce' that the applicant has adequately identified

the SI pumps cooling system components that'are within the scope of license renewal, as

required by 10 CFR 54.4(a),'and that the'applicant has adequately identified the SI pumps

cooling system components that are subject to anrAMR, as required by 10 CFR 54.21 (a)(1).

2.3B.3.9 Neutron Shield Tank Cooling System

2.3B.3.9.1 Summary of Technical Information'in the Application

In LRA Section 2.3.3.9, the applicant described the neutron shield tank cooling system. The

purpose of the neutron shield tank cooling system is to cool the water circulated through the

neutron shield tank, which is heated by neutron and gamma radiation from the reactor. The

neutron shield tank cooling system also provides attenuation of neutrons via the water-filled

neutron shield tank. The neutron shield tank cooling system includes the neutron shield tank,

the neutron shield tank coolers, neutron shield tank cooling surge tank, and associated piping

and components.

The neutron shield tank cooling system contains NSR components that are spatially oriented

such that their failure could prevent the satisfactory accomplishment of a safety-related function

associated with a safety-related SSC, provides neutron moderation in'support of the nuclear

instrumentation function, and provides cooling of the water surrounding the neutron detectors

located in the neutron shield tank.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-9, the applicant identified the following neutron shield tank cooling system

component types that are within the scope of license renewal and subject to an AMR: neutron

shield tank; neutron shield tank coolers; neutron shield tank surge tank; pipe; tubing; and

valves.

2.3B.3.9.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.9 and Millstone FSAR Section 9.2.2.3. The staffs review,

using the evaluation methodology'described iri'Section 2.3 of this SER, was conducted in

accordahce with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements 6f 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR'54.21 (a)(1).

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2.3B.3.9.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the neutron shield tank cooling system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the neutron shield tank cooling system components that are subject to an AMR, as

required by 10 CFR 54.21(a)(1).

2.3B.3.10 Containment Atmosphere Monitoring System

2.3B.3.10.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.10, the applicant described the containment atmosphere monitoring

system. The containment atmosphere monitoring system provides the capability to obtain,

analyze, and return atmosphere samples to the containment.

The containment atmosphere monitoring system provides a containment pressure boundary

integrity and isolation function and safety-related RG 1.97 indications. The containment

atmosphere monitoring system contains environmental qualification equipment.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-10, the applicant identified the following containment atmosphere monitoring

system component types that are within the scope of license renewal and subject to an AMR:

bolting; pipes; and valves.

2.3B.3.10.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.10 and Millstone FSAR Section 11.5.2.2.9. The staffs

review, using the evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3B.3.10.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

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AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the containment atmosphere monitoring system components that are within the scope

of license renewal, as required by 10 CFR 54:4(a), and that the applicant has adequately

identified the containment atmosphere monitoring system components that are subject to an

AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.3.11 Containment Instrument Air System

2.3B.3.1 1.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.11, the applicant described the'containment instrument air system. The

containment instrument air system is 'supplied by the instrument air system and 'provides a

reliable source of clean, dry, oil-free compressed air at the proper pressure to supply airoperated valves, instruments, and other miscellaneous components in the containment. The

system provides compressed air to operate valves associated with reactor coolant letdown and

pressurizer spray for a fire in the containment.

The containment instrument air system supports fire protection.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-11, the applicant identified the following containment instrument air system

component types that are within the scope of license renewal and subject to an AMR: bolting;

pipe; tubing; and valves.

2.3B.3.11.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.11 and Millstone FSAR Section 9.3.1.2. The staffs

review, using the evaluation methodology described'in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1 800. - ', ' .. ,. { .

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license'renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.3.11.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant; No omissions were identified. In addition,

the staff performed a review to determine whether any'components that should be subject to an

AMR were not identified by the applicant.' No omissions were identified. On' the basis of its , ., * fi * ~~-- -";

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review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the containment instrument air system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the containment instrument air system components that are subject to an AMR, as

required by 10 CFR 54.21 (a)(1).

2.3B.3.12 Instrument Air System

2.3B.3.12.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.12, the applicant described the instrument air system. The instrument air

system provides a reliable source of clean, dry, oil-free compressed air at the proper pressure

to supply air-operated valves, instruments, and other miscellaneous components in the plant.

The instrument air system provides containment pressure boundary integrity and safety-related

RG 1.97 indications. The instrument air system contains environmental qualification equipment

and supports fire protection.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-12, the applicant identified the following instrument air system component

types that are within the scope of license renewal and subject to an AMR: air dryers; filters;

instrument air aftercooler, instrument air compressor, instrument air filter silencer, instrument air

receiver, pipe; strainers; traps; tubing; and valves.

2.36.3.12.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.12 and Millstone FSAR Section 9.3.1. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of. NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.31.3.12.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the instrument air system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the instrument air

system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

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2.3B.3.13 Nitrogen System

2.3B.3.13.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.13, the applicant described the nitrogen system. The nitrogen system

provides clean, dry gas that is utilized in multiple applications throughout the plant.

The nitrogen system provides containment pressure boundary integrity and safety-related RG

1.97 indications. The nitrogen system contains NSR components that are spatially oriented

such that their failure could prevent the satisfactory accomplishment of a safety-related function

associated with a safety-related SSC. The nitrogen system also provides environmental

qualification equipment and supports fire protection.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-13, the applicant identified the following nitrogen system component types

that are within the scope of license renewal and subject to an AMR: pipe and valves.

2.3B.3.13.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.13 and Millstone FSAR Section 9.5.9.2. The staff's

review, using the evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 5421 (a)(1).

2.3B.3.13.3 Conclusion

The staff reviewed the LRA to determine whether any _SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the nitrogen system components that are within the scope of license renewal, as

required byl10 CFR 54.4(a), and that the applicant has adequately identified the nitrogen

system components that are subject to an AMR,-as required by 10 CFR 54.21(a)(1).

2.3B.3.14 Service AirSystem - ,- .

2.3B.3.14.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.14, the applicant described the service air system. The service air system

provides a source of clean, oil-free compressed air at the proper pressure to support the

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operation of air-operated tools and other devices. The service air system can be used as a

source of compressed air to the instrument air system.

The service air system provides a containment pressure boundary-integrity and a

supplementary leak collection- and-release system boundary isolation function at ESF building

wall penetrations.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-14, the applicant identified the following service air system component types

that are within the scope of license renewal and subject to an AMR: pipe and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the service air system. In its December 3, 2004, RAI

response, the applicant identified the flow transmitters component type that was added to the

scope of the service air system.

2.3B.3.14.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.14 and Millstone FSAR Section 9.3.1. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA andMillstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

The staff s review of LRA Section 2.3.3.14 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAI as discussed below.

In its review, the staff noted that LRA Section 2.3.3.14 stated that the service air system can be

used as a source of compressed air to the instrument air system. The Millstone FSAR states

that during routine maintenance, the service air serves as a backup to the instrument air

system. However, the only portion of service air that was shown to be within the scope of

license renewal and subject to an AMR was the portion that penetrates the containment and

provides a boundary-isolation function at the ESF building wall penetrations. In order to ensure

that the system evaluation boundaries chosen for the service air system would permit

successful performance of its system-level intended functions, the staff requires more

information. In RAI 2.3.3.14-1 B, dated June 9, 2004, the staff requested the applicant to explain

why portions from the service air system that serve as a backup to instrument air were not

included within the scope of license renewal.

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In its response, dated July 26, 2004, the applicant stated that the service air system capability

of providing backup air to the instrument airsystem does not meet the criteria of

10 CFR 54.4(a)(1) or (a)(2). The NSR instrument air system is within the scope of license

renewal because it provides containment pressure boundary integrity at the piping penetration

and it supports fire protection. The fire protection analysis does not credit service air as a

backup. Therefore, the portions of the service air~system that serve as a backup to the

instrument air system are not within the scope of license'renewal.

The staff finds the applicant's response to RAI 2.3.3.14-1B acceptable, because the applicant

adequately explained that while the instrument air system is credited in the fire protection

evaluations, backup air from the service air system is not. Therefore backup compressed air

from the service air system is not required to be within the scope of license renewal. Therefore,

the staffs concern described in RAI 2.3.3.14-1B is resolved.

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and' ' December 3,-2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant'adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The'staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results' of the

service air system is acceptable. - -

2.3B.3.14.3 Conclusion

The staff reviewed the LRA and RAI responses described above to determine whether any

SSCs that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determiine whether any

components that should be subject to an AMR were'not identified by the applicant. No,

omissions were identified. On the basis of its 'review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the service air system

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the service air system components that are subject'

to an AMR, as required by 10 CFR 54.21(a)(1). r- -

2.3B.3.15 Chemical and Volume Control System

2.3B.3.15.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.15, the applicant described the chemical and volume control system

(CVCS).-The CVCS provides a method for controlling the inventory and chemistry of the RCS

and supplies seal injection flow to the RCPs: During normal operation,'reactor coolant letdown

flow is cooled; conditioned via ion exchangers, filters, and chemical addition; heated; and

returned to the RCS. The system also provides the capability to adjust reactor coolant soluble

boron concentration in order to effect reactivity changes within the reactor core. During

emergency conditions, the CVCS charging pumps provide a high-pressure source of borated

water injection to the RCS. -* - -

The CVCS provides a borated water flowpath to the RCS for reactivity control and for safety

injection in the event of an accident. The system also provides RCP seal injection flow; an RCS

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pressure boundary at system interfaces; boration, make-up, and RCP seal injection in support

of safety-grade cold shutdown; decay heat removal, boration, and inventory control during

shutdown conditions; auxiliary pressurizer spray; safety-related RG 1.97 indications; and

containment penetration pressure boundary integrity. The CVCS contains NSR components

credited for mitigating the effects of a high-energy line break and NSR components spatially;

oriented such that a failure could prevent the satisfactory accomplishment of a safety-related

function of a safety-related SSC. The CVCS also contains environmental qualification

equipment and supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

* restricts flow

In LRA Table 2.3.3-15, the applicant identified the following CVCS component types that are

within the scope of license renewal and subject to an AMR: bolting; boric acid blender; boric

acid tanks; charging pump lube oil coolers; chemical mixing tank; chiller surge tank; CS

manifolds; demineralizers; excess letdown heat exchanger; filter/strainers; flexible hoses; flow

elements; letdown chiller heat exchanger; letdown heat exchanger; letdown reheat heat

exchanger, level indicators; lube oil reservoirs; moderating heat exchanger, pipe; pumps; RCP

seal standpipes; regenerative heat exchanger; restricting orifices; seal water heat exchanger;

thermal regeneration chiller compressor oil cooler; thermal regeneration chiller condenser,

thermal regeneration chiller evaporator; tubing; valves; and volume control tank.

2.3B.3.15.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.15 and Millstone FSAR Section 9.3.4. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3B.3.15.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition;

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its.

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the CVCS components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the CVCS components that

are subject to an AMR, as required by 10 CFR 54.21(a)(1).

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2.3B.3.16 Reactor Plant Sampling System

2.3B.3.16.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.16 the applicant described the reactor plant sampling system. The reactor

plant sampling system provides the means for determining chemical and radiological conditions

of plant processes and environments.

The reactor plant sampling system limits loss of inventory through sampling line breaks through

the use of flow restrictions, providing a pressure boundary at interfaces with safety-related

systems, providing containment penetration pressure boundary integrity, and providing safetyrelated RG 1.97 indications. The reactor plant sampling system contains NSR components''

spatially oriented such that a failure' could prevent the satisfactory accomplishment of a'safetyrelated function of a safety-related SSC. The reactor plant sampling system also contains

environmental qualification equipment and supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

* restricts flow

In LRA Table 2.3.3-16, the applicant identified the following reactor plant sampling system

component types that are within the scope of license renewal and subject to an AMR: bolting;

flexible hoses; pipe; tubing; and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the reactor plant sampling system. In its December 3,

2004, RAI response, the applicant identified the following component types that were added to

the scope of the reactor plant sampling system:

* flow elements

* mechanical refrigeration unit condenser

* mechanical refrigeration unit evaporator/chiller

* radiation detectors

2.3B.3.16.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.16 and Millstone FSAR Section 9.3.2. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in -Section 2.3 of NUREG-1 800. -- r K . - -

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from'being subject to an'AMR in accordance with

10 CFR 54.21 (a)(1). -

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The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

reactor plant sampling system is acceptable.

2.38.3.16.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the reactor plant sampling

system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the reactor plant sampling

system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3B.3.17 Primary Grade Water System

2.3B.3.17.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.17, the applicant described the primary grade water system. The primary

grade water system provides demineralized water for use in primary and auxiliary systems in

the plant.

The primary grade water system provides containment penetration pressure boundary integrity

and safety-related RG 1.97 indications. The primary grade water system contains NSR

components spatially oriented such that a failure could prevent the satisfactory accomplishment

of a safety-related function of a safety-related SSC. The primary grade water system also

contains environmental qualification equipment and supports station blackout.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-17, the applicant identified the following primary grade water system

component types that are within the scope of license renewal and subject to an AMR: bolting;

pipe; and valves.

2.3B.3.17.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.17 and Millstone FSAR Section 9.2.8. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

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In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any comPonents with intended'

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted'from beinrg subject to an AMR in accordance with

10 CFR 54.21(a)(1). ' ;

The staffs review of LRA'Section 2.3.3.17 idehtified'an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results; The

applicant responded to the'staff's RAI as discussed below.

In its review, the staff noted that a license renewal 'drawing for the primary grade water system

shows the reactor coolant pressurizer relief tank internal spray line not within the scope of

license renewal f6r' license renewal while the shell of the tank is included within the scope of

license renewal. The internal spray line appearfs to perfoirm a LSI intended function. In RAI

2.3.3.17-1B,-dated June 9, 2004, the staff requested the applicant to explain' why the internal

spray line was excluded from the scope of license renewal and from being subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that the reactor coolant pressurizer

relief tank is an NSR component. The pressurizer relief tank' is within the scope of license'

renewal because it is spatially oriented such'that its failure 'could prevent the satisfactory

accomplishment of a safety-related function.' The pressurizer relief tank spray line that is

internal to the tank does not meet the criterion of 10 CFR 54.4(a)(2) since it is not spatially

oriented near any safety-related SSCs. Therefore, the internal spray line is not within the scope

of license renewal.

The staff finds the applicant's response to RAI 2.3.3.17-1 B acceptable because the applicant

adequately explained that the pressurizer relief tank internal spray line does not present a

potential for spatially interacting with safety-related SSCs; nor does it functionally support any

system-level intended functions. The' staff coridludes that the pressurizer relief tank internal

spray line in the pressurizer relief tank was scoped in accordance with the requirements of

10 CFR 54.4(a) and screened in accordance with the requirements of 10 CFR 54.21(a)(1). Therefore, the staff's concern described in RAI 2.3.3.17-1 B is resolved.

2.3B.3.17.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawing, and RAI response

described above to determine whether any SSCs'that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that'should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the primary grade water system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the primary grade

water system components that are subject to anAMR, as required by 1 0 CFR 54.21 (a)(1).

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2.3B.3.18 Auxiliary Building Ventilation System

2.3B.3.18.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.18, the applicant described the auxiliary building ventilation system. The

auxiliary building ventilation system provides an environment suitable for personnel access and

equipment operation within the building. It also controls and minimizes the potential for the

spread of airborne radioactive material by maintaining a negative pressure within the building.

The auxiliary building ventilation system is comprised of subsystems that provide local area

cooling and heating within the building. There are two filtration units within the exhaust system

that can be aligned to remove radioactive material from the ventilation exhaust flow. The

system contains fire dampers to prevent the spread of a fire.

The auxiliary building ventilation system is within the scope of license renewal because the

system provides an exhaust flowpath through filters and maintaining a negative pressure within

the auxiliary building and other areas in the event of an accident; providing an acceptable.

operating environment for safety-related equipment, and providing RG 1.97 safety-related

indications. The auxiliary building ventilation system provides isolation in support of the

supplementary leak collection-and-release system, and the system contains NSR components

that are spatially oriented such that their failure could prevent the satisfactory accomplishment

of a safety-related function associated with a safety-related SSC. The auxiliary building

ventilation system also contains environmental qualification equipment and supports station

blackout and fire protection.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides limited structural integrity

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides for heat transfer

In LRA Table 2.3.3-18, the applicant identified the following auxiliary building ventilation system

component types that are within the scope of license renewal and subject to an AMR: auxiliary

building filter bank housings; auxiliary building heating and ventilation air supply heating coils;

damper housings; ductwork; filter bank housing; flex connections; flow elements; MCC, rod

control and cable vault AC air supply cooling coils; MCC, rod control and cable vault AC air

supply unit; pipe; silencers; tubing; and valves.

2.3B.3.18.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.18 and Millstone FSAR Section 9.4.3. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

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functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.31.3.18.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified.' In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the auxiliary building ventilation system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately '

identified the auxiliary building ventilation system components that are subject to an AMR, as

required by 10 CFR 54.21 (a)(1).

2.3B.3.19 Circulating and Service Water Pumphouse Ventilation System

2.38.3.19.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.19, the applicant described the circulating and service water (SW)

pumphouse ventilation system. The circulating and SW pumphouse ventilation system provides

a suitable environment for personnel and equipment within the pumphouse. Each SW pump

cubicle has a safety-related ventilation system.

The circulating and SW pumphouse ventilation system provides an acceptable operating

environment for safety-related equipment and RG 1.97 safety-related indications. The

circulating and SW pumphouse ventilation system also supports fire protection and station

blackout.

The intended function within the scope of license'renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-19, the applicant identified the following circulating and SW pumphouse

ventilation system component types that are within the scope of license renewal and subject to

an AMR: damper housings; ductwork; fan/blower housings; flex connections; and silencers.

2.3B.3.19.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.19 and Millstone FSAR Section 9.4.8.1. The staff's

review, using the evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

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2.38.3.19.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the circulating and SW pumphouse ventilation system components that are within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the circulating and.SW pumphouse ventilation system components that are subject to

an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.3.20 Containment Air Filtration System

2.3B.3.20.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.20, the applicant described the containment air filtration system. The

containment air filtration system filters the containment atmosphere to reduce the concentration

of airborne radioactive particulates and iodine to permit containment access. The containment

air filtration system includes two 100-percent capacity fans and filter banks. Each filter bank

includes a heater, prefilter, carbon adsorber, and two high-efficiency particulate air filters. There

are fire detectors installed on the carbon adsorber units.

The containment air filtration system supports fire protection.

The applicant identified no component groups that require aging management review.

2.3B.3.20.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.20 and Millstone FSAR Section 9.4.7.1 using the

evaluation methodology described in Section 2.3 of this SER. The staff conducted its review in

accordance with the guidance described in SRP-LR Section 2.3, uScoping and Screening

Results - Mechanical Systems."

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed those components that the

applicant identified as being within the scope of license renewal to verify that the applicant did

not omit any passive and long-lived components that should be subject to an AMR in

accordance with the requirements of 10 CFR 54.21 (a)(1).

In LRA Section 2.3.3.20, the applicant stated that the containment air filtration system meets

10 CFR 54.4(a)(3) and is within the scope of license renewal because the system supports fire

protection. The applicant further stated that there are no containment air filtration system

components that are subject to aging management review since only the active fire detector

components are within the scope of license renewal.

On the basis of its review of the applicable FSAR section, the staff determined that the

containment air filtration system is not a safety-related system, and agrees with the applicant's

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determination that it meets 10 CFR 54.4(a)(3). The staff also determined that the acceptability

of the applicant's treatment of this system will be'addressed in the fire protection section'of this

SER.

2.3B.3.20.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were'identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the containment air filtration system components are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified that

none of the containment air filter components that are subject to an'AMR, as required by

10 CFR 54.21 (a)(1).

2.3B.3.21 Containment Air Recirculation System

2.3B.3.21.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.21, the applicant described the containment air recirculation system. The

containment air recirculation system is designed to maintain the bulk air temperature in the

containment suitable for personnel access and equipment operation during normal plant

operation, and for equipment operation following a loss of offsite power. The containment air

recirculation system supports a fire safe shutdown event. -

The containment air recirculation system cooling coils are NSR components that are spatially

oriented such that their failure could prevent the satisfactory accomplishment of a safety-related

function associated with a safety-related SSC.:The system also supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity -

* provides a pressure boundary

In LRA Table 2.3.3-20, the applicant identified the following containment air recirculation system

component types that are within the scope of license renewal and subject to an AMR:

containment air recirculation cooling coils; containment air recirculation cooling unit housings;

damper housings; ductwork; fan/blower housings; flex connections; and tubing.

2.3B.3.21.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.21 and Millstone FSAR Section 9.4.7.2. The staff's

review, using the evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

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reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.3.21.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the containment air recirculation system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the containment air recirculation system components that are subject to an AMR, as

required by 10 CFR 54.21 (a)(1).

2.3B.3.22 Containment Purge Air System

2.3B.3.22.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.22, the applicant described the containment purge air system. The

containment purge air system is designed to reduce the airborne radioactivity in the

containment and to provide air exchange during extended periods of containment occupancy,

such as during refueling outages.

The containment purge air system provides containment pressure boundary integrity and

RG 1.97 safety-related indications. The containment purge air system provides isolation in

support of the supplementary leak collection-and-release system, and the system contains NSR

components that are spatially oriented such that their failure could prevent the satisfactory

accomplishment of a safety-related function associated with a safety-related SSC. The

containment purge air system also contains environmental qualification equipment and supports

station blackout.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-21, the applicant identified the following containment purge air system

component types that are within the scope of license renewal and subject to an AMR:

containment purge heating and ventilation air supply heating coils; damper housings; ductwork;

flex connections; pipe; and valves.

2.3B.3.22.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.22 and Millstone FSAR Section 9.4.7.3. The staffs

review, using the evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1800.

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In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The'staff did not identify any omissions. The staff thenreviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3B.3.22.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its -.

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the containment purge air system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

containment purge air system components that are subject to an AMR, as required by

10 CFR 54.21 (a)(1).

2.3B.3.23 Containment Leakage Monitoring System

2.31.3.23.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.23, the applicant described the containment leakage monitoring system.

The containment leakage monitoring system provides containment pressure signals to the ESF

actuation system. The system can also be used for containment leak-rate testing.

The containment leakage monitoring system provides containment pressure boundary integrity

and RG 1.97 safety-related indications and signals. The containment leakage monitoring

system also contains environmental qualification equipment and supports station blackout.

Intended functions within the scope of license renewal include providing a pressure boundary.

In LRA Table 2.3.2-22, the applicant identified the following containment leakage monitoring

system component types that are within the scope of license renewal and subject to an AMR:

pipe; tubing; and valves. - . ;: '

2.38.3.23.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.23 and Millstone FSAR Sections 6.2.6 and 7.6.7. The

staffs review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

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2.3B.3.23.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the containment leakage monitoring system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the containment leakage monitoring system components that are subject to an AMR,

as required by 10 CFR 54.21 (a)(1).

2.3B.3.24 Containment Vacuum System

2.3B.3.24.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.24, the applicant described the containment vacuum system. The

containment vacuum system establishes and maintains sub-atmospheric containment internal

pressure during normal operations.

The containment vacuum system provides containment pressure boundary integrity and RG

1.97 safety-related indications. The containment vacuum system also contains environmental

qualification equipment and supports station blackout.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-23, the applicant identified the following containment vacuum system

component types that are within the scope of license renewal and subject to an AMR: bolting;

pipe; pumps and vacuum ejectors; and valves.

2.3B.3.24.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.24 and Millstone FSAR Section 9.5.10. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.3.24.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

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review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the containment vacuum system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

containment vacuum system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3B.3.25 Control Building Ventilation System

2.3B.3.25.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.25, the applicant described the control building ventilation system. The

control building ventilation system provides heating, ventilation, and air conditioning to the - - control room envelope and switchgear area during normal operation.' It also provides air supply,

filtration, and cooling in post-accident conditions.'The control room envelope consists of the

control room area, shift manager's office, tagging office, viewing gallery'and ramp, conference

room, toilet, kitchen,-instrument rack and computer room, piping/duct chase, 'and the

mechanical and equipment room. :

The control building ventilation system provides a suitable environment for equipment cooling

and personnel habitability, the capability to isolate; pressurize, and control radiological

conditions within the control room envelope in the event of an accident, and RG 1.97-safetyrelated indications. The control building ventilation system contains NSR components that are

spatially oriented such that their failure could prevent the satisfactory accomplishment of a

safety-related function associated with a safety-related SSC. The control building ventilation

system also supports fire protection and station blackout. ' ,

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary -

* provides for heat transfer .

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant - - --

* restricts flow

* provides limited structural integrity

In LRA Table 2.3.3-24, the applicant identified the following control building ventilation system

component types that are within the scope of license renewal and subject to an AMR: air

storage tanks; chiller oil coolers; chiller reservoirs; compressors; condensers; control building

air handling units; control room emergency ventilation filter bank housings; damper housings;

duct flow restrictors; ductwork; economizers; evaporators; expansion joints; expansion tanks;

fan/blower housings; filter/strainers; flex connections; flow elements; heaters; humidifiers; level

indicators; moisture indicators; pipe; pumps; tubing; and valves.

2.3B.3.25.2 Staff Evaluation . .. . - .- .;. i - . ) --... . .

The staff reviewed LRA Section 2.3.3.25 and Millstone FSAR Section 6.4.2 and 9.4.1. The

staff's review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1800.

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In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.3.25.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the control building ventilation system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

control building ventilation system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

23B.3.26 CRDM Ventilation and Cooling System

2.3B.3.26.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.26, the applicant described the control rod drive mechanism (CRDM)

ventilation and cooling system. The CRDM ventilation and cooling system removes heat from

the CRDM magnetic coils. Containment ambient air is drawn through the CRDM shroud and

ductwork, and heat from the CRDM coils is transferred to the chilled water system via the

CRDM shroud cooler cooling coils. The CRDM ventilation and cooling system contains three

50-percent fans, cooling coils, and a duct plenum.

The CRDM shroud cooler cooling coils are NSR components that are spatially oriented such

that their failure could prevent the satisfactory accomplishment of a safety-related function

associated with a safety-related SSC.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-25, the applicant identified the CRDM shroud cooler cooling coils as the

CRDM ventilation and cooling system component type that is within the scope of license

renewal and subject to an AMR.

2.3B.3.26.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.26 and Millstone FSAR Section 9.4.7.4. The staff's

review, using the evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1 800.

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In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.3.26.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the CRDM ventilation and cooling system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately - identified the CRDM ventilation and cooling system components that are subject to an AMR, as

required by 10 CFR 54.21(a)(1). !

2.3B.3.27 Emergency Generator Enclosure Ventilation System

2.3B.3.27.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.27, the applicant described the emergency generator enclosure ventilation

system. The emergency generator enclosure ventilation system provides an acceptable

environment for personnel and equipment within the building. The system includes tornado

dampers. -

The emergency generator enclosure ventilation system provides an acceptable operating

environment for safety-related equipment and providing RG 1.97. safety-related indications. The

emergency generator enclosure ventilation system supports fire protection and station blackout.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.3-26, the applicant identified the following emergency generator enclosure

ventilation system component types that are within the scope of license renewal and subject to

an AMR: damper housings; ductwork; fan/blower housings; and flex connections.

2.3B.3.27.2 Staff Evaluation -

The staff reviewed LRA Section 2.3.3.27 and Millstone FSAR Section 9.4.6. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

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reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3B.3.27.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the emergency generator enclosure ventilation system components that are within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the emergency generator enclosure ventilation system components that are subject to

an AMR, as required by 10 CFR 54.21(a)(1).

2.3B.3.28 Engineered Safety Features Building Ventilation System

2.3B.3.28.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.28, the applicant described the engineered safety features (ESF) building

ventilation system. The ESF building ventilation system provides a suitable environment for

equipment operation and personnel within the building. The ESF building ventilation system

includes normal and emergency ventilation. The normal ventilation is operated during normal

plant operation. Emergency ventilation contains five safety-related subsystems and four selfcontained AC chiller units serving the safety injection pump, quench spray pump, residual heat

removal pump, and ESF heat exchanger areas. These emergency ventilation subsystems

automatically start when the associated ESF equipment is required to operate. The ESF

building ventilation system contains fire dampers to prevent the spread of fires.

The ESF building ventilation system provides ESF building isolation in the event of an accident,

an acceptable operating environment for safety-related equipment, and RG 1.97 safety-related

indications. The ESF building ventilation system also contains environmental qualification

equipment and supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides for heat transfer

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.3.3-27, the applicant identified the following ESF building ventilation system

component types that are within the scope of license renewal and subject to an AMR: air

handling units; compressors; condensers; damper housings; ductwork; fan/blower housings;

filter dryer, filter/strainers; flex connections; flow indicators; pipe; suction traps; tubing; and

valves

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2.3B.3.28.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.28 and Millstone FSAR Section 9.4.5. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in-Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in'the LRA and

Millstone FSAR in accordance with the requirements'of 10 CFR 54:4(a) to verify that the'

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived ,components were not omitted from being

subject to an AMR'in accordance with 10 CFR 54.21(a)(1).

2.3B.3.28.3 Conclusion'

The staff reviewed the LRA to determine whether any SSCs that should be within the s cope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified.'On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the ESF building ventilation system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

ESF building ventilation system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3B.3.29 Fuel Building Ventilation System

2.3B.3.29.1 Summary of Technical Information'in'the'Application

In LRA Section 2.3.3.29, the applicant described the fuel building ventilation system. The fuel

building ventilatidri system provides'a suitable environment for equipment operation and

personnel within 'the building. 'The system is operated to limit the potential 'radioactive release'

by maintaining a negative operating pressure within the building and processing the exhaust air

flow through a charcoal filter prior to release to 1the atmosphere. The system contains fire

dampers to prevent th'e spread of fires.

The fuel building ventilation system provides an exhaust flowpath through filters 'and maintains

a negative pressure within the fuel building in the event of a contaminated fuel building

atmosphere, 'providing isolation of the normal exhaust flowpath via supply''backdraft dampers,

and RG 1.97 safety-related indications. The fuel building ventilation system provides isolation in'

support of the supplementary leak collection-and-reiease' s'ster ,'and the system contains NSR

components'that 'are spatially oriented such that their failure could prevent the 'atisfactory

accomplishment of a safety-related function associated with a'safety-related SSC. The fuel

building ventilation system also contains'environmental qualification' equipment and supports

fire protection.

Intended functions within the'scope of license renewal include the following:

provides a rated fire barrier to confine or retard a' fire from spreading to or from adjacent

areas of the plant

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* provides a pressure boundary

* provides limited structural integrity

In LRA Table 2.3.3-28, the applicant identified the following fuel building ventilation'system

component types that are within the scope of license renewal and subject to an AMR: damper

housings; ductwork; fan/blower housings; flex connections; fuel building filter bank housings;

heating coils; pipe; silencers; tubing; and valves.

2.3B.3.29.2' Staff Evaluation

The staff reviewed LRA Section 2.3.3.29 and Millstone FSAR Section 9.4.2. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did 'not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3B.3.29.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the fuel building ventilation system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

fuel building ventilation system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3B.3.30 Hydrogen Recombiner and Hydrogen Recombiner Building HVAC System

2.3B.3.30.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.30, the applicant described the hydrogen recombiner and hydrogen

recombiner building HVAC system. The hydrogen recombiner and hydrogen recombiner

building HVAC system includes the hydrogen recombiner unit and the ventilation system

associated with the hydrogen recombiner and the hydrogen recombiner building. The hydrogen

recombiner controls the concentration of hydrogen within the containment to below the

flammability limit following a LOCA. The hydrogen recombinrer unit provides hydrogen

recombiner return gas cooling to limit recombiner effluent temperature to 150 OF. The hydrogen

recombiner building HVAC system provides hydrogen recombiner building heating and AC and

hydrogen recombiner building post-accident exhaust. A high-radiation level in the hydrogen

recombiner ventilation exhaust stream automatically shuts down the ventilation system and the

hydrogen recombiner. The system contains fire dampers to prevent the spread of a fire.

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The hydrogen recombiner and hydrogen recombiner building HVAC system limits the postaccident concentration of hydrogen in the containment, limiting the recombiner exhaust stream

temperature to 150 0F, providing isolation of the ventilation system in a recombiner ventilation

exhaust high-radiation condition, providing containment pressure boundary integrity, and

providing RG 1.97 safety-related indications.'The hydrogen recombiner and hydrogen

recombiner building HVAC system also contains environmental qualification equipment and

supports fire protection.'

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides a rated fire barrier to confine orretard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.3.3-29, the applicant identified the following hydrogen recombiner and hydrogen

recombiner building HVAC system component types that are within the scope of license

renewal and subject to an AMR: airblast heat exchangers; damper housings; ductwork;

fan/blower housings; flex connections; flow elements; pipe; radiant heaters; reaction chamber;

tubing; and valves.

2.3B.3.30.2 Staff Evaluation

The staff reviewed LRASection 2.3.3.30 and MPS Unit 2 FSAR Sections 6.2.5 and 9.4.11. The

staff's review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated In 10 CFR'54.4(a). The 'staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3B.3.30.3 Conclusion

The staff reviewed the LRA to determine whether'any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff perfoirm'ed a review to determine'whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the hydrogen recombiner and hydrogen recombiner building HVAC system

components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has idequatelyidentified the hydrogen recombiner and hydrogen recombiner

building HVAC systemn components that'are subject to an' AMR, as required by

10 CFR 54.21 (a)(1). -

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23B.3.31 Main Steam Valve Building Ventilation System

2.3B.3.31.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.31, the applicant described the main steam valve building ventilation

system. The main steam valve building ventilation system provides the environment suitable for

personnel access and equipment operation within the building. The main steam valve building ventilation system also provides an isolation boundary function for the supplementary leak

collection-and-release system.

The main steam valve building ventilation system provides a suitable environment for

equipment cooling and personnel habitability, isolation in support of the supplementary leak

collection-and-release system boundary, and RG 1.97 safety-related indications. The main

steam valve building ventilation system contains NSR components that are spatially oriented

such that their failure could prevent the satisfactory accomplishment of a safety-related function

associated with a safety-related SSC. The main steam valve building ventilation system also

contains environmental qualification equipment and supports station blackout.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides limited structural integrity

In LRA Table 2.3.3-30, the applicant identified the following main steam valve building ventilation system component types that are within the scope of license renewal and subject to

an AMR: damper housings; ductwork; fan/blower housings; flex connections; and heating coils.

2.3B.3.31.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.31 and Millstone FSAR Section 9.4.10. The staffs review, using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.38.3.31.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition, the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the main steam valve building ventilation system components that are within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

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identified the main steam valve building ventilation system components that are subject to an

AMR, as required by 10 CFR 54.21(a)(1).:-

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

2.3B.3.32.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.32, the applicant described the process, effluent, and airborne radiation

monitoring system. The process, effluent, and airborne radiation monitoring system provides

indications and actuation signals based on detected radiation levels in plant areas and process

streams.

The process, effluent, and airborne radiation monitoring system provides actuation signals in.

response to detected radiation levels and provides RG 1.97 safety-related indications; The'

process,'effluent, and airborne radiation monitoring system also contains environmental

qualification equipment. ' -

The applicant identified no component groups that require aging management review.

2.38.3.32.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.32 and Millstone FSAR Section i 1. 5. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance withthe guidance described in' Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated'the system functions described in the LRA and

Millstone FSAR in accordanc6 with the re~quirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.3.32.3 Conclusion -

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified.' In addition,

the staff performed a review to determine'whether any components that should be subject to an

AMR were not identified b' the applicant. Nolomissions were identified. On' the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified process, effluent, and airborne'radiation monitoring system components that are

within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has

adequately identified that there are no process, effluent, and airborne radiation monitoring

components that are subject to an AMR,,as required by' 10 CFR 54.21 (a)(1).*

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

2.3B.3.33.1 Summary of Technical Information in the Application'

In LRA Section 2.3.3.33, the applicant described the service building ventilation and airconditioning (AC) system. The service building ventilation and AC system provides an

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environment suitable for personnel access and equipment operation within the building. The

system contains fire dampers to prevent the spread of a fire.

The service building ventilation and AC system provides an isolation boundary for the auxiliary

.building ventilation system. The system also supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a pressure boundary

In LRA Table 2.3.3-31, the applicant identified the following service building ventilation and AC

system component types that are within the scope of license renewal and subject to an AMR:

damper housings; ductwork; and flex connections.

2.3B.3.33.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.33 and Millstone FSAR Section 9.4.12. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did 'not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.38.3.33.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the service building ventilation and AC system components that are within the scope

of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the service building ventilation and AC system components that are subject to an

AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.3.34 Station Blackout Diesel Generator Building Ventilation System

2.3B.3.34.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.34, the applicant described the station blackout (SBO) diesel generator

building ventilation system. The SBO generator building ventilation system provides an

acceptable environment for personnel and equipment within the SBO diesel generator

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enclosure. The system consists of a self-contained AC unit for the SBO diesel generator control

room and ventilation supply fans and dampers forthe diesel room.

The SBO diesel generator building ventilation system supports SBO. The evaluation boundary

of the SBO diesel generator building ventilation system consists of the SBO diesel generator

control room AC unit and the diesel room fan housings.

The intended function within the scope of license renewal includes providing a pressure

boundary..

In LRA Table 2.3.3-32, the applicant identified the following SBO diesel generator building

ventilation system component types that are within the scope of license renewal and subject to

an AMR: AC units, self contained; and fan/blower housings.

2.3B.3.34.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.34 and Millstone FSAR Section 8.3.1. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 ofNUREG-1800.

In conducting its 'review, the staff evaluated the' system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were notomitted from' being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.3.34.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the SBO generator building ventilation-systern components' that are'within the scope

of license renewal, as required by 10 CFR 54.A(a), and that the applicant has adequately

identified the'SBO generator building ventilation system components that are subject'to an'

AMR, as required by 10 CFR 54.21(a)(1). '

2.3B.3.35 Supplementary Leak Collection andi Release System ;~~~~ ', ';. !_. _

2.3B.3.35.1 Summary of Technical Information in the Application !

In LRA Section 2.3.3.35, the applicant described the' supplementary leak 'colle'ction-'and-reiease'

system. The purpose of the supplementary leak collection-and-release system is to collect

containment post-accident leakage from the buildings contiguous' to the 'containment and that'

house the containment penetrations and ESF equipment. The system maintains negative

pressure in these areas, and it filters'potentially contaminated air exhausted from these areas

and releases it to the atmosphere through th6'sitack. The system also includes fire dampers.

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The supplementary leak collection-and-release system provides an exhaust flowpath through

filters, maintaining a negative pressure within the area's cntiguous to the'containment in the

event of an accident, and providing RG 1.97 safety-related indications. The supplementary leak

collection-and-release system also contains environmental qualification equipment and

supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a pressure boundary

In LRA Table 2.3.3-33, the applicant identified the following supplementary leak collection-andrelease system component types that are within the scope of license renewal and subject to an

AMR: damper housings; ductwork; fan/blower housings; flex connections; flow elements; pipe;

supplementary leak collection-and-release filter bank housings; tubing; and valves.

2.3B.3.35.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.35 and Millstone FSAR Section 6.2.3. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.3.35.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the supplementary leak collection-and-release system components that are within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the supplementary leak collection-and-release system components that are subject to

an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.3.36 Technical Support Center HVAC and Filtration System

2.3B.3.36.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.36, the applicant described the technical support center HVAC and

filtration system. The technical support center HVAC and filtration system provides a suitable

environment for maintaining proper equipment operation and provides for radiological protection

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to personnel occupying the technical support center.2,The system includes a heat detector for

the charcoal filter.

The technical support center HVAC and filtration system supports fire protection.

The applicant identified no component groups that require aging management review.

2.B3.3.36.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.36 and Millstone FSAR Section 9.4.13. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

In LRA Section 2.3.3.36 the applicant stated that the technical support center HVAC and

filtration system meets 10 CFR 54.4(a)(3) and is within the scope of license renewal because

the system supports fire protection. The applicant further stated that there are no technical

support center HVAC and filtration system'components that are subject to aging management

review since only the active fire detector components are within the scope of license renewal.

On the basis of its review of the applicable FSAR section, the staff determined that the

technical support center HVAC and filtration'system is not a safety-related system, and agrees

with the applicant's determination that it meets 10 CFR 54.4(a)(3). The staff also determined

that the acceptability of the applicant's treatment of this system will be addressed in the fire

protection Section of this SER.

2.3B.3.36.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant adequately

identified technical support center HVAC and filtration system components'are within the scope

of license renewal, as required by 10 CFR 54.4(a), and that the applicant adequately identified

there are no technical support center HVAC and filtration system components that are subject

to an AMR, as required by 10 CFR 54.21(a)(1).

2.3B.3.37 Turbine Building Area Ventilation System

2.3B.3.37.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.37, the applicant described the turbine building area ventilation system.

The turbine building area ventilation system provides a suitable environment for the equipment'

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and personnel within the turbine building. The turbine building area ventilation system contains

fire dampers to prevent the spread of fire.

The turbine building area ventilation system supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a pressure boundary

In LRA Table 2.3.3-34, the applicant identified the following turbine building area ventilation

system component type that is within the scope of license renewal and subject to an AMR:

damper housings.

2.3B.3.37.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.37 and Millstone FSAR Section 9.4.4. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.3.37.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the turbine building area ventilation system components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the turbine building area ventilation system components that are subject to an AMR,

as required by 10 CFR 54.21(a)(1).

2.3B.3.38 Waste Disposal Building Ventilation System

2.3B.3.38.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.38, the applicant described the waste disposal building ventilation system.

The waste disposal building ventilation system provides a suitable environment for personnel

access and equipment operation within the building, and minimizes the release of airborne

radioactive material to the atmosphere. The system contains fire dampers to prevent the spread

of fire.

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The waste disposal building ventilation system provides isolation in support of the

supplementary leak collection-and-release system and the auxiliary building ventilation system,

and provides RG 1.97 safety-related indications. The waste disposal building ventilation system

also contains environmental qualification equipment and supports fire protection.

Intended functions within the scope of license renewal include'the following:

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a pressure boundary.

In LRA Table 2.3.3-35, the applicant identified the following waste disposal building ventilation

system component types that are within the scope.of license renewal and subject to an AMR:

damper housings; ductwork; and flex connections.

2.3B.3.38.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.38 and MPS Unit 2 FSAR Section 9.4.9. The staff's

review, using the evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.3.38.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No'iissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has-adequately

identified the waste disposal building ventilationrsystem components that are within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the waste disposal building ventilation system components that are subject to an

AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.3.39 Unit 2 Fire Protection System

2.3B.3.39.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.39, the applicant described the Unit 2 fire protection system. The MPS fire

protection system is a shared system'that'pr6ides intended functions for both Millstone Unit 2

and Unit 3. This section addresses those'p'ortions of the fire protection system that are

specifically designated as Unit 2 components."Since this is a 'shared system, this section is

duplicated in the Millstone Unit 2 license renewal application. '

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The Unit 2 fire protection system provides for detection and suppression of fires such

that plant equipment damage is minimized and safe shutdown of the plant can be achieved.

The Unit 2 fire protection system is comprised of fire and smoke detection components, waterbased fire suppression components, and gas-based fire suppression components. The system

also includes the RCP motor oil collection system components.

The Unit 2 fire protection system provides containment pressure boundary integrity. The fire

protection system provides fire detection and suppression capability to protect safe shutdown or

safety-related equipment, provides oil collection for the prevention of an oil fire around the

RCPs, supports station blackout, provides emergency lighting, and provides backup cooling

water to the EDGs in response to a fire event.

Intended functions within the scope of license renewal include the following:

* provides enclosure, shelter, or protection for in-scope equipment (including radiation

shielding and pipe whip restraint)

* provides a pressure boundary

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* restricts flow

* provides a spray pattern

In LRA Table 2.3.3-36, the applicant provided the screening results for Unit 2 fire protection

system components (shared with Unit 3), identifying those components that require aging

management review. Similarly, LRA Table 2.4.2-36 provides the screening results for the Unit 2

miscellaneous structural commodities. Table 2.4.2-36 includes fire barrier penetration seals and

fire doors.

In LRA Table 2.3.3-36, the applicant identified the following Unit 2 fire protection system

component types that are within the scope of license renewal and subject to an AMR: drip pans;

fire hydrants; flame arrestors; flex connections; flow indicators; flow orifices; nozzles; pipe;

pumps; RCP oil collection tanks; retard chambers; sprinkler heads; strainers; tubing; valves;

and water motor gongs.

2.3B.3.39.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.39 and Millstone FSAR Section 9.10. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

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2.3B.3.39.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No'omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the Unit 2 fire protection system components'that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

Unit 2 fire protection system components'that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3B.3.40 Unit 3 Fire Protection System

2.3B.3.40.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.40, the applicant described the Unit 3 fire protection system. The MPS fire

protection system is a shared system that provides intended functions for both Millstone Unit 2

and Unit 3. This section addresses those portions of the fire protection system that are

specifically designated as Unit 3 components. Since this is a shared system, this section is

duplicated in the Millstone Unit 2 license renewal application.

The Unit 3 Fire protection system provides for detection and suppression of fires such that plant

equipment damage is minimized and safe shutdown of the plant can be achieved.

The Unit 3 fire protection'system is comprised of fire and smoke detection components, waterbased fire suppression components, and gas-based fire suppression components.'The system

also includes the RCP motor oil collection system components.

The Unit 3 fire protection system provides containment pressure boundary integrity, RG 1.97

safety-related indications, and pressure relief for tornado protection in the cable spreading area.

The Unit 3 fire protection system also provides fire detection and suppression capability to

protect safe shutdown or safety-related equipment, provides oil collection for the prevention of,

an oil fire around the RCPs, supports station blackout, and contains environmental qualification

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Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides for heat transfer - ' '

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides enclosure, shelter, or protection for in-scope equipment (including radiation

shielding and pipe whip restraint)

* provides filtration -. ,. : -

* provides a spray pattem

* restricts flow ^

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provides for vortex suppression

In LRA Table 2.3.3-37 the applicant provided the screening results for Unit 3 fire protection

system components, identifying those components that require aging management review.

Similarly, LRA Table 2.4.2-36 provides the screening results for the Unit 3 miscellaneous

structural commodities. Table 2.4.2-36 includes fire barrier penetration seals and fire doors.

In LRA Table 2.3.3-37, the applicant identified the following Unit 3 fire protection system

component types that are within the scope of license renewal and subject to an AMR: CO2

storage tank; CO2 tank cooling coils; compressed air cylinders; compressed halon cylinders; coolant heat exchanger, damper housings; diesel fuel storage tank; drip pans; ductwork;

exhaust silencer; expansion tank overflow container, fan/blower housings; filter/strainers; fire

hydrants; fire protection RCP oil collection tanks; fire water storage tank; flame arrestors; flex

connections; flexible hoses; flow indicatiors; flow switches; heater unit; hydropneumatic tank;

instrument snubbers; level indicators; lube oil cooler; nozzles; odorizers; oil mist recovery unit;

oil reservoirs; pipe; pumps; restricting orifices; self contained breathing apparatus; sprinkler heads; tubing; vacuum limiter; valves; vortex breaker assembly; water cooled exhaust manifold;

and water manifold.

2.3B.3.40.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.40 and Millstone FSAR Section 9.10. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3B.3.40.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the Unit 3 fire protection system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

Unit 3 fire protection system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3B.3.41 Domestic Water System

2.3B.3.41.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.41, the applicant described the domestic water system. The purpose of

the domestic water system is to provide potable water for various uses, including make-up

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water to the fire water storage tanks, and back-up cooling for the instrument air compressors.

The domestic water system is supplied by the public water system from the town of Waterford,

Connecticut. .

The domestic water system contains NSR components spatially oriented such that their failure

could prevent the satisfactory accomplishment of a safety-related function associated with a

safety-related SSC. The domestic water system also provides makeup water to the fire water

storage tanks and cooling water flow to the instrument air compressor that is credited for fire

protection.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides limited structural integrity

In LRA Table 2.3.3-38, the applicant identified the following domestic water system component

types that are within the scope of license renewal and subject to an AMR: flow indicator; heater;

pipe; shock absorbers; strainers; and valves. -,

2.3B.3.41.2,Staff Evaluation

The staff reviewed LRA Section 2.3.3.41 and Millstone FSAR Section 9.2.4. The staff's review,

using the evaluation methodology described in Section 2.3 of this SERF was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.3.3.41 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that a license renewal drawing for the domestic water system

shows that backflow preventors are within the scope of license renewal and subject to an AMR.

However, component type ubackflow preventor",is not listed in LRA Table 2.3.3-38 as a

component type with intended functions. In RAI 2.3.3.41-1 B, dated June 9, 2004, the staff

requested the applicant to explain whether, these components were included with another

component type or to explain their exclusion from the scope of license renewal and from being.

subject to an AMR. - . .;.;

In its response, dated July 26, 2004, the applicant stated that the subject backflow preventors

are within the scope of license renewal and are included in the component type, "Valves," in

LRA Table 2.3.3-38. ,--, -

In its review, the staff finds the applicant's response to 2.3.3.41-1 B acceptable based on

inclusion of the component.

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In its review, the staff also noted that a license renewal drawing for the domestic water system

indicates that showers are within the scope of the license renewal and subject to an AMR.

However, component type "shower" is not listed in LRA Table 2.3.3-38 as a component type

with intended functions. In RAI 2.3.3.41-2B, dated June 9, 2004, the staff requested the

applicant to explain whether these components were included with another component type or

to explain their exclusion from the scope of license renewal and from being subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that the subject showers shown are

within the scope of license renewal and are included in the component type, "Pipe," in LRA

Table 2.3.3-38.

In its review, the staff finds the applicant's response to RAI 2.3.3.4-2B acceptable based on

inclusion of the component.

2.3B.3.41.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the domestic water system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the domestic water

system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.3.42 Emergency Diesel Generator System

2.3B.3.42.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.42, the applicant described the emergency diesel generator system. The

purpose of the emergency diesel generator (EDG) system is to provide a dependable on-site

AC power source capable of automatically starting and supplying the loads necessary to safely

shutdown the plant and maintain it in a safe shutdown condition.

The EDG system is comprised of two identical EDGs. Each EDG supplies 4160 vac power to its

respective emergency bus. The EDG system includes the starting air subsystem, lubricating oil

subsystem, cooling water subsystem, and the combustion air intake and exhaust subsystem.

The EDG system provides a reliable source of emergency power for the required loads and

providing RG 1.97 safety-related indications. The EDG system contains NSR components that

are spatially oriented such that their failure could prevent the satisfactory accomplishment of a

safety-related function associated with a safety-related SSC. The EDG system supports station

blackout and fire protection.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides for heat transfer

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* provides limited structural integrity

* provides filtration

* restricts flow

In LRA Table 2.3.3-39, the applicant identified the following EDG system component types that

are within the scope of license renewal and subject to an AMR: air distributors; air receiver

tanks; air tanks; crankcase vacuum manometers; diesel engine jacket water cooler heat

exchangers; engine air cooler water heat e'6hahigers; engine sumps; expansion joints;

filterlstrainers; fresh water expansion tanks; governor lube oil coolers; jacket water heaters;

level indicators; lube oil heat exchangers; oil reservoirs; oil separators; pipe; pre-lube oil

heaters; pumps; restricting orifices; servo fuel rack shutdown and starting boosters; silencers;

tubing; turbo chargers; and valves.

2.3B.3.42.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.42 and Millstone FSAR Sections 8.3.1, 9.5.5, 9.5.6, 9.5.7,

and 9.5.8. The staff's review, using the evaluation methodology described in Section 2.3 of this

SER, was conducted in accordance with the guidance described in Section 2.3 of NUREG1800.' ' ' '

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify' that passive or long-lived 'components were not omitted from 'being

subject to an AMR in'accordance'with 10 CFR 54.21 (a)(1).

2.B3.3.42.3 Conclusion.

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant.'No omissions were identified. In addition,

the staff performed a 'review to determine whether any components that'should be subject to an

AMR were not identified by the applicant. No omissions wereidentified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has'adequately

identified the EDG system components that are within the scope of license renewal, as required

by' 10 CFR 54.4(a), and that'the applicant ias -adequately'dentified the EDG system

components that are subject to an AMR, as' required by 10 CFR 54.21 (a)(1).

2.3B.3.43 Emergency Diesel Generator F1uel OilSystem

2.36.3.43.1 Summary of Technical Information in'the Application

In LRA Section 2.3.3.43, the applicant'described the EDG fuel oil system. The EDG fuel oil

system provides fuel oil to the 'diesel eng'ind''linde'rs.The EDG fuel oil system includes fuel oil

tanks, transfer pumps,' strainers, piping, and valves. '

The EDG fuel oil system provides adequate fuel oil to support the safety function of the diesel

generators. The EDG fuel oil system contains NSR components that are spatially oriented such

that their failure could prevent the satisfactory accomplishmnent of a safety-related function

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associated with a safety-related SSC. The EDG fuel oil system supports station blackout and

fire protection.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides enclosure, shelter, or protection for in-scope equipment (including radiation

shielding and pipe whip restraint)

* provides limited structural integrity

* provides filtration

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* restricts flow

In LRA Table 2.3.3-40, the'applicant identified the following EDG fuel oil system component

types that are within the scope of license renewal and subject to an AMR: accumulator tanks;

drip pans; filter/strainers; flame arrestors; flow elements; fuel oil day tanks; fuel oil storage

tanks; injectors; pipe; pumps; restricting orifices; tubing; and valves.

2.3B.3.43.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.43 and Millstone FSAR Section 9.5.4. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with.

10 CFR 54.21 (a)(1).

The staff's review of LRA Section 2.3.3.43 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that the Millstone FSAR states that backflow prevention devices

preclude oil backing up out of the floor drains in the event of a day tank rupture. These devices

are not shown on license renewal drawings for the EDG fuel oil system and are not listed in

LRA Table 2.3.3-40 as components requiring an AMR. In RAI 2.3.3.43-1 B, dated June 9, 2004,

the staff requested the applicant to explain whether these components were included with

another component type or to explain their exclusion from the scope of license renewal and

from being subject to an AMR.

In its response, datedJuly 26, 2004, the applicant stated that the subject backflow prevention

devices are located in the diesel generator room floor drains to prevent the backflow of

combustible liquids to safety-related areas through the interconnected drain systems. The

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backflow devices are part of the sanitary water system. Upon further review, the applicant

concluded that the backflow prevention devices should be included within the scope of license

renewal, since these components support fire protection and the sanitary water system should

include an intended function that meets the criteria of 10 CFR 54.4(a)(3) for fire protection. The

carbon steel backflow prevention devices are included in the component type, "Valves," in LRA

Table 2.3.3-50.

In its review, the staff finds the applicant's response to RAI 2.3.3.43-1 B acceptable based on

inclusion of the component.

Another license renewal drawing for the EDG fuel oil system shows dewatering boxes excluded

from scope and not subject to an AMR. Additionally, sump and water pumping connections are

shown not to be subject to an AMR. In order for the staff to complete its review, more

information was necessary to ensure that all the components performing the system-level

intended functions were included within the scope of license renewal. In RAI 2.3.3.43-2B, dated

June 9, 2004, the staff requested the applicant to supply the FSAR references that describe

these components, or provide a summary description of their functions including any intended

functions.

In its response, dated July 26, 2004, the appli6ant'stated that the Millstone FSAR does not

contain a description of the dewatering boxes. The dewatering boxes shown on the license

renewal drawing for the EDG'fuel oil systei'6are used to remove water that accumulates inside

each fuel oil storage'tank. The dewatering tank' and 'its components were not highlighted on the

license renewal drawing. The tank well, tank' well pipe; and tank well pipe cap were evaluated

as an integral part of the "Fuel Oil Storage Tank" shown in LRA Table 2.3.3-40.

In its review, the staff finds the applicant's response to RAI 2.3.3.43-2B acceptable based on

inclusion of the component.

2.3B.3.43.3 Conclusion

The staff reviewed the LRA, the' accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omnissions were identified. On the basis'of its review, the

staff concludes that there is reasonable assurance that the applicantlhbs adequately identified

the EDG fuel oil system components that are within the scope of license renewal, as required

by 10 'CFR 54.4(a), and that the applicant has adequately identified the EDG fuel oil system

components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3B.3.44 Station Blackout DieseI Generator System

2.3B.3.44.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.44, the applicant described the station blackout (SBO) diesel generator

system. The Millstone SBO diesel generator system is a shared system that provides intended

functions for both Millstone Unit 2 and Millstone Unit 3. Since this is a shared system, this

section is duplicated in the Millstone Unit 2 license renewal application.

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The purpose of the SBO diesel generator system, installed in response to 10 CFR 50.63, is to

provide an alternate AC power source to either the Millstone Unit 2 or Unit 3 emergency bus.

The SBO diesel generator system consists of the diesel generator and includes the lubricating

oil subsystem, engine cooling subsystem, air intake and exhaust subsystem, fuel oil subsystem,

and starting air subsystem.

The SBO diesel generator system supports station blackout and fire protection.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides filtration

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* restricts flow

In LRA Table 2.3.3-41, the applicant identified the following SBO diesel generator system

component types that are within the scope of license renewal and subject to an AMR:

aftercoolers; air receivers; aspirators; expansion joints; expansion tanks; filter/strainers; flame

arrestors; flow indicators; fuel heaters; fuel oil day tanks; fuel oil storage tanks; immersion

heaters; injectors; lube oil coolers; lubricators; oil sumps; pipe; pulsation dampeners; pumps;

radiators; restricting orifices; silencers; tubing; turbo chargers; upper and lower air start motors;

and valves.

2.3B.3.44.2 Staff Evaluation

The Millstone SBO diesel generator system is a shared system that provides intended functions

for both Millstone Unit 2 and Millstone Unit 3. The staff reviewed the Millstone Unit 3 LRA

Section 2.3.3.44, Millstone Unit 2 FSAR Section 1.2.9, and Millstone Unit 3 FSAR Section 8.3.1.

The staffs review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive'.

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.3.44 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

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In its review, the staff noted that a license renewal drawing for the SBO diesel generator system

shows a 28-inch exhaust rain cap to be subject to an AMR. The rain cap appears to provide a

pressure boundary function. Millstone Unit 2 LRA Table 2.3.3-36 and Millstone Unit 3 LRA

Table 2.3.3-41 do not list the rain cap as a component type requiring an AMR. In RAI.2.3.3.44-

1 B, dated June 9, 2004, the staff requested the applicant to explain whether the rain cap was

included with another component type or to explain its exclusion.

In its response, dated July 26, 2004, the applicant stated that the subject rain cap, shown on

the SBO diesel generator system license renewal drawing,- is an integral part of the exhaust

silencer. The exhaust silencer with the integral rain cap is within the scope of license renewal:

and included in the component type, "Silencers," in Unit 2 LRA Table 2.3.3-36,and Unit 3 LRATable 2.3.3-41.

The staff finds the applicant's response to RAI 2.3.3.44-11B acceptable, based on inclusion of

the component.

The Millstone Unit 3 FSAR states that all safety-related lines or valves, which are subject to

freezing, are electrically heat-traced and insulated. A license renewal drawing for the station

blackout fuel oil system shows a line going from the fuel oil storage tank to the fuel oil day tank

that is within the scope of license renewal. It appears that the line in question is insulated.. -

Thermal insulation is not listed as within the scope of license renewal and subject to an AMR for

any Unit 2 or Unit 3 systems; nor is it discussed in the Unit 2 or Unit 3 Millstone Unit 3 LRA. In

RAI 2.3.3.44-2B, June 9, 2004, the staff requested the applicant to explain the apparent

exclusion of pipe insulation.

In its response, dated July 26, 2004, the applicant stated that the subject fuel line is heat traced

and thermally insulated. This insulation does not perform an intended function since the -

effectiveness of the heat trace system on the fuel temperatures in the subject fuel line and fuel

tank is monitored. In the event of low fuel temperatures, a heat trace trouble alarm is activated

in the control room. Insulation-related problems would be rapidly identified and repaired;-

Therefore, the thermal insulation is not within the scope of license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.44-2B acceptable

based on operator actions respond to a heat-trace trouble alarm and initiate the subsequent

corrective actions. The ability of the system's temperature monitoring instrumentation to localize

a low temperature along the length of the piping would allow differentiation between thermal

insulation or heat-trace circuit problems. Therefore, the cause of the trouble alarm would be

localized such that identification and appropriate repair would be made before loss of systemlevel intended function would occur. Therefore, the staff's concern described in RAI 2.3.3.44-2B

is resolved.

2.3B.3.44.3 Conclusion -

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any,components that should be subject to an AMR

were not identified by the applicant. No omissions were identified.:On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the SBO diesel generator system components that are within the scope of license renewal, as

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required by 10 CFR 54.4(a), and that the applicant has adequately identified the SBO diesel

generator system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.3.45 Security System

2.3B.3.45.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.45, the applicant described the security system. The Millstone security

system is a shared system that provides intended functions for both Millstone Unit 2 and

Millstone Unit 3. Since this is a shared system, this section is duplicated in the Millstone Unit 2

license renewal application.

Security system lighting provides illumination for operator access routes required in response to

fire protection events. The security system diesel generator provides back-up electrical power

for plant security features including security perimeter lighting. The security system includes the

lubricating oil subsystem, engine cooling subsystem, fuel oil subsystem, and the air intake and

exhaust subsystem that support the security diesel generator.

The security system provides yard lighting, and back-up electrical power for yard lighting, in

support of fire protection.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides filtration

In LRA Table 2.3.3-42, the applicant identified the following security system component types

that are within the scope of license renewal and subject to an AMR: coolers; diesel fuel oil

storage tank; fan/blower housings; filter/strainers; heaters; oil pans; pipe; pumps; radiators;

tubing; and valves.

2.3B.3.45.2 Staff Evaluation

The staff reviewed the Millstone Unit 3 LRA Section 2.3.3.45. The staffs review, using the

evaluation methodology'described in Section 2.3 of this SER, was conducted in accordance

with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.1B3.3.45.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

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review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the security system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the security

system components that are subject to an AMR .as required by 10 CFR 54.21 (a)(1).

2.3B.3.46 Boron Recovery System

2.3B.3.46.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.46, the applicant described the boron recovery system. The boron

recovery system receives reactor coolant letdown from the CVCS that has been degasified in

the radioactive gaseous waste system. The liquid entering the boron recovery system is

produced by the feed and bleed operations necessary to maintain the boron concentration in

the reactor coolant at the desired level.

The boron recovery system contains NSR components spatially oriented such that their failure

could prevent the satisfactory accomplishment of a safety-related function of a safety-related

SSC. The boron recovery system also supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-43, the applicant identified the following boron recovery system component

types that are within the scope of license renewal and subject to an AMR: bolting; boron

recovery tanks; cesium-removal ion exchangers; filter/strainers; pipe; tubing; and valves.

2.3B.3.46 Staff Evaluation

The staff reviewed LRA Section 2.3.3.46 and Millstone FSAR Section 9.3.5. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.3.46.3 Conclusion , , ,-:; - -

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the boron recovery system components that are within the scope of license renewal,

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as required by 10 CFR 54.4(a), and that the applicant has adequately identified the boron

recovery system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.3.47 Radioactive Liquid Waste Processing System

2.3B.3.47.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.47, the applicant described the radioactive liquid waste processing system. The radioactive liquid waste processing system collects, stores, processes, recycles, and disposes of liquid radioactive waste.

The radioactive liquid waste processing system contains NSR components spatially oriented

such that their failure could prevent the satisfactory accomplishment of a safety-related function

of a safety-related SSC.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-44, the applicant identified the following radioactive liquid waste processing system component types that are within the scope of license renewal and subject to an AMR:

bolting; flow elements; pipe; and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant expanded the system boundaries for the radioactive liquid waste processing system. In its

December 3, 2004, RAI response, the applicant identified the following component types that

were added to the scope of the radioactive liquid waste processing system:

* pumps

* radiation detectors

* tubing

2.3B.3.47.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.47 and Millstone FSAR Section 11.2. The staffs review, using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staff also reviewed the results of the scoping methodology changes, set forth in responses to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

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components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

boron recovery system is acceptable.

2.38.3.47.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the liquid waste processing

system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the liquid waste processing

system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).*

2.3B.3.48 Radioactive Gaseous Waste System

2.3B.3.48.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.48, the applicant described the radioactive gaseous waste system. The

radioactive gaseous waste system processes and controls the release of potentially radioactive

waste gases.

The radioactive gaseous waste system provides pressure boundary integrity and isolation for

the containment, and by providing RG 1.97 safety-related indications. The radioactive gaseous

waste system provides a pressure boundary for interfacing systems and since the system

contains NSR components spatially oriented such that their failure could prevent the

satisfactory accomplishment of a safety-related function of a safety-related SSC. The

radioactive gaseous waste system also supports fire protection and contains environmental

qualification components.

Intended functions within the scope of license renewal include the following: ;

* provides a pressure boundary

* provides limited structural integrity

In LRA Table 2.3.3-45, the applicant identified the following radioactive gaseous waste system

component types that are within the scope of license renewal and subject to an AMR: damper

housings; ductwork; pipe; process vent cooler, and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the radioactive gaseous waste system. In its December 3,

2004, RAI response, the applicant identified the following component types that were added to

the scope of the radioactive gaseous waste system: '-

* -degasifier feed preheater

* degasifiers

degasifier condenser

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* tubing

2.38.3.48.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.48 and Millstone FSAR Section 11.3. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial andlor attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

radioactive gaseous waste system is acceptable.

2.3B.3.48.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the radioactive gaseous

waste system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the radioactive gaseous waste

system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.3.49 Post-Accident Sampling System

2.3B.3.49.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.49, the applicant described the post-accident sampling system. The postaccident sampling system is designed to obtain samples of the reactor coolant, the containment

sump fluid, and the containment atmosphere under accident conditions. The post-accident

sampling system includes the containment hydrogen analyzers.

The post-accident sampling system provides the capability to obtain a post-accident sample of

the containment atmosphere and the primary coolant, providing pressure boundary integrity and

isolation for the containment and interfacing safety-related systems, and providing RG 1.97

safety-related indications. The post-accident sampling system contains NSR components that

are spatially oriented such that their failure could prevent the satisfactory accomplishment of a

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safety-related function of a safety-related SSC. The post-accident sampling system also

contains environmental qualification components.-

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides limited structural integrity

* provides filtration

* provides for heat transfer

In LRA Table 2.3.3-46, the applicant identified the following post-accident sampling system

component types that are within the scope of license renewal and subject to an AMR:

accumulators; bolting; de-ionized water flush tank; drain tanks; filter/strainers; flow elements;

hoses; hydrogen sensors; hydrogen tanks; pipe; pumps; restricting orifices; sample coolers;

sample cylinders/chambers; tubing; and valves.

2.3B.3.49.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.49 and Millstone FSAR Section 9.3.2.6. The staffs

review, using the evaluation methodology described in Section 2.3 of this SER, was conducted

in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.3.49.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its :

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the post-accident sampling system components that are within the scope of license,

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

post-accident sampling system components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.3B.3.50 Radioactive Solid Waste System

2.3B.3.50.1 Summary of Technical Information in the Application -: * , !F. f ,,

In LRA Section 2.3.3.50, the applicant described the radioactive solid waste system. The

radioactive solid waste system is designed to collect,-dewater, package, and temporarily store

solid radioactive waste materials prior to shipment offsite and ultimate disposal.

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The radioactive solid waste system contains NSR components spatially oriented such that their

failure could prevent the satisfactory accomplishment of a safety-related function of a safetyrelated SSC. The radioactive solid waste system also supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-47, the applicant identified the following radioactive solid waste system

component types that are within the scope of license renewal and subject to an AMR: bolting;

pipe; and valves.

2.3B.3.50.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.50 and Millstone FSAR Section 11.4. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.B3.3.50.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the radioactive solid waste system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

radioactive solid waste system components that are subject to an AMR, as required by

10 CFR 54.21 (a)(1).

2.3B.3.51 Reactor Plant Aerated Drains System

2.3B.3.51.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.51, the applicant described the reactor plant aerated drains system. The

reactor plant aerated drains system collects potentially contaminated effluent from sumps '

located inside the containment, ESF building, auxiliary building, pipe tunnel, fuel building, waste

disposal building, and turbine building. The collected effluent is discharged to the radioactive

liquid waste processing system for processing and disposal.

The reactor plant aerated drains system provides containment pressure boundary integrity,

collection and removal of groundwater from the ESF building underdrains and porous concrete,

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prevention of backflow of the SW pump cubicles drains, a means to detect flooding due to

leakage from emergency core cooling system components, RG 1.97 safety-related indications,

and a supplemental leak collection-and-release system boundary in the ESF building. -The

reactor plant aerated drains system contains NSR components spatially oriented such that their

failure could prevent the satisfactory accomplishment of a'safety-related function of a safetyrelated SSC.'The reactor plant aerated drains systedm'also contains environmental qualification

components:.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity ' -

* provides a pressure boundary

* restricts flow

In LRA Table 2.3.3-48, the applicant identified'the following reactor plant aerated drains system -

component types that are within the scope of license renewal and subject to an AMR:

expansion joints; filter/strainers; flow elements; flow indicators; groundwater sump; pipe;

pumps; restricting orifices; tubing; and valves.,

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the plant aerated drains system. In its December 3, 2004,

RAI response, the applicant identified the groundwater underdrains storage tank component

type that was added to the scope of the plant aerated drains system.

2.3B.3.51.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.51, the November 9, 2004, response, and Millstone

FSAR Sections 3.8.1 and 9.3.3. The staff's review, using the evaluation methodology described

in Section 2.3 of this SER, was conducted in accordance with the guidance described in Section

2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the'

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1). -. X

The staff also reviewed the results of the scoping' methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. .The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

reactor plant aerated drains system is acceptable.

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2.3B.3.51.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs

that should be within the scope of license renewal were not identified by the applicant. No

omissions were identified. In addition, the staff performed a review to determine whether any

components that should be subject to an AMR were not identified by the applicant. No

omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the reactor plant aerated

drains system components that are within the scope of license renewal, as required by'

10 CFR 54.4(a), and that the applicant has adequately identified the reactor plant aerated

drains system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.3.52 Reactor Plant Gaseous Drains System

2.3B.3.52.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.52, the applicant described the reactor plant gaseous drains system. The

reactor plant gaseous drains system collects primary coolant drains and hydrogenated liquids

from valve and pump leakoffs, and other equipment.

The reactor plant gaseous drains system provides containment pressure boundary integrity and

RG 1.97 safety-related indications. The reactor plant gaseous drains system contains NSR

components spatially oriented such that their failure could prevent the satisfactory

accomplishment of a safety-related function of a safety-related SSC. The reactor plant gaseous

drains system also contains environmental qualification components and supports station

blackout.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-49, the applicant identified the following reactor plant gaseous drains

system component types that are within the scope of license renewal and subject to an AMR:

bolting; flow indicators; pipe; pumps; tubing; and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the reactor plant gaseous drains system. In its December

3, 2004, RAI response, the applicant identified the following component types that were added

to the scope of the reactor plant gaseous drains system:

* containment drains transfer tank

* primary drains transfer tank

2.3B.3.52.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.52 and Millstone FSAR Section 9.3.3. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

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In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1). - .

The staffs review of LRA Section 2.3.3.52 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that a license renewal drawing for the reactor plant gaseous drains

system shows containment drains transfer tanks excluded from the scope of license renewal.

These tanks serve pressure boundary and limited structural support intended functions and

should be included within the scope of license renewal. In RAI 2.3.3.52-1 B. dated June 9, 2004,

the staff requested the applicant to explain why the transfer tanks in the reactor plant gaseous

drains system were excluded from the scope of license renewal and from being subject to an

AMR.

In its response, dated July 26, 2004, the applicant stated that the NSR primary drains transfer

tank and the NSR containment drains transfer tank are located on the lowest level of the,

structures that house them and neither is in the immediate vicinity of any safety-related

equipment. Additionally, neither tank operates at an elevated pressure. Consequently, the

primary drains transfer tank and the containment drains transfer tank are not within the scope

of license renewal, since they do not meet the criteria for pressure boundary or limited structural

integrity defined in Section 2.1.3.6 of the LRA. The lines attached to these tanks, however, are

within the scope of license renewal because they traverse into areas that do contain safetyrelated equipment.

The staff finds the applicant's response to RAI 2.3.3.52-1 B acceptable because the applicant

adequately explained that the primary drains transfer tank and the containment drains transfer

tank do not present a potential for spatially interacting with safety-related SSCs, nor do they*

functionally support any system-level intended functions. The staff concludes that the primary

drains transfer tank-and the containment drains transfer tank were scoped in accordance with

the requirements of 10 CFR 54.4(a) and screened in accordance with the requirements of

10 CFR 54.21(a)(1). Therefore, the staffs concern described in RAI 2.3.3.52-1B is resolved.'

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with,

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

reactor plant gaseous drains system is acceptable.:

2.3B.3.52.3 Conclusion : --

The staff reviewed the LRA, the accompanying scoping boundary drawing, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

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renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the reactor plant gaseous drains system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

reactor plant gaseous drains system components that are subject to an AMR, as required by

10 CFR 54.21 (a)(1).

2.3B.3.53 Sanitay Water System

2.3B.3.53.1 Summary of Technical Information in the Application

In LRA Section 2.3.3.53, the applicant described the sanitary water system. The sanitary water

system collects drainage from sanitary components and directs non-radioactively contaminated

drainage to the public sewer system. The sanitary water system directs potentially

contaminated drainage to a contaminated sump for further transfer to the radioactive liquid

waste processing system.

The sanitary water system contains NSR components spatially oriented such that their failure

could prevent the satisfactory accomplishment of a safety-related function of a safety-related

SSC.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.3-50, the applicant identified the following sanitary water system component

types that are within the scope of license renewal and subject to an AMR: pipe and valves.

2.3B.3.53.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.53 and Millstone FSAR Section 9.2.4. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staff s review of LRA Section 2.3.3.53 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

The FSAR states that portions of the domestic and sanitary water systems in the control

building are seismically supported, to assure that the failure of the piping will not cause a loss of

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positive pressure in the control building. A license renewal drawing shows sanitary water

system piping running from floor drains excluded from the scope of license renewal. Sanitary

system piping running through the control building from roof drains is also shown as not being

within the scope of license renewal. Failure of this piping could cause the sanitary water system

to fail to maintain positive pressure in the control building, whether or not seismic support is

required. The subject piping should be included within the scope of license renewal because it

performs a pressure boundary intended function.-ln RAI 2.3.3.53-1B, dated June 9, 2004, the

staff requested the applicant to confirm that the piping in the domestic and sanitary water,

system does not perform system intended functions that would necessitate its inclusion within

the scope of license renewal. -

In its response, dated July 26, 2004, the applicant stated that the sanitary water floor drains and

piping license renewal drawings for the sanitary water system are in the mechanical room

portion of the control building and have drain traps (loop seals) installed. These drain traps are

located directly below the drain opening, but are .not shown on the license renewal drawing. The

drain traps are currently within the scope of license renewal as part of the control building

pressure boundary and are included in the component type, "Pipe,' in LRA Table 2.3.3-50. The

drain line pipe downstream of the drain traps is embedded in concrete and does not perform

the function of maintaining a positive pressure in the control building. There is effectively no

upstream piping associated with these drain traps. The roof drains shown on the license

renewal drawing, are embedded in the ceiling and walls of the control building and do not

penetrate into the control building pressure boundary. Since failure of the piping shown on the

license renewal drawing, associated with the floor drains, and of the roof drain piping, will not

cause a loss of positive pressure in the control building, the applicant stated that this piping is

not the subject of the discussion in FSAR Section 9.2.4.3 and is not within the scope of license

renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.53-1 B acceptable

because the applicant adequately explained that the drain lines are embedded in concrete such

that their failure would not affect the pressure boundary of the control building. The discussion

in the FSAR does not describe the embedded piping which has no intended functions.

Additionally, there is adequate explanation that the drain traps are associated with exposed

drains are within the scope of license renewal and included in Table 2.3.3-50. The staff

concludes that the drain lines associated with the sanitary water system were scoped in

accordance with the requirements of 10 CFR 54.4(a) and screened in accordance with the

requirements of 10 CFR 54.21(a)(1). Therefore, the staffs concern described in RAI

2.3.3.53-1B is resolved.

A license renewal drawing for the sanitary water system shows a line to be within the scope of

license renewal that is indicated to continue onto another license renewal drawing where it is

stated that the subject line provides continuous drip for maintaining the house trap seal, which

is shown to be within the scope of license renewal. From the drawings it does not appear that

the subject line connects directly to the running trap. To maintain the trap seal, lines that carry

the flow to the "in-scope" trap, should be included within the scope of license renewal. In RAI

2.3.3.53-2B, dated June 9, 2004, the staff requested the applicant to explain the apparent

exclusion of these lines.

In its response, dated July 26, 2004, the applicant stated that the drain line on the license

renewal drawing was inadvertently highlighted and is not within the scope of license renewal.

The drain trap shown on the license renewal drawing is within the scope of license renewal

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since it is the only component necessary to maintain the negative pressure envelope in the

main steam valve house as part of the supplementary leak collection-and-release system

boundary (which is further described in main steam valve building ventilation system). The inscope drain trap is included in the component type, "Pipe," in LRA Table 2.3.3-50.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.53-2B acceptable

because the applicant clarified that the drain line was inadvertently highlighted and is not within

the scope of license renewal, and that the drain trap was scoped in accordance with the

requirements of 10 CFR 54.4(a) and screened in accordance with the requirements of

10 CFR 54.21(a)(1). Therefore, the staffs concern described in RAI 2.3.3.53-1B is resolved.

2.31B.3.53.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the sanitary water system components that are within the scope of license renewal, as required

by 10 CFR 54.4(a), and that the applicant has adequately identified the sanitary water system

components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.36.4 Steam and Power Conversion Systems

In LRA Section 2.3.4, the applicant identified the structures and components of the steam and

power conversion systems that are subject to an AMR for license renewal.

