Safety Evaluation Report 

Related to the License Renewal of 

Susquehanna Steam Electric 

Station, Units 1 and 2 

Docket Nos. 50-387 and 50-388 

PPL Susquehanna, LLC 

Office of Nuclear Reactor Regulation 

NUREG-1931
AVAILABILITY OF REFERENCE MATERIALS

IN NRC PUBLICATIONS

NRC Reference Material

As of November 1999, you may electronically access

NUREG-series publications and other NRC records at

NRC's Public Electronic Reading Room at

http://www.inrc..ov/readinq-rm.html.

Publicly released records include, to name a few,

NUREG-series publications; Federal Register notices;

applicant, licensee, and vendor documents and

correspondence; NRC correspondence and internal

memoranda; bulletins and information notices;

inspection and investigative reports; licensee event

reports; and Commission papers and their

attachments.

NRC publications in the NUREG series, NRC

regulations, and Title 10, Energy, in the Code of

Federal Regulations may also be purchased from one

of these two sources.

1. The Superintendent of Documents

U.S.'Government Printing Office

Mail Stop SSOP

Washington, DC 20402-0001

Internet: bookstore.gpo.gov

Telephone: 202-512-1800

Fax: 202-512-2250

2. The National Technical Information Service

Springfield, VA 22161-0002

www.ntis.gov

1-800-553-6847 or, locally, 703-605-6000

A single copy of each NRC draft report for comment is

available free, to the extent of supply, upon written

request as follows:

Address: U.S. Nuclear Regulatory Commission

Office of Administration

Reproduction and Mail Services Branch

Washington, DC 20555-0001

E-mail: DISTRIBUTION(,nrc.qov

Facsimile: 301-415-2289

Some publications in the NUREG series that are

posted at NRC's Web site address

http://www.nrc.qovireadinq-rm/doc-collections!nureqs

are updated periodically and may differ from the last

printed version. Although references to material found

on a Web site bear the date the material was

accessed, the material available on the date cited may

subsequently be removed from the site.

Non-NRC Reference Material

Documents available from public and special technical

libraries include all open literature items, such as

books, journal articles, and transactions, Federal

Register notices, Federal and State legislation, and

congressional reports. Such documents as theses,

dissertations, foreign reports and translations, and

non-NRC conference proceedings may be purchased

from their sponsoring organization.

Copies of industry codes and standards used in a

substantive manner in the NRC regulatory process are

maintained atThe NRC Technical Library

Two White Flint North

11545 Rockville Pike

Rockville, MD 20852-2738

These standards are available in the library for

reference use by the public. Codes and standards are

usually copyrighted and may be purchased from the

originating organization or, if they are American

National Standards, fromAmerican National Standards Institute

11 West 4 2nd Street

NewYork, NY 10036-8002

www.ansi.org

212-642-4900

Legally binding regulatory requirements are stated only

in laws; NRC regulations; licenses, including technical

specifications; or orders, not in

NUREG-series publications. The views expressed in

contractor-prepared publications in this series are not

necessarily those of the NRC.

The NUREG series comprises (1) technical and

administrative reports and books prepared by the staff

(NUREG-XXXX) or agency contractors

(NUREG/CR-XXXX), (2) proceedings of conferences

(NUREG/CP-XXXX), (3) reports resulting from

international agreements (NUREG/IA-XXXX), (4)

brochures (NUREG/BR-XXXX), and (5) compilations

of legal decisions and orders of the Commission and

Atomic and Safety Licensing Boards and of Directors'

decisions under Section 2.206 of NRC's regulations

(NUREG-0750).
Safety Evaluation Report 

Related to the License Renewal of 

Susquehanna Steam Electric 

Station, Units 1 and 2 

Docket Nos. 50-387 and 50-338 

PPL Susquehanna, LLC 

Manuscript Completed: November 2009 

Date Published: November 2009 

Office of Nuclear Reactor Regulation 

NUREG-1931 
/
ABSTRACT

This safety evaluation report (SER) documents the technical review of the Susquehanna Steam

Electric Station (SSES), Units 1 and 2, license renewal application (LRA) by the United States

(US) Nuclear Regulatory Commission (NRC) staff (the staff). By letter dated September 13,

2006, PPL Susquehanna, LLC (PPL or the applicant) submitted the LRA in accordance with

Title 10, Part 54, of the Code of Federal Regulations, "Requirements for Renewal of Operating

Licenses for Nuclear Power Plants." PPL requests renewal of the Units 1 and 2 operating

licenses (Facility Operating License Numbers NPF-14 and NPF-22, respectively) for a period of

20 years beyond the current expirations at midnight July 17, 2022, for Unit 1, and at midnight

March 23, 2024, for Unit 2.

SSES is located approximately 5 miles northeast of Berwick, PA. The NRC issued the

construction permits for Units 1 and 2 on November 2, 1973. The NRC issued the operating

licenses for Unit 1 on July 17, 1982, and on March 23, 1984, for Unit 2. Units 1 and 2 are of

Mark 2 boiling water reactor (BWR) design. General Electric supplied the nuclear steam supply

system and Bechtel originally designed and constructed the balance of the plant. On January

3 0 th , 2008, an Extend Power Uprate amendment was approved for SSES and the licensed

power output of each unit is 3952 megawatt thermal with a gross electrical output of

approximately 1300 megawatt electric.