The applicant described the supporting structures and components of the steam and power

conversion systems in the following sections of the LRA:

* 2.3.4.1 main steam system

* 2.3.4.2 feedwater system

* 2.3.4.3 condensate make-up and draw-off system

* 2.3.4.4 steam generator blowdown system

* 2.3.4.5 auxiliary feedwater system

* 2.3.4.6 auxiliary steam system

* 2.3.4.7 auxiliary boiler condensate and feedwater system

* 2.3.4.8 hot water heating system

* 2.3.4.9 hot water pre-heating system

* 2.3.4.10 steam generator chemical addition system

* 2.3.4.11 turbine plant miscellaneous drains system

The corresponding subsections of this SER (2.3B.4.1 - 2.3B.4.1 1, respectively) present the

staff's related review findings.

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2.3B.4.1 Main Steam System

2.3B.4.1.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.1, the applicant described the main steam system. The main steam

system transports steam from the steam generators to the turbine-generator. This system also

provides a means of controlled heat release from the nuclear steam supply system during

periods of station electrical load rejection or when the condenser is not available. The system

provides steam for various auxiliary services including the steam generator auxiliary feedwater

pump turbine, turbine gland sealing, and auxiliary steam.

The main steam system provides a steam flow path to remove heat from the RCS,

overpressure protection for the steam generators, steam to the steam generator auxiliary

feedwater pump turbine, isolation at system interfaces, containment pressure boundary

integrity, and RG 1.97 safety-related indications. The main steam system also prevents

uncontrolled blowdown of more than one steam generator following a main steam line break

(MSLB), limits the maximum steam flow rate from a faulted steam generator; and provides

steam generator isolation and RCS heat removal in'the event of a high-energy line break

(HELB) outside containment. The main steam system contains NSR components that are

spatially oriented such that their failure could prevent the satisfactory accomplishment of a

safety-related function associated with a safety-related SSC. The system' also includes

environmental qualification components and supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

a provides a pressure boundary

In LRA Table 2.3.4-1, the applicant identified the following main steam system component types

that are within the scope of license renewal and subject to an AMR: expansion joints; flexible

hoses; flow elements; pipe; steam traps; tubing; and valves.

2.3B.4.1.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.1 and Millstone FSAR Sections 7.1.2.5, 7.3.2, 10.3, and

15.0. The staff's review, using the evaluation methodology described in Section 2.3 of this SER,

was conducted in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.4.1.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

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AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the main steam system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the main steam

system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.4.2 Feedwater System

2.3B.4.2.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.2, the applicant described the feedwater system. The feedwater system heats and supplies condensate-quality water to the secondary-side of the steam generators to

support heat removal from the RCS. A portion of the system provides the flowpath for auxiliary feedwater flow to the steam generators.

The feedwater system provides a flow path for auxiliary feedwater to the steam generators, isolation of feedwater flow in response to an MSLB accident, steam generator isolation and

auxiliary feedwater flowpath in response to a HELB outside containment, containment pressure boundary integrity, and RG 1.97 safety-related indications. The feedwater system provides NSR

signals to the plant process computer for calorimetric calculations. The system contains

environmental qualification components and supports fire protection and station blackout.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.4-2, the applicant identified the following feedwater system component types that are within the scope of license renewal and subject to an AMR: control blocks, flow

elements; hydraulic reservoirs; nitrogen accumulators; pipe; tubing; and valves.

2.3B.4.2.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.2 and Millstone FSAR Sections 7.1.2.5, 10.4.7, 15.1, and

15.2. The staffs review, using the evaluation methodology described in Section 2.3 of this SER,

was conducted in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.4.2 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that a license renewal drawing for the feedwater system indicates

that a portion of the feedwater system is continued on another license renewal drawing. However, this drawing is not included in the LRA. Additionally, LRA Section 2.3.4.2 states that

"the evaluation boundary begins at the feedwater flow elements" but does not identify the

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particular elements to which the LRA refers. In RAI 2.3:.2-1 B, dated June 9, 2004, the staff

requested the applicant to supply the drawing that contained the remainder of the feedwater

system or to describe the portions of the system that are not shown on a license renewal

drawing, such as the flow elements.

In its response, dated July 26, 2004, the applicant stated that the feedwater system license

renewal boundary begins at the subject flow elements shown on license renewal drawings for

the feedwater system. The flow elements are FE-48A, -48B, -48C, and -48D. There are no

feedwater system components within the scope of license renewal on other drawings.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.2-1 B acceptable,

because the applicant adequately explained that the'system evaluation boundary for the

feedwater system begins at flow elements FE48A, -48B, -48C, and -48D shown on the license

renewal drawings and that no other feedwater system components within the scope of license

renewal exist on other drawings. Therefore, the staff's concern described in RAI 2.3.4.2-1 B is

resolved. -

2.38.4.2.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI response:

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On' the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the feedwater system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the feedwater system

components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

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

2.38.4.3.1 Summary of Technical Information inthe Application

In LRA Section 2.3.4.3, the applicant described the condensate make-up and draw-off system.

The condensate make-up and draw-off system supplies make-up water to various plant

systems, including condensate and feedwater.

The condensate make-up and draw-off system supports fire protection.

The intended function within the scope of license renewal includes providing a pressure

boundary.

In LRA Table 2.3.4-3, the applicant identified the following condensate make-up and draw-off

system component types that are within the scope of license renewal and subject to an AMR:

condensate storage tank; pipe; rupture disk; tubing; and valves.

2.38.4.3.2 Staff Evaluation ^.;-

The staff reviewed LRA Section 2.3.4.3 and Millstone FSAR Sections 10.3.5, 10.4.7.2, and

10.4.8. The staff's review, using the evaluation methodology described in Section 2.3 of this

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SER, was conducted in accordance with the guidance described in Section 2.3 of NUREG1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.3.4.3 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAI as discussed below.

In its review, the staff stated that the FSAR states that a recirculation heating subsystem is

provided for the condensate storage tank to maintain a minimum water temperature of 40 OF

and thus prevent freezing of tank inventory. The components of this subsystem are located

outside of the condensate storage tank in the yard and are heat-traced to prevent freezing. A

license renewal drawing for the condensate make-up and draw-off system shows that the

components downstream of valves isolating the recirculating heating system from the

condensate storage tank are not within the scope of license renewal. The condensate make-up

and draw-off system is within the scope of license renewal because the condensate storage

tank provides a backup supply of water to the auxiliary feedwater pumps. Ice in the condensate

storage tank has the potential of blocking flow to the auxiliary feedwater pumps. In RAI 2.3.4.3-

1 B, dated June 9, 2004, the staff requested the applicant to explain the apparent exclusion of

the condensate storage tank recirculation heating system piping from the scope of license

renewal and from being subject to an AMR.

In its response, dated June, 9, 2004, the applicant stated that the condensate storage tank is

an NSR tank and is within the scope of license renewal to support operation of the auxiliary

feedwater pumps during an Appendix R fire event. Although the condensate storage tank is

provided with a recirculation heating subsystem, the installed low-temperature alarm and

associated actions initiated in response to the alarm, together with the thermal inertia

associated with such a large tank, provide assurance that freezing of the tank contents will not

occur. Therefore, the condensate storage tank recirculation heating subsystem is not required

for the tank to perform its intended function and is not within the scope of license renewal.

In its review, the staff finds the applicant's response to RAI 2.3.4.3-1 B acceptable based on the

explanation for exclusion of the component.

2.3B.4.3.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawing, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the condensate make-up and draw-off system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

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condensate make-up and draw-off system components that are subject to an AMR, as required

by 10 CFR 54.21(a)(1).

2.3B.4.4 Steam Generator Blowdown Systemn

2.3B.4.4.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.4, the applicant described the steam generator blowdown system. The

steam generator blowdown system is used in conjunction with the condensate demineralizer,

chemical addition, and sample systems to control th6 chemistry of the steam generator shell

side water. Steam generator blowdown system flow is automatically isolated upon indications of

a steam generator tube leak or an event requiring conservation of steam generator secondaryside inventory.

The steam generator blowdown system provides'isolation at system interfaces, automatic

isolation of steam generator blowdown flow, containment pressure boundary integrity, and RG

1.97 safety-related indications. The steam generator blowdown system contains NSR

components that are spatially oriented such that their failure could prevent the satisfactory

accomplishment of a safety-related function associated with a safety-related SSC. The system

also includes environmental qualification components and supports fire protection and

anticipated transient without scram.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

v provides a pressure boundary

In LRA Table 2.3.4-4, the applicant identified the following steam generator blowdown system

component types that are within the scope of license renewal and subject to an AMR: flow

elements; pipe; pumps; tubing; and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the steam generator blowdown system. In its December 3,

2004, RAI response, the applicant identified the steam generator blowdown tank component

type that was added to the scope of the steam generator blowdown system.

2.3B.4.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.4 and Millstone FSAR Sections7.1.2.5, 10.4.7, 15.1, and

15.2. The staffs review, using the evaluation methodology described in Section 2.3 of this SER,

was conducted in accordance with the guidance'described in Section 2.3 of NUREG-1800.'''

In conducting its review, the staff evaluated the syst6m functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope'of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

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The staff's review of LRA Section 2.3.4.4 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAI as discussed below.

In its review, the staff noted that a license renewal drawing for, the steam generator blowdown

system shows the license renewal boundary ending at isolation valves for sample lines and

components associated with a skid-mounted radiation monitor. The radiation monitor provides

one of the signals that affect steam generator blowdown system isolation, and lines and

components upstream of the monitor have a pressure boundary intended function. In RAI

2.3.4.4-1 B. dated June 9, 2004, the staff requested the applicant to explain the apparent

exclusion of the radiation monitoring and sample lines and components from the scope of

license renewal and from being subject to an AMR.

In its response, dated July 26, 2004, the applicant stated that the isolation of steam generator

blowdown flow in response to a steam generator blowdown sample monitor signal is not a

license renewal intended function as defined in 10 CFR 54.4(a).. Failure to automatically isolate

the flow of steam generator bldwdown effluent with increased activity levels would not prevent

safe shutdown of the reactor or challenge the offsite dose limits of 1 0 CFR 100. Therefore, the

applicant concluded that the steam generator blowdown sample monitor and associated

components are not within the scope of license renewal.

The staff finds the applicant's response to RAI 2.3.4.4-1 B acceptable, because the applicant

adequately explained exclusion of the component.

The staff also reviewed the results of the scoping methodology changes, set forth in responses

to RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the expanded scope of mechanical components identified in

the December 3, 2004, response acceptable, because the applicant adequately included NSR

components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with

spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the

applicant's December 3, 2004, response related to the scoping and screening results of the

steam generator blowdown system is acceptable.

2.3B.4.4.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawing, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the steam generator blowdown system components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

steam generator blowdown system components that are subject to an AMR, as required by

10 CFR 54.21 (a)(1).

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2.3B.4.5 Auxiliary Feedwater System

2.36.4.5.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.5, the applicant described the auxiliary feedwater system. The auxiliary

feedwater system provides a supply of feedwater to the secondary-side of the steam

generators for RCS heat removal if normal feedwater flow is unavailable. The system consists

of two motor-driven pumps powered from the'emergency busses, and a steam turbine-driven

pump that provides feedwater flow upon a loss ofall AC power. The auxiliary feedwater sy"stem

includes the demineralized water storage tank'that provides a missile-protected 'source of water

to the auxiliary feedwater pumps. Emergency make-up to the tank can be provided from;

domestic water via removable spool pieces. Additionally, the SW system can provide an

alternate source of water to the pumps through removable spool pieces.

The auxiliary feedwater system provides feedwater to the steam generators for removal of

sensible and decay heat from the RCS, isolation of auxiliary feedwater flow to a faulted or''

ruptured steam generator, auxiliary feedwater flow limitation to prevent pump runout, feedwater

flow and steam generator isolation in response to a high-energy line break outside containment,

containment pressure boundary integrity,' and RG 1.97 safety-related indications. The auxiliary

feedwater system contains NSR components that are spatially oriented such that their failure'

could prevent the satisfactory accomplishment of'a safety-related function associated with 'a

safety-related SSC. The system contains environmental qualification components and supports

fire protection, anticipated transient without scram, and station blackout.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary ':

* restricts flow

* provides limited structural integrity': '

In LRA Table 2.3.4-5, the applicant identified the following auxiliary feedwater system

component types that are within the scope of license renewal and subject to an AMR: auxiliary

feedwater (AFW) pump oil coolers; cavitating venturies; demineralized water storage tank; flow

elements; level indicators; lube oil fiiters; oil reservoirs; pipe; pumps; restricting orifices; spool'

pieces; strainers; tubing; turbine casings; and valves.

As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for, the auxiliary feedwater system. In its December 3, 2004,

RAI response, the applicant identified the demineralized water storage tank (DWST) heater

component type that was added to the scope of the auxiliary feedwater system.

2.36.4.5.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.5 and Millstone FSAR Sections 7.3.1 and 10.4.9. The

staffs review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

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functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive' or long-lived components were not omitted from being subject to an AMR in accordance with 10 CFR 54.21(a)(1).

The staff also reviewed the results of the scoping methodology changes, set forth in responses to 04, and December 3, 2004. The staff finds the expanded scope of mechanical components identified in the December 3, 2004, response acceptable, because the applicant adequately included NSR components with the configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with spatial and/or attached piping interaction with safety-related SSCs. The staff concluded that the applicant's December 3, 2004, response related to the scoping and screening results of the auxiliary feeder system is acceptable.

2.3B.4.5.3 Conclusion

The staff reviewed the LRA and RAI response described above to determine whether any SSCs that should be within the scope of license renewal were not identified by the applicant. No omissions were identified. In addition, the staff performed a review to determine whether any components that should be subject to an AMR were not identified by the applicant. No omissions were identified. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the auxiliary feedwater system components that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the auxiliary feedwater system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3B.4.6 Auxiliary Steam System

2.3B.4.6.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.6, the applicant described the auxiliary steam system. The auxiliary steam system supplies steam to various heating and processing equipment during normal plant operations.

The auxiliary steam system provides isolation in the event of a HELB. The auxiliary steam system contains NSR components that are spatially oriented such that their failure could prevent the satisfactory accomplishment of a safety-related function associated with a safety- related SSC. The system also provides environmental qualification components.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity * provides a pressure boundary

In LRA Table 2.3.4-6, the applicant identified the following auxiliary steam system component types that are within the scope of license renewal and subject to an AMR: pipe; tubing; and valves.

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2.3B.4.6.2 Staff Evaluation ;

The staff reviewed LRA Section 2.3.4.6 and Millstone FSAR Section 10.4.10. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were hot omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.3B.4.6.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its'

review, the staff concludes that there is reasonable assurance that the applicant has adequately'

identified the auxiliary steam system provides components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

auxiliary steam system provides components that are subject to an AMR, as required by'

10 CFR 54.21 (a)(1).

2.3B.4.7 Auxiliary Boiler Condensate and Feedwater System

2.3B.4.7.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.7, the applicant described the auxiliary boiler condensate and feedwater

system. The auxiliary boiler condensate and feedwater system provides condensate to the

auxiliary boiler for the generation of auxiliary steam when the main steam system'is not;'

available.

The auxiliary boiler condensate and feedwater system contains NSR components that are

spatially oriented such that their failure could prevent the satisfactory accomplishment of a

safety-related function associated with a safety-related SSC. :

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary -

In LRA Table 2.3.4-7, the applicant identified the following auxiliary boiler condensate and

feedwater system component types that are'within the scope'of license renewal and subject to

an AMR: auxiliary condensate cooler; auxiliary condensate flash tank; auxiliary condensate

tank; level indicators; pipe; pumps; restricting orifices; sample coolers; steam traps; strainers;

tubing; and valves. .

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As a result of the scoping methodology changes made in response to RAI 2.1-1, the applicant

expanded the system boundaries for the auxiliary boiler condensate and feedwater system. In

its December 3, 2004, RAI response, the applicant identified the following component types that

were added to the scope of the auxiliary boiler condensate and feedwater system:

* flow elements

* radiation detectors

2.3B.4.7.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.7 and Millstone FSAR Section 10.4.10. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21 (a)(1).

The staff's review of LRA Section 2.3.4.7 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that the LRA Table 2.3.4.7 lists "Level Indicators" as a component

type subject to an AMR. A license renewal drawing for the auxiliary boiler condensate and

feedwater system shows a level-observation glass for the auxiliary condensate tank as Within

the scope of license renewal. However, a different level-observation glass for the auxiliary

condensate flash tank is shown not within the scope of license renewal. Since the line in which

this component is installed is shown to be within the scope of license renewal, this results in a

discontinuity of the pressure boundary. In RAI 2.3.4.7-1 B, dated June 9, 2004, the staff

requested the applicant to explain the apparent exclusion of the level-observation glass for the

auxiliary condensate flash tank from the scope of license renewal and from being subject to an

AMR.

In its response, dated July 26, 2004, the applicant stated that the level-observation glass for the

auxiliary condensate flash tank is within the scope of license renewal but was inadvertently not

highlighted on the license renewal drawing. The level-observation glass is included in the

existing component type, 'Level Indicators," in LRA Table 2.3.4-7.

The staff finds the applicant's response to RAI 2.3.4.7-1 B acceptable based on inclusion of the

component.

The staff also reviewed the results of the scoping methodology changes, due to response to

RAI 2.1-1, that are described in the applicant's responses dated November 9, 2004, and

December 3, 2004. The staff finds the auxiliary boiler condensate and feedwater system

expanded scope of mechanical components identified in of the December 3, 2004, response

acceptable, because the applicant adequately included the NSR components with the

configurations that meet the scoping criterion of 10 CFR 54.4(a)(2) with spatial and/or attached

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piping interaction with safety-related SSCs.iThe staff concluded that the applicant's

December 3, 2004, response related to the scoping and screening results of the auxiliary boiler

condensate and feedwater system is acceptable. -

2.38.4.7.3 Conclusion '

The staff reviewed the LRA, the'accompanying scoping boundary drawings, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were'identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On'the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the auxiliary boiler condensate and feedwater system components that are within the scope of

license renewal,'as required by 10 CFR 54.4(a),;and that the applicant has adequately

identified the auxiliary boiler condensate and fe'edwater system components that are subject to

an AMR, as required by 10 CFR 54.21 (a)(1). F. . , . - . ,

2.3B.4.8 Hot Water Heating System -

2.3B.4.8.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.8, the applicant described the hot water heating system. The hot water

heating system provides hot water for heating of various plant buildings.

The hot water heating system provides isolation in -the event of a HELB. The hot water heating

system contains NSR components that are spatially oriented such that their failure could -- prevent the satisfactory accomplishment of a safety-related function associated with a safety-' related SSC. The system also provides environmental qualification components.

Intended functions within the scope of license renewal include the following:

v provides limited structural integrity. * provides a pressure boundary

In LRA Table 2.3.4-8, the applicant identified the following hot water heating system component

types that are within the scope of license renewal and subject to an AMR: flex connections; flow

elements; pipe; tubing; unit heaters; and valves.,

2.3B.4.8.2 Staff Evaluation'

The staff reviewed LRA Section 2.3.4.8 and Millstone FSAR Section 9.4.12. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10'CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1). - . -

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The staffs review of LRA Section 2.3.4.8 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that the LRA Section 2.3.4.8 states that the hot water heating

system provides isolation in the event of a HELB and that the evaluation boundary includes the

valves that isolate this break. The FSAR identifies the valves that effect isolation as NSR

valves. A license renewal drawing for the hot water heating system shows these valves within

the scope of license renewal. In RAI 2.3.4.8-1 B, dated June 9, 2004, the staff requested the

applicant to explain how the selected system evaluation boundary would ensure that all the

system-level intended function including HELB isolation would be effected.

In its response, dated July 26, 2004, the applicant stated that the subject valves credited with

the isolation of the HELB were erroneously identified as meeting 10 CFR 54.4(a)(1) instead of

meeting 10 CFR 54.4(a)(2) as these valves are NSR. Further, the applicant stated that with

respect to HELBs, components are determined to be within the scope of license renewal when

they are credited for isolation of pipe breaks in the Millstone 3 current licensing basis for HELBs

outside of containment. Components were not determined to be within the scope of license

renewal solely to provide isolation of pipe breaks of portions of plant systems that are within the

scope of license renewal. Breaks in piping downstream of the subject valves on the license

renewal drawing for the hot water heating system are not postulated in the HELB analysis.

Therefore, no components exist within the scope of license renewal to isolate breaks in the

subject piping.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.8-1 B acceptable,

because the applicant adequately explained that the subject valves are not credited to isolate a

HELB from the piping not within the scope of license renewal. Therefore, the staffs concern

described in RAI 2.3.4.8-1 B is resolved.

2.3B.4.8.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawings, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the hot water heating system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the hot water

heating system components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3B.4.9 Hot Water Pre-heating System

2.3B.4.9.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.9, the applicant described the hot water pre-heating system. The hot water

pre-heating system supplies heated water to various heating coils in the plant.

The hot water pre-heating system contains NSR components that are spatially oriented such

that their failure could prevent the satisfactory accomplishment of a safety-related function

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associated with a safety-related SSC and NSR components that are used to mitigate the effects

of a HELB. The system also provides environmental qualification components.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.4-9, the applicant identified the following hot water pre-heating system

component types that are within the scope of license renewal and subject to an AMR: flow

elements; pipe; tubing; and valves.

2.3B.4.9.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.9 and Millstone FSAR Sections 9.2.6,10.4.7, and 10.4.9.

The staffs review, using the evaluation methodology described in Section 2.3 of this SER, was

conducted in accordance with the guidance described in Section 2.3 of NUREG-1 800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components-with intended

functions delineated in 10 CFR 54.4(a). The staff then reviewed the LRA to verify that passive

or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1). .i

The staff's review of LRA Section 2.3.4.9 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In its review, the staff noted that the LRA Section 2.3.4.9 states that one reason the hot water

preheating system is within the scope of license renewal in accordance with 10 CFR 54.4(a)(2)

is that it contains NSR components that are:used to mitigate the effects of a HELB. In order for

the staff to complete its review of the hot water pre-heating system, information about the

valves credited with the isolation of a HELB was needed. In RAI 2.3.4.9-1 B, dated June 9,

2004, the staff requested the applicant to provide the location of the isolation valves on a

license renewal drawing and identify the high energy line where the potential break would

occur.

In its response, dated July 26, 2004, the applicant stated that LRA Section 2.3.4.9 inadvertently

identified a HELB function for the hot water pre-heating system. The applicant further stated

that there are no hot water pre-heating system components relied upon to mitigate a HELB in

this system.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.9-1 B acceptable,

because the applicant adequately explained that the subject valves are not credited to isolate a

HELB from the piping not within the scope of license renewal. Therefore, the staffs concern

described in RAI 2.3.4.9-1 B is resolved.

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2.3B.4.9.3 Conclusion

The staff reviewed the LRA, the accompanying scoping boundary drawing, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the hot water pre-heating system components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the hot water preheating system components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.3B.4. 10 Steam Generator Chemical Addition System

2.3B.4.10.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.10, the applicant described the steam generator chemical addition system.

The steam generator chemical addition system is used during plant shutdown to control steam

generator secondary-side water chemistry.

The steam generator chemical addition system provides containment pressure boundary

integrity and RG 1.97 safety-related indications. The steam generator chemical addition system

contains NSR components that are spatially oriented such that their failure could prevent the

satisfactory accomplishment of a safety-related function associated with a safety-related SSC.

The system also provides environmental qualification components.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.4-10, the applicant identified the following steam generator chemical addition

system component types that are within the scope of license renewal and subject to an AMR:

pipe and valves.

2.3B.4.10.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.10 and Millstone FSAR Section 10.4.7. The staff's review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21(a)(1).

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2.3B.4.10.3 Conclusion

The staff reviewed the LRA to determine whether any SSCs that should be within the scope of;

license renewal were not identified by the applicant. No omissions were identified. In addition,

the staff performed a review to determine whether any components that should be subject to an

AMR were not identified by the applicant. No omissions were identified. On the basis of its

review, the staff concludes that there is reasonable assurance that the applicant has adequately

identified the steam generator chemical addition system components that are within the scope

of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the steam generator chemical addition system components that are subject to an

AMR, as required by 10 CFR 54.21(a)(1).

2.3B.4.11 Turbine Plant Miscellaneous Drains System

2.3B.4.11.1 Summary of Technical Information in the Application

In LRA Section 2.3.4.11, the applicant described the turbine plant miscellaneous drains system.

The turbine plant miscellaneous drains system provides a flowpath for the removal of moisture

from the main steam system, including steam lines to the steam-driven auxiliary feedwater

pump turbine.

The turbine plant miscellaneous drains system provides 'a pressure boundary for the main

steam system, containment pressure boundary integrity, and RG 1.97 safety-related

indications. The turbine plant miscellaneous drains-system contains NSR components that are

spatially oriented such that their failure could prevent the satisfactory accomplishment of a

safety-related function associated with a safety-related SSC. The system contains

environmental qualification equipment.

Intended functions within the scope of license renewal include the following:

* provides limited structural integrity

* provides a pressure boundary

In LRA Table 2.3.4-11, the applicant identified the following turbine plant miscellaneous drains

system component types that are within the scope of license renewal and subject to an AMR:

pipe; steam traps; valves.

2.3B.4.11.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.11 and Millstone FSAR Section 10.3. The staffs review,

using the evaluation methodology described in Section 2.3 of this SER, was conducted in

accordance with the guidance described in Section 2.3 of NUREG-1800.

In conducting its review, the staff evaluated the system functions described in the LRA and

Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the

applicant did not omit from the scope of license renewal any components with intended

functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then

reviewed the LRA to verify that passive or long-lived components were not omitted from being

subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

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2.3B.4.11.3 Conclusion

During its review of the information provided in the LRA and licensing basis information, the

staff did not identify any omissions or discrepancies in the applicant's scoping and screening

results for the components of the turbine plant miscellaneous drains system. Therefore, the

staff concludes that the applicant has adequately identified the turbine plant miscellaneous

drains system components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the turbine plant

miscellaneous drains system components that are subject to an AMR, as required by

10 CFR 54.21 (a)(1).

2.4 Scoping and Screening Results - Structures

This section documents the staffs review of the applicant's scoping and screening results for

structures. Specifically, this section discusses the following structures:

* containment

* structures and component supports

* nuclear steam supply system equipment supports

* general structural supports

* miscellaneous structural commodities

* load handling cranes and devices

In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant must identify and list

passive, long-lived structures, systems, and components (SSCs) that are within the scope of

license renewal and subject to an AMR. To verify that the applicant properly implemented its

methodology, the staff focused its review on the implementation results. This approach allowed

the staff to confirm that there was no omissions of SSCs that meet the scoping criteria and are

subject to an AMR.

Staff Evaluation Methodology. The staffs evaluation of the information provided in the LRA was

performed in the same manner for all structures. The objective of the review was to determine if

the components and supporting structures for a specific structure that appeared to meet the

scoping criteria specified in the Rule were identified by the applicant as within the scope of

license renewal in accordance with 10 CFR 54.4. Similarly, the staff evaluated the applicant's

screening results to verify that all long-lived, passive components were subject to an AMR in

accordance with 10 CFR 54.21 (a)(1).

Scoping. To perform its evaluation, the staff reviewed the applicable LRA section and

associated component drawings, focusing its review on components that had not been

identified as within the scope of renewal. The staff reviewed relevant licensing basis

documents, including the final safety analysis report (FSAR), for each structure and component

to determine if the applicant had omitted system components with intended functions delineated

under 10 CFR 54.4(a) from the scope of license renewal. The staff also reviewed the licensing

basis documents to determine if all intended functions delineated in 10 CFR 54.4(a) were

specified in the LRA. If omissions were identified, the staff requested additional information to

resolve the discrepancy.

Screening. Once the staff completed its review of the scoping results, the staff evaluated the

applicant's screening results. For those structures and components with intended functions, the

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staff sought to determine (1) if the functions are performed with moving parts or involve a

change in configuration or properties, or (2) if the structures and components are subject to

replacement based on a qualified life or specified time period, as described in

10 CFR 54.21 (a)(1). For those that did not meet either of these criteria, the staff sought to

confirm that these structures and components were subject to an AMR as required by

10 CFR 54.21(a)(1). If discrepancies were identifiedthe staff requested additional information

to resolve them.

Tables 2.2-4 in the Millstone 2 and Millstone 3 LRAs are identical; they list the structures that

are not within the scope of license renewal. The staffs review of LRA Table 2.2-4 identified

several areas in which additional information was necessary to complete the review of the

applicant's scoping results. Therefore, the staff issued RAI 2.4-1 and RAI 2.4-2, to determine

whether the applicant properly applied the scoping criteria of 10 CFR 54.4(a).

RAI 2.4-1. For most of the structures listed, there is no descriptive information in the FSARs.

Consequently, the staff could not conclude that all of the structures listed in LRA Table 2.2-4

serve no intended function. For each of the following structures not described in the FSARs, the

applicant was requested to submit its technical basis for concluding the structure is not within

the scope of license renewal:

* above ground 6000-gallon fuel tank foundation

* above ground diesel fuel tank foundation

* above ground gasoline tank foundation

* a-frame -

* block house (electric)

*. chemistry safety storage building .;. -

* condensate polishing service water strainer house (Unit 2)

* flammable liquids/ hazardous material building

* flammable storage buildings

* fuel oil storage facility

* gas bottle storage building

* hazardous waste processing

* hazardous waste storage building

* hydrogen recombiner portable personnel contamination monitors (PCM) enclosure

* incompatible hazardous waste storage building

* low-level radwaste storage

* Millstone radwaste reduction facility PCM enclosure

* steel transmission towers - -

* Unit 1 discharge structure ,i

* Unit I intake structure

* Unit 1 reactor building

* Unit 1 solid radwaste building

* Unit 1 switchyard

* Unit 1 waste surge tank foundationri.

* Unit 1 xenon-krypton building' -

* Unit 2 hydrogen cylinder storage area

* Unit 2 service water pump strainer house structure

* Unit 3 auxiliary building PCM enclosure

v Unit 3 condensate surge tank foundation

v Unit 3 domestic water storage tank foundation

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* Unit 3 groundwater underdrains storage tank foundation * Unit 3 PGST A and B nitrogen storage tank foundation

* Unit 3 water treatment storage tank foundation

The applicant was also asked to verify that a seismic 11/l intended function, in accordance with 10 CFR 54.4(a)(2), is not applicable to any of the structures and structural components listed in LRA Table 2.24.

In its response to RAI 2.4-1, dated December 3, 2004, the applicant stated:

Part 1

6000 Gal. Above Ground Fuel Tank Foundation (bldg 484)

The foundation for this tank is the concrete loading dock. This is a freestanding modular tank structure that is located on top of the concrete loading dock between buildings 409 and 410. The tank does not have a foundation designed specifically for the tank. The tank stores heating fuel oil for the heating systems in these buildings. Neither these buildings nor the loading dock or the tank has a license renewal intended function. This non-safety related structure is located such that it does not affect any safety related structures.

Above Ground Diesel Fuel Tank Foundation (bldg 476)

This is a concrete foundation that provides structural support for the tank that is used to store diesel fuel oil for the motor pool. Neither the foundation nor the tank has a license renewal intended function. This non-safety related structure is located such that it does not affect any safety related structures.

Above Ground Gasoline Tank Foundation (bldg 474)

This is a concrete foundation that provides structural support for the tank that is used to store gasoline for the motor pool. Neither the foundation nor the tank has a license renewal intended function. This non-safety related structure is located such that it does not affect any safety related structures.

A-Frame (bldg 503)

This is a freestanding structure outside the protected area that is used for meetings and administrative functions. It does not have a license renewal intended function. This non- safety related structure is located such that it does not affect any safety related structures.

Block House (Electric) (bldg 423)

This is a freestanding structure that houses electrical equipment for the non-safety related off-site power supply. It does not have a license renewal intended function. This non-safety related structure is located such that it does not affect any safety related structures.

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Chemistry Safety Storage Building (bldg 457)

This is a freestanding modular structure that is'used for temporary storage of flammable

or hazardous materials. It does not have a license renewal intended function. This

non-safety related structure is located such that it does not affect any safety related

structures.

Condensate Polishing Service Water Strainer House (Unit 2) (bldg 222) .

This is the same structure as the "Unit 2 Service Water Pump Strainer House Structure"

listed below. This Class II structure is located adjacent to and north of the Unit 2 Intake

Structure and originally housed the strainer for. the service water supply to the r

condensate polishing facility. The service water supply is no longer required, the strainer

has been removed, and the associated pipin g'is capped and abandoned. The building is

currently used by the Maintenance Department for storage of maintenance equipment. It

does not contain any equipment that is'within the scope of license renewal. The Unit 2

Intake Structure,'which is a safety related Class I structure, is within the scope of license

renewal.

The Condensate Polishing Service Water.Strainer House is a heavily reinforced

concrete structure with 12-inch-thick walls and an 8-inch reinforced concrete roof slab

that supports a built-up ro6fing systrm: The Condensate P6lishing Service Water

Strainer House is separated from'the Intake'Structure'by a seisrriic gap filled with

compressible material. This compressible material is within the scobpe of license renewal

and subject to aging management. It is included in the Commodity Group "Expansion

joint/Seismic gap material (between adjacent buildings/structures)," as indicated in LRA

Table 2.4.2-25, Miscellaneous Structural Commodities.

FSAR Section 5.1.1.1 Class I Structures states that "Class I structures are designed to

withstand the appropriate' seismic and 'other applicable loads without loss of function.

These Class I structures are sufficiently isolated or protected from Class II structures to

ensure that their integrity are maintained at all times."

Based on the statements from FSAR Section 5.1.1.1 and on the robust design and

construction 'of the Condensate Polishing Service Water Strainer House including the

seismic gap,. it is not credible to postulate failure of this structure. Even if such failure is

postulated, it will not prevent the Class I Intake Structure from performing its'intended

function. However, to conservatively ensure the integrity of the Class 1 Intake Structure,

the Condensate Polishing Service,Water Strainer House will be added to the scope of

license renewal. The structure consists of structural reinforced concrete in air-and

atmosphere/weather environment. The aging effects requiring management are loss of

material, cracking, and change of material properties. These aging effects will be

managed by-the Structures Monitoring Program AMP that is described in LRA Section

B2.1.23. The aging management review results are included in Table 1.

Flammable Liquids/ Hazardous Material Building (bldg 479)_ - '

,This is a freestanding modular structure that is used for temporary storage of flammable

or hazardous materials., It does not have a license renewal intended function. This

non-safety related structure is'located such that it'does not affect any safety related

structures.

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Flammable Storage Buildings (bidgs 421, 477, 481)

These are freestanding structures that are used for temporary storage of flammable

materials. None has a license renewal intended function. These non-safety related

structures are located such that they do not affect any safety related structures.

Fuel Oil Storage Facility (bldg 128)

This is a freestanding structure that was under construction when it was abandoned in

place. It was never completed and does not store any fuel oil. It does not have a license

renewal intended function. This non-safety related structure is located such that it does

not affect any safety related structures.

Gas Bottle Storage Building (bldg 450)

This is a freestanding structure that is used for storage of bottled gas. It does not have a

license renewal intended function. This non-safety related structure is located such that

it does not affect any safety related structures.

Hazardous Waste Processing (bIdg 455)

This is a freestanding structure that is used for processing hazardous waste. It does not

have a license renewal intended function. This non-safety related structure is located

such that it does not affect any safety related structures.

Hazardous Waste Storage Bldg. (bldg 543)

This is a freestanding structure outside the protected area that is used for temporary

storage of hazardous waste materials. It does not have a license renewal intended

function. This non-safety related structure is located such that it does not affect any

safety related structures.

Hydrogen Recombiner Portable PCM Enclosure (bldg 657)

This enclosure housed the personnel contamination monitors (PCM) used for monitoring

personnel contamination when exiting the radiologically controlled area of the hydrogen

recombiner building. This enclosure has been removed from the south side of the

hydrogen recombiner building.

Incompatible Hazardous Waste Storage Bldg. (bldg 544)

This is a freestanding structure outside the protected area that is used for temporary

storage of incompatible hazardous waste materials. It does not have a license renewal

intended function. This non-safety related structure is located such that it does not affect

any safety related structures.

Low Level Radwaste Storage (bldg 505)

This is a freestanding structure outside the protected area that is used for temporary

storage of low-level radwaste materials. It does not have a license renewal intended

function. This non-safety related structure is located such that it does not affect any

safety related structures.

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MRRF PCM Enclosure (bldg 461)

This is a freestanding structure that houses the personnel contamination monitors

(PCM) used for monitoring personnel contamination when exiting radiologically

controlled area at the Millstone Radwaste Reduction Facility (MRRF). It does not have a

license renewal intended function;:This non-safety related structure is located such that

it does not affect any safety related structures.''--

Steel Transmission Towers

These are freestanding steel towers mounted on concrete foundations. The steel

transmission towers and their foundations are generally not within the scope of license

renewal with one exception. The three steel transmission towers and foundations

required to support the electrical lines for Station Blackout as required by

10 CFR 54.4(a)(3) are within the scope of license renewal. These towers are identified

as being within the scope of license renewal in Section 2.4.2.25 of the Unit 3 LRA and

Section 2.4.2.16 of the Unit 2 LRA. The' remaining steel towers are those referenced in

Table 2.24.

Of the three towers that are in scope, one tower supports the 345kV lines between the

Unit 3 reserve station service transformer and the switchyard 'and the other two support

the 345kV lines between the Unit 2 reserve station service transformer and the

switchyard as shown on license renewal Site Plan 25205-LRI0025.

The height of Steel Transmission Towers' varies from 85 to 115 feet as indicated in the

table below.

Tower No. Height (ft) Unit In-scope of LR

1T-1 100 .1 N

1T-2 115 1 N

1T-3 115 1 N

1G-1 105 .,1 N

1G-2 105 1- N

IG-3 110 1 N

2T-2 85 2 Y

2T-3 90 2 Y

2G-2 85 2 N

2G-3 90 2 N

3G-2 85 _ 3 N

3G-3 '110 3 N

3T-3 , 110' ',3 Y

All steel transmission towers are located far enough away from the plant so that if any

were to fall, they would not cause'any damage to'any in scope structure/component that

performs a safety related function.

The steel transmission tower not within the scope of license renewal that is closest to a

safety related structure/component is tower number 3G-2. The safety related structure is

the Unit 3 Refueling Water Storage Tank' (bldg 313). This tower is 85 feet tall and is

located approximately 160 feet to the east of the-Refueling Water'Storage Tank. All the

remaining steel transmission towers that are not within the scope of license renewal are

more than 360 feet away from any safetyrelated structure/component. 7. . .,..:..

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X

Unit 1 Discharge Structure (bldg 102)

This is a reinforced concrete embedment type structure that terminates the Unit 1

condenser discharge piping where it enters the common discharge quarry. It is part of

the permanently defueled boiling water reactor nuclear power complex located at the

southern end of the site. It does not have a license renewal intended function. This Unit

1 non-safety related structure is located such that it does not affect any Unit 2 or Unit 3

safety related structures.

Unit 1 Intake Structure (bIdg 107)

This is a freestanding reinforced concrete structure that houses the cooling water

pumps that used to supply the Unit 1 condenser and service water systems. It is part of

the permanently defueled boiling water reactor nuclear power complex located at the

southern end of the Millstone site. It does not have a license renewal intended function.

This Unit 1 non-safety related structure is located such that it does not affect any Unit 2

or Unit 3 safety-related structures.

Unit 1 Reactor Building (bldg 111)

This is a reinforced concrete structure that houses the remnants of the Unit 1 nuclear

reactor, and the spent fuel pool. It is part of the permanently defueled boiling water

reactor nuclear power complex located at the southern end of the Millstone site. It does

not have a license renewal intended function. The Unit 1 reactor building structure is

being maintained as safety-related class 1 for Unit 1 decommissioning purposes only.

Therefore, it does not affect any Unit 2 or Unit 3 safety-related structures.

Unit 1 Solid Radwaste Building (bldg 119)

This is a concrete and steel structure that provides an area for indoor storage of solid

radwaste for the Unit 1 radwaste processing systems. It is part of the permanently

defueled boiling water reactor nuclear power complex located at the southern end of the

Millstone site. It does not have a license renewal intended function. This Unit I

non-safety-related structure is located such that it does not affect any Unit 2 or Unit 3

safety-related structures.

Unit I Switchyard (bldg 104)

This is a series of steel structures that supports the transmission equipment for the

electrical power previously generated at Unit 1. It is part of the permanently defueled

boiling water reactor nuclear power complex located at the southern end of the Millstone

site. It does not have a license renewal intended function. This Unit 1 non-safety-related

structure is located such that it does not affect any Unit 2 or Unit 3 safety-related

structures.

Unit 1 Waste Surge Tank Foundation (bIdg 115)

This is a concrete foundation that provides structural support for the waste surge tank. It

is part of the permanently defueled boiling water reactor nuclear power complex located

at the southern end of the Millstone site. It does not have a license renewal intended

function. This Unit 1 non-safety-related structure is located such that it does not affect

any Unit 2 or Unit 3 safety-related structures.

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:Unit I Xenon-Krypton Building (bldg 116)

This is'a'freestanding coricrete structure that houses the charcoal absorption beds

previously used to process effluent gases from Unit 1. It is part of the permanently

defueled boiling water reactor nuclear, power complex located at the southern end of the

Millstone site. It does not have a license'renewal intended function. This Unit 1

non-safety-related structure is located such that it does not affect any Unit 2 or Unit 3

safety-related structures.

Unit 2 Hydrogen Cylinder Storage Area (bldg 226)

This is a freestanding multi-tank structure'that is used for storage and supply of

hydrogen used at Unit 2. The structure consists of a concrete slab foundation on grade

that supports a masonry block wall on Mtwo6sides. Upon further review, the masonry block

wall has been determined to function as a firewall between the storage facility and the

Unit 2 turbine building and should have-been identified with a fire barrier function. As a

result, this structure has been added to the scope of license renewal

Unit 2 Service Water Pump Strainer House Structure (bldg 222)

This is the same structure as the Condensate Polishing Service Water Strainer House

(Unit 2)" listed above.

Unit 3 Auxiliary Building PCM Enclosure (bldg 463)

This is a wooden structure that houses the personnel contamination monitors (PCM)

used for monitoring personnel contamination when exiting the radiologically controlled

areas within the buildings of the Unit 3 nuclear power complex. It does not have a*

license renewal intended function. This non-safety-related structure is located such that

it does not affect any safety-related structures.' -

Unit 3 Condensate Surge Tank Foundation (bldg 304)--:

This is a concrete foundation that provides'structural support for the condensate surge tank: Neither the foundation nor the'tank has a license renewal intended function. This

non-safety-related structure is located 'such that it does not affect any safety-related

structures.

Unit 3 Domestic Water Storage Tank Foundation

This item was listed in error. Unit 3.does not have a tank (or foundation) with this name.

Unit 3 does have a water treatment storage tank that contains domestic water. The

Water Treatment Storage Tank and its foundation are not within the scope of license

renewal. This non-safety-related structure is located such that it does not affect any

- safety-related structures. -

Unit 3 Groundwater Underdrains Storage Tank Foundation

This tank shares the concrete foundation of the refueling water storage tank (bldg 313).

Note that LRA Section 2.2-4 inadvertently listed a structure "Unit 3 Groundwater ,,, - 'Underdrains Storage Tank Foundation", although there is'no such structure at Millstone

Power Station. The refueling water storag'e tank and its fdundation are within the scope

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of license renewal. In addition, the groundwater underdrains storage tank was added to the scope of license renewal during the 10 CFR 54.4(a)(2) review (reference RAI 2.1-1). Therefore, both tanks and the common foundation are within the scope of license renewal.

Unit 3 PGST A and B Nitrogen Storage Tank Foundation

This is a concrete foundation that provides structural support for the A & B primary grade water storage tanks nitrogen system tank. It is located adjacent to the primary grade water storage tanks foundation. Neither this tank nor its foundation has a license renewal intended function. These non-safety-related structures are located such that they do not affect any safety-related structures.

Unit 3 Water Treatment Storage Tank Foundation (bldg 306)

This is a concrete foundation that provides structural support for the water treatment storage tank. Neither this tank nor its foundation has a license renewal intended function. This nonsafety-related structure is located such that it does not affect any safety-related structures.

Part 2

With regard to verification of the applicability of the seismic 11/l intended function for all the structures or structural components in LRA Table 2.2-4, the scoping process, outlined in Section 2.1.4.1, required review of the seismic 11/I intended function of all of the structures. The structures reviewed above provide another verification through a sampling of the process and indicate that the scoping methodology is consistent with the requirements in 10 CFR 54.4.

Based on its review, the staff finds the applicant's response to RAI 2.4-1 acceptable for all of the structures listed in the RAI. The staff concurs with the applicant's decision to include several of the listed structures within the scope of license renewal. The staff also concurs with the applicant's basis for excluding the remaining listed structures from the license renewal scope. The staff evaluated the applicant's AMR results for the structures added to the license renewal scope, including Tables 1' and 2 attached to this response, in Section 3.5 of this DSER.

Therefore, the staff considers its concern described in RAI 2.4-1 resolved for all structures listed in the RAI.

In addition, the staff issued RAI 2.4-2 to determine whether the applicant has properly applied the scoping criteria of 10 CFR 54.4(a). The staff's RAI is described below.

Based on the review of the FSAR sections referenced in LRA Table 2.2-4 and additional related sections of the FSAR, the staff could not conclude that all of the structures described in the FSAR sections serve no intended function.

Part 1

The Units 2 and 3 main and normal station transformers are described in Unit 2 FSAR Section 8.1.1, Unit 3 FSAR Section 8.1.7, and Unit 3 FSAR Section 8.3.1.1.1. In Unit 3 FSAR Section 8.3.1.1.1, it states:

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The normal station service transformers have the capacity to supply normal auxiliaries

and those emergency auxiliaries (both load groups) required during normal operation up

to the full output of the main generator plus the capacity to supply Millstone Unit 2 GDC

17 requirements as an alternate offsite source for minimum post-accident loads." and

"Power is supplied to the normal 6.9 kV and 4.16 kV buses through four stepdown

transformers, of which two are normal station service transformers and two are reserve

station service transformers. Each transformer is fully rated to carry all the loads on its

buses during normal operation and any postulated design basis accident plus to carry

Millstone Unit 2 minimum post-accident loads to satisfy GDC 17 requirements as a Unit

2 alternate offsite source.

In Unit 3 FSAR Section 3.1.2.5 OSharing of Structures, Systems, and Components (Criterion

5)," it states:

The following equipment may be shared and utilized by Millstone Unit 2 to meet its GDC

17 requirements for an alternate offsite source to relieve one of its emergency diesel

generators and supply power to minimum post-accident loads:

* Main Transformers 15G-3X-A and 15G-3X-B

* Normal Station Service Transformer 15G-3SA

* Reserve Station Service Transformer 15G-23SA

The sharing of this equipment does not impair its ability to perform its safety function. The

transformers are adequately sized and have sufficient capacity to meet maximum postulated

Unit 3 loading requirements while supplying Unit 2 General Design Criterion-17 (GDC-17)

minimum loads.

Based on this FSAR information, it appeared to the staff that some of these transformers

perform an intended function; if so, then the transformers' structural support would also perform

an intended function. The applicant was requested to clarify whether any of these transformers

and their structural supports perform an intended function and need to be included within the

scope of license renewal.

Part 2

"Miscellaneous Warehouses (#9, #8, #3, #4,- #5;-#6)" are listed in LRA Table 2.2-4 as out-ofscope. The FSAR reference is Unit 3 FSAR Section 3.1.2.5 and FPER 5.5 Analysis 76. The

staff notes that LRA Tables 2.2-3 for both Unit 2 and Unit 3 list the "Unit 2 Condensate

Polishing Facility and Warehouse No. 5" as being within the scope of license renewal. The

applicant was requested to clarify whether Warehouse No. 5 is within the scope of license

renewal and to provide the technical basis for its determination.

Part 3

The Unit 2 sodium hypochlorite building is described in Unit 2 FSAR Section 5.6.1. It states:

An adjacent Class II building, which houses the chlorination equipment, is isolated from

the intake structure by a joint filled with compressible material. General layouts of the

intake structure and circulating water system are shown on Figures 5.6-1 and 5.6-2,

respectively.

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Based on Unit 2 FSAR Figure 5.6-1, it appeared to the staff that failure of the Class-2 building

in a seismic event has the potential to damage safety-related structures and components in

close proximity. The applicant was requested to submit its technical basis for concluding that

the Unit 2 Sodium hypochlorite building does not satisfy the criteria of 10 CFR 54.4(a)(2), for

inclusion within the scope of license renewal.

Part 4

The following tank foundations are referenced to the FSAR sections noted in parentheses:

Unit 1 Demineralized Water Storage Tank Foundation (Unit 2 FSAR Table 9.12 - 1)

Unit 2 Condensate Surge Tank Foundation (Unit 2 FSAR Section 2.7.5.1)

Unit 2 Primary Water Storage Tank Foundation (Unit 2 FSAR Table 9.12 - 1)

Unit 3 Boron Test Tanks Foundation (Unit 3 FSAR Section 9.3.5.2)

Unit 3 Liquid Nitrogen Storage Tank Foundation (Unit 3 FSAR Section 9.2.8.2)

Unit 3 Primary Grade Water Storage Tank Foundation (Unit 3 FSAR Section 9.2.8.3)

Unit 3 Waste Test Tanks Foundation (Unit 3 FSAR Section 11.2.2.1)

Unit 3 Yard Vacuum Priming Tank Foundation (Unit 3 FSAR, FPER 5.5 Analysis 86)

The applicant was requested to verify that none of the systems serviced by these tanks are

within the scope of license renewal. If any system is within the scope of license renewal, the

applicant was requested to submit the technical basis for concluding that the associated tank

and its foundation is not within the scope of license renewal.

In its response to RAI 2.4-2, dated December 3, 2004, the applicant stated:

Part 1

Both Millstone Unit 2 and Unit 3 are designed with preferred normal and alternate offsite

power supplies, as described in the FSAR sections cited in RAI 2.4-2. The design for

offsite power supply includes the main transformers, normal station service

transformers, and reserve station service transformers. In addition, the Millstone Unit 2

licensing basis, for general design criterion (GDC) 17 requirements, credits Unit 3

electrical components, including the main transformers, and a normal station service

and reserve station service transformer, as an alternate offsite power source. For both

units, the emergency onsite power source (i.e., the emergency diesel generators), is the

safety-related power source credited in the accident analyses. The emergency onsite

power source components are included within the scope of license renewal. The main

transformers and normal station service transformers do not meet the scoping criteria of

10 CFR 54.4(a) and do not perform a license renewal intended function. These

transformers do not meet 10 CFR 54.4(a)(1) since they are non-safety-related

components and do not perform safety-related functions. They do not meet

10 CFR 54.4(a)(2) since their failure cannot prevent the accomplishment of the intended

function of any safety-related equipment, and they do not meet 10 CFR 54.4(a)(3) since

they are not credited for any of the cited regulated events. Therefore, the main and

normal station service transformers that provide the preferred normal and alternate

offsite power supplies to the units are not included within the scope of license renewal.

The reserve station service transformers for both Millstone Unit 2 and Unit 3 are

included in scope per 10 CFR 54.4(a)(3) because they are required for the restoration of

offsite power following a station blackout event. The reserve station service transformers

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foundations are within the scope of license renewal and are included in Unit 2 LRA

Table 2.4.2-16 and Unit 3 LRA Table 2.4.2-25 as "Structural Reinforced Concrete."

Part2

There are two separate and individual site structures that have the designation

Warehouse No. 5. These structures are shown on the License Renewal Site Plan

(license renewal drawing 25205-LRI0025, Sh. 1) as Building No. 212 (Unit 2

Condensate Polishing Facility and Warehouse No. 5) and Building No. 435 (Warehouse

#5). Tables 2.2-3 for both Unit 2 and Unit 3 list the Unit 2 Condensate Polishing Facility

and Warehouse No. 5, so designated since the Condensate Polishing Facility is located

within this building, as being within the scope of license renewal. Unit 2 LRA Section

2.4.2.10 and Unit 3 LRA Section 2.4.2.20 provide a description of this structure and the

criteria for which it is considered within the scope of license renewal.

Building No. 435 does not house any equipment or systems that meet the criteria for

inclusion within the scope of license renewal. Therefore, this building is not within the

scope of license renewal and is listed in LRA Table 2.2-4 for both Unit 2 and Unit 3

under Miscellaneous Warehouses (#9, #8, #3, #4, #5, #6).

Part 3

The Unit 2 FSAR Section 5.1.1.1, Class I Structures, states that "Class I structures are

designed to withstand the appropriate seismic and other applicable loads without loss of

function. These Class I structures are sufficiently isolated or protected from Class II

structures to ensure that their integrities are maintained at all times."

The Class II Sodium Hypochlorite Building for Unit 2 is located adjacent to and east of

the Class I Intake Structure. Two safety-related cable pits are also located adjacent to

and east of the Intake Structure, one to the north of and near, the other to the south of

and near the Sodium Hypochlorite Building.

The Sodium Hypochlorite Building is a reinforced concrete structure 16 ft. tall with

12-inch thick walls and a structural steel roof support system. It does not contain any

equipment that is within the scope of license renewal and is a robust structure that is

unlikely to fail in a seismic event. It is separated from the Intake Structure by a seismic

gap filled with compressible material. This compressible material is within the scope of

license renewal and subject to aging management. It is included in the Commodity

.Group "Expansion joint/Seismic gap material (between adjacent buildings/structures),"

as indicated in LRA Table 2.4.2-25, Miscellaneous Structural Commodities.

The Class I Intake Structure is a reinforcedconcrete structure with wall thickness of 1

ft.- 3 in. where it is adjacent to the Sodium Hypochlorite Building wall and is within the

scope of license renewal. The Intake Structure is designed and sufficiently isolated or

protected from the Class II Sodium Hypochlorite Building to ensure that its integrity is

maintained at all times as stated in FSAR Section 5.1.1.1; Class I Structures.

The cable pits are designated safety-related since they house safety-related cables and

are concrete bunkers consisting of 12-inch-thick reinforced concrete walls and roof

supported on a reinforced concrete foundation. The robust design of the cable pits and

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separation from the Sodium Hypochlorite Building (1 foot 5 % inches) is adequate to

ensure that they are sufficiently isolated or protected from the Class II Sodium

Hypochlorite Building to ensure that their integrity are maintained at all times.

Based on the statements from FSAR Section 5.1.1.1 and on the robust design and

construction of the Sodium Hypochlorite Building including the seismic gap, it is not

credible to postulate failure of this structure during a design basis earthquake. Even if

such failure is postulated, it will not prevent the Class I Intake Structure or the Cable Pits

from performing their respective intended functions. However, to conservatively ensure

the integrity of the Class 1 Intake Structure and the Safety-related Cable Pits, the

Sodium Hypochlorite Building will be added 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 an air environment. The aging effects

requiring management are loss of material, cracking, and change of material properties

for structural reinforced concrete and loss of material for structural steel. These aging

effects will be managed by the Structures Monitoring Program AMP that is described in

LRA Section B2.1.23. The aging management review results are included in Table 1.

Part 4

- Unit 1 Demineralized Water Storage Tank Foundation (Unit 2 FSAR Table 9.12-1):

The Millstone Unit 1 demineralized water storage tank has been permanently removed

from service and is not within the scope of license renewal. Therefore, the tank

foundation is not within the scope of license renewal.

- Unit 2 Condensate Surge Tank Foundation (Unit 2 FSAR Section 2.7.5.1): The

condensate surge tank is part of the Condensate Storage and Transfer System which

provides a protected water'source for the auxiliary feedwater pumps.-The condensate

surge tank itself is not the protected water source required to support this license

renewal system intended function and is not within the scope of license renewal.

Therefore, the associated tank foundation is not within the scope of license renewal.

-Unit 2 Primary Water Storage Tank Foundation (Unit 2 FSAR Table 9.12-1): The

primary water storage tank is part of the Primary Makeup Water System, which is within

the scope of license renewal. The Primary Makeup Water System includes

safety-related instrumentation and provides a containment pressure boundary. The

system meets 10 CFR 54.4(a)(2) since the system contains non-safety-related

components that are spatially oriented such that their failure could prevent the function

of safety-related SSCs. The system also meets 10 CFR 54.4(a)(3) because it contains

environmentally qualified equipment. The source of water provided by the tank does not

support the system intended functions and the tank was not originally included within the

scope of license renewal. However, in response to RAI 2.1-1 the Unit 2 primary water

storage tank and foundation were added to the scope of license renewal.

- Unit 3 Boron Test Tanks Foundation (Unit 3 FSAR Section 9.3.5.2): The boron test

tanks are part of the Boron Recovery System which contains non-safety-related

components that are spatially oriented such that their failure could prevent the function

of safety-related SSCs. The system also meets 10 CFR 54.4(a)(3) because it supports

fire protection by providing an alternate letdown path to the boron recovery tanks. The

boron test tanks themselves do not support the system intended functions and are not

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within the scope of license renewal. Therefore,'the associated foundation is not within

the scope of license renewal.

Unit 3 Liquid Nitrogen Storage Tank-Foundation (Unit 3 FSAR Section 9.2.8.2): The

liquid nitrogen storage tank is part of the Nitrogen System, which is within the scope of

license renewal. The Nitrogen System meets .10 CFR 54.4(a)(1) because it includes

safety-related instrumentation and provides a containment pressure boundary. The

system meets 10 CFR 54.4(a)(2) since the system contains non-safety-related

components that are spatially oriented such that their failure could prevent the function

of safety-related SSCs. The system also meets 10 CFR 54.4(a)(3) because it supports

fire protection and contains environmentally qualified equipment. However, the liquid

nitrogen storage tank itself is not required to support any license renewal system

intended functions. Therefore, the liquid nitrogen storage tank and foundation are not

included within the scope of license renewal.

- Unit 3 Primary Grade Water Storage Tank Foundation (Unit 3 FSAR Section 9.2.8.3):

The primary grade water storage tank is part of the Primary Grade Water System, which

is within the scope of license renewal. The Primary Grade Water System meets

10 CFR 54.4(a)(1) because it includes safety-related instrumentation and provides a

containment pressure boundary. The system meets 10 CFR 54.4(a)(2) since the system

contains non-safety-related components that are spatially oriented such that their failure

could prevent the function of safety-related SSCs. The system also meets

10 CFR 54.4(a)(3) because it supports station blackout events and contains

environmentally qualified equipment.

However, the source of water provided by the primary water storage tanks does not

support any license renewal system intended functions. Therefore, the tanks and

associated foundation are not included within the scope of license renewal.

- Unit 3-Waste Test Tanks Foundation (Unit 3 FSAR Section 11.2.2.1): The waste test

tanks are part of the Radioactive Liquid Waste Processing System which contains

non-safety-related components that are spatially oriented such that their failure could

prevent the function of safety-related SSCs. The waste test tanks are not located near

any SR SSCs and do not perform a license renewal intended function. Therefore, the

tanks and associated foundation are not within the'scope of license renewal.

- Unit 3 Yard Vacuum Priming Tank Foundation (Unit 3 FSAR,'FPER 5.5 Analysis 86):

The yard vacuum priming tank is part of the Vacuum Priming System which'is not within

the scope of license renewal since it does not meet any of the criteria of

10 CFR 54.4(a). Therefore, the yard vacuum priming tank and associated foundation

are not within the scope of license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.4-2 acceptable for'Parts 1,

2, 3, and 4 of the RAI. In response to Part 1, the applicant identified the reserve' station service

transformers and their foundations as in-scope, to meet 10 CFR 54.4(a)(3) for station blackout.

In response to Part 2, the applicant clarified the-difference between Warehouse No. 5 and

Warehouse #5. In response to Part 3, the applicant identified that the Unit 2 Sodium

Hypochlorite Building has been added to the license renewal scope. In response to Part 4, the

applicant provided an acceptable basis for-excluding the subject tank foundations, but noted

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that the Unit 2 Primary Water Storage Tank and Foundation have been added to the LR scope

in response to RAI 2.1-1. The staff considers its concern described in RAI 2.4-2 to be resolved.

RAI 2.4.3. The staff also requested additional information concerning the possibility that some

thermal insulation may serve an intended function, in accordance with 10 CFR 54.4(a)(2), to

control the maximum temperature of safety-related structures and structural components that

meet 10 CFR 54.4(a)(1). Thermal insulation is typically passive and long-lived. If it also serves

an intended function in accordance with 10 CFR 54.4(a)(2), then it meets the criteria for

inclusion within the scope of license renewal. Therefore, the staff issued RAI 2.4-3, to

determine whether the applicant properly applied the scoping criteria of 10 CFR 54.4(a), and

the screening criteria of 10 CFR 54.21 (a)(1) to thermal insulation. The staff's RAI is described

below.

Thermal insulation is typically passive and long-lived. If it also serves an intended function in

accordance with 10 CFR 54.4(a)(2), it meets the criteria for inclusion within the scope of license

renewal.

Possible examples of intended functions are (1) maintaining the maximum temperature of

NSSS support members below the maximum temperature assumed in the design basis of the

supports; and (2) maintaining the maximum temperature of structural concrete below the

threshold levels of 150 OF for general areas and 200 OF for local areas around hot penetrations.

Part I - Millstone 2

Millstone 2 FSAR Section 5.2.7.2.2, "Design of High-Temperature Penetrations," states:

High-temperature piping penetrations consist of two for feedwater, two for main steam,

and two for steam generator blowdown. These have a maximum operating temperature

range between 435 *F and 550 "F. Thermal insulation is provided in the air gap between

the pipe and penetration liner sleeve. The combination of insulation and penetration

cooling is designed to restrict maximum temperature in the concrete to 150 "F.

For the condition created by-loss of penetration cooling, the maximum steady state

temperature in the concrete is 300"F at the penetration surface and decreases to 120OF

at a maximum radial depth of 48 inches in the containment wall (Section 9.9.4.4.1).

Millstone 2 FSAR Section 9.9.4, "Containment Penetration Cooling System," states in

subsection 9.9.4.4.1:

The containment penetration cooling system is provided with two full-capacity fans.

Each fan has the capability of maintaining the concrete temperature around the sleeve

below 150 OF. Following the unlikely loss of penetration cooling, a maximum temperature

of 390 OF may be tolerated for 120 days without appreciable loss of strength of the

concrete (Subsection 5.1.3).

Millstone 2 LRA Section 2.3.3.18, "Containment Penetration Cooling System," states:

The Containment Penetration Cooling System functions to limit the temperature of

Containment structure concrete to 150 OF in the vicinity of hot piping penetrations. The

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system consists of two vane axial fans and'the associated system ductwork and

dampers. The system contains fire dampers to prevent the spread of a fire.

The Containment Penetration Cooling'System is within the scope of license renewal

because the system meets 10 CFR 54.4(a)(2) by providing cooling air to the concrete

area surrounding the Contairpment piping prenetrations. The Containment Penetration

Cooling System also supports fire protection.

From the information in FSAR Section 5.2.7.2.2,- thermal insulation works in combination with

the containment penetration cooling system to limit the temperature of concrete at hightemperature penetrations. LRA Section 2.3.3.18 indicates that the containment penetration

cooling system is within the scope of license renewal because the system meets

10 CFR 54.4(a)(2). On this basis, it appears to the staff that the thermal insulation also meets

10 CFR 54.4(a)(2).

Therefore, the applicant was requested to (1) identify whether any thermal insulation at

Millstone 2 serves an intended function in accordance with 10 CFR 54.4(a)(2); (2) describe

plant-specific operating experience related to degradation of (a) thermal insulation in general,

and (b) thermal insulation that serves an intended function in accordance with

10 CFR 54.4(a)(2); and (3) describe the scoping and screening evaluation for thermal insulation

that serves an intended function in accordance with 10 CFR 54.4(a)(2), including the technical

basis for either inclusion within or exclusion from the scope of license renewal.

Part 2 - Millstone 3

Millstone 3 FSAR Section 3.8.1.1.4 (D)(1) describes 'Sleeved Piping Penetration" as follows:

These penetrations have a sleeve around the'outside of forged piping with integral flued

head. Sleeved penetrations are used for multiple small pipes passing through one

penetration and for thermally hot piping systems. Thermally hot piping is insulated to

prevent the operating temperature of the-concrete adjacent to the sleeve, during normal

operation or any other long-term period,-from exceeding 150 !F except at local areas

around the penetrations which are allowed to have' increased temperatures not

exceeding 200 OF; for accident or other short-term periods, the temperatures are not to

exceed 350 OF for the interior surface. However, local areas are allowed to reach 650 OF

from steam or water jets in the event'of pipe failure. Penetrations in which'the insulation

would be insufficient to maintain the concrete within the allowable temperature limit are

equipped with a cooling jacket located inside the sleeve. The cooling water for the

cooling jacket is supplied by the component cooling water subsystem. Each penetration

sleeve carrying thermally hot piping is'designed with adequate space between the

sleeve and the piping to allow for-the required'pipe insulation and for the cooling jacket.'

Millstone 3 LRA Table 2.3.3-4 identifies "Penetration Coolers" as a component type requiring

aging management for the reactor plant component cooling system.

From the information in FSAR Section 3.8.1.1.4 (D)(1), thermal insulation works alone or in

combination with the cooling jacket to limit the temperature of concrete at high-temperature

penetrations. LRA Table 2.3.3-4 indicates that penetration coolers are included within the scope

of license renewal. On this basis, it appears to the staff that the thermal insulation serves an

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intended function in accordance with 10 CFR 54.4(a)(2) and meets the criteria for inclusion

within the scope of license renewal.

Therefore, the applicant was requested to (1) identify whether any thermal insulation at

Millstone 3 serves an intended function in accordance with 10 CFR 54.4(a)(2); (2) describe

plant-specific operating experience related to degradation of (a) thermal insulation in general,

and (b) thermal insulation that serves an intended function in accordance with

10 CFR 54.4(a)(2); and (3) describe the scoping and screening evaluation for thermal insulation

that serves an intended function in accordance with 10 CFR 54.4(a)(2), including the technical

basis for either inclusion within or exclusion from the scope of license renewal.

In its response to RAI 2.4-3, dated November 9, 2004, the applicant stated that:

There is no discussion of insulation functioning to limit the maximum temperature of

NSSS equipment supports included in the FSAR. There are no insulated NSSS

equipment supports.

Cooling systems and the application of thermal insulation for high-temperature piping

containment penetrations are designed to maintain containment structure concrete

temperatures within limits to ensure that long-term degradation of the concrete does not

occur that could degrade the integrity of the structure, as identified in the FSAR

references cited in RAI 2.4-3. Although failure of the penetration cooling systems would

not immediately result in the inability of the containment structure to perform its intended

function, the penetration cooling systems were conservatively included within the scope

of license renewal in accordance with 10 CFR 54.4(a)(2).

There is currently no thermal insulation included within the scope of license renewal for

Millstone Unit 2 or Unit 3. Since the thermal insulation associated with containment

piping penetrations functions to limit the heat transferred to the surrounding concrete,

similar to the piping penetration cooling systems that are within the scope of license

renewal, Dominion will conservatively also include the thermal insulation within the

scope of license renewal. The intended function applied to the insulation is to prevent

excessive heat transmission to the containment concrete surrounding the piping

penetrations.

Based on the aging management review performed for the fiberglass, asbestos, and calcium

silicate piping penetration thermal insulation, there are no applicable aging effects in the indoor

air environment and no aging management program is required.

Based on its review, the staff finds the applicant's revised response to RAI 2.4-3 acceptable

because the applicant has included the subject thermal insulation within the scope of license

renewal. The staff considers RAI 2.4-3 resolved.

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2.4A Unit 2 Scoping and Screening Results - Structures

2.4A.1 Containment

2.4A.1.1 Summary of Technical Information in the Application

In LRA Section'2.4.1, the applicant identified the structures and components of the containment

that are subject to an AMR for license renewal. The containment is a Class I structure, housing

the reactor, NSSS equipment, and various safety-related and non-safety-related components.

The evaluation boundary of the containment consists of the containment structure, including the

liner and internal structural members, and containment penetrations (equipment access'and

personnel lock openings, piping penetrations, electrical penetrations, and the'fuel transfer tube

assembly). The neutron shield tank, refueling cavity liner and reactor cavity seal ring are also

included in the containment evaluation boundary.

The containment .is a Class I structure. The containment non-safety-related structural members

support the function of safety-related equiprment' -The containment also contains EQ equipment

and supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides a pressure boundary

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint) .

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a missile (intemal or external) barrier

* provides EQ barrier and/or HELB barrier- -'

* provides jet impingement shielding for high energy line breaks

In LRA Table 2.4.1-1, the applicant identified the following containment component types that

are within the scope of license renewal and subject to an AMR: containment liner; containment

shell (cylindrical wall and domne);'containient sump screen; door locking mechanism; electrical

penetrations; equipment hatch; equipment pads/grout; expansion bellows; fuel transfer tube;

fuel transfer tube gate valve; fuel transfer tube penetration; gaskets; hinges and pins; jet

impingement barriers, mechanical penetrations; miscellaneous steel [brackets, checkered

plates, embedded steel-exposed surfaces (shapes, plates, unistrut, etc.) ladders, plafforms and

grating, stairs]; missile barriers', moisture barrier; neutron shield tank, brings, personnel lock;

pipe; primary shield wall piate;rea'ct6r' ciavityse ring;,refueling cavitiliner, spare penetrations;

structural reinforced.concrete (beams, columns, floor slabs, foundation mat slabs, pedestals,

walls); structural steel (beams, bracing, columns and baseplates, trusses); tendon anchorages;

tendon gallery; teridon wires; and valve bodies.

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2.4A.1.2 Staff Evaluation

The staff reviewed LRA Section 2.4.1 and the referenced Millstone FSAR Sections. The staffs review was conducted in accordance with the guidance described in Section 2.4 of the NUREG- 1800.

In conducting its review, the staff evaluated the structural or component functions of the containment described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The staff then verified that the passive, long-lived components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

The staff's review of LRA Section 2.4.1 identified several areas in which additional information was necessary to complete the review of the applicant's scoping and screening results. Therefore, the staff issued RAIs 2.4-4, 2.4-5, and 2.4-12 to determine whether the applicant has properly applied the scoping criteria of 10 CFR 54.4(a), and the screening criteria of 10 CFR 54.21 (a)(1).

RAls 2.4-4 and 2.4-5 are applicable to both Unit 2 and Unit 3. The staff's RAls, the applicant's responses, and the staff's evaluations are documented in Millstone 3 SER Section 2.4B.1.

RAI 2.4-12, which is specific to Unit 2, is described below.

LRA Section 2.4.1 'Containment" references FSAR Section 5.9.3.3 for additional details about the containment post-tensioning system. FSAR Section 5.9.3.3.4, 'Corrosion Protection," states:

As a result of the Millstone Unit No. 2 tendon surveillance program, sixteen horizontal tendons have been identified as subject to ground water intrusion. To prevent ground water intrusion, the corrosion protection material is continuously supplied to the subject tendons at a pressure slightly above hydrostatic pressure of the ground water. The tendons so pressurized are horizontal tendons 12H01 through 12H06, 12H08 through 12H10, 31H01 through 31H04, 31H01, 32H02, and 32H03.

In accordance with 10 CFR 54.4(a)(2), the system that continuously supplies corrosion protection material to the sixteen (16) horizontal tendons appears to serve an intended function. The applicant was requested to submit a scoping and screening evaluation and AMR for this system and, If applicable, to provide the technical basis for excluding this system from the scope of license renewal.

In its response to RAI 2.4-12, dated November 9, 2004, the applicant stated that:

The safety-related containment post-tensioning system is in the scope of license renewal because it provides containment structural integrity. The post-tensioning system is composed of horizontal and vertical tendon wires and associated tendon anchorages that are used to prestress the cylindrical portion of the concrete Containment. Corrosion protection material (grease) is continuously applied as a preventative measure to prevent the intrusion of water into 16 horizontal hoop tendons that have been identified

as subject to ground water intrusion. Failure to supply the corrosion protection material

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to the tendons may allow ground water intrusion, but would not affect the tension on the

containment tendons or the structural integrity of the Containment. Additionally, no credit

is taken for corrosion protection of the containment tendons' in the determination of

aging effects. Loss of material was identified for the containment tendons and is

managed with the Inservice Inspection Program: Containment Inspections AMP as

indicated in LRA Table 3.5.2-1.

Therefore, since the pressurized application of corrosion protection material to the tendons is

not required for containment structural integrity or to maintain proper tension-of the tendons,

and is not credited in the aging management review, it does not meet the criteria of

10 CFR 54.4(a)(2) for being included in the scope of license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.4-12 acceptable because

the post-tensioning system is in scope as indicated in LRA Table 3.5.2-1. The staff considers its

concern described in RAI 2.4-12 resolved.

2.4A.1.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were'not identified by the

applicant. In addition, the staff performed a review to determine whether any components that

should be subject to an AMR were not identified by the applicant. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the components of the containment that are within the scope of license renewal, as required by -

10 CFR 54.4(a), and that the applicant has adequately identified the components of the

containment that are subject to an aging management review, as required by

10 CFR 54.21 (a)(1).

2.4A.2 Structures and Component Supports

In LRA Section 2.4.2, the applicant identified the structures and components of the structures

and component supports that are subject to an AMR for license renewal.

The applicant described the structures 'ard component supports in the'following sections

* 2.4.2.1

* 2.4.2.2

* 2.4.2.3

-0 . 2.4.2.4 -

* 2.4.2.5

* 2.4.2.6

* 2.4.2.7--

* 2.4.2.8

* 2.4.2.9

* 2.4.2.10

* 2.4.2.11

* 2.4.2.12

* 2.4.2.13

* 2.4.2.14

* 2.4.2.15

Unit 2 containment enclosure building

Unit 2 auxiliary building

Unit 2 warehouse budilding

Unit 2 turbine building ! s'

Unit 1 turbine building

Unit I 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

iswitchyard control house'.

retaining wall

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* 2.4.2.16 switchyard, 345kV

* 2.4.2.17 Unit 2 intake structure

* 2.4.2.18 sea walls:

* 2.4.2.19 Unit 2 discharge tunnel and discharge structure

* 2.4.2.20 Unit 2 bypass line

* 2.4.2.21 tank foundations

* 2.4.2.22 yard structures

The corresponding subsections of this SER (2.4A.2.1 - 2.4A.2.22, respectively) present the

staffs related findings.

2.4A.2.1 Unit 2 Containment Enclosure Building

2.4A.2.1.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.1, the applicant described the Unit 2 containment enclosure building. The

Unit 2 containment enclosure building is a steel-framed structure, with metal siding and a roof

deck. The enclosure building completely surrounds the containment above grade and is

designed and constructed to limit radioactive leakage to the environment in the unlikely event of

a loss-of-coolant accident (LOCA). The containment enclosure building also encloses the

auxiliary building equipment areas (the east and west main steam and main feedwater

penetration areas).

The containment enclosure building is a Class I structure. The containment enclosure building

non-safety-related structural members support the function of safety-related equipment. The

containment enclosure building also contains EQ equipment, and supports fire protection and

station blackout.

Intended functions within the scope of license renewal include the following:

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a protective barrier for internal/extemal flooding events

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.4.2-1, the applicant identified the following Unit 2 containment enclosure'

building component types that are within the scope of license renewal and subject to an AMR:

blow-off metal siding/panel; doors; equipment pads/grout; flood/spill barriers, including curbs,

dikes, toe plates, and stop logs; metal siding; metal siding-caulking; miscellaneous steel

[embedded steel-exposed surfaces (shapes, plates, unistrut, etc.) ladders, platforms and

grating, stairs]; scuppers; structural reinforced concrete (caisson, floor slabs, grade beams,

slabs on grade, walls); structural steel (beams, bracing, columns and baseplates, concrete floor

framing and decking, roof framing and decking); and vent stacks (supports).

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2.4A.2.1.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.1 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the'guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 2

containment enclosure building described in the LRA and Millstone FSAR in accordance with

the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

2.4A.2.1.3 Conclusion -

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 2

containment enclosure building that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the Unit 2

containment enclosure building that are subject to an aging management review, as required by

10 CFR 54.21 (a)(1).

2.4A.2.2 Unit 2 Auxiliary Building

2.4A.2.2.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.2, the applicant described the Unit 2 auxiliary building. The Unit 2 auxiliary

building includes the auxiliary building structure, spent fuel pool (including transfer canal), spent

fuel storage racks, control room, and service water pipe tunnel. The auxiliary building structure

is a multi-story, reinforced concrete structure founded on bedrock, with'concrete floor slabs,

roof slabs, and walls. Unit 1 control room steel columns support a portion of the auxiliary

building structure in Unit 2. A steel frame structure, which is supported on the operating floor,

supports the cask handling crane and the concrete roof slab, above the spent fuel pool. Steel

platforms, stairs, grating, and ladders are provided inside the auxiliary building structure.

The Unit 2 auxiliary building is a Class I structure. The Unit 2 auxiliary building non-safetyrelated structural members support the function of safety-related equipment. The Unit 2

auxiliary building contains EQ equipment and supports fire protection;station blackout, and

anticipated transient without scram. E.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3) a f s t

*provides structural and/or functional support to equipment meeting 1 0 CFR 54.4(a)(1 )

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* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides jet impingement shielding for HELBs

* provides a protective barrier for internal/external flooding events

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a missile (internal or external) barrier

* provides a pressure boundary

* provides EQ barrier and/or HELB barrier

In LRA Table 2.4.2-2, the applicant identified the following Unit 2 auxiliary building component

types that are within the scope of license renewal and subject to an AMR: control room ceiling

panels; control room ceiling supports; doors; equipment pads/grout; flood/spill barriers including

curbs, dikes, toe plates, and stop logs; masonry block walls; metal siding; metal smoke barrier;

miscellaneous steel [embedded steel-exposed surfaces (shapes, plates, unistrut, etc.) ladders,

platforms and grating, stairs]; neutron absorber elements; scuppers; sliding bearings; spent'fuel

pool gate; spent fuel pool gate-seal; spent fuel pool liner plates; spent fuel storage racks;

structural reinforced concrete (beams, columns, floor slabs, foundation mat slabs, roof slabs,

slabs on grade, walls); structural steel (beams, bracing, columns and baseplates, concrete floor

framing and decking, roof framing and decking); sumps; and tunnel.

2.4A.2.2.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.2 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 2

auxiliary building described in the LRA and Millstone FSAR in accordance with the requirements

of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4A.2.2.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine'whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 2

auxiliary building that are within the scope of license renewal, as required by 10 CFR 54.4(a),

and that the applicant has adequately identified the components of the Unit 2 auxiliary building

that are subject to an aging management review, as required by 10 CFR 54.21(a)(1).

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2.4A.2.3 Unit 2 Warehouse Building

2.4A.2.3.1 Summary of Technical Information in the'Application

In LRA Section 2.4.2.3, the applicant described the Unit 2 warehouse building. The Unit 2

warehouse building includes the warehouse building structure and associated diesel oil supply

tank rooms, new fuel storage room, cask wash pit, emergency diesel generator rooms, and the

pipe tunnel to the RWST. The warehouse building structure is a safety-related structure ' -

founded on compacted structural backfill:The structure is located on the east side of the

auxiliary building and the containment enclosure building. Most of the warehouse building

structure is a multi-story reinforced concrete structure. The cask-handling area has a higher'

roof, which is supported by a steel-framed structure with metal siding. -

The Unit 2 warehouse building is a Class I structure. The Unit 2 warehouse building non-safetyrelated structural members support the function of safety-related equipment. The Unit 2

warehouse building contains EQ equipment and supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides a protective barrier for intemal/extemal flooding events

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a missile (internal or external) barrier

* provides EQ barrier and/or HELB barrier

In LRA Table 2.4.2-3,-the applicant identified the following Unit 2 warehouse building

component types that are within the scope of license renewal and subject to an AMR: cask

wash pit liner; doors; equipment pads/grout; flood/spill barriers including curbs, dikes, toe

plates, and stop logs; masonry block walls; metal siding; miscellaneous steel [embedded steelexposed surfaces (shapes, plates, unistrut, 'etc) ladders, platfonrmsand grating 'stairs]; missile

barriers; new fuel racks assembly; scuppers; structural reinforced concrete (floor slabs,'

foundation mat slabs, roof slabs, walls); structural steel (beams, columns and baseplates,

concrete floor framing and decking, roof framing and decking); and tunnel.

2.4A.2.3.2 Staff Evaluation ' ' '

The staff reviewed LRA Section 2.4.2.3 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800. '' ' '

In conducting its review, the staff evaluated the structural or component functions of the Unit 2

warehouse building described in the LRA and Millstorne FSAR in accordance with the

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requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4A.2.3.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 2

warehouse building that are within the scope of license renewal, as required by 10 CFR 54.4(a),

and that the applicant has adequately identified the components of the Unit 2 warehouse

building that are subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4A.2.4 Unit 2 Turbine Building

2.4A.2.4.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.4, the applicant described the Unit 2 turbine building. The Unit 2 turbine

building is located west of the auxiliary building and the containment enclosure building, and

north of the Unit 1 turbine building. The Unit 2 turbine building is a two-bay steel-framed multistory structure with a high and low roof. The turbine building is enclosed with metal siding, blowoff metal siding/panels and pre-cast concrete panels, roof decking on the high roof, and

concrete slab on the low roof. The foundations for the frames are spread-footing bearing on

bedrock.

The Unit 2 turbine building is a Class I structure. The Unit 2 turbine building non-safety-related

structural members support the function of safety-related equipment. The Unit 2 turbine building

also contains EQ equipment, and supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides a protective barrier for internal/external flooding events

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a missile (internal or external) barrier

* provides EQ barrier and/or HELB barrier

provides jet impingement shielding for high energy line breaks

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In LRA Table 2.4.2-4, the applicant identified the following Unit 2 turbine building component

types that are within the scope of license renewal and subject to an AMR: blow-off metal siding/

panel; doors; equipment pads/grout; flood/spill barriers including curbs, dikes, toe plates, and

stop logs; hatches; masonry block walls; rietal sidin g'; metal siding-caulking; miscellaneous

steel [brackets, checkered plates, embedded steel-exposed surfaces (shapes, plates, unistrut,

etc.) ladders, platforms and grating, stairs]; scuppers; sliding bearings; structural reinforced

concrete (floor slabs, footing and grade beams,'grade beams, pedestals; roof slabs,'slabs on

* grade, spread footing, turbine pedestal, walls); structural steel (beams, bracing, columns and

baseplates, concrete floor framing and-decking, roof framing and 'decking); sump liner; and

sumps. l

2.4A.2.4.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.4 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 2

turbine building described in the LRA and Millstone FSAR in accordance with the requirements

of 10 'CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in'accordance with 10 CFR 54.21(a)(1). "

2.4A.2.4.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were'not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 2

turbine building that are within the scope of license renewal, as required by 10 CFR 54.4(a),

and that the applicant has adequately identified the components of the Unit'2 turbine building

that are subject to an aging management review,'as required by 10'CFR 54.21(a)(1).

2.4A.2.5 Unit I Turbine Building

2.4A.2.5.1 Summary of Techn ical Information in the Application

In LRA Section 2.4.2.5, the applicant described the Unit I turbine building. The Unit 1 turbine

building is a seismic Class I and 11 structure'.The Unit 1 turbine building north wall is common

with the safety-related Unit 2 turbine building. Protection from external flooding on the Unit 2.

turbine building south side is provided by the Unift 1 turbine building.

The Unit 1 turbine building provides support for the safety-related Unit 2 turbine building. The

Unit 1 turbine'building non-safety-related structural members provide flood protectiorn for the

south side of the Unit 2 turbine building.

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IIntended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides a protective barrier for intemal/extemal flooding events

In LRA Table 2.4.2-5, the applicant identified the following Unit 1 turbine building component

types that are within the scope of license renewal and subject to an AMR: h-piles; scuppers;

sliding bearings; structural reinforced concrete (floor slabs, foundation mat slabs, walls); and

structural steel (beams, bracing, columns and baseplates, concrete floor framing and decking,

roof framing and decking).

2.4A.2.5.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.5 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 1

turbine building described in the LRA and Millstone FSAR in accordance with the requirements

of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21(a)(1).

2.4A.2.5.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 1

turbine building that are within the scope of license renewal, as required by 10 CFR 54.4(a),

and that the applicant has adequately identified the components of the Unit 1 turbine building

that are subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4A.2.6 Unit I Control Room and Radwaste Treatment Building

2.4A.2.6.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.6, the applicant described the Unit 1 control room and radwaste treatment

building. The Unit 1 control room and radwaste treatment building is a Seismic Class I and 11

structure with a foundation mat on bedrock. The building includes a below-grade reinforced

1,

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concrete structure with the control room located above grade. The control room is constructed

of reinforced concrete walls with a two-foot-thick reinforced concrete roof.

The Unit 1 control room and radwaste treatment building provides support for-the safety-related

Unit 2 auxiliary building's structure. The Unit 1 control room and radwaste treatment building

non-safety-related structural members provide flood protection. The Unit 1 control room and

radwaste treatment building also supports fire protection.

Intended functions within the scope of license renewal include the following: , p s s l a r f.a

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides structural and/or functional support to equipment meeting 1 0 CFR 54.4(a)(2) or

(a)(3)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides a protective barrier for intemal/extemal flooding events

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant -

* provides a missile (internal or extemal) barrier

In LRA Table 2.4.2-6, the applicant identified the following Unit 1 control room and radwaste

treatment building component types that are within the scope of license renewal and subject to

an AMR: miscellaneous steel (brackets, embedded steel-exposed surfaces (shapes, plates,

unistrut, etc.)); sliding bearings; structural reinforced concrete (floor slabs, foundation mat

slabs, roof slabs, walls); and structural steel (beams, columns and baseplates).

2.4A.2.6.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.6 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.. ,* -

In conducting its review, the staff evaluated the structural or component functions of the Unit 1

control room and radwaste treatment building described in the LRA and Millstone FSAR in

accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit

from the scope of license renewal any components with intended functions delineated in 10

CFR 54.4(a). The staff did not identify any omissions. The staff then verified that the passive,

long-lived components were subject to an AMR,- in accordance with 10 CFR 54.21 (a)(1).

2.4A.2.6.3 Conclusion . -

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

2-259
nIl.

No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 1

control room and radwaste treatment building that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the components of

the Unit 1 control room and radwaste treatment building that are subject to an aging

management review, as required by 10 CFR 54.21(a)(1).

2.4A.2.7 Unit 2 Fire Pump House

2.4A.2.7.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.7, the applicant described the Unit 2 fire pump house. The Unit 2 fire

pump house is supported on a reinforced concrete mat foundation with reinforced masonry walls and structural steel beams supporting the roof. The roof is made up of a 4-inch-thick

concrete slab over metal decking.

The Unit 2 fire pump house supports fire protection.

Intended functions within the scope of license renewal include providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-7, the applicant identified the following Unit 2 fire pump house component types that are within the scope of license renewal and subject to an AMR: equipment

pads/grout; masonry block walls; structural reinforced concrete (foundation mat slabs, roof

slabs); and structural steel (roof framing and decking).

2.4A.2.7.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.7 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 2

fire pump house described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21(a)(1).

2.4A.2.7.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant. No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 2

fire pump house that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the components of the Unit 2 fire pump house

that are subject to an aging management review, as required by 10 CFR 54.21(a)(1).

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2.4A.2.8 Unit 3 Fire Pump House

2.4A.2.8.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.8, the applicant described the Unit 3 fire pump house.'The Unit 3 fire

pump house consists of a reinforced concrete mat foundation with reinforced masonry walls

and structural steel beams supporting the roof. The roof is made up of a 4-inch-thick concrete

slab over metal decking. - -

The Unit 3 fire pump house supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides a rated fire barrier to confine or retard a fire from spreading to or from'adjacent

areas of the plant

* provides a protective barrier for intemal/extemal flooding events

In LRA Table 2.4.2-8, the applicant identified the following Unit 3 fire pump house component'

types that are within the scope of license renewal and subject to an AMR: equipment

pads/grout; flood/spill barriers including curbs,= dikes, toe plates, and stop logs; masonry block

walls; structural reinforced concrete (foundation mat slabs, roof slabs); and structural steel (roof

framing and decking).

2.4A.2.8.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.8 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

fire pump house described in the LRA and Millstone FSAR in accordance with the requirements

of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any'

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21(a)(1). ; ' 

2.4A.2.8.3 Conclusion - :

The staff.reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to'determirie

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

fire pump house that are within the scope of license renewal, as required by 10 CFR 54.4(a),

and that the applicant has adequately identified the components of the Unit 3 fire pump house

that are subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

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

2.4A.2.9.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.9, the applicant described the station blackout (SBO) diesel generator

enclosure and fuel oil tank vault. The SBO diesel generator enclosure includes the SBO diesel

generator switchgear enclosure, the concrete pad that supports the SBO diesel generator

exhaust, and the separate building that provides support and shelter for the SBO diesel.

The SBO diesel generator enclosure and fuel oil tank vault supports fire protection and station

blackout.

The intended function within the scope of license renewal includes providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-9, the applicant identified the following SBO diesel generator enclosure and

fuel oil tank vault component types that are within the scope of license renewal and subject to

an AMR: miscellaneous steel (checkered plates); roofing; siding; structural reinforced concrete

(foundation mat slabs); and structural steel (beams, bracing).

2.4A.2.9.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.9 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the SBO

diesel generator enclosure and fuel oil tank vault described in the LRA and Millstone FSAR in

accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit

from the scope of license renewal any components with intended functions delineated in 10

CFR 54.4(a). The staff did not identify any omissions. The staff then verified that the passive,

long-lived components were subject to an AMR, in accordance with 10 CFR 54.21(a)(1).

2.4A.2.9.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the SBO

diesel generator enclosure and fuel oil tank vault that are within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the components

of the SBO diesel generator enclosure and fuel oil tank vault that are subject to an aging

management review, as required by 10 CFR 54.21 (a)(1).

I'

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

2.4A.2.10.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.10,,the applicant described the Unit 2 condensate polishing facility and

Warehouse No. 5.: The Unit 2 condensate polishing facility is a non-safety-related, non-seismic

structure located in Warehouse No. 5, which also houses Unit 3 fire protection piping. Unit 2

shares this warehouse with Unit 3. The structurelis located north of the Unit 2 turbine building

and has a reinforced concrete mat foundation founded on structural fill. The Unit 2 condensate

polishing facility is located approximately 20 feet below grade. There are three main levels anda penthouse that is located in the middle of the structure near the west wall. The superstructure

is a steel-framed structure and some areas of the structure have masonry walls.

The Unit 2 condensate polishing facility and Warehouse No. 5 supports station blackout and fire

protection. . .. , .4 ..

The intended function within the scope of license renewal includes providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-1 0, the applicant identified the following Unit 2 condensate polishing facility

and Warehouse No. 5 component types that'are within the scope of license renewal and

subject to an AMR: masonry block walls; miscellaneous steel (platforms and grating); structural

reinforced concrete (beams, columns, floor slabs, foundation mat slabs',- walls); and structural

steel (beams, bracing, columns and baseplates).

2.4A.2.10.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.10 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 2

condensate polishing facility and Warehouse No. 5 described in the LRA and Millstone FSAR in

accordance with the requirements of.10 CFR 54.4(a) to verify that the applicant did not omit

from the scope of license renewal any components with intended functions delineated in 10

CFR 54.4(a). The staff did not identify any omissions. The staff then verified that the passive,

long-lived components were subject to an AMR, in accordance with 10 CFR 54.21(a)(1).

2.4A.2.10.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the ,

applicant. No omissions were found. In additionthe staff performed a review to'determine

whether any components that should be subject to anAMR were not identified by the applicant.

No omissions were found. On the basis of its review, the staff concludes that there is ' -

reasonable assurance that the applicant has adequately identified the components of the Unit 2

condensate polishing facility and Warehouse No. 5 that are within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the'applicant has adequately identified the components

of the Unit 2 condensate polishing facility and Warehouse No. 5 that are subject to an aging

management review, as required by 10 CFR 54.21(a)(1).

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A

2.4A.2.11 Security Diesel Generator Enclosure

2.4A.2.11.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.11, the applicant described the security diesel generator enclosure. The

security diesel generator enclosure is a non-safety-related, non-seismic, one-story freestanding structure that houses the security diesel generator and its support equipment,"

including the security diesel fuel oil tank. Power from the security diesel generators is used for

general exterior illumination that is credited for fire protection events. The structure is

constructed with aluminum sheeting riveted to a combination of aluminum and steel frame. The

walls and roof are insulated and lined with plywood on the inside. The building is above grade,

is supported by steel channels, and sits on a concrete slab foundation. Power cables and

conduits from the generator are supported from the ceiling and internal wall surfaces of the

structure.

The security diesel generator enclosure supports fire protection.

Intended functions provides structural and/or functional support to equipment meeting

10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-11, the applicant identified the following security diesel generator enclosure

component types that are within the scope of license renewal and subject to an AMR:

miscellaneous steel (checkered plates); roofing; siding; structural framing; structural reinforced

concrete (foundation mat slabs); and structural steel (beams, bracing).

2.4A.2.11.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.11 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the

security diesel generator enclosure described in the LRA and Millstone FSAR in accordance'

with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope

of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4A.2.11.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the

security diesel generator enclosure that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the' components of the security

diesel generator enclosure that are subject to an aging management review, as required by'

10 CFR 54.21 (a)(1).

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2.4A.2.12 Stack Monitoring Equipment Building

2.4A.2.12.1 Summary of Technical Informationhin'the Application

In LRA Section 2.4.2.12, the applicant described the stack monitoring equipment building. The

stack monitoring equipment building is a non'-safety-related, non-seismic, single-storj structure

that provides support and shelter to non-safety-related equipment that 6an'affect safety-related

equipment. The building has a concrete roof and floor slab on grade with non-reinforced

grouted masonry walls that are supported on a concrete spread footing.

The stack monitoring equipment building non-safety-related structural members support the

function of safety-related equipment.

Intended functions within the scope of license renewal include providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-12, the applicant identified the following stack monitoring equipment

building componenttypes that are within the scope of license renewal and subject to an AMR:

equipment'pads/grout; masonry block walls; aind structural reinforced concrete (roof slabs,

slabs on grade, spread footing, walls).

2.4A.2.12.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.12 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordancedwith the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting'its'review, the staff evaluated the structural or component functions'of the stack

monitoring equipment building described in the LRA and Millstone FSAR in accordance with the''

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then' verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21(a)(1).'

2.4A.2.12.3 Conclusion

The staff reviewed the LRA and related'structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found' In addition, the staff performed a review to determine

whether any components that should be subject to 'n AMR were not identified'by the applicant.

No omissions were found..On the basis of its review, the staff concludes that there is -

reasonable assurance that the applicant has-adedquately identified the components of the stack

monitoring'equipment building that are within the scope of license renewal, as rfquired by

10 CFR 54.4(a), and that the applicant has adequately identified the' components of the stack

monitoring equipment building that are subject to an aging maniagement review, as required by

10 CFR 54.21(a)(1).

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2.4A.2.13 Millstone Stack

2.4A.2.13.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.13, the applicant described the stack. The stack is a safety-related

reinforced-concrete structure supported on a reinforced concrete mat foundation. The stack

extends 375 feet above grade and has a circular orifice with a 7 foot inside diameter. The stack

is a Class I structure.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a missile (intemal or external) barrier

In LRA Table 2.4.2-13, the applicant identified the following stack component types that are

within the scope of license renewal and subject to an AMR: structural reinforced concrete (floor

slabs, foundation mat slabs, walls); and structural steel (beams, bracing).

2.4A.2.13.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.13 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the stack

described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR

54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21(a)(1).

2.4A.2.13.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should, be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the stack

that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the

applicant has adequately identified the components of the stack that are subject to an aging

management review, as required by 10 CFR 54.21(a)(1).

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2.4A.2.14 Switchyard Control House

2.4A.2.14.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.14, the applicant described the switchyard control house. The switchyard

control house is a non-safety-related, non-seismic, one-story building that provides support and

shelter for equipment utilized for closure of the 345kV circuit breakers that are credited for

restoration of offsite power in the event of a station blackout.

The switchyard control house supports station blackout.

Intended functions within the scope of license renewal include providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-14, the applicant identified the following switchyard control house

component types that are within the scope of license renewal and subject to an AMR:

equipment pads/grout; masonry block walls; structural reinforced concrete; and structural steel.

2.4A.2.14.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.14 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the

switchyard control house described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4A.2.14.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found. On the basis of its. review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the

switchyard control house that are withiri the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the

switchyard control house that are subject to an aging management review, as required by

10 CFR 54.21 (a)(1).

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2.4A.2.15 Retaining Wall

2.4A.2.15.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.15, the applicant described the retaining wall. The retaining wall is a nonsafety-related, non-seismic, reinforced concrete wall supported on reinforced concrete footing

that is adjacent to the Unit 2 condensate polishing facility and Warehouse No. 5.

The retaining wall supports station blackout.

Intended functions within the scope of license renewal include providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-15, the applicant identified the following retaining wall component types that

are within the scope of license renewal and subject to an AMR: structural reinforced concrete

(footing, walls).

2.4A.2.15.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.15 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the

retaining wall described in the LRA and Millstone FSAR in accordance with the requirements of

10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4A.2.15.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the

retaining wall that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the components of the retaining wall that are

subject to an aging management review, as required by 10 CFR 54.21(a)(1).

2.4A.2.16 Switchyard, 345kV

2.4A.2.16.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.16, the applicant described the 345kV switchyard. Structural members

associated with the in-scope electrical equipment required for the restoration of offsite power

include transmission towers and dead-end structures and associated foundations, breaker and

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disconnect foundations and support structures, the non-safety-related, non-seismic, reserve

station service transformer foundation, and the A700 'switchgear enclosure and foundation.

The 345kV switchyard structural members supports station blackout.

Intended functions within the scope of license' renewal include providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-16, the applicant identified the following 345kV switchyard component types

that are within the scope of license renewal and subject to an AMR: structural reinforced

concrete and structural steel.

2.4A.2.16.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.16 and the referenced Millstone FSAR Sections. The

staffs review was *conducted in accordance with the guidance described inSection 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the `structural or component functions of the 345kV

switchyard described in the LRA and Millstone FSAR in accordance with the requirements of 10

CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, lbng-lived components were subject to an

AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4A.2.16.3 Conclusion

The staff reviewed the LRA and related structural/component informmatior to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found.COn the basis of its review, the staff concludes that there is

reasonable -assurance that the applicant has adequately identified the components of the 345kV

switchyard that are within the scope of license renewal, as required by 10 CFR'54.4(a), and that

the applicant has adequately identified the componients of the 345kV switchyard that are

subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4A.2.17 Unit 2 Intake Structure .

2.4A.2.17.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.17, the applicant described the Unit 2 intake structure. The Unit 2 intake

structure is a Class I reinforced concrete structure located west of the main plant. The structure

consists of four individual bays that provide sea water from 'the Niantic Bay to four non-safetyrelated circulating water pumps.*Three of the four bays also supply water to three safety-related

service water pumps for the purpose of emergency and normal heat removal from heat'

exchangers and equipment. The service water (SW) system is the only safety-related system

located in the Unit 2 intake structure.'

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The Unit 2 intake structure is a Class I structure (SW cubicles only) that provides a source of

cooling water to the safety-related SW pumps. The Unit 2 intake structure non-safety-related

structural members support the function of safety-related equipment. The Unit 2 intake

structure also supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a missile (intemal or extemal) barrier

* provides a source of cooling water for plant shutdown

In LRA Table 2.4.2-17, the applicant identified the following Unit 2 intake structure component

types that are within the scope of license renewal and subject to an AMR: doors; equipmentpads/grout; hatches; miscellaneous steel [checkered plates, embedded steel-exposed surfaces

(shapes, plates, unistrut, etc.) ladders, platforms and grating]; missile barriers; structural

reinforced concrete (beams, columns, floor slabs, foundation mat slabs, roof slabs, walls);

structural steel (beams, bracing, roof framing and decking); and trash racks.

2.4A.2.17.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.17 and the referenced Millstone FSAR sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 2

intake structure described in the LRA and Millstone FSAR in accordance with the requirements

of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff then verified that

the passive, long-lived components were subject to an AMR, in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.4.17 identified one area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. Therefore,

the staff issued RAI 2.4-6, to determine whether the applicant has properly applied the scoping

criteria of 10 CFR 54.4(a), and the screening criteria of 10 CFR 54.21(a)(1). The staffs RAI is

described below.

* The LRA stated that the trash racks for the Unit 2 intake structure were within the scope

of license renewal and referenced FSAR Section 5.6 for further details. The staff

reviewed this FSAR section and could not identify the trash racks on FSAR Figure 5.6-1.

This figure did not identify a course screen guide and a fine screen guide. The staff..

requested whether these two guides were the same as the trash racks referred to in the

LRA. If not, the applicant was requested to identify the location of the trash racks on

FSAR Figure 5.6-1 and clarify whether the course screen and fine screen guides were

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within the scope of license renewal. If not, the applicant was requested to explain why

not.

The LRA stated that the traveling screens for the Unit 2 intake structure were not in the

scope of license renewal because they did not perform an intended function. FSAR

Section 9.7.2.2.1 stated that the SW pumps took suction downstream from the traveling

screens in the intake structure. This configuration was also illustrated in FSAR

Figure 5.6-1. The applicant was requested to provide the technical basis for the

conclusion that the traveling screens were hot within the scope of license renewal.

* FSAR Figure 5.6-1 identified four sluice gates located on the north face of the intake

structure. These sluice gates appeared to be located in the recirculation distribution box

on the intake structure wall as shown on FSAR Figure 5.6-2 and apparently were

associated with the operation of the Unit 2 bypass line discussed in LRA Section

2.4.2.20. The applicant was requested to clarify whether these sluice gates were within

the scope of license renewal. If they were, the applicant was requested to identify where

they were included in LRA Table 2.4.2-i7. If they were not, the applicant was requested

to explain why not.

In its response to RAI 2.4-6, dated November 9, 2004, the applicant stated:

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* FSAR Figure 5.6-1 identifies a course screen guide and a fine screen guide. The course

screen guide is installed for the trash racks. The course screen guide is within the scope

of license renewal and inspected as part of the trash rack assembly. The fine screen

and guide are not within the scope of licensee renewal because the fine screen is not

utilized.

* The traveling screens are part of the non-safety-related circulating water system that

supports normal plant dperation.'During normal plant operation, the circulating water

pumps draw a significant flow of cooling water through the bays of the intake structure

to support the main condenser cooling requirements. The flow velocity during normal

plant operation is approximately 1.0 ftfsec. This flow rate creates the potential for debris

and sediment to enter the bays. During emergency operation when the circulating water

pumps are not in operation, the service'water pumps draw a small amount of cooling

water through the bays with a low flowyelocity (approximately 0.09 ft/sec). The low flow

velocity will create an insignificant amount of debris and sediment and the traveling

*water screens will be able to pass sufficient amount of cooling water to the service water

pumps to allow for safe shutdown.-The service water pumps also have their own

discharge strainers to filter out small debris and vegetation. Therefore, the traveling

screens do not provide a license renewal intended function as defined in 10 CFR

54.4(a)(1), (2) or (3) and are not in scope for license renewal.

* The sluice gates consist of a frame, guides, and sliding gate installed in the concrete

chamber walls. These component parts are the equivalent of valve internals and have

been determined to be active components. However, the sluice gate is not configured

with a housing in a manner similar to a valve body. Therefore, although the sluice gates

are in the scope of license renewal, they are active components that do not require - aging management review, and are not included in LRA Table 2.4.2-26.

Based on its review, the staff finds the applicant's response to RAI 2.4-6 acceptable, because

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the applicant has adequately clarified its scoping and screening evaluation for the screen

guides, traveling screens, and sluice gates. The staff considers its concern described in RAI

2.4-6 resolved.

2.4A.2.17.3 Conclusion

The staff reviewed the LRA, related structural/component information, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were found. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were found. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the components of the Unit 2 intake structure that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the components of

the Unit 2 intake structure that are subject to an aging management review, as required by

10 CFR 54.21 (a)(1).

2.4A.2.18 Sea Walls

2.4A.2.18.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.18, the applicant described the sea walls. The shores immediately north

and south of the Unit 2 intake structure are protected from erosion by post-tensioned,

reinforced concrete sea walls. The walls are supported by a reinforced concrete footing, which

is founded upon bedrock. The top of the walls are approximately 14 feet above mean sea level.

The concrete sea walls are safety-related structures protecting the structural integrity of the

safety-related Unit 2 intake structure.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a protective barrier for intemal/extemal flooding events

In LRA Table 2.4.2-18, the applicant identified the following sea walls component types that are

within the scope of license renewal and subject to an AMR: structural reinforced concrete and

structural steel.

2.4A.2.18.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.18 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the sea

walls described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR

54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff then verified that

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the passive, long-lived components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.4.18 identified one area in which additional information is

necessary to complete the review of the applicant's scoping and screening results. Therefore,

the staff issued RAI 2.4-7, to determine whether the applicant has properly, applied the scoping

criteria of 10 CFR 54.4(a), and the screening criteria of 10 CFR 54.21(a)(1).

In RAI 2.4-7, the staff noted that LRA Section 2.4.2.18 for Millstone 2 discussed the scoping

and screening results for the sea walls. The LRA stated that the walls are post-tensioned,

reinforced concrete sea walls. FSAR Section 2.5.4.2.1 stated that the anchorage system for the

walls consists of 5 to 11 strands, consisting of 7 wires per strand, which are anchored into

bedrock by drilling and grouting. It also stated that the anchorages are encased in concrete. A

typical anchorage was shown in FSAR Figure 2.5-15; LRA Table 2.4.2-18 stated that the sea

wall structural members that require aging management review were "structural reinforced

concrete (footing, walls)." The applicant was requested to clarify whether the wall anchorage

system shown in FSAR Figure 2.5-15 was also within the scope of license renewal and included

as part of the item listed in LRA Table 2.4.2-18.- If it was not, that applicant was requested to

explain why not.

In its response to RAI 2.4-7, dated November 9, 2004, the applicant stated that:

The sea wall anchorage functions to maintain the integrity of the sea wall and is in the

scope of license renewal. The sea wall anchorage was inadvertently omitted from LRA

Table 2.4.2-18 and Table 3.5.2-19. The sea wall anchorage system, consisting of the

anchorage strands, has been evaluated for the effects of aging. The carbon steel

anchor strands are anchored in rock by drilling and grouting. The unbonded length of

the steel strands is located within a polyvinyl chloride (PVC) pipe that is completely.

grouted following the post-tensioning operation. The anchorage system is located in the

center of the 4-foot thick reinforced concrete sea wall. The concrete, in addition to the

grout and PVC pipe, provides ample protection such that the anchorage system is not

exposed to an aggressive environment. Therefore, the aging management review

concluded that there are no aging effects requiring management of the anchorage

system.

Based on its review, the staff finds the applicant's response to RAI 2.4-7 acceptable from the

scoping and screening perspective. The staff considers its concern described in RAI 2.4-7

resolved based on the inclusion of the component. --

2.4A.2.18.3 Conclusion

The staff reviewed the LRA, related structuraVcomponent information, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were found. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were found. On the basis of its review, the

staff concludes that there is reasonable aissurarice that the applicant has adequately identified

the components of the sea walls that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the sea

walls that are subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

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A2.4A.2.19 Unit 2 Discharge Tunnel and Discharge Structure

2.4A.2.19.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.19, the applicant described the Unit 2 discharge tunnel and discharge

structure. The SW and circulating water systems discharge into the discharge tunnel. The

discharge tunnel is a non-safety-related reinforced concrete structure that is located below

grade. It extends from the turbine building to the rock quarry.

The discharge structure, a continuation of the discharge tunnel, is located at the end of the

discharge tunnel. It is a reinforced concrete structure with a portion of the structure below grade

and a portion exposed to atmosphere and weather. At the discharge structure, SW is

discharged to a rock quarry. From the quarry, the water passes through a channel into Long

Island Sound.

The Unit 2 discharge tunnel and discharge structure are non-safety-related structures whose

failure could affect the discharge path for the safety-related SW system.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides a pressure boundary

In LRA Table 2.4.2-19, the applicant identified the following Unit 2 discharge tunnel and

discharge structure component types that are within the scope of license renewal and subject to

an AMR: structural reinforced concrete (floor slabs, roof slabs, walls).

2.4A.2.19.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.19 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 2

discharge tunnel and discharge structure described in the LRA and Millstone FSAR in

accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit

from the scope of license renewal any components with intended functions delineated in 10

CFR 54.4(a). The staff did not identify any omissions. The staff then verified that the passive,

long-lived components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4A.2.19.3 Conclusion

The staff reviewed the LRA and related structurallcomponent information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were found. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were found. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 2

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discharge tunnel and discharge structure that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the components of

the Unit 2 discharge tunnel and discharge structure that are subject to an aging management

review, as required by 10 CFR 54.21 (a)(1).

2.4A.2.20 Unit 2 Bypass Line

2.4A.2.20.1 Summary of Technical Information'in the Application

In LRA Section 2.4.2.20, the applicant described the Unit 2 bypass line. A non-safety-related

bypass line is provided from the discharge tunnel to the'Unit 2 intake structure to provide for deicing at the intake, if required.

The Unit 2 bypass line is a non-safety-related 'structure whose failure could allow the formation

of ice to occur in front of the Unit 2 intake structure, thus blocking flow to the safety-related SWsystem.

Intended functions within the scope of license renewal include the following:

provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

In LRA Table 2.4.2-20, the applicant identified the following Unit 2 bypass line component type

that is within the scope of license renewal and subject to an AMR: pipe.

2.4A.2.20.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.20 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 2

bypass line described in the LRA and Millstone FSAR in accordance with the requirements of

10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21 (a)(1).-

2.4A.2.20.3 Conclusion

The staff reviewed the LRA and related structural/comrponent information to -determine whether

any SSCs that should be within the scope of license renewal were nhot identified by the

applicant. No omissions were identified. In addition,;the staff performed a review to'determine

whether any components that should be subjebt td an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the' staff concludes that there is

reasonable assurance that the applicant has adequately identified the6components of the Unit 2

bypass line that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the components of the Unit 2 bypass line that are

subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

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2.4A.2.21 Tank Foundations

2.4A.2.21.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.21, the applicant described the tank foundations. The following foundations are within the scope of the license renewal:

* Unit 2 condensate storage tank foundation and missile barrier

* fire water tanks 1 and 2 foundations

* Unit 2 diesel fuel oil storage tank foundation

* Unit 2 refueling water storage tank foundation

* SBO diesel fuel oil storage tank foundation

The condensate storage tank foundation and missile barrier provides support for the safety- related condensate storage tank. Fire water tanks 1 and 2 foundations support fire protection. The diesel fuel oil storage tank foundation supports the in-scope diesel fuel oil storage tank. The refueling water storage tank foundation qualifies as a Class 1 structure. The SBO diesel fuel oil storage tank foundation supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a missile (internal or extemal) barrier

In LRA Table 2.4.2-21, the applicant identified the following tank foundations component types that are within the scope of license renewal and subject to an AMR: miscellaneous steel (brackets, ladders, platforms and grating); structural reinforced concrete (foundation mat slabs, walls); structural reinforced concrete (footing); structural reinforced concrete; structural reinforced concrete (foundation mat slabs); and structural reinforced concrete (foundation mat slabs).

2.4A.2.21.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.21 and the referenced Millstone FSAR Sections. The staff's review was conducted in accordance with the guidance described in Section 2.4 of the NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the tank foundations described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then verified that the passive, long-lived components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

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2.4A.2.21.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the tank

foundations that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the components of the tank foundations that are

subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4A.2.22 Yard Structures

2.4A.2.22.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.22, the applicant described the yard structures. The following structures

are within the scope of the license renewal:

* Unit 2 transformer firewalls and dikes

* A700 switchgear enclosure dike

* Unit 2 diesel fuel oil storage tank dike

* Unit 2 refueling water storage tank (RWST) valve pit

* Unit 2 pipe trenches

* Unit 2 manholes

* Unit 2 duct banks

* Unit 2 security lighting supports (including poles)

The transformer firewalls and dikes, diesel fuel oil storage tank dike, and the security lighting

supports (including poles) supports fire protection.-The A700 switchgear enclosure dikes

supports station blackout. The RWST valve pit is Class 1 structure that provides enclosure and

protection for safety-related piping associated with the RWST. The pipe trenches provides

protection for safety-related condensate pipe from the storage tank to the auxiliary feedwater

pumps; the pipe trenches also supports fire protection and station blackout. The manholes

contain electrical cables for safety-related, in-scope equipment; other in-scope manholes

support fire protection.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides a protective barrier for intemal/extemal flooding events

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a missile (internal or external) barrier

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

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In LRA Table 2.4.2-22, the applicant identified the following yard structures component types

that are within the scope of license renewal and subject to an AMR: structural reinforced

concrete (footing, walls); doors; structural reinforced concrete; flood/spill barriers including

curbs, dikes, toe plates, and stop logs; structural reinforced concrete (footing); structural steel

(beams); manhole covers; structural reinforced concrete (foundation mat slabs, roof slabs,

walls); hatches; miscellaneous steel [embedded steel-exposed surfaces (shapes, plates,

unistrut, etc.)]; structural reinforced concrete (foundation mat slabs, walls); manhole covers;

structural reinforced concrete (foundation mat slabs, roof slabs, walls); duct banks; lighting

poles; miscellaneous steel (embedded steel-exposed surfaces (shapes, plates, unistrut, etc.));

and structural reinforced concrete (footing).

2.4A.2.22.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.22 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the yard

structures described in the LRA and Millstone FSAR in accordance with the requirements of 10

CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4A.2.22.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the yard

structures that are within the scope.of license renewal, as required by 10 CFR 54.4(a), and that

the applicant has adequately identified the components of the yard structures that are subject to

an aging management review, as required by 10 CFR 54.21(a)(1).

2.4A.3 NSSS Equipment Supports

24A.3.1 Summary of Technical Information in the Application

In LRA Section 2.4.3, the applicant identified the components of the NSSS equipment supports

that are subject to an AMR for license renewal. The NSSS equipment supports are the plant

components that support and restrain the following reactor coolant system equipment:

* reactor vessel

* reactor coolant pumps

* steam generators

* pressurizer

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Intended functions within the scope of license renewal include providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(1)

In LRA Table 2.4.2-23, the applicant identified the following NSSS equipment supports

component types that are within the scope of license renewal and subject to an AMR:

pressurizer support - bolting; reactor coolant pump support - plate and structural shapes, spring

hanger assemblies; reactor vessel support - bolting, plate and structural shapes; sliding support

assembly; steam generator support - sliding support assembly, bolting, plate and structural

shapes, sliding base, and snubber attachment hardware.

2.4A.3.2 Staff Evaluation

The staff reviewed LRA Section 2.4.3 and the referenced Millstone FSAR Sections. The staffs

review was conducted in accordance with the guidance described in Section 2.4 of the NUREG1800.'''''

In conducting its review, the staff evaluated the structural or component functions of the NSSS

equipment supports described in the LRA and Millstone FSAR in accordance with the'

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any cormiponents with intended functions delineated in 10 CFR 54.4(a).' The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4A.3.3 Conclusion

The staff reviewed the LRA and related structural/component information to determin6.whether

any SSCs that should be within the scope, of license renewal were not identified by the'

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the NSSS

equipment supports that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the NSSS

equipment supports that are subject to an aging management review, as requiired by'

10 CFR 54.21(a)(1).

2.4A.4 General Structural Supports -

2.4A.4.1 Summary of Technical Information in the Application

In LRA Section 2.4.4, the applicant identified the' components of the general structural supports

that are subject to an AMR for license renewal. Structural supports for mechanical and electrical

components are an integral part of all plant systems. Many of these supports are not uniquely

identified with component identification numbers. However,'characteristics of the supports, such

as design, materials of construction, environments, and anticipated stressors, are similar..

Therefore, structural supports'for mecha aical'd electricalncomponents are evaluated as

commodities across system boundaries.

Structural supports protect and support equipment. Non-safety-related supports prevent'

interaction between safety-related'and non-safety-related components. Other supports provide

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support for components credited for fire protection, station blackout, anticipated transient

without scram, pressurized thermal shock, or environmental qualification of electrical

equipment.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

In LRA Table 2.4.2-24, the applicant identified the following general structural supports

component types that are within the scope of license renewal and subject to an AMR: battery racks; electrical conduit, cable trays; 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.).

2.4A.4.2 Staff Evaluation

The staff reviewed LRA Section 2.4.4 and the referenced Millstone FSAR Sections. The staffs

review was conducted in accordance with the guidance described in Section 2.4 of the NUREG1800.

In conducting its review, the staff evaluated the structural or component functions of the general structural supports described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then vdrified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4A.4.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff 'performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant. No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that-the applicant has adequately identified the components of the

general structural supports that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the components of the general structural supports that are subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4A.5 Miscellaneous Structural Commodities

2.4A.5.1 Summary of Technical Information in the Application

In LRA Section 2.4.5, the applicant identified the components of the miscellaneous structural

commodities that are subject to an AMR for license renewal. Miscellaneous structural

commodities are within the scope of license renewal because they provide safety-related

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functions, by supporting safety-related component functions, and/or by supporting

environmental qualification, fire protection, station blackout, anticipated transient without scram,

and pressurized thermal shock regulations. n

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides EQ barrier and/or HELB barrier

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a pressure boundary

* provides a protective barrier for internal/external flooding events

In LRA Table 2.4.2-25, the applicant identified the following miscellaneous structural

commodities component types that are within the scope of license renewal and subject to an

AMR: bus duct enclosures; cable tray cover and assembly; electrical component supports within

cabinets and panels; enclosure; expansion joint/seismic gap material (between adjacent

buildings/structures); expansion joint/seismic gap material (fire-rated walls); fire boots; fire

doors and/or eq barrier doors; fire resistant coating; fire stops; fire-rated cable wraps; fire/eq

barrier penetration seals (including ceramic damming material); flood d6or/gate gasket; flood

doors/gates; flood prevention plugs; gaskets in junction, terminal, and pull boxes; gypsum

boards; junction, terminal, and pull boxes; panels and cabinets; radiant energy shields; stop log;

stop log brackets; stop log gasket; switchgear enclosures; watertight door gasket; and

watertight doors.

2.4A.5.2 Staff Evaluation

The staff reviewed LRA Section 2.4,5 and the referenced Millstone FSAR Sections. The staffs

review was conducted in accordance with the guidance described in Section 2.4 of the NUREG1800.

In conducting its review, the staff evaluated the structural or component functions of the

miscellaneous structural commodities described in the LRA and Millstone FSAR in accordance

with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope

of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff thein Verified that the passive, long-lived

components were subject to an AMR,- in accordance with 10 CFR 54.21 (a)(1).

2.4A.5.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were'not identified by the

applicant. No omissions were identified. In additionr;the staff performed 'a review to determine

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whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the

miscellaneous structural commodities that are within the scope of license renewal, as required

by 10 CFR 54.4(a), and that the applicant has adequately identified the components of the

miscellaneous structural commodities that are subject to an aging management review, as

required by 10 CFR 54.21(a)(1).

2.4A.6 Load Handling Cranes and Devices

2.4A.6.1 Summary of Technical Information in the Application

In LRA Section 2.4.6, the applicant identified the components of the load handling cranes and

devices that are subject to an AMR for license renewal. The load handling cranes and devices

are within the scope of license renewal because certain load handling cranes and devices are

Seismic Class I and meet, or are seismically designed and meet to ensure that they will not

adversely impact safety-related components during or subsequent to a seismic event.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

In LRA Table 2.4.2-26, the applicant identified the following load handling cranes and devices

component types that are within the scope of license renewal and subject to an AMR: cranes

and monorails including bridge and trolley support members (girders, beams, angles, frames,

plates, rails & anchorage); fuel elevator support members (structural plates, tracks &

anchorage); and fuel transfer machine and tilting mechanism support members (structural

frame, tracks, and anchorage).

2.4A.6.2 Staff Evaluation

The staff reviewed LRA Section 2.4.6 and the referenced Millstone FSAR Sections. The staffs

review was conducted in accordance with the guidance described in Section 2.4 of the NUREG1800.

In conducting its review, the staff evaluated the structural or component functions of the load

handling cranes and devices described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4A.6.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

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whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review,' the staff concludes that there is -

reasonable'assurance that the applicant has adequately identified the components of the load

handling cranes and devices' that are within the scope of license renewal,' as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the load

handling cranes and devices that are subject to an aging management review, as required by

10 CFR 54.21(a)(1).-:

2.4B Unit 3 Scoping and Screening Results'- Structures

2.4B.1 Containment

2.4B.1.1 Summary of Technical Information in the Application

In LRA Section 2.4.1, the applicant identified'the'components of the containment that are

subject to an AMR for license renewal. The containment is a seismic Category I structure,

housing the reactor, NSSS equipment, and various safety-related and non-safety-related

components. The evaluation boundary of the containment consists of the containment

structure, including the liner and internal structural'members, and containment penetrations

(equipment access and personnel air lock openings,;piping penetrations, 'electrical penetrations,

and the fuel transfer tube assembly). The refueling cavity liner and reactor cavity seal ring are

also included in the containment evaluation boundary.

The containment is a Seismic Category I structure. The containment non-safety-related

structural members support the function of safety-related equipment. The containment also

contains EQ equipment and supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides a pressure boundary

* provides EQ barrier and/or HELB barrier

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides jet impingement shielding for high' energy line breaks

* provides a protective barrier for intemallextemal flooding events

* provides a rated fire barrier to confine'bor'retard a fire from spreading' to or from adjacent

areas of the plant

* provides a missile (internal or external) barrier

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint) '

In LRA Table 2.4.1-1, the applicant identified the following containment component types that

are within the scope of license renewal and subject to an AMR: concrete blocks (shielding);

containment liner, containment recirculation sump; containment recirculation sump screen;

containment recirculation sump vortex breaker, containment shell (cylindrical wall and dome);

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door locking mechanism; electrical penetrations; equipment hatch; equipment pads/grout; expansion bellows; flood/spill barriers including curbs, dikes, toe plates, and stop logs; fuel transfer tube; fuel transfer tube enclosure protection shield; fuel transfer tube gate valve; fuel transfer tube penetration; gaskets; hatches; hinges and pins; jet impingement barriers; mechanical penetrations; miscellaneous steel [brackets, checkered plates, embedded steel- exposed surfaces (shapes, plates, unistrut, etc.), ladders, platforms and grating, stairs]; missile barriers; moisture barrier, o-rings; personnel air lock; pipe; reactor cavity seal ring; refueling' cavity liner, ring girder; spare penetrations; structural reinforced concrete (beams, columns, floor slabs, foundation mat slabs, pedestals, walls); structural steel (beams, bracing, columns and baseplates, trusses); sub-foundation; and valve bodies.

2.4B.1.2 Staff Evaluation

The staff reviewed LRA Section 2.4.1 and the referenced Millstone FSAR Sections 3.8.1.1, 3.8.1.1.4, 3.8.1.1.5, 3.8.3, Table 3.2-1, Figure 3.8-20, Figure 3.8-21, and Figure 3.8-22. The staffs review was conducted in accordance with the guidance described in Section 2.4 of the NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the containment described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The staff then verified that the passive, long-lived components were subject to an AMR, in accordance with

10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.4.1 identified several areas in which additional information

was necessary to complete the review of the applicant's scoping and screening results.

Therefore, the staff issued RAls 2.4-4, 2.4-5, 2.4-8, and 2.4-13 to determine whether the applicant has properly applied the scoping criteria of 10 CFR 54.4(a), and the screening criteria of 10 CFR 54.21 (a)(1).

The staffs RAI 2.4-4 is described below.

In both the Millstone 2 and Millstone 3 LRAs, Table 2.4.1-1 'Unit X Containment" lists "pipe" and "valve bodies" under the "Structural Member" column. In both LRAs, Section 2.4.1

"Containment" does not specifically describe these items. The applicant was requested to describe the pipe and valve bodies that are included as part of the Millstone 2 and 3

containments.

In its response to RAI 2.4-4, dated November 9, 2004, the applicant stated that:

LRA Section 2.4.1, Containment, describes the personnel lock, which allows, for access

into and out of the Containment. The personnel lock includes an equalizing system to equalize pressure inside and outside the lock. This function is accomplished through the

use of piping and valves. In LRA Table 3.5.2-1, a note is assigned to the Structural

Members "Pipe" and 'Valve Bodies" which states that these components are related to the personnel. lock equalizing system.

Based on its review, the staff finds the applicant's response to RAI 2.4-4 acceptable, because

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it clearly describes the pipe and valve bodies that are included as part of the Millstone 2 and 3

containments. The staff considers its concern described in RAI 2.4-4 resolved.

The staffs RAI 2.4-5 is described below.

In both the Millstone 2 and Millstone 3 LRAs, Section 2.4.1 UContainmentr describes

containment electrical penetrations as follows:

The electrical penetrations consist of an electrical penetration module installed into a

penetration sleeve that is welded to the liner plate. The evaluation boundary consists of

the sleeve and attachment weld to the electrical penetration module. Spare electrical

penetrations are also part of the evaluation boundary. The electrical penetration module

is evaluated as described in Section 2.5.2, Electrical Penetrations.

LRA Section 2.5.2 "Electrical Penetrations" states:

Electrical penetrations permit the conduction of electrical power or signals through the

Containment wall while maintaining the integrity of the Containment pressure boundary.

The electrical penetration feed-through modules consist of one or more electrical

conductors in a tubular metallic cylinder; The cylinder passes through a header plate

which is manufactured with an adapter ring that is field-welded to the Containment

penetration sleeve to provide the Containment pressure boundary. The header plate

may contain one or more modules that make up the total electrical penetration

assembly. The modules contain conductor extensions, conductor supports, and seals

which are either epoxy, O-ring, or mechanical compression seals. Nitrogen is used for

monitoring of seal pressure integrity..

From the information provided in the LRAs, it appears that the AMR for the containment -

pressure boundary function of the electrical penetration feed-through modules is evaluated as

part of the electrical scope, instead of as part of the structures scope. The staff considers the

containment pressure boundary function of the electrical penetration feed-through modules to

be part of the structures scope. The applicant was requested to submit an AMR for the - containment pressure boundary function of electrical penetration feed-through modules as part

of the structures scope.

In its initial response to RAI 2.4-5, dated November 9, 2004, the applicant stated:

The evaluation boundaries for the containment electrical penetrations are described in

LRA Sections 2.4.1 and 2.5.2 and the aging management review results are provided in

LRA Tables 3.5.2-1 and 3.6.2-2. The information provided in these sections meets the

requirements of 10 CFR 54.21 (a). Therefore, no changes to the LRA are deemed

necessary.

In its supplemental response to RAI 2.4-5,Adated December 3, 2004, the applicant stated:

Supplemental Information: . . .-

In a November 9, 2004, telephone conversation, the staff requested further clarification

of the containment pressure boundary function and the aging management review

results for the electrical penetration feed-through modules. In addition, the staff

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requested that Dominion provide the basis that there is no aging management program

for the portion of the electrical penetration modules that provide the containment

pressure boundary function, or provide an aging management program for these

components.

As described in LRA Section 2.5.2, the electrical penetration feed-through module is

installed in a containment structure penetration by field welding the module header plate

to the containment liner via an adapter ring. The sleeve and weld are further described

in LRA Section 2.4.1. The electrical penetration module, header plate, adapter, and

sleeve, and the associated field weld, provide a containment pressure boundary

function. The module, including non-metallic penetration seals, compression connectors,

and feed-through sealants, and the header plate are evaluated for the effects of aging

based on the containment pressure boundary function as indicated in LRA Table

3.6.2-2. The containment penetration sleeve, adapter, and associated welds are

evaluated for the effects of aging based on the containment pressure boundary function

as Electrical Penetrations and the results are provided in LRA Table 3.5.2-1.

As indicated in LRA Table 3.5.2-1, the electrical penetrations were determined to be

subject to loss of material and are managed for the effects of aging by the Inservice

Inspection Program: containment Inspections AMP. This AMP is described in LRA

Section B2.1.16 and is modified by the response to RAI 3.5-1 provided in Dominion

letter SN 04-673 dated 11/9/04.

After further consideration, and in response to NRC staff concems, the aging

management review results provided in LRA Table 3.6.2-2 for the Feed-through Sealant

and the Penetration Seals component types are supplemented to indicate that the aging

effects of cracking and change of material properties will be managed by the Inspection

Program: Containment Inspections AMP as modified by the response to RAI 3.5-1

provided in Dominion letter SN 04-673 dated 11/9/04.

Based on its review, the staff finds the applicant's response to RAI 2.4-5 acceptable, because

the applicant has committed to inspect electrical penetration feed-through modules for cracking

and change in material properties under its inspection program: containment inspections AMP,

as modified by the response to RAI 3.5-1 provided in Dominion letter SN 04-673 dated

November 9, 2004. The staff considers its concern described in RAI 2.4-5 resolved.

The staff's RAI 2.4-8 is described below.

LRA Section 2.4.1 for Millstone 3 discusses the scoping and screening results for the

containment. The LRA states that a seismic Category 1 reinforced concrete ring girder encircles

the containment structure to prevent postulated sliding of rock wedges toward the containment

wall during a seismic event. LRA Table 2.4.1-1 identifies the ring girder as requiring an AMR

and LRA Table 3.5.2-1 presents the AMR results for the concrete structural members of the

ring girder. FSAR Section 3.8.1.1.5 states that the ring girder is isolated from the containment

wall by a compressible material. FSAR Figures 3.8-1, 3.8-23, and 3.8-24 identify the following

components between the ring girder and the containment wall: compressible material,

waterproofing membrane, protection board, ribbed fiberglass and waterstop. Some applicable

components such as moisture barrier and expansion jointlseismic gap material (between

adjacent buildings/structures) are generally identified in LRA Tables 2.4.1-1 and 2.4.2-36 as

requiring an AMR. Please clarify whether all the components between the ring girder and the

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containment wall that are identified in FSAR Figures 3.8-1, 3.8-23, and 3.8-24 are within the

scope of license renewal. If so, please identify where they are included in LRA Tables 2.4.1-1

and 2.4.2-36. - " a . .

In its response to RAI 2.4-8, dated November 9, 2004,'the applicant stated:

The components listed in RAI 2.4-8, that are located between the ring girder and the

containment wall, are identified in FSAR Figures 3.8-1, 3.8-23, and 3.8-24. They

include: compressible material; waterproofing membrane, protection board, ribbed

fiberglass, and waterstop. Of these, only the ribbed fiberglass material and the

waterstops are within the scope of license renewal and subject to aging management

review as described below. -,

The compressible material was installed during construction to maintain a separation

gap between the ring girder and the containment structure. The gap material also

functioned as a gap filler to prevent debris from entering this gap until the adjacent

building floors were constructed. With these floors in place, there is no possibility of

debris entering the gap between the ring girder and the containment structure, and the

gap filler material no longer serves a function. Therefore, the compressible material is

not within the scope of license renewal.

The waterproofing membrane is installed to minimize the effects of groundwater on the

containment walls and foundation. However, the membrane is known to be breached

and,- when groundwater penetrates or otherwise circumvents the membrane, the water

drains to an underdrains removal system that includes a layer of porous'concrete:

beneath the containment and engineered safety features (ESF) building foundations. As

such, failure of the waterproof membrane' does not affect the' structural integrity of the

containment structure or liner. Therefore, the waterproof membrane does not perform a

license renewal intended function and is not within the scope of license renewal.

The protection board was placed during construction of the containment and ring girder

structures to protect the waterproofing mnembrane. This component no longer serve's a

function and is not within the scope of license renewal.

The ribbed fiberglass was placed in sheets against the outside wall of the containment'

structure during construction to provide an intentional space for flow of any groundwater

leaking through the waterproofing'membrane down to the underdrains removal system.'

Although it is considered unlikely that this flowpath would not be maintained even in the

event of failure of the ribbed fiberglass sheets, these components were included within'

the scope of license renewal and subjected to an aging management review. As a,

result, the fiberglass material has been'evaluated for the'effects of aging in an air and a

water environment. There are no applicable aging effects in these environments and

there is no requirement to apply an aging management program for these components. - !.,, . -,.,,.-

Waterstops are included within the scope of license renewal and are subject to aging

management review as part of the concrete structural member with which they are

associated as described in LRA Appendix C, Section C2.4.

Based on its review, the staff finds the applicant's response to RAI 2.4-8 acceptable. The staff

considers its concern described in RAI 2.4-8 resolved.

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The staff's RAI 2.4-13 is described below.

Millstone 3 LRA Sections 2.4.1 and 2.4.2.7, identify the presence of a porous concrete

subfoundation that is founded on bedrock, under the containment structure and part of the ESF

building. LRA Tables 2.4-1 and 2.4.2-7 list "subfoundation" as a component type subject to

aging management review. LRA Section 2.3.3.51 'Reactor Plant Aerated Drains System"

states:

In addition, the Reactor Plant Aerated Drains System includes the Engineered Safety

Features Building porous concrete groundwater sump that collects groundwater and

prevents it from adversely affecting the Containment or imparting hydrostatic pressure

on the Containment liner. The sump pump discharges the collected groundwater to the

groundwater underdrains storage tank located in the yard.

The Reactor Plant Aerated Drains System provides Containment pressure boundary

integrity, collection and removal of groundwater from the ESF building underdrains and

porous concrete.

The evaluation boundary of the Reactor Plant Aerated Drains System includes piping

and components that provide for collection and removal of groundwater from the ESF

Building underdrains and porous concrete, and those components that provide an

isolation boundary for the service water pump cubicles and the Supplemental Leak

Collection and Release System. The evaluation boundary also includes components that

are spatially oriented near safety-related equipment in the Auxiliary Building, ESF

Building, Control Building, and structure.

LRA Table 2.3.3-48 lists the 'groundwater sump" as a component type subject to aging

management review for the reactor plant aerated drains system.

The staff reviewed referenced Millstone 3 FSAR Sections 1.2.3, 3.8.1, 3.8.1.1, 3.8.3, 9.3.3 and

Table 3.2-1. The staff also reviewed other applicable FSAR Sections 1.8, 2.5.4.6.1, 3.4.1.2,

3.8.1.6.4, 3.8.5.1, 3.8.5.6, 9.3.3.1, 9.3.3.2.4, 9.3.3.2.4.1, 9.3.3.3, and 9.3.3.4, in order to better

understand the porous concrete subfoundation and its intended function, and the components

of the reactor plant aerated drains system that are essential to accomplish this intended

function. The staff identified a number of other structural and mechanical components, in

addition to the porous concrete subfoundation and the porous concrete groundwater sump, that

appear to be essential to accomplish this intended function. Examples are the groundwater

underdrains storage tank and its foundation; flow path between the groundwater sump and the

groundwater underdrains storage tank; the outflow components from the groundwater

underdrains storage tank; sump pump; standpipe assembly; sump water level and pump

operability monitoring instrumentation. Therefore, the applicant was requested to (1) provide a

clear and concise description of the safety-related groundwater collection and removal intended

function; (2) identify all the structural and mechanical components that are essential to

accomplishing this intended function; (3) list the components identified in (2), above, that are

within the scope of license renewal, and indicate where they are covered in LRA Sections 2.3 or

2.4; and (4) list the components identified in (2), above, that are not within the scope of license

renewal, and provide the technical basis for this determination.

In its response to RAI 2.4-13, dated November 9, 2004, the applicant stated:

I

I

it

It

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As stated in Millstone Unit 3 LRA Section 2.3.3.51, an intended function of the Reactor

Plant Aerated Drains System is the collection and removal of groundwater from the ESF

building underdrains and porous concrete. As further stated in Section 2.3.3.51, the

evaluation boundary of the system includes the piping and components that provide for

collection and removal of groundwater from the ESF Building underdrains and porous

concrete. Specifically, the evaluation boundary, as identified on license renewal drawing

25212-LR26906, Sh. 4, includes the piping from the porous concrete subfoundation

underdrains to the collection sump, the sump pump, the pump discharge piping, and the

sump casing and expansion joint to a point outside the ESF Building. The applicable

components are included in the component types "Expansion Joints," "Groundwater

Sump," "Pipe," and "Pumps" in LRA Table 2.3.3-48. (Note: The groundwater sump,

3SRW*SUMP6, was inadvertently not highlighted on license renewal drawing

25212-LR26906, Sh. 4). The evaluation boundary shown on license renewal drawing

25212-LR26906, Sh. 4, stops where the sump discharge reaches the yard area outside

the ESF Building since this is sufficient to accomplish the intended function to collect

and remove drainage from the porous concrete subfoundation. The groundwater

underdrains storage tank and associated foundation, and components in the flowpath

outside the ESF Building, are not required to support the identified intended function.

However, in response to RAI 2.1-1, the groundwater underdrains storage tank and

associated piping have been added to the scope of license renewal as a non-safetyrelated component that is spatially oriented such that its failure could prevent the

function of safety-related SSCs. The groundwater underdrains storage tank shares the

foundation of the Unit 3 refueling water storage tank which is within the scope of license

renewal as indicated in LRA Table 2.4.2-32.

Sump level monitoring and pump operability instrumentation, although in scope, are active

components and not subject to aging management review.

Based on its review, the staff finds the applicant's response to RAI 2.4-13 acceptable because

the applicant has appropriately addressed all of the items identified in the RAI. The staff notes

that the applicant added the groundwater underdrain storage tank and foundation and

associated piping to the LR scope in response to RAI 2.1-1. The staff considers its concern

described in RAI 2.4-13 resolved.

2.4B.1.3 Conclusion -

The staff reviewed the LRA, related structural/component information, and RAI responses

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. In addition, the staff performed a review to

determine whether any components that should be subject to an AMR were not identified by the

applicant. On the basis of its review, the staff concludes that there is reasonable assurance that

the applicant has adequately identified the components of the containment that are within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the components of the containment that are subject to an aging management review,

as required by 10 CFR 54.21 (a)(1).

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2.4B.2 Structures and Component Supports

In LRA Section 2.4.2, the applicant identified the structures and components of the structures

and component supports that are subject to an AMR for license renewal.

The applicant describes the structures and component supports in the following sections:

* 2.4.2.1

* 2.4.2.2

* 2.4.2.3

* 2.4.2.4

* 2.4.2.5

* 2.4.2.6

* 2.4.2.7

* 2.4.2.8

* 2.4.2.9

* 2.4.2.10

* 2.4.2.11

* 2.4.2.12

* 2.4.2.13

* 2.4.2.14

* 2.4.2.15

* 2.4.2.16

* 2.4.2.17

* 2.4.2.18

* 2.4.2.19

* 2.4.2.20

* 2.4.2.21

* 2.4.2.22

* 2.4.2.23

* 2.4.2.24

* 2.4.2.25

* 2.4.2.26

* 2.4.2.27

* 2.4.2.28

* 2.4.2.29

* 2.4.2.30

* 2.4.2.31

* 2.4.2.32

* 2.4.2.33

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 waster 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

switchyard, 345kV

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

I

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t

I,

The corresponding subsections of this SER (2.4B.2.1 - 2.4B.2.33, respectively) present the

staffs related review findings.

24B.2.1 Unit 3 Containment Enclosure Building

2.4B.2.1.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.1, the applicant described the Unit 3 containment enclosure building. The

Unit 3 containment enclosure building is a cylindrical steel framed structure with metal siding,

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intermediate grating floors, and a metal roof deck. The containment enclosure building is

designed and constructed to limit radioactive leakage to the environment in the unlikely event of

a loss-of-coolant accident. It envelops the containment building completely above grade, as well

as a portion of the engineering safety features building, auxiliary building, main steam valve

building, and the hydrogen recombiner building. The containment enclosure building is

supported entirely on the containment structure with sliding joints and has no foundation.

The containment enclosure building is a Seismic Category I structure. The containment

enclosure building non-safety-related structural members support the function of safety-related

equipment. The containment enclosure building also contains EQ equipment, and supports fire

protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* *provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

In LRA Table 2.4.2-1, the applicant identified the following Unit 3 containment enclosure

building component types that are within the scope of license renewal and subject to an AMR:

doors; gaskets; hatches; metal siding; metal siding-caulking; miscellaneous steel (brackets,

ladders, platforms and grating, stairs); scuppers; sliding joints; structural reinforced concrete

(grade beams, slabs on grade); structural steel (beams, bracing, columns and baseplates, and

roof framing and decking).

2.4B.2.1.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.1 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in 'Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

containment enclosure building described in the LRA and Millstone FSAR in accordance with

the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive,-long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4B.2.1.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

containment enclosure building that are within the scope of license renewal, as required by

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10 CFR 54.4(a), and that the applicant has adequately identified the components of the Unit 3

containment enclosure building that are subject to an aging management review, as required by

10 CFR 54.21(a)(1).

2.4B.2.2 Unit3AuxiliaryBuilding

2.4B.2.2.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.2, the applicant described the Unit 3 auxiliary building. The auxiliary

building (including the electrical cable tunnel) is a multi-story structure located west of the Fuel

building, east of the service building, and north of the containment. An electrical cable tunnel

extends from the auxiliary building, through the basement level of the service building to the

control building. The auxiliary building structure is comprised of a reinforced concrete mat

founded on bedrock. The southern end of the auxiliary building is open on the side adjacent to

the containment electrical penetrations. The auxiliary building exterior walls provide vertical

support for beams on the east-side of the service building.

The Unit 3 auxiliary building is a Seismic Category I structure. The Unit 3 auxiliary building nonsafety-related structural members support the function of safety-related equipment. The Unit 3

auxiliary building also contains EQ equipment, and supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides a missile (intemal or extemal) barrier

* provides a protective barrier for intemal/extemal flooding events

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides EQ barrier and/or HELB barrier

In LRA Table 2.4.2-2, the applicant identified the following Unit 3 auxiliary building component

types that are within the scope of license renewal and subject to an AMR: doors; equipment

pads/grout; flood/spill barriers including curbs, dikes, toe plates, and stop logs; hatches;

masonry block walls; miscellaneous steel [checkered plates, embedded steel-exposed surfaces

(shapes, plates, unistrut, etc.) ladders, platforms and grating, stairs]; missile barriers; structural

reinforced concrete (beams, columns, floor slabs, foundation mat slabs, roof slabs, walls);

structural steel (columns and baseplates, concrete floor framing and decking, roof framing and

decking); sump liner, and tunnel.

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2.4B.2.2.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.2 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800. -

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

auxiliary building described in the LRA and Millstone FSAR in accordance with the requirements

of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff then verified that

the passive, long-lived components were subject to an AMR, in accordance with

10 CFR 54.21(a)(1).

The staffs review of LRA Section 2.4.2 identified one area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. Therefore,

the staff issued RAI 2.4-14, to determine whether the applicant has properly applied the scoping

criteria of 10 CFR 54.4(a), and the screening criteria of 10 CFR 54.21(a)(1). The staff's RAI is

described below.

FSAR Sections 2.5.4.12 and 3.8.4.1 stated that rock dowels were installed around the periphery of the auxiliary building to provide stability during seismic loading. FSAR Section 2.5.4.12 also

stated that rock anchors were installed (1) in the turbine building to provide resistance to

overturning due to tornado loading, and (2) in the service building to provide resistance to uplift

due to buoyant forces and seismic forces. LRA Section 2.4.2.2, Unit 3 auxiliary building; LRA

Section 2.4.2.12, Unit 3 service building; and LRA Section 2.4.2.13, Unit 3 turbine building did

not discuss the use of rock dowels and/or rock anchors for these structures, and rock

dowels/rock anchors were not specifically identified as component types requiring an aging

management review in LRA Tables 2.4.2-2, 2.4.2-12, and 2.4.2-13. In RAI 2.4-14, the staff

requested the applicant to clarify whether these rock dowels/anchors are within the scope of

license renewal. If they were, the applicant was requested to identify where they were included

in LRA Tables 2.4.2-2, 2.4.2-12, and 2.4.2-13. If not within the scope of license renewal, the

applicant was requested to provide the technical basis for this determination.

In its response to RAI 2.4-14, dated November 9, 2004, the applicant stated that rock dowels

were installed around the periphery of the auxiliary building foundation and rock anchors were

installed in the service building and turbine building foundation. These rock dowels and rock

anchors were considered part of the concrete foundation and were 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.

Based on its review, the staff finds the applicant's response to RAI 2.4-14 acceptable, because

the applicant has clarified that the rock dowels and rock anchors are included in the LR scope,

under the component type, "Structural Reinforced Concrete," in LRA Tables 2.4.2-2, 2.4.2-12,

and 2.4.2-13. The staff considers its concern described in RAI 2.4-14 resolved.

2.4B.2.2.3 Conclusion -

The staff reviewed the LRA, related structural/component information, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

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performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the components of the Unit 3 auxiliary building that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the components of

the Unit 3 auxiliary building that are subject to an aging management review, as required by

10 CFR 54.21 (a)(1).

2.4B.2.3 Unit 3 Control Building

2.4B.2.3.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.3, the applicant described the Unit 3 control building. The Unit 3 control

building houses the control room, which maintains an independent pressure boundary envelope

for habitability during a design basis accident. The Unit 3 control building is located north of the

Unit 3 turbine building, south of the emergency generator enclosure, east of the Unit 3 technical

support center, arid west of the Unit 3 service building. The Unit 3 control building is comprised

of a reinforced concrete mat founded on structural backfill, overlying till, and bedrock. The Unit

3 control building's exterior walls provide vertical support for beams on the west side of the Unit

3 service building.

The Unit 3 control building is a Seismic Category I structure. The Unit 3 control building nonsafety-related structural members support the function of safety-related equipment. The Unit 3

control building also supports fire protection, station blackout, and anticipated transient without

scram.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides a pressure boundary

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a protective barrier for internal/external flooding events

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides a missile (internal or external) barrier

* provides EQ barrier and/or HELB barrier

* provides jet impingement shielding for HELBs

In LRA Table 2.4.2-3, the applicant identified the following Unit 3 control building component

types that are within the scope of license renewal and subject to an AMR: access covers;

control room ceiling supports; doors; equipment pads/grout; flood/spill barriers including curbs,

dikes, toe plates, and stop logs; hatches; masonry block walls, miscellaneous steel [embedded

steel-exposed surfaces (shapes, plates, unistrut, etc.), ladders, platforms and grating, stairs];

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missile barriers; scuppers; service water pipe enclosure; structural reinforced concrete (floor

slabs, foundation mat slabs, roof slabs, walls); structural steel (beams, bracing, columns and

baseplates, concrete floor framing and decking, and roof framing and decking).

2.4B.2.3.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.3 and the referenced Millstone' FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800. '

In conducting'its review, the staff evaluated the structural or component functions of the Unit 3

control building described in the LRA and Millstone FSAR in accordance'with the requirements

of 10 CFR 54.4(a) to verify that the applicant did not omit from the scop'e of license renewal any

components with'intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. Thie staff then Verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21(a)(1).' -

2.4B.2.3.3 Conclusion

The staffreviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition,'the staff perfofr'ied a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has'adequately identified the components of the Unit 3

control building that are within'the scope of license renewal, as required by 10 CFR'54.4(a),

and that the applicant has' adequately identified the components of the Uinit 3 control building

that are subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4B.2.4 Unit 3 Fuel Building

2.4B.2.4.1 Summary of Technical Information in the Application

In LRA Section 2A4.2.4, the applicant described the Unit 3 fuel building. The' Unit 3 fuel building

includes the fuel building structure (including piple'tunnel), spent fuel pool (inrcluding transfer

canal and shipping cask storage area), spent fuel storage racks, cask washdown area, and new

fuel storage racks.' ' '

The Unit 3 fuel building is a Seismic Category I structure. The fuel building non-safety-related

structural members support the function of safety-related equipment. The fuel building also

contains EQ equipment and supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

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* provides a protective barrier for internal/external flooding events

* provides a pressure boundary

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a missile (internal or external) barrier

In LRA Table 2.4.2-4, the applicant identified the following Unit 3 fuel building component types

that are within the scope of license renewal and subject to an AMR: cask wash pit liner, doors;,

equipment pads/grout; flood/spill barriers including curbs, dikes, toe plates, and stop logs;

hatches; miscellaneous steel [embedded-steel-exposed surfaces (shapes, plates, unistrut, etc.)

ladders, platformrs and grating, stairs]; neutron absorber elements; new fuel storage racks;

spent fuel pool gate;'spent fuel pool liner plates; spent fuel storage racks; structural reinforced

concrete (floor slabs, foundation' mat slabs, roof slabs, walls); structural steel (beams, bracing,,

columns and baseplates, concrete floor framing and decking, roof framing and decking); sump

liner; and tunnel.

2.4B.2.4.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.4 and the referenced Millstone FSAR Sections. The:

staff's review was conducted in accordance with the guidance des&ibed in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

fuel building described in the LRA and Millstone FSAR in accordance with the requirements of,

10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21(a)(1).

2.4B.2.4.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omission's were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

fuel building that are within the scope of license renewal, as required by 10 CFR 54.4(a), and

that the applicant has adequately identified the components of the Unit 3 fuel building that are

subject to an aging management review, as required by 10 CFR 54.21(a)(1).

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2.4B.2.5 Railroad Canopy

2.4B.2.5.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.5, the applicant described the railroad canopy. The railroad canopy is

located to the east of the fuel building and protects the spent fuel pool from tornado-generated

missiles. The canopy structure is comprised of a reinforced concrete mat foundation founded

on concrete fill. It has reinforced concrete walls and a roof slab with a metal deck supported by

structural steel.

The railroad canopy is is a Seismic Category I structure that provides missile protection for the

spent fuel pool.

Intended functions within the scope of license renewal include the following:'

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a missile (internal or extemal) barrier

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

In LRA Table 2.4.2-5, the applicant identified the following railroad canopy component types

that are within the scope of license renewal and subject to an AMR: structural reinforced

concrete (foundation mat slabs, roof slabs, walls); and structural steel (roof framing and

decking).

2.4B.2.5.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.5 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800. '

In conducting its review, the staff evaluated'the structural or component functions of the railroad

canopy described in the LRA and Millstone FSAR in accordance with the requirements of 10

CFR 54.4(a) to verify that the applicant did not 6mit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21(a)(1).

2.4B.2.5.3 Conclusion - ", ' '

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were idehtified.1ln'addition,' the staff performed a review to determine

whether any'components that should be subject to an AMR were not identified by the' applicant.

No omissions were identified. On the basisof 'its' review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the '

railroad canopy that are within' the scope of license 'renewal, 'as required by 10 CFR 54.4(a),

and that the applicant has adequately identified th'ecomponents of the railroad canopy that are

subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

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2.4B.2.6 Unit 3 Hydrogen Recombiner Building

2.4B.2.6.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.6, the applicant described the Unit 3 hydrogen recombiner building. The

Unit 3 hydrogen recombiner building is located adjacent to the containment, on the southeast

side, directly below the equipment hatch. The structure is constructed of reinforced concrete - floor slabs, a roof slab, and walls supported on a reinforced concrete mat, founded on concrete

fill. Concrete roof hatches allow for access to equipment. Roof scuppers are installed to control flooding in the event of heavy rainfall.

The Unit 3 hydrogen recombiner buildingis a Seismic Category I structure. The hydrogen recombiner building non-safety-related structural members support the function of safety- related equipment. The hydrogen recombiner building also supports fire protection.

Intended functions within the scope of license renewal include the following:

* 'provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides enclosure, shelter, or other protection for in-scope equipment (including radiation shielding and pipe-whip restraint)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a missile (internal or external) barrier

* provides a protective barrier for intemal/external flooding events

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.4.2-6, the applicant identified the following Unit 3 hydrogen recombiner building component types that are within the scope of license renewal and subject to an AMR: doors; equipment pads/grout; hatches; miscellaneous steel [brackets, embedded steel-exposed surfaces (shapes, plates, unistrut, etc.) ladders, platforms and grating, stairs]; missile barriers;

scuppers; and structural reinforced concrete (beams, floor slabs, foundation mat slabs, roof

slabs).

2.4B.2.6.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.6 and the referenced Millstone FSAR Sections. The staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

hydrogen recombiner building described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functionrs delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

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2.4B.2.6.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the' staff concludes that there is

reasonable assurance that the applicant has'adequately'identified the components of the Unit 3

hydrogen recombiner building that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the-applicant has adequately identified the components of the Unit 3

hydrogen recombiner building that are subject to an aging management review, as required by

10 CFR 54.21 (a)(1).

2.4B.2.7 Unit 3 Engineered Safety Features Building

2.4B.2.7.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.7, the applicant described the Unit 3 engineered safety features building;

The Unit 3 ESF building is a safety-related structure that wraps around the east side of the

containment. Most of the Unit 3 ESF building is founded on bedrock and a portion (containment

recirculation pump pit area) of the structure is founded on a porous concrete sub-foundation,

that is placed on the bedrock.-

The Unit 3 ESF building is a Seismic Category I structure. The Unit 3 ESF building non-safetyrelated structural members support the function of safety-related equipment: The' Unit 3 ESF

building also contains EQ equipment, and supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

-(a)(3) - {

* -provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides a missile (intemal or extemal) barrier

* provides structural and/or function'a1 support to equipment meeting i 0 CFR 54.4(a)(1)

* provides a protective barrier for intemaVextemal flooding events

* provides a rated fire barrier to confine or retard a fire from spreading'to6or from 'adjacent

areas of the plant .

* provides EQ barrier and/or HELB barrier

In LRA Table 2.4.2-7, the applicant identified the following Unit 3 ESF building component types

that are within the scope of license renewal and subject to an AMR: doors; equipment

pads/grou't; flood/spill barriers including cu-rbs"dikes, toe plates,' and stop logs; hatches;'

miscellaneous steel [embedded steel-exposed surfaces (shapes, plates, unistrut, etc') ladders,

platforms and grating]; structural reinforced concrete (beams, floor slabs, foundation mat slabs,

roof slabs, walls); structural steel (beams, columns and baseplates, concrete floor framing and

decking, roof framing and decking);'sub-foundation; and sump liner.'

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2.4B.2.7.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.7 and the referenced Millstone FSAR Sections. The

staff s review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

ESF building described in the LRA and Millstone FSAR in accordance with the requirements of

10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4B.2.7.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine'

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

engineered safety features building that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the Unit 3

engineered safety features building that are subject to an aging management review, as

required by 10 CFR 54.21(a)(1).

2.4B.28 Unit 3 Main Steam Valve Building

2.46.2.8.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.8, the applicant described the Unit 3 main steam valve building. The Unit 3

main steam valve building, located west of and directly adjacent to the containment, protects

the main steam and feedwater valves and piping from tomado-generated missiles.

The Unit 3 main steam valve building is a Seismic Category I structure, which provides

protection for main steam and feedwater valves and piping from missiles. The Unit 3 main

steam valve building non-safety-related structural members support the function of safetyrelated equipment. The Unit 3 main steam valve building also contains EQ equipment, and

supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a protective barrier for intemal/external flooding events

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* provides a missile (internal or external) barrier

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides jet impingement shielding for high energy line breaks

* provides EQ barrier and/or HELB barrier

In LRA Table 2.4.2-8, the applicant identified the foliowing Unit 3 main steam valve building

component types that are within the scope of license renewal and subject to an AMR: blow-off

metal siding/ panel; doors; equipment pads/grout; flood/spill barriers' including curbs, dikes, toe

plates, and stop logs; miscellaneous steel [embedded steel-exposed surfaces (shapes, plates,

unistrut, etc.) ladders, platforms and grating, stairs]; missile barriers; structural reinforced

concrete (floor slabs, foundation mat slabs, roof slabs, walls); and structural steel (beams,

bracing, concrete floor framing and decking, roof framing and decking).

2.4B.2.8.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.8 and the'referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

main steam valve building described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not'omit from the scope of

license renewal any components with intended furfictionrs delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance'with 10 CFR 54.21 (a)(1).

2.4B.2.8.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the'basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

main steam valve building that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the Unit 3

main steam valve building that are subject to'an aging management review, as required by'

10 CFR 54.21(a)(1).

2.4B.2.9 Unit 3 Emergency Generator Enclosure and Fuel Oil Tank Vault'

2.4B.2.9.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.9, the applicant described the Unit 3 emergency generator enclosure and

fuel oil tank vault. The Unit 3 emergency generator enclosure and fuel oil tank vault is a multistory, reinforced concrete structure with concrete floor slabs, roof slabs, and walls. It is

supported on a reinforced concrete spread footing'placed on glacial till.

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The Unit 3 emergency generator enclosure and fuel oil tank vault is a Seismic Category I

structure that provides support and protection for the emergency diesel generator units and

associated fuel oil tanks. The Unit 3 emergency generator enclosure and fuel oil tank vault nonsafety-related structural members support the function of safety-related equipment. The Unit 3

emergency generator enclosure and fuel oil tank vault also supports fire protection and station

blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip restraint)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a protective barrier for intemal/extemal flooding events

* provides a missile (internal or extemal) barrier

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides EQ barrier and/or HELB barrier

In LRA Table 2.4.2-9, the applicant identified the following Unit 3 emergency generator

enclosure and fuel oil tank vault component types that are within the scope of license renewal

and subject to an AMR: doors; equipment pads/grout; flood/spill barriers including curbs, dikes,

toe plates, and stop logs; fuel oil tank vault; hatches; miscellaneous steel [embedded steelexposed surfaces (shapes, plates, unistrut, etc.) ladders, platforms and grating]; structural

reinforced concrete (beams, floor slabs, footing, foundation mat slabs, roof slabs, slabs on

grade, walls); and trench.

2.4B.2.9.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.9 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

emergency generator enclosure and fuel oil tank vault described in the LRA and Millstone

FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not

omit from the scope of license renewal any components with intended functions delineated in

10 CFR 54.4(a). The staff did not identify any omissions. The staff then verified that the

passive, long-lived components were subject to an AMR, in accordance with

10 CFR 54.21 (a)(1).

2.4B.2.9.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

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whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

emergency generator enclosure and fuel oil tank vault that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

components of the Unit 3 emergency generator enclosure and fuel oil tank vault that are subject

to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4B.2.10 Unit 2 Fire Pump House .

2.48.2.10.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.1 0, the applicant described the Unit 2 fire pump house. The Unit 2 fire

pump house is supported on a reinforced concrete mat foundation with reinforced masonry

walls and structural steel beams supporting the roof. The roof is made'up of a 4-inch-thick

concrete slab over metal decking.

The Unit 2 fire pump house supports fire protection.

Intended functions within the scope of license renewal include providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-1 0, the applicant identified the following Unit 2 fire pump house component

types that are within the scope of license renewal and subject to an AMR: equipment

pads/grout; masonry block walls; structural reinforced concrete (foundation mat slabs, roof

slabs); and structural steel (roof framing and decking). -

2.48.2.10.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.10 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 2'

fire pump house described in the LRA and Millstone FSAR in accordance with the requirements

of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54;4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21(a)(1).'

2.4B.2.10.3 Conclusion I

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 2

fire pump house that are within the scope of license renewal, as required by 1 0 CFR 54.4(a), .: .. ; .. '

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and that the applicant has adequately identified the components of the Unit 2 fire pump house

that are subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4B.2.11 Unit 3 Fire Pump House

2.4B.2.1 1.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.11, the applicant described the Unit 3 fire pump house. The Unit 3 fire

pump house consists of a reinforced concrete mat foundation with'reinforced 'masonry walls

and structural steel beams supporting the roof. The roof is made up of a 4-inch-thick concrete

slab over metal decking.

The Unit 3 fire pump house supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a protective barrier for intemal/extemal flooding events

In LRA Table 2.4.2-11, the applicant identified the following Unit 3 fire pump house component

types that are within the scope of license renewal and subject to an AMR: equipment

pads/grout; flood/spill barriers including curbs, dikes, toe plates, and stop logs; masonry block

walls; structural reinforced concrete (foundation mat slabs, roof slabs); and structural steel (roof

framing and decking).

2.4B.2.11.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.11 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

fire pump house described in the LRA and Millstone FSAR in accordance with the requirements

of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4B.2.11.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

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fire pump house that are within the scope of license renewal, as required by 10 CFR 54.4(a),

and that the applicant has adequately identified the components of the Unit 3 fire pump house

that are subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4B.2.12 Unit 3 Service Building

2.4B.2.12.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.12, the applicant described the Unit 3 service building. The Unit 3 service

building is located between the control building and the auxiliary building. It has a concrete mat

foundation and spread footings and is founded on bedrock. The superstructure is a steelframed building with a metal roof deck.

The Unit 3 service building supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a protective barrier for intemal/extemal flooding events

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.4.2-12, the applicant identified the following Unit 3 service building component

types that are within the scope of license renewal and subject to an AMR: equipment

pads/grout; masonry block walls; sliding joints; structural reinforced concrete (beams, columns,

floor slabs, footing, foundation mat slabs, walls); structural steel (beams, columns and

baseplates, concrete floor framing and decking, and roof framing and decking).

2.4B.2.12.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.12 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

service building described in the LRA and Millstone FSAR in accordance with the requirements

of 10 CFR 54.4(a) to verify that the applicant did not omit from' the scope of license renewal any

components with intended functions delineated 'in 10'CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21(a)(1). -

2.4B.2.12.3 Conclusion

The staff reviewed the LRA and related structural/component information'to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. No omissions were identified. On the basis of its

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review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the components of the Unit 3 service building that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

components of the Unit 3 service building that are subject to an aging management review, as required by 10 CFR 54.21(a)(1).

2.4B.2.13 Unit 3 Turbine Building

2.4B.2.13.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.13, the applicant described the Unit 3 turbine building. The Unit 3 turbine building is located west of the Unit 3 containment. The Unit 3 turbine building is a non-safety- related structure supported on spread footings and founded on basal till and compacted select granular fill. The foundation walls are reinforced concrete to grade with a steel-framed

superstructure. There is an auxiliary bay of the same construction on the east side of the Unit 3 turbine building. The Unit 3 turbine building has a basement level 10 feet below-grade. The Unit 3 turbine building contains the turbine pedestal, which supports the operating floor framing. A 4-inch concrete dike is provided around the perimeter of the seal oil tank for oil containment.

The Unit 3 turbine building contains EQ equipment and supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent areas of the plant

In LRA Table 2.4.2-13, the applicant identified the following Unit 3 turbine building component types that are within the scope of license renewal and subject to an AMR: equipment pads/grout; flood/spill barriers including curbs, dikes, toe plates, and stop logs; structural

reinforced concrete (beams, columns, floor slabs, footing and grade beams, walls); structural steel (beams, columns and baseplates, concrete floor framing and decking); and turbine

pedestal.

2.4B.2.13.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.13 and the referenced Millstone FSAR Sections. The staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3 turbine building described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then verified that the passive, long-lived components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

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The staff's review of LRA Section 2.4.13 identified one area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The staff

issued RAI 2.4-14; to determine whether the applicant properly applied the scoping criteria of

10 CFR 54.4(a), and the screening criteria of 10 CFR 54.21(a)(1). The staff's RAI, the

applicant's response, and the staffs evaluation are discussed in Section 2.4.2.2.2 of this SER.

For the reasons set forth in that subsection, the staff considers its concern described in RAI

2.4-14 to be resolved.

2.4B.2.13.3 Conclusion

The staff reviewed the LRA and related structural/component information, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. .No omissions were identified. No omissions were

identified. On the basis of its review, the staff concludes that there is reasonable assurance that

the applicant has adequately identified the components of the Unit 3 turbine building that are -

within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has

adequately identified the components of the Unit 3 turbine building that are subject to an aging

management review, as required by 10 CFR 54.21 (a)(1).

2.4B.2.14 Unit 3 Auxiliary Boiler Enclosure

2.4B.2.14.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.14, the applicant described the Unit 3 auxiliary boiler enclosure. The Unit 3

auxiliary boiler enclosure is located south of the Unit 3 turbine building and houses the two

auxiliary boilers and related equipment. The structure has a concrete floor supported on spread

footings. It is a conventional steel-framed structure.

The Unit 3 auxiliary boiler enclosure supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3) -

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant -- ,

In LRA Table 2.4.2-14, the applicant identified the following Unit 3 auxiliary boiler enclosure

component types that are within the scope of license renewal and subject to an AMR: -

equipment pads/grout; structural reinforced concrete (floor slabs, foundation mat slabs, walls);

and structural steel (beams, columns and baseplates, concrete floor framing and decking, roof

framing and decking).

2.4B.2.14.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.14 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

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In conducting its review, the staff evaluated the structural or component functions of the Unit 3

auxiliary boiler enclosure described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21(a)(1).

2.4B.2.14.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

auxiliary boiler enclosure that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the Unit 3

auxiliary boiler enclosure that are subject to an aging management review, as required by

10 CFR 54.21 (a)(1).

2.4B.2.15 Unit 3 Technical Support Center

2.4B.2.15.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.15, the applicant described the Unit 3 technical support center. The Unit 3

technical support center is located adjacent to the Unit 3 control building. It is a one-level

reinforced concrete structure that is supported on a concrete mat foundation, placed on

structural fill.

The Unit 3 technical support center supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3).

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.4.2-15, the applicant identified the following Unit 3 technical support center

component types that are within the scope of license renewal and subject to an AMR:

equipment pads/grout and structural reinforced concrete (beams, columns, floor slabs, footing,

roof slabs, walls).

2.4B.2.15.2 Staff Evaluation

The staff reviewed. LRA Section 2.4.2.15 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

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In conducting its review, the staff evaluated the structural or component functions of the Unit 3

technical support center described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4B.2.15.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes'that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

technical support center that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the Unit 3

technical support center that are subject to an aging management review, as required by

10 CFR 54.21 (a)(1).

2.4B.2.16 Unit 3 Maintenance Shop

2.4B.2.16.1 Summary of Technical Information in'the'Application

In LRA Section 2.4.2.16, the applicant described the Unit 3 maintenance shop. The Unit 3

maintenance shop is located adjacent to the north wall of the Unit 3 service building. The walls

of the maintenance shop are constructed of a combination of solid masonry-block walls and

steel framing. The roof consists of a concrete'slab on metal decking that is supported by a

structural steel frame. The maintenance shop is supported on reinforced concrete spread

footings and has a reinforced concrete floor slab.

The Unit 3 maintenance shop supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.4.2-16, the applicant identified the following Unit 3 maintenance shop

component types that are within the scope of license renewal and subject to an AMR:

equipment pads/grout; masonry block walls; structural reinforced concrete (beams, floor slab,

spread footings, walls); and structural steel (beams, bracing, columns and baseplates, concrete

floor framing and decking, roof framing and decking). -

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2.4B.2.16.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.16 and the referenced Millstone FSAR Sections. The

staff s review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

maintenance shop described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4B.2.16.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

maintenance shop that are within the scope of license renewal, as required by 10 CFR 54.4(a),

and that the applicant has adequately identified the components of the Unit 3 maintenance

shop that are subject to an aging management review, as required by 10 CFR 54.21(a)(1).

2.4B.2.17 Unit 3 Waste Disposal Building

2.46.2.17.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.17, the applicant described the Unit 3 waste disposal building. The Unit 3

waste disposal building is located north of the Unit 3 fuel building and east of the auxiliary

building. The Unit 3 waste disposal building consists of a superstructure with reinforced

concrete walls, and a steel-framed enclosure that is supported on a concrete mat foundation

founded on bedrock and basal till. The roof is constructed of metal decking.

The Unit 3 waste disposal building supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.4.2-17, the applicant identified the following Unit 3 waste disposal building

component types that are within the scope of license renewal and subject to an AMR:

equipment pads/grout; masonry block walls; structural reinforced concrete (beams, floor slabs,

footing, slabs on grade, walls); and structural steel (beams, columns and baseplates, roof

framing and decking).

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2.4B.2.17.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.17 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the'structural or component functions of the Unit 3

waste disposal building described in the LRA and Millstone FSAR in accordance with the -

requirements of 10 CFR54.4(a) to verify that the' applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance'with 10CFR 54.21(a)(1).

2.4B.2.17.3 Conclusion

The staff reviewed the LRA and related structuralcomponent information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition,-the staff performed a review to determine

whether any components that should be'subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

waste disposal building that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the Unit 3

waste disposal building that are subject to an aging management review, as required by

10 CFR 54.21 (a)(1). ' :

2.4B.2.18 SBO Diesel Generator Enclosure and Fuel Oil Tank Vault

2.4B.2.18.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.18, the applicant described the SBO diesel generator enclosure and fuel

oil tank vault. The SBO diesel generator enclosure includes the SBO diesel generator

switchgear enclosure, the concrete pad that supports the SBO diesel generator exhaust, and

the separate building that provides support and shelter for the SBO diesel.

The SBO diesel generator enclosure and fuel oil tank vault supports fire protection and station

blackout.

Intended functions within the scope of license renewal include providing structural and/or

functional support to equipment meeting 10 CER 54.4(a)(2) or (a)(3). -

In LRA Table 2.4.2-18, the applicant identified the following SBO diesel generator enclosure

and fuel oil tank vault component types that'are'within the scope of license-renewal and subject

to an AMR: miscellaneous steel (checkered plates); roofing; siding; structural reinforced

concrete (foundation mat slabs); and structural steel (beams, bracing).

.

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2.4B.2.18.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.18 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review; the staff evaluated the structural or component functions of the SBO

diesel generator enclosure and fuel oil tank vault described in the LRA and Millstone FSAR in

accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit

from the scope of license renewal any components with intended functions delineated in 10

CFR 54.4(a). The staff did not identify any omissions. The staff then verified that the passive,

long-lived components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.46.2.18.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the SBO

diesel generator enclosure and fuel oil tank vault that are within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the components

of the SBO diesel generator enclosure and fuel oil tank vault that are subject to an aging

management review, as required by 10 CFR 54.21 (a)(1).

24B.2. 19 Unit 3 Condensate Polishing Enclosure

2.46.2.19.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.19, the applicant described the Unit 3 condensate polishing enclosure.

The Unit 3 condensate polishing enclosure is located south of the Unit 3 turbine building. The

enclosure is a two-story, reinforced concrete structure supported on a spread footing placed on

structural fill.

The Unit 3 condensate polishing enclosure supports fire protection.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.4.2-19, the applicant identified the following Unit 3 condensate polishing

enclosure component types that are within the scope of license renewal and subject to an AMR:

equipment pads/grout; structural reinforced concrete (beams, columns, floor slabs, spread

footing, walls); and structural steel (beams, columns and baseplates, concrete floor framing and

decking, roof framing and decking).

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2.4B.2.19.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.19 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

condensate polishing enclosure described in the LRA and Millstone FSAR in accordance with

the requirements of 10 CFR 54.4(a) to verify that the- applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.48.2.19.3 Conclusion

The staff reviewed the LRA and related structuralcomponent information to determine whether

any SSCs that should be within the scope of license' renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

condensate polishing enclosure that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the Unit 3

condensate polishing enclosure that are subject to an aging management review, as required

by 10 CFR 54.21 (a)(1).

2.4B.2.20 Unit 2 Condensate Polishing Facility and Warehouse No. 5

2.48.2.20.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.20, the applicant described the Unit 2 condensate polishing facility and

Warehouse No. 5. The Unit 2 condensate polishing facility is a non-safety-related, non-seismic

structure located in Warehouse No. 5, which also houses Unit 3 fire protection piping. Unit 2

shares this warehouse with Unit 3. The structure is located north of the Unit 2 turbine building

and has a reinforced concrete mat foundation founded on structural fill. The Unit 2 condensate

polishing facility is located approximately 20 feet below grade. There are three main levels and

a penthouse that is located in the middle of the structure near the west wall. The superstructure

is a steel-framed structure and some areas of the structure have masonry walls.

The Unit 2 condensate polishing facility and Warehouse No. 5 supports station blackout and fire

protection.

Intended functions within the scope of license renewal include providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-20, the applicant identified the following Unit 2 condensate polishing facility

and Warehouse No. 5 component types that are within the scope of license renewal and

subject to an AMR: masonry block walls; miscellaneous steel (platforms and grating); and

structural reinforced concrete (beams, columns, floor slabs, foundation mat slabs, walls);

structural steel (beams, bracing, columns and baseplates).

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2.4B.2.20.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.20 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 2

condensate polishing facility and Warehouse No. 5 described in the LRA and Millstone FSAR in

accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit

from the scope of license renewal any components with intended functions delineated in 1 0

CFR 54.4(a). The staff did not identify any omissions. The staff then verified that the passive,

long-lived components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4B.2.20.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 2

condensate polishing facility and Warehouse No. 5 that are within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the components

of the Unit 2 condensate polishing facility and Warehouse No. 5 that are subject to an aging

management review, as required by 10 CFR 54.21(a)(1).

24B.2.21 Security Diesel Generator Enclosure

2.4B.2.21.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.21, the applicant described the security diesel generator enclosure. The

security diesel generator enclosure is a non-safety-related, non-seismic, one-story, freestanding structure that houses the security diesel generator and its support equipment,

including the security diesel fuel oil tank. Power from the security diesel generators is used for

general exterior illumination that is credited for fire protection events. The structure is

constructed with aluminum sheeting riveted to a combination of aluminum and steel frame. The

walls and roof are insulated and lined with plywood on the inside. The building is above grade,

is supported by steel channels, and sits on a concrete slab foundation. Power cables and

conduit from the generator are supported from the ceiling and internal wall surfaces of the

structure.

The security diesel generator enclosure supports fire protection.

Intended functions within the scope of license renewal include providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-21, the applicant identified the following security diesel generator enclosure

component types that are within the scope of license renewal and subject to an AMR:

miscellaneous steel (checkered plates); roofing; siding; structural framing; structural reinforced

concrete (foundation mat slabs); and structural steel (beams, bracing).

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2.4B.2.21.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.21 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the

security diesel generator enclosure described in the LRA and Millstone FSAR in accordance

with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope

of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4B.2.21.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.'

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the

security diesel generator enclosure that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the security

diesel generator enclosure that are subject to an aging management review, as required by

10 CFR 54.21 (a)(1).

2.4B.2.22 Stack Monitoring Equipment Building

2.4B.2.22.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.22, the applicant described the stack monitoring equipment building. The

stack monitoring equipment building is a non-safety-related, non-seismic,-single-story structure

that provides support and shelter to non-safety-related equipment that can affect safety-related

equipment. The building has a concrete roof and floor slab on grade with non-reinforced

grouted masonry walls that are supported on a concrete spread footing.

The stack monitoring equipment building non-safety-related structural members support the

function of safety-related equipment.

Intended functions within the scope of license renewal include providng structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-22, the applicant identified the following stack monitoring equipment

building component types that are within the scope of license renewal and subject to an AMR:

equipment pads/grout; masonry block walls; and structural reinforced concrete (roof slabs;

slabs on grade, spread footing, walls).

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2.4B.2.22.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.22 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the stack

monitoring equipment building described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21(a)(1).

2.4B.2.22.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the stack

monitoring equipment building that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the stack

monitoring equipment building that are subject to an aging management review, as required by

10 CFR 54.21 (a)(1).

2.4B.2.23 Millstone Stack

2.4B.2.23.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.23, the applicant described the stack. The stack is a safety-related

reinforced-concrete structure supported on a reinforced concrete mat foundation. The stack

extends 375 feet above grade and has a circular orifice with a 7-foot inside diameter.

The stack is a Seismic Category I structure.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a missile (internal or external) barrier

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

In LRA Table 2.4.2-23, the applicant identified the following stack component types that are

within the scope of license renewal and subject to an AMR: structural reinforced concrete (floor

slabs, foundation mat slabs, walls); and structural steel (beams, bracing).

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2.4B.2.23.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.23 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800. -X

In conducting its review, the staff evaluated the structural or component functions of the stack

described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR

54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive,-long-lived components were subject to an

AMR, in accordance with 1 0 CFR 54.21 (a)(1).

2.4B.2.23.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the stack

that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the

applicant has adequately identified the components of the stack that are subject to an aging

management review, as required by 10 CFR 54.21(a)(1).

2.4B.2.24 Switchyard Control House

2.4B.2.24.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.24, the applicant described the switchyard control house. The switchyard

control house is a non-safety-related, non-seismic, one-story building that provides support and

shelter for equipment utilized for closure of the 345kV circuit breakers that are credited for

restoration of offsite power in the event of a station blackout.

The switchyard control house supports station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

In LRA Table 2.4.2-24, the applicant identified the following switchyard control house

component types that are within the scope of license renewal and subject to an AMR:

equipment pads/grout; masonry block walls; structural reinforced concrete; and structural steel.

2.4B.2.24.2 Staff Evaluation - -

The staff reviewed LRA Section 2.4.2.24 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

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In conducting its review, the staff evaluated the structural or component functions of the

switchyard control house described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4B.2.24.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the

switchyard control house that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the

switchyard control house that are subject to an aging management review, as required by

10 CFR 54.21(a)(1).

2.4B.2.25 Switchyard, 345kV

2.4B.2.25.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.25, the applicant described the 345kV switchyard. Structural members

associated with the in-scope electrical equipment required for the restoration of offsite power

include transmission towers and dead end structures and associated foundations, breaker and

disconnect foundations and support structures, and the non-safety-related, non-seismic,

reserve station service transformers foundations.

The 345kV switchyard structural members support station blackout.

Intended functions within the scope of license renewal include providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-25, the applicant identified the following 345kV switchyard component types

that are within the scope of license renewal and subject to an AMR: structural reinforced

concrete and structural steel.

2.4B.2.25.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.25 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the 345kV

switchyard described in the LRA and Millstone FSAR in accordance with the requirements of 10

CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

2-318
omissions. The staff then verified that the passive, lonr-lived components were subject to an

AMR, in accordance with 10 CFR 54.21(a)(1).I'

2.4B.2.25.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified.:On'the basis of its'review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the 345kV

switchyard that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that

the applicant has adequately identified the components of the 345kV switchyard that are

subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4B.2.26 Unit 3 Circulating and Service Water Pumphouse

2.4B.2.26.1 Summary of Technical Information in'the Application

In LRA Section 2.4.2.26, the applicant described the Unit 3 circulating and SW pumphouse.

The Unit 3 circulating and service water pumphouse serve as the intake structure. The

circulating and service water pumphouse is a Seismic Category I (service water cubicles only)'

reinforced concrete structure located west of the main'plant. The structure consists of six

individual bays that provide sea water from the Niantic Bay to six non-safety-related circulating

water pumps. Four of the six bays also supiply water to four safety-relat6d service water pumps

for the purpose of emergency and normal heat removal from heat exchangers and equipment. -

The SW system is the only safety-related system located in the Unit 3 circulating and SW

pumphouse.

The Unit 3 circulating and service water pumphouse is a Seismic Category I (service water

cubicles only) structure that provides a source of cooling water to the safety-related SW pumps.

The Unit 3 circulating and service water pumphouse non-safety-related structural'members

support the function of safety-related equipment. The Unit 3 circulating and service water

pumphouse also supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3) -

* provides structural and/or functional uppobrt to equipment meeting 10 CFR 54.4(a)(1)

* provides a missile.(intemal or extemal) barrier,

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides a source of cooling water forplan't shutdown

* - provides a protective barrier for intemal/extemal flooding events

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In LRA Table 2.4.2-26, the applicant identified the following Unit 3 circulating and service water pumphouse component types that are within the scope of license renewal and subject to an. AMR: equipment pads/grout; flood/spill barriers including curbs, dikes, toe plates, and stop logs; hatches; miscellaneous steel [embedded steel-exposed surfaces (shapes, plates, unistrut, etc.) ladders, platforms and gratingj; missile barriers; structural reinforced concrete (beams, columns, floor slabs, foundation mat slabs, roof slabs, walls); and trash racks.

2.4B.2.26.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.26 and the referenced Millstone FSAR Sections. The staffs review was conducted in accordance with the guidance described in Section 2.4 of the NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3 circulating and service water pumphouse described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then verified that the passive, long-lived components were subject to an AMR, in accordance with

10 CFR 54.21 (a)(1).

The staff's review of LRA Section 2.4.26 identified one area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. Therefore, the staff issued RAI 2.4-9 to determine whether the applicant has properly applied the scoping criteria of 10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21(a)(1). The staffs RAI is described below.

LRA Section 2.4.2.26 for Millstone 3 discussed the scoping and screening results for the Unit 3 circulating and SW pumphouse and referenced FSAR Section 3.8.4 for further details. FSAR Figure 3.8-69 (sheet 4 of 4) indicated that sluice gates were located in the concrete chamber located in the front of the pumphouse. It appeared that these sluice gates were associated with the operation of the Unit 3 recirculation tempering line discussed in LRA Section 2.4.2.30. The applicant was requested to clarify whether these sluice gates were within the scope of license renewal. If they were, the applicant was requested to identify where they were included in LRA Table 2.4.2-26. If they were not, the applicant was requested explain why not.

In its response to RAI 2.4-9, dated November 9, 2004, the applicant stated:

The sluice gates consist of a frame, guides, and sliding gate installed in the concrete chamber walls. These component parts are the equivalent of valve internals and have been determined to be active components. However, the sluice gate is not configured with a pressure boundary housing. Therefore, although the sluice gates are within the

scope of license renewal, they are active components that do not require aging management review, and are not included in LRA Table 2.4.2-26.

Based on its review, the staff finds the applicant's response to RAI 2.4-9 acceptable. The staff

concurs with the applicant's assessment that the sluice gates are in the LR scope, but may be treated as active components, similar to valves. Unlike valves, the sluice gates do not perform a passive pressure boundary intended function, and consequently do not require aging management. The staff considers its concern described in RAI 2.4-9 resolved.

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2.4B.2.26.3 Conclusion

The staff reviewed the LRA, related structural/component information, and RAI response,

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant.N1No omissions werelderitified. In addition, the staff

performed a-review to determine whether anytcdiponents that should be subject to an AMR

were not identified by the applicant. No omissiohs'were identified. On the basis of its review, the

staff concludes that there is reasonable aisurance' that the applicant has adequately identified

the components of the Unit 3 circulating and service water pumphouse that are within the scope

of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the components of the Unit 3 circulating and service water pumphouse that are

subject to an aging management review, as recuired by 10 CFR 54.21 (a)(1).

2.4B.2.27 Unit 3 West Retaining Wall

2.4B.2.27.1 Summary of Technical Informationhin the Application

In LRA Section 2.4.2.27, the'applicant described the Unit 3 west retaining wall.- A safety-related

reinforced concrete retaining wall is provided on'the west side of the circulating and service

water pumphouse to protect the safety-related SW lines' and the concrete duct bank containing

the power and control cables from being undermined due to wave action on the adjoining slope.

The Unit 3 west retaining wall, which is approximately 126 feet in lenrgth,'is an extension of the

west wall on the circulating and SW pumphouse and extends in a northerly'direction along an

adjoining earthen slope. The top of the Unit 3 west retaining wall is at approximately 14 feet

mean sea level. The retaining wall footing is founded on bedrock.

The Unit 3 west retaining wall is a Seismic Category I'structure that provides protection for

safety-related service water piping.

Intended functions within the scope of license renewal include the following:

provides structural and/or-functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3) -- , .

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a protective barrier for in'temal/extemal flooding events

In LRA Table 2.4.2-27, the applicant identified the following Unit 3 west retaining wall

component type that is within the scope of license renewal and subject to an AMR: structural

reinforced concrete (footing, walls).

2.4B.2.27.2 Staff Evaluation '

The staff reviewed LRA Section 2.4.2.27 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

~~~* * -.- ** ivIn conducting its review, the staff evaluated the' structural or component functions of the Unit 3

west retaining wall described in the LRA and MillstorieFSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not onit from the sc6pe of

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license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff then verified that the passive, long-lived components were subject to an AMR, in

accordance with 10 CFR 54.21 (a)(1).

The staffs review of LRA Section 2.4.27 identified one area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. Therefore,

the staff issued RAI 2.4-10, to determine whether the applicant has properly applied the scoping

criteria of 10 CFR 54.4(a), and the screening criteria of 10 CFR 54.21 (a)(1). The staffs RAI is

described below.

LRA Section 2.4.2.27 for Millstone 3 discusses the scoping and screening results for the Unit 3

west retaining wall. The LRA states that the Unit 3 retaining wall is within the scope of license

renewal because it meets 10 CFR 54.4(a)(1) because it is a Seismic Category I structure that

provides protection for safety-related SW piping. FSAR Section 3.8.4.1 states that the function

of the west retaining wall is to protect the Category 1 SW and electrical lines located behind the

wall and to be part of the shoreline protection. FSAR Section 2.5.5.1.1 further states that the

west retaining wall is to protect the circulating and SW lines from being undermined due to

wave action on the adjoining slope. This slope is referred to in FSAR Section 2.5.5.1.1 as the

"shoreline slope," and the FSAR states that a multilayer stone armor zone was placed on the

slope for protection against wave action during the probable maximum hurricane. There is

considerable discussion in FSAR Section 2.5.5 concerning the analysis of the stability of this

slope under static, dynamic and post-earthquake conditions. The applicant was requested to

explain whether the shoreline slope serves an intended function in accordance with

10 CFR 54.4(a)(2). If so, applicant was requested to identify the components of the slope that

are subject to an AMR and the results of that review.

In its response to RAI 2.4-10, dated November 9, 2004, the applicant stated:

The shoreline slope configuration and multilayer stone armor zone described in FSAR

Section 2.5.5.1.1 is not required to protect the nearby West Retaining Wall and

Circulating and Service Water Pumphouse Category I structures or the service water

lines and electrical cabling. However, failure of the shoreline slope stone armor, which

was placed to protect the slope from wave action based on the probable maximum

hurricane, could result in erosion or a slope failure of the shoreline slope and

displacement of material to near the intake bays, possibly resulting in a restriction of the

service water pump suction. Therefore, the multilayer stone armor zone should have

been included within the scope of license renewal and subject to aging management

review.

Based on its review, the staff finds the applicant's response to RAI 2.4-10 acceptable from the

scoping and screening perspective. The applicant has identified that the 'multilayer stone armor

zone" is included in the LR scope, because failure of the shoreline slope might restrict SW

pump suction. The staff considers its concern described in RAI 2.4-10 resolved.

2.4B.2.27.3 Conclusion

The staff reviewed the LRA, related structural/component information, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

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were not identified by the applicant. No omissions were identified. On the basis of its review, the'

staff concludes that there is reasonable assurance that the applicant has adequately identified

the components of the Unit 3 west retaining wall that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that are subject to-an aging management review, as required

by 1 0 CFR 54.21 (a)(1).

2.4B.2.28 Sea Wall . . - I . . i . I ; .

2.4B.2.28.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.28, the applicant described the sea wall. The Unit 3 circulating and SW'

pumphouse is protected from wave action by a reinforced concrete sea wall with post-tensioned

rock anchors consisting of steel tendons. The wall is supported by a reinforced concrete

footing, which is founded upon concrete fill and rock. The top of the wall is approximately 14 ft.

above mean sea level.

The concrete sea wall is a non-safety-related structure that protects the structural integrity of

the safety-related Unit 3 circulating and SW pumphouse.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides a protective barrier for internal/extemal flooding events

In LRA Table 2.4.2-28, the applicant identified the following sea wall component type that is

within the scope of license renewal and subject to an AMR: structural reinforced concrete

(footing, walls).,

2.4B.2.28.2 Staff Evaluation '

The staff reviewed LRA Section 2.4.2.28 and the referenced Millstone FSAR Sections.' The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800. , - .

In conducting its review, 'the staff evaluated the structural or component functions of the sea

wall described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR

54.4(a) to verify that the applicant did not omrnit from the scope of license re'newal any

components with intended functions delineated in 10 CFR 54.4(a). The staff then verified that

the passive, long-lived components were subject to an'AMR, in accordance with

10 CFR 54.21 (a)(1). h a

The staff's review of LRA Section 2.4.28 id6ntifie&done'area in which additional information was

necessary to complete the review of the applicaht's scoping and screenin'g results. Therefore,

the staff issued RAI 2.4-11, to determine wh'ethr the applicant has properly applied the scoping

criteria of 10 CFR 54.4(a), and the screening criteria of 10 CFR 54.21 (a)(1).'The' staff's RAI is

described below.

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LRA Section 2.4.2.28 for Millstone 3 discussed the scoping and screening results for the sea

walls. The LRA stated that the walls are reinforced concrete with post-tensioned rock anchors

consisting of steel tendons. FSAR Section 2.5.5.1.1 provided similar information. A typical

anchorage was not shown in the Millstone 3 FSAR; however, from the written description, it

appeared that the details are similar to those shown in Figure 2.5-15 of the Millstone 2 FSAR.

LRA Table 2.4.2-28 listed the sea wall structural members requiring aging management review

as "structural reinforced concrete (footing, walls)." The applicant was requested to clarify.

whether the Millstone 3 sea wall anchorage system was the same as that shown in the Millstone

2 FSAR Figure 2.5-15 and to indicate whether the anchorage system was within the scope of

license renewal and included as part of the item listed in LRA Table 2.4.2-28. If the anchorage

system was not included within the scope of license renewal, the applicant was requested to

explain why not.

In its response to RAI 2.4-11, dated November 9, 2004, the applicant stated that the Unit 3 sea

wall anchorage design is the same as the Unit 2 design except that the unbonded length of the

anchor strands is protected with a corrosion protection material instead of grout.

The sea wall anchorage functions to maintain integrity of the sea wall and is within the scope of

license renewal. The sea wall anchorage was omitted from LRA Table 2.4.2-28 and Table

3.5.2-29.

Based on its review, the staff finds the applicant's response to RAI 2.4-11 acceptable based on

the inclusion of the component. The staff considers its concern described in RAI 2.4-11

resolved.

2.4B.2.28.3 Conclusion

The staff reviewed the LRA, related structural/component information, and RAI response

described above to determine whether any SSCs that should be within the scope of license

renewal were not identified by the applicant. No omissions were identified. In addition, the staff

performed a review to determine whether any components that should be subject to an AMR

were not identified by the applicant. No omissions were identified. On the basis of its review, the

staff concludes that there is reasonable assurance that the applicant has adequately identified

the components of the sea wall that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the sea

wall that are subject to an aging management review, as required by 10 CFR 54.21(a)(1).

2.4B.2.29 Unit 3 Circulating Water Discharge Tunnel and Discharge Structure

2.4B.2.29.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.29, the applicant described the Unit 3 circulating water discharge tunnel

and discharge structure. The SW and circulating water systems discharge into the discharge

tunnel. The circulating water discharge tunnel is a reinforced concrete structure that is located

below grade: It extends from the turbine building to the rock quarry. The reinforced concrete

tunnel is founded on rock, concrete fill, and till.

The circulating water discharge structure, a continuation of the circulating water discharge

tunnel, is located at the end of the circulating water discharge tunnel. It is a reinforced-concrete

structure with a portion of the structure below grade and a portion exposed to atmosphere and

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weather. The circulating water discharge structure has a seal pit with a concrete weir wall where

the discharge water is forced up and over the wall and into the rock quarry. From the quarry,

the water passes through a channel into Long Island Sound.

The Unit 3 circulating water discharge tunnel and discharge structure are Seismic Category I

structures whose failure could affect the discharge path of the safety-related SW system.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a pressure boundary

In LRA Table 2.4.2-29, the applicant identified the following Unit 3 circulating water discharge

tunnel and discharge structure component type that is within the scope of license renewal and

subject to an AMR: structural reinforced concrete (floor slabs, roof slabs, walls).

2.4B.2.29.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.29 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

circulating water discharge tunnel and discharge structure described in the LRA and Millstone

FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not

omit from the scope of license renewal any components with intended functions delineated in

10 CFR 54.4(a). The staff did not identify any omissions. The staff then verified that the

passive, long-lived components were subject to an'AMR, in accordance with

10 CFR 54.21 (a)(1).

2.4B.2.29.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is ' '

reasonable assurance that the applicant has adequately identified the components of the Unit 3

circulating water discharge tunnel and discharge' structure that are within the scope of license*

renewal, as required by 10 CFR 54.4(a),-and 'that the applicant has adequately identified the

components of the Unit 3 circulating water discharge tunnel and discharge structure that are

subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4B.2.30 Unit 3 Recirculation Tempering Line

2.4B.2.30.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.30, the applicant described the Unit 3 recirculation tempering line. A nonsafety-related recirculation tempering line is provided from the circulating water discharge

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tunnel to the Unit 3 circulating and SW pumphouse to provide for de-icing at the intake, if

required.

The Unit 3 recirculation tempering line is a non-safety-related structure whose failure could

allow the formation of ice to occur in front of the Unit 3 circulating and SW pumphouse, thus

blocking flow to the safety-related SW system.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.4.2-30, the applicant identified the following Unit 3 recirculation tempering line

component types that are within the scope of license renewal and subject to an AMR:

equipment pads/grout; miscellaneous steel [embedded steel-exposed surfaces (shapes, plates,

unistrut, etc.) platforms and grating]; and structural reinforced concrete (beams, foundation mat

slabs, roof slabs, walls).

2.4B.2.30.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.30 and the referenced Millstone FSAR Sections. The

staff's review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the Unit 3

recirculation tempering line described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4B.2.30.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the Unit 3

recirculation tempering line that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the Unit 3

recirculation tempering line that are subject to an aging management review, as required by

10 CFR 54.21(a)(1).

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2.4B.2.31 Vacuum Priming Pumphouse

2.4B.2.31.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.31, the applicant described the vacuum priming pumphouse. The vacuum

priming pumphouse contains the vacuum priming system for the Unit 3 circulating water

discharge tunnel and includes fire suppression equipment. The vacuum priming pumphouse,

which is located on top of the Unit 3 circulating water discharge structure, is a one-level

reinforced-concrete structure with a concrete mat foundation. The structural walls and roof slab

are constructed of concrete.

The vacuum priming pumphouse supports fire protection.

Intended functions within the scope of license renewal include providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(2) or (a)(3).

In LRA Table 2.4.2-31, the applicant identified the following vacuum priming pumphouse

component type that is within the scope of license renewal and subject to an AMR: pipe.

2.4B.2.31.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.31 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1800.

In conducting its review, the staff evaluated the structural or component functions of the

vacuum priming pumphouse described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

component was subject to an AMR, in accordance with' 10 CFR 54.21 (a)(1).

2.4B.2.31.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal wer6'not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequateiy'identified the component of the

vacuum priming pumphouse that is within thei scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the component of the vacuum

priming pumphouse that is subject to an aging management review, as required by

10 CFR 54.21 (a)(1). '

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2.4B.2.32 Tank Foundations

2.4B.2.32.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.32, the applicant described the tank foundations. The applicant described

the following foundations that are within the scope of license renewal:

* Unit 3 condensate storage tank foundation

* fire water tank 1 and 2 foundations

* Unit 3 refueling water storage tank foundation

* SBO diesel fuel oil storage tank foundation

* Unit 3 demineralized water storage tank foundation and enclosure

* Unit 3 carbon dioxide tank foundation

* Unit 3 boron recovery tanks foundation and enclosure

The fire water tank I and 2 foundations, the carbon dioxide tank foundation, and the boron

recovery tank foundation and enclosure supports fire protection. The refueling water storage

tank foundation and the demineralized water storage tank foundation and enclosure qualify as

Seismic Category I structures and enclosures. The condensate storage tank foundation

provides support for the in-scope, non-safety-related condensate storage tank. The SBO diesel

fuel oil storage tank foundation supports fire protection and station blackout.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a missile (internal or external) barrier

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

In LRA Table 2.4.2-32, the applicant identified the following tank foundations component type

that is within the scope of license renewal and subject to an AMR: structural reinforced concrete

(foundation mat slabs, roof slabs, footing, walls).

2.4B.2.32.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.32 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the tank

foundations described in the LRA and Millstone FSAR in accordance with the requirements of

10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21 (a)(1).

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2.4B.2.32.3 Conclusion

The staff reviewed the LRA'and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any-components that should be'subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the tank

foundations that are within the scope of license renewal, as required by 10 CFR 54.4(a), andthat the applicant has adequately identified the components of the tank foundations that are

subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4B.2.33 Yard Structures

2.48.2.33.1 Summary of Technical Information in the Application

In LRA Section 2.4.2.33, the applicant described the yard structures; The applicant described

the following yard structures that are within the scope of license renewal:

* Unit 3 transformer firewalls and dikes

* SBO diesel fuel oil storage tank dike

* SBO fuel oil tank tent

* Unit 3 yard valve pits and enclosure

* Unit 3 pipe tunnel

* Unit 3 encasement

* Unit 3 manholes

* Unit 3 duct banks

* Unit 3 security lighting supports '(including'poles)

v technical support building

The transformer firewalls and dikes, the SBO diesel fuel oil storage tank dike, the SBO fuel oil

tank vent, the pipe tunnel, the security lighting supports; and the technical support building

support fire protection. The valve yard pits and enclosure non-safety-related structural members

support the function of safety-related equipment; the valve yard pits 6and enclosure also meet by

supporting fire protection. The encasement is a non-safety-related structure that provides

protection for safety-related service water'system piping. The manholes contain electrical

cables for safety-related in scope equipment; the manholes also supports station blackout. The

duct banks support and protect electrical cables for safety-related, in-scope equipment; other

duct banks support station blackout. "-

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

* provides a missile (intemal or external) barrier

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In LRA Table 2.4.2-33, the applicant identified the following yard structures component types

that are within the scope of license renewal and subject to an AMR: structural reinforced

concrete (footing, walls); flood/spill barriers including curbs, dikes, toe plates, and stop logs;

miscellaneous steel (checkered plates); structural steel (beams, bracing); access covers;

manhole covers; metal siding; structural reinforced concrete (foundation mat slabs, roof slabs,

walls); manhole covers; structural steel; encasement; duct banks; and lighting poles.

2.4B.2.33.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2.33 and the referenced Millstone FSAR Sections. The

staffs review was conducted in accordance with the guidance described in Section 2.4 of the

NUREG-1 800.

In conducting its review, the staff evaluated the structural or component functions of the yard

structures described in the LRA and Millstone FSAR in accordance with the requirements of 10

CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any

components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any

omissions. The staff then verified that the passive, long-lived components were subject to an

AMR, in accordance with 10 CFR 54.21(a)(1).

2.46.2.33.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the yard

structures that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that

the applicant has adequately identified the components of the yard structures that are subject to

an aging management review, as required by 10 CFR 54.21(a)(1).

2.4B.3 NSSS Equipment Supports

24B.3.1 Summary of Technical Information in the Application

In LRA Section 2.4.3, the applicant identified the components of the NSSS equipment supports

that are subject to an AMR for license renewal. The applicant described the following NSSS

equipment supports that are the plant components that support and restrain the following

reactor coolant system equipment:

* reactor vessel

* reactor coolant pumps

* steam generators

* pressurizer

The intended function within the scope of license renewal includes providing structural and/or

functional support to equipment meeting 10 CFR 54.4(a)(1).

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In LRA Table 2.4.2-34, the applicant identified the following NSSS equipment supports

component types that are within the scope of license renewal and subject to an AMR:

pressurizer support - bolting, manufactured items, plate and structural shapes; reactor coolant

pump support - bolting,' manufactured items and snubber attachment hardware,'plate and

structural shapes; reactor vessel support - bolting, neutron shield tank assembly, plate and

structural'shapes, sliding support plate; steahi generator support - manufactured items and

snubber attachment hardware, bolting, plate and structural shapes.

2.4B.3.2 Staff Evaluation

The staff reviewed LRA Section 2.4.3 and the referenced Millstone FSAR Sections. The staffs

review was conducted in accordance with the guidance described in Section 2.4 of the NUREG1800.

In conducting its review, the staff evaluated the structural or component functions of the NSSS

equipment supports described in the LRA and Millstone FSAR in accordance with the

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive,'long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21(a)(1).

2.4B.3.3 Conclusion .

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of. license renewal were not identified by the,

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that'should be subject to an AMR were not identified by the applicant.

No omissions were identified. On the basis of its review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the NSSS

equipment supports that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the NSSS

equipment supports that are subject to an aging management review, as required by

10 CFR 54.21(a)(1). ,

2.4B.4 General Structural Supports

2.4B.4.1 Summary of Technical Information in the Application

In LRA Section 2.4.4, the applicant identified thecomponents of the general structural supports.

that are subject to an AMR for license renewal. Structural supports for mechanical and electrical

components are an integral part of all plant systems. Many of these supports are not uniquely

identified with component identification numbers. However, characteristics of the supports, such

as design, materials of construction, environments, and anticipated stressors, are similar.

Therefore, structural supports for mechanical and electrical components are evaluated as

commodities across system boundaries.

Structural supports protect and support equipment that is within the scope of license renewal.

Non-safety-related supports prevent interaction between safety-related and non-safety-related

components. Other supports provide support for components credited for fire protection, station

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blackout, anticipated transient without scram, pressurized thermal shock, or environmental qualification of electrical equipment.

Intended functions within the scope of license renewal include the following:

* provides 

(a)(3)

structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or I

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

In LRA Table 2.4.2-35, the applicant identified the following general structural supports component types that are within the scope of license renewal and subject to an AMR: battery racks; electrical conduit; cable trays; 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.).

2.4B.4.2 Staff Evaluation

The staff reviewed LRA Section 2.4.4 and the referenced Millstone' FSAR Sections. The staffs review was conducted in accordance with the guidance described in Section 2.4 of the NUREG- 1800.

In conducting its review, the staff evaluated the structural or component functions of the general structural supports described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any-omissions. The staff then verified that the passive, long-lived components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4B.4.3 Conclusion

The staff reviewed the LRA and related structural/component information-to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine whether any components that should be subject to an AMR were not identified by the applicant. No omissions were identified. On the basis of its review, the staff concludes that there is reasonable assurance that the applicant has adequately identified the components of the

general structural supports that are within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the components of the general structural supports that are subject to an aging management review, as required by 10 CFR 54.21 (a)(1).

2.4B.5 Miscellaneous Structural Commodities

2.4B.5.1 Summary of Technical Information in the Application

In LRA Section 2.4.5, the applicant identified the components of the miscellaneous structural commodities that are subject to an AMR for license renewal. Miscellaneous structural commodities are within the scope of license renewal because they meet provides safety-related functions, 10 CFR 54.4(a)(2) by supporting safety-related component functions, and/or

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10 CFR 54.4(a)(3) by supporting environmental qualification, fire protection, station blackout,

anticipated transient without scram, and pressurized thermal shock regulations.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides enclosure, shelter, or other protection for in-scope equipment (including

radiation shielding and pipe-whip'restraint)''

* provides a rated fire barrier to confine or retard a fire from spreading to or from adjacent

areas of the plant.

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1.)

* provides EQ barrier and/or HELB barrier.'.

* provides a.protective barrier for intemal/extemal flooding events

* provides a pressure boundary

In LRA Table 2.4.2-36, the applicant identified the following miscellaneous structural

commodities component types that are within the scope of license renewal and subject to an

AMR: bus duct enclosures; cable tray cover assembly; electrical component supports within

cabinets and panels; expansion jointiseismid gap material (between adjacent

buildings/structures); expansion jointlseismic gap material (fire-rated walls); fire boots; fire

doors and/or EQ barrier doors; fire resistant coating; fire stops; fire-rated duct wrap; fire/EQ

barrier penetration seals (including ceramic dammiing material); flood gate gasket; flood gates; " flood prevention'plugs; gaskets in junction, terrminal, and pull boxes; gypsum boards; junction,'

terminal, and pull boxes; panels and cabinets,, oof hatch seals; switchgear enclosures;

watertight door gasket; and watertight doors.

2.4B.5.2 Staff Evaluation

The staff reviewed LRA Section 2.4.5 and the referenced Millstone FSAR Sections. The staffs

review was conducted in accordance with'the'guidance described in Section 2.4 of the NUREG1800.

In conducting its review, the staff evaluated the structural or component functions of the

miscellaneous structural commoditie'sdescribed'in the LRA'and Millstone FSAR in accordance

with the requirements of 10 CFR 54.4(a) tde'rify that'the applicant did not omit from the scope

of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions.iThe staff then verified that the passive, long-lived

components were subject to an AMR, in adcordafice with 10 CFR'54.21 (a)(1).

2.4B.5.3 Conclusion

The staff reviewed the LRA and related structural/component information to determine whether

any SSCs that should be within the scope of license' reneewal were not identified by the

applicant. No omissions'were identified. In addition,' the staff performed a review to determine

whether any components that should be subject to an AMR were'inot identified by the applicant.

No omissions were identified. On the basis of itssievi6w; the staff concludes that there is

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reasonable assurance that the applicant has adequately identified the components of the

miscellaneous structural commodities that are within the scope of license renewal, as required

by 10 CFR 54.4(a), and that the applicant has adequately identified the components of the

miscellaneous structural commodities that are subject to an aging management review, as

required by 10 CFR 54.21(a)(1).

2.4B.6 Load Handling Cranes and Devices

2.4B.6.1 Summary of Technical Information in the Application

In LRA Section 2.4.6, the applicant identified the components of the load handling cranes and

devices that are subject to an AMR for license renewal. The load handling cranes and devices

are within the scope of license renewal because certain load handling cranes and devices are

Seismic Category I and meet 10 CFR 54.4(a)(1), or are seismically designed and meet

10 CFR 54.4(a)(2) to ensure that they will not adversely impact safety-related components

during or subsequent to a seismic event.

Intended functions within the scope of license renewal include the following:

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(2) or

(a)(3)

* provides structural and/or functional support to equipment meeting 10 CFR 54.4(a)(1)

In LRA Table 2.4.2-37, the applicant identified the following load handling cranes and devices

component types that are within the scope of license renewal and, subject to an AMR: cranes

and monorails including bridge & trolley support members (girders, beams, angles, frames,

plates, rails & anchorage); fuel elevator support members (structural plates, track &

anchorage); and fuel transfer system support members (structural base supports, tracks, &

anchorage).

2.4B.6.2 Staff Evaluation

The staff reviewed LRA Section 2.4.6 and the referenced Millstone FSAR Sections. The staffs

review was conducted in accordance with the guidance described in Section 2.4 of the NUREG1800.

In conducting its review, the staff evaluated the structural or component functions of the load

handling cranes and devices described in the LRA and Millstone FSAR in accordance with the.

requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff did not identify any omissions. The staff then verified that the passive, long-lived

components were subject to an AMR, in accordance with 10 CFR 54.21 (a)(1).

2.4B.6.3 Conclusion

The staff reviewed the LRA and related structurallcomponent information to determine whether

any SSCs that should be within the scope of license renewal were not identified by the

applicant. No omissions were identified. In addition, the staff performed a review to determine

whether any components that should be subject to an AMR were not identified by the applicant.

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No omissions were identified. On the basis of its 'review, the staff concludes that there is

reasonable assurance that the applicant has adequately identified the components of the load

handling cranes and devices that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the components of the load

handling cranes and devices that are subject to an aging management review, as required by

10 CFR 54.21 (a)(1).

2.5 Scopina and Screening Results -Electrical and Instrumentation and Controls

Systems '

This section documents the staff's review of the applicant's scoping and screening results for

electrical and instrumentation and controls (I&C) systems. Specifically, this section discusses

the following systems:

* cables and connectors

* -electrical penetrations

* - bus duct .'

In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant must identify and list

passive, long-lived electrical and l&C systems and components that are within the scope of

license renewal and subject to an AMR. To verify that the applicant properly implemented its

methodology, the staff focused its review on the implementation results. This approach allowed

the staff to confirm that there were no omissions of electrical and I&C system components that'

meet the scoping criteria and are subject to an AMR.

Staff Evaluation Methodology. The staff's evaluation of the information provided in the LRA was

performed in the same'manner for all electrical and 'I&C systems. The objective of the review

was to determine if the components and supporting structures for a specific electrical and I&C

system that appeared to meet the scoping criteria specified in the rule were identified by the

applicant as within the scope of license renewal in accordance with 10 CFR 54.4.'Similarly, the

staff evaluated the applicant's screening results to verify that all long-lived, passive components

were subject to an AMR in accordance with 10 CFR 54.21 (a)(1).

Scoping; To perform its evaluation, the staff r6iewed the applicable LRA section and

associated component drawings, focusing its review'on 'components that had not been -

identified as within the scope of renewal. The staff reviewed relevant licensing basis

documents, including the final safety'analysis report (FSAR), for each electrical and l&C system

component to determine if the applicant had'binitted components with-intended functions"

delineated in 10 CFR 54.4(a) from the scope of license renewal. The staff also' reviewed the

licensing basis documents to'determine if all intended functions delineated in 10 CFR 54.4(a)

were specified in the LRA. If omissions were identified, the staff requested additional

information to resolve the discrepancies.

Screening. Once the staff's review of the scoping results was completed, the staff evaluated the

applicant's screening results. For those structures and components with' intended functions, the

staff sought to determine if the functions are performed with moving 'parts or a change in

configuration or properties, or if they are subject to replacement based on'a qualified life or

specified time period, as described in 10 CFR 54.21 (a)(1). For those that did not'reet either of

these criteria, the staff sought to confirm that these electrical and l&C system components were

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subject to an AMR as required by 10 CFR 54.21(a)(1). If discrepancies were identified, the staff requested additional information to resolve them.

2.5.1 Cables and Connectors Systems

2.5.1.1 Summary of Technical Information in the Application

In LRA Section 2.5.1, the applicant described the cables and connectors systems. Cables and associated connectors provide electrical connections to specified sections of an electrical circuit to deliver voltage, current, or signals. Insulation resistance, which precludes shorts, grounds, and unacceptable leakage currents, maintains circuit integrity.

The cables and connectors within the scope of renewal supply electrical/control power and signals for electrical and l&C equipment: (i) that perform safety-related functions; (ii) whose failure could adversely impact the safety-related function of a safety-related component; or (iii) that are relied upon for fire protection (FP), station blackout (SBO), pressurized thermal shock (PTS), or anticipated transients without scram (ATWS). Cables and connectors within the scope of the EQ program are the subject of time-limited aging analyses (TLAAs) as described in LRA Section 4.4, Environmental Qualification of Electric Equipment.

Intended functions within the scope of license renewal include the following:

* conducts electricity

* insulates electrical conductors

In LRA Table 2.5.1-1, the applicant identified the following cables and connectors systems component types that are within the scope of license renewal and subject to an AMR:

conductors and insulation.

2.5.1.2 Staff Evaluation

The staff reviewed LRA Section 2.5.1 using the evaluation methodology described in Section 2.5 of this SER. The staff conducted its review in accordance with the guidance described in the NRC's Standard Review Plan (NUREG-1800), Section 2.5, 'Scoping and Screening Results - Electrical and Instrumentation and Controls Systems."

In conducting its review, the staff evaluated the structure and component functions of the cables and connectors described in the LRA and Millstone FSAR in accordance with the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of license renewal any components with intended functions delineated in 10 CFR 54.4(a). The staff did not identify any omissions. The staff then reviewed the LRA to verify that passive or long-lived components were not omitted from being subject to an AMR in accordance with

10 CFR 54.21(a)(1).

The applicant states that the cables and connectors within the scope of license renewal meet 10 CFR 54.21; (a)(1), (2) or (3) by supplying electrical control power and signals for electrical and I&C equipment: (i) that performs safety-related functions; (ii) whose failure could adversely impact the safety-related function; or (iii) that is relied upon for fire protection, station blackout, pressurized thermal shock, or anticipated transients without scram. The evaluation boundary for the non-EQ cables and connectors includes cables, connectors, terminations, and cables in

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storage. The commodity groups that require AMR are indicated in Table 2.5.1-1, "Cables and

Connectors." The commodity group includes conductors and insulation. The function of

insulated cables and connections is to electrically connect specified sections of an electrical

circuit to deliver voltage, current, or signals. Electrical cables and their connections are

reviewed as commodity groups. In RAI 2.5-1, the staff requested the following information:

(1) Table 2.5.1 of the LRA lists electrical cables and connectors not subject to EQ

requirements to be subjected to an-aging management review (AMR). It did not include

splices, and fuse holder (non-metallic portions). The applicant was requested to provide

a technical justification of why splices, and fuse holders are excluded from the AMR.

(2) The applicant was requested to discuss whether there are there any non-safety related

cables (not within the scope of license renewal) excluded from an AMR that includes

cables. If that includes cables, the applicant was requested to discuss how these cables

are treated if they run in the same conduits or race ways with the other cables.

(3) The applicant was requested to explain why grounding systems are not within the scope

of license renewal.

(4) Section 2.5, Table 2.5.1 of the LRA did not include the transmission connections to be

included in the AMR. Transmission connections are within the scope of license renewal,

are considered long-lived, passive components and should be included in the AMR.

Therefore, the applicant was requested to explain why the transmission connections are

excluded from the AMR. :-

By letter dated November 9, 2004, the applicant responded to the staff's questions as follows:

(1) The splices are considered an integral part of the cable and non-EQ splices are included

in the commodity groups, uConductors". and insulation" in LRA Table 2.5.1-1 and the

AMR results are included in LRA table 3.6.2-1. Fuse holders (including non-metallic

portions) that are not part of a larger assembly, but support safety-related and nonsafety-related functions in which a failure of a fuse precludes a safety function from

being accomplished, are subject to AMR and will be evaluated prior to the period of

extended operation as described in LRA Section 2.1.6.5. This commitment is identified

as Commitment 6 in LRA Appendix A, Table A6.0-1.

The staff finds the applicant's commitment to be acceptable based on the applicant's statement,

the splices are already included in the LRA Table 3.6.2-1 and it's commitment to complete the

evaluation of fuse holders prior to the period of extended operation, this resolves RAI 2.5-1(1).

(2) The only non-safety-related cables that are not subject to AMR are the Unit 2 control

element drive mechanism and Unit 3 control rod drive mechanism cables. In some

instances, these cables may be routed in the same raceways as in-scope non-EQ

cables. However, since an area-based approach is used to manage the effects of aging

for non-EQ cables, as described in LRA Section B2.1.8, "Electrical Cables and

Connectors not Subject to 10 CFR 50.49 Environmental Qualification Requirements," all

cables within a raceway are subject to aging management program.

The staff finds the applicant's response to be acceptable based on the applicant's clarification

that all cables within a raceway are subject to aging management, this resolves RAI 2.5-1(2).

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(3) The station grounding system bonds metal raceways, building structural steel, and plant

equipment to earth ground through an installed grounding grid. The station grounding

system is non-safety related and is provided for personnel and equipment protection. In

the event of a fault in an electrical circuit or component, the grounding system includes

the capability to detect and/or isolate the fault to minimize equipment damage. The

grounding system does not prevent faults and is not required for equipment operation.

Failure of the system cannot affect the accomplishment of any safety functions.

Therefore, the system does not perform an intended function that meets the criteria of

10 CFR 54.4(a) and is not within the scope of license renewal.

The staff finds the applicant's response to be acceptable based on the applicant's clarification

that the grounding system does not prevent faults and is not required for equipment operation,

this resolves RAI 2.5-1(3).

(4) Transmission connections are within the scope of license renewal and subject to AMR.

Transmission connections are included in the commodity group 'Conductors" in LRA

Table 2.5.1-1.

The staff finds the applicant's response to be acceptable based on the applicant's clarification

that transmission connections are included in Table 2.5.1-1, this resolves RAI 2.5-1(4).

2.5.1.3 Conclusion

During its review of the information provided in the LRA, license renewal drawings, and RAI

responses discussed above, the staff did not identify any omissions or discrepancies in the

applicant's scoping and screening results for the structures and components of the cables and

connectors. Therefore, the staff concludes that the applicant has adequately identified the

cables and connectors systems components that are within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the cables and

connectors systems components that are subject to an AMR, as required by

10 CFR 54.21(a)(1). However, fuse holders (including non-metallic portions) that are not part of

a larger assembly, will be evaluated prior to the period of extended operation as described in

LRA Section 2.1.6.5. This commitment is identified as Commitment 6 in LRA Appendix A, Table

A6.0-1.

2.5.2 Electrical Penetrations Systems

2.5.2.1 Summary of Technical Information in the Application

In LRA Section 2.5.2, the applicant described the electrical penetrations systems. Electrical

penetrations permit the conduction of electrical power or signals through the containment wall

while maintaining the integrity of the containment pressure boundary.

The electrical penetrations provide a seal between the containment and the outside

atmosphere. The electrical penetration assemblies within the scope of the EQ program are the

subject of a TLAA as described in LRA Section 4.4, Environmental Qualification of Electric

Equipment.

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Intended functions within the scope of license renewal include the following:

* conducts electricity

* insulates electrical conductors

* provides a pressure boundary

* provides structural and/or functional support related to mechanical components

In LRA Table 2.5.2-1 the applicant identified the following electrical penetrations systems

component types that are within the scope of license renewal and subject to an AMR:

conductors; feed-through module; header plates; bolting hardware; compression connectors;

feed-through sealant; insulation; internal conductor support; and penetration seals.

2.5.2.2 Staff Evaluation

The staff reviewed LRA Section 2.5.2 using the evaluation methodology described in Section

2.5 of this SER. The staff conducted its review in accordance with the guidance described in the

NRC's Standard Review Plan (NUREG-1800), Section 2.5, "Scoping and Screening

Results - Electrical and Instrumentation and Controls Systems."

In conducting its review, the staff evaluated the structure and component functions of the

electrical penetrations systems described in the LRA and Millstone FSAR in accordance with

the requirements of 10 CFR 54.4(a) to verify that the applicant did not omit from the scope of

license renewal any components with intended functions delineated in 10 CFR 54.4(a). The

staff then reviewed those components that the applicant identified as being within the scope of

license renewal to verify that the applicant did not omit any passive and long-lived components

that should be subject to an AMR in accordance with the requirements of 10 CFR 54.21 (a)(1).

Electrical penetrations are used to pass electrical circuits through the containment wall while

maintaining containment integrity. They provide electrical continuity for the circuit as well as a

pressure boundary for the containment. The electrical penetrations are within the scope of

license renewal because they provide a seal between the containment and the outside

atmosphere. All primary containment electrical penetrations are included in the scope of the

rule. The electrical continuity function of penetrations is managed under the EQ program which

is discussed in Section 4.4, "Environmental Qualification of Electrical Equipment." The

evaluation boundary of the non-EQ electrical penetrations includes the sealed conductor feedthrough module. The components subject to an -AMR are indicated in Table 2.5.2.1, "Electrical

Penetrations." The results of the AMR of these components are provided in Table 3.6.2-2:

Electrical Components-Electrical Penetrations-Aging Management Evaluation.

The applicant's methodology has adequately addressed the electrical penetrations and is,

therefore, acceptable.

2.5.2.3 Conclusion

During its review of the information provided in the LRA, license renewal drawings, and

licensing basis information, the staff did not identify any omissions or discrepancies in the

applicant's scoping and screening results for the structures and components of the electrical

penetrations systems. Therefore, the staff concludes that the applicant has adequately

identified the electrical penetrations systems components that are within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

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electrical penetrations systems components that are subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.5.3 Bus Duct Systems

2.5.3.1 Summary of Technical Information in the Application

In LRA Section 2.5.3, the applicant described the bus duct systems. A switchyard-type' tubular

bus duct is a bare, rigid conductor supported on insulator posts or stacks. These insulators are

non-porous, translucent, porcelain ceramic covered with an oven-baked glaze. The bus support

insulator attaches to the bus duct and a support stand to provide a rigid insulating support for

the bus duct.

These switchyard-type tubular bus ducts are required for the restoration of offsite power during

a station blackout event.

Intended functions within the scope of license renewal include the following:

* conducts electricity

* insulates electrical conductors

* provides structural and/or functional support related to mechanical components

In LRA Table 2.5.3-1, the applicant identified the following bus duct systems component types

that are within the scope of license renewal and subject to an AMR: bus duct and bus support

insulator.

25.3.2 Staff Evaluation

The staff reviewed LRA Section 2.5.3 using the evaluation methodology described in Section

2.5 of this SER. The staff conducted its review in accordance with the guidance described in the

NRC's Standard Review Plan (NUREG-1800), Section 2.5, "Scoping and Screening Results -

Electrical and Instrumentation and Controls Systems."

In conducting its review, the staff evaluated the systems functions described in the LRA in

accordance with the' requirements of 10 CFR 54.4(a) to verify that the applicant did not omit

from the scope of license renewal any components with intended functions delineated in

10 CFR 54.4(a). The staff then reviewed those components that the applicant identified as

being within the scope of license renewal to verify that the applicant did not omit any passive

and long-lived components that should be subject to an AMR in accordance with the

requirements of 10 CFR 54.21(a)(1).

The switchyard-type tubular bus ducts are within the scope of license renewal for

10 CFR 54.4(a)(3) since they are required for the restoration of offsite power during a station

blackout event. The applicant described the bus ducts in LRA Section 2.5.3 and provided a list

of components subject to an AMR in LRA Table 2.5.3-1, "Bus Duct," and 3.6.2-3, uElectrical

Components-Bus Duct-Aging Management Evaluation."

The applicant has adequately addressed the bus duct and is, therefore, acceptable.

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2.5.3.3 Conclusion

During its review of the information provided in the LRA, license renewal drawings, and

licensing basis information, the staff did not identify any omissions or discrepancies in the

applicant's scoping and screening results for the structures and components of the bus duct

systems. Therefore, the staff concludes that the applicant has adequately identified the bus

duct systems and components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the bus duct systems

components that are subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.6 Conclusion for Scoping and Screening

The staff has reviewed the information in Section 2, "Structures and Components Subject to

Aging Management Review" of the LRA. The staff determined the applicant's scoping and

screening methodology, including its supplement 10 CFR 54.4(a)(2) review which brought

additional nonsafety-related piping segments and associated components into the scope of

license renewal, was consistent with the requirements of 10 CFR 54.21 (a)(1) and the staff's

position on the treatment of safety and nonsafety-related SSC's within the scope of license

renewal and the structures and components requiring an AMR is consistent with the

requirements of 10 CFR 54.4 and 10 CFR 54.21(a)(1).

On the basis of its review, the staff concludes that the applicant has adequately identified those

systems and components that are within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified those systems and

components that are subject to an AMR, as required by 10 CFR 54.21 (a)(1).

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

licensing basis in order to comply with 10 CFR 54.29(a) are in accord with the Act and the

Commission's regulations.

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SECTION 3

AGING MANAGEMENT!REVIEW RESULTS

This section of the SER contains the staffs evaluation of the applicant's aging management

programs (AMPs) and aging management reviews (AMRs). In Appendix B of the LRA, the

applicant described the 25 AMPs that it relies on to manage or monitor the aging of long-lived,

passive components and structures. -

By letter dated December 3, 2004, the applicant supplemented the program discussions in

Appendix B to the license renewal application (LRA) by providing a new AMP, Section B2.1.26,

"Bolting Integrity." A

In Section 3 of the LRA, the applicant provided the results of the AMRs for those structures and

components that were identified in Section 2 of the LRA'as being within the scope of license

renewal and subject to an AMR.

3.0 Applicant's Use of the Generic Aging Lessons Leamed Report

In preparing its license renewal application (LRA), Dominion Nuclear Connecticut, Inc.

(Dominion or the applicant) credited NUREG-1 801,"Generic Aging Lessons Leamed (GALL)

Report," dated July 2001. The GALL Report contains the staffs generic evaluation of the

existing plant programs and documents the technical basis for determining where existing

programs are adequate without modification and where existing programs should be

augmented for the extended period of operation.-The evaluation'results documented in the

GALL Report indicate that many of the existing programs are adequate to manage the aging'

effects for particular structures or components for license renewal without change. The GALL

Report also contains recommendations on specific areas for which existing programs should be,

augmented for license renewal. An applicant may reference the GALL Report in its LRA to

demonstrate that the programs at its facility correspond to those reviewed and approved in the

report.

The purpose of the GALL Report is to provide the staff with a summary of staff-approved AMPs

to manage or monitor the aging of structures and components that are subject to an AMR. If an

applicant commits to implementing these staff-approved AMPs, the time, effort, and resources

used to review an applicant's LRA will be greatly reduced, thereby improving the efficiency and

effectiveness of the license renewal review process. The'GALL Report also serves as a

reference for applicants and staff reviewers to quickly identify those AMPs and activities that the

staff has determined will adequately'manage 'or monitor aging during the period of extended

operation.

The GALL Report identifies (1) systems, 'structures, and components' (SSCs), (2) structure and

component (SC) materials, (3) the environments'to which the SCs are exposed, (4) the aging

effects associated with the materials anid environments, (5) the AMPs that are credited with

managing or monitoring the aging effects, and'(6);recommendations f6r further applicant

evaluations of aging management for certain component types.

To determine whether using the GALL Report would improve the efficiency of the license

renewal review, the staff conducted a demonstration project to exercise the GALL process and

3-1
I.v1

to determine the format and content of a safety evaluation based on this process. The results of

the demonstration project confirmed that the GALL process will improve the efficiency and

effectiveness of the LRA review while maintaining the staff's focus on public health and safety.

NUREG-1 800, "Standard Review Plan for the Review of License Renewal Applications," dated

April 2001 (SRP-LR), was prepared based on both the GALL Report model and lessons learned

from the demonstration project.

The staff performed its review in accordance with the requirements of Title 10, Part 54, of the

Code of Federal Regulations (10 CFR Part 54), 'Requirements for Renewal of Operating

Licenses for Nuclear Power Plants," the guidance provided in NUREG-1 800, the guidance

provided in NUREG-1801.

In addition to its review of the LRA, the staff conducted onsite audit of selected aging

management reviews and associated aging management program as described in the 'Audit

and Review Plan for Plant Aging Management Reviews and Programs, Millstone Power Station,

Units 2 and 3," dated October 27, 2004, (ADAMS ML043290430). The onsite audits and -

reviews are designed to maximize the efficiencies of the staffs review of the LRA. The need for

formal correspondence between the staff and the applicant was reduced, and therefore,

improved the efficiency of the review. Also the applicant could respond to questions, and the

staff could readily evaluate the responses made by the applicant.

3.0.1 Format of the License Renewal Application

The applicant submitted an application that followed the standard LRA format, as agreed to

between the NRC staff and the Nuclear Energy Institute (NEI) (see letter dated April 7, 2003,

ML030990052). This revised LRA format incorporates lessons learned from the staff s reviews

of the previous five LRAs. These previous applications used a format developed from

information gained during an NRC staff and NEI demonstration project conducted to evaluate

the use of the GALL Report in the staff's review process.

The organization of Section 3 of the LRA parallels Chapter 3 of the SRP-LR. The AMR results

information in Section 3 of the LRA is presented in the following two table types:

* Table 1: Table 3.x.1 - where "3" indicates the LRA section number, "x" indicates the

subsection number from the GALL Report, and "1" indicates that this is the first table

type in Section 3 of the LRA.

* Table 2: Table 3x.2-y - where "3" indicates the LRA section number, "x" indicates the

subsection' number of the GALL Report, "2" indicates that this is the' second table type in

Section 3 of the LRA, and "y" indicates the system table number.

The content of the previous applications and the MPS applications is essentially the same. The

intent of the revised format used for the MPS applications was to modify the tables in Chapter 3

to provide additional information to assist the staff in its review. In Table 1 the applicant

summarized the portions of the application it considered to be consistent with the GALL Report.

In Table 2, the applicant identified the linkage between the scoping and screening results' in

Chapter 2 and the AMRs in Chapter 3.

3-2
3.0.1.1 Overview of Table 1 .. I.

Table 3.x.1 (Table 1) provides a summary comparison of how the facility aligns with the

corresponding tables of the GALL Report, Volume 1. The table is essentially the same as

Tables 1 through 6 provided in the GALL Report, Volume 1, except that the 'Type" column has

been replaced by an "Item Number" column and the "Item Number in'GALL" column has been

replaced by a "Discussion" column. The 'Iterh' Number" column provides the reviewer with a

means to cross-reference from Table 2 to Table 1. The "Discussion" 'column is used by the

applicant to provide clarifying/amplifying information. The following are examples of information

that might be contained within this column: - - , i .

*.. further evaluation recommended - information or reference to where that information is

located

* the name of a plant-specific program being used

*' exceptions to the GALL Report assumptions

* a discussion of how the line is consistent with the corresponding line item in the GALL

Report when that may not be intuitively obvious

* a discussion of how the item is different than the corresponding line item in the GALL

Report (e.g., when there is exception taken to an aging management program that is

listed in the GALL Report) .

The format of Table 1 allows the staff to align a specific Table 1 row with the corresponding

NUREG-1801, Volume 1, table row so that consistency can be checked easily.

3.0.1.2 Overview of Table 2

Table 3.x.2-y (Table 2) provides the detailed results of the AMRs for those components

identified in LRA Section 2 as being subject to an AMR. The LRA contains a Table 2 for each of

the components or systems within a system grouping (e.g., reactor coolant systems,

engineered safety features, auxiliary systems,. etc.). For example, the engineered safety

features group contains tables specific to the containment spray system, containment isolation

system, and emergency core cooling system; Table 2 consists of the following nine columns:

(1) 'Component Type- The first colurinn identifies tle 'component types from Section 2 of the

LRA that are subject to aging manageient review. They a re listed in alphabetical order.

(2) Intended Function - The second column contains the license renewal intended functions

(including abbreviations where applicable) for the listed component types. Definitions

and abbreviations of intended functions arepcontained within the Intended Functions

table of LRA Section 2. ; ;' - '

(3) Material - The third column lists the particular materials of construction for the

component type. ; ' A--

(4) Environment - The fourth column lists the environment to which the component types,

are exposed. Internal and external service environments are in~dicated and a list of these

environments is provided inthe'tInte-mal Service Environments 'and External Service

Environments tables of LRA Section 3.

3-3:
4

(5) Aging Effect Requiring Management - The fifth column lists aging effects requiring

management. As part of the aging management review process, the applicant

determined any aging effects requiring management for each material and environment

combination.

(6) Aging Management Programs - The sixth column lists the aging management programs

the applicant used to manage the identified aging effects.

(7) GALL Vol. 2 Item - The seventh column lists the GALL Report item(s) that the applicant

identified as being similar to the AMR results in its LRA. The applicant compared each

combination of component type, material, environment, aging effect requiring

management, and aging management program in Table 2 of the SER to the items in the

GALL Report. If there were no corresponding item in the GALL Report, the applicant left

the column blank. In this way, the applicant identified the AMR results in the LRA tables

that corresponded to items in the GALL Report tables.

(8) Table 1 Item - The eighth column lists the corresponding summary item number from

Table 1. If the applicant identifies AMR results in Table 2 that are consistent with the

GALL Report, then the associated Table 3.x.1 line summary item number should be

listed in Table 2. If there is no corresponding item in the GALL Report, then column

eight is left blank. That way, the information from the two tables can be correlated.

(9) Notes - The ninth column lists the corresponding notes that the applicant used to identify

how the information in Table 2 aligns with the information in the GALL Report. The notes

identified by letters were developed by a Nuclear Energy Institute working group and will

be used in future license renewal applications. Any plant-specific notes are identified by

a number and provide additional information concerning the consistency of the line item

with the GALL Report.

3.0.2 Staff's Review Process

The staff conducted the following three types of evaluations of the AMRs and associated AMPs.

(1) For items that the applicant stated were consistent with the GALL Report, the staff

conducted either an audit or a technical review to determine consistency with the GALL

Report.

(2) For items the applicant stated were consistent with the GALL Report with exceptions

and/or enhancements, the staff conducted either an audit or a technical review of the

item to determine consistency with the GALL Report. In addition, the staff conduct either

an audit or a technical review of the applicant's technical justification for the exceptions

and the adequacy of the enhancements.

(3) For other items, the staff conducted a technical review per 10 CFR 54.21 (a)(3).

The staff performed audits and technical reviews of the license renewal applicant's AMPs and

AMRs. These audit and technical reviews are to determine whether the effects of aging on

structures and components can be adequately managed so that their intended functions can be

maintained consistently with the plant's current licensing basis (CLB) for the period of extended

operation as required by 10 CFR Part 54, "Requirements for Renewal of Operating Licenses for

Nuclear Power Plants."

3-4
The staff performed onsite audits during the weeks of March 29, May 3, May 10, and June 7,

2004, to verify selected AMPs and AMR results that the applicant claimed were consistent with

the GALL Report were actually consistent as claimed. The staff conducted a public exit meeting

on July 13, 2004. Details of the staffs onsite audidt are'documented in the'uAudit and Review

Report for Plant Aging Management Reviews'' Milistbone Power Station, Units 2 and 3," dated

February 2, 2005 (MPS Audit and Review Report) (ML050330059).

3.0.2.1 Review of AMPs -.

For those AMPs for which the applicant 'claime'd consistency with the GALL AMPs, the' staff

conducted either an audit or a technical review 'to verify that the' applicant's AMPs' were'

consistent with the AMPs in the GALL Report. For each AMP that had one or more deviations,

the staff evaluated each deviation to determin'ed (1) whether the deviation' was acceptable, and

(2) whether the AMP, as modified, would adequately manage the aging effect(s) for which it

was credited.

For AMPs that were not evaluated in the GALL Report, the staff performed a full review to

determine the adequacy of the AMPs. The staff.evaluated the AMPs against the following 10

program elements defined in SRP-LR Appendix A.'

(1) Scope of the Program - Scope of the program should include the specific structures and

components subject to an AMR for license renewal.

(2) Preventive Actions - Preventive actions should prevent or mitigate aging degradation.

(3) Parameters monitored or inspected - Parameters monitored or inspected should be

linked to the degradation of the particular structure or component intended functions(s).

(4) Detection of Aging Effects - Detection of aging effects should occur before there is a

loss of structure or component intended functions(s). This includes aspects such as

method or technique (i.e., visual, volumetric, surface inspection),-frequency, sample'

-size, data collection and timing of new/one-time inspections to ensure timely detection of

aging effects.: . I, * -

(5) Monitoring and Trending - Monitoring and trending should provide predictability of the

extent of de and timely corrective.or mitigative actions.

(6) Acceptance Criteria - Acceptance criteria, against which the need for corrective action

will be evaluated, should ensure that the structure or component intended function(s)

are maintained under all CLB design conditions during the period of extended operation.

(7) Corrective Actions - Corrective actions, including root cause determination and

prevention of recurrence, should be timely.

(8) Confirmation Process Confirmation process should ensure-that preventive actions are

adequate and that appropriate corrective actions have been completed and are

effective.

3-5
(9) Administrative Controls - Administrative controls should provide a formal review and

approval process.

(10) Operating experience - Operating experience of the aging management program,

including past corrective actions resulting in program enhancements or additional

programs, should provide objective evidence to support the conclusion that the effects

of aging will be managed adequately so that the structure and component intended

function(s) will be maintained during the period of extended operation.

Details of the staff's audit evaluation of program elements (1) through (6) is documented in its

MPS audit and review report and is summarized in Section 3.0.3 of this SER.

The staff reviewed ihe applicant's corrective action program and documented its evaluations in

Section 3.0.4 of this SER. The 'staffs evaluation of the corrective action program included

assessment of the following program elements: (7) corrective actions, (8) confirmation process,

and (9) administrative controls.

The staff reviewed the information concerning the (10) operating experience program element

and documented its evaluation in its MPS audit and review report and summarized it in

Section 3.0.3 of this SER.

The staff reviewed the Final Safety Analysis Report (FSAR) supplement for each AMP to

determine if it provided an adequate description of the program or activity, as required by

10 CFR 54.21(d).

3.0.2.2 Review of AMR Results

Table 2 of the LRA contains information concerning whether or not-the AMRs align with the

AMRs identified in the GALL Report. For a given AMR in.Table 2, the staff reviewed the

intended function, material, environment, aging effect requiring management, and aging

management program (MEAP) combination for a particular component type within a system.

The AMRs that correlate between a combination in Table 2 and a combination in the GALL

Report were identified by a referenced item number in column seven, "GALL, Volume 2 Item."

The staff also conducted onsite audits to verify the correlation. A blank column seven indicates

that the applicant was unable to locate an appropriate corresponding combination in the GALL

Report. The staff conducted a technical review of these combinations that were not consistent

with the GALL Report. The next column, "Table 1 Item," provided a reference number that

indicated the corresponding row in Table 1.

3.0.2.3 FSAR Supplement

Consistent with the SRP-LR, for the AMRs and associated AMPs that it reviewed, the staff also

reviewed the FSAR supplement that summarizes the applicant's programs and activities for

managing the effects of aging for the period of extended operation, as required by

10 CFR 54.21 (d).

3-6
3.0.2.4 Documentation and Documents Reviewed

In performing its review, the staff relied heavily-on the LRA, the LRA supplements, the SRP-LR,

and the GALL Report.

Also, during the onsite audit, the staff examined the applicant's justification, as documented in

the staff's MPS audit and review report, to verify that the applicant's activities and programs will

adequately manage the effects of aging on SCs. The staff also conducted detailed discussions

and interviews with the applicant's license renewal project personnel and others with technical

expertise relevant to aging management.

3.0.3 Aging Management Programs

Table 3.0.3-1 presents the AMPs credited by the applicant and described in Appendix B of the

LRA. The table also indicates the GALL program that the applicant claimed its AMP was

consistent with (if applicable) and the SSCs for managing or monitoring aging. The section of

the safety evaluation report in which the staffs evaluation of the program is documented also is

provided.

Table 3.0.3-1 MPS's Aging Management Programs

-> MPS's AMP -l' - GALL .|- GA ULRA SystomsorSt tu =4 | ta-s w

-(LRA Section). .' sohat redltth MP' e V SERS ect onExisting AMPs

Battery rack Plant-specific NA Structures and component 3.0.3.3.1

inspections supports

(B2.1.1)

Boraflex monitonng Consistent XL.M22 Structures and component 3.0.3.1.1

(B2.1.2) supports

Boric acid corrosion Consistent XI.M1O Reactor vessel, internals, 3.0.3.1.2

(B2.1.3) and reactor coolant system;

engineered safety features;

auxiliary systems; steam and

power conversion system;

structures and component

l_ supports

Buried pipe Consistent with XI.M28,- - Auxiliary systems 3.0.3.2.1

inspection program exceptions and XL.M34

(B2.1.4) enhancements

Chemistry control for Consistent with X1.M2 Reactor vessel, internals, 3.0.3.2.2

primary systems exception and reactor coolant system;

program engineered safety features;

(B2.1.5) auxiliary systems; structures

and component supports

Chemistry control for Consistent with Xl.M2 Reactor vessel, internals,. 3.0.3.2.3

secondary systems exception :.and reactor coolant system;

programs auxiliary systems; steam and

(B2.1.6) power conversion system

3-7
.1

'MPS'isAMP-: GA--~ `..N GALLn-3⁄44 ~;LRS~oms &StrcuiosW--aw

.(IRA7Section) S Comparison s * _AM P(s) '.2'-That 4 Credit the iMP ' SER Sction

Closed-cycle cooling Consistent with XI.M21 Reactor vessel, intemals, 3.0.3.2.4

water system exception and and reactor coolant system;

(82.1.7) enhancement engineered safety features;

auxiliary systems; steam and

power conversion system

Electrical cables not Consistent with XL.E2 Electrical components 3.0.3.2.6

subject to enhancement

10 CFR 50.49

environmental

qualification

requirements used in

instrumentation

circuits

(B2.1.9)

Fire protection Consistent with XL.M26 Auxiliary systems; structures 3.0.3.2.7

program exception and XL.M27 and component supports

(B2.1.10) enhancements

Flow-accelerated Consistent with XI.M17 Reactor vessel, intemals, 3.0.3.2.8

corrosion exception and reactor coolant system;

(B2.1.11) steam and power conversion

system

Fuel oil chemistry Consistent with XI.M30 Auxiliary systems 3.0.3.2.9

(82.1.12) exceptions

General condition Plant-specific NA Reactor vessel, intemals, 3.0.3.3.2

monitoring and reactor coolant system;

(82.1.13) engineered safety features;

auxiliary systems; steam and

power conversion system;

structures and component

supports

Inaccessible Consistent with XL.E3 Electrical components 3.0.3.2.10

medium-voltage exception and

cables not subject to enhancement

10 CFR 50.49

environmental

qualification

requirements

(12.1.14)

Inservice inspection Consistent with XI.S1 Structures and component 3.0.3.2.11

program: exceptions XL.S2 supports

containment XI.S4

inspections

(82.1.16)

Inservice inspection Consistent with XI.M12 Reactor vessel, internals, 3.0.3.2.12

program: reactor exceptions and XL.M13 and reactor coolant system

vessel internals enhancements XI.M16

(82.1.17)

3-8
. .

r -r J?

Sn o<(L . T C h; SER Section)-.--

Inservice inspection Consistent with XL.M1 Reactor vessel, internals, 3.0.3.2.13

program: systems, exceptions and Xl.M3 and reactor coolant system;

components and enhancements XL.M1I engineered safety features;

supports XL.M12 auxiliary systems; structures

(B2.1.18) Xl.S3 and component supports

Inspection activities: Consistent with XL.M23 Structures and component 3.0.3.2.14

load handling cranes enhancements . I supports

and devices

(B2.1.19)

Reactor vessel Consistent XL.M31 Reactor vessel, internals, 3.0.3.1.3

surveillance . and reactor coolant system

(82.1.20) -_._'

Service water system tConsistent with XL.M20' Auxiliary systems 3.0.3.2.15

(open-cycle cooling) exceptions

(B2.1.21)

Steam generator Consistent Xi.M19 , Reactor vessel, internals, 3.0.3.1.4

structural integrity and reactor coolant system ' (82.1.22) ._-;_:_'-_-_:

Structures'monitoring Consistent with XL.S5 ' Structures and component 3.0.3.2.16

program enhancements XL.S6 ' - supports

(B2.1.23) XI.S7 /'

Tank inspection Consistent with XI.M29 Engineered safety features; 3.0.3.2.17

program enhancements auxiliary systems; steam and

(B2.1.24) power conversion system l

Work control process P'lant-specific NA - Reactor vessel, internals, 3.0.3.3.4

(82.1.25) . and reactor coolant system;

engineered safety features;

auxiliary systems; steam and

power conversion system;

structures and component

.,_____ 5 _ supports ._,

Bolting integrity Consistent with XI.M18 - Reactor vessel, internals, .3.0.32.18

(82.1.26) exception and reactor coolant system;

engineered safety features;

auxiliary systems; steam and

. .~ power conversion system

New AMPs ; ; , E

Electrical cables and C6nsistent with XL.EI Electrical components 3.0.3.2.5

connectors not enhancement

subject to

10 CFR 50.49

environmental

qualification

requirements' m ! :

(B2.1.8) . , . .; ,.: . , 

Infrequently Plant-specific NA' Auxiliary systems'; stricthires 3.0.3.3.3

accessed areas "and component supports

inspection program

(82.1.15) _

3-9:
I .lI

3.0.3.1 AMPs that are Consistent with the GALL Report

In Appendix B of the LRA, the applicant indicated that the following AMPs were consistent with

the GALL Report:

* Boraflex monitoring (62.1.2)

* boric acid corrosion (B2.1.3)

* reactor vessel surveillance (B2.1.20)

* steam generator structural integrity (62.1.22)

3.0.3.1.1 Boraflex Monitoring

Summary of Technical Information in the Aoplication. The applicant's Boraflex monitoring

program is described in LRA Section B2.1.2, uBoraflex Monitoring." In the LRA, the applicant

stated that this is an existing program. This program is consistent with GALL AMP XI.M22,

"Boraflex Monitoring."

The applicant stated, in the LRA, that the Boraflex monitoring program manages the aging

effect of change of material properties on the sheets of neutron-absorbing materials affixed

inside spent fuel racks at Unit 2. For the Boraflex panels, gamma irradiation and long-term

exposure to the wet pool environment cause shrinkage, which results in gap formation, gradual

degradation of the polymer matrix, and the release of silica to the spent fuel storage pool water.

The resultant loss of boron carbide from the neutron-absorbing sheets reduces the neutron

absorption capabilities. The program ensures that periodic testing and monitoring is performed

to verify the condition of the neutron-absorbing panels in the spent fuel storage pool.

The applicant also stated, in the LRA, that Boraflex panels are installed in the Unit 3 spent fuel

racks but are not credited for neutron absorption and criticality prevention of the spent fuel pool.

For that reason, the Boraflex monitoring program at MPS Unit 3 is not included in this AMP.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs evaluation of this AMP are documented

in the MPS audit and review report. .The staff determined that this AMP is consistent with the

AMP described in the GALL Report, including the associated operating experience attribute.

Based on its review, the staff concludes that the applicant's Boraflex monitoring program

provides reasonable assurance of aging management of change of material properties on the

sheets of neutron-absorbing materials affixed inside spent fuel racks at Unit 2. The staff finds

this AMP acceptable because it conforms to the recommended program description, program

elements, and acceptance criteria for the Boraflex monitoring program, as discussed in GALL

AMP XL.M22, uBoraflex Monitoring."

Also, the applicant stated, in the MPS LRA, that Boraflex panels are installed in the MPS Unit 3

spent fuel racks but the panels are not credited for neutron absorption and criticality prevention

of the spent fuel pool. For that reason, the Boraflex monitoring program at MPS Unit 3 is not

included in this AMP. Since the applicant did not credit spent fuel racks with Boraflex panels for

neutron absorption and criticality prevention of the spent fuel pool for MPS Unit 3, the staff

agrees that the Boraflex monitoring program is not applicable to MPS Unit 3.

3-10
- - -

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. 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). The staff also reviewed the FSAR supplement for this AMP and finds that

it provides an adequate summary description of the program,-as required by 10 CFR 54.21(d).

3.0.3.1.2 Boric Acid Corrosion -

Summary of Technical Information In the Application. The applicant summarizes the boric acid

corrosion program in Section B2.1.3 of Appendix B to the LRA. In Section B2.1.3 of the LRA,

the applicant stated that the AMP is'used to manage loss of material in areas where carbon

steel, low-alloy steel, copper and cast iron 'structures and components may be susceptible to

the effects of borated reactor coolant leaks. The program ensures that boric acid corrosion is

consistently identified, documented, evaluated, and trended so that loss of material is effectively

repaired. The applicant stated that this AMP is developed to address industry-recommendations

reflected in Generic Letter (GL) 88-05 and the information from NRC Bulletins 2002-01 and

2002-02.

Staff Evaluation. The applicant stated that the borated water leakage assessment and

evaluation program has been developed to address industry recomrrieidations reflected in GL

88-05, and that the AMP is consistent with th'e program attributes in GALL AMP XI.M10, "Boric

Acid Corrosion." in addition, the recommendations of NRC Bulletins 2002-01 and 2002-02 have

been addressed in this program. It should be noted that Bulletins 2003-02 and 2004-01, and

NRC Order EA-03-009 provide additional documentation of industry experience related to

cracking in ASME Class I nickel-alloy partial-penetration welds, including those used to join the

upper RV head penetration nozzles to the upper RV heads and those used to join the bottom

mounted instrumentation (BMI) nozzles to the lower RV heads of PWRs. The staff requested

additional clarification regarding the scope of the boric acid program and the process the

applicant uses to augment the list of components "within the scope of the AMP based on

pertinent industry experience. Specifically, the staff requested the following actions of the

applicant in RAI B2.1.3-1: -.

Corrective actions have been effectively implemented to mitigate active leakage prior to

experiencing a loss of intended function. Discuss how program revisions have

incorporated lessons learned from the Davis-Besse vessel head degradation, the control

rod drive mechanism penetration cracking and the bottom mounted instrumentation

(BMI) nozzles to the lower RV heads discussed in NRC Bulletins 2002-01, 2002-02,

2003-02, and NRC Order EA-03-009 to prevent reoccurrence of degradation caused by

boric acid leakage, as required by Generic Letter 88-05. This discussion should include

the identification of component locations that have been added to the scope of the

program and clarify what type of visual examinations (i.e., specify whether VT-1, VT-2 or

VT-3, and whether the visual examinations are enhanced, bare-surface, qualified, etc.)

will be performed on the components.

In response to RAI B2.1.3-1, in a letter dated December 3, 2004, the applicant provided the

following representative list of applicable component locations and corresponding examination

methods, which have been incorporated into the boric acid corrosion control (BACC) program to

3-11
[II

address operating experience, lessons learned from Davis Besse, the identified NRC bulletins,

and the identified NRC order

Unit 2

* After Fort Calhoun reported leakage from a pressurizer heater or instrument penetration

in December 2001, Millstone added the bare metal visual examination of heater sleeves

and instrument nozzles on the pressurizer to the GL 88-05 inspection procedure starting

with the April 2002 refueling outage (2R14) for Millstone Unit 2. These examinations

found two leaking heater sleeves. Both were repaired with Mechanical Nozzle Seal

Assembly (MNSA) clamps.

* In the fall of 2002, bare metal examinations of the instrument nozzles on the reactor

coolant piping and steam generators for Millstone Unit 2 were added to the inspection

procedure.

* In February 2003, Dominion instituted a corporate level program to manage borated

water leakage for Millstone, North Anna, and Surry.

* In the fall outage of 2003 (2R15), Millstone Unit 2 performed bare metal visual

examinations of the pressurizer heater sleeves and all of the instrument nozzles and

repeated 100 percent ultrasonic testing (UT) of the reactor pressure vessel penetrations

in accordance with NRC Order EA-03-009. Two leaking heater sleeves and 11 cracked

reactor pressure vessel penetrations were identified. All of the heater sleeves and

reactor vessel head penetrations were repaired. No leakage was found on any of the

instrument nozzles.

* Prior to 3R09, the Boric Acid Corrosion Control (BACC) program procedure was revised

into four separate implementing procedures to address the overall program

requirements, on-line walkdowns, refueling outage walkdowns, and boric acid corrosion

evaluations.

* Prior to outage 2R1 6, Millstone Unit 2 will add bare metal visual examinations of Alloy

82/182 butt welds in the reactor coolant system to the BACC program.

* As identified in letter S/N 04-140 from Ms. Leslie N. Hartz, Dominion Nuclear

Connecticut, to U. S. Nuclear Regulatory Commission, dated June 3, 2004; Dominion

announced its intention to replace the pressurizer for Millstone Unit 2 using materials

that are resistant to PWSCC. Dominion intends to replace the Unit 2 pressurizer during

the Fall 2006 refueling outage.

Unit 3

* In the fall outage of 2002 (3R08), Millstone Unit 3 performed bare metal visual

examinations of the reactor vessel head penetrations under the insulation of the reactor

vessel head even though it was in the low susceptibility category according to NRC

Bulletin 2002-02. 3R08 was the first outage after NRC Bulletin 2002-02 was issued. The

results of this examination concluded that there was no evidence of material

degradation or RCS leakage.

* In February 2003, Dominion instituted a corporate level program to manage borated

water leakage for Millstone, North Anna, and Surry.

3-12
* After the Unit 2 fall outage of 2003 (2R15), bare metal visual examinations of Alloy

82/182 butt welds in the Millstone'Unit 3reactor coolant system (RCS) were added to

the inspection procedure. Bare metal'visual examinations of Alloy 600 Resistance

Temperature Detectors (RTDs) on Millstone Unit 3 were added to the program as a - result of operating experiences from North'Anna and Surry. Bare metal visual

examination of the bottom mounted instrumentation (BMI) nozzles on Millstone Unit 3

was added in accordance with NRC Bulletin 2003-2.

* Prior to 3R09, the'Boric Acid Corrosion Control (BACC) program procedure was revised

into four separate implementing procedures tobaddress the overall program

requirements, on-line walkdowns, refueling outage walkdowns, and boric acid corrosion

evaluations.

* -During outage 3R09, Millstone Unit 3 performed bare metal visual examinations for alloy 82/182 butt welds (except for RPV nozzles). This included the pressurizer and steam

generator pipe connections. Bare metal visual examinations were performed for the BMI

:-nozzles in accordance with NRC Bulletin 2003-02.

In issuing RAI B2.1.3-1, the staff inquired as to the process the applicant would use to augment

the list of components within the scope of the boric acid corrosion program as based on

pertinent industry experience. This was done, in part, to account for any industry experience on

borated water leakage events that could possibly impact the AMP prior to the time of the

pending issuance of the renewed operating licenses for the Millstone units. For example, NRC

Bulletin 2004-01, Inspection'of Alloy 82/182/600 Materials Used in the Fabrication of

Pressurizer Penetrations and Steam Space Piping Connections at Pressurized-Water Reactors

(May 28, 2004), provided industry experience that demonstrated that Alloy 600 base metal and

Alloy 82/182 weld components used in pressurizer penetration nozzles and steam space piping'

connections may be susceptible to PWSCC and reactor coolant leakage. Since the staff's - issuance of NRC Bulletin 2004-01, the applicant's response to RAI B2.1.3-1 confirms that the

applicant is updating the list of components within the scope of the applicant's boric acid

corrosion program based on pertinent industry experience on reactor coolant-leakage events

and that the applicant has included Alloy 600 base metal and Alloy 82/182 weld components as

being'within the scope of the boric acid corrosion program assessment and evaluation program.

This includes the Alloy 600 base metal and Alloy 82/182 weld metal components in the

pressurizer system specified in NRC Bulletin 2004-01.-I

The staff and the industry are currently pursuing resolution of the issues raised and discussed

in NRC Bulletin 2004-01 on PWSCC and reactor coolant leakage in pressurizer penetrations

and steam space piping connections. Because this is'an emerging issue that has yet to be

resolved, but will be resolved during the current operating terms for the Millstone units,

consideration of these issues is beyond the scope of this license renewal review, pursuant to

10 CFR 54.30(b). However, it should be noted that as identified in Dominion letter S/N 04-140

from Ms. Leslie N. Hartz, Dominion Nuclear Connecticut, to U. S. Nuclear Regulatory -- Commission, dated June 3, 2004, Dominion announced its intention to replace the pressurizer

for Millstone Unit 2 during the fall 2006 refueling outage using materials that are resistant to

PWSCC. The replacement of the pressurizer.would resolve the current issues concerning

PWSCC in the pressurizer penetrations for Millstone Unit 2. For other susceptible nickel-based

piping connections, in Millstone Unit 2, the applicant has a commitment to follow the industry

efforts investigating the aging effects applicable to nickel-based alloys (i.e., PWSCC in Alloy

600 base metal and Alloy 82/182 weld metals) and identifying the appropriate aging

management activities and will implement the appropriate recommendations resulting from this

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guidance. This commitment is identified in the Millstone Unit 2 LRA, Appendix A, Table A6.0-1

License Renewal Commitments, Item 14. Millstone Unit 3 does not have nickel-based

pressurizer penetrations. However, Millstone Unit 3 does have nickel-based alloy welds

attaching the safe ends to the pressurizer surge nozzle and the pressurizer relief, spray and

safety valve nozzles. To manage these welds, the applicant has a commitment to follow the

industry efforts investigating the aging effects applicable to susceptible nickel-based alloys (i.e.,

PWSCC in Alloy 600 base metal and Alloy 821182 weld metals) and identifying the appropriate

aging management activities and will implement the appropriate recommendations resulting

from this guidance. This commitment is identified in the Millstone Unit 3 LRA, Appendix A,

Table A6.0-1 License Renewal Commitments, Item 15.

Based on this assessment, the staff concludes that the program is applying pertinent generic

communications on borated reactor coolant leakage events as the basis for augmenting the

scope of the boric acid corrosion program and that the program has been updated to include

Alloy 600 base metal and Alloy 82/182 weld metal components in addition to implementing

industry efforts to manage aging of PWSCC in Alloy 600 base metal and Alloy 82/182 weld

metals.

Section B2.1.3 of the LRA also states that the program addresses the structures and - -

components composed of susceptible materials, which includes carbon and low-alloy steel,

copper, and cast iron. The program inspects the surfaces of structures and components from

which borated water may leak. The boric acid corrosion program includes systematic measures

to ensure that corrosion caused by leaking borated coolant does not lead to degradation of the

leakage source or adjacent structures or components. However, the applicant did not address

electrical components on which borated coolant may leak onto as recommended by GALL AMP

XI.M1O. This should be added to the LRA and FSAR supplement, and was addressed in RAI

B2.1.3-3a.

In response to RAI B2.1.3-3a in a letter dated December 3, 2004, the applicant stated that

design features such as those detailed in LRA Table 3.6.1, Item Number 3.6.1-05, provide

physical protection and prevent the corrosion of the connector contact surfaces caused by

intrusion of borated water. In addition, the boric acid corrosion program uses visual inspections

to detect the boric acid leakage source, path and any targets of boric acid leakage. The

applicant is also clarifying the scope of the program in the FSAR supplement by including the

following information in Section A2.1.3 of the Unit 2 FSAR supplement and Section A2.1.2 of

the Unit 3 FSAR supplement; "The program uses visual inspections to detect the boric acid

leakage source, path and any targets of the leakage." Therefore, the staff finds that the

program includes all potential targets, including electrical components, as recommended by

NUREG-1 801 to manage the degradation of these components.

In addition, some components and structures that are not adjacent to the leakage source may

still be targets of the borated coolant. Therefore, the staff asked the applicant in RAI B2.1.3-3b

that this AMP should reflect that targets include adjacent systems and components to the

leakage source and systems and components that may be leaked on, such as components that

are spatially under the leakage source, yet are not directly adjacent to the source.

In response to RAI B2.1.3-3b in a letter dated December 3, 2004, the applicant stated that the

boric acid corrosion program uses visual inspections to detect the boric acid leakage source,

path and any targets of the leakage. This program inspects the surfaces of structures and

components from which the borated water may have leaked, and confirms whether degradation

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has occurred for any potential targets of the identified leakage. In determining the path of boric

acid leakage, the applicable adjacent systems and components are identified, as well as

systems and components that are spatially located under the leakage and which may have

become targets of the leakage. The program is consistent with NUREG1 801, and the applicant

will clarify the scope of the program by including the following:

The boric acid corrosion program uses visual inspections to detect the boric acid'

leakage source, path and any targets of the leakage.

The staff finds the response to this RAI acceptable, since the boric acid corrosion program in

the LRA is consistent with GALL AMP XI.M1 0 0Boric Acid Corrosion," and the applicant clarified

the scope of the program to include any potential target of boric acid leakage.

FSAR SupDplement. The applicant provides the following FSAR supplement summary

description for the boric acid program'in Section A2.1.3 of Appendix A to the LRA:

- Boric Acid Corrosion corresponds to NUREG-1801, Section Xl.Ml0 'Boric Acid

Corrosion." The program manages the aging effect of loss of material and

ensures that systems, structures, and components susceptible to boric acid

corrosion are properly monitored.' It ensures that boric acid corrosion is

consistently identified, documented, evaluated, trended and effectively repaired.

The acceptance criterion is the absence of any boric acid leakage or -

precipitation. If boric acid leakage or precipitation is found by any personnel, it is

required to be reported using the Corrective Action Program. Corrective action

for conditions that are adverse to quality are performed in accordance with the

Corrective Action Program as part of the Quality Assurance Program. The

corrective action process provides reasonable assurance that deficiencies

adverse to quality are either promptly corrected or are evaluated to be

acceptable.

The applicant's FSAR supplement summary description for the boric acid program provides a

general reference to commitments made to GL'88-05 and NRC Bulletins. The staff requested

that the applicant amend the FSAR supplement summary description to provide more specific

references to the applicant's response (iLe., Dominion's response)'to GL 88-05, and to any'

additional responses to NRC generic communications"(i.e., Generic Letters, Bulletins, Orders,

or Circular Letters) that are germane to the scope for the AMP, including those responses to

NRC Bulletin 2002-01, 2002-02 and 2003-02 and to NRC Order EA-03-009, as appropriate.

The staff issued these requests in RAI B2.1.3-2.

In response to RAI B2.1.3-2, in abetter dated December 3, 2004, the applicant provided the

following information: -- X> 

Dominion's response to Generic Letter 88-05 and subsequent NRC communications on

boric acid corrosion and leakage detection; which'include NRC Bulletins 2001-01, 2002-

02 and 2003-02, and NRC Order EA-03-009 (as revised) are part of the current '-

licensing basis (CLB) for Millstone Units 2 and 3. In accordance with 10 CFR 54, the

CLB will carry forward into the period of extended operation. The specific responses to

these NRC generic communications for Millstone Units 2 and 3 are readily retrievable in

the NRC Public Document Room. Dominion'feels that providing these commitment

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details in the FSAR supplement summary would be inconsistent with the level of detail

normally presented in the FSAR supplement.

The staff issued RAI B2.1.3-2 to assure that the applicant's discussion in its FSAR supplement

summary description for the borated water leakage assessment and evaluation program was

consistent with relevant NRC generic communications and the CLB for the plants. The

applicant's response to RAI B2.1.3-3b indicates that the applicant will not amend the FSAR

supplement summary description for the borated water leakage assessment and evaluation

program to include a reference to the applicant's responses and commitments provided in the

applicant's responses to NRC Bulletins 2001-01, 2002-01, 2002-02, 2003-02, and the response

to NRC Order EA-03-009, as amended by applicant's response to the first revision of the Order.

The staff found this unacceptable because the summary description was not current with the

CLB for the facilities and did not reference Dominion's responses and commitments to NRC

generic communications that are relevant to the scope and implementation of the AMP. It

should be noted that as discussed above, the LRA only addressed Generic Letter (GL) 88-05,

and NRC Bulletins 2002-1 and 2002-2. NRC Bulletin 2003-02 and NRC Order EA-03-009 were

not included in the LRA. Therefore, the staff requested that the applicant amend the FSAR

supplement to ensure that the summary description is current with the CLB for the facilities and

references Dominion's responses and commitments to NRC generic communications that are

relevant to the scope and implementation of the AMP. This is consistent with other applicants

that have included its responses and commitments to NRC Bulletins 2001-01, 2002-01, 2002-

02, 2003-02, and the response to NRC Order EA-03-009.

In response to supplemental RAI B2.1.3-2 in a letter dated February 8, 2005, the applicant

stated that the FSAR supplement will be revised to identify of the applicable NRC generic

communications that the program implements, including NRC Bulletin 2003-02 and NRC Order

EA-03-009. The applicant response is acceptable since it will revise the FSAR supplement to

include the applicable NRC generic communications that are relevant to the scope of and

implementation of this AMP. This resolves RAI B2.1.3-2.

Conclusion. On the basis of its review, the staff finds that the program will adequately manage

the aging effects 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 FSAR supplement for this AMP and finds that it provides an adequate summary description

of the program, as required by 10 CFR 54.21(d).

3.0.3.1.3 Reactor Vessel Surveillance Program

The staffs regulatory bases for the establishment of the applicant's reactor vessel surveillance

programs (RVSPs) for Millstone, Units 2 and 3 are specified in Appendix H to Part 50 of Title

10, Code of Federal Regulations (10 CFR Part 50, Appendix H).

Summary of Technical Information in the Application. The applicant's RVSP is discussed in

LRA Section B2.1.20, "Reactor Vessel Surveillance." The applicant stated that the program is

consistent with and takes no exceptions to GALL AMP XL.M31, "Reactor Vessel Surveillance."

Staff Evaluation The staffs evaluation of the RVSP is based on its review of the program

description in LRA Section B2.1.20, as supported with pertinent information reported in the

staffs MPS audit and report. The staffs criteria for accepting the RVSP are based on both

conformance with aging management program (AMP) XI.M31, "Reactor Vessel Surveillance," in

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NUREG-1 801, and compliance with the applicable requirements of 10 CFR Part 50, Appendix

H. The staff also reviewed the FSAR supplement to determine whether it provides an adequate

description of the program. Furthermore, the staff reviewed the applicant's evaluation to

determine whether it addressed the additional issues recommended in NUREG-1 801 and

confirmed that the AMP would adequately address these issues. -

The applicant's AMP, Section B2.1.20 of Appendix B to the LRA, and the FSAR-supplement

provide a general description of the RVSP for;Millstone, Units 2 and 3 and state that it is

consistent with the guidelines of Section XL.M31, Reactor Vessel Surveillance," of NUREG1801: However, the staff notes that 10 CFR Part 50, Appendix H, requires licensees to submit

any proposed changes to their RVSP withdrawal schedules to the NRC for review and approval.

In addition, Items 5 through 7 in NUREG-1 801, Section XL.M31, "Reactor Vessel Surveillance,"

provide recommendations for the withdrawal schedule of the RVSP capsules during the period

of license renewal. The staff requested that the applicant identify how the Millstone, Units 2 and

3, capsule withdrawal schedule for the period of license renewal complies with Items 5 through

7 in NUREG-1801, AMP XI.M31. r -

The response for RAI B2.1.20-1 (1), provided in a letter dated December 3, 2004, is discussed

below for Items 5 through 7 of NUREG-1 801 and the requirements of 10 CFR Part 50,

Appendix H:- ;

Unit 2

Appendix H of 10 CFR Part 50 requires licensees to submit any proposed changes to

their RVSP withdrawal schedules to the NRC for review and approval. The applicant

stated that Dominion will revise the surveillance capsule withdrawal schedule from 40 to

60 years (54 EFPY) for Millstone Unit 2, consistent with NUREG-1 801, AMP Xl.M31,

item 5. To ensure that this reporting requirement will carry forward after the Millstone

operating license have been renewed, the staff is imposing the following condition in the

renewed license for Millstone, Unit 2:

All capsules in the reactor vessel that are removed and tested must meet

the test procedures and reporting requirements of ASTM E 185-82 to the

extent practicable for the configuration of the specimens in the capsule.

Any changes to the capsule withdrawal schedule, including spare

capsules, must be approved by the NRC prior to implementation. All

capsules placed in storage must be maintained for future insertion. Any

changes to storage requirements must be approved by the NRC, as

required by 10 CFR Part 50, Appendix H.

Item 5 in NUREG-1801, section XI.M31 provides guidelines for changes to the

withdrawal schedule for capsules with a projected fluence of less than 60-year fluence

at the end of 40 years. The applicant stated that Dominion is consistent with Item 5 of

NUREG-1801, section XI.M31; The applicant is consistent with this item because their

capsules will have a projected fluence of less than 60-year fluence at the end of

40 years. In addition the applicant will include withdrawal and testing of at least one of

the three remaining capsules during the period of extended operation. This methodology

is consistent with the recommendations of NUREG-1801, AMP XI.M31, Item 5 to

withdraw a capsule during the period of extended operation to monitor the effects of

long-term exposure to neutron irradiation, and therefore the staff finds this acceptable

3-17 Z
Item 6 of NUREG-1801, AMP XL.M31 provides guidelines for changes to the withdrawal

schedule for capsules with a projected fluence exceeding the 60-year fluence at the end

of 40 years. This item also recommends the applicant to withdraw one capsule at an:

outage in which the capsule receives a neutron fluence equivalent to the 60-year fluence

and test the capsule in accordance with the requirements of ASTM E 185. The staff

notes that this item does not apply to Millstone Unit 2 since it will not have surveillance

capsules with a projected fluence exceeding the 60-year fluence at the end of 40 years.

Item 7 of NUREG-1801, AMP XL.M31 provides a recommendation for applicants without

in-vessel capsules to use alternative dosimetry to monitor neutron fluence during the

period of extended operation. The applicant has three standby capsules, of which at

least one will be removed during the period of extended'operation. This will provide up

to two capsules to monitor neutron fluence during the period of extended operation. In

addition, the applicant has stated if the last Millstone Unit 2 capsule is removed prior to

year 55, Dominion will provide additional dosimetry for the reactor pressure vessel. This

is consistent with the recommendations of NUREG-1 801 AMP XL.M31, Item 7, and the

staff finds this acceptable.

For reactor vessels with high lead factors, the standby capsules are recommended by NUREG1801, AMP XL.M31 to be removed and placed in storage. Therefore, the staff requested the

applicant in RAI B2.1.20-1(2) to provide the lead factors for Millstone Unit 2. In addition, the

applicant was requested to discuss how capsules with high lead factors are stored to ensure

that they are not disposed.

In response to RAI B2.1.20-1(2), in a letter dated December 3, 2004, the applicant stated that

the lead factor for the remaining Millstone Unit 2 surveillance capsules is approximately 1 (0.97

to 1.31). Therefore, the applicant will withdraw one or more of these capsules in the extended

period of operation. The staff finds this response acceptable since the applicant has

provided the requested information. This resolves RAI B2.1.20-1(2) for Millstone Unit 2. Since

there can be up to two standby capsules in the Unit 2 reactor vessel, these capsules have the

potential to be removed for storage. However, the staff notes that currently, there is no detailed

guidance regarding the treatment of standby capsules. Therefore, the staff has imposed the

following license condition to ensure that any surveillance capsules removed'from the Millstone

unit, without the intent to test them, are maintained in a condition which would permit their

future use, including the period of extended operation, if necessary:

All capsules in the reactor vessel that are removed and tested must meet the

test procedures and reporting requirements of ASTM E 185-82 to the extent

practicable for the configuration of the specimens in the capsule. Any changes to

the capsule withdrawal schedule, including spare capsules, must be approved by'

the NRC prior to implementation. All capsules placed in storage must be

maintained for future insertion. Any changes to storage requirements must be

approved by the NRC, as required by 10 CFR Part 50, Appendix H.

The imposition of this license condition is consistent with actions that the staff has taken with

other, recent license renewal applicants with respect to the control of standby" RPV

surveillance capsules and reporting requirements.

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Unit 3

10 CFR Part 50, Appendix H requires licensees to submit any proposed changes to their

RVSP withdrawal schedules to the NRC for review and approval. The applicant stated

that Dominion will revise the surveillance capsule withdrawal schedule from 40 to

60 years (54 EFPY) for Millstone Unit 3, consistent with NUREG-1801, AMP XL.M31,

item 6. To ensure that this reporting requirement will carry forward after the Millstone

operating license have been renewed, the staff is imposing the following condition in the

renewed license for Millstone, Unit 3: ,

All capsules in the reactor vessel that are removed and tested must meet

the test procedures and reporting requirements of ASTM E 185-82 to the

extent practicable for the configuration of the specimens in the capsule.

Any changes to the capsule withdrawal schedule, including spare

capsules, must be approved by the NRC prior to implementation. All

capsules placed in storage must be maintained for future insertion. Any

changes to storage requirements must be approved by the NRC, as

required by 10 CFR Part 50, Appendix H.

* Item 5 in NUREG-1801, section XL.M31 provides guidelines for changes to the

withdrawal schedule for capsules with a projected fluence of less than 60 year fluence at

the end of 40 years. The applicant stated that the Millstone Unit 3 surveillance program

consists of capsules with a projected fluence of less than 60 year fluence at the end of

40 years. The staff notes that this item does not apply to Millstone Unit 3 since it will not

have surveillance capsules with a projected fluence of less than 60 year fluence at the

end of 40 years.

* Item 6 of NUREG-1 801, AMP XL.M31 provides guidelines for changes to the withdrawal

schedule for capsules with a projected fluence exceeding the 60 year fluence at the end

of 40 years. This item also recommends the applicant to withdraw one capsule at an

outage in which the capsule receives a neutron fluence equivalent to the 60-year fluence

and test the capsule in accordance with the requirements of ASTM E 185. The applicant

stated that the Millstone Unit 3 surveillance program consists of capsules with a

projected fluence exceeding the 60 year fluence at the end of 40 years. The applicant

also stated that Millstone Unit 3 will withdraw capsule W when it receives a neutron

fluence equivalent to 60 year fluence (approximately 54EFPY). This capsule will be

tested in accordance with the requirements of ASTM E 185. The staff finds this

response acceptable since it is consistent with the recommendations of NUREG-1 801

AMP XL.M31, Item 6. ;,

* Item 7 of NUREG-1 801, AMP XL.M31 provides a recommendation for applicants without

in-vessel capsules to use altemative dosimetry to monitor neutron fluence during the

period of extended operation. The applicant stated that there are three standby capsules

in Millstone .. -

Unit 3 that will be removed prior to these capsules receiving neutron fluence equivalent to

60 year fluence. One of these may be selected to remain in place for the purpose of flux

monitoring, but will be over-irradiated in terms of meaningful metallurgical information. If the last

capsule is withdrawn prior to year 55, Dominion will provide additional dosimetry for the reactor

pressure vessel. The staff finds this response acceptable since a standby capsule or additional

3-19.
dosimetry will be available to monitor neutron fluence during the period of extended operation

consistent with the guidelines of NUREG-1 801 AMP Xl.M31, Item 7. For reactor vessels with

high lead factors, the standby capsules are recommended by NUREG-1 801, AMP XL.M31 to be

removed and placed in storage. Therefore, the staff requested the applicant in RAI B2.1.20-1(2)

to provide the lead factors for Millstone Unit 3. In addition, the applicant was requested to

discuss how capsules with high lead factors are stored to ensure that they are not disposed.

The applicant stated that for Millstone Unit 3, the lead factors for the remaining standby

surveillance capsules are approximately 4 (4.11 to 4.32). Therefore, in accordance with the

recommendations of NUREG-1 801 AMP XL.M31, Item 6, these standby capsules would be

removed since further exposure would not provide meaningful metallurgical data. These

removed standby capsules will be placed in storage for potential reuse should supplemental

information be needed. The applicant also stated that storage of irradiated components in the

spent fuel pool is administratively controlled by unit specific procedures. However, the staff

notes that currently, there are no detailed guidance regarding the treatment'of standby

capsules. Therefore, the staff has imposed the following license condition to ensure that any

surveillance capsules removed from the Millstone unit, without the intent to test them, are

maintained in a condition which would permit their future use, including the period of extended

operation, if necessary:

All capsules in the reactor vessel that are removed and tested must meet the

test procedures and reporting requirements of ASTM E 185-82 to the extent

practicable for the configuration of the specimens in the capsule. Any changes to

the capsule withdrawal schedule, including spare capsules, must be approved by

the NRC prior to implementation. All capsules placed in storage must be

maintained for future insertion. Any changes to storage requirements must be

approved by the NRC, as required by 10 CFR Part 50, Appendix H.

The imposition of this license condition is consistent with actions that the staff has taken with

other, recent license renewal applicants with respect to the control of "standby" RPV

surveillance capsules and reporting requirements.

FSAR Supplement. The applicant's.FSAR supplement summary description for the RVSP is

given in Section A2.1.20 and A2.1.19, of Appendix A to the Millstone Units 2 and 3 LRAs,

respectively.

This summary description provides an acceptable general description of the RVSPs for

Millstone Units 2 and 3. The staff finds that the FSAR supplement for this AMP is acceptable

and provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its inspection of the applicant's program and its review of the

information provided by the applicant to address the NUREG-1 801 recommendation, the staff

finds that the program is consistent with NUREG-1 801 and adequately addresses the additional

issues as recommended by NUREG-1 801.

3.0.3.1.4 Steam Generator Structural Integrity Program

The applicant describes its steam generator structural integrity program (SGSIP) for Units 2

and 3 in LRA Appendix B, Section B2.1.22. The staff reviewed LRA Appendix B, Section

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B2.1.22 to determine if the applicant has demonstrated that the program will adequately

manage the applicable aging effects in the steam generators (SGs) during the period of

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

Summary of Technical Information in the ADplication. The applicant stated that the SGSIP is

consistentwith the 10 attributes of the program described in GALL AMPXI.M19, I "Steam 

Generator Tube Integrity Program," with no exceptions. In addition, the program scope includes

the Units 2 and 3 steam generator tubesheet and cladding. The applicant stated that its

program is based on Nuclear Energy Institute (NEI) 97-06 (Steamr Generator Program

Guidelines) and the associated Electric Power Researchilnstitute (EPRI) guidelines, which

provide performance acceptance criteria and guidance for monitoring and maintaining SG

tubes. The applicant's program includes performance acceptance criteria for structural integrity,

accident-induced and operational leakage, as well as SG integrity and support elements. The

program also includes preventive measures to mitigate degradation through control of primary

side and secondary side water chemistry; assessment of degradation mechanisms;' leakage

monitoring; in-service inspection of the SG; and evaluation and plugging, as needed, to ensure

the leakage integrity of the pressure boundary. The applicant stated that the tube inspection

scope and frequency, tube plugging or-repair,'and leakage monitoring are in accordance'with

the Millstone Units 2 and 3 Technical Specifications.

The applicant stated that it currently participates in industry programs whose goals include the

investigation of aging effects applicable to nickel-based alloys (i.e., primary water stress

corrosion cracking in Alloy 600 base metal and Alloy 82/182 weld metals) and identification of

appropriate aging management activities. The applicant commits to implementing the

appropriate recommendations that result from this investigation. This commitment is identified

in Appendix A, Table A6.0-1 of License Renewal Commitments, Item 14.

The applicant concludes that the SGSIP ensures that the effects of aging associated with the

in-scope components will be adequately managed so that there is reasonable assurance that

their intended functions will be maintained consistent with the current licensing basis (CLB)

throughout the period of extended operation. -

Staff Evaluation. The staff reviewed the information included in LRA Appendix B, Section

B2.1.22 and the applicant's response to the staffs RAI, dated August 11, 2004, to ensure that

the aging effects will be adequately managed so that the intended functions of the SG tubes will

be maintained consistent with the CLB throughout the period of extended operation.

The 10 program attributes in the GALL SG Section XI.M19 provide detailed programmatic

characteristics and criteria that the staff considers necessary to manage aging effects of the SG

tubes and tube plugs. The GALL SG AMP recommends preventive measures to mitigate

degradation phenomena; assessment of degradation mechanisms; in-service inspection of SG

tubes to detect degradation; evaluation and plugging or repair, as needed, of the SG tubes; and

leakage monitoring to ensure the leakage integrity of the pressure boundary. Although the

applicant did not describe the program attributes in LRA Section B2.1.22, the -applicant has

stated that the program attributes are consistent with those stipulated in GALL SG AMP,

Section Xl.M19, without exceptions nor enhancements. -

r * ' '',' - ,

In addition, the applicant identifies the SGSIP as the AMP to manage the aging effect loss of

material in the tubesheet and cladding. Currently,'the GALL SG AMP does not address the SG

tubesheet and its cladding; therefore, the staff asked the applicant to explain how SGSIP

3;21,
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manages aging in those areas. Based on operating experience, cladding has not shown

significant degradation. In addition, during routine SG tube inspections, the applicant would

inspect the cladding and the tube-end welds as part of the SGSIP. If degradation is identified,

the applicant would take appropriate measures to correct the problem. In its response to RAI

B2.1.22-2, the applicant stated that although the scope of the GALL SG AMP only addresses

the SG tubes, the SGSIP for Millstone Units 2 and 3 additionally addresses the secondary side

of the steam generator tubesheet. The staff asked the applicant to discuss how the SGSIP

manages the aging effects through the effective incorporation of the following program

elements: Preventive Actions, Parameters Monitored/Inspected; Detection of Aging Effects,

Monitor and Trending, and Acceptance Criteria. The five elements to manage the aging effects

associated with the tubesheet are discussed below.

(1) Preventive Actions: The program includes preventive measures to mitigate degradation

through control of primary side and secondary side water chemistry consistent with

NEI 97-06 and GALL Section XI.M19. The applicant's SGSIP relies upon secondary

systems chemistry control to prevent or mitigate initiation of degradation mechanisms or

reduce rates of degradation in the tubesheet. The applicant identified loss of material as

the aging effect for the tubesheet. The staff finds that the chemistry control for

secondary systems acceptable because it will be effective in preventing or mitigating the

secondary side tubesheet degradation.

(2) Parameters Monitored/Inspected: The applicant stated that the SGSIP identified loss of

material as the aging effect for the uncladded secondary side of the tubesheet. The

applicant will perform an assessment prior to the inspection to predict the expected

amount of degradation. The applicant also stated that in addition to tubesheet

secondary side inspection, it performs primary side inspections of the tubesheet.

Secondary side visual inspections of the tubesheet are performed in accordance with

the applicable guidance in NEI 97-06. The applicant's inspection procedures include

remote and direct visual examination of the tubesheet's accessible areas for evidence of

degradation. The applicant considers factors such as potential degradation

mechanisms, industry operating experience and SG design when determining the

appropriate inspection requirements. The staff finds that the inspection parameters

monitored or inspected are acceptable because the inspection requirements provide

reasonable assurance that the SGSIP will monitor the parameters necessary to prevent

and mitigate degradation of the secondary side of the tubesheet.

(3) Detection of Aging Effects: The applicant stated that the SGSIP manages the aging

effects for the tubesheet prior to the loss of intended function. Visual inspections of the

secondary side of the tubesheets are performed in accordance with the guidance

identified in NEI 97-06. Typically, the tubesheet in Millstone Unit 2 SGs is inspected

every other refueling outage while the tubesheet in the Unit 3 SGs is inspected every

outage. The applicant performs a degradation assessment before inspection in which it

predicts the expected amount of degradation. Inspection frequencies are based on the

results of the degradation assessments and the comparison of such assessments to the

as-found inspection results. The applicant may perform visual inspections should the'

eddy current testing of the tubes indicate the presence of a foreign object. Loose parts

or foreign objects are removed from the steam generators unless it can be shown that

these objects would not represent any challenge to tube integrity. The staff finds that

these are acceptable methods for identifying tubesheet degradation.

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-

(4) Monitoring and Trending: Degradation is managed within the corrective action process

to ensure that timely corrective and mitigative actions are performed as necessary. The

applicant monitors and trends the tubesheet degradation found through inspections to

assure that the intended function is maintained. The staff finds that the applicant's

monitoring and trending activities follow GALL-AMP Section XI.M1 9, and therefore, are

acceptable.

(5) Acceptance Criteria: The applicant stated that the acceptance criteria for tubesheet

secondary side inspections is based on the corrective action process and engineering analysis. Whenever degradation is identified, it is entered into the corrective actions:.

program where an evaluation is performed. Deficiencies that may present a challenge for the component to complete its intended function are promptly corrected or evaluated

to be acceptable. If an evaluation is performed without repair or replacement, an

engineering analysis is executed to reassure that the'intended function is maintained.

The staff finds the acceptance criteria acceptable because they follow the GALL AMP

Section Xl.M19.

Operating Experience. In the fall of 1992, Millstone Unit 2 steam generators were replaced with

Babcock and Wilcox steam generators. The pre-service inspection consisted of a 100 percent eddy current examination and it covered the full length of each tube from the hot leg plenum. The applicant did not identify any measurable flaws. During the February 2002 outage, the

applicant performed a 100 percent full length bobbin examination of No. 1 SG. The applicant expanded the scope of examination to include locations of special interest tested with a rotating probe. The examinations were performed in the hot and cold leg areas, dings and dents. A

visual inspection of the cold leg tubesheet surface of the secondary side revealed a foreign object lodged diagonally between pairs of tubes. The applicant was not successful in retrieving the object. No tubes were plugged in association with this object since'no evidence of

degradation was observed. The applicant will examine the tubes to verify that there has not

been any change to these two tubes in the conditions evaluated.

The Millstone Unit 3 original SGs began commercial operation in the spring of 1986. During the

September 2002 outage, the applicant performed a bobbin inspection on approximately ;;

50 percent of the tubes in SGs A and C. The applicant expanded the scope'of examination to

include tPointff coil inspections on special interest areas such as the hot leg expansion transitions, low row U-bends, dents and locations where the bobbin response was ambiguous. The inspection results showed seven tubes exhibiting anti-vibration bar wear, two tubes with . loose part wear, one tube with an obstruction not allowing the insertion of a probe, and one tube

with an single volumetric indication (SVI) and in contact with an adjacent lodged loose part. All

of these tubes were preventively plugged. The tube with the lodged loose part had incurred

minor damage and was stabilized and plugged. In addition, the applicant performed a 20

percent inspection expansion at top-of-tubesheet locations in both the hot and cold legs of SG -

A to address the inspection results related to loose part wear. The staff reviewed the annual

inspection report and found the SG inspection results consistent with industry experience with

similar models of SGs.

During the August 2004, outage, the applicant performed a bobbin inspection on approximately

50 percent of the tubes in SGs B and D in Unit 3. The applicant expanded the scope of the

examination to include +Pointf coil inspection 'on special interest areas' such as the hot leg expansion transitions, low row U-bends; dents and locations where the bobbin response was

ambiguous. The inspection results showed two tubes with loose part wear, one tube with anti3-23
I W

vibration wear, one tube with a SVI exceeding the plugging limit and a cluster of five tubes

identified with SVI signals. Of the cluster of five tubes, three were potentially caused by a loose

part. Since the area is not accessible for visual inspection, all of the tubes were plugged and

removed from service. One tube in the U-bend region was identified with an SVI. The applicant

determined that this indication seems to be a manufacture defect, similar to the tubes plugged

prior to startup. This indication was small and not detectable with the bobbin probe. This tube

was plugged and removed from service.

No degradation of either the primary side or secondary side of the tubesheets has been

identified for Millstone Units 2 and 3. The staff found these SG inspection results consistent

with industry experience with similar models of SGs.

FSAR Supplement. The FSAR supplement for the SGSIP is discussed in LRA Appendix A,

Sections A2.1.22 and A2.1.21 in the Millstone Unit 2 and Unit 3 LRAs, respectively. The staff

verified that the information in the FSAR supplement provides an adequate summary of the

program activities, and is consistent with Table 3.1-2 of NUREG-1 800. The staff concludes that

the information provided in the FSAR supplement for aging management of the steam

generators is acceptable because it provides an adequate summary of the program activities,

as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review of the applicant's SGSIP and the consistency of this AMP

to GALL AMP Section X1 .MI 9,- the staff concludes that the applicant has demonstrated that the

effects of aging associated with the SGs will be adequately managed by the SGSIP so that the

intended functions of the SGs will be maintained consistent with the current licensing basis for

the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed

the FSAR supplement for this AMP and finds that it provides an adequate description of the

program, as required by 10 CFR 54.21(d).

3.0.3.1.5 Summary of Conclusions for AMPs That Are Consistent With the GALL Report

On the basis of its review and audit of the applicant's program, the staff finds that those

program elements for which the applicant claimed consistency with the GALL program are

consistent with the GALL program. 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 current licensing basis (CLB) for the period of extended

operation, as required by 10 CFR 54.21 (a)(3). The staff reviewed the associated FSAR

supplements for these AMPs and concludes that the FSAR supplements provide an adequate

summary description of the programs, as required by 10 CFR 54.21 (d).

3.0.3.2 AMPs that are Consistent with the GALL Report with Exceptions or

Enhancements

In Appendix B of the LRA, the applicant indicated that the following AMPs were or will be

consistent with the GALL Report with exceptions or enhancements:

* buried pipe inspection program (B2.1.4)

* chemistry control for primary systems program (B2.1.5)

* chemistry control for secondary systems programs (B2.1.6)

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* closed-cycle cooling water system (B2.1.7)

* electrical cables and connectors not subject to 10 CFR 50.49 environmental qualification

requirements (B2.1.8)

* -electrical cables not subject to 10 CFR 50.49 environmental qualification requirements

used in instrumentation circuits (B2.1.9):

* fire protection program (B2.1.10).

* flow-accelerated corrosion (B2.1.1 1)

* fuel oil chemistry (82.1.12)

* inaccessible medium-voltage cables not subject to 10 CFR 50.49 environmental

qualification requirements (B2.1.14)-','

* inservice inspection program: containment inspections (B2.1.16)

* inservice inspection program: reactor vessel intemals (B2.1.17)

* inservice inspection program: systems, components and supports (B2.1.18)

* inspection activities: load handling cranes and devices (82.1.19)

* service water system (open-cycle cooling) (82.1.21)

* structures monitoring program (B2.1 ;23)

* tank inspection program (82.1.24) ' '

* bolting integrity program (82.1.26)

For AMPs that the applicant claimed are consistent with the GALL Report with exceptions or

enhancements, the staffperfomied 'an audit to confirm that those attributes or features of the

program for which the applicant claimed consistency with the GALL Report wee' indeed

consistent. The staff 'also reviewed the exception's and enhancements to the GALL Report to'

determine whether they were acceptable and adequate. The results of the staffs audit and

reviews are documented in the following sections.

3.0.3.2.1 Buried Pipe Inspecti-onProgramr '.

Summary of Technical Information in the Ap~licatio'n. The applicant's buried pipe inspection

program is described in LRA Section B2.1.4, "Buried Flipe Inspection Program." In the LRA, the

applicant stated that this is an existing' program. This program is consistent, with exceptions

and enhancements, with GALL AMPs Xl.M28, Burdied Pipirig and Tanks Surveillance," and

XI.M34, uBuried Piping and Tanks lnspection.n

The applicant stated in the LRA that the buried pipe inspection progra'm manages the aging

effect of loss of material through'the'use of preventive 'measures'(i.e.,'c 6ating, wrapping, and

cathodic protection) and inspections. Though preventive measures were applied to the'extermal

surfaces of the buried piping, no credit was taken for these measures in the determination of

the aging effects for,'the u'nderlying materials:.Th'e program evaluates the condition of the

coatings'and/or wraps as an indication 'of the '6ndition of the underlying-matenals.

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sing

The applicant also stated in the LRA that the use of impressed-current cathodic protection for

in-scope piping is limited to the Unit 2 off-gas pipeway and the Unit 3 supplementary leak

collection-and-release system piping.

In addition, the applicant stated that a baseline inspection of the in-scope buried components,

located in a damp soil environment, will be performed for a representative sample of each of

the following combinations of material and protective measures: Unit 2 - carbon steel/coated,

Unit 2 - carbon steel/wrapped, Unit 2 - cast iron/wrapped, Unit 3 - stainless steel/coated,

Unit 3 - carbon steel/wrapped, Unit 3 - cast iron/wrapped, and Unit 3 - copper alloy/uncoated.

The program requires that the inspections be completed using available industry guidance such

as the National Association of Corrosion Engineers' (NACE) Standard RP-0169, "Control of

External Corrosion on Underground or Submerged Metallic Piping Systems," dated 1996.

Furthermore, the applicant stated that inspections will also be performed when the buried

components are excavated for maintenance or for any other reason which will provide an

effective method to evaluate the condition of the buried piping and protective coatings on a

continuing basis.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details'of the staffs evaluation of this AMP are documented

in its MPS audit and review report. Furthermore, the staff reviewed the exceptions and

enhancements and their justifications to determine whether the AMP, with the exceptions and

enhancements, remains adequate to manage the aging effects for which it is credited.

In Appendix B, Section B2.1.4 of the LRA, the applicant stated that the buried pipe inspection

program is consistent with GALL AMPs XL.M28 and XL.M34, with exceptions and

enhancements. The buried pipe inspection program takes exception to the "scope of program"

program element in that the NACE Standard RP-0169-96, uControl of External Corrosion on

Underground or Submerged Metallic Piping Systems," dated 1996,' may not have' been utilized

during initial installation of the piping in establishing the preventive measures, as recommended

in the GALL Report.

The staff understands that NACE Standard RP-01 69-96 may not have been utilized during

installation of the in-scope buried piping. As an enhancement to the program scope, the

applicant will perform baseline inspections of the in-scope buried, piping located in a damp soil

environment to develop a representative sample of each combination of material and protective

measures identified in the program description. The irnspections will include piping or valves and

will provide an effective method for evaluating the condition of the buried components and

protective coatings. The inspections will use available industry guidance such as NACE

Standard RP-0169-96. With these inspections, the applicant's program for buried piping and

valves will meet the intent of the GALL AMP XI.M28 with regard to establishing that the

protective' measures put in'place during construction are effective. Therefore the staff finds this

exception to be acceptable.

The buried pipe inspection program also takes exception to the monitoring and trending"

program element in that coating conductance and current requirement for cathodic protection

are not trended versus time, as recommended in the GALL Report. Performance parameters of

the impressed current cathodic protection systems are checked either monthly or quarterly and

compared to predetermined values to verify proper operation.

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The staff finds that the difference between'trending of cathodic protection versus time and the

checking of impressed cathodic protection system current either monthly or quarterly and

comparing these values with predetermined values for proper operation is insignificant since

aging effects are typically manifested over several years. The staff reviewed the operating

experience associated with the buried pipe inspection-program and identified no specific

instances where degradation had occurred for the buried piping with cathodic protection. Since

the verification of performance parameters for the impressed current cathodic protection system

ensures proper operation, the intent of the GALL program element is satisfied. The staff

concludes that the monthly or quarterly periodicity of checking the cathodic protection system

against predetermined values adequately manages the aging effects of buried pipe

components during the period of extended operation. The staff finds this exception to be

acceptable.

The applicant stated in the LRA that it will enhance the buried pipe inspection program scope of

program and detection of aging effects program elements such that a baseline inspection will

be performed on a representative sample of different piping materials with different protective

measures for the buried piping located in a damp soil environment. The inspections will include

a short length of piping and any associated valves for each combination of material and burial

condition.

The applicant stated in the LRA that these inspections, using available industry guidance such

as NACE Standard RP-0169-96, will provide an effective method to evaluate the condition of

the buried piping and protective coatings. With these inspections, the program for buried piping

and valves will be consistent with the programs described in GALL AMP XL.M28, "Buried Piping

and Tanks Surveillance," with regard to establishing that the protective measures put in place

during construction are effective. Components protected by cathodic protection will not be

inspected. The staff finds that although the applicant stated that it will perform baseline -

inspections for in-scope buried piping, it does not specify the type of inspection. The applicant

was asked to justify the type of inspection (only visual), or provide other means of detection

such as Brinnell hardness, destructive testing, or other mechanical means'such as scraping,

chipping, etc. By letter dated July 7, 2004, the applicant modified its commitment such that

inspection will be performed by visual, and mechanical or other appropriate methods. These

inspections will be initiated prior to the period of extended operation. This commitment is

identified on the applicant's license renewal commitment list in the MPS LRA, Appendix A,

Table A6.0-1, as Item 3, and in the July 7,-2004, LRA supplement. On the basis that these

inspections will cause the applicant's program to be consistent with GALL AMP XL.M28, the

staff finds this enhancement to be acceptable. -

The applicant also stated that it will enhance the "scope of program" and "detection of aging

effects" program elements for the buried pipe inspection program such that the maintenance

and work control procedures will be revised .to ensure that inspections of buried components'

are performed when the piping is excavated during maintenance or for any other reason. These

inspections will ensure on a continuing basis that the condition of the buried and protective

coating and wrapping remains intact so they will be able to perform their intended function.

The staff identified the following difference regarding the detection of aging effects program

element:-.-;.-;

The applicant stated in the discussion of MPS.LRA Table 3.3.1, Item 29 that

components (aluminum bronze, brass, cast iron, cast steel) in open-cycle and

3-27-;.
closed-cycle cooling water systems, and the ultimate heat sink; are subject to

loss of material due to selective leaching. Management of this aging effect is

assigned to the work control process and buried pipe inspection program.

GALL AMP XI.M.33, 'Selective Leaching of Materials," recommends a combination of one-time

inspection and hardness measurement. Since selective leaching is a slow acting corrosion

process, it is recommended that this be performed as late in the plant life as possible,

preferably after 30 years of service.

Selective leaching generally does not cause changes in dimension and is difficult to detect by

visual inspection. Hence, a Brinnell hardness test on the inside surfaces of a selected set of

components is recommended to determine if selective leaching has occurred. Alternatively, if a

component is removed from service for whatever reason, a destructive test could be performed.

As documented in the staffs MPS audit and review report for the in the buried piping inspection

program, the applicant will revise its maintenance and work control procedures to ensure that

inspections of buried components are performed when the piping is excavated during

maintenance or for any other reason. The applicant stated, in the LRA, that these inspections

will ensure on a continuing basis that the condition of the buried and protective coating and

wrapping remain intact so they will be able to perform their intended function. With these

inspections, the applicant's program for buried piping will be consistent with GALL AMP XL.M34,

"Buried Piping and Tanks Inspection." This commitment is identified on the applicant's license

renewal commitment list in the MPS LRA, Appendix A, Table A6.0-1, as Item 4, and the July 7,

2004, LRA supplement. On the basis that these inspections will cause the applicant's program

to be consistent with the GALL AMP Xi.M34, the staff finds this enhancement to be acceptable.

Operating Experience. The staff reviewed operating experience for the applicant's buried pipe

inspection program. The review indicated the buried pipe inspection program is effective in

identifying age-related degradation, implementing repairs, and maintaining the integrity of

buried pipe. The following examples, based on review of condition reports generated under the

corrective action program, are representative of internal operating experience at MPS and were

considered for evaluating the effectiveness of the program.

During performance of cathodic protection system maintenance on rectifiers, the applicant

noted that one of its anodes had a low reading. As a result, a work order was developed to

perform excavation as required to facilitate the replacement of the anode' Contingency plans'

were made to replace additional anodes in system if it was discovered that the affected node

had been sacrificed. Subsequently, cathodic protection vendor representatives visited the site

and performed a walkdown of the off-gas cathodic protection system. Further evaluations and

discussions with the applicant's technical personnel included review of photographs of the

anodes that were recently replaced and a briefing on the recent history of the system. ;

Agreement was reached that a wholesale replacement of all the anodes in the system was not

warranted based on the condition of the affected anode.

The applicant stated in the LRA that corrosion mechanisms seen in the firewater piping are

similar to those seen in the domestic water (city water) piping. These mechanisms are well

known and do not require sampling to determine their cause or extent. Additionally, the fire

water system is flow-tested every three years, and no significant degradation in overall loop flow

has been noted. Further, due to the recent decommissioning of Unit 1, several parts of the

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site's firewater above ground piping have been removed and made available for detailed

inspection.

All of the Unit 1 piping segments had been in place and filled with water for approximately'

30 years. No significant corrosion was identified in the'above ground piping. While one piece of

unlined 6-inch carbon steel pipe had about %-inch of corrosion buildup, this buildup was

evaluated and determined to not restrict flow nor challenge the system's pressure boundary.

The rest of the aboveground piping segments irspected were clean. Since the fire pumps are

run frequently, the piping associated with the pumps'-suction' lines and tank recirculation lines

was considered subject to corrosion buildup.-During'the fire tank replacement project,

segments of the firewater suction piping and tank recirculation piping were'disassembled and

inspected. When disassembled, these lines were observed to have a significant corrosion

buildup, but this corrosion buildup did not affect pump performance, which was measured using

lines that frequently experienced flow. Much of this corroded piping,- and the tanks themselves,

were replaced as part of the fire tank replacement project.

On the basis of its review of the above operating-experience, the staff concludes that the buried

pipe inspection program adequately manages the aging effects that have been'observed'at the

applicant's plant. . - -

FSAR SuDplement. In Appendix A, Section A2.1.4 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.3 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

buried pipe inspection program, as supplement by the July 7, 2004, letter. The staff reviewed

these sections and determined that the information in the FSAR supplement provides an'

adequate summary of the program activities.: The staff finds these section's bf the FSAR

supplement and the July 7, 2004, letter suffici6et,'as required by 10 CFR 54.21 (d). '. '. , .1 .:. '' .. '' i ' ' '

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the' staff has reviewed the exceptions and

the associated justifications and determined that the AMP, with the exceptions is adequate to

manage the aging effects for which it is credited.' Also, the staff has reviewed the

enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing aging management program being consistent

with the GALL Report AMP to which it was compared. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d). '

3.0.3.2.2 Chemistry Control for Primary Systems Program

Summary of Technical Information in the Application. The applicant's chemistry control for

primary systems program is described in LRA-Section B2.1.5, Chemistry Control for Primary

Systems Program." In the LRA, the applicant stated that this is an existing MPS program. This

program is consistent, with an exception, withGALL AMP XI.M2, "Water Chemistry." , .. ,

; , ' .,.; : ... . .

3-29
The applicant stated in the program basis document that the chemistry control for primary

systems program includes periodic monitoring and control of known detrimental contaminants

such as chlorides, fluorides, dissolved oxygen, and sulfate concentration below the levels

known to result in loss of material or cracking in accordance with the Electric Power Research

Institute (EPRI) Technical Report TR-1 05714, 'PWR Primary Water Chemistry Guidelines,"

Revision 4, dated March 1999.

The applicant also stated in the program basis document that the chemistry control for primary

systems program monitors the fluids within the following systems and components: reactor

coolant system, emergency core cooling system (refueling water storage tank and safety

injection accumulator tanks), chemical and volume control system (boric acid storage tank,

letdown demineralizer (Unit 2), and volume control tank (Unit 2)), spent fuel pool cooling and

purification system (spent fuel pool demineralizer), sampling system, primary makeup water

(primary water storage tank (Unit 2), primary grade water storage tank (Unit 3), and

demineralized water storage tank (Unit 3)).

The applicant stated in the program basis document that the monitored chemistry parameters

are based on information provided in EPRI TR-105714 and the requirements of the plant

technical specifications and the plant technical requirements manual. The monitored

parameters include the following items: chlorides, conductivity, dissolved oxygen, fluorides,

hydrogen, hydrogen peroxide, lithium, pH, and sulfates. In addition, the applicant stated in the

LRA that verification of the effectiveness of the chemistry control for primary systems program

is provided by the work control process.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs audit evaluation are documented in the

MPS audit and review report. Furthermore, the staff reviewed the exception and its justification

to determine whether the AMP, with the exception, remains adequate to manage the aging

effects for which it is credited.

In Appendix B, Section B2.1.5 of the LRA, the applicant stated that the chemistry control for

primary systems program is consistent with GALL AMP XI.M2, with an exception. The chemistry

control for primary systems program takes exception to the "scope of program" program

element in that the applicant's program is based on Revision 4 of EPRI guideline TR-105714

(the applicable EPRI guideline for the primary water chemistry systems program), rather than

Revision 3 or a later revision approved by the NRC, as recommended by the GALL Report.

Revision 4 of EPRI TR-1 05714 has not yet been approved by the NRC.

The later revision of the EPRI guideline incorporates additional industry operating experience

not available at the time of the issuance of the earlier revision and is in keeping with the latest

industry practice. Further, the later revision is more conservative with regard to monitoring and

control of primary chemistry parameters. On the basis that the later revision of the EPRI

guidance applies more stringent guidelines than the earlier version, the staff finds this exception

to be acceptable.

Operatina Experience. The applicant stated in the program basis documents that the chemistry

control for primary systems program is based on the EPRI guidelines to take advantage of

industry operating experience as is done in the GALL Report. The staff reviewed condition

reports and interviewed the applicant's technical staff, which did not reveal any examples where

the loss of intended function occurred as the result of inadequate primary water chemistry

I

iI

I

I

1

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controls. The staff determined that the operating experience indicates that the chemistry control

for primary systems program creates an environment that minimizes material degradation. The

staffs review of the applicant's operating experience indicates that primary water systems

chemistry parameters can drift from their acceptable ranges, but the chemistry control for

primary systems program is effective in identifying these anomalies, implementing effective

corrective action, and trending the parameters.-When chemistry results reach a level at which

loss of material or cracking could become a concern related to the loss of intended function,

immediate corrective actions have been implemented to preclude the necessity for a plant

shutdown.

On the basis of its review of the above operating experience, the staff concludes that the

chemistry control for primary systems program adequately manages the aging effects that have

been observed at the applicant's plant.

FSAR SupDlement. In Appendix A, Section A.2.1.5 of the MPS Unit 2 LRA and Appendix A.

Section A2.1.4 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

chemistry control for primary systems program. The staff reviewed these sections and

determined that the information in the FSAR supplement provides an adequate summary of the

program activities. The staff finds these sections of the FSAR supplement sufficient, as

required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the exception and the

associated justifications and determined that the AMP, with the exception is adequate to

manage the aging effects for which it is credited.: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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.2.3 Chemistry Control for Secondary Systems Program

Summary of Technical Information in the Application. The applicant's chemistry control for

secondary systems program is described in LRA Section B2.1.6, "Chemistry Control for

Secondary Systems Program." In the LRA, the applicant stated that this is an existing program.

This program is consistent, with an exception, with GALL AMP XL.M2, "Water Chemistry."

The applicant stated in the LRA that this program includes periodic monitoring and control of

known detrimental contaminants such as chlorides, sodium, dissolved oxygen, and sulfate

concentrations below the levels known to result in loss of material or cracking in accordance

with EPRI Technical Report TR-1 02134, "PWR Secondary Water Chemistry Guidelines,"

Revision 5, dated May 3, 2000.

As documented in the staff's MPS audit and review report for the chemistry control for

secondary systems program, the applicant stated that the chemistry control for secondary

systems program ensures that the effects of aging are managed for the main steam, feedwater,

and auxiliary feedwater systems, as well as the following plant-specific systems: for MPS Unit 2,

sampling, moisture separation and re-heat, condensate, condensate storage and transfer,

3-31
feedwater heater vents and drains, plant heating and condensate recovery, secondary chemical

addition, extraction steam, turbine gland sealing steam, and condensate demineralizer mixed

bed system; for MPS Unit 3, auxiliary steam, auxiliary boiler condensate and feedwater, reactor

plant sampling, steam generator blowdown, and condensate make-up and draw-off systems.

The applicant also stated, as documented in the staff's MPS audit and review report for the

chemistry control for secondary systems program, that in accordance with EPRI TR-1 02134,

Revision 5, dated May 3, 2000, the monitored parameters include cation conductivity, chloride,

copper, dissolved oxygen, hydrazine, iron, lead, pH, sodium, specific conductivity, and sulfate.

Additionally, the applicant stated,- as documented in the staffs MPS audit and review report for

the chemistry control for secondary systems program, that verification of the effectiveness of

the secondary systems water chemistry program is provided by the work control process, which

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

involves a sufficient number of components such that it provides-an ongoing representative

indication of the integrity of components affected by the chemistry control tasks.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation are documented in the

MPS audit and review report. Furthermore, the staff reviewed the exception and its justification

to determine whether the AMP, with the exception, remains adequate to manage the aging

effects for which it is credited.

In Appendix B, Section B2.1.6 of the LRA, the applicant stated that the chemistry control for

secondary systems program is consistent with GALL AMP XI.M2, with an exception. The

chemistry control for secondary systems program takes'exception to the "scope of program"

element in that the applicant's program is based on Revision 5 of EPRI guideline EPRI

TR-1 02134 (the applicable EPRI guideline for the secondary water chemistry systems

program), rather than Revision 3 or a later revision approved by the staff, as recommended by

the GALL Report. Revision 5 of EPRI TR-1 02134 has not yet been approved by the staff.

The later revision of the EPRI guideline incorporates additional industry operating experience

not available at the time of the issuance of the earlier revision and is in keeping with the latest

industry practice. Further, the later revision is more conservative with regard to monitoring and

control of secondary chemistry parameters. On the basis that the later revision of the EPRI

guidance applies more stringent guidelines than the earlier version, the staff finds this exception

to be acceptable.

ODerating ExDerience. The applicant stated in the program basis documents that the chemistry

control for secondary systems program is based on the EPRI guidelines to take advantage of

industry operating experience as is done in the GALL Report. The staff reviewed condition

reports and interviewed the applicant's technical staff, which did not reveal any examples where

the loss of intended function occurred as the result of inadequate secondary systems water

chemistry controls. The staff determined that the operating experience indicates that the

chemistry control for secondary systems program creates an environment that minimizes

material degradation. The staffs review of the applicant's operating experience indicates that

chemistry parameters can drift from their acceptable range, but the chemistry control for

secondary systems program is effective in identifying these anomalies, implementing corrective;

action, and trending the parameters. When chemistry results reach a level at which loss of

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material or cracking could become a concemf(i.e.-, potentially affect the intended function), plant

power reductions are implemented until corrective actions are completed.

On the basis of its review of the above operating experience, the staff concludes that the

chemistry control for secondary systems program adequately manages the aging effects that

have been observed at the applicant's plant.

FSAR Supplement. In Appendix A, Section A2.1.6 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.5 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

chemistry control for secondary systems program. The staff reviewed these sections and

determined that the information in the FSAR supplement provides an adequate summary of the

program activities. The staff finds these sections'of the FSAR supplement sufficient, as

required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition; the staff has reviewed the exception and the

associated justifications and determined that the AMP, with the exception is adequate to -

manage the aging effects for which it is credited. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21 (d).

3.0.3.2.4 Closed-Cycle Cooling Water System

Summary of Technical Information in the ADplication. The applicant's closed-cycle cooling water

system program is described in LRA Section B2.1.7, 'Closed-Cycle Cooling Water System." In

the LRA, the applicant stated that this is an existing MPS program. This program will be

consistent, with an exception, with GALL AMP XL.M21, 'Closed-Cycle Cooling Water Systems."

Also, in an LRA supplement letter dated July 7, 2004, the applicant added an enhancement to

its closed-cycle cooling water system program.

The applicant stated in the LRA that the closed-cycle cooling water (CCCW) system program

manages the effects of loss of material through maintenance of process fluid chemistry and'

performance monitoring of CCCW systems to ensure parameters remainrwithin acceptable

limits. The program is based on guidance contained in EPRI Technical Report TR-107396,

"Closed Cooling Water Chemistry Guidelines," dated November1997.

The applicant stated, as documented in the staffs MPS audit and review report for the

closed-cycle cooling water system program, that the CCCW system program monitors fluids

and components within the following in-scope systems: for Unit 2 - chilled water, reactor

building, closed cooling water, emergency'diesel generator (jacket cooling water) systems; and

for Unit 3 - reactor plant component cooling water, emergency diesel generator (jacket cooling

water), control building chilled water, safety injection pumps cooling, and charging pumps

cooling system. - ..

Additionally, the applicant stated, as documented in the staffs MPS audit and review report for

the closed-cycle cooling water system program, that the CCCW system program monitors only

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the CCCW side of the heat exchangers that are within the scope of license renewal. The

service water system (open-cycle cooling) program monitors the service water side of the heat

exchangers.

The applicant also stated, as documented in the staffs MPS audit and review report for the

closed-cycle cooling water system, that the parameters that are currently monitored by the

CCCW system program are in accordance with the closed cooling water system chemistry

control procedure and EPRI TR-107396. The following parameters are monitored or used as a

diagnostic tool as part of this program: adenosine triphosphate, ammonia, chloride,

conductivity, copper, dissolved oxygen, fluoride, Freon, gross activity, hydrazine, iron, LCS-60

(as nitrogen dioxide), LCS-1200 (as molybdenum), pH, tolyltriazole, total organic carbon, and

total petroleum.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs audit evaluation of this AMP are

documented in the MPS audit and review report. Furthermore, the staff reviewed, the exception

and enhancement and their justifications to determine whether the AMP, with the exception and

enhancement, remains adequate to manage the aging effects for which it is credited.

In Appendix B, Section B2.1.7 of the LRA and the LRA supplemental letter dated, July 7, 2004,

the applicant stated that the closed-cycle cooling water system program is consistent with GALL

AMP XI.M21, with an exception and enhancement. The closed-cycle cooling water system

program takes exception to the "parameters monitored/inspected," "detection of aging effects,"

"monitoring and trending," and "acceptance criteria' program elements in that this program

does not include performance testing of the CCCW side of heat exchangers.

For the 'parameters monitored/inspected" program element associated with the exception taken

by the applicant, the GALL Report states that the AMP monitors the effects of corrosion by

surveillance testing and inspection in accordance with standards in EPRI TR-107396 to

evaluate system and component performance. For pumps, the uparameters

monitored/inspected" include flow and discharge and suction pressures. For heat exchangers,

the "parameters monitored/inspected" include flow, inlet and outlet temperatures, and

differential pressure.

The applicant stated, in the LRA, that the parameters recommended in the GALL Report for a

heat exchanger are not specifically monitored by the CCCW program to indicate corrosion

buildup. Instead, the CCCW program relies on the use of corrosion inhibitors to minimize and to

maintain heat exchanger performance. The applicant also stated, as documented in the staffs

MPS audit and review report for the CCCW system program, that the heat exchangers for the

CCCW system use service water as the cooling medium and are monitored, inspected, and

trended on the service side by the service water program, as described in the service water

system (open-cycle cooling) program. The staff has approved, in GL 89-13, "Service Water

System Problems Affecting Safety-Related Equipment," dated July 18, 1989, the performance

of regular, frequent cleaning of the service water side in lieu of thermal performance testing.

The applicant added, as documented in the staffs MPS audit and review report for the CCCW

system program, that MPS maintains low corrosion rates on the closed-cycle cooling water side

by using corrosion inhibitors. Operating experience indicates that the corrosion of the CCCW

side of the heat exchangers is not a concern. Inspections of the internal piping surfaces,

performed by the applicant during normal maintenance activities, indicate that corrosion was

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not occurring. Volumetric inspections of piping, and eddy current testing and visual inspections

of heat exchanger tubes also showed no signs of corrosion activity. Performance testing of the

CCCW side of heat exchangers is not performed at MPS.-

For the .detection of aging effects" program element associated with the exception taken by the

applicant, the GALL Report states that control of water chemistry does not preclude corrosion

at locations of stagnant flow conditions or crevices:'Degradation of a component due to

corrosion would result in degradation of system or component performance. The extent and

schedule of inspections and testing in accordance with EPRI TR-107396 assure detection of

corrosion before the loss of intended function of the component. Performance and functional

testing in accordance with EPRI TR-107396,'ensures acceptable functioning of the CCCW

system or components serviced by the CCCW system. For systems and components in

continuous operation, performance adequacy is determined by monitoring data trends for

evaluation of heat transfer fouling; pump wear characteristics, and branch flow changes.

Components not in operation are periodically tested to ensure operability.

The applicant stated in the LRA, that thermal performance testing of the closed-cycle cooling

heat exchangers is not performed, so the parameters specified in GALL AMP XL.M21 are not

periodically monitored. The CCCW system program eliminates the need for this monitoring by

the use of corrosion inhibitors.

The applicant also stated, as documented in the staff's MPS audit and review report for the

CCCW system program, that the CCCW system program includes both aging effect mitigation

activities (chemistry control) and performance monitoring activities, neither of which directly

detects aging effects. The identification of out-of-specification water chemistry conditions or

declining component performance indicates the potential for component degradation. The

applicant added that monitoring the chemistry of the in-scope CCCW system is generally

performed weekly with additional testing performed monthly and/or quarterly. Performance

testing of the in-scope pumps is performed quarterly as part of the inservice testing program or

diesel engine surveillance. Performance testing of the CCCW side of the heat exchangers is

not performed at MPS.

For the monitoring and trending" program element associated with the exception taken by the

applicant, the GALL Report states that the frequency of sampling water chemistry varies and

can occur on a continuous, daily, weekly, or as needed basis, as indicated by plant operating

conditions. Per EPRI TR-107396, performance and functional tests are performed at least

every. 18 months to demonstrate system operability, and tests to evaluate heat removal

capability of the system and degradation of system components are7 performed every five years.

The testing intervals may be adjusted on the basis of the results of the reliability analysis, type

of service, frequency of operation, or age of components and systems.

The applicant stated in the LRA that periodic performance tests are not performed for CCCW

system heat exchangers. As a result, monitoring of heat exchanger flow, inlet and outlet

temperatures, and differential pressure is not performed and this data is not trended; The

CCCW system program relies on the use of corrosion inhibitors to minimize the effects of

corrosion and to maintain heat exchanger performance, eliminating the need for periodic

performance testing. - . -

The applicant stated, as documented in the staff's MPS audit and review report for the

closed-cycle cooling water system program, that water chemistry parameters are monitored and

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the results are trended to provide timely indication of abnormal chemistry conditions. Chemistry

supervisors and control room personnel are notified and determine the need for additional

sampling, analysis, and corrective actions when the established limits are exceeded. If

out-of-specification parameters are deemed to promote accelerated corrosion or produce a

component or system failure, a condition report is initiated in accordance with the corrective

action program. Trending of chemistry data provides a basis for confirming that sampling

frequencies are appropriately set to continue the effective monitoring of chemistry trends.

Component performance is also monitored and trended to detect potential degradation before

any loss of intended function. If monitored parameters are outside proceduralized ranges or

values, chemistry supervisors and control room personnel are notified and a condition report is

initiated in accordance with the corrective action program.

During the audit and review, the staff noticed a footnote in the monitoring and trending section

of the closed-cycle cooling water system program, as documented in the staff's MPS audit and

review report, which stated that, heat exchangers cooled by service water are performance

monitored, inspected, and trended on the service water side as part of the service water system

program. The staff reviewed the service water system (open-cycle cooling) program, as

documented in the staff's MPS audit and review report, and found that performance testing is

done on only some heat exchangers, while the above footnote' implies that performance testing

is done on all heat exchangers. The staff requested that the applicant provide clarification for

this footnote. The applicant concurred with the staff that there was an error in the above

mentioned footnote. The applicant revised the footnote to read, "Not all the CCCW heat

exchangers. .." The staff reviewed the applicant response, as documented in the staffs MPS

audit and review report, and concludes that concerns related to the footnote in the CCCW are

resolved.

In addition, during the audit, the staff asked the applicant to explain how performance of the

heat exchangers will be monitored and trended since the applicant is taking an exception to the'

heat exchanger performance monitoring approach, as recommended by GALL AMP XI.M21. In

its response during the audit, the applicant presented a pump summary report for Unit 3 for the

period of January 1, 1999 through April 1, 2004; and a pump summary report for Unit 2 for the

period of January 1, 1999 through March 31, 2004. During the audit, the staff reviewed the data

and found that no degradation was identified. The staff finds the pump data to be acceptable as

documented in the audit and review report.

For the uacceptance criteria" program element associated with the exception taken by the

applicant, the GALL Report states that corrosion inhibitor concentrations are maintained within

the limits specified in the EPRI water chemistry guidelines for CCCW. System and component

performance test results are evaluated in accordance with the guidelines of EPRI TR-107396.

Acceptance criteria and tolerances are also based on system design parameters and functions.

The applicant stated in the LRA that periodic performance testing of CCCW system heat

exchangers is not performed. Therefore, the analysis and trending of system and component

performance test results described in GALL AMP XI.M21 cannot be performed. The applicant

also stated that lack of negative operating experience indicates that this is acceptable.

Additionally, the applicant stated, as documented in the staff's MPS audit and review report for

the closed-cycle cooling water system program, that the acceptance criteria reflect EPRI

guidelines for parameters in the CCCW systems that have been shown to contribute to

component degradation. Adherence to the guidelines minimizes loss of material and detects

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potential component degradation before the loss of intended function occurs. The applicant

stated that system and component performance'test results are evaluated in accordance with

procedural requirements that meet or exceed EPRI guideline requirements.

During the audit and review, the staff noted that there was not sufficient information available to

provide a basis for accepting the applicant's exception as stated in the AMP for the CCCW

system program. In subsequent discussions with the staff, the applicant proposed the addition

of an enhancement to the CCCW system program and documented the enhancement in an

LRA supplement letter dated July 7, 2004. The applicant committed; in the LRA supplement

letter, that baseline inspections of the CCCW:side of a sample of closed-cycle cooling heat

exchangers will be performed to verify that the corrosion control program is acceptable'and

heat exchangers performance is maintained.

On the basis of its review of the CCCW heat exchanger operating data and the additional

commitment to perform the inspection, as described in the enhancement to the CCCW system

program, the staff finds the exception to be acceptable. This commitment is identified in

Appendix A, Table A6.0-1 License Renewal Commitments, Item 29 for MPS Unit 2 and Item 30

for MPS Unit 3. The enhancements are described in detail below.

The applicant stated in an LRA supplement letter dated July 7, 2004, that it will enhance the

CCCW system program uparameters monitored/inspected," "detection of aging effects," and

"monitoring and trending' program elements by performing a baseline visual inspection of the

accessible areas of the heat exchanger shell side of a sample of CCCW heat exchangers prior

to the period of extended operation. The inspection will verify that the chemistry control portion'

of the closed-cycle cooling water system program is adequately maintaining the corrosion

control of the closed-cycle cooling heat exchangers..:

The applicant stated that the parameters recommended by the GALL Report to be monitored

for a heat exchanger are not specifically monitored by the CCCW system program for corrosion

buildup indication. The applicant stated, in the'LRA supplement letter dated July 7, 2004, that

instead, baseline inspections of the CCCW side of a sample of closed-cycle cooling heat,

exchangers will be performed to verify that the corrosion control program is acceptable and that

the heat exchanger performance is maintained. On the basis of its review of the CCCW heat

exchanger operating data and the additional commitment to perform the inspection, described

in the LRA supplement letter for the CCCW system program, the staff finds the enhancement to

be acceptable. The staff finds this enhancement is required and is acceptable as any such

changes will provide additional assurance that the effects of aging will be adequately managed.

The applicant stated in the LRA that thermal performance testing of the closed-cycle cooling

heat exchangers is not performed on most heat exchangers. Instead, the applicant stated, in its

LRA supplement letter dated July 7, 2004, that baseline inspections of the CCW side of a'

sample of closed-cycle cooling heat exchangers will be performed to verify that the corrosion

control program is acceptable, heat transfer fouling is not occurring, and heat removal capability

is maintained. On the basis of its review of the CCCW.heat exchanger operating data'land the

additional commitment to perform the inspection,^described in the LRA supplement letter for the

CCCW system program, the staff finds this enhancement is required 'and is acceptable'as any

such changes will provide additional assurance that the effects of aging will be adequately

managed. - 'l* - .- -

3-37'.
Operating Experience. The staff reviewed operating experience for the applicant's CCCW

system program. The applicant stated in the LRA that operating experience indicates that

chemistry parameters and component performance can drift from their acceptable ranges, but

that the CCCW system program is effective in identifying these anomalies, implementing

corrective action, and trending the parameters. The applicant also stated that when chemistry

results reach a predetermined level, corrective actions are properly completed to return theparameter to within acceptable limits, or compensatory measures are implemented. Similarly,

supervisors and control room personnel are notified when component performance falls outside

proceduralized ranges or values, and a condition report is initiated in accordance with the

corrective action program. During discussions with the staff, the applicant's technical staff

indicated that, to the best of its knowledge, there has not been a loss of intended function for

the components managed by the CCCW system program.

On the basis of its review of the above operating experience, the staff concludes that the

CCCW system program adequately manages the aging effects that have been observed at the

applicant's plant.

FSAR Supplement. In Appendix A, Section A2.1.7 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.6 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

CCCW system program. The staff reviewed these sections and determined that the information

in the FSAR supplement provides an adequate summary of the program activities. The staff

finds these sections of the FSAR supplement sufficient, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the exception and the

associated justifications and determined that the AMP, with the exception is adequate to

manage the aging effects for which it is credited. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.2.5 Electrical Cables and Connectors Not Subject to 10 CFR 50.49 Environmental

Qualification Requirements

Summary of Technical Information in the Application. The applicant's program for electrical

cables and connectors not subject to 10 CFR 50.49 EQ requirements is described in LRA

Section B2.1.8, 'Electrical Cables and Connectors Not Subject to 10 CFR 50.49 Environmental

Qualification Requirements." In the LRA, the applicant stated that this is a new program that will

be established prior to the period of extended operation. This commitment is identified on the

applicant's license renewal commitment list in the MPS Units 2 and 3 LRAs, Appendix A, Table

A6.0-1, as Item 5. This program will be consistent, with an enhancement, with GALL AMP

XL.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental

Qualification Requirements."

The applicant stated in the LRA that this program will include electrical cables and connections

within the scope of license renewal that are exposed to an adverse localized environment but

are not subject to the EQ requirements of 10 CFR 50.49. Connection types within the scope of

3-38
the program include connectors, fuse holders, splices, and terminal blocks. Fuse holders

(including fuse clips and fuse blocks) are included consistent with Interim Staff Guidance

(ISG-5, "Identification and Treatment of Electrical Fuse Holders-for License Renewal," dated

March 10, 2003. Adverse local environments include heat, radiation, or moisture local to the

cables or connections. The applicant also stated in-the LRA that this program will manage the:

aging effects of cracking and embrittlement to ensure that the cables and connections within

the scope of the program are capable of performing their intended function. The program will

sample and inspect cables and connections from accessible areas having an adverse localized

environment, in a manner intended to also represent, with reasonable assurance, cables and

connectors in inaccessible areas with an adverse localized environment.

The applicant stated in the LRA that the inspection plans will be developed consistent with

GALL AMP XL.E1 and considering the technical information and guidance contained in EPRI

Technical Report TR-109619, "Guideline for the Management of Adverse Localized Equipment

Environments," dated June 1999, IEEE Standard P1205-2000, "IEEE Guide for Assessing,

Monitoring, and Mitigating Aging Effects on Class IE Equipment Used in Nuclear Power

Generating Stations," NUREG/CR-5643, "Insights Gained from Aging Research," dated

March 1992, and SAND96-0344, 'Aging Management Guideline for Commercial Nuclear Power

Plants - Electrical Cable and Terminations," dated September 1996. This program will use a

sampling methodology based on a recognized industry or military standard.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of.the staff's audit evaluation are documented in the

MPS audit and review report. Furthermore, the staff reviewed the enhancement and its

justification to determine whether the AMP, with the enhancement, remains adequate to

manage the aging effects for which it is credited.

In Appendix B, Section B2.1.8 of the LRA, the applicant stated that the program for electrical

cables and connectors not subject to 10 CFR 50.49 EQ requirements will be consistent with

GALL AMP XI.E1, with an enhancement. The applicant stated that it will enhance the "detection

of aging effects" program element such that initial visual inspections for representative samples - of accessible non-EQ insulated cables and connections will be performed and applicable fuse

holders will be tested between year 30 and the end of the current operating license.

Subsequent confirmation of ambient conditions and fuse holder testing will be performed at

least once every 10 years during the period of extended operation.

For the "Detection of the Aging Effects" program element associated with the enhancement by,

the applicant, the GALL Report states that conductor insulation aging degradation from heat,

radiation, or-moisture in the presence of oxygen causes cable and connection jacket surface

anomalies. Accessible electrical cables and connections installed in adverse localized

environments are visually inspected at least once every 10 years. This is an adequate period to

preclude failures of the conductor insulation since'experience has shown that aging degradation

is a slow process. A 10-year inspection frequency will provide two data points during a 20-year

period, which can be used to characterize the degradation rate. The first inspection for license

renewal is to be completed before the period of extended operation. . ~.' .' .....

~~~~~~.. ....-.. h.J

In a letter dated March 10, 2003, (ML030690512), the NRC forwarded to the Nuclear Energy

Institute (NEI) and Union of Concerned Scientists interim staff guidance (ISG)-5 for the

identification and treatment of electrical fuse holders for license renewal. In ISG-5, the staff

indicated that fuse holders should be scoped, screened, and included in the AMR in the same

3-39
4

manner as terminal blocks and other types of electrical connections that are currently being

treated in the process. Further, this applies to fuse holders that are not part of a larger

assembly such as switchgear, power supplies, power inverters, battery chargers, circuit boards,

etc. Fuse holders in these types of active components would be considered to be piece parts of

the larger assembly and not subject to an AMR.

Operating experience, as discussed in NUREG-1760, "Aging Assessment of Safety-Related

Fuses Used in Low- and Medium-Voltage Applications in Nuclear Power Plants," identified that

aging stressors such as vibration, thermal cycling, electrical transients, mechanical stress,

fatigue, corrosion, chemical contamination, or oxidation of the connections surfaces can result

in fuse holder failure. Visual inspection alone may not be sufficient to detect the aging effects

from fatigue, mechanical stress, vibration, or corrosion of the metallic clamps of the fuse

holders. Other methods of aging detection may be necessary.

The applicant, in MPS LRA Table A6.0-1, License Renewal Commitments, Commitment

Number 6, committed to evaluate external fuse holders before the beginning of the extended

period of operation for possible aging effects. The staff reviewed the applicant's commitment

and finds that evaluation of the external fuse holders before the beginning of the extended

period of operation is not consistent with the staffs position as described in ISG-5. Also, in the

LRA, the applicant credits the program for the electrical cables and connectors not subject to

10 CFR 50.49 EQ requirements as the applicable AMP. The staff reviewed the program for

electrical cables and connectors not subject to 10 CFR 50.49 EQ requirements and finds that,

with respect to fuse holders, this AMP only addresses the aging effects of insulation portions of

fuse holders and that it does not address the aging effects from fatigue, mechanical stress, or

vibration on the metallic portions of fuse holders. During the audit, the staff requested that the

applicant provide an aging management program to address the metallic portion of fuse holders

or provide justification as to why an AMP is not required.

By letter dated February 15, 2005, the applicant provided its response. In its response, the

applicant stated that a scoping and screening review had been performed to identify fuse

holders that meet the requirements as delineated in ISG-5. For Millstone Units 2 and 3, the

review identified fuse holders that are not a part of a larger active assembly and that support

intended functions under 10 CFR 54.4(a)(1) and (a)(2), and therefore are subject to aging

management review. The aging management review performed for these fuse holders

concluded that there are no aging effects that require management. The applicant, in its

response, provided the following information which describes the scoping and screening

process and the aging management review performed for fuse holders:

Scoping and Screening Process - Millstone Units 2 and 3 fuse holders were identified

through plant walkdowns and a review of the Millstone master equipment list, electrical

drawings, and electrical specifications. Fuse holders that were located within larger

active assemblies were subsequently eliminated from further consideration with respect

to the requirements of ISG-5. Active components were determined based on the

guidance contained in NUREG-1800.

The fuse holders installed in safety related (SR) fuse panels were included in scope in

accordance with 10 CFR 54.4(a)(1) and were determined to be subject to aging

management review. Of the remaining fuse holders, a number of non-safety related fuse

holders that do not perform an intended function in accordance with 10 CFR 54.4(a)(2)

were identified based on an electrical circuit review and were not included in the scope

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of license renewal. The remaining non-safety related fuse holders were included in

scope and subject to aging management review.

Aging Management Review -An aging management review has been performed for the

fuse holders identified above (including both the insulation material and the metallic

clips). The fuse holders that are subject to aging management review are associated

with low-voltage circuits and are mounted on fuse panels that are installed in gasketed

enclosures located indoors. i

ISG-5 states that an aging management program would be required for the aging

stressors of fatigue, mechanical stress, vibration, chemical contamination, and

corrosion, if these stressors are applicable for fuse holders subject to aging

management review.

The non-metallic insulation material of the fuse holders was previously evaluated and

found to have no aging effects requiring management. The insulation material is

identified in LRA Table 3.6.2-1 as the Insulation commodity group with Inorganic

Materials as the material and "air" as the environment.

The aging stressors identified in ISG-5 have been evaluated for fuse holder metallic

clips and the following is a summary of the four aging management review results.

(1) Fatigue - NUREG-1760;,.Aging Assessment of Safety-Related Fuses

Used in Low- and Medium-Voltage Applications in Nuclear Power Plants,"

states that fatigue of fuse holders can typically occur due to elevated . ,temperature, mechanical stress, and repeated insertion and removal of

fuses. NUREG-1760 further states that fuse failures resulting from

thermal cycling are associated with the fuse element, and not the fuse

holder.

The fuse holders requiring aging management review are located indoors

in a mild environment. There are no significant sources of heat in close

proximity to the fuse holders such that elevated temperatures are not --expected. Therefore, fatigue due to elevated temperature was

determined not to require management for these fuse holders.

- Fatigue related to mechanical stress and/or repeated insertion and.

removal is evaluated under Mechanical Stress.

: . .i .. . , . .....

-(2) Mechanical Stress - For the fuse holders subject to aging management - review, the fuses are not routinely removed and reinserted into the fuse

clips. With the exception of one panel of fuse holders, the fuse holders;

are comprised of a block assembly of two or three fuses (i.e., two or three

sets of fuse clips on a removable block). The removable block assembly

permits interruption of the circuit for testing or.isolation without removal of

the fuses from the fuse holder metallic clips. The block assembly fuses

* are only removed from the fuse clips during fuse replacement. For the

other panel, the fuse holders are the typical base insulating material with

attached fuse clips. The fuses for this configuration are also only

removed during fuse replacement with circuit isolation performed by other

3-41
- l A

devices in the circuit. Therefore, these fuse clips are not subject to

repeated manipulation, which could lead to mechanical fatigue.

Mechanical stress resulting from electrical faults and transients is not

considered a credible aging mechanism since electrical faults are

infrequent and random in nature. Stresses resulting from electrical faults

and transients are mitigated by fast acting circuit protective devices.

Therefore, no aging management is required for mechanical stress.

(3) Vibration - The fuse holders subject to aging management review are

located in fuse panels. These panels are not mounted on rotating

equipment or in close enough proximity to rotating equipment to be

affected by vibration. Therefore, no aging effects related to vibration

require management.

(4) Chemical Contamination/Corrosion - The fuse panels containing fuse

holders that are subject to aging management review consist of gasketed

enclosures that are located indoors. The fuse holders'are not subject to

moisture or chemicals inside the panel enclosures that would provide a

corrosive environment. Therefore, chemical contamination and corrosion

do not require management for the fuse holders.

The results of the aging management review are summarized in the LRA supplemental tables

3.6.2-1 a for Unit 2 and Unit 3. The aging management review for fuse holders concludes that

there are no aging effects that require management. These aging management review results

are supported by a Millstone operating experience review which did not identify any instances of

fuse holder age related degradation.

As a result of this review of fuse holders, the commitment described in LRA Table A6.0-1, Item

6 is completed.

In ISG-5, the staff indicates that the AMR for fuse holders (metallic clamps) needs to include

the following stressors, if applicable: fatigue, mechanical stress, vibration, chemical

contamination, and corrosion. Where environments or operating conditions preclude such aging

effects (e.g., fuse holders not subject to vibration from rotating machinery), they need not be

addressed by the AMP. For the fuse holders subject to aging management review at Millstone

Units 2 and 3, the fuses are not routinely removed and reinserted into the fuse clips. With the

exception of one panel of fuse holders, these fuse holders are comprised of a block assembly

of two or three fuses (i.e., two or three sets of fuse clips on a removable block). The removable

block assembly permits interruption of the circuit for testing or isolation without removal of the

fuses from the fuse holder metallic clips. The block assembly fuses are only removed from the

fuse clips during fuse replacement. For the other panel, the fuse holders are the typical base

insulating material with attached fuse clips. The fuses for this configuration are also only

removed during fuse replacement with circuit isolation performed by other devices in the circuit.

Therefore, these fuse clips are not subject to repeated manipulation, which' could lead to

mechanical fatigue. For other'aging effects identified in ISG-5, the staff reviewed the applicant's

response and determined that the applicant provided adequate technical justification of why an

AMP for the metallic portions of these fuse holders is not required. On the' basis of its review,

the staff finds that applicant's response adequately addresses each' aging effects identified in

ISG-5, and therefore, finds the applicant's response acceptable.

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Operating Experience. The staff reviewed operating experience for the applicant's program for

electrical cables and connectors not subject to 10 CFR 50.49 EQ requirements; The applicant

stated in the LRA that electrical cables and connectors not subject to 10 CFR 50.49 EQ

requirements is a new program for which there is no operating experience. The operating

experience data associated with implementing this program will be addressed in the'applicant's

corrective action program.

During the audit, in discussions with the staff, the applicant stated that its review of prior

operating experience found that no significant non-EQ cable jacket or fuse holder anomalies

have been identified that can be attributed to age-related degradation. Asia part of the

documentation supporting this program, the applicant screened and compiled condition reports

involving cable or connection degradation for Units 2and 3. The staff reviewed a sample of

these condition report summaries, compiled by the'applicant, and found the evaluation and

disposition of the various conditions as reported therein to'be consistent with that conclusion.

On the basis of its.review of the above operating experience, the staff concludes that the

applicant's program for electrical cables and connectors not subject to 10 CFR 50.49 EQrequirements adequately manages the aging effects that have been observed at the applicant's

plant.

FSAR supplement. In Appendix A, Section A2.1.8 of the MPS Unit 2 LRA, Appendix A,;Section

A2.1.7 of the MPS Unit 3 LRA, and subsequent LRA supplements, the applicant provided the

FSAR supplement for the applicant's program'for electrical cables and connectors not subject

to 10 CFR 50.49 EQ requirements. The staff reviewed these sections'and determined that the

information in the FSAR supplement provides an adequate summary of the program activities.

The staff finds these sections of the FSAR supplement sufficient, as required by

10 CFR 54.21 (d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the enhancement and

confirmed that the implementation of the enhancement prior to the period of extended operation

would result in the aging management program being consistent with the GALL Report AMP to

which it was compared. 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). The staff

also reviewed the FSAR supplement for this AMP and finds that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.2.6 Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification

Requirements Used in Instrumentation Circuits-:-

Summary of Technical Information in the Application. The applicant's program for electrical

cables not subject to 10 CFR 50.49 EQ requirements used in instrumentation circuits is

described in LRA Section B2.1.9, "Electrical Cables"Not Subject to 10 CFR 50.49

Environmental Qualification Requirements Used in Instrumentation Circuits." In the LRA, the

applicant stated that this is an existing program. This program is consistent, with an

enhancement, with GALL AMP XI.E2, Electrical Cables Not Subject to 10 CFR 50.49

Environmental Qualification Requirements Used in Instrumentation Circuits."

3-43
The applicant stated in the LRA that the program includes instrumentation cable and

connectors used in circuits with sensitive low-level signals (such as nuclear instrumentation and

radiation monitoring), within the scope of license renewal, that are exposed to an adverse

localized environment but are not subject to the EQ requirements of 10 CFR 50.49. Adverse

local environments include heat, radiation, or moisture local to the cables or connectors. The

program manages the aging effects of cracking and embrittlement to ensure that the cables

and connectors within the scope of the program are capable of performing their intended

functions. For cables within the scope of this program that are energized during calibration of

the associated instrumentation, the program relies on in-situ calibration data and results from

surveillance required by technical specifications for the instrumentation. Surveillance of this

type includes channel calibrations, channel functional testing, and channel checks. For these

sensitive, low-level signal channels, the applicant expects to detect reduced insulation

resistance during calibration. In addition, troubleshooting of these instrumentation channels

includes visual inspection of cables and connections.

The applicant stated in the LRA that for instrument channels within the scope of this program

where the applicant does not perform in-situ calibration, such as for certain area radiation

monitors, the applicant will monitor cable degradation by an alternate method that tests the

cable. The applicant stated in its license renewal project position paper for in-scope

non-environmentally qualified instrumentation circuits with sensitive low-level signals, that

appropriate tests would be used to determine the cable insulation condition, such as insulation

resistance tests or time domain reflectometry. The test program will be developed using the

guidance cited in GALL AMP XL.E2 and articulated in EPRI TR-109619, IEEE Std 1205-2000,

NUREG/CR-5643, and SAND96-0344.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation are documented in the

MPS audit and review report. Furthermore, the staff reviewed the enhancement and justification

to determine whether the AMP, with the enhancement, remains adequate to manage the aging

effects for which it is credited.

In Appendix B, Section B2.1.9 of the LRA, the applicant stated that its program for electrical

cables not subject to 10 CFR 50.49 EQ requirements used in instrumentation circuits will be

consistent with GALL AMP XL.E2 with an enhancement. The applicant stated that it will enhance

the "scope of program" and "detection of aging effects" program elements by developing

procedures to employ an alternate testing methodology to confirm the condition of cables and

connectors in circuits that have sensitive, low-level signals and where the instrumentation is not

calibrated in-situ, such as the area radiation monitors. For the "scope of program" program

element associated with the enhancement proposed by the applicant, the GALL Report states

that this program applies to electrical cables used in circuits with sensitive, low-level signals

such as radiation monitoring and nuclear instrumentation that are within the scope of license

renewal.

For the detection of aging effects" program element associated with the enhancement by the

applicant, the GALL Report states that calibration provides sufficient indication of the need for

corrective actions by monitoring key parameters and providing trending data based on

acceptance criteria related to instrumentation loop performance. The normal calibration

frequency specified in the plant technical specifications provides reasonable assurance that

severe aging degradation will be detected prior to loss of the cable intended function. The first

tests for license renewal are to be completed before the period of extended operation.

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As stated in the LRA, for instrumentation equipment in circuits that have sensitive, low-level

signals, and where in-situ calibration is not performed, the applicant will develop procedures

that use an alternate test method to confirm the condition of the cables and connectors. The

testing may include insulation resistance tests, time domain reflectometry tests, or other testing

judged to be effective in determining cable insulation condition. The tests will be completed

prior to the period of extended operation and not to exceed a 10-year frequency. This

commitment is identified in Appendix A, Table A6.0-1 License Renewal commitments, Item 7.

The applicant stated that its program for electrical cables not subject to 10 CFR 50.49 EQ

requirements used in instrumentation circuits is consistent with the program as modified in the

staffs ISG-15. ISG-15 requires that "review of calibration results or findings of surveillance

program can provide an indication of the existence of aging effects based on acceptance

criteria related to instrumentation circuit performance. By reviewing the results obtained during

normal calibration or surveillance, an applicant may detect severe aging degradation prior to the

loss of the cable and connection intended function. The first review will be completed before the

end of the initial 40-year license term and at least 10 years thereafter. All calibration or

surveillance results that fail to meet acceptance criteria will be reviewed for aging effects when

the results are available." The staff reviewed the applicant's program for electrical cables not

subject to 10 CFR 50.49 EQ requirements used in instrumentation circuits. The staff finds that

the applicant's program does not require a review of calibration or surveillance results for

indication of cable degradation. Since the enhancement, as proposed by the applicant, is not

consistent with the staffs ISG-15, the staff requested that the applicant revise its program to

include this requirement or provide justification of why the review of calibration or surveillance

results is not necessary. '

In a supplement letter dated December 3, 2004, the applicant provided its response. The

applicant stated that to clarify the monitoring of aging effects for instrumentation cables that are

tested in-situ, a commitment will be added to the LRA Appendix A, "FSAR Supplement".Section

A2.1.9 for Unit 2 and Section A2.1.8 for Unit 3. This commitment is identified in the applicant's

license renewal commitment list in the MPS Units 2 and 3 LRA, Appendix A, Table A6.0-1, as

Item 32 and Item 33, respectively. The applicant has committed to review calibration results for

cables tested in situ to detect severe aging degradation of the cable insulation. The initial

review will be completed prior to the period of extended operation and will include at least

5 years of surveillance test data for each cable reviewed. Subsequent reviews will be performed

on a period not to exceed 10 years.

On the basis of its review, the staff finds the applicant's response acceptable because the

applicant has committed to review calibration or surveillance results for indication of cable

degradation, as required by ISG-15.

The staff concludes that this enhancement is acceptable because the alternate testing

methodology will be in place, prior to the period of extended operation. The staff also finds by

reviewing the results obtained during normal calibration or surveillance, that the applicant can

detect severe aging degradation prior to the loss of the cable and connection intended function.

Operating Experience. The staff reviewed operating experience for the applicant's program for

electrical cables not subject to 10 CFR 50.49 EQ requirements used in instrumentation circuits.

The review indicated that this program is effective in identifying age-related degradation,

implementing repairs, and maintaining the integrity of instrumentation components. The

applicant stated in the LRA that its review of prior operating experience has not identified any

3-45..
age-related degradation of instrumentation cables. As a part of the documentation supporting

this program, the applicant reviewed condition reports involving cable or connection degradation

for both units, and presented examples they considered in evaluating the effectiveness of the

program. The staff reviewed the condition reports referenced in the applicant's license renewal

project position paper for in-scope non-environmentally qualified instrumentation circuits with

sensitive low-level signals and found the evaluation and disposition of the conditions as

reported therein to be consistent with that conclusion.

The alternate cable testing that the applicant proposes as an enhancement, to be used when

in-situ calibration is not performed, is a new part of the program, so no operating experience

associated with this aspect of the program was available to the staff. The operating experience

data associated with implementing this program will be addressed in the applicant's corrective

action program.

On the basis of its review of the above operating experience, the staff concludes that the

applicant's program for electrical cables not subject to 10 CFR 50.49 EQ requirements used in

instrumentation circuits adequately manages the aging effects that have been observed at the

applicant's plant.

FSAR SuDDlement. In Appendix A, Section A2.1.9 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.8 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

applicant's program for electrical cables and connectors not subject to 10 CFR 50.49 EQ

requirements used in instrumentation circuits. Also, in an LRA supplement letter dated

December 3, 2004, the applicant stated that a commitment will be added to the LRA Appendix

A, "FSAR Supplement" Section A2.1.9 for Unit 2 and Section A2.1.8 for Unit 3. The applicant

has committed to review calibration results for cables tested in-situ to detect severe aging

degradation of the cable insulation. The initial review will be completed prior to the period of

extended operation and will include at least 5 years of surveillance test data for each cable

reviewed. Subsequent reviews will be performed on a period not to exceed 10 years. The staff

reviewed these sections and the supplement and determined that the infomiation in the FSAR

supplement provides an adequate summary of the program activities. The staff finds these

sections of the FSAR supplement sufficient, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the enhancement and

confirmed that the implementation of this enhancement prior to the period of extended

operation would result in the existing aging management program being consistent with the

GALL Report AMP to which it was compared. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21 (d).

3.0.3.2.7 Fire Protection Program

Summary of Technical Information in the Application. The applicant's fire protection program is

described in LRA Section B2.1.10, 'Fire Protection Program." In the LRA, the applicant stated

that this is an existing program. This program is consistent, with an exception and

3-46
enhancements, with GALL AMPs XI.M26, "Fire Protection," and XL.M27, "Fire Water System,"

and with the revised guidance described in NRC ISG-04, "Aging Management of Fire Protection

Systems for License Renewal," dated December 3, 2002.

The applicant stated in the LRA that the fire protection program manages the aging effects of

loss of material, cracking, and change of material properties for plant fire protection features

and components. The program manages these aging effects through the use of periodic

inspections and tests.

The applicant also stated in the LRA that the fire protection program manages the aging effects

for the diesel-driven fire pump fuel supply line, the reactor coolant pump oil collection systems,

and 10 CFR 50 Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating

Prior to January 1, 1979," support equipment.

The halon/carbon dioxide fire suppression systems for Units 2 and 3 are included within the

scope of the license renewal program and subject to an AMR. The AMP for halon and carbon

dioxide fire suppression systems for Unit 2 is consistent with GALL Report. However, the

applicant takes exceptions over the AMP for halon and carbon dioxide fire suppression systems

for Unit 3. Specifically the exception with the inspection interval to test the halon and carbon

dioxide fire suppression systems every 12-month and 18-month respectively, instead of

biannually as recommended by the GALL Report.

In addition, the applicant stated in the LRA that visual inspection of fire protection piping internal

surfaces that are exposed to water is performed when the system is opened for maintenance

and/or repair. The work control process provides guidance for the performance of internal

inspections of fire protection piping and components whenever the system is entered for

maintenance or repair.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs audit evaluation are documented in the

MPS audit and review report. Furthermore,'the staff reviewed the exception and enhancements

and their justifications to determine whether the AMP, with the exception and enhancements,

remains adequate to manage the aging effects for which it is credited.

In Appendix B, Section B2.1.1 0 of the LRA, the applicant stated that the fire-protection program

is consistent with GALL AMPs XL.M26 and XL.M27, and with the revised guidance described in

NRC ISG-04, with an exception and enhancements. The fire protection program takes an

exception to inspection interval to test the halon and carbon dioxide fire suppression system for

Unit 3 every 12-month and 18-month respectively, instead of biannually as recommended by

the GALL Report.

Exception 1: XL.M26 - Aging Management of the Halon and Carbon Dioxide Systems

NUREG-1801 recommends that periodic visual inspection and function tests of Halon

and CO2 fire suppression systems be performed at once every six months to detect

degradation in the system. Per the Millstone Unit 3 Current Licensing Basis (CLB), the

Technical Requirements Manual (TRM) requires functional tests of the Unit 3 Halon and

C02 systems be performed at a 12-month and 18-month frequency, respectively. In

addition, (not required by the TRM) comprehensive system walkdowns inspections are

performed by the system engineer on an annual basis. Plant operating experience has

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demonstrated that this frequency is adequate to maintain the intended function of these

systems.

Exception 2: XL.M26 - Aging Management of the Halon and Carbon Dioxide Systems

NUREG-1801 recommends that periodic visual inspection and function tests of Halon

and CO2 fire suppression systems be performed at once every six months to detect

degradation in the system. In lieu of a functional test of the Unit 3 Normal Switchgear

Area, the Auxiliary Boiler Enclosure Fuel Oil Pump Pit, and the Alternator/Exciter

Bearing and Casing Enclosure CO2 systems, comprehensive system walkdowns

inspections are conducted on an annual basis. These walkdowns visually verify that

degradation of the system is not occurring. Any noticeable degradation is addressed

using the Corrective Action Program.

The staff reviewed Exception 1, plant operating experience and fire surveillance procedures.

Plant operating experience indicate that no aging effects have been identified in the halon and

CO2 systems and components and that there has been no aging-related event that has

adversely affected systems operation. Therefore, the staff concluded that 12-month and 18-

month test interval frequency for Unit 3 halon and CO2 fire suppression systems respectively

will be sufficient to detect aging of halon and CO2 fire suppression systems. The 12-month and

18-month test interval frequency is included in the Millstone Unit 3 CLB.

The staff reviewed Exception 2, and concurred that the CO2 fire suppression system protecting

Unit 3 normal switchgear area, the auxiliary boiler enclosure fuel oil pump pit, and the

altemator/exciter bearing and casing enclosure does not required a function test, since these

areas do not contain any safety-related equipment or equipment that is important to safety.

Annual system walkdowns are adequate for managing the effect of aging of CO2 fire

suppression system in these areas.

In addition, the applicant stated in the LRA that the fire protection program will be enhanced for

the "detection of aging effects" program element such that a baseline visual inspection will be

performed on a representative sample of the buried fire protection piping and components

whose internal surfaces are exposed to raw water to confirm there is no degradation.

For the detection of aging effects program element associated with the enhancement by the

applicant, the GALL Report states that visual inspection of fire protection system internals will

be used for monitoring the age-related degradation of system piping and component internals.

ISG-4 provides additional guidance as follows:

However, internal inspections performed during each refueling cycle by

disassembling portions of the fire protection system piping, as stated in GALL

AMP XL.M27, may not be the most effective means to detect this aging effect.

Each time the system is opened, oxygen is introduced into the system and this

accelerates the potential for general corrosion. Therefore, the staff recommends

that the applicant perform a baseline pipe wall thickness evaluation of the fire

protection piping using a non-intrusive means of evaluating wall thickness, such

as volumetric inspection, to detect this aging effect before the current license

term expires.

3-48
The applicant stated in the LRA that it will evaluate,-develop, and implement appropriate

activities (e.g., baseline inspections) for assessing the buried fire water system piping to identify

or preclude wall thinning due to internal corrosion prior to the period of extended operation.

Consistent with ISG-4, the applicant stated that subsequent inspections may be required based

on engineering evaluation. The staff finds this enhancement'is required and is acceptable as

any such changes'to the fire protection pr6gram will provide additional assurance that the

effects of aging will be adequately managed:This commitment is identified on'the applicant's

license renewal commitment list in the MPS Units 2 and 3 LRA, Appendix A, Table A6.0-1,

Item 8.

The applicant also stated in the LRA that the fire protection program will be enhanced for the

"preventive actions' and 'detection of aging effects" program elements such that testing or

replacing a representative sample of sprinkler heads that have been in service for 50 years is

not specifically included in the applicant's fire protection program. Licensee follow-up action

items have been initiated to ensure that a representative sample of sprinkler heads will be

tested, or all affected sprinkler heads will be replaced in accordance the requirements of the

National Fire Protection Association (NFPA) Code 25, Section 2.3.3.1. This commitment is also

identified on the applicant's license renewal commitment list in the LRA, Appendix A, Table

A6.0-1, Item 9.

For the preventive actions and detection of aging effects program elements associated with the

with the second enhancement, the GALL Report states that this program element identifies

methods or techniques to ensure appropriate fire prevention measures are maintained and no

significant degradation occurs (XI.M26 and XI.M27). To ensure no significant corrosion, MIC, or

biofouling has occurred in water-based fire protection systems, periodic flushing, system

performance testing, and inspections are conducted (XI.M27). This program element identifies

methods or techniques to ensure timely detection of aging effects (XI.M26 and XI.M27).

Sprinkler systems are inspected once every refueling outage to ensure that signs of

degradation, such as corrosion, are detected in a timely manner (XI.M27).

ISG-4 provides additional guidance as follows:

NFPA 25, 1999 Edition, Section 2.3.3.1, "Sprinklers," states, where sprinklers

have been in place for 50 years, they shall be replaced or representative

- samples from one or more sample areas shall be submitted to a recognized

testing laboratory for field service testing. NFPA 25 also contains guidance to

perform this sampling every 10 years after the initial field service testing.

The 50-year service life of sprinkler heads does not necessarily occur at the 50th

hyear of operation in terms of licensingn.The service life is defined from the time

the sprinkler system is installed and functional. The staff recommends, in

accordance with NFPA 25, that sprinkler head testing should be performed at

year 50 of sprinkler system service life, not at year 50 of plant operation, with

subsequent sprinkler head testing every 10 years thereafter.

The staff noted that applicant stated in the LRA that it has included follow-up items to

accommodate the requirements of NFPA 25 but does not clearly state when the fire protection

program will identify and test, or replace, sprinkler heads. During the audits, the staff requested

that the applicant clarify this enhancement. In LRA supplement letter dated July 7,2004, theapplicant stated the following: '

3-49:
The commitment regarding sprinkler head testing or replacement should have

the wording "The first tests will be completed prior to the sprinkler heads

achieving 50 years of service life. The frequency of subsequent tests will not

exceed a 10-year interval." inserted after the words "Testing a representative

sample of fire protection sprinkler heads or replacing those that have been in

service for 50 years will be included in the Fire Protection Program." This

commitment appears in the Unit 2 LRA and the Unit 3 LRA in the following

locations:

Unit 2 Appendix B, Section B2.1.10

Unit 3 Appendix B, Section B2.1.10

Unit 2 Appendix A, Section A2. 1.10

Unit 3 Appendix A, Section A2.1.9

The staff finds that this enhancement is consistent with the recommendations set forth in ISG-4.

On that basis, the staff finds this enhancement is required and is acceptable as any such

changes to the fire protection program will provide additional assurance that the effects of aging

will be adequately managed.

Operating Exoerience. The staff reviewed operating experience for the applicant's fire

protection program. The review indicated that the fire protection program is effective in

identifying age-related degradation, implementing repairs, and maintaining the integrity of the

fire protection system components.

In the LRA, the applicant stated that component inspections and surveillance tests are

performed in compliance with the applicable sections of the corresponding technical

requirements manuals and in accordance with approved station procedures. Surveillance tests

have been performed routinely and have been successful in identifying fire protection

suppression system degradation. Station operating experience indicates that while degradation

has occurred, the fire protection program has been effective in identifying any anomalies,

implementing corrective actions, and trending the parameters. When inspection results have

exceeded allowable values, corrective actions have been implemented to ensure the continued

capability of the system to perform its intended functions.

On the basis of its review of the above operating experience, the staff concludes that the fire

protection program adequately manages the aging effects that have been observed at the

applicant's plant.

FSAR Suoplement. In Appendix A, Section A2.1.10 of the MPS Unit 2 LRA, Appendix A,

Section A2.1.9 of the MPS Unit 3 LRA, and the July 7, 2004, LRA supplement, the applicant

provided the FSAR supplement for the fire protection program. The staff reviewed these

sections and determined that the information in the FSAR supplement provides an adequate

summary of the program activities. The staff finds these sections of the FSAR supplement

sufficient, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the exception and the

associated justifications and determined that the AMP, with the exception is adequate to

manage the aging effects for which it is credited. Also, the staff has reviewed the

3-50

i
enhancements and confirmed that the implementation of the enhancements prior to the period

of extended operation would result in the existing aging management program being consistent

with the GALL Report AMP to which it was compared. '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). The staff also -reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.2.8 Flow-Accelerated Corrosion

Summary of Technical Information in the ApDlication. The applicant's flow-accelerated corrosion

program is described in LRA Section B2.1 .1 1; "Flow-Accelerated Corrosion." In the LRA, the

applicant stated that this is an existing program. This program is consistent, with an exception',

with GALL AMP Xl.M17, "Flow-Accelerated Corrosion."

The applicant stated in the LRA that the flow-accelerated corrosion (FAC) program manages

the aging effect of loss of material in accordance with the EPRI guidelines defined in the

Nuclear Safety Analysis Center (NSAC) Report, NSAC-202L, "Recommendation for an'

Effective Flow Accelerated Corrosion Program,".Revision 1, dated January 1996. The FAC

program includes controls to assure that the structural integrity of carbon steel and low-alloy

steel piping and components is maintained.

The applicant further stated in the LRA that specific procedures and methods satisfy NRC

Bulletin 87-01, "Thinning of Pipe Wall in Nuclear Power Plants," dated'July 9, 1987, and NRC

GL- 89-08, 'Erosion/Corrosion-Induced Pipe Wall Thinning," dated May 2, 1989. The program

predicts, detects, and monitors FAC as identified by wall thinning (loss of material) in plant

piping and components.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's'claim of

consistency with the GALL Report. Details of the staffs audit evaluation are documented in the

MPS audit and review report. Furthermore, the staff reviewed the exception and its justification

to determine whether the AMP, with the exception, remains adequate to manage the aging

effects for which it is credited.

In Appendix B, Section B2.1.11 of the LRA, the applicant stated that the flow-accelerated

corrosion program is consistent with GALL AMP XL.M17, with an exception. The flow--

accelerated corrosion program takes exception to the 'scope of program" program element in

that GALL AMP XI.M17 recommends that the program follow guidance identified in

NSAC-202L, "Recommendation for an Effective Flow-Accelerated Corrosion Program,"

Revision 2. The MPS program is based on Revision 1 of the same guidance.'

The applicant stated in the LRA that it reviewed .the differences between the two revisions of

NSAC-202L and concluded that no changes that are relevant to the flow-accelerated corrosion

program were made from Revision 1 to Revision 2.

The staff reviewed NSAC-202L'and relevant current EPRI technical documents, and

interviewed the applicant's technical staff.-On the basis of these reviews and interviews, the

staff concludes that the differences between the two revisions are not applicable to the flowaccelerated corrosion program and, therefore, finds this exception to be acceptable.

3-51 :'
Operating Exgerience. The staff reviewed operating experience for the applicant's flowaccelerated corrosion program. The number of planned and unplanned replacements has

generally trended downward over the past several years due to the establishment of the flowaccelerated corrosion program and following the recommendations identified in NSAC-202L.

The applicant stated in the LRA that operating experience indicates that while wall thinning has

occurred since implementation of the flow-accelerated corrosion program, the flow-accelerated

corrosion inspection activities have effectively identified degraded components for repair or

replacement. These corrective actions have been effective in maintaining the integrity of

FAC-susceptible components.

On the basis of its review of the above operating experience, the staff concludes that the flowaccelerated corrosion program adequately manages the aging effects that have been observed

at the applicant's plant.

FSAR Supplement. In Appendix A, Section A2.1.11 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.10 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

flow-accelerated corrosion program. The staff reviewed these sections and determined that the

information in the FSAR supplement provides an adequate summary of the program activities.

The staff finds these sections of the FSAR supplement sufficient, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the exception and the

associated justifications and determined that the AMP, with the exception is adequate to

manage the aging effects for which it is credited. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21 (d).

3.0.3.2.9 Fuel Oil Chemistry

Summary of Technical Information in the ADplication. The applicant's fuel oil chemistry program

is described in LRA Section B2.1.12, 'Fuel Oil Chemistry." In the LRA, the applicant stated that

this is an existing program. This program is consistent, with six exceptions, with GALL AMP

XI.M30, 'Fuel Oil Chemistry."

The applicant stated in the LRA that the fuel oil chemistry program activities control the aging

effect of loss of material by monitoring and controlling fuel oil quality to ensure that it is

compatible with the materials of construction for in-scope components containing diesel fuel oil.

Fuel oil quality limits are established to ensure the operability of the respective diesels, and

compliance with applicable technical specifications and technical requirements, and to reduce

the likelihood of loss of material within the fuel oil systems. The program basis document

indicates that poor fuel oil quality could lead to (1) degradation of fuel oil storage tanks or (2)

accumulations of particulate or biological growth that could interfere with the operation of plant

equipment.

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The applicant stated, as documented in the staffs MPS audit and review report for the fuel oil

chemistry program, that the fuel oil chemistry program involves the sampling and testing of fuel

oil used for equipment that is' within the scope of license renewal. Testing is performed to

ensure the acceptability of fuel oil quality, thus maintaining the integrity of the fuel oil system.

The fuel oil chemistry sampling and testing activities mitigate the aging effect of loss of material

in the fuel oil system. The effectiveness of the fuel oil chemistry program for in-scope tanks is

verified by the tank inspection'program, and by. the work control process for other diesel fuel

system'components. These programs provide input to the corrective-action program if 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

fuel oil chemistry program. .-

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs' audit evaluation are documented in the

MPS audit and review report. Furthermore, the staff reviewed the exceptions and their

justifications to determine whether the AMP, with exceptions, remains adequate to manage the

aging effects for which it is credited.

In Appendix B, Section B2.1.12 of the LRA, the applicant stated that the fuel oil chemistry ' program is consistent with GALL AMP XI.M30, with exceptions. The fuel oil chemistry program

takes exception to the Opreventive actions," !detection of aging effects," and monitoring and

trending" program elements such that (1) this program does not include the addition of biocides,

stabilizers, or corrosion inhibitors and (2) sampling and testing of the fuel and dewatering of the

security diesel fuel oil storage tank is performed semi-annually. For the program elements ' associated with the first and second exceptions taken by the applicant, the GALL Report states

that the quality of fuel oil is maintained by additions of biocides to minimize biological activity,

stabilizers to prevent biological breakdown of the diesel fuel, and corrosion inhibitors to mitigate

corrosion. Periodic cleaning of a tank allowsiremoval of sediments, and periodic draining of ' water collected at the bottom of a tank minimizes the amount of water'and the length of contact

time. Accordingly, these measures are effective in mitigating corrosion inside diesel fuel oil

tanks. Coatings, if used, prevent or mitigate corrosion by protecting the internal surfaces of the

tank from contact with water and microbiological organisms.

Degradation of the diesel fuel oil tank cannot occur without exposure of the tank internal

surfaces to contaminants in the fuel oil, such as water and microbiological organisms; Compliance with diesel fuel oil standards and periodic multi-level sampling provide assurance

that fuel oil contaminants are below acceptable levels. Internal surfaces of tanks that are

drained for cleaning are visually inspected to detect potential degradation. However, corrosion

may occur at locations in which contaminants may accumulate, such as'a tank bottom, and an

ultrasonic thickness measurement of the tank bottom surface ensures that significant

degradation is not occurring. - :- >

Water and biological activity or particulate contamination concentrations are monitored and

trended at least quarterly. Based on industry operating 'experience, quarterly sampling and

analysis of fuel oil provide for timely detection of conditions conducive to corrosion of the

internal surface of the diesel fuel oil tank before the potential loss of its intended function.'

The applicant stated in the LRA that the fuel oil chemistry program does not include the addition'

of biocides, stabilizers, or corrosion inhibitors. Operating experience and sample results confirm

that microbiologically influenced corrosion (MIC) and breakdown of the fuel oil have not be'e'n

3-53
I

issues requiring the use of fuel oil additives. On the basis of its review of the operating

experience and determination that mitigation of the effects of MIC and fuel oil breakdown has

not necessitated the use of fuel oil additives at MPS, the staff finds the first exception to be

acceptable.

The applicant stated, as documented in the staffs MPS audit and review report for the fuel oil!

chemistry program that, although the Unit 3 emergency diesel fuel tanks and the station

blackout storage tanks are coated, these coatings are not credited for preventive actions for the

purpose of license renewal. The applicant stated that the fuel oil tanks are included in the tank

inspection program and are subjected to a 1 0-year draining, cleaning, and inspection activity.

The applicant added the diesel fire pump fuel oil tank and the security diesel fuel oil storage

tank to the tank inspection program, so that they undergo the semi-annual tank inspection and

cleaning in order to mitigate corrosion at the bottom of the tanks. The staff reviewed four work

orders that documented that the security diesel fuel oil storage tank was tested and dewatered

on a semi-annual basis beginning in July 2002. The results indicate that no water has been

found.

The GALL AMP XI.M30 detection of aging effects program element recommends periodic,

multilevel sampling and visual inspection of the internal surfaces of the tanks that are drained

for cleaning. In addition, the GALL AMP XI.M30 monitoring and trending program element

recommends that water and biological activity or particulate contamination concentrations are

monitored and trended at least quarterly. As documented in the staffs MPS audit and review

report for the fuel oil chemistry program, the applicant stated that loss of material is an aging

effect that is detected through condition monitoring via periodic tank inspection activities. In

addition, the applicant stated that implementation of new fuel oil testing and periodic multilevel

surveillance for fuel oil quality in the various storage tanks is accomplished using surveillance

procedures and automated work orders. Periodic sampling and testing is performed monthly for

the Unit 3 emergency diesel fuel oil storage tanks, quarterly for most of the in-scope tanks, and

semi-annually for the security diesel fuel oil storage tank. The staff requested that the applicant

add justification for this exception to the GALL Report (e.g., the size of the tank, negligible

water accumulation due to the location of the tank outlet piping connection, and the frequency

of fuel oil testing) to the fuel oil chemistry program.

In a subsequent onsite.visit to the plant, the applicant presented the staff with Revision 3 of the

fuel oil chemistry program, as documented in the staffs MPS audit and review report, which

provides justification for size and frequency of testing. However, Revision 3 does not ,

acknowledge that there would be negligible accumulation in the tank due to the location of the

tank outlet. During its review of the tank drawings, the applicant confirmed that the outlet is on

the bottom of the side of the tank and not directly on the bottom of the tank. Therefore, the

applicant did not make the statement that there would be a negligible amount of accumulation

in the tank. The staff reviewed the examples of operating experience regarding the "like new"

condition of the tank internals and the lack of water found in the fuel oil tanks and discussed the

examples with the applicant. On the basis of its review of this operating experience and the

clarifications provided by the applicant in Revision 3, as documented in the staffs MPS audit

and review report for the fuel oil chemistry program, the staff finds the second exception to be

acceptable.

The fuel oil chemistry program also takes exception to the 'parameters monitored/inspected"

and "acceptance criteria" program elements such that (3) this program uses an unmodified

ASTM D 2276 Method A for the determination of particulates. For the program elements

3-54

I
associated with the third exception taken by the applicant, the GALL Report states that for

determination of particulates, modified ASTM D 2276, Method A, is used. The modification

consists of using a filter with a pore size of 3.0 micrometers (pm), instead of 0.8 pm. These are

the principal parameters relevant to tank structural integrity.

Modified ASTM D 2276, Method A, is used for determination of particulates. The modification

consists of using a filter with a pore size of 3.0 pm, instead of 0.8 pm.

The applicant stated in the LRA that the fuel oil chemistry program does not use the modified

ASTM Standard D 2276, Method A, for determination of particulates. The unmodified version of

the same standard is used. The unmodified version is considered to be more conservative than

the modified version because it uses a smaller filter pore size. On the basis that the applicant

uses a more conservative version of the ASTM standard for the determination of particulates,

the staff finds the third exception to be acceptable.

The fuel oil chemistry program also takes exception to the "detection of aging effects" program

element such that (4) the in-scope tanks are included in the tank inspection program, which

provides for ultrasonic testing activities based on the evaluation of the conditions found during

visual inspections. For the program element associated with the fourth exception taken by the

applicant, the GALL Report states that degradation of the diesel fuel oil tank cannot occur

without exposure of the tank internal surfaces to contaminants in the fuel oil, such as water and

microbiological organisms. Compliance with diesel fuel oil standards and periodic multilevel

sampling provide assurance that fuel oil contaminants are below acceptable levels. Internal

surfaces of tanks that are drained for cleaning are visually inspected to detect potential

degradation. However, corrosion may occur at locations in which contaminants may

accumulate, such as a tank bottom, and an ultrasonic thickness measurement of the tank

bottom surface ensures that significant degradation is not occurring.

As documented in the staff's MPS audit and review report for the fuel oil chemistry program, the

applicant stated that loss of material is detected through condition monitoring via periodic tank

inspections. However, the ultrasonic thickness measurement of the tanks is not addressed in

this report. The applicant stated in the LRA that the in-scope tanks are included in the tank

inspection program, which provides for ultrasonic testing activities based on an evaluation of

the conditions found during visual inspections. On the basis that the tank inspection program

provides an adequate means for evaluating the integrity of the tank internals, the staff finds the

fourth exception to be acceptable.

In addition, the fuel oil chemistry program takes exception to the "preventive actions" program

element in that (5) this program cannot perform 'dewatering of the Unit 2 emergency diesel day

tanks because the bottom drains are located in the side of the tanks. For the program element

associated with the fifth exception taken by the applicant, the GALL Report states that the

quality of fuel oil is maintained by additions of biocides to minimize biological activity, stabilizers

to prevent biological breakdown of the diesel fuel, and corrosion inhibitors to mitigate corrosion.

Periodic cleaning of a tank allows removal of sediments, and periodic draining of water

collected at the bottom of a tank minimizes the amount of water and the length of contact time.

Accordingly, these measures are effective in mitigating corrosion inside diesel fuel oil tanks.

Coatings, if used, prevent or mitigate corrosion by protecting the internal surfaces of the tank

from contact with water and microbiological organisms.

3-55
The applicant stated in the LRA that the fuel oil chemistry program cannot perform dewatering

of the Unit 2 emergency diesel day tanks because the bottom drains are located on the side of

the tanks. However, the applicant also stated that the tanks are inspected and cleaned as

required by the tank inspection program. The staff reviewed the examples of operating

experience regarding the 'like new' condition of the tank intemals and the lack of water found in

the fuel oil tanks and discussed these findings with the applicant. On the basis of its review of

the operating experience and discussion with the applicant, the staff concludes that corrosion

caused by prolonged water contact with tank bottoms is not an aging effect of significance for

the Unit 2 emergency diesel day tanks and, therefore, finds the fifth exception to be acceptable.

Also, the fuel oil chemistry program takes exception to the "parameters monitored/inspected"

and "acceptance criteria" program elements such that (6) the Unit 3 technical specifications

require the use of American Society for Testing and Materials (ASTM) Standard D 1796 for the

determination of water and sediment contamination in the diesel fuel. For the program elements

associated with the sixth exception taken by the applicant, the GALL Report states that the

AMP monitors fuel oil quality and the levels of water and microbiological organisms in the fuel

oil, which cause the loss of material of the tank internal surfaces. The ASTM Standard D 4057

is used for guidance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for

determination of water and sediment contamination in diesel fuel.

The ASTM Standards D 1796 and D 2709 are used for guidance on the determination of water

and sediment contamination in diesel fuel.

The applicant stated in the LRA that the Unit 3 technical specifications require the use of ASTM

Standard D 1796 for the determination of water and sediment contamination in the diesel fuel.

The fuel oil chemistry program is a common program for both Units 2 and 3 and the fuel oil for

both units is procured to the same specification. The staff review of the ASTM Standards D

1796 and D 2709 reveals that ASTM D 1796 is acceptable for the fuel oil used at Unit 2 based

on the Unit 3 technical specification requirement to use ASTM D 1796 and the fact that the

program is common to Units 2 and 3. On the basis of its review, the staff finds the sixth

exception to be acceptable.

Operating Experience. The staff reviewed operating experience for the applicant's fuel oil

chemistry program. The applicant stated in the LRA that operating experience indicates that

while fuel oil deliveries from commercial vendors and tank samples do not always meet MPS

quality specifications, fuel oil chemistry activities are effective in identifying any anomalies,

implementing corrective actions, and trending the parameters. When chemistry results have

exceeded allowable values, corrective actions have been implemented to ensure that the

quality of the fuel oil in the storage tanks has not been compromised and that the continued use

of the fuel oil in the other tanks is considered based on the extent of condition requirements of

the corrective action program. The applicant further stated that no failures of fuel oil system

components were identified at MPS due to contamination or water-induced degradation.

On the basis of its review of the above operating experience, the staff concludes that the fuel oil

chemistry program adequately manages the aging effects that have been observed at the

applicant's plant.

FSAR SupDlement. In Appendix A, Section A2.1.12 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.11 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

fuel oil chemistry program. The staff reviewed these sections and determined that the

3-56
information in the FSAR supplement provides an adequate summary of the program activities.

The staff finds these sections of the FSAR supplement sufficient, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition,-the staff has reviewed the exceptions and.

the associated justifications and determined that the AMP, with the exceptions is adequate to

manage the aging effects for which it is credited. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21 (d).

3.0.3.2.10 Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental

Qualification Requirements

Summary of Technical Information in the ADplication. The applicant's program for inaccessible

medium-voltage cables not subject to 10 CFR 50.49 EQ requirements is described in LRA

Section B2.1.14, "inaccessible Medium-Voltage Cables not Subject to 10 CFR 50.49

Environmental Qualification Requirements." In the LRA, the applicant stated that this is an

existing MPS program. This program will be consistent, with an exception and an enhancement,

with GALL AMP XL.E3, Inaccessible Medium Cables not Subject to 10 CFR 50.49

Environmental Qualification Requirements." -

The applicant stated in the LRA that its program for inaccessible medium-voltage cables not

subject to 10 CFR 50.49 EQ requirements manages the aging effect of formation of water trees

and ensures that inaccessible medium-voltage cables within the scope of license renewal that

have been submerged and exposed to significant voltage will remain capable of performing

their intended function. Exposure to both conditions is necessary for age-related degradation of

insulation resulting from water treeing. This program considers the combined effects of

submergence (i.e., significant moisture exposure) and significant voltage exposure, using the

definitions for these exposures as defined in GALL'AMP XL.E3. This program identifies areas

where the potential for submergence exists, and relies upon inspection and pumping of cable

vaults, manholes, and handholes to prevent significant moisture exposure. The inspections

verify that the cables, including those protected by conduit, are not submerged and that no

evidence of cable submergence since the last inspection is detected.

The applicant's structures monitoring program ensures that underground cable enclosures such

as vaults, manholes, and handholes containing in-scope medium-voltage cables, which could

potentially become submerged, are pumped and inspected at specified frequencies. Pumping

frequencies are adjusted as necessary to ensure that cables do not become submerged

between preventive maintenance activities.-The staff reviewed the applicant's structures.

monitoring program, as documented in the staff's MPS audit and review report, which describes

preventive maintenance work orders associated with the structures monitoring program.

The applicant stated, as documented in the staff's MPS audit and review report for the

structures monitoring program, that if in-scope medium-voltage cables are found to have been

exposed to significant moisture under significant voltage conditions, the structures monitoring

3-57-
.A44

program personnel will coordinate with engineering to ensure that the cables are evaluated to

assess any potential impact on the integrity of the insulation.

GALL AMP XL.E3 stipulates that any tests that might be performed will be proven tests for

detecting deterioration of the insulation due to wetting, and will be acceptable to the nuclear

industry and the NRC. Examples of possible test methods considered power factor, partial

discharge, or polarization index, as described in EPRI Technical Report TR-103834-P1-2,

"Effects of Moisture on the Life of Power Plant Cables," dated August 1994, or other

appropriate testing.

The applicant stated in the LRA that the program will consider the technical information and

guidance cited in GALL AMP XI.E3 that is provided by EPRI TR-1 09619, IEEE Std 1205-2000,

NUREG/CR-5643, and SAND96-0344.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's audit evaluation are documented in the

MPS audit and review report. Furthermore, the staff reviewed the exception and enhancement

and their justifications to determine whether the AMP, with the exception and enhancement,

remains adequate to manage the aging effects for which it is credited.

In Appendix B, Section B2.1.14 of the LRA, the applicant stated that the applicant's program for

inaccessible medium-voltage cables not subject to 10 CFR 50.49 EQ requirements is consistent

with GALL AMP XL.E3, with an exception and enhancement. The program takes exception to

the "scope of program," "parameters monitored/inspected," and "detection of aging effects"

program elements such that an engineering evaluation will be performed to determine the

appropriate actions to fully address the identified condition of the cables, including the

identification of testing requirements as necessary, and the corresponding test frequency

should evidence of submerged medium-voltage cables with significant voltage be identified.

The staff noted that inaccessible medium-voltage cables may be exposed to condensation and

wetting in inaccessible locations, such as conduits, cable trenches, cable troughs, and duct

banks. When an energized medium-voltage cable is exposed to wet conditions for which it is

not designed, water treeing or a decrease in the dielectric strength of the conductor insulation

can occur. Water trees occur when the insulating materials are exposed to long-term,

continuous electric stress and moisture; these water trees eventually result in breakdown of the

dielectric and ultimate failure. The growth and propagation of water trees is somewhat

unpredictable.

The applicant stated that its program for inaccessible medium-voltage cables not subject to

10 CFR 50.49 EQ requirements uses periodic actions, such as pumping and inspection of cable

vaults (manholes), to prevent cables from being submerged. In the event that submerged

cables are found, an engineering evaluation will be performed and the appropriate testing

required will be specified, as necessary to confirm the condition of the cable insulation. For the

program elements associated with the exception taken by the applicant, the GALL Report

states that in-scope, inaccessible medium-voltage cables exposed to significant moisture

(periodic exposure to moisture that last more than few days) and significant voltage are tested

at least once every 10 years to provide an indication of the cable insulation condition.

3-58
During the audit, the staff requested that the applicant provide the frequency of manholes

inspection and technical justification of how visual inspections are adequate to conclude that

the cables are not subject to significant moisture that lasts more than few days.

In a supplement letter dated December 3, 2004, the applicant stated that it has identified two

Unit 3 duct lines with low points that are susceptible to moisture accumulation. These two duct

lines contain 26 in-scope medium-voltage cables. No similar duct lines were identified for Unit

2. Prior to the period of extended operation, these cables will be tested to demonstrate that

water treeing will not prevent the cables from performing their intended function.

Further,-the applicant stated that the other duct banks for both units are not susceptible to

moisture accumulation due to the slope of the embedded conduit between manholes and the

inspections performed by the applicant's structures monitoring program. The duct banks consist

of 5-inch Schedule 40 PVC pipe embedded in reinforced concrete, which is founded on dense

soil over bedrock. The applied contact pressure by the duct banks is well below the allowed

bearing pressure of the supporting material resulting in insignificant settlement (Ref. Unit 2

FSAR Section 2.7.5.2). Therefore, the duct banks will maintain the design cable run slope to

their respective termination points in manholes or buildings and the structures monitoring

program inspections will identify any water intrusion.

For the cable in these duct banks, the design,'in conjunction with the structures monitoring

program inspections, ensures that any cable that becomes submerged will be identified by the

structures monitoring program inspections. The inaccessible medium-voltage cables not subject

to 10 CFR 50.49 EQ requirements program currently addresses the testing of cables that have

been submerged. For the cables that have not been submerged, the aging effect of water

treeing is precluded and testing is not required.- -

To implement the testing of inaccessible medium-voltage cables identified in the two Unit 3 duct

lines with low points that are susceptible to moisture accumulation, the applicant will add the

following commitment to the MPS LRA Appendix A, "FSAR Supplement" Unit 2, Section

A2.1.14 and Unit 3, Section A2.1.13: ;

Testing of Inaccessible Medium-Voltage Cables:

"The Unit 3 duct lines # 929 (SBO Diesel to Unit 3 4.16kV Normal Switchgear)

and # 973 (RSST 3RTX-XSR-B to 6.9kV Normal Switchgear Bus 35A, 35B, 35C

and 35D) have low points that are susceptible to moisture accumulation. Prior to

the period of extended operation, the in scope cables in these two duct lines will

be tested to demonstrate that water treeing will not prevent the cables from

performing their intended function. Subsequent testing will be performed on a

frequency not to exceed a 10-year interval.".-

An additional item will be added to Unit 2 and Unit 3 Appendix A "FSAR Supplement,"

Table A6.0 -1 as follows: , - 1

Item: N33" (Unit 2) and "34" (Unit 3)

Commitment - 'The in scope cables in Unit 3 duct lines # 929 (SBO Diesel to Unit 3

4.16kV Normal Switchgear) and # 973 (RSST 3RTXXSR-B to 6.9kV Normal Switchgear

3-59,
l4!

Bus 35A, 35B, 35C and 35D) will be tested to demonstrate that water treeing will not

prevent the cables from performing their intended function.'

Source - inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49

Environmental Qualification Requirements"

Schedule - "Prior to Period of Extended Operation Not to Exceed a 10 Year Frequency

Thereafter."

The staff reviewed the applicant's response. The staff finds, other than the duct lines #929 and

#973 (26 cables) which the applicant committed to test, that the slope of these duct banks

between manholes and the inspection performed, as required by the applicant's structures

monitoring program, are not adequate to preclude significant moisture for these duct banks. It

was not clear to the staff how the applicant's structures monitoring program will identify water

intrusion in these duct banks because these banks are underground and are not accessible.

Periodic actions are taken to prevent cables from being exposed to significant moisture, such

as inspection of water collection in cable manholes and conduit, and draining the water, as*

needed. However, those actions are not sufficient to assure that water is not trapped elsewhere

in the raceways. For example, if duct bank conduit has low points in the routing, there could

potentially be long term submergence at these low points. In addition, concrete raceways may

crack due to soil settling over a long period of time and that the conduit between manhole

covers may not be water tight. Additionally, in certain areas, the water table is high in seasonal

cycles and therefore, the raceways may get refilled with water soon after purging. Further, the

potential uncertainties involved with water trees exist even with duct banks that are sloped to

minimize water accumulation. Experience has shown that insulation degradation will occur if the

cables are exposed to 100 percent relative humidity. Periodically removal of water in manholes

is required to minimize the potential for insulation degradation. In addition to removal of water,

in-scope, medium-voltage cables exposed to significant moisture and significant voltage must

be tested to provide an indication of the condition of the conductor insulation. The specific type

of test performed will be determined prior to the initial test and is to be a proven test for.

detecting deterioration of the insulation material due to wetting.

The staff finds, other than the duct lines #929 and #973 (26 cables) which the applicant

committed to test, that the slope of these duct banks between manholes and the inspection

performed, as required by the applicant's structure's monitoring program, are not adequate to

preclude significant moisture for these duct banks.

On the basis of its review, the staff finds that the slope of these duct banks between manholes

and the inspection performed, as required by the applicant's structures monitoring program, are

not adequate to preclude significant moisture for these duct banks and not adequate to prevent

cables from being subject to water trees due significant moisture and significant voltage. The

staff determined that inaccessible medium-voltage cables not subject to 10 CFR 50.49 EQ

requirement AMP at MPS are not consistent with GALL AMP XL.E3. In its letter dated

January 11, 2005, the applicant stated that it has decided to perform testing of a representative

3-60
sample of inaccessible medium-voltage cables. The applicant stated that the following

commitment will be added to its LRA Appendix A, FSAR Supplement Unit 2 Section A2.1.14

and Unit 3 Section A2.1.13:

Sample Testing of Inaccessible Medium-Voltage,

Prior to the period of extended operation, a representative sample of inscope mediumvoltage cables will be tested to demonstrate that water treeing will not prevent the

cables from performing their intended function. This sample testing is in addition to thetesting specified in the previous comrmitmenit. Subsequent testing will be performed on a

frequency not to exceed a 1 0-year interval.''

This commitment is identified in Appendix A, Table A6.0-1 License Renewal

Commitments as Item (34 for Unit 2) (35 for Unit 3).

An additional item will be added to Millstone Power Station Unit 2 and Unit 3 Appendix A FSAR

Supplement, Table A6.0-1 as follows:

Item: 34 (Unit 2) and 35 (Unit 3)

Commitment - In addition to the testing specified in Commitment (33'for Unit 2) (34 for -

Unit 3), a representative sample of in-scope medium-voltage cables will be tested to '

demonstrate that water treeing will not prevent the cables from performing their intended

function.

Source - Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49

Environmental Environmental Qualification Requirements.

Schedule - Prior to Period of Extended Operation Not to Exceed a 10 Year Frequency

Thereafter.

The staff reviewed the applicant response and finds it acceptable because in addition to inspect

manholes and draining water, as needed, the applicant will also test a representative sample of

inaccessible medium-voltage cables which would provide an indication of the condition of the

cable insulation. .

The applicant stated in the LRA that it will enhance the program for inaccessible mediumvoltage cables not subject to 10 CFR 50.49 EQ requirements "scope of program" and 'detection

of aging effects" program elements such that engineering will identify testing requirements, as

necessary, to confirm the condition of the cable insulation for inaccessible medium-voltage

cables having significant voltage and having been submerged. If cables have become

submerged during the period of extended operation,'engineering will evaluate to determine the

appropriate testing, as necessary, .to be performed during the corresponding'ten-year interval.

Any tests performed will be proven tests for detecting deterioration of the insulation due to

wetting. This commitment is identified in Appendix A, Table A6.0-1 License Renewal

commitments, Item 11. ''

The applicant stated in the LRA that the enhancement uses periodic action, such as pumping of

cable vaults to prevent cables from being submerged and inspections to determine that cables

are not submerged. In the event that submerged cables are found, an engineering evaluation

will be performed and the appropriate testing required will be specified, as necessary to confirm

3-:61'
sIII

the condition of the cable insulation. The staff finds that periodic action, as suggested by the -

applicant's program, may not be sufficient as compared to GALL AMP XL.E3. In its letter dated

January 11, 2005, the applicant committed to inspect manholes and test a representative

sample of inaccessible medium-voltage cables to provide an indication of the condition of cable

insulation. The staff reviewed the applicant's response and finds the applicant's response

acceptable.

Operating Experience. The staff reviewed operating experience for the applicant's inaccessible

medium-voltage cables not subject to 10 CFR 50.49 EQ requirements program. The applicant

stated during audit discussion's that there was minimal plant-specific operating experience

regarding the testing of non-environmentally qualified, medium-voltage cables to confirm the

condition of insulation after submergence. The applicant stated that it recently established the

periodic pumping and inspections of cable vaults, manholes, and handholes based on industry

operating experience with submerged cables and the recognition of water treeing as an aging

effect. The operating experience data associated with implementing this aspect of the program

is being addressed in the applicant's corrective action program.

The staffs review of prior operating experience included the applicant's evaluation of condition

reports addressing issues similar to those identified in NRC Information Notice 2002-12,

'Submerged Safety-Related Electrical Cables," dated March 2002. Initial investigations by the

applicant determined that some manholes containing safety-related cables had the potential for

cable submergence. Each unit identified seven manholes with this potential vulnerability. The

Unit 3 manholes had been governed by a preventive maintenance program whereby they were

being routinely inspected and pumped out as necessary. Through this program, the applicant

concluded that the Unit 3 cables had not been submerged.

Unit 2 did not have a similar preventive maintenance program. Therefore the applicant

concluded that the Unit 2 cables in question might have been submerged. To address this

concern, the applicant identified the specific safety-related cables and reviewed the applicable

purchase specifications, manufacturers' specifications, and qualification records. The applicant

also inspected the cables for indications of degradation resulting from submergence, but found

none. The applicant's engineering evaluation determined that the cables were acceptable for

continued use. The applicant added the Unit 2 manholes to a preventive maintenance program

requiring periodic inspection and pumpout (if necessary) of the manholes.

On the basis of its review of the above operating experience, the staff condudes, that the*

applicant's program for inaccessible medium-voltage cables not subject to 10 CFR 50.49 EQ

requirements adequately manages the aging effects that have been observed at the applicant's

plant.

FSAR Supplement. In Appendix A, Section A2.1.14 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.13 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

inaccessible medium-voltage cables not subject to 10 CFR 50.49 EQ requirements program.

The staff reviewed these sections, together with the supplement letters, and determined the

information in the FSAR supplement provides an adequate summary of the program activities.

The staff finds these sections of the FSAR supplement sufficient as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

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are consistent with the GALL program. In addition,'the staff has reviewed the exception and the

associated justifications and determined that the AMP, with' the exception is adequate to

manage the aging effects for which it is credited. Also, the staff has reviewed the enhancement

and confirmed that the implementation of the enhancement prior to the period of extended

operation would result in the existing aging management program being consistent with the

GALL Report AMP to which it was compared.: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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.2.11 Inservice Inspection Program: Containment Inspections

Summary of Technical Information in the ApDlication'. The applicant's inservice inspection

program for containment inspections is described in LRA Section B2.1.16, 'Inservice Inspection

Program: Containment Inspections." In the LRA, the applicant stated that this is an existing

program. This program is consistent, with exceptions, with GALL AMPs XL.SI, 'ASME Section

Xl, Subsection IWE;" XI.S2, "ASME Section Xl, Subsection IWB;" and XI.S4, I10 CFR Part 50,

Appendix J."

The applicant stated in the LRA that the inservice inspection program: containment inspections

program manages the aging effects of change of material properties, cracking, and loss of

material. The program is consistent with the ASME "Boiler and Pressure Vessel Code," Section

Xl, Subsections IWE and IWB, and 10 CFR 50.55a(b)(2), which provide the criteria for inservice

inspections of containment structural components. ASME Section Xl, Subsection IWE specifies

the examination requirements for steel containments (Class MC) and the steel liners of

concrete containments (Class CC), including their integral attachments. ASME Section Xl,

Subsection IWB specifies the examination requirements for reinforced and prestressed

concrete containments (Class CC).

The scope of Subsection IWE and IWB examinations includes the surface areas and

components identified in IWE-1231 and IWB-1210. Exempted or inaccessible areas as allowed

by Subsections IWE and IWB are specifically identified by the program.

The applicant stated in the LRA that the prestressed, post-tensioned concrete'containment is

assessed pursuant to the examination requirements of ASME Section Xi, Subsection IWB, -

Examination Category L-B for unbonded post-tensioning systems.-Examination requirements

similar to those specified in Subsection IWB are also identified in the technical specifications in

order to meet the requirements of Regulatory Guide 1.35, "Inservice Inspection of Ungrouted

Tendons in Prestressed Concrete Containments," Revision 3, dated July 1990.

Appendix J leakage rate testing is included as part of the inservice inspection program:

containment inspections. The program implements Type A tests to measure the overall primary

containment integrated leakage rate. -

Prestress on the Unit 2 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 evaluation of

containment tendon examination and surveillance test results is considered a time-limited aging

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analysis (TLAA) for license renewal. This TLAA is addressed in the Unit 2 LRA, Section 4.5,

and is addressed in Section 4 of this SER.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs evaluation of the audit and review are

documented in the audit and review report. Furthermore, the staff reviewed the exceptions and

their justifications to determine whether the AMP, with the exceptions, remains adequate to

manage the aging effects for which it is credited.

In Appendix B, Section B2.1.16 of the LRA, the applicant stated that the inservice inspection

program: containment inspections is consistent with GALL AMPs XI.S1, XI.S2, and XI.S4, with

exceptions. The inservice inspection program: containment inspections takes exception to the

"scope of program," parameters monitored/inspected," "detection of aging effects," 'monitoring

and trending," and "acceptance criteria" program elements such that GALL AMPs XI.S1 and

XI.S2 cover both the 1992 Edition with the 1992 Addenda and the 1995 Edition with'the 1996

Addenda of ASME Section Xl, as approved in 10 CFR 50.55a. The ASME Section Xl,

Subsections IWE/IWB inservice inspection program complies with ASME Section Xl, 1998

Edition with no addenda. Significant changes have been made to Subsections IWE/IWB

between these respective Code editions.

The staff noted that the ASME Section Xl, Subsections IWE and IWB inservice inspection

program complies with an edition of Section Xi approved by the NRC for use at MPS. The NRC

mandated that all operating reactor licensees bring their Code of record uniformly compliant

with the ASME Section Xl, 1998 Edition with no addenda, which is current with programs such

as the Program Demonstration Initiative (66 FR 40626).

On the basis that the Code edition of record for MPS is a later version of the ASME Section Xl

Code that also meets the intent of the GALL Report, the staff finds the first exception to be

acceptable.

The inservice inspection program: containment inspections also takes exception to the "scope

of program" program element in that the program credits only the Type A integrated leak rate

test to manage the effects of aging. For the program element associated with the second

exception taken by the applicant, the GALL Report states that the scope of the containment

leakage rate testing program includes all pressure-retaining components. Two types of tests

are implemented. Type A tests are performed to measure the overall primary containment -

integrated leakage rate. Type B tests are performed to measure local leakage rates across-.

each pressure-containing or leakage-limiting boundary for containment penetrations. Type A

and B tests described in 10 CFR 50, Appendix J, are acceptable methods for performing. these

leakage rate tests. Leakage testing for containment isolation valves (normally performed under

Type C tests), if not included under this program, is included under leakage rate testing

programs for systems containing the isolation valves.

The applicant stated in the LRA that the inservice inspection program: containment inspections

credits only Type A integrated leak rate testing to manage the effects of aging. However, the

staff noted that the Type B test is a local leak rate test intended to measure leakage of

containment penetrations whose design incorporates resilient seals and gaskets, including air

locks door seals and equipment hatch gaskets. The staff found that not crediting the Type B

test in accordance with the guidance in GALL AMP XI.S.4 was unacceptable and requested

additional clarifications from the applicant regarding how the aging effects on resilient seals and

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gaskets, including air locks door seals and equipment hatch gaskets, will be managed. In an

LRA supplement letter dated July 7, 2004, the'applicant stated the following:

For Unit 2 and Unit 3 Appendix B, Section'B2.1.16 (page B-63), the fourth

paragraph should read: -

"The Containment Appendix J Leakage'Rate Test Program implements Type A

tests to measure the overall primary Containment integrated leakage rate (ILRT)

and Type B tests to detect and measure local leakage across each

pressure-containing or leakage limiting boundary for Containment penetrations,

airlock doors and hatches, whose design incorporates a resilient seal, gasket or

expansion bellows, and for electrical penetrations."

For Unit 2 and Unit 3 Appendix B, Section B2.1.16, Exception 2: XL.S4 - Leak

Rate Testing (page B-67), the exception wording should read:

'The NUREG-1801, Section XI.S4 discusses 10 CFR 50 Appendix J,.Type A

Integrated Leak Rate Testing (ILRT) as well as Type B and C Local Leak Rate

Testing (LLRT). The Inservice Inspection'Program: Containment Inspections

credits only the Type A ILRT and Type B LLRT to manage the effects of aging ' identified in the NUREG-1 801 program element, Detection of Aging Effects.

Program Elements Affected - -

Sco e of Program - -

"This program element identifies three types of leak rate testing (Type A, B and

C) as defined by 10 CFR 50, Appendix J.-The Inservice Inspection Program:

Containment Inspections utilizes only the Type A integrated leak rate testing and

Type B local teak rate tests to manage the effects of aging."

On the basis that the exception, as revised by the supplement letter, credits both Types A and

B testing for management of aging effects for license renewal, the staff finds this exception to

be acceptable.-

Operating Experience. The staff reviewed operating experience for the applicant's inservice

inspection program: containment inspections program. The applicant stated in the LRA that

operating experience indicates that the inspection and corrective action activities have

successfully maintained the integrity of in-scope components. Any degradation of the

containment found during inspections has been noted and corrected, as necessary, to preclude

adverse effects on plant safety and operability. '.

On the basis of its review of the above operating experience, the staff concludes that the

inservice inspection program: containment inspections adequately manages the aging effects

that have been observed at the applicant's plant., -

FSAR Supplement. In Appendix A, Section A2.1.16 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.15 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

inservice inspection program: containment inspections. The staff reviewed these sections and

determined that the information in the FSAR supplement provides'an adequate summary of the:

program activities. The staff finds these sections of the FSAR supplement sufficient, as

required by 10 CFR 54.21(d).

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4

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the exceptions and

the associated justifications and determined that the AMP, with the exceptions is adequate to

manage the aging effects for which it is credited. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.2.12 Inservice Inspection Program: Reactor Vessel Internals

Summary of Technical Information the application. The applicant's inservice inspection

program: reactor vessel internals is described in LRA Section B2.1.17, 'Inservice Inspection

Program: Reactor Vessel Internals." In the LRA, the applicant stated that this is an existing

MPS program. This program will be consistent, with exceptions and an enhancement, with

GALL AMPs XI.M12, "Thermal Aging Embrittlement of CastAustenitic Stainless Steel (CASS),"

XI.M13, "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless

Steel (CASS)," and XI.M16, UPWR Vessel Intemals."

The applicant stated in the LRA that the inservice inspection program: reactor vessel internals

manages the aging effects of loss of material, cracking, loss-of-preload, change in dimension,

and loss of fracture toughness (which presents itself as cracking due to embrittlement) through

the use of inspections. The stainless steel and nickel-based alloy internals components

susceptible to stress corrosion cracking, irradiation-assisted'stress corrosion cracking, primary

water stress corrosion cracking, void swelling, fretting wear, stress relaxation, and neutron

irradiation embrittlement that support the intended function of the reactor vessel in a passive

manner are in scope for this AMP. Reactor vessel internals components made from cast

austenitic stainless steel (CASS) are in scope for this program and additionally are susceptible

to thermal aging embrittlement. The inclusion of CASS components precludes the need for -

susceptibility screening (based on casting method, molybdenum content, and ferrite content) to

determine applicability of the identified aging mechanisms. The reactor vessel internals

components that are in scope for this AMP include the interior of the reactor vessel, integrally

welded core support structure and interior attachments to the reactor vessel, and removable

core support structures. Examinations conducted under the inservice inspection program:

reactor vessel internals include inservice inspections performed in accordance with

ASME Section Xl, Class 1, examination categories B-N-1, B-N-2, and B-N-3 for accessible

reactor vessel internals surfaces, and augmented examinations not required by

ASME Section Xl.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs evaluation of the audit and review are'

documented in the audit and review report. Furthermore, the staff reviewed the exceptions and

the applicant's justifications for the exceptions and enhancement to determine whether the AMP

remains adequate to manage the aging effects for which it is credited. The staffs evaluation of

the exceptions taken by the applicant in the program for the reactor vessel internals program is

given in the paragraphs that follow.

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Exceptions to NUREG-1 801

Exceotion Number 1in LRA, Section 82.1.17. In Appendix B2.1.17 of the LRA, the applicant

took an exception to the staffs position recommending augmented examinations in addition to

the current inspections required by the ISI program. Generally, the staffs positions in Sections

X1.M12, X1.M13, and X1.M16 of NUREG-1801, is to use enhanced volumetric examinations,

enhanced visual VT-1 examinations or perform a plant-specific or component-specific flaw

tolerance evaluations.

The applicant stated that it will not perform these augmented inspections, but will follow the

industry efforts on reactor vessel internals regarding such issues as thermal or neutron

irradiation embrittlement (loss of fracture toughness), void swelling (change in dimensions),

stress corrosion cracking (PWSCC and IASCC), and loss of pre-load for baffle and

former-assembly bolts and will implement the appropriate recommendations resulting from this

guidance. .The EPRI MRP's activities include the issues of thermal or neutron irradiation

embrittlement (loss of fracture toughness),'void swelling (changes in dimensions), and stress

corrosion cracking (PWSCC and IASCC) for the in-scope components. -In addition, the issue of

loss of pre-load for baffle and former assembly bolts for Millstone Unit 3 will also be addressed

by the EPRI MRP activities. Millstone Unit 2 is a Combustion Engineering design and therefore

the aging management of the baffle and former assembly bolts are not applicable. The

applicant will implement these appropriate recommendations and is identified as Commitment

13 in Appendix A, Table A6.0-1 of the LRA.

Since it has been adopted in NUREG-1801, use of industry (EPRI MRP) research studies and

activities on age-related degradation of PWR RV internal components may be used as an

alternative basis for determining which age-related degradation mechanisms are applicable to

PWR RV internals and what types of examinations are necessary to manage these

mechanisms. This is a process-oriented approach to aging management that will ensure that

the inspections proposed for PWR RV internals are those that the industry research studies

have demonstrated are necessary to maintain the structural integrity or functionality of the

components. NRC review of the recommended activities is an integral part of the industry

initiative process.

Therefore, any proposal to use the industry's research studies and activities on RV internals as

the basis for aging management should be coupled with: (1) a formal commitment to submit the

inspection plans for the RV internals to the NRC for review and approval no later than

three years prior to the period of extended operation, and (2) including this commitment in the

Millstone Units 2 and 3 LRAs commitment tracking system. The staff addressed this in RAI

B2.1.17-1 (1) and B2.1.17-1 (2).

In response to RAI B2.1.17-1 (1) in a letter dated December 3, 2004, the applicant provided the

following:

The LRAs for Millstone Units 2 and 3 (Appendix A, Table'A6.0-1, commitment

13) identify that Millstone will follow the industry efforts on reactor vessel

internals regarding such issues as thermal or neutron irradiation embrittlement

(loss of fracture toughness), void swelling, stress corrosion cracking (PWSCC

: and IASCC), and for the Millstone Unit 3 commitment only, loss of pre-load for

the baffle and former-assembly bolts. Dominion provided a supplemental

response applicable to commitment 13 for both Millstone Unit 2 and 3 as

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.1j

documented in the Dominion letter (Serial Number 04-320) dated July 7, 2004,

(Audit Item Number 6). The supplemental response letter identifies the

statement, "The revised program description, including a comparison to the 10

program elements of the NUREG-1801 program, will be submitted to the NRC

for approval," should be inserted at the end of the [current] commitment.

Appendix A, Table A6.0-1 for both the Unit 2 LRA and the Unit 3 LRA already

states that commitment 13 is scheduled to be completed prior to the period of

extended operation. The supplemental response letter also identifies the other

applicable locations in both the Unit 2 LRA and the Unit 3 LRA where this

additional wording should be inserted.

The staff found this commitment unacceptable since the applicant had not specifically

committed to submit the program two years prior to the period of extended operation in order

for the NRC to review and approve the program prior to its implementation at the facility during

the period of extended operation. Therefore, the applicant was requested to revise commitment

13 of Appendix A, Table A6.0-1 of the Millstone Units 2 and 3 LRAs to state that the revised

program implementing the industry efforts on reactor vessel intemals will be submitted to the

NRC for approval "two years" prior to the period of extended operation.

In response to supplemental RAI B2.1.17-1 (1) in a letter dated February 8, 2005, the applicant

has revised commitment 13 of Appendix A, Table A6.0-1 of the Millstone Units 2 and 3 LRAs to

state that the revised program implementing the industry efforts on reactor vessel internals will

be submitted to the NRC for approval two years prior to entering the period of extended

operation. This commitment is acceptable to the staff. This resolves RAI B2.1-17(1).

In response to RAI B2.1.17-1(2) in a letter dated December 3, 2004, the applicant stated that

commitment 13 in LRAs for Millstone Unit 2 and 3 will be included in the commitment tracking

system, as is done for all new licensing commitments. Since the applicant confirmed that the

commitment will be included in the commitment tracking system, the staff finds the proposal to

use the industry's research studies and activities on RV internals acceptable for implementing

into their aging management program and to be submitted to the NRC for approval prior to

entering the extended period of operation. This resolves RAI B2.1.17-1(2).

Exception Number 2 in LRA. Section B2.1.17. The applicant's second exception to NUREG1801, is the use of ASME Section Xl, 1989 Edition with no addenda in lieu of the 1995 Edition

with the 1996 Addenda recommended by GALL AMP XI.M16. However, both editions identify

the same inspections (VT-3) for the applicable ASME Section Xl examination requirements for

Category B-N-3 PWR internals. Therefore, since the inspections are the same, the use of

ASME Section Xl, 1989 Edition with no addenda in lieu of the 1995 Edition with the 1996

Addenda is acceptable to the staff for the PWR vessel internals. It should be noted that these

inspections will be augmented by the industry recommendations guidelines that will be

implemented prior to entering the extended period as discussed above.

Enhancement to NUREG-1801. NUREG-1801, Section IVB2.1-d identifies the use of the ASME

Section Xl Inservice Inspection AMP to manage loss of preload for the core barrel holddown

spring. The applicant proposed an enhancement to the core barrel holddown spring inspection.

Specifically, the augmented inspection of the Millstone Unit 3 core barrel holddown spring will

be performed to detect gross indication of loss of preload. However, in order for the staff to

determine whether this is' an enhancement to the current requirements, the staff required the

applicant to provide the type of inspections to be performed, the inspection frequency and the

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acceptance criteria to justify that these inspections will be will be effective in managing the

aging effects specified in Table 3.1.2-2 of the LRA for the holddown springs. This was

addressed in RAI B2.1.17-2.

In response to RAI B2.1.17-2, in a letter dated December 3, 2004, the applicant stated that the

exact examination method, acceptance criteria and frequency of inspections are in the process

of being determined. Currently, commitment'14 of Table'A6.0-1 of the Millstone Unit 3 LRA

states that the proposed inspection will detect gross indication of loss of-preload as an aging

effect and be performed prior to the period of extended operation. However, the applicant has

stated that as an alternative to performing an augmented inspection, the holddown spring may

be replaced prior to the period of extended operation. Therefore, the applicant will include the

following statement in commitment ;14 of the' Millstone Unit 3 LRA, "As an alternative to

performing an augmented inspection, the holddown spring will be replaced prior to the period of

extended operation." Since the proposed augmented inspection has not be'ddveloped or

approved, -the staff requests the applicant to commit to submit this inspection plan to the NRC

for approval two years prior to entering the extend period or commit to replace the holddown

springs two years prior to entering the extended period.

In response to supplemental RAI B2.1.17-1 (2) in' a letter dated February 8,2005, the applicant

has revised commitment 14 of Appendix A, Table A6.0-1 of the Millstone Units 3 LRA to state

that as an alternative to performing an augmented inspection, the holddown spring will be

replaced at least two years prior to entering the period of-extended operation. This commitment

is acceptable to the staff. This resolves RAI B2.1.17-2.

The staff also requested in RAI B2.1.17-1(3), that the applicant include loss of preload in List of

Commitments, Table A6.0-1 in Appendix A of the Millstone Units 2 and 3 LRA to fully describe

all of the necessary aging effects and their management. In response to RAI B2.1.17-1(3) in a

letter dated December 3, 2004, the applicant stated that for both Millstone Units 2 and 3, loss of

pre-load is an applicable aging effect that is managed by the inservice inspection program:

reactor vessel internals program for bolting used in the reactor vessel. The Millstone Unit 3 LRA'

(Appendix A, Table A6.0-1; commitment 13) identifies that Millstone Unit 3 will follow the'

industry efforts on the loss of pre-load for the baffle and former assembly bolts. This is

applicable to Millstone Unit 3 only since Millstone Unit 2 is a Combustion Engineering design,

and therefore the aging management of the baffle and former assembly bolts is not applicable:

The staff finds this acceptable since the bolting in the reactor vessel intermals for Millstone Units

2 and 3 will be inspected in accordance with the ASME Code, Section Xl, and the baffle and

former assembly bolts in Millstone Unit 3 will have augmented inspections performed. This

augmented inspection will be based on industry'efforts and will be submitted to the NRC for

approval prior to entering the period of extended operation. Since the'pr6posed augmented

inspection had not be developed or approved, the staff requested the applicant to commit to

submit this inspection plan to the NRC for approval three years prior to'entering the period of

extended operation. - ' -

In response to supplemental RAI B2.1.17-1(3) in a letter dated February 8,2005, the applicant

has revised Commitment 13 of Appendix A,'Table A6.0-1 of the Millstone Unit 3 LRA to state

that the revised program implementing the industry efforts on reactor vessel internals, including

the augmented inspection of the baffle and former bolts, will be submitted to the NRC for'

approval two years priorto entering the period of extended operation. This-commitment is

acceptable to the staff. This resolves RAI B2.1.17-1(3).

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NUREG-1801, Sections IVB2.1k, IVB2.5-l, and IVB2.5-h, recommends loss of preload to be

managed by the AMP XI.M1, "ASME Section Xl Inservice Inspection," which correlates to the

applicant's AMP B2.1.18, "Inservice Inspection Program: Systems, Components and Supports."

The applicant stated that AMP B2.1.17, "Reactor Vessel Intemals," will be used to manage loss

of preload/stress relaxation for the clevis insert bolts, upper support column bolts and the lower

support plate column bolts. However, the applicant's AMP B2.2.17, has no requirement for

these bolts. The applicant was requested in RAI B2.1.18-4 to specify the correct AMP as

recommended by NUREG-1 801 or provide the necessary information in AMP B2.1.17.

In response to RAI B2.1.18-4 in a letter dated December 3, 2004, the applicant stated that the

inservice inspection program: reactor vessel intemals, AMP B2.1.17 includes the requirements

for examination category B-N-3 of the ASME Code, Section Xl, Subsection IWB.

Category B-N-3 of Table IWB-2500-1 of the ASME Code includes examination requirements for

removable core support structures (i.e., reactor vessel intemals) including the clevis insert bolts,

the upper support column bolts, and the lower support plate column bolts. This is acceptable to

the staff since these examinations are identical to the examinations recommended by GALL

AMP XI.M1, "ASME Section Xl Inservice Inspection," which correlates to the applicant's AMP

B2.1.18 for these components. Therefore, RAI B2.1.18-4 is resolved.

ODerating Experience. The staff reviewed operating experience for the applicant's inservice.

inspection program: reactor vessel internals program. The review indicated that this program is

in compliance with the inspection requirements of ASME Section Xl and has identified no

issues related to age degradation of in-scope reactor vessel internals components.

On the basis of its review of the above operating experience the staff concludes that the

inservice inspection program: reactor vessel internals adequately manages the aging effects

that have been observed at the applicant's plant.

FSAR Supplement. In Appendix A, Section A2.1.17 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.16 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

inservice inspection program: reactor vessel internals. The staff reviewed these sections and

determined that the information in the FSAR supplement provides an adequate summary of the

program activities. The staff finds these sections of the FSAR supplement sufficient, as

required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the exceptions and

the associated justifications, and determined that the AMP, with the exceptions is adequate to

manage the aging effects for which it is credited. Also, the staff has reviewed the enhancement

and confirmed that the implementation of the enhancement prior to the period of extended

operation would result in the existing aging management program being consistent with the

GALL Report AMP to which it was compared. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

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3.0.3.2.13 Inservice Inspection Program: Systems; Components and Supports

Summary of Technical Information in the A1plication. The applicant's inservice inspection

program: systems, components and supports is described in LRA Section B2.1.18, uInservice

Inspection Program: Systems, Components & Supports." In the LRA, the applicant stated that

this is an existing MPS program. This program will be consistent, with exceptions,'with GALL:

AMPs XI.M1, "ASME Section Xl Inservice Inspection, Subsection IWB, IWC, and IWD," Xl.M3,

"Reactor Head Closure Studs," XI.M11, "Ni-Alloy Nozzles and Penetrations," XI.M12, 'Thermal

Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)," and XI.S3,'"ASME Section Xl

Inservice Inspection, Subsection IWF."

The applicant stated in the LRA that the inservice inspection program: systems, components,

and supports is an existing program that was developed to comply with the requirements of

ASME Section Xi. The ASME Code provides the requirements for inservice inspection, repair,

and replacement of all Class 1, 2,:and 3 components and associated component supports. For

license renewal, the applicant credits managing the effects of aging for only Class I and

specific Class 2 components (on the secondary side of the steam generators as determined

through the AMR process), and for Class 1, 2, and 3 component supports. The applicant's

program manages the aging effects of cracking, loss of fracture toughness, loss of material,

and loss of preload.

The applicant stated in the LRA that the program addresses the inservice inspection

requirements for reactor vessel closure bolting, including those associated with detection of

aging effects and those associated with performing the preventive measures presented in

Regulatory Guide 1.65, "Identification and Characterization of Seismic Sources and

Determination of Safe Shutdown Earthquake Ground Motion," dated March 1997.

ISG-1 2, 'Addition of Generic Aging Lessons Learned (GALL) Aging Management Program

(AMP) XI.M35, 'One-Time Inspection of Small-Bore'Piping,' for License Renewal," dated

November 3, 2003, addresses cracking of small-bore Class 1 piping as a result of thermal

fatigue or stress corrosion cracking. ISG-12 states that for plants that have'not experienced

cracking of small-bore Class 1 piping, a one-time inspection is an acceptable method to confirm

that these aging effects are not occurring. However, if a plant has experienced cracking in

small-bore Class 1 piping resulting from these aging effects, periodic inspections may be

necessary as a plant-specific AMP. The applicant stated that although cracking of small-bore

Class 1 piping from thermal fatigue or stress corrosion cracking has not been a problem, it has

included small-bore piping in the Units 2 and 3 risk-informed inservice inspection (RI-ISI)

programs. Based on risk significance (determined by an evaluation of the consequence of

failure) and on the probability of failure; a volumetric, surface, or VT-2 visual examination is

performed for specific small-bore pipe welds and base metal areas as defined in the

unit-specific RI-ISI inspection plans. These examination methods detect cracking and leakage

resulting from thermal fatigue, cyclic loading, stress corrosion cracking, and primary water

stress corrosion cracking.

Industry programs are currently investigating aging effects applicable to nickel-based alloys

(i.e., primary water stress corrosion cracking in Alloy. 600 base metal and Alloy 82/182 weld

metals) and are attempting to identify appropriate aging management activities to manage

these aging effects. The applicant stated in the LRA that it will follow these industry efforts and

will implement the appropriate recommendations resulting from this guidance. This commitment

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is identified on the applicant's license renewal commitment list in the Unit 2 LRA, Appendix A,

Table A6.0-1, Item 14, and the Unit 3 LRA, Appendix A, Table A6.0-1, Item 15.

The applicant stated in the LRA that 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.

The applicant stated in the LRA that as a result of NRC Bulletin 88-09, "Thimble Tube Thinning

in Westinghouse Reactors," dated July 26, 1988, Unit 3 actively manages incore thimble tube

degradation through performance of eddy current testing during each outage.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs evaluation of the audit and review are

documented in the audit and review report. Furthermore, the staff reviewed the exceptions and

their justifications to determine whether the AMP, with the exceptions, remains adequate to

manage the aging effects for which it is credited.

The applicant describes the reactor head closure stud program in LRA Section B2.1.18,

"Inservice Inspection Program: Systems, Components and Supports." The applicant's

discussion in LRA Section B2.1.18, "Inservice Inspection Program: Systems, Components and

Supports," indicates that the inservice inspection program incorporates program attributes from

GALL AMPs XI.M1, "ASME Section Xl Inservice Inspection, Subsection IWB, IWC, and IWD;"

XI.M3, 'Reactor Head Closure Studs;" AMP XI.M1 1, "Nickel Alloy Nozzles and Penetrations;"

XI.M12, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS);" and XI.S3,

"ASME Section Xl, Subsection IWF," and include discussions on thimble tube inspection and

mechanical nozzle seal assemblies.

The applicant stated in the LRA that the ASME Class 2 and Class 3 components that are not in

the scope of this AMP will continue to be inspected during the period of extended operation as

part of the ASME Section Xl inservice inspection program. However, the staff noted that the

applicant has opted to use other appropriate preventive and condition monitoring programs,

such as the general condition monitoring, to manage the effects of aging for these components.

The applicant stated that this program is an existing program that is consistent with the GALL

Report, with exceptions that will be discussed in the evaluation below. This AMP will be

reviewed in subsections that correspond to the incorporated NUREG-1801 AMPs discussed

above to determine if they are consistent and provide the necessary information to manage the

appropriate aging effects such that there is reasonable assurance that their intended functions

will be maintained.

ASME Section Xl Inservice Inspection (GALL AMP XI.M1)

Staff Evaluation. The applicant describes the ASME Section Xl Inservice Inspection, Subsection

IWB, IWC, and IWD program in LRA Section B2.1.18, 'Inservice Inspection Program: Systems,

Components and Supports." The aging effects that are managed by this AMP include cracking,

loss of fracture toughness, loss of material, and loss of pre-load. This AMP, is an existing

program that was developed to comply with the requirements of Section XI of the ASME Boiler

and Pressure Vessel Code. The ASME program provides the requirements for ISI, repair, and

replacement of all Class 1, 2, and 3 components and the associated component supports. For

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license renewal, the Millstone program has been credited to manage the effects of aging for

Class 1, specific Class 2 components, and the'Class 1, 2, and 3 component supports. The

applicant stated that this program is consistent with GALL AMP XI.M1, with exceptions.

Exception Number 1: XI.M1 - Risk-informed Inservice Inspection

GALL AMP XI.M1 does not currently recognize'risk informed - inservice inspection (RI-ISI)

programs as an alternative to the current ASME Section Xl inservice inspection requirements.-

Millstone Unit 2 has submitted a request to implement a Rl-ISI program by letter dated

November 10, 2003. The Unit 3 RI-ISI program was approved by the staff by letter dated March

12, 2002. The RI-ISI program is applicable to the nondestructive examination (NDE)

requirements for ASME Section Xl Examination Category B-F and B-J welds and, for Unit 3

only, base metal locations. (Note: The RI-ISI analysis performed at Millstone Unit 2 identified no

base metal locations that were considered to be potentially susceptible to thermal fatigue.) For

these locations, examination requirements are determined on a component-specific basis.

Pressure tests and VT-2 visual examinations shall continue to be performed -as currently

required by the Code. While the number of examinations is reduced, the risk from - -

implementation of this program is expected to slightly decrease when compared to that

estimated from the current requirements., The primary basis for the'risk reduction is that

examinations will be required for safety significant piping segments, which may not be currently

inspected per the existing ASME Section Xl program. In addition, the RI-ISI program is a living

program that requires updating and expansion based on industry and site specific inspection

findings. At present, a RI-ISI program is approved for use on an ASME Code 10-year ISI

interval specific basis. Therefore, the applicant will have to request approval to use the Rl-ISI

program for the specific intervals during the period of extended operation in accordance with

the appropriate ASME Code of record for the fifth and sixth ISI intervals, as referenced in

10 CFR 50.55a twelve months prior to each interval. Therefore, the staff finds that the ASME

Code Section Xl, as referenced in 10 CFR 50.55a, twelve months prior to each inspection

interval of extended operation, as modified by a staff approved or authorized RI-ISI program, is

acceptable for the period of extended operation.-.

Since the V.C. Summer 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.- 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, .PWR!Materials Reliability Project Interim Alloy 600

Safety Assessment for US PWR Plants (MRP44),; Part 1:'Alloy 82/182 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.' These industry initiatives

and/or regulatory requirements will supersede the RI-ISI program requirements for dissimilar

metal welds. -

The inservice inspection program: systems,-components and supports also takes exception to

the "scope of the program," 'parameters monitored/inspected," "detection of aging effects," and

"monitoring and trending" program elements such that for the Units 2 and 3 Class 1

examination category B-F and B-J type welds and, for Unit 3 only, base metal locations,

inspection, examination, and additional examination requirements have been developed on a

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--I

component-specific, risk-informed basis as part of an integrated approach for risk-informed

analyses. For the program elements associated with the second exception taken by the

applicant, the GALL Report, in GALL AMP XI.M1, stated that the program element refers to

ASME Section Xl, Table IWB-2500-1 for the identification of examination and inspection

requirements for Class 1 components. The examination methods are based on the

requirements in ASME Section Xl, Table IWB-2500-1 for Class 1 components. The inspection

extent and frequency are based on IWB-2500, which provides for timely detection of

degradation for Class 1 components. Indications during examination which exceed acceptance

standards are to be extended to include additional examinations in accordance with IWB-2430

for Class 1 components.

The applicant stated in the LRA that Unit 2 has submitted a request to implement an RI-ISI

program and Unit 3 has received approval from the NRC to implement an RI-ISI program. The

process of developing the scope for the RI-ISI programs includes not only an evaluation of risk

significance and failure probability, but also considers operating experience. RI-ISI

implementation will reduce the risk and failure probability. The inspection and examination

requirements, examination methods, and inspection extent and frequency are determined on a

component-specific, risk-informed basis as part of an integrated approach for risk-informed

analyses. The staff reviewed the Unit 3 RI-ISI program plan, and determined that the reduction

in risk provides sufficient justification for this exception.

Reactor Head Closure Studs Program (GALL AMP XI.M3)

Staff Evaluation. The applicant describes the Reactor Head Closure Stud program in LRA

Section B2.1.18, 'Inservice Inspection Program: Systems, Components and Supports." The

aging effects that are managed by this AMP include cracking, loss of fracture toughness, loss

of material and loss of pre-load. This AMP addresses the inservice inspection requirements for

the reactor vessel closure bolting, including inservice inspection to detect aging effects and

preventive measures of Regulatory Guide 1.65, "Materials and Inspections for Reactor Vessel

Closure Studs," to mitigate cracking. The applicant stated that this program is consistent with

GALL AMP XL.M3 with some exceptions, discussed in the evaluation below (Section 3.1.2.3.3.2

of this SER).

Exception Number 3 in LRA. Section B2.1.18. The applicant stated that Millstone Unit 3

complies with ASME Code Section Xl, 1989 Edition with no addenda. GALL AMP XL.M3

describes a reactor head closure stud program that is, in part, based upon the 1995 Edition of

the Code through the 1996 addenda. The 1995 Edition of the ASME Code through the 1996

addenda requires a visual (VT-1) examination of the closure head studs. The 1989 Edition to

the ASME Code with no addenda requires a surface examination (e.g., magnetic particle, or

liquid penetrant). Therefore, the Millstone Unit 3 inservice inspection plan specifies a surface

examination (e.g., magnetic particle, or liquid penetrant) in accordance with the requirements of

the 1989 ASME Code Edition in lieu of a visual (VT-1) examination of the surface of the closure

head nuts. The examination method for nuts used in other Class 1 components, such as steam

generators, pressurizer, heat exchangers, piping, pumps and valves, has always been a VT-1

visual examination. Therefore, the 1995 Edition of the Code through the 1996 addenda is

consistent with the examination method used for the other Class 1 components. The 1995

Edition of the Code through the 1996 addenda also included a more detailed acceptance

standard for the VT-1 visual examination, thereby making the visual examination comparable to

the surface examination. Therefore, the surface examination is comparable to the visual

examinations required by the later editions of the ASME Code. In addition, the surface

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examination is a well-qualified examination method that is widely used to detect cracking in

ASME Code components and therefore, the 'staff finds the use of the surface inspection to the

ASME Code Section Xl, 1989 Edition with no addenda acceptable.

Exception Number 4 in LRA. Section B2.1.18.:The applicant stated that the closure studs at

Millstone Unit 2 are consistent with the recommendations of Regulatory Guide 1.65, except that

the material requirements used for the corresponding nuts and washers are in accordance with

ASTM A540, Grade B-23 in lieu of ASME SA 540, Grade B-23 material identified in Regulatory

Guide 1.65. Based on the review of these material specifications, the materials chemical and

mechanical properties are the same. Therefore, the staff finds this exception to be acceptable

since it uses material similar to the regulatory guide requirements.'

In addition, Section B2.1.18 of the LRA stated that Millstone Unit 2 complies with ASME Code

Section Xl, 1989 Edition with no addenda. GALL AMP XI.M3 describes a reactor head closure

stud program that is, in part, based upon the 1995 Edition of the Code through the 1996

addenda which requires a visual (VT-1) examination on the surfaces of the closure head nuts.

Although Millstone Unit 2 complies with the 1989 Edition of the ASME Code, relief was granted

from performing the surface examination of the nuts as required by the 1989 Edition. Thus,

Millstone Unit 2 performs a visual examination. This is acceptable to the staff in that this is the

inspection identified by GALL AMP XI.M3 and the 1995 Edition of ASME Code through the :

1996 Addenda. Therefore; the applicant is performing the inspections as'required by the ASME

Code to manage the aging effects of the closure studs, nuts and washers.

NUREG-1801 indicates that reactor head closure studs are susceptible to loss of material due

to wear and to crack initiation and growth due to stress corrosion cracking (SCC). GALL -

recommends Chapter XI.M3, 'Reactor Head Closure Studs" program as a program acceptable

for mitigating and monitoring these aging effects. This program relies on ASME Code Section

Xl, Subsection IWB to monitor and detect this aging effects. Preventive measures identified in

the GALL program include avoiding the use of.metal-plated stud bolting to prevent degradation

due to corrosion or hydrogen embrittlement and using manganese phosphate or other

acceptable surface treatments and stable lubricants'(RG 1.65). In RAI B2.1.18-5,'.the staff

requested that the applicant provide the operating experience of the reactor vessel closure

studs, including the use of coatings or lubrication, and what degradation, if any, that was found

during these inspections with the corresponding corrective actions.

In response to RAI B2.1.18-5 in a letter dated December 3, 2004, the applicant provided the

following: ;

Millstone Unit 2 uses ASME SA 540, Grade B-24 as the material for the vessel

studs, with a manganese phosphate coating on the studs.'ASTM A 540, Grade

B-23 material is used for the reactor vessel closure nuts and washers, and

* parkerizing". (manganese phosphate) is the specified coating. The bolting is

lubricated at installation with Fel-Pro-N-5000, a nickel-based,-anti-seize lubricant,

which can be used in applications with a dry surface temperature as high as

2400 *F.

For Millstone Unit 3, the reactor vessel 'closure bolting is fabricated from ASME

SA-540 material. The closure studs are Grade B-24 material and the nuts and

washers are Grade B-23 material. A-phosphate coating is applied to the bolting.

In accordance with a design modification, the threaded portions of the studs

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have a PlasmaBond coating applied in lieu of the original phosphate coating.

PlasmaBond is a Nickel-Silver/Palladium coating using a vapor deposition

process that eliminates the potential for hydrogen embrittlement. This newer

anti-galling coating was added to provide for lubrication, and has no adverse

metallurgical interactions. This coating is fully endorsed by Westinghouse for use

on vessel head closure studs. Application of Fel-Pro-N-5000 is not needed when

vessel closure studs have been PlasmaBond coated.

As recommended by Regulatory Guide 1.65, plugs are installed in the empty

stud hole cavities following stud removal during refueling for both Millstone Unit 2

and 3 in order to provide protection against contamination and corrosion.

Nondestructive examinations are performed to comply with the requirements of

ASME Section Xl, Subsection IWB. To date, no age related degradation has

been identified for the vessel closure bolting for either Millstone Unit.

For Millstone Unit 2, the applicant follows the recommendations of RG 1.65. However, for

Millstone Unit 3, the staff notes that the response to- RAI B2.1.18-5 stated that the closure

bolting for Unit 3 uses Plasma Bond coating (Nickel-Silver/Palladium). RG 1.65 stated that

silver plated studs had severe galling and severe corrosion damage in the thread roots of the

studs at LaCrosse (BWR) and Yankee Rowe. Therefore, in accordance with RG 1.65, section

C.1.b(3), the applicant should demonstrate that the plating will not degrade the quality of the

material in any significant way (e.g., corrosion, H2 embrittlement) or reduce the quality of

results attainable by the various required inspection procedures.

In response to supplemental RAI B2.1.18-5 in a letter dated February 8, 2005, the applicant

stated that the use of PlasmaBond coating was applied to the threaded portions of the studs as

an alternative to the phosphate coating. The PlasmaBond coating was developed and tested by

the Millstone Unit 3 NSSS vendor (Westinghouse) for use on vessel head closure studs andother locations such as steam generator manway studs. This newer anti-galling coating was

added to provide for enhanced lubrication. The coating has no adverse metallurgical

interactions and will not affect the base metal physical properties. The applicant also stated that

industry experience includes the use of the PlasmaBond coating for reactor vessel studs at

Comanche Peak, Units 1 and 2, Catawba Unit 2, Beaver Valley Units I and 2, and Seabrook

without any issues. Comanche Peak has had the most operating experience with PlasmaBond,

which included six operating cycles without any degradation of the studs due to the

PlasmaBond coating; In addition, Millstone Unit 3 has inspected the closure studs with the

PlasmaBond coating and found no indications from the volumetric or magnetic particle

examinations performed during their inservice inspection program.

PlasmaBond is a Nickel-Silver/Palladium coating that uses a vapor deposition process in lieu of

an electrolytic process.,Therefore, there is no hydrogen generation and no potential for

hydrogen embrittlement of. the fastener. The applicant also stated that this improved anti-galling

coating is an approved coating recommended by Westinghouse and does not increase -

corrosion attack or introduce any new material degradation mechanisms. The PlasmaBond

coating process precludes degradation due to hydrogen embrittlement, has no effect on

ultrasonic, magnetic particle, or dye penetrant inspection techniques, and will not mask any

defects. The staff finds this response acceptable since it addressed the requirements of RG

1.65, and demonstrated that this coating does not degrade the quality of the material through

mechanisms such as corrosion or hydrogen embrittlement or reduce the quality of the required

inspection. This resolves RAI B2.1.18-5.

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NUREG-1 801, Sections IVB2.1k, IVB2.5-l, and IVB2.5-h, recommends loss of preload to be

managed by the AMP Xl.M1, "ASME Section XI Inservice Inspection," which correlates to the

applicant's AMP B2.1.18, "Inservice Inspection Program: Systems, Components and Supports."

The applicant stated that AMP B2.1.17,"Reactor Vessel Intemals," will be used to manage loss

of preload/stress relaxation for the clevis insert bolts, upper support column bolts and the lower -

support plate column bolts. This issue was discussed and resolved in Section 3.0.3.2.1 of this

SER.

Nickel Alloy Nozzles and Penetrations (GALL AMP XI.M11)

Summary of Technical Information. In Section B2.1.18 of Appendix B of the LRA, the applicant

addressed Nickel Alloy Nozzles and Penetrations and stated it is consistent with NUREG 1801,

Section Xl.M11 with an exception.- -

Exception Number 6: XI.M1 1 - Reactor Vessel Top Head Inspections.

GALL-AMP XI.M1 1 references the development of an industry wide integrated, long-term

inspection program based on industry responses to Generic Letter (GL) 97-01 as contained in

NEI correspondence. However, since the issuance of GL 97-01, significant operating

experience has been gained and corresponding staff guidance has been issued to better

characterize and address the PWSCC of nickel alloys issue.

In response to the more recent staff guidance'such as'NRC Bulletins 2002-01 and 2002-02,

Millstone Unit 2 has performed vessel top head examinations during its most recent refueling

outages to assess the overall condition of the reactor vessel head. The head inspections are

further discussed in the "Operating Experience" section of this program. '

Staff Evaluation. In accordance with 10 CFR 54.21 (a)(3), the staff reviewed the nickel alloy

nozzles and penetration program to determine if the program demonstrates 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.

The staffs original basis for inspection nickel-based reactor vessel head (RVH) penetration

nozzles in U.S. PWRs is provided in GL 97-01,'"Degradation of Control Rod Drive Mechanism

Nozzle and Other Vessel Head Penetrations," issued on April 1, 1997. Between November

2000 and April 2001, reactor coolant pressure boundary leakage was identified from the RVH

penetration nozzles of four U.S. PWR-designed light water reactor facilities. Supplemental

examinations of the degraded nozzles indicated the presence of circumferential cracks in four -

of the RVH nozzles. These cracks initiated from the'outer surface of the nozzle, either in'the '

associated J-groove weld or heat-affected-zone, and not from the inside surface of the nozzle,

as was assumed in the industry responses to NRC GL 97-01. These cracks penetrated through

the nozzles and were identified as circumferential cracking. In NRC Bulletin 200101,

"Circumferential Cracking of Reactor Pressure Vessel Head Penetratiori'Nozzles," issued on

August 3, 2001, the staff discussed the generic safety significance and impacts of these cracks

on RVH penetration nozzles and recommended that enhanced visual examinations or

volumetric examination methods be used for the inspection of RVH nozzles.

A;~~~ . ~ ', .; _- * ! . ' . . .

In March 2002, during a refueling outage at the Davis-Besse Nuclear Power Station, the

licensee for the plant reported the occurrence of reactor coolant leakage from RVH penetration

3-,77
4.'

nozzles. As a result of follow-up evaluations of the reactor coolant leakage, the licensee

reported that the leakage resulted in significant boric-acid-related wastage of the RVH. The -

wastage affected the entire thickness of the RVH with the exception of the RVH cladding

(stainless steel). On March 18, 2002, the NRC issued. NRC Bulletin 2002-01, "Reactor Pressure

Vessel Head Degradation and Reactor Coolant Pressure Boundary Integrity," to owners of

PWR designed plants, requesting that EH licensee's address the impact of the Davis-Besse

event on the structural integrity of their RVHs and associated penetration nozzles. On August 9,

2002, the staff issued NRC Bulletin 2002-02, "Reactor Vessel Head and Vessel Head

Penetration Nozzle Inspection Programs," to address additional technical issues resulting from

the Davis-Besse event. In NRC Bulletin 2002-02, the staff specifically suggested that further

augmented inspections, more comprehensive than those suggested in NRC Bulletin 2001-01,

be performed on RVH penetration nozzles. On February 11, 2003, the staff issued Order EA- -

03-009, "Issuance of Order Establishing Interim Inspection Requirements for Reactor Pressure

Vessel Heads at Pressurized Water Reactors," to further define to the licensee's the frequency

and extent of inspection of the RPV head nozzles. On August 21, 2003, the staff issued NRC

Bulletin 2003-02, "Leakage form Reactor Pressure Vessel Lower Head Penetrations and -

Reactor Coolant Pressure Boundary Integrity," to advise licensee's that RPV lower head

inspections may need to be supplemented with additional measures to assure that the RCPBI

leakage is detected. On February 20, 2004, the staff issued First Revised Order EA-03-009, to

modify the inspection requirements for reactor pressure vessel heads at pressurized water

reactors.

The applicant stated that Millstone will follow the industry efforts investigating the aging effects

applicable to nickel-based alloys (i.e., PWSCC in Alloy 600 base metal and Alloy 82/182 weld

metals) and identifying the appropriate aging management activities and will implement the

appropriate recommendations resulting from this guidance. This commitment is identified in

Appendix A of the LRA, Table A6.0-1 License Renewal Commitments, Item 14 for Unit 2 and

Item 15 for Unit 3.

In RAI B2.1.18-1 the staff requested that the applicant modify its commitment to state that the..

aging management activities to monitor the aging effects of nickel-based alloys will be

submitted three years prior to the period of extended operation in order for the staff review and

approval to determine if the program demonstrates the ability to manage the effects of aging in

nickel-based components per 10 CFR 50.54.21(a)(3). In addition, the applicant needs to

address how nickel-based components will be evaluated in terms of susceptibility to PWSCC.

The applicant, by letter dated December 3, 2004, modified its commitment to submit its

program prior to the period of extended operation for staff review and approval. The applicant's

response did not meet with the staff's request to submit the program three years prior to the

period of extended operation to allow the staff time to review and approve the program. This

was identified as Confirmatory Item 12.1.18-3.

In response to Confirmatory Item 82.1.18-3, in a letter dated April 1, 2005, the applicant stated

that in LRA Appendix A "FSAR Supplement," Sections A2. 118 and A2.1.22 for Unit 2 and

Sections A2.1.27 and A2.1.21 for Unit 3, the commitment to follow industry efforts regarding

nickel-based alloys has been modified to read:

The revised program description will be submitted at least two years prior to the period

of extended operation for staff review and approval to determine if the program

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demonstrates the ability to manage the effects of aging in nickel-based components per.

1 0 CFR 54.21 (a)(3).

Additionally, the schedule for Table A6.0-1, Commitment 14 (Unit 2) and 15 (Unit 3), in LRA

Appendix A will be changed to:.

At Least Two Years Prior to the Period of Extended Operation.

Based on this revised commitment, Confirmatory Item B2.1 .18-3 is closed.

Thermal Aging Embrittlement of CASS (GALL AMP XI.M12)

Summary of Technical Information in the Application. In Section B2.1 .18 of Appendix B of the

LRA, the applicant stated that the AMP 'Inservice Inspection Program:,Systems, Components.

and Supports" is consistent with the NUREG 1801 AMP Xl.M12, Thermal Aging Embrittlement

of Cast Austenitic Stainless Steel (CASS).

Staff Evaluation. The applicant stated in Section B2.1.18 of Appendix B of the LRA that the

potential for thermal aging embrittlement of CASS components is addressed through the

performance of plant-specific or component-specific evaluations in accordance with Section

Xl.M12 of NUREG-1801,,to assess whether the-ma'terial has adequate fracture toughness. This

is consistent with thie NUREG-1IB0l screening for 'susceptibility to thermal aging embrittlement

of CASS piping. -NUREG-1801 does -not require additional inspections beyond those required by

the ASMECode for pump casings and valve bodies and the ASME Code Case N-481 for pump

casings. If CASS piping is not susceptible, then no additional inspections are required. ,,

However, susceptible CASS piping is required to beinspected by anenhanced volumetric

examination to detect and size cracks. Therefore, the applicant was requested in RAI B2.1 .18-6

to update the AMP to include the necessary inspections recommended by NUREG-1801 for

CASS piping that are found to be susceptible (inadequate fracture toughness).

In response to RAI B2.1 .18-6 in a letter datedDecember 3, 2004, the applicant stated that the

following information wiill be added to the inservice inspection program: systems, components

and suppor~t~s aging ma'nagement program (AMP B2.1 .18) to assure that the necess'ary

inspections will be performed for CASS piping that are found to be susceptible to thermal aging

embrittlement: "-

For potentially susceptible CASS materials, either enhanced volumetric

examinations or. a unit specific flaw tolerance evaluation considering reduction in

fracture toughness and using specific geometry and stress information will be

used to demonstrate that the thermally embrittled material has adequate

toughness in accordance with NUREG-1801, Section XILM12, April 2001. This

commitment is identified in the FSAR Supplement, Table A6.0-1 License

Renewal Commitments, Item 27.for Unit 2 and Item 28 for Unit 3

The staff finds this response acceptable because the applicant has included the necessary

management for thermal aging embrittlement of CASS components by an enhanced volumetric

examination or a plant-specific flaw evaluation as recommended by NUREG -1 801, Section

XI.M12. This resolves RAI B2.1.18-6..

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1

ASME Section Xi, Subsection IWF (GALL AMP XL.S3)

Staff Evaluation. GALL AMP XI.S3 recommends specific percentages of Class 1, 2, and 3

ASME Section Xl, Subsection IWF supports to be examined at each inspection interval that are

based on later editions of the ASME Code than that used to develop the MPS inservice

inspection program. When asked by the staff to justify the use of the earlier edition of the Code,

the applicant stated that the percentages of MPS Units 2 and 3 Subsection IWF supports

examined by the MPS AMP are based on ASME Code Case N-491-1 (Table -2500-1), which

establishes the same percentages as those in the later editions of the Code and acceptable in

the GALL Report. The applicant stated in the MPS LRA, that ASME Code Case N-491 was

used to obtain a relief request for IWF supports examinations. The staff reviewed the

applicant's internal document and identified that ASME Code Case N-491-1 was used to obtain

a relief request. To clarify this, the applicant submitted an MPS LRA supplement letter, dated

July 7, 2004, which stated that the revision for the referenced ASME Code Case, 'N-491"

should be replaced with "N-491-1" in MPS Unit 2 and Unit 3 Appendix B, Section B2.1.18 (page

B-76). The staff finds this to be acceptable.

Thimble Tube Inspection

The staff's regulatory basis for establishment of the applicant's the Flux detector thimble

inspection program is given in NRC Bulletin (BL) 88-09, Thimble Tube Thinning in

Westinghouse Reactors [July 26, 1988], which was addressed to all holders of operating

licenses or construction permits for Westinghouse-designed nuclear reactors that utilize bottom

mounted instrumentation nozzles. In this Bulletin, the staff requested, in part, that each licensee'

addressed by the Bulletin establish an inspection program for flux detector thimble tubes

(henceforth referred to as 'thimble tubes") with the following program attributes:

(1) The establishment, with technical justification, of an appropriate thimble tube wear

acceptance criteria (for example, based on percent through-wall loss). The staff

recommended that the acceptance criteria include allowances for such items as

inspection methodology and wear scar geometry uncertainties.

(2) The establishment, with technical justification, of an appropriate inspection frequency

(for example, every refueling outage).

(3) The establishment of an inspection methodology that is capable of adequately detecting

wear of the thimble tubes (such as eddy current testing).

Summary of Technical Information in the Application In Section B2.1.18 of Appendix B of the

LRA, the applicant stated that as a result of NRC Bulletin 88-09, Millstone Unit 3 actively

manages incore thimble tube degradation through performance of eddy current testing during

each refueling cycle.

Staff Evaluation. In LRA Section B2.1.18, "Inservice Inspection Program: Systems,

Components and Supports," the applicant specified eddy current inspections to manage the

integrity of the incore neutron monitoring thimble tubes, which serve as a portion of the reactor

coolant pressure boundary. As discussed in NRC Bulletin 88-09, "Thimble Tube Thinning in

Westinghouse Reactors," July 26, 1988, thimble tube wall-thinning can occur as a result of flowinduced vibration. This wear damage is detected at locations associated with geometric

discontinuities or area changes along the reactor coolant flow path, such as areas near the

lower core plate, the core support forging, the lower tie plate, and the vessel penetrations.

I

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To determine the acceptability of this AMP, as recommended by NUREG-1 801, Section IV

B2.6-c, the acceptance criterion, with technical justification, (e.g., percent through-wall loss, and

wear scar geometry uncertainty) needed to be submitted to the staff. In addition, the applicant

was requested in RAI B2.1.18-8 to provide the scope (the number of total tubes and the percent

of the tubes inspected) of the eddy current inspections. The NRC staff also asked that the

operating experience of the thimble tubes be provided.

In response to RAI B2.1.18-8 in a letter dated December 3, 2004, the applicant provided the

following: -

The structural acceptance criterion for the Millstone Unit 3 BMI flux thimble tubes

is 80 percent wall thinning, as determined by current and previous readings

conservatively projected to the time of the next inspection. The 80% acceptance

figure includes significant margins against structural failure, and is based on

evaluations and testing documented in Westinghouse proprietary report WCAP12866, "Bottom Mounted Instrumentation Flux Thimble Wear," dated January

1991. Thimbles that do not meet the acceptance standards are either capped or

replaced. The eddy current calibration standard includes the most severe wear

scar geometries, such that readings of actual flaws with less severe geometry

are conservative. Therefore no adjustment for postulated wear scar geometry is

required. Although the WCAP states that " .Z it is not necessary to add additional

uncertainty margin to the eddy current wall loss indications...," an instrument

uncertainty of 3% is assumed. This value is conservative based on the scatter in

data observed at Millstone for the highly worn thimbles.

There are a total of 58 BMI flux thimble tubes and currently 100% inspection is

performed each outage. The frequency of future inspections may be adjusted,

for example, if highly worn tubes are replaced with wear resistant material and

the remaining thimbles can be shown to meet acceptance criteria for multiple

cycles. To date, fourteen BMI flux thimble tubes have been repositioned and four

have been capped because they might not have met the acceptance criterion

prior to the next inspection.

The applicant's response demonstrates that the applicant is taking acceptable corrective

actions for thimble tubes that are projected to wear beyond the acceptance criterion prior to the

next inspection. Since the applicant is using the Millstone Unit 3 eddy current test (ECT) results

to project the amount of wear occurring in the Millstone Unit 3 thimble tubes, and since the

applicant is taking acceptable corrective action for thimbles tubes that are unacceptable for

further service, the staff concludes that the inspection of the Millstone Unit 3 thimble tubes

every refueling outage is acceptable.

In NRC BL 88-09, the staff requested each licensee "to establish an inspection program to

monitor thimble tube performance, that includes the establishment, with technical justification,

of an appropriate thimble tube wear acceptance criterion (for example, percent through-wall

loss)."

The staff reviewed Proprietary WCAP-1 2866 and determined that the acceptance criterion in

the topical report was based on conservative burst tests on Westinghouse thimble tube designs

that support an 80 percent through-wall acceptance criterion for the thimble tubes at Millstone

Unit 3. This value includes an additional safety margin established by Westinghouse for

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allowable wear in the thimble tube. This safety margin, however, does not include an allowance

for instrument uncertainties, which, as a percentage of the wall thickness, must be accounted

for by either adding it to the eddy current testing (ECT) wear result data or subtracting it from

the acceptance criterion.

As indicated in its response to RAI B1.1.18-8 discussed above, the applicant accounted for the

instrument uncertainties of three percent in its wear assessments for the thimble tubes by

adding the instrument uncertainties to wall measurement data after the ECT examinations have

been performed. This is acceptable. The staff concludes that the applicant's 80 percent

through-wall acceptance criterion is acceptable because it is based on conservative burst tests

for the thimble tubes and because it includes an acceptable safety margin on allowable wear.

Therefore, the staff concludes the acceptance criteria for the flux thimble inspection program is

acceptable and RAI B2.1.18-8 is resolved.

Table 3.1.2-1 of the Millstone Unit 3 LRA identified the BMI Flux Thimble Tubes and BMI guide

tubes as being susceptible to cracking from SCC. The aging management programs for

cracking of the BMI flux thimble tubes and BMI guide tubes includes water chemistry and AMP

B2.1.18, 'Inservice Inspection Program: Systems, Components and Supports" of the LRA.

However, the thimble tube inspections were initially designed to inspect for wear in the thimble

tubes and NUREG-1 801, Section IVB2.6-a recommends the use of the PWR Vessel Internals

AMP to manage cracking in the guide tubes. Details of these inspections including scope,

examination method, acceptance criteria, and examination frequencies were not included in

AMP B2.1.18 of the LRA. Since the OD surface of the thimble tubes is exposed to the same

environment as the ID surface of the guide tube and both components are fabricated from

stainless steel they would both be susceptible to SCC. Therefore, the staff requested in RAI

B2.1.18-3 that the applicant provide the types of inspections that will be performed to manage

cracking in the thimble and guide tubes, along with a discussion on why these types of

inspections, their frequency and inspection criteria will be effective in managing cracking.

Operating experience of cracking in these tubes and any resulting replacements was also to be

provided.

In response to RAI B2.1.18-3 in a letter dated December 3, 2004, the applicant provided the

following:

Although the thimble tubes are inserted into the core, the BMI Flux Thimble

Tubes and the BMI Guide Tubes identified in Unit 3 LRA Table 3.1.2-1 are not

reactor vessel internals component[s] and the inservice inspection program:

reactor vessel internals AMP is not applicable for management of the associated

aging effects for these components.

The BMI flux thimble tubes (corresponding to NUREG-1801 item IV.B2.6.2) are the

in-core flux detector thimble tubes and are the subcomponents that are inserted and

extracted from the core area through the 58 reactor vessel bottom head penetrations.

The 5/16" OD BMI flux thimble tubes are exposed to the reactor coolant pressure

externally and are loaded in compression in service. This compressive load combined

with the small surface area does not result in a significant stress component for SCC to

occur in the BMI flux thimble tubes. However, cracking due to SCC has been

conservatively applied as an aging effect to the BMI flux thimble tubes. Aging

management for cracking is provided by the chemistry control for primary systems

program AMP in order to minimize potential contaminants. Additional aging

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management is provided by crediting the existing inspection of the seal table pressure

boundary during each refueling outage via the inservice inspection program: systems,

components, and supports AMP.

The BMI guide tubes (no corresponding NUREG-1801 item) are the guide tubes

in which the BMI flux thimble tube travels. The stainless steel BMI guide tubes

extend from the seal table to the nickel-based alloy instrument tubes that are

attached to the reactor vessel bottom head.-This configuration results in a

significant temperature reduction in theBMI guide tubes from RCS operating

temperature, which greatly reduces susceptibility of the stainless steel material to

SCC. Based on service temperature, the most susceptible location for cracking

due to SCC in the BMI tubes is the interface weld between the BMI guide tubes

and the [Instrumentation Tubes (bottom head)] in Table 3.1.2-1. This weld is

inspected as part of the inservice inspection program: systems, components,

and supports AMP and provides a leading indicator for BMI guide tube cracking.

The reduced temperature, along with control of contaminants provided by the

chemistry control for primary systems program AMP, reduces the potential for

stress corrosion cracking of the BMI guide tubes.

There have been no instances of cracking found in the Millstone Unit 3 BMI flux

thimble tubes or the BMI guide tubes.,-;

The applicant's response credits the water chemistry AMP for controlling contaminants to

reduce the potential of stress corrosion cracking in the flux thimble tubes and the guide tubes.

For the flux thimble tubes, the applicant also credits the existing inspection of the seal table

pressure boundary during each refueling outage in accordance with their inservice inspection,

program. In supplemental RAI B2.1.18-3(1), the staff requested the applicant specify the type of

inspection (i.e. visual inspection or ultrasonic).

In its response to supplemental RAI B2.1.18-3(1) dated February 8, 2005, the applicant stated

that a VT-2 examination is performed during the'system leakage test performed at normal

operating temperature and pressure in accordance with Examination Category B-P of the

ASME Code, Section Xl, Subsection IWB, during each refueling outage. The acceptance

criteria for the examination is no signs of leakage, and any indications of leakage would be

evaluated through the plant-specific corrective action system. The applicant also stated that

operating experience related to the thimble tubes at Millstone Unit 3 has identified no

occurrences of SCC. In addition, there is no known operating experience with SCC of thimble

tubes having occurred in the nuclear industry.' Based on the plant-specific and industry

experience, the staff agrees that a VT-2 examination every refueling outage is sufficient to

monitor cracking in these components. This resolves RAI B2.1.18-3(1).

For the guide tubes, the applicant credits the water chemistry AMP. for reducing the potential for

stress corrosion cracking and the inservice inspection program: systems, components, and

supports AMP for inspecting the most susceptible location to stress corrosion cracking, which is

the weld between the BMI guide tubes and instrumentation tubes on the reactor vessel bottom

head, in Table 3.1.2-1 of the LRA. To determine if the inspections of the inservice inspection

AMP is capable of managing SCC in the guide tubes the applicant was requested to address

the following: -

Specify the type of inspection or the inspection frequency.

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-Il;

* In addition, if indications in this weld are found, what increase in the sampling will be

performed since this is being used as an indicator that SCC is occurring?

* Also, the applicant stated that the reduced temperature from that of the RCS operating

temperature reduces the potential for SCC. What temperatures do the Guide Tubes

experience?

* Generic Letter 88-01 indicates that at temperatures below 200 0F stainless steel

components are not susceptible to SCC. If the temperature of the guide tubes is above

200 OF, the potential for SCC is not reduced, and the applicant was requested to

determine whether the inspection frequency is acceptable to detect cracking of the

guide tube.

In its response to supplemental RAI B2.1.18-3(2) dated February 8, 2005, the applicant stated

that to confirm that the water chemistry program is effective in mitigating SCC, a VT-2

examination during the system leakage test in accordance with the ASME Code Section Xl,

Subsection IWB, is performed every refueling outage. In addition, the BMI guide tubes are

welded to the instrumentation tubes which penetrate and are welded to the reactor vessel

bottom head. Therefore, the Instrumentation Tubes are more susceptible to SCC due to the

higher operating temperature than the BMI guide tubes. The instrumentation tubes then

become a leading indicator of SCC. The aging of the Instrumentation Tubes is managed the

inservice inspection program: systems, components, and supports AMP. The applicant also

committed to perform a 360-degree bare metal visual examination of all 58 penetrations during

each refueling outage, as documented in Dominion letter S/N 03-459A dated November 17,

2003, that responded to the NRC Bulletin 2003-02. The acceptance criterion is no evidence of

leakage. Any indications of leakage would be evaluated through the corrective action system.

Leakage in this area would result in further examinations, including the BMI guide tubes, to

determine the extent of the condition. he applicant also reviewed their operating experience,

and found no occurrences of SCC at the BMI guide tubes. The staff finds that the applicant

conservatively applied SCC as an aging effect for the BMI guide tubes, based on the operating

experience that has identified no occurrences of SCC. In addition, the applicant has provided

an inspection program to manage SCC in the BMI guide tubes. This resolves RAI B2.1.18-3(2).

Mechanical Nozzle Seal Assemblies (MNSA)

Summary of Technical Information in the Application In Appendix B, AMP B2.1.3 of the LRA,

the applicant stated that nickel-based pressurizer heater penetrations for Millstone Unit 2, two

penetrations were found to show evidence of leakage. A design change was generated to

address the issue by installing mechanical nozzle seal assembly (MNSA) clamps on the leaking

heater penetrations to prevent leaking.

Staff Evaluation. Table 3.1.2-3 of the LRA specified AMP B2.1.18, inservice inspection

program, to manage cracking of the nickel-based pressurizer heater sheathes and sleeves.

However, AMP B2.1.18 did not provide specific information on these components. In addition,

Appendix B, AMP B2.1.3 of the LRA stated that during ISI visual inspection of the nickel-based

pressurizer heater penetrations for Millstone Unit 2, two penetrations were found to show

evidence of leakage. A design change was generated to address the issue by installing MNSA

clamps on the leaking heater penetrations to prevent leaking. However, MNSAs are currently

not considered long-term repairs, in particular for the extended period of operation, without

providing justification which includes an analysis of the pressure boundary component and an

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inservice inspection program to be maintained throughout the licensed life of the plant. As

stated in NRC letter dated December 8, 2003,'to the Westinghouse Owners Group, the analysis

and inservice inspection program required NRC approval. Therefore, in'RAI B2.1.18-7 the

applicant was requested to provide the information, set forth in the December 8, 2003, letter to

justify the continued approval of the MNSAs for the period of extended operation. This

information was also to include corrective actions, such as weld repairs, half-nozzle repairs or

pressurizer replacements that may be performed in the future to'eliminate the MNSAs. The

applicant was requested to include this information in AMP B2.1.18 which manages cracking of

the pressurizer penetrations. --

In response to RAI B2.1.18-7 in a letter dated December 3, 2004, the applicant stated 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 was 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). -

In response to supplemental RAI B2.1.18-8 in a letter dated February 8, 2005, the applicant

added Commitment Item 36 to the Millstone Unit 2 LRA, Appendix A, FSAR Supplement, Table

A6.0-1 which states that Dominion will replace the Millstone Unit 2 pressurizer using materials

that are more resistant to PWSCC prior to entering the extended period of operation. This

commitment is acceptable to the staff and resolves RAI B2.1.18-1.

ODerating Experience. The staff reviewed operating experience for the applicant's inservice

inspection program: systems, components, and supports. The applicant stated in the LRA that

the program identifies -examples to demonstrate how the portions of the inservice inspection

program related to GALLAMPs XI.M1 and XL.S3 are adequate to manage the aging effects - during the extended period of operation. These examples were considered during the staffs.

evaluation of this AMP.

The applicant stated in the LRA that the portion of the inservice inspection program related to

GALL AMP XI.M12 is new and will be implemented prior to the period of extended operation.

The applicant stated in the LRA that no plant-specific operating experience exists for thermal

aging embrittlement of CASS. The applicant also stated in the LRA that its program for thermal

aging embrittlement of CASS was developed using research data obtained on both

laboratory-aged and service-aged materials.

On the basis of its review of the above operating experience, the staff concludes that the

inservice inspection program: systems, components and supports adequately manages the,

aging effects that have been observed at the applicant's plant.

FSAR Supplement. In Appendix A, Section A2.1 :18 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.17 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

inservice inspection program: systems, components and supports. The staff reviewed these

sections and the information provided by the LRA supplements, dated July 7, 2004, and

December 3, 2004, and determined that the information in the FSAR supplement provides an

adequate summary of the program activities. The staff finds these sections of the FSAR

supplement sufficient, as required by 10 CFR 54.21 (d).

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Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the exceptions and

the associated justifications and determined that the AMP, with the exceptions is adequate to

manage the aging effects for which it is credited. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21 (d).

3.0.3.2.14 Inspection Activities: Load Handling Cranes and Devices

Summary of Technical Information in the ADplication. The applicant's inspection activities: load

handling cranes and devices program is described in LRA Section B2.1.19, "Inspection , -

Activities: Load Handling Cranes and Devices Program." In the LRA, the applicant stated that

this is an existing MPS program. This program will be consistent, with enhancements, with

GALL AMP Xl.M23, 'Inspection of Overhead Heavy Load (Related to Refueling) Handling

Systems."

The applicant stated in the LRA that the inspection activities: load handling cranes and devices

program manages the aging effect of loss of material for the load handling cranes and devices

within the scope of license renewal. The in-scope load handling cranes and devices are either

safety-related or seismically designed to ensure that they will not adversely impact

safety-related components during or subsequent to a seismic event.

Load handling cranes and devices inspections address the overall condition of the crane or

device, including checking the condition of the structural members (i.e., rails, girders, etc.) and

fasteners on the crane or device, the runways along which the crane or device moves, and the

base plates and anchorages for the runways and monorails.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL ReporL Details of the staff's evaluation of the audit and review are

documented in the audit and review report. Furthermore, the staff reviewed the enhancements

and their justifications to determine whether the AMP, with the enhancements, remains

adequate to manage the aging effects for which it is credited.

In Appendix B, Section B2.1.19 of the LRA, the applicant stated that the inspection activities:

load handling cranes and devices program will be consistent with GALL AMP XL.M23, with

enhancements. The applicant stated that it will enhance the scope of program, program

element to include those lifting devices that require monitoring for license renewal, but are not

already included in the program. This enhancement will be implemented prior to the period of

extended operation. This commitment is also identified on the applicant's license renewal

commitment list in the Unit 2 LRA, Appendix A, Table A6.0-1, Item 15, and the Unit 3 LRA,

Appendix A, Table A6.0-1, Item 16. The applicant will also enhance the detection of aging

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effects program element to include visual inspections for the loss of material on the crane and

trolley structural components and the rails in'the scope of license renewal added by the first

enhancement. This enhancement will be implemented prior to the period of extended operation.

This commitment is also identified on the applicant's license renewal commitment list in the 'Unit

2 LRA, Appendix A, Table A6.0-1, Item 16, and the Unit 3 LRA, Appendix A, Table A6.0-1,

Item 17.

The staff noted that the inspection activities: load handling cranes and devices program does

not currently include all lifting devices required for license renewal. The applicant has initiated

followup items to ensure that this program will be modified to include those lifting devices

required for license renewal but not already managed by the program. Although this

enhancement comprises more than the list of items specifically identified in the scope for

GALL AMP XL.M23, the staff determined that this enhancement will bring the applicant's

program into agreement with the intent of the GALL AMP XL.M23 program element. On this

basis, the staff finds the first enhancement to be acceptable.

The staff noted that the AMP's implementing procedures and documentation do not currently

provide all of the inspection criteria required to manage aging effects for lifting devices. The

applicant has initiated followup items to ensure that the applicant's lifting and handling program

implementing procedures and/or automated work orders are modified; or new ones created, to

provide the required structural inspection guidance for monitoring the effects of aging. Evidence

of aging effects that are potentially adverse to quality are entered into the corrective action

program.

The staff finds that the applicant's proposed changes to the implementing procedures and

documentation for the inspection criteria will ensure that degradation of the lifting devices will be

identified before there is a loss of intended function. On this basis, the staff finds this

enhancement to be acceptable since it will bring the applicant's program into agreement with

the GALL Report. -.

Operating Experience. The staff reviewed operating experience for the applicant's inspection

activities: load handling cranes and devices program. The review indicated the inspection

activities: load handling cranes and devices'program is effective in identifying and implementing

repairs, and maintaining the integrity of load handling cranes and devices.

The applicant stated in the LRA that during the operating history of MPS, anomalous conditions

with cranes and lifting devices have been identified. These anomalies have included principally

administrative or operational issues. None of these issues has resulted from age-related

degradation and they are not a 'concern associated with license renewal. However, in the few

instances where inspection results have indicated signs of potential degradation, corrective

actions have been implemented to ensure the continued capability of the system to perform its

intended functions. - - - - ' -.

On the basis of its review of the above operating experience, the staff concludes that the

inspection activities: load handling cranes and devices program adequately manages the aging

effects that have been observed at the applicant's plant. - ; B ~ ~ ~ . -an ~ I\ , 

3-87:.
--A

FSAR Supplement. In Appendix A, Section A2.1.19 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.18.of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

inspection activities: load handling cranes and devices program. The staff reviewed these

sections and determined that the information in the FSAR supplement provides an adequate

summary of the program activities. The staff finds these sections of the FSAR supplement

sufficient, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the enhancements

and confirmed that the implementation of the enhancements prior to the period of extended

operation would result in the existing aging management program being consistent with the

GALL Report AMP to which it was compared. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21 (d).

3.0.3.2.15 Service Water System (Open-Cycle Cooling)

Summary of Technical Information in the Application. The applicant's service water system

(open-cycle cooling) program is described in LRA Section B2.1.21, "Service Water System

(Open-Cycle Cooling)." In the LRA, the applicant stated that this is an existing MPS program.

This program will be consistent, with three exceptions, with GALL AMP XL.M20, "Open-Cycle

Cooling Water System."

The applicant stated, in the LRA, that the service water systems for Units 2 and 3 are

open-cycle, once-through cooling systems that are subject to the requirements of GL 89-13,

"Service Water System Problems Affecting Safety-Related Equipment," dated July 1989. The

applicant uses the surveillance and control techniques recommended by GL 89-13 to manage

the effects of aging on the service water systems. The program addresses the aging effects of

corrosion (including MIC), erosion, protective coating failure, silting, and biofouling of service

water piping and components.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's evaluation are documented in the MPS

audit and review report. Furthermore, the staff reviewed the exceptions and their justifications to

determine whether the AMP, with the exceptions, remains adequate to manage the aging

effects for which it is credited.

In Appendix B, Section B2.1.21 of the LRA, the applicant stated that the service water system

(open-cycle cooling) program will be consistent with GALL AMP XL.M20, with exceptions. The

service water system (open-cycle cooling) program takes exception to the "scope of program,"

"detection of aging effects," and "monitoring and trending" program elements in that (1) Unit 2

relies on frequent, regular inspection and cleaning of heat exchangers, in lieu of thermal

performance testing as recommended by the GALL Report. Fouling determinations are made

based on established differential pressure limits (fixed or derived from curves) under maximum

service water flow conditions.

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The staff determined that frequent, regular inspection and cleaning is allowed by GL 89-13 and

meets the intent of the -GALL Report for ensuring that heat exchangers are capable of

performing their intended function of heat transfer during the period of extended operation. On

the basis of a review of GL 89-13 and interviews with the applicant's technical staff, the staff

determined that this exception is consistent with the CLB and therefore finds this first exception

to be acceptable.

The service water system (open-cycle cooling) program also takes exception to the "scope of

program," "detection of aging effects," and "monitoring and trending" program elements such

that (2) the Unit 3 reactor plant component cooling system heat exchangers and containment

recirculation coolers are not testable. For the program element associated with the exception

taken by the applicant, the GALL Report states that thermal performance testing is an effective

method for assessing the effects of aging on heat exchangers. The staff determined that the

containment recirculation coolers are maintained in a dry lay-up condition and the service water

supply to these heat exchangers is flushed on a'semi-annual basis, greatly reducing the

possibility of biofouling and potential reduction in heat transfer rate. The reactor plant

component cooling system heat exchangers are cleaned on the tube side and inspected

annually. As with the other service water heat exchangers, trending and assessments of

biofouling are performed for the reactor plant component cooling system heat exchangers to'

detect the presence of macro-fouling, and the necessary actions are taken to preclude fouling

and reduction in heat transfer rate. On the basis of a review of GL 89-13 and interviews with the

applicant's technical staff, the staff determined that this exception is consistent with the CLB

and therefore finds the second exception to be acceptable.

The service water system (open-cycle cooling) program also takes exception'to the "preventive

actions" program element in that, generally, (3) the Unit 3 redundant cooling loops for the

service water system are rotated into service on a regular basis; therefore, flushing and testing

requirements do not apply. The only exceptions are the'Unit 3 containment recirculation coolers

and the service water supply piping to these heat exchangers. For the program element

associated with the exception taken by the applicant, the GALL Report discusses flushing and

testing requirements in accordance with GL 89-13 for "infrequently used cooling loops."

The staff agrees with the applicant's statement in the LRA that because the containment

recirculation coolers are maintained in a dry lay-up condition, no mechanism exists f6r tube-side

fouling and the ability of the coolers to perform their interided function is maintained. The

applicant stated in the LRA that the service water supply piping to these heat exchangers is

flushed on a semi-annual basis. On the basis of a-review of GL 89-13 and interviews with the

applicant's technical staff, the staff determined that this exception is consistent with the CLB

and therefore finds the third exception to be acceptable.,

Operatina Experience. The staff reviewed the operating experience for the applicant's service

water system (open-cycle cooling) program. The applicant stated in the LRA that repairs and

design changes have been implemented to replace degraded portions of the service water,

systems. Continuing adherence to existing service water system inspection and testing

procedures provides reasonable assurance that deficiencies will be identified and corrected so -

that the service water components remain capable of performing their intended functions.

On the basis of its review of the above operating experience, the staff concludes that the

service water system (open-cycle cooling) program adequately manages the aging effects that

have been observed at the applicant's plant.! <v---

3-89.
FSAR Supplement. In Appendix A, Section A2.1.21 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.20 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

service water system (open-cycle cooling) program. The staff reviewed these sections and

determined that the information in the FSAR supplement provides an adequate summary of the

program activities. The staff finds these sections of the FSAR supplement sufficient, as

required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the exceptions and

the associated justifications and determined that the AMP, with the exceptions is adequate to

manage the aging effects for which it is credited. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21 (d).

3.0.3.2.16 Structures Monitoring Program

Summary of Technical Information in the Application. The applicant's structures monitoring

program is described in LRA Section B2.1.23, "Structures Monitoring Program." In the LRA, the

applicant stated that this is an existing MPS program. This program will be consistent, with

enhancements, with GALL AMPs XI.S5, 'Masonry Wall Program," XI.S6, "Structures Monitoring

Program," and XI.S7 URG 1.127, Inspection of Water Control Structures Associated with

Nuclear Power Plants."

The applicant stated in the LRA that the structures monitoring program manages the aging

effects of cracking, loss of material, and change of material properties. The applicant's program

monitors those 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 NRC Regulatory Guide (RG) 1.160, 'Monitoring the

Effectiveness of Maintenance at Nuclear Power Plants," Revision 2, dated March 1997, and

NUMARC 93-01, 'Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear

Power Plants," Revision 2, dated April 1996. 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 in 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 applicant stated in the LRA that the scope of the structures monitoring program includes all

masonry walls and water-control structures identified as performing intended functions in

accordance with 10 CFR 54.4.

The applicant stated in the LRA that the structures monitoring program does not include the

inspection of the supports specifically inspected per the requirements of the inservice inspection

program: systems, components, and supports program, or inspection of the structural condition

of the hangers and supports incorporated into the general condition monitoring program.

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The applicant stated in the LRA that the structures monitoring program takes no credit for

coatings applied to external surfaces of structural members in the determination of the aging

effects for the underlying materials. The structures monitoring program does, however,-evaluate

the condition of the coatings as an indication of the condition of the underlying materials. * ; ~~~, * -., i- w

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staff's evaluation of the audit and review are

documented in the audit and review report. Furthermore, the staff reviewed the enhancements

and their justifications to determine whether the AMP, with five enhancements, remains

adequate to manage the aging effects for which it is credited. -

In Appendix B, Section B2.1.23 of the LRA, the applicant stated that the structures monitoring

program will be consistent with GALL AMPs XL.S5,-"Masonry Wall Program," XI.S6, 'Structures

Monitoring Program," and Xl.S7, "RG 1.127, -Inspection of Water Control Structures Associated

with Nuclear Power Plants," with enhancements. The applicant stated that it will enhance the

"parameters monitored/inspected," "detection of aging effects," and "acceptance criteria"

program elements such that program (1) procedures will be revised to include American

Concrete Institute (ACI) Standard 349.3R-96,"Evaluation of Existing Nuclear Safety Related

Concrete Structures," dated 1996, and American Nuclear Standards Institute/American Society

of Chemical 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. This is identified on the applicant's license renewal commitment list in the

Unit 2 LRA, Appendix A, Table'A6.0-1, Item 17; and the Unit 3 LRA, Appendix A, Table A6.0-1,

Item 18.

The staff reviewed the applicant's technical document in which the applicant stated that it will

revise program procedures to include ACI 349.3R-96 and ANSI/ASCE 11-90 as references and

input documents for the structures monitoring program. The existing program procedures

generally follow the recommendations of ACI .349.3R-96 and ANSI/ASCE 11-90. However,

these two documents were not specifically used or referenced in the development of the current

program procedures. The applicant stated in the LRA that these revisions will be initiated prior

to the period of extended operation. This enhancement will bring the applicant's program into -

agreement with the GALL AMP XL.S6 program elements. The staff finds the first enhancement

to be acceptable. --

The applicant also stated that it will enhance the "scope of program," program element such

that (2) the implementing engineering procedures will be modified to include all additional

structures inspections required for license renewal. This is identified on the applicant's license

renewal commitment list in the Unit 2 LRA, Appendix A, Table A6.0-1, Item 18, and the Unit 3

LRA, Appendix A, Table A6.0-1, Item 19. The applicant's structures monitoring program does

not currently monitor all structures required for license renewal. In addition, the applicant stated,

as documented in the staffs MPS audit and review report for the structures monitoring

program, that the structures monitoring program does not currently identify certain types of

structural members (concrete beams, columns, etc.) and structural components (flood barriers,

stairs, sumps, etc.) that are subject to inspection. In order to ensure that all in-scope structural

members and components are addressed, the program procedures shall be further clarified and

enhanced so that all in-scope structural members and components are identified. The applicant

stated in the LRA that the procedures will be revised prior to the period of extended operation.

This enhancement will bring the applicant's program into agreement with the GALL AMP XI.S6:

program element. The staff finds the second enhancement to be acceptable.

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The applicant also stated that it will enhance the "parameters monitored/inspected" and -

"detection of aging effects" program elements such that (3) additional groundwater samples will

be taken to establish a baseline with regard to the aggressiveness of the water and its effect on

concrete structures. The staff reviewed the applicant's structures monitoring program, as

documented in the its MPS audit and review report, in which the applicant stated that

groundwater samples will be collected to establish a baseline with regard to the aggressiveness

of the water and its effect on concrete structures. Also, the applicant stated that additional

samples need to be taken on a periodic basis, considering seasonal variations, to ensure that

the groundwater is not of a nature that could cause the below-grade concrete to degrade. This

is identified on the applicant's license renewal commitment list in the Unit 2 LRA, Appendix A,

Table A6.0-1, Item 19, and the Unit 3 LRA, Appendix A, Table A6.0-1, Item 20. The applicant

stated in the LRA that the samples will be taken prior to the period of extended operation. This

enhancement will bring the applicant's program into agreement with the GALL AMP Xl.S6

program elements. The staff finds the third enhancement to be acceptable.

In addition, the applicant stated that it will enhance the "parameters monitored/inspected"

program element such that (4) the structures monitoring program procedures will be modified

so that the electrical engineering staff will be alerted if medium-voltage cables in scope of

license renewal have been found to be exposed to significant moisture during structures

inspections. This is identified on the applicant's license renewal commitment list in the Unit 2

LRA, Appendix A, Table A6.0-1, Item 20, and the Unit 3 LRA, Appendix A, Table A6.0-1, Item

21. The staff reviewed the applicant's structures monitoring program, as documented in the

staff's MPS audit and review report, in which that applicant stated that the structures monitoring

program procedures will be modified so that the electrical engineering staff will be alerted if,

during structures inspections, in-scope medium-voltage cables are found to have been exposed

to significant moisture. Water intrusion can occur within the in-scope structures due to

groundwater in-leakage or leakage of a plant system. The applicant stated in the LRA that the

procedures will be revised prior to the period of extended operation. This enhancement will

bring the applicant's program into agreement with the GALL AMP XL.S6 program element. The

staff finds the fourth enhancement to be acceptable.

The applicant will also enhance the "parameters monitored/inspected" program element such

that (5) the maintenance and work control procedures will be revised to take advantage of

inspection opportunities for structures required for license renewal and identified as

"inaccessible." This is identified on the applicant's license renewal commitment list in the Unit 2

LRA, Appendix A, Table A6.0-1, Item 21, and the Unit 3 LRA, Appendix A, Table A6.0-1, Item

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

report for the structures monitoring program, in which the applicant stated that the maintenance:

and work control procedures will be revised to take advantage of inspection opportunities for

structures required for license renewal and identified as "inaccessible." As inaccessible areas

become accessible by such means as excavation or installation of shielding or for any other

reason, additional inspections of those areas will be performed. As determined by the corrective

action program, engineering evaluation of the examination results will determine the need for

any subsequent inspections. The applicant stated in the LRA that this enhancement will be

implemented prior to the period of extended operation. This enhancement will bring the

applicant's program into agreement with the GALL AMP XI.S6 program element. The staff finds

the fifth enhancement to be acceptable.

Operating Experience. The staff reviewed operating experience for the applicant's structures

monitoring program. The review indicated the structures monitoring program is effective in

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identifying structural degradation, implementing corrective actions, and trending the

parameters. When degradation has been identified, corrective actions have been implemented

to-ensure that the integrity of the affected structure is maintained.

On the basis of its review of the above operating experience, the staff concludes that the

structures monitoring program adequately manages the aging effects that have been observedat the applicant's plant.

FSAR Supplement. In Appendix A, Section A2.1.23 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.22 .of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

structures monitoring program. The staff reviewed these sections and determined that the - information in the FSAR supplement provides an adequate summary of the program activities.

The staff finds these sections of the FSAR supplement sufficient, as required by

10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the enhancements

and confirmed that the implementation of the enhancements prior to the period of extended

operation would result in the existing aging management program being consistent with the

GALL Report AMP to which it was compared. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.2.17 Tank Inspection Program

Summary of Technical Information in the ApDlication. The applicant's tank inspection program

is described in LRA Section B2.1.24, "Tank Inspection Program." In the LRA, the applicant

stated that this is an existing MPS program. This program will be consistent, with

enhancements, with GALL AMP XI.M29, "Aboveground Carbon Steel Tanks."

The applicant stated in the LRA that the tank inspection program manages the aging effect of

loss of material through periodic internal and external tank inspections. The program includes

inspections of the sealant and caulking in and around the tank and concrete foundation;.and

evaluations to monitor the condition of coatings, linings, and structural elements to prevent

deterioration of the tanks to unacceptable levels. The program also includes performance of

volumetric examinations of inaccessible locations, such as the external surfaces of tank

bottoms. The acceptance criterion for visual inspections of paint, coatings, sealant, caulking,

and structural elements is the absence of anomalous indications that are signs of degradation.

Thickness measurements of the tank walls and bottoms are evaluated against design

thickness, established baseline values, or loss of material allowances.

Staff Evaluation. During its audit and review, the staff confirmed the applicant's claim of

consistency with the GALL Report. Details of the staffs evaluation of the audit and review are

documented in the audit and review report. Furthermore, the staff reviewed the enhancements

and their justifications to determine whether the AMP, with three enhancements, remains

adequate to manage the aging effects for which it is credited.

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In Appendix B, Section B2.1.24 of the LRA, the applicant stated that the tank inspection

program will be consistent with GALL AMP XL.M29, with enhancements. The applicant stated

that it will enhance the 'scope of the program," "parameters monitored/inspected," "detection of

aging effects," and "acceptance criteria" program elements such that (1) inspections of sealants

and caulking used for moisture intrusion prevention in and around aboveground tanks will be

performed. This is identified on the applicant's license renewal commitment list in the Unit 2

LRA, Appendix A, Table A6.0-1, Item 22, and the Unit 3 LRA, Appendix A, Table A6.0-1, Item

23. For the program elements associated with the enhancement, the GALL Report states that

the AMP consists of (a) preventive measures to mitigate corrosion by protecting the external

surfaces of carbon steel tanks protected with paint or coatings and (b) periodic system -

walkdowns to manage the effects of corrosion on the intended function of these tanks. Plant

walkdowns cover the entire outer surface of the tank up to its surface in contact with soil or

concrete.

The GALL Report also states that the AMP utilizes periodic plant system walkdowns to monitor

degradation of coatings, sealants, and caulking because it is a condition directly related to the

potential loss of materials.

In addition, the GALL Report states that degradation of exterior carbon steel surfaces cannot

occur without degradation of paint or coatings on the outer surface and of sealant and caulking

at the interface between the component and concrete. Periodic system walkdowns to confirm

that the paint, coating, sealant, and caulking are intact is an effective method to manage the

effects of corrosion on the external surface of the component.

The GALL Report also states that any degradation of paint, coating, sealant, and caulking is to

be reported and will require further evaluation. Degradation consists of cracking, flaking, or

peeling of paint or coatings, and drying, cracking, or missing sealant and caulking. Thickness

measurements of the tank bottom are evaluated against the design thickness and corrosion

allowance.

The staff reviewed the applicant's tank inspection program, as documented in the staffs MPS

audit and review report, in which the applicant stated that it will perform appropriate inspections

of sealants and caulking used for moisture intrusion prevention in and around aboveground

tanks. The applicant stated in the LRA that these inspections will be initiated prior to the period

of extended operation. This enhancement will bring the applicant's program into agreement with

the GALL AMP XI.M29 program elements. The staff finds the first enhancement to be

acceptable.

The applicant stated that it will enhance the detection of aging effects, monitoring and tending,

and acceptance criteria program elements in that (2) non-destructive volumetric examinations

of inaccessible locations, such as the external surfaces of tank bottoms for those tanks that

require aging management for license renewal, will be performed. This is identified on the

applicant's license renewal commitment list in the Unit 2 LRA, Appendix A, Table A6.0-1, Item

23, and the Unit 3 LRA, Appendix A, Table A6.0-1, Item 24. For the program elements

associated with the enhancement, the GALL Report states that degradation of exterior carbon

steel surfaces cannot occur without degradation of paint or coatings on the outer surface and of

sealant and caulking at the interface between the component and concrete. Periodic system

walkdowns to confirm that the paint, coating, sealant, and caulking are intact is an effective

method to manage the effects of corrosion on the external surface of the component. However,

corrosion may occur at inaccessible locations, such as the tank bottom surface, and thickness

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measurement of the tank bottom is to be taken to ensure that significant degradation is not

occurring and the component intended function will be maintained during the extended period of

operation.

The GALL Report also states that the effects of corrosion on the aboveground external surface

are detectable by visual techniques. Based on operating experience, plant system walkdowns

during each outage provide for timely detection of aging effects. The effects of corrosion of the

underground external surface are detectable by thickness measurement of the tank bottom and

are monitored and trended if significant material loss is detected.

In addition, the GALL Report states that any degradation of paint, coating, sealant, and -caulking

is reported and will require further evaluation. Degradation consists of cracking, flaking, or

peeling of paint or coatings, and drying; cracking,-or missing sealant and caulking. Thickness'

measurements of the tank bottom are evaluated against the design thickness and corrosion

allowance. -

The staff reviewed the tank inspection program, as documented in the staff's MPS audit and

review report, in which the applicant stated that it will perform non-destructive volumetric

examinations of inaccessible locations, such as the external surfaces of tank bottoms for.those

tanks that require aging management for license renewal. The applicant stated in the LRA that

these volumetric examinations will be performed prior to the period of extended operation and

will be performed on a frequency consistent with scheduled tank internals inspection activities.

This enhancement will bring the applicant's program into agreement with the GALL AMP

XL.M29 program elements. The staff finds the second enhancement to be acceptable.

Also, the applicant stated that it will enhance the Scope of program," program element such

that (3) the Unit 2 security diesel fuel oil tank and the Unit 3 diesel fire pump fuel oil tank will be

added to the list of in-scope components for this program. This is identified on the applicant's

license renewal commitment list in the Unit 2 LRA, Appendix A, Table A6.0-1, Item 24, and the

Unit 3 LRA, Appendix A, Table A6.0-1, Item 25. For the program element associated with the

enhancement, .the GALL Report states that the program consists of (a) preventive measures to

mitigate corrosion by protecting the external surfaces of carbon steel tanks protected with paint

or coatings and (b) periodic system walkdowns to manage the effects of corrosion on the

intended function of these tanks.

The staff reviewed the tank inspection program, as documented in the staff's MPS audit and

review report, in which the applicant stated that it will add the Unit 2 security diesel fuel oil tank

and the Unit 3 diesel fire pump fuel oil tank to the list of in-scope tanks for the tank inspection

program and will include the tanks on the respective inspection plans. Although these two tanks

have been identified as in scope for license renewal, the applicant noted in the tank inspection

program, as documented in the staffs MPS audit and review report, that the tanks are not

currently identified on the respective tank inspection plans. This enhancement will bring the

applicant's program into agreement with the GALL AMP XI.M29 program elements. The staff

finds the third enhancement to be acceptable.;

Operating Experience. The staff reviewed operating experience for the applicant's tank

inspection program. The review indicated the tank inspection program is effective in identifying

age-related degradation, implementing repairs, and maintaining the integrity of aboveground

tanks.

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On the basis of its review of the above operating experience, the staff concludes that the tank

inspection program adequately manages the aging effects that have been observed at the

applicant's plant.

FSAR Supplement. In Appendix A, Section A2.1.24 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.23 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

tank inspection program. The staff reviewed these sections and determined that the information

in the FSAR supplement provides an adequate summary of the program activities. The staff

finds these sections of the FSAR supplement sufficient, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

those program elements for which the applicant claimed consistency with the GALL program

are consistent with the GALL program. In addition, the staff has reviewed the enhancements

and confirmed that the implementation of the enhancements prior to the period of extended

operation would result in the existing aging management program being consistent with the

GALL Report AMP to which it was compared. 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). The staff also reviewed the FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).

3.0.3.2.18 Bolting Integrity Program

Summary of Technical Information in the Application. The applicant added bolting integrity to

the aging management programs of Appendix B of the LRA in RAI response 3.3.11-A-1 by

letter dated December 3, 2004.

The bolting integrity program ensures that the effects of aging associated with the in-scope

components will be adequately managed so that there is reasonable assurance that their

intended functions will be maintained consistent with the current licensing basis throughout the

period of extended operation.

Millstone good bolting practices are established in accordance with plant procedures. These

procedures include requirements for proper disassembling, inspecting, and assembling of

connections with threaded fasteners. The general practices that are established in this program

are based on EPRI NP-5067 Volume 1, "Good Bolting Practices, A Reference for Nuclear

Power Plant Maintenance Personnel, Volume 1: Large Bolt Manual," EPRI NP-5067, Volume 2,

'Good Bolting Practices, A Reference for Nuclear Power Plant Maintenance Personnel, Volume

2: Small Bolts and Threaded Fasteners," and EPRI TR-104213, "Bolted Joint Maintenance and

Applications Guide."

The bolting integrity program is an existing program that manages the aging effects of cracking,

loss of material, and for ASME Class 1 bolting, loss of preload. The program includes the good

bolting practices established for in scope threaded fasteners in plant procedures in accordance

with recognized industry organizations such as EPRI and AISC. The program also includes the

inservice inspection requirements established in accordance with ASME Section Xl,

Subsections IWBI, IWC,- IWD, and IWF for ASME Class bolting. The applicant stated that the

bolting integrity program is consistent with the aging management program described in

Chapter Xl of GALL AMP XI.M1 8, with the clarification and exceptions as described below:

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Clarification Number 1: XI.M18 - Loss of Preload

GALL AMP XI.M18, identifies loss of preload as an aging effect requiring management for all

bolting within the scope of license renewal. The applicant identifies loss of preload as an aging effect requiring management for ASME Class I bolting only. The applicant stated that the

operating temperature for all in scope bolted connections other than Class 1 bolting are well

below the threshold temperature at which stress relaxation of pressure boundary bolting would

occur.

Exception 1: XI.M18 - Reference Documents

Documents referenced in NUREG-1801 for safety-related bolted connections are not directly

referenced by the Millstone bolting integrity program. NUREG-1801 Section XI.M18 states that

the program relies on recommendations for a comprehensive bolting integrity program, as

delineated in NUREG-1339, and industry recommendations, as delineated in EPRI NP-5769

(with exceptions as noted in NUREG-1 339) for safety-related bolting:

The procedures for ensuring bolting integrity at Millstone identify inspection requirements and

general practices for in scope bolting that are consistent with the bolting recommendations

identified in Section XI.M18, but do not directly.reference EPRI NP-5769 or NUREG-1339 as

applicable source documents for these recommendations. However, the Millstone procedures

do reference and incorporate the good bolting'practices identified in EPRI NP-5067. EPRI NP5769 and EPRI NP-5067 are very closely related documents that cross-reference one another

and reference NUREG-1339.

Exception 2: XI.M18 - Use of Different Code Year than Identified -in NUREG-1 801

GALL AMP XI.M18 identifies inservice inspection requirements in accordance with Table IWB2500-1 and the 1995 Edition through the 1996 Addenda of ASME Section Xl. The Millstone

current ISI program is based on the 1989 Edition with no addenda. There are no differences

between these Code years with respect to examination requirements for ASME Class 1, 2, and

3 bolting and their support bolting. -

Staff Evaluation. The applicant added bolting integrity to the aging management programs of

Appendix B of the LRA in RAI response 3.3.11-A-1,'by letter dated December 3, 2004.

The bolting integrity program is an existing program that manages the aging effects of cracking,

loss of material, and for ASME Class 1 bolting, loss of preload: The program includes the good

bolting practices established for in scope threaded fasteners in plant procedures in accordance

with recognized industry organizations such as EPRI and AISC. The program'also includes the

inservice inspection requirements established in accordance with ASME Section Xl,

Subsections IWB, IWC, IWD, and IWF for ASME Class bolting. The applicant stated that the

bolting integrity program is consistent with the aging management program described in GALL

AMP XI.M18, with the clarification and exceptions as reviewed below:

Clarification Number 1: XI.M18 - Loss of Preload: .- '-

The applicant stated that the operating temperature for all other in-scope bolted connections

are well below the threshold temperature at which stress relaxation of pressure boundary

bolting would occur. The staff found that other factors such as vibration can contribute to loss of

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JJI

preload. The applicant needed to address other factors which can contribute to loss of preload

and justify if loss of preload is an aging effect requiring management for all bolting within the

scope of license renewal. This was identified as Open Item 3.0.3.2.18-1.

In response to Open Item 3.0.3.2.18-1, dated July 14, 2005, the applicant stated the Millstone

bolting integrity AMP has now been revised to manage loss of preload as an applicable aging

effect for all in-scope bolting. Based on this change to the bolting integrity AMP, Open Item

3.0.3.2.18-1 is closed.

Exception 1: XL.M18 - Reference Documents

Documents referenced in NUREG-1801 for safety-related bolted connections are not directly

referenced by the Millstone bolting integrity program. NUREG-1801 Section XL.M18 states that

the program relies on recommendations for a comprehensive bolting integrity program, as

delineated in NUREG-1339, and industry recommendations, as delineated in EPRI NP-5769

(with exceptions as noted in NUREG-1339) for safety-related bolting.

The procedures for ensuring bolting integrity at Millstone identify inspection requirements and

general practices for in scope bolting that are consistent with the bolting recommendations

identified in Section XL.M18, but do not directly reference EPRI NP-5769 or NUREG-1339 as

applicable source documents for these recommendations. However, the Millstone procedures

do reference and incorporate the good bolting practices identified in EPRI NP-5067. EPRI

NP-5769 and EPRI NP-5067 are very closely related documents that cross-reference one

another and reference NUREG-1 339. The staff requested clarification on how the guidance in

EPRI NP-5067 and EPRI TR-1 04213 meets the intent of EPRI NP-5769 and NUREG-1 339 as

identified in GALL AMP XI.M18. This was identified as Open Item 3.0.3.2.18-2.

By letter dated April 1, 2005, the applicant provided a comparison of EPRI NP-5769 and EPRI

NP-5067 as they relate to the bolting integrity program at Millstone. In summary, the Millstone

bolting integrity program is consistent with the recommendations in NUREG-1801,

Section XI.M18. The comparison provided by the applicant demonstrates that EPRI NP-5067

provides adequate guidance for addressing the bolting integrity for Millstone Units 2 and 3.

Therefore, Open Item 3.0.3.2.18-2 is closed.

Exception 2: XI.M18 - Use of Different Code Year than Identified in NUREG-1 801

The current ISI program for Millstone is based on the 1989 Edition with no addenda of Section

Xl of the ASME Code. GALL AMP XI.M18 identifies inservice inspection requirements in

accordance with Table IWB-2500-1 and the 1995 Edition through the 1996 Addenda of Section

Xl of the ASME Code.

The regulations require that inservice inspection of components be conducted during the first

10-year interval and subsequent intervals to comply with the requirements in the latest edition

and addenda of Section XI of the ASME Code, which was incorporated by referenced in

10 CFR 50.55a(b) twelve months prior to the start of the 120-month interval, subject to the

limitations and modifications listed therein. The current code of record for Millstone is the 1989

Edition with no Addenda of Section XI of the ASME Code. When NUREG-1801 was drafted the

edition referenced in 10 CFR 50.55a(b) was the 1995 Edition through the 1996 Addenda of:

Section Xl of the ASME Code. The editions and addenda of Section Xl of the ASME Code that

are referenced in 10 CFR 50.55a(b) have been reviewed and found acceptable, subject to the

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limitations and modifications listed therein. Therefore, the staff finds the use of the Code of

Record (1989 Edition) for Millstone is acceptable. In addition, for the period of extended

operation, the applicant will be required to update its Code of Record to the Edition and

Addenda as referenced in 10 CFR 50.55a(b) twelve months prior to the start of each 120-month

interval.

FSAR Supplement. The bolting integrity program corresponds to GALL AMP XI.M18, "Bolting

Integrity." The program manages the aging effects of cracking, loss of material, and, for Class 1

bolting, loss of preload.

The aging effects are managed by establishing good bolting practices in accordance with EPRI

NP-5067 Volume 1, 'Good Bolting Practices, A Reference for Nuclear Power Plant

Maintenance Personnel, Volume 1: Large Bolt Manual," EPRI NP-5067, Volume 2, "Good

Bolting Practices, A Reference for Nuclear Power Plant Maintenance Personnel, Volume 2:.

Small Bolts and Threaded Fasteners," and EPRI TR-1 04213, "Bolted Joint Maintenance and

Applications Guide." -

In addition, ASME Class bolting is managed bylthe performance of inservice examinations in

accordance with ASME Section Xl, Subsections IWB, IWC, IWD, and IWF. Engineering

evaluations determine if a component needs to be repaired/replaced or is acceptable for

continued operation until the next scheduled inspection. Corrective actions for conditions that'

are adverse to quality are performed in accordance with the corrective action program as-part

of the quality assurance program. The corrective action process provides reasonable assurance

that deficiencies adverse to quality are either, promptly corrected or are evaluated to be

acceptable.

The staff found that the resolution of Open Items 3.0.3.2.18-1 and 3.0.3.2.18-2 may warrant a

modification to the FSAR. This issue was identified as Confirmatory Item'3.0.3.2.18-1. By letter

dated July 14, 2005, the applicant provided the'revised FSAR sections to reflect resolution of

Open Items related to the bolting integrity program. Based on these FSAR changes,

Confirmatory Item 3.0.3.2.18-1 is closed.

Conclusion. Based on the information provided by the applicant, the staff finds that the effects

of aging will be adequately managed by the bolting integrity program 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 FSAR supplement for this AMP

and finds that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d).. -

3.0.3.3 AMPs that are Not Consistent with or Not Addressed in the GALL

In Appendix B of the LRA, the applicant indicated that the following AMPs were plant-specific:

v battery rack inspections (B2.1.1) ' " ' " * general condition monitoring (B2.1.13)''

v infrequently accessed areas inspection program (B2.1.15)

work control process (B2.1.25) ' -

For AMPs that are not consistent with or not addressed by the GALL Report, the staff

performed a complete review of the AMPs to determine if they were adequate to monitor or

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l~~ ' I 

manage aging. The staffs review of these plant-specific AMPs is documented in the following

sections of this SER:

3.0.3.3.1 Battery Rack Inspections

Summary of Technical Information in the Application. The applicant's battery rack inspections

program is described in LRA Section B2.1.1, 'Battery Rack Inspections.' In the LRA; the

applicant stated that this is an existing plant-specific program. The applicant credits this

program with managing the aging effects for loss of material of such design elements as

anchorages, bracing and supports, side and end rails, and spacers between battery cells.

Potential degradation of the racks is evaluated for its effect on their structural integrity during a

seismic event, and repairs are implemented as necessary.

Staff Evaluation. In accordance with 10 CFR 54.21 (a)(3), the staff reviewed the information

included in Appendix B, Section B2.1.1, of the LRA, regarding the applicant's demonstration of

the battery rack inspections program to ensure that the effects of aging, as discussed above,

will be adequately managed so that the intended functions will be maintained consistent with

the CLB throughout the period of extended operation.

The staff reviewed the battery rack inspections program against the AMP elements found in the

SRP-LR, Appendix A, Section A.1.2.3, and SRP-LR Table A.1-1 and focused on how the

program manages aging effects through the effective incorporation of 10 elements (i.e.,

program scope, preventive actions, parameters monitored or inspected, detection of aging

effects, monitoring and trending, acceptance criteria, corrective actions, confirmation process,

administrative controls, and operating experience).

The applicant indicated that the corrective actions, confirmation process, and administrative

controls are part of the site-controlled quality assurance program. The staffs evaluation of the

quality assurance program is provided separately in Section 3.0.4 of this SER. The remaining

seven elements are discussed below:

(1) Scope of the Program - The applicant stated, in Appendix B, Section B2.1.1 of the LRA,

that for this program element, the battery racks' provide support and restraint for various

batteries that supply power to equipment in the plant. The applicant stated that the

battery racks for the following batteries are within the scope of license renewal for this

program: Unit 2 main station batteries, Unit 2 non-safety-grade turbine battery, Unit 2

security diesel generator battery, Unit 3 main station batteries, Unit 3 non-safety-grade

battery 5, Unit 3 diesel-driven fire pump batteries, Unit 3 station blackout diesel

generator battery, and 345-kilovolt switchyard relaying and control batteries. Seismic

design elements such as anchorages (including bolting to the building structure);

bracing and supports, side and end rails, and spacers between cells are included as part

of this program.

The existing battery rack inspection program will be modifiedto include those battery

racks that require monitoring for license renewal, but are 'not already in the program.

The enhancement will be implemented prior to the pe'riod of extended operation. This

commitment is also identified on the applicant's license renewal commitment list in the

LRA, Appendix A, Table A6.0-1, Item 1. The staff finds'this enhancement is required

and is acceptable as any such changes will provide additional assurance that the effects

of aging will be adequately managed.

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The staff reviewed and confirmed that this program element satisfies the criterion

defined in Appendix A.1 of the SRP-LR. The proposed scope, including the

enhancements, identifies the specific components for which the program manages

aging. On this basis, the staff finds that the applicant's proposed program scopeis

acceptable.

(2) Preventive Actions - The applicant stated, in Appendix B, Section B.2.1.1 of the LRA

that this program element is not applicable because the battery rack inspection program

is an inspection program and no actions will be taken as part of this program to prevent

or mitigate aging degradation.

The staff confirmed that the preventive actions program element satisfies the criterion

defined in Appendix A.1.2.3.2 of the6SRP-LR.'The staff did not identify~'the need for

preventive actions for this AMP because it is a condition monitoring program. Therefore,

the staff finds this acceptable.

(3) Pararmeters Monitored or Inspected The'applicant stated,'in Appendix B, Section

B2.1.1 of the LRA that the battery support racks are visually inspected to ensure that

their physical condition is not degraded d(loss of material). Where installed, items such

as anchorages (including bolting to thlebuildirig structure), bracing and supports, side

and end rails, and spacers are also inspected.

The staff confirmed this program ele'ment satisfies the criteria defined in

Appendix A.1.2.3.3 of the SRP-LR. The battery rack inspection program is acceptable

because the visual inspections for matedrial loss are intended to' detect the presence and

extent of aging effects. On this basis, .the staff finds that the parameters monitored or

inspected'program element is acceptable.

(4) Detection of Aging Effects - The applicant stated, in Appendix B, Section B2.1.1 of the

LRA, that battery rack inspections are performed on a periodic basis. Visual inspections

identify degradation of the support racks. These inspections include items such as

anchorages (including bolting to the building structure), bracing and supports, side and

end rails, and spacers. These inspections check for loss of material (such as corrosion)

of the support racks.

In the LRA the applicant also stated that implementing procedures will be modified to

include loss of material as a potential aging effect and to provide guidance in' the'

inspection of items (such as anchoags;brabing and supports, side and end rails, and

spacers), which contribute to battery rack integrity6r seismic'design of the battery

racks. This commitment is identified in Appendix A, Table A6.0-1 License Renewal

commitments, ltem'2.

The staff reviewed and confirmed that this program element satisfies the criterion

defined in Appendix A.1.2.3.4 of the SRP-LR.The detection of aging effects, including

* the enhancements, identifies the-specific components for which the program manages aging. On this basis, the staff finds that the applicant's detection of aging effects

program element is acceptable.

(5) Monitoring and Trending -The applicant stated; in Appendix B, Section B2.1.1 of the

LRA, that battery rack inspections determine the extent of aging effects. The material

condition of the battery rack's isrecorded. lnaccordance with inspection procedures and

if acceptance crteria are not met, the corrective action program is employed to evaluate

the issue and provide corrective actions' in a'tihnely manner. Engineering evaluations

assess whether the extent of aging could cause a loss of intended function.

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_ _ _ _ _a

The staff confirmed that this program element satisfies the criteria defined in

Appendix A.1 of the SRP-LR. Trending of inspection results will be performed and will

enhance the applicant's ability to detect aging effects before there is a loss of intended

function. On this basis, the staff finds that the applicant's monitoring and trending

program element is acceptable.

(6) Acceptance Criteria - The applicant stated, in Appendix B, Section B2.1.1 of the LRA,

that the acceptance criterion for visual inspections is the absence of anomalous

indications that are signs of degradation. Engineering evaluations determine whether

observed deterioration of material condition is significant enough to compromise the

ability of a battery rack to perform its intended function. Occurrence of degradation that

is adverse to quality will be entered into the corrective action system.

The staff confirmed that this program element satisfies the criteria defined in

Appendix A.1 of the SRP-LR. Any anomalous indications that are signs of degradation

will be evaluated by an engineer to determine whether the observed deterioration of

material condition is significant enough to compromise the ability of a battery rack to

perform its intended function. If found unacceptable, corrective measures will be

implemented. On' this basis, the staff finds that the acceptance criteria program element

is acceptable.

(7) Operating Experience - The applicant stated, in Appendix B, Section B2.1.1 of the LRA,

that the inspections and corrective actions have been successful in maintaining battery

support rack integrity. Incidents of battery rack corrosion' have occurred and corrective

action has been taken to repair or replace storage rack'components as necessary.

Periodic inspections of the support racks help ensure their continued integrity and

proper functioning during routine operation, as well as during the limiting condition of a

seismic event.

On the basis of its review of the above operating experience, the staff concludes that

the battery rack inspections program will adequately manage the aging effects that have

been observed at the applicant's plant.

FSAR Supplement. In Appendix A, Section A2.1.1 of the LRA, the applicant provided the FSAR

supplements for the battery rack inspections program and stated that the program will manage

the aging effect of loss material for the station' battery support racks within the scope of license

renewal. Visual inspections will be performed to ensure the absence of anomalous indications

that are signs of degradation. Corrective actions for conditions that are adverse to quality are

performed in accordance with the applicant's corrective action program as part of the quality

assurance program.

The staff reviewed the FSAR supplements and confirmed that they provide an adequate

summary description of the program, as identified in the SRP-LR FSAR supplement table and

as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, 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); The staff also reviewed the FSAR supplement

for this AMP and finds that it provides an adequate summary description of the program, as

required by 10 CFR 54.21(d).

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3.0.3.3.2 General Condition Monitoring 'At

Summary of Technical Information in the Application. The applicant's general condition

monitoring program is described in LRA Section B2.1.13, "General Condition Monitoring." In the

LRA, the applicant stated that this is an existing plant-specific program. The applicant credits

this program with managing the aging effects for loss of material, cracking, and change of

material properties on the external surfaces of components. The external surfaces of structures

and components are monitored for signs of aging that can be detected via visual observations.

General condition monitoring includes the observations that are made during focused

inspections performed on a periodic basis for plant components and structures, including those

within the scope of license renewal. The results of the monitoring activities provide the basis for

initiating required corrective action in a timely manner.

Staff Evaluation. In accordance with 10 CFR 54.21 (a)(3), the staff reviewed the information

included in Appendix B, Section B2.1.13, of the'LRA, regarding the applicant's demonstration of

the general condition monitoring program to ensure that the effects of aging, as discussed

above, will be adequately managed so that the intended functions will be maintained consistent

with the CLB throughout the period of extended operation.

The staff reviewed the general condition monitoring program against the AMP elements found

in the SRP-LR, Appendix A, Section A.1.2.3, and SRP-LR Table A.1-1 and focused on how the

program manages aging effects through the effective incorporation of 10 elements (i.e.,

program scope, preventive actions, paramete'rs monitored or inspected, detection of aging

effects, monitoring and trending, acceptance'criteria, corrective actions, confirmation process,

administrative controls, and operating experience).

The applicant indicated that the corrective actions, confirmation process, and administrative

controls are part of the site-controlled quality assurance program. The staff's evaluation of the

quality assurance program is provided separately in Section 3.0.4 of this SER. The remaining

seven elements are discussed below.

(1) Scope of the Program - The applicant stated, in Appendix B, Section B2.1.13 of the

LRA, that the general condition monitoring program detects aging effects by visual

inspections of the exterior surface of plant equipment, whether it is constructed of metal,

concrete, or polymers.

The staff reviewed and confirmed that this program element satisfies the criterion

defined in Appendix A.1 of the SRP-LR. The proposed scope identifies the specific

components for which the program manages aging. On this basis, the staff finds that the

applicant's proposed program scope is acceptable.

(2) Preventive Actions -The applicant stated, in Appendix B, Section B2.1.13 of the LRA,

that the general condition monitoring program is an inspection program and no actions

will be taken as part of this program to prevent or mitigate aging degradation.

The staff confirmed that the preventive actions program element satisfies the criterion

defined in Appendix'A.1.2.3.2 of the' SRP-LR. The staff did not identify the need for

preventive actions for the general condition monitoring program because it is a condition

monitoring program.-

(3) Parameters Monitored or Inspected - The applicant stated, in Appendix B, Section

B2.1.13 of the LRA, that system engineer walkdown inspections monitor the material

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condition of plant systems, structures, and components during normal operation,

shutdown conditions, and refueling outages. Inspectors look for the following types of

degradation or adverse conditions during visual inspections: worm, flaking, or rusted

painted surfaces; excessive rust, material wastage or signs of degradation, cracking or

aging on equipment surfaces; leaks, including evidence of boric acid; damaged or

degraded hangers and supports; signs of general corrosion on machined or sliding

surfaces with close tolerances; signs of unusual concrete or grout deterioration, erosion,

corrosion, chipping, cracking, or spalling on equipment foundations; and loose,

corroded, stressed, seized, or rusted skids, foundations, supports, hangers, and

fasteners.

During performance of radiologically controlled area surveys, health physics personnel

look for evidence of boron precipitation and active radioactive system leaks.

During their rounds, plant equipment operators monitor the material condition of plant

systems, structures, and components in all modes of operation. During visual

inspections, plant equipment operators look for evidence of system leakage, including

evidence of boric acid; evidence of groundwater intrusion or leakage; loose or missing

pipe hangers; evidence of degradation (e.g., excessive corrosion or scaling); and signs

of unusual concrete or grout deterioration, erosion, corrosion, chipping, cracking, or

spalling.

The general condition monitoring program also credits visual inspection for the detection

of changes in material properties in elastomers in the ventilation systems and in support

members. During the audit and review, it was not clear to the staff how visual

inspections would be used to monitor this aging effect. In a subsequent staff visit to the'

plant, the applicant stated that the change of material properties for these elastomer -

components is visually observable by evidence of cracking and crazing, discoloration,

distortion, evidence of swelling, tackiness, evaluation of resilience and indentation

recovery, etc. These conditions are observable during the general condition monitoring

activities performed by the system engineers as part of comprehensive inspections

performed quarterly, and by the plant equipment operators during daily inspections of

plant areas to verify component or system operation. The staff reviewed the document

change request, as documented in the staff's MPS audit and review report, that will add

the details for the visual inspection of elastomers to the general condition monitoring

program. The applicant stated in the LRA that the procedures and training for personnel

performing general condition monitoring inspections and walkdowns will be enhanced to

identify the requirements for the inspection of aging effects. This will provide a

reasonable assurance that changes in material properties of elastomer components will

be adequately managed. This commitment is identified on the applicant's license

renewal commitment list in the LRA, Appendix A, Table 6.0-1, Item 10. Based on

discussions with plant staff and the review of the LRA commitment and document

change request, the staff concurs that change in material properties can be visually

observed.

The staff confirmed that this program element satisfies the criteria defined in Appendix

A.1.2.3.3 of the SRP-LR. The general condition monitoring program is' acceptable

because the visual inspections for material loss, cracking, and change in material

properties are intended to detect the presence and extent of aging effects. On this

basis, the staff finds that the parameters monitored or inspected program element is

acceptable.

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(4) Detection of Aging Effects -The applicant stated, in Appendix B, Section B2.1.13 of the

LRA, that the external condition of components and structures is determined by visual

inspection. These inspections provide information to help manage the aging effects of

loss of material, cracking, and change in material properties. The applicant also stated,

in Appendix B, Section B2.1.13 of the' LRA,'that visual monitoring of the systems,

structures, and components in norrnallykaccdssed areas is performed in accordance

with the guidance provided in'administrative and surveillance procedures. The

inspection frequency varies from'twice a"day to once per refueling outage, in

accordance with applicable station procedures.

The general condition monitoring program also credits visual inspection for the detection

of changes in material'properties in'elastomers in the ventilation systems and in support

members. During the audit and review, it was not clear to the staff how visual

inspections would be used to monitor'this aging effect. In'a subsequent staff visit to the

plant, the applicant'stated that the change of material properties for these elastomer

components is visually observable by evidence of cracking and crazing, discoloration,

distortion, evidence'of swelling, tackiness, evaluation of resilience and indentation

recovery, etc. These conditions are'observable during the general condition monitoring

activities performed by the system engine'ers'as part of comprehensive inspections

performed quarterly, and by the' plant equipment operators during daily inspections of

plant areas to verify component or system operation. The staff reviewed the document

change request, as documented in the staffs MPS audit and review report, that will add

the details for the visual inspection of elastomers to the general condition monitoring

program. The applicant stated in the LRA that the procedures and training for personnel

performing general condition monitoring inspections and walkdowns will be enhanced to

identify the requirements for the inspection of aging effects. This will provide a

reasonable assurance that changes in -material properties of elastomer components will

be adequately managed. This commitmerit is identified on the applicant's license

renewal commitment list in the LRA Appendix A, Table 6.0-1, Item 10. Based on the

review of the LRA commitment and document change request, the staff concurs that

change in material properties can be visually observed.

The staff reviewed and confirmed that this program element satisfies the criteria defined

in Appendix A.1.2.3.4 of the SRP-LR. The detection of aging effects identifies the

specific components for which'the program' manages aging. On this basis, the staff finds

that the applicant's detection'6f aging 'effects program element is acceptable.

(5) Monitoring and Trending -The applicant stated, in Appendix B, Section B2.1.13 of the

LRA, that observations of significant degradation are identified for engineering -

evaluation and documented in accordance with governing procedures. Additionally,

system health reports provide a quarterly engineering perspective on system conditions

and provide an effective tool by which management can focus attention and resources

on systems that'do not meet performance goals.

Degradation due to boric acid corrosion is monitored and trended by-the activities in the

general condition monitoring program in conjunction with the'corrective action program.

When degradation is identified through general condition monitoring, the corrective

action program is utilized to track the specific issue,' provide corrective actions, and

trend the general issue. -; .

The staff confirmed that this program element satisfies the criteria defined in

Appendix A.1.2.3.5 of the SRP-LR. Trending of the inspection results will be performed

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and will enhance the applicant's ability to detect aging effects before there is a loss of

intended function. On this basis, the staff finds that the applicant's monitoring and

trending program element is acceptable.

(6) Acceptance Criteria - The applicant'stated, in Appendix B, Section B2.1.13 of the LRA,

that the acceptance criterion for visual inspections is the absence of any visual

indication'of external degradation. Evaluations of anomalies found during general

condition monitoring activities determine whether analysis, repair, or further inspection is

required. Degraded conditions that are adverse to quality are entered into the corrective

action program.

The general condition monitoring program also credits visual inspection for the detection

of changes in material properties in elastomers in the ventilation systems and in support

members. During the audit and review, it was' not clear'to the staff how visual

inspections would be used to monitor this aging effect. In a subsequent staff visit to the

plant, the applicant stated that the change of material properties for these elastomer

components is visually observable by evidence of crackinig and crazing, discoloration,

distortion, evidence of swelling, tackiness, evaluation of resilience and indentation

recovery, etc. These conditions are observable during the general condition monitoring

activities performed by the system engineers as part of comprehensive inspections

performed monthly, and by the plant equipment operators during daily inspections of

plant areas to verify component or system operation. The staff reviewed the document

change request, as documented in the staff's MPS audit and review report, that will add

the details for the visual inspection of elastomers to the general condition monitoring

program. The applicant stated in the LRA that the procedures and training for personnel

performing general condition monitoring inspections and walkdowns will be enhanced to

identify the requirements for the inspection of aging effects. This will provide a

reasonable assurance that changes in material properties of elastomer components will

be adequately managed. This commitment is identified on the applicant's license

renewal commitment list in the LRA, Appendix A, Table 6.0-1, Item 10. Based on

discussions with plant staff and the review of the LRA commitment and document

change request, the staff concurs that change in material properties can be visually

observed.

The staff confirmed that this program element satisfies the criteria defined in Appendix

A.1.2.3.6 of the SRP-LR. Any anomalous indications that are signs of degradation will

be evaluated to determine whether the observed deterioration of material condition is

significant enough to compromise the ability of the in-scope structures and components

to perform their intended functions. If found unacceptable, corrective measures will be

implemented. On this basis, the staff finds that the applicant's acceptance criteria

program element is acceptable.

(7) Operating Experience - The applicant stated, in the program basis document, that the

effects of aging are found in normally accessed areas during routine work tasks,

walkdowns, and inspections. Engineering evaluations and corrective actions are

implemented, as necessary, to correct conditions that are adverse to quality.

Management of degradation due to aging effects is not typically required and minor

degradation is resolved through the work control process. Additionally, inspection results

from reviews by outside organizations are used to help confirm that plant integrity and

material condition are maintained.

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The staffs review of station operating experience indicates that while degradation has

occurred, routine work tasks, walkdowns and inspection activities have been effective in

identifying anomalies and implementing corrective actions. When inspection results

have warranted, corrective actions have been implemented to ensure that the structures

and components continue to perform their intended function.

No operating experience was'identified that allowed the staff to conclude that general

condition monitoring activities have been' effe6ctive in rmanaging changes'in the matenrial

properties of elastomers in the ventilation systems or in support structures and

components. However, as part of the commitment identified in LRA Appendix A, Table

6.0-1, Item 10, the procedures and training for' personnel performing general condition,

monitoring inspections and walkdowns will be enha'nced to identify the requirements for

the inspection of aging effects. This will provide reasonable assurance that changes in

material properties of elastomer components will be adequately managed.

On the basis of its review of the above operating experience, the staff concludes that

the general condition monitoring program will adequately manage the aging effects that

have been observed at the applicant's plant..'

FSAR SupDlement. In Appendix A, Section A2.1.13 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.12 of the MPS Unit 3 LRA, the applicant provided the FSAR supplement for the

general condition monitoring program and stated that the program manages the aging effects

of loss of material, change of material properties, and cracking on the external surfaces of

components. It is performed in accessible plant areas for components and structures including

those within the scope of license renewal and involves visual inspections for evidence of

age-related degradation. The acceptance criterion for visual inspections is the absence of

anomalous indications that are signs of degradation. Corrective actions for conditions that are

adverse to quality are performed in accordance with the corrective action program as part of the

quality assurance program.

The staff reviewed the FSAR supplements and confirmed that they provide an adequate

summary description of the program, as identified in the SRP-LR FSAR supplement table and

as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, the staff finds that

the applicant has demonstrated that the effects'of aging will be adequatelynmanaged 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 FSAR supplements

for this AMP and finds that they provide an adequate summary description of the program, as

required by 10 CFR 54.21 (d). . .:, '

3.0.3.3.3 Infrequently Accessed Areas Inspection Program

Summary of Technical Information in the Abplication. The applicant's infrequently accessed

areas inspection program is described in LRA'Section'B2.1.15, "Infrequently'Accessed Areas

Inspection Program." In the LRA, the applicant stated that this program is a new plant-specific

program that will be initiated prior to the period of 'extended operation. The applicant credits this

program with managing the aging effects for loss of material, change in material properties, and

cracking using visual inspections of the external surfaces of structures and components. All

areas not normally accessible for inspection and evaluation, and that contain structures or

components subject to aging management, have been identified for inclusion in the program.

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The applicant stated in the LRA that a baseline inspection of in-scope structures and

components will be performed. An engineering evaluation of the inspection results will be used

to determine whether additional inspections of SCs in the infrequently accessed areas

inspection program are required.

In the LRA, the applicant stated that the infrequently accessed areas inspection program will be

established prior to the period of extended operation. This commitment is identified in Appendix

A, Table A6.0-1 License Renewal commitments, Item 12.

Staff Evaluation. In accordance with 10 CFR 54.21 (a)(3), the staff reviewed the information

included in Appendix B, Section B2.1.15 of the LRA, regarding the applicant's demonstration of

the infrequently accessed areas inspection program to ensure that the effects of aging, as

discussed above, will be adequately'managed'so that the intended functions will be maintained

consistent with the CLB throughout the period of extended operation.

The staff reviewed the infrequently accessed areas inspection program against the AMP

elements found in the SRP-LR, Appendix A, Section A.1.2.3, and SRP-LR Table A.1-1 and

focused on how the program manages aging effects through the effective incorporation of 10

elements (i.e., program scope, preventive actions, parameters monitored or inspected,

detection of aging effects, monitoring and trending, acceptance criteria, corrective actions,

confirmation process, administrative controls, and operating experience).

The applicant indicated that the corrective actions, confirmation process, and administrative

controls are part of the site-controlled quality assurance program. The staff's evaluation of the

quality assurance program is provided separately in Section 3.0.4 of this SER. The remaining

seven elements are discussed below.

(1) Scope of the Program - The applicant stated, in Appendix B, Section B2.1.15 of the

LRA, that the following infrequently accessed areas of the plant are in scope of this

program: Unit 2 and Unit 3 intake structure circulating water bays (below the floor and

above the water); Unit 2 bypass line (interior of the concrete pipe); Unit 3 auxiliary

building heat exchanger room at elevation 4-feet, 6-inch elevation; Unit 3 service water

pipe enclosure in the control building; Unit 3 regenerative heat exchanger room in

containment; Unit 3 auxiliary building to fuel building pipe tunnel; Unit 3 containment

enclosure building (supplementary leak collection-and-release system duct); Unit 3 area

between the reactor vessel and neutron shield tank in containment; Unit 3 emergency

diesel generator cubicles upper level area; Unit 3 cable spreading area, north and south

electrical tunnels, tops of the switchgear rooms; Unit 3 recirculation tempering line

(interior of concrete pipe) and associated valve pit; Unit 3 auxiliary building demineralizer

alley (inside the cubicles); and MPS stack.

The staff reviewed and confirmed that this program element satisfies the criterion

defined in Appendix A.1.2.3 of the SRP-LR. The proposed scope identifies the specific

components for which the program manages aging. On this basis, the staff team finds

that the applicant's proposed program scope is acceptable.

(2) Preventive Actions - The applicant stated, in Appendix B, Section B2.1.15 of the LRA,

that the inspection activities for infrequently accessed areas are designated condition

monitoring. No preventive actions are performed.

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The staff confirmed that the preventive actions program element satisfies the criterion

defined in Appendix A.1.2.3.2 of the'SRP-LR. The staff did not identify the need for

preventive actions for the infrequently accessed areas inspection program because it is

a condition monitoring program.

(3) Parameters Monitored or Inspected -The applicant stated, in Appendix B, Section

B2.1.15 of the LRA, that infrequently accessed areas will undergo visual inspections to

identify degradation or adverse conditions that include component leakage; rust or

corrosion products; peeling, bubbling, or flaking coatings; indications of chemical attack;

corroded fasteners; deformed or mispoisitioned piping and cable supports; and cracking of concrete, supports, or sealant. i

The staff confirmed that this program element satisfies the criteria defined in Appendix A.1.2.3.3 of the SRP-LR. The infrequently accessed areas inspection program is

acceptable because the visual inspections for loss of material, change in material

properties, and cracking are intended to detect the presence'and extent of aging effects.

On this basis, the staff finds that the parameters monitored or inspected program element is acceptable. '

(4) Detection of Aging Effects - The applicant stated, in Appendix B, Section B2.1.15 of the

LRA, that the external conditions of structures and components located in the

infrequently accessed areas are determined by visual inspection. These inspections detect the aging effects of loss of material, cracking, and change of material properties. An inspection plan will be developed and inspections in infrequently'accessed areas will

be performed prior to the period of extended operation. The inspections will assess the

aging of in-scope components and structures located in the infrequently accessed areas

identified above. An engineering evaluation of the inspection results will determine the

need for subsequent inspections. -

The staff reviewed and confirmed that this program element satisfies the criteria defined

in Appendix A.1.2.3.4 of the'SRP-LR.'The use of visual inspection of the external

condition of infrequently accessed structures, supports, piping, and equipment is

consistent'with industry practices, and is considered by the staff to be a reasonable

means of detecting loss of material, cracking, and change in material properties before

the loss of intended function. On this basis, the staff finds that the applicant's detection

of aging effects program element is acceptable.

(5) Monitoring and Trending - The applicant stated, in Appendix B, Section B2.1.15 of the

LRA, that monitoring of the structures and components in infreqikently accessed areas

will be accomplished through the performance of baseline inspections. These'

inspections will be conducted prior to the period of extended operation. Inspection

results will be documented for engineering evaluation and retention.

The staff confirmed that this program delement satisfies the criteria in Appendix A.1.2.3.5

of the SRP-LR. The applicant committed to conducting one-time' inspections prior to the

end of the current operating license term and will document the results for evaluation

and retention. If degradation is ideritified, itwill be evaluated and correctd in

accordance with the applicant's corrective action program. Trending is currently not part of this program and none is required by current industry practices for visual inspection activities in similar applications. On this basis, the staff finds that the applicant's

monitoring and trending program element is acceptable.

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(6) Acceptance Criteria - The applicant stated, in Appendix B, Section B2.1.15 of the LRA,

that the acceptance criterion for visual inspections is the absence of anomalous

indications that are signs of degradation. Degradation that is adverse to quality will be

entered into the corrective action system.

The staff confirmed that this program element satisfies the criteria defined in

Appendix A.1.2.3.6 of the SRP-LR. Any anomalous indications that are signs of

degradation will be evaluated by an engineer to determine whether the observed

deterioration of material condition is significant enough to compromise the ability of an

SC in an infrequently accessed area to perform its intended function. If found

unacceptable, corrective measures will be implemented. On this basis, the staff finds

that the acceptance criteria program element is acceptable.

(7) Operating Experience - The applicant stated, in Appendix B, Section B2.1.15 of the

LRA, that the infrequently accessed areas inspection program is a new program for

which there is no operating experience.

The staff finds that the one-time baseline inspections of infrequently accessed areas are

consistent with years of industry practice that has been effective in maintaining similar

SCs and, therefore, can reasonably be expected to be effective at maintaining the

intended functions of the SCs that are within the scope of this evaluation for the period

of extended operation.

On the basis of its review of the above operating experience, the staff concludes that

the infrequently accessed areas inspection program will adequately manage the aging

effects that have been observed at the applicant's plant.

FSAR Supplement. In Appendix A, Section A2.1.15 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.14 of the MPS Unit 3 LRA, the applicant provided the FSAR supplements for the

infrequently accessed areas inspection program, which state that the program will manage the

aging effects of loss of material, change in material properties, and cracking. Visual inspections

will be performed to ensure the absence of anomalous indications that are' signs of degradation.

The acceptance criterion for the visual inspections is the absence of anomalous indications that

are signs of degradation. Corrective actions for conditions that are adverse to quality are

performed in accordance with the corrective action program as part of the quality assurance

program.

The staff reviewed the FSAR supplements and confirmed that they provide an adequate

summary description of the program, as identified in the SRP-LR FSAR supplement table and

as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review and audit of the applicant's program, 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). The staff also reviewed the FSAR supplements

for this AMP and finds that they provide an adequate summary description of the program, as

required by 10 CFR 54.21 (d).

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3.0.3.3.4 Work Control Process

Summary of Technical Information in the ADDlication. The applicant's work control process is

described in LRA Section B2.1.25, "Work Control Process." In the LRA, the applicant stated

that this is an existing plant-specific program. The applicant credits the'work control process as

means for planning and conducting maintenance activities to manage the aging effects on

system components, commodities, and adjacent piping, and structures within the scope of

license renewal. Preventive and corrective maintenance activities are planried and conducted in

accordance with the applicant's work control process.

The applicant stated in the LRA that the work control process is used to'manage the aging

effects of buildup of deposits, change of material properties, cracking, and loss of material for

components and plant commodities within the scope of license renewal. Maintenance activities

performed under the work control process provide an opportunity to visually inspect system

components, commodities, and adjacent piping, and plant structures. Adjacent piping, including

surfaces immediately adjacent to a component, is accessible for visual inspection through the

component. Plant structures are accessible wh'en an area next to-a structure is excavated for

other maintenance work. The work control process also provides opportunities to collect oil and

engine coolant fluid samples for subsequent analysis of contaminants and chemical properties,

which could either indicate or affect aging. The work control process tracks and documents the

performancelof inspection and surveillance activities, such as Appendix R fire cage inspections

and pump-down and inspection of underground electrical cable enclosures. Maintenance

activities performed through the work control process also verify the effectiveness of the

chemistry control for primary systems, chemistry' control for secondary systems, and fuel oil

chemistry programs.

Staff Evaluation. In accordance with 10 CFR 54.21 (a)(3),'the staff reviewed the information

included in Appendix B,'Section B2.1.25, of the LRA, regarding the applicant's demonstration of

the work control process to ensure that the effects of aging, as discussed above, will be

adequately managed so that the inteided functions will be maintained consistent with the CLB

throughout the period of extended operation.

The staff reviewed the work control process againtst the AMP elements found in the SRP-LR,

Appendix A, Section A.1.2.3, and SRP-LR Table A.1-1 and focused on how the program

manages aging effects through the effective'incorporation of 10 elements (i.e., program scope,

preventive actions, parameters monitored or inspected, detection of aging effects, monitoring

and trending,'acceptance criteria, corrective actions, confirmation process, administrative

controls, and operating experience).

The applicant indicated that the corrective actions, confirmation process, and administrative

controls are part of the site-controlled quality assurance program. The staff's evaluation of the

quality assurance program is provided separately in' Section 3:0.4 of this SER. The remaining

seven elements are discussed below.

Scope of the Program The applicant'stated, in Appendix B, Section B2.1.25 of the

LRA, that the program encompasses' performance testing and maintenance activities

(preventive and corrective) that are planned and conducted in accordance with the work

control process. These activities provide an opportunity to perform and document visual

inspections of the internal and external surfaces of various material and environment

combinations of plant components and commodities within the scope of license renewal,

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-" I

including visual examination of the internal and external surfaces of plant components,

visual examination of plant commodities, performance (periodic) tests of mechanical

components, routine maintenance sampling of motor lubricating oil and engine coolant,

recurring inspection and surveillance activities, equipment monitoring, and data trending

and analysis. Activities performed by the work control process also verify the

effectiveness of other aging management programs.

The staff requested that the applicant provide additional information to confirm that all of

the component groups listed in Section 3 of the MPS Units 2 and 3 LRAs that credit the

work control process program are covered by the planned maintenance portion (i.e.,

preventive maintenance, predictive analysis, periodic surveillance) of the work control

process program such that these components will be periodically inspected during the

period of extended operation.

In an LRA supplement letter, dated July 7, 2004, (ML041900407), the applicant stated

the following in response to the staff's request:

The following wording should be added to MPS Unit 2 and Unit 3 Appendix B,

Section B2.1.25 (page B-112):

Enhancement 2 - Verification of Program Scope

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, Items (31 for MPS

Unit 2) (32 for MPS Unit 3).

This commitment will be implemented prior to the period of extended operation.

The staff reviewed and confirmed that this program element, as modified, satisfies the

criterion defined in Appendix A of the SRP-LR. The proposed scope, including the

enhancements change, identifies the specific components for which the program

manages aging. On this basis, the staff finds that the applicant's proposed program

scope is acceptable.

Preventive Actions - The applicant stated, in Appendix B, Section B2.1.25 of the LRA,

that the inspection activities conducted as part of the work control process program are

designated as condition monitoring, the testing activities of the work control process

program are designated as performance monitoring, and the chemistry control activities,

in conjunction with the maintenance sampling activities, are designated as preventive

actions.

The staff confirmed that this program element satisfies the criterion defined in

Appendix A.1.2.3.2 of the SRP-LR. The absence of preventive actions in the condition

and performance monitoring portions of the program is consistent with the requirements

of the SRP-LR. Description of the chemistry control activities and sampling activities as

preventive is appropriate. On this basis, the staff finds the preventive actions program

element is acceptable.

Parameters Monitored or Inspected - The applicant stated, in Appendix B, Section

B2.1.25 of the LRA, that visual inspections of the internal and external surfaces of plant

components and plant commodities are performed during the performance of

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maintenance to determine the presence of cracking, loss of material, change of material

properties, and buildup of deposits. Lubricating oil and engine coolant samples are

analyzed to detect contaminants that may indicate an environment that can lead to

material degradation. - -'

This AMP identifies the use of lubricating oil analysis to detect contaminants.' During the

audit, the staff requested that the applicant provide information to show that oil sampling

is performed to specific industry standards and that the samples are representative, and

to identify the basis for the frequency of sampling and present operating experience to

demonstrate that the sampling is effective in detecting contaminants. The applicant

identified to the staff that the governing procedures for oil sampling at MPS are

CBM-103 "Oil Sampling" and CBM-106 "Oil Analysis." The sampling procedures include

a check for the presence of water. Frequencies for sampling are 'established based on

equipment operating schedules, operating history, etc. Corrective actions are

determined to resolve abnormal indications. The staff reviewed oil sampling procedures

and finds the information presented therein to be acceptable.

The staff confirmed that this pr6gram element satisfies the criteria defined in

Appendix A.1.2.3.3 of the SRP-LR. On the basis of interviews with the applicant's

technical staff and the enhancement to the scope of program element, the staff finds

that the applicant's parameters monitored or inspected program element is acceptable.

Detection 'of Aging Effects - The applicant stated, in Appendix B, Section B2.1.25 of the

LRA, that cracking, loss of material,- buildup of deposits, and changes of material

properties are the aging effects that are monitored by visual inspections of the internal

and external surfaces of structural and mechanical components, and plant commodities.

The results of analyses of lubricating oil and engine coolant samples provide indication

of any adverse environment that could lead to material degradation.

The applicant stated in the LRA that the program will be enhanced such that changes

will be made to maintenance and work control procedures to ensure that inspections of

plant components and commodities will be appropriately and consistently performed and

documented for aging effects during maintenance activities. ;

In the LRA, the applicant also stated that maintenance and work control procedures

ensure that inspections of plant components and plant commodities will be appropriately

and consistently performed and documented during maintenance activities. This

commitment is identified in Appendix A, Table A6.0-1 License Renewal commitments,

Item 25 (MPS ,Unit 2) and 26 (MPS Unit 3).'

The work control process credits visual inspection for the detection of changes in

material properties in rubber in steam generator nozzle dams and holddown rings,

elastomers in ventilation systems, rubber expansion joints in the condensate system,

O-rings and gaskets in containment structures (personnel hatch and reactor cavity seal)

supports, the spent fuel pool gate seal, fire/EQ barrier penetration seals, 'and gaskets (in

junction, terminal, and pull boxes)., --

The staff could not determine how vis'ual inspections could be used to manage this

aging effect and requested further clarification from the applicant. During the audit, the

applicant stated to the staff that the change of material properties for these elastomer

conImponents is visually observable'3' such conditiohs as evidence of 'cracking and

crazing, discoloration, distortion, evidence of swelling, ta6kiness, evaluation of resilience

and indentation recovery, etc. These conditions are observable during the internal

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*_-__

inspections performed as part of the work control process program. The staff reviewed

the document change request, as documented in the staff's MPS audit and review

report, that will add the details for the visual inspection of elastomers to the work control

process. The staff finds that change of material properties could be observable visually

as clarified by the applicant.

The applicant stated in the LRA that selective leaching was not identified during the

applicant's aging management reviews as an'aging mechanism requiring management.

However, the LRA Table 3.3.1, stated that components (aluminum bronze, brass, cast

iron, cast steel) in open- and closed-cycle cooling water systems 'and the ultimate heat

sink are subject to loss of material due to selective leaching.: The applicant identified in

LRA Table 3.3.1, the work control process and buried pipe inspection programs to

manage selective leaching. In discussions between the staff and the applicant, the

applicant stated that the purpose of crediting the work control process program with

managing the effects of selective leaching was to provide an accounting of which GALL

AMPs were being implemented at MPS, and that the wording in LRA Table 3.3.1 was

not intended to indicate that selective leaching does not require management at MPS.

GALL AMP XI.M.33, -Selective Leaching of Materials," recommends a-combination of

one-time inspection and hardness measurement to manage selective leaching. Since

selective leaching is a slow-acting corrosion process, it is recommended that this should

be performed as late in the plant life as possible, preferably after 30 years of service.

Selective leaching generally does not cause changes in dimension and is difficult to

detect by visual inspection. Hence, the GALL Report recommends a Brinnell hardness

test be performed on the inside surfaces of a' selected set of components to determine if

selective leaching has occurred. Alternatively, if a component is removed from service

for whatever reason, a destructive test could be performed.

The applicant stated in the LRA that the work control process program credits visual

inspection only for detection of selective leaching. During the audit, the staff asked the

applicant to justify the use of visual inspection only, or to provide other means of

detection such as, Brinnell hardness, destructive testing, or other mechanical means

such as scraping, chipping, etc.

In an LRA supplement letter dated July 7, 2004, (ML041900407), the applicant stated

the following:

For MPS Unit 2 and Unit 3 Appendix B, Section B2.1.25, Detection of

Aging Effects (page B-109), the following should be inserted after the first

sentence:

"When performing field inspections for loss of material due to selective leaching,

visual inspections will include mechanical means, such as resonance when

struck by another object, scraping, or chipping."

For MPS Unit 2 and Unit 3 Appendix B, Section B2.1.25, new Enhancement 3

should be added and read (page B-1 12), as follows:

Enhancement 3: Selective Leaching Inspections

Using the Work Control Process, a baseline inspection for the loss of material

due to selective leaching will be perforrhed on a representative sample of

locations for susceptible materials by visual, and mechanical or other. appropriate

methods prior to entering the period of extended operation.

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This commitment is identified in Appendix A, Table A6.01 License Renewal

commitments, Item 30 (MPS Unit 2) and 31 (MPS Unit 3).

This enhancement will be implemented 'prior to the period of extended operation.

Program Elements Affected

Detection of Aging Effects

The NUREG-1801 program element identifies that the program should detect

aging effects before there is a loss of structure or component intended function.

The baseline inspection for selective leaching will provide reasonable assurance

that the loss of material aging effect, due to selective leaching, will be detected

before there is a loss of intended function.

The staff finds the revisions to the MPS LRA, as presented in the supplement letter, to

be acceptable.

The results of analyses of lubricating 61 and 'engine coolant samples prov~ide indication

of any adverse environment'that could lead to material degradation. The applicant's

work control process program, as described in the LRA, identifies the use' of lubricating

oil analysis to'detect contaminants. During the audit, the staff requested that the -

applicant provide information to'show that oil sampling is performed to specific industry

standards and that the samples are representative, and to identify the basis for the

frequency of sampling and present operating experience to demonstrate that the

sampling is effective in detecting contaminants. The applicant stated to the staff the

governing procedures for oil sampling at MPS are CBM-103'and CBM-1 06. The

sampling procedures include a check for the presence of water' Frequencies for

sampling are established based on equipment operating schedules, operating history,

etc. Corrective actions are determined to resolve abnormal indications. The staff

reviewed oil sampling procedures andfinds the information presented therein to be

acceptable.

The staff reviewed and confirmed that this program element,-as modified, satisfies the

criteria defined in Appendix A.1.2.3.4 of the SRP-LR with enhancements, revisions, and

clarifications as identified above. The measurements and inspections use a frequency

and sample size based ori operating experience to detect the presence and extent of

aging effects. On this basis, the staff finds that the detection of aging effects program

element is acceptable.

Monitoring and Trending - The applicant stated, in Appendix B, Section B2.1.25 of the

LRA, that frequencies of preventive maintenance work activities vary, with some

activities being performed only during refueling outages. Monitoring these activities

involves reviews of the documentation generated by the work control process program,

including completed procedures and technical reviews of engineering evaluations. In

addition, as described in the applicant's procedures, reviews and evaluations are

conducted for changes to preventive mairitenance work activities, including deferrals,

missed implementation dates, and frequency' changes, as Well as additions, revisions, or

deletions. The applicant stated in the LRA that the reviews are conducted by system

engineers, preventive maintenance 'coordinators, and affected program owners, as

appropriate.

In the LRA, the applicant stated that an integral function of the work control process

program is to maintain a component work history database to support long-term

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equipment reliability monitoring, trending, and analysis. The work history database is

maintained and accessible.

In the LRA, the applicant also stated that maintenance and work control procedures

ensure that inspections of plant components and plant commodities will be appropriately

and consistently performed and documented during maintenance activities.

The applicant stated in the LRA that the program will be enhanced such that changes

will be made to maintenance and work control procedures to ensure that inspections of

plant components and commodities will be appropriately and consistently performed and

documented for aging effects during maintenance activities. This commitment is

identified in Appendix A, Table A6.0-1 License Renewal commitments, Items 25 (MPS

Unit 2) and 26 (MPS Unit 3).

The staff confirmed that this program element satisfies the criteria defined in Appendix

A. 1.2.3.5 of the SRP-LR. Trending of inspection results will be performed and will

enhance the applicant's ability to detect aging effects before there is a loss of intended

function. On this basis, the staff finds that the applicant's monitoring and trending

program element is acceptable.

Acceptance Criteria - The applicant stated, in Appendix B, Section B2.1.25 of the LRA,

that the acceptance criterion for visual inspections is the absence of anomalous signs of

degradation. The acceptance criteria for testing or sampling are specified in the various

station procedures and/or vendor technical manuals or recommendations. Evidence of

aging effects that are potentially adverse to quality is entered into the corrective action

program and engineering evaluations are performed as necessary to determine whether

the observed condition is acceptable without repair, or if repair or replacement is

necessary.

The staff confirmed that this program element satisfies the criteria defined in Appendix

A.1.2.3.6 of the SRP-LR. Appropriate criteria are in place and any evidence of aging

effects potentially adverse to quality will be adequately documented and appropriate

action taken per the applicant's corrective action program. On this basis, the staff finds

that the acceptance criteria program element is acceptable.

Operating Experience - The applicant stated, in Appendix B. Section B2.1.25 of the

LRA, that the work control process activities that involve component inspections,

performance testing, and fluid sampling are performed routinely. The applicant has

reviewed site-specific work history data to confirm that an adequate number of

inspection opportunities are afforded by the work control program. The applicant also

stated in the LRA that the plant corrective action program, which captures internal and

external plant operating experience issues, provides reasonable assurances that

operating experience will be reviewed in the future to provide objective evidence to

support the conclusion that the effects of aging will be managed adequately.

The staff reviewed an assessment based on observations made during industry group

evaluations (e.g., Institute of Nuclear Power Operations) regarding the station's

operation and material condition. Based on the staff's review of that assessment and of

station-specific operating experience, the staff finds that the work control process

program has been effective in identifying anomalies, implementing appropriate

corrective actions, and trending parameters. When inspection results have indicated

signs of degradation, corrective actions have been implemented to ensure the continued

capability of the system to perform its intended functions.

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On the basis of its review of the above 'perating experience, the staff finds that the

work control process will adequately manage the aging effects that have been observed

at the applicant's plant.

FSAR SupDlement. In Appendix A, Section A2.1.25 of the MPS Unit 2 LRA and Appendix A,

Section A2.1.24 of the MPS Unit 3 LRA, the applicant provided the FSAR supplements for the

work control process program which state that the'program integrates'and 'coordinates the

combined efforts of maintenance, engineering, operations, and other support organizations to

manage maintenance activities. The program manages the aging effects of loss of material,

change of material properties, cracking, and buildup of deposits for components'and plant

commodities within the scope of license renewal. -The acceptance criterion for visual inspections

is the absence of anomalous signs of degradation.The'acceptance criteria for testing or

sampling are specified in the various station procedures and/or vendor technical manuals or

recommendations. Corrective actions for conditions that are adverse to quality are performed in

accordance with the corrective action program as part of the quality assurance program.

The staff reviewed.the FSAR supplement and the additional information as identified in the LRA

supplement letter, and confirmed that it provides an'adequate summary description of the

program, as identified in the SRP-LR FSAR supplement table and as required by

10 CFR 54.21 (d).

Conclusion. On the basis of its review and audit of the applicant's program, 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). The staff also reviewed the FSAR supplement

for this AMP and finds that it provides an adequate summary description of the program, as

required by 10 CFR 54.21(d).

3.0.4 Quality Assurance Program Attributes Integral to Aging Management Program

Pursuant to 10 CFR 54.21 (a)(3), a license renewal applicant is required to demonstrate that the'

effects of aging on SCs subject to an AMR will be adequately managed so that their intended

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

NUREG-1 800,' Branch Technical Position RLSB-1, T

Aging Management Review - Generic,"

describes ten attributes of an acceptable AMP. Three of these'ten attributes (program

elements) are associated with the QA activities of (7) corrective action, (8) confirmation

process, and (9) administrative control. Table A.1-1, 'Elements of an Aging Management

Program for License Renewal," of Branch Technical Position RLSB-1 provides the following description of these quality attributes: -

* corrective actions, including root cause determination and prevention of 'recurrence,

should be timely; .

* the confirmation process should ensure that preventive actions are adequate and that

appropriate corrective actions have bben'cormpleted and are effective; and,

* administrative controls should provide a formal review and approval process.

NUREG-1800, Branch Technical Position IQMB-1, "Quality Assurance For Aging Management

Programs," noted that those aspects of the AMP 'that affect quality of SR SSCs are subject to

the QA requirements of 10 CFR Part 50, Appendix B. Additionally, for NSR SCs subject to an

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AMR, the existing .10 CFR Part 50, Appendix B, QA program may be used by the applicant to

address the program elements of (7) corrective action, (8) confirmation process, and (9)

administrative control. Branch Technical Position IQMB-1 provides the following guidance with

regard to the QA attributes of AMPs:

Safety-related SCs are subject to 10 CFR Part 50, Appendix B, requirements which are

adequate to address all quality-related aspects of an AMP consistent with the CLB of the facility

for the period of extended operation..

For NSR SCs that are subject to an AMR for license renewal, an applicant has an option to

expand the scope of its 10 CFR Part 50, Appendix B, program to include these SCs to address

corrective action, confirmation process, and administrative control for aging management

during the period of extended operation. In this case, the applicant should document such a

commitment in the FSAR supplement in accordance with 10 CFR 54.21(d).

3.0.4.1 Summary of Technical Information in Application

Section 3.0, 'Aging Management Review Results," of the LRAs provides an AMR summary for

each unique structure, component, or commodity group at the MPS, Units 2 and 3, determined

to require aging management during the period of extended operation. This summary includes

identification of aging effects requiring management and AMPs utilized to manage these aging

effects. Appendix A, UFSAR Supplement," and Appendix B, "Aging Management Programs," of

the LRA, demonstrate how the identified programs manage aging effects using attributes

consistent with the industry and NRC guidance. The applicant's programs and activities that are

credited with managing the effects of aging can be divided into three types of programs:

existing, enhanced, and new AMPs. In Section A2.0, "Programs That Manage the Effects of

Aging," the applicant discusses that the QA program includes the program elements of

corrective action, confirmation process, and administrative controls and is applied to both SR

and NSR SSCs that are within the scope of license renewal. In Section B.1.3, "Quality

Assurance Program and Administrative Controls," the applicant discusses the implementation

of 10 CFR 50, Appendix B, and its consistency with the summary in Appendix A.2 of NUREG1800 (Reference B-1). The QA program includes the elements of corrective action, confirmation

process, and administrative control, and is applicable to the SR and NSR SSCs that are subject

to an AMR. In many cases, existing programs were found to be adequate for managing aging

effects during the period of extended operation. Generically, the three elements are applicable

as follows:

(1) Corrective Action - A single corrective actions process is applied regardless of the safety

classification of the structure or component. Corrective actions are implemented through

the initiation of an action request in accordance with plant procedures established

pursuant to 10 CFR 50, Appendix B. Plant procedures require the initiation of an action

request for actual or potential problems, including unexpected plant equipment

degradation, damage, failure, malfunction, or loss. Site documents that implement AMP

for license renewal will direct that an action request be prepared in accordance with

those procedures whenever non-conforming conditions are found (i.e., the'acceptance

criteria are not met). Equipment deficiencies are corrected through the initiation of a

work order in accordance with plant procedures. Although equipment deficiencies may

initially be documented by a work order, the corrective action process specifies that an

action request also be initiated if required.

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(2) Confirmation Process - The focus of the confirmation process is on the follow-up actions

that must be taken to verify effective lmpleimentation of corrective actions. The measure

of effectiveness is in terms of correcting the adverse condition and precluding repetition

of significant conditions adverse to quality. Pl6nt procedures include provisions for timely

evaluation of adverse conditions and implementation of any corrective actions required,

including root cause determinations and prevention of recurrence where appropriate

(e.g., significant conditions adverse to quality). These procedures provide for tracking,

coordinating, monitoring, reviewing, verifying, validating, and approving corrective

actions, to ensure effective corrective actions are taken. The action request process is

also monitored for potentially adverse trends. The existence of an adverse trend due to

recurring or repetitive adverse conditions will result in the initiation of an action request.

The AMP required for license renewal would also uncover any unsatisfactory condition

due to ineffective corrective action. Since the same 10 CFR 50, Appendix B, corrective

action and confirmation process is applied for nonconforming SR and NSR SCs subject

to AMR for license renewal, the corrective action program is consistent with NUREG1800.

(3) Administrative Control - Administrative control procedures provide information on

procedures and other forms of administrative control documents as well as guidance on

classifying documents into the proper document type.'Procedure attachments provide a

chart showing the administrative controls hierarchy and a document type decision tree.

3.0.4.2 Staff Evaluation

The staff reviewed the applicant's AMPs described in Appendix A, 'FSAR Supplement,"

specifically Appendix A2.0, 'Programs That Manage the Effects of Aging," and Appendix B,

'Aging Management Programs," specifically Appendix B1.3, "Quality Assurance Program and

Administrative Controls," of the MPS Unit 2 and 3 LRAs. The purpose of this review was to

assure that the aging management activities were consistent with the staff's guidance

described in NUREG-1 800, Section A.2, "Quality Assurance for Aging Management Programs

(Branch Technical Position IQMB-1)," regarding QA attributes of AMPs. Based on the staff's

evaluation, the descriptions and applicability of the plant-specific AMPs and their associated

quality attributes provided in Appendix A2.0 and Appendix B1.3, the staff concluded that the

program descriptions are consistent with the staff's position and the Branch Technical Position

discussed in IQMB-1.

The station switchyard, which is not owned by the applicant, contains components which were

determined to be in scope of license renewal in accordance with the SBO criterion in

10 CFR 54.4(a)(3) and have been determined to require an AMP. The applicant documented

this conclusion and indicated that the applicable switchyard components would be included in

the applicable AMP and that the attributes of corrective action, confirmation process, and

administrative controls would be administered in accordance with the applicant's 10 CFR Part

50, Appendix B, QA program as discussed in both Appendix A and B of the LRA. In addition,

Appendix B of the LRA also identified the addition of the switchyard components to the

applicable AMPs.

3.0.4.3 Conclusion

The staff concludes that the QA attributes of the applicant's AMPs are consistent with

10 CFR 54.21 (a)(3). Specifically, the applicant described the quality attributes of the programs

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and activities for managing the effects of aging for both SR and NSR SSCs within the scope of

license renewal and stated that the 10 CFR Part 50, Appendix B, QA program addresses the

elements of corrective action, confirmation process, and administrative control. Therefore, the

applicant's QA description for its AMPs is acceptable.

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NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(9-2004) (Ass Igned by NRC, Add Vol., Supp., Rev,

NRCMD 3.7 and Addendum Numbers. It any.)

BIBLIOGRAPHIC DATA SHEET

(See GostructWos on the reverse) Vol. 1

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

Safety Evaluation Report Related to the License Renewal of the Millstone Power Station, Units MONTH YEAR

2 and 3

October 2005

4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

Johnny H. Eads

7. PERIOD COVERED (Indlusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (it NRC. pmovde Divsior Office or Region, US. Nuclear Regutatory Commisson. and maling address; contractor.

provide name and maising 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 Same as above; ifcontracor provideNRCDrOsion. Office orRegion. U.S. NudearRegulatory Commission.

and mairing address)

Same as above

10. SUPPLEMENTARY NOTES

11. ABSTRACT (200 wonrds or ess)

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

License 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 staff's 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 WORDS/DESCRIPTORS (List words orphrases that wixm ssisresearchers ilocatingte report) 13. AVALABILITY STATEMENT

license renewal, nuclear power unlimited

14. SECURITY CLASSIFICATION

(M!us page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (92004) PRINTED ON RECYCLED PAPER
Printed

son reccld

paper

Federal Recycling Program
5

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, DC 20555-0001

OFFICIAL BUSINESS

I.j'