This SER presents the status of the staff's review of information submitted through July 28,

2009. The staff identified no open or confirmatory items. SER Section 6 provides the staff's final

conclusion of its LRA review.

iii

TABLE OF CONTENTS

A B S T R A C T ............................................................................................................................... iii

TABLE OF CONTENTS ........................................................................................................ v

ABBREVIATIONS .................................................................................................................... xiii

INTRODUCTION AND GENERAL DISCUSSION ................................................................... 1-1

1.1 Intro d uctio n .......................................................................................................... 1-1

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

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

1.2.2 Environmental Review ........................................................................... 1-4

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

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

1.5 Summary of Proposed License Conditions ........................................................... 1-7

STRUCTURES AND COMPONENTS SUBJECT TO AGING MANAGEMENT REVIEW ....... 2-1

2.1 Scoping and Screening Methodology ................................................................... 2-1

2 .1 .1 Intro ductio n ............................................................................................ 2 -1

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

2.1.3 Scoping and Screening Program Review ............................................... 2-2

2.1.3.1 Implementation Procedures and Documentation Sources for

Scoping and Screening ........................................................... 2-3

2.1.3.2 Quality Controls Applied to LRA Development ........................ 2-5

2 .1.3.3 T ra ining ................................................................................... 2-6

2.1.3.4 Conclusion of Scoping and Screening Program Review .......... 2-6

2.1.4 Plant Systems, Structures, and Components Scoping Methodology ...... 2-7

2.1.4.1 Application of the Scoping Criteria in 10 CFR 54.4(a)(1) ......... 2-7

2.1.4.2 Application of the Scoping Criteria in 10 CFR 54.4(a)(2) ........ 2-10

2.1.4.3 Application of the Scoping Criteria in 10 CFR 54.4(a)(3) ........ 2-16

2.1.4.4 Plant-Level Scoping of Systems and Structures ..................... 2-19

2.1.4.5 Mechanical Component Scoping ............................................ 2-21

2.1.4.6 Structural Component Scoping ............................................... 2-23

2.1.4.7 Electrical Component Scoping ............................................... 2-24

2.1.4.8 Conclusion for Scoping Methodology ..................................... 2-24

2.1.5 Screening Methodology ........................................................................ 2-25

2.1.5.1 General Screening Methodology ............................................ 2-25

2.1.5.2 Mechanical Component Screening ......................................... 2-26

2.1.5.3 Structural Component Screening ........................................... 2-27

2.1.5.4 Electrical Component Screening ............................................ 2-28

2.1.5.5 Conclusion for Screening Methodology .................................. 2-30

2.1.6 Summary of Evaluation Findings .......................................................... 2-30

2.2 Plant-Level Scopinc Results ................................................................................ 2-30

2.2.1 Staff Evaluation ..................................................................................... 2-30

2.2.2 Summary of Technical Information in the Application ........................... 2-36

2.3 Scoping and Screening Results: Mechanical Systems ........................................ 2-36

2.3.1 Reactor Vessel, Reactor Vessel Internals, and Reactor

Coolant System .................................................................................... 2-38

2.3.1.1 Reactor Pressure Vessel ........................................................ 2-38

2.3.1.2 Reactor Vessel Internals ........................................................ 2-38

V
2.3.1.3 Reactor Coolant System Pressure Boundary ......................... 2-40

2.3.2 Engineered Safety Features ................................................................. 2-41

2.3.2.1 Residual Heat Removal System ............................................. 2-41

2.3.2.2 Reactor Core Isolation Cooling System .................................. 2-42

2.3.2.3 Core Spray System ................................................................ 2-43

2.3.2.4 High Pressure Coolant Injection System ................................ 2-44

2.3.2.5 Containment and Suppression System ................................... 2-45

2.3.2.6 Containment Atmosphere Control System .............................. 2-47

2.3.2.7 Standby Gas Treatment System ............................................ 2-52

2.3.3 Auxiliary Systems .................................................................................. 2-52

2.3.3.1 Building Drains Nonradioactive System .................................. 2-53

2.3.3.2 Containment Instrument Gas System ..................................... 2-54

2.3.3.3 Control Rod Drive Hydraulics System ..................................... 2-54

2.3.3.4 Control Structure Chilled W ater System ................................. 2-55

2.3.3.5 Control Structure Heating, Ventilation, and Air Conditioning

(HVAC) Systems .................................................................... 2-57

2.3.3.6 Cooling Tower System ........................................................... 2-57

2.3.3.7 Diesel Fuel Oil System ........................................................... 2-59

2.3.3.8 Diesel Generator Building HVAC Systems ............................. 2-64

2.3.3.9 Diesel Generator System ....................................................... 2-65

2.3.3.10 Domestic W ater System ....................................................... 2-65

2.3.3.11 Emergency Service W ater System ....................................... 2-65

2.3.3.12 Engineered Safeguards Service Water Pumphouse

HVAC System ..................................................................... 2-67

2.3.3.13 Fire Protection System ......................................................... 2-67

2.3.3.14 Fuel Pool Cooling and Cleanup System and Fuel Pools

and A uxiliaries ..................................................................... 2-83

2.3.3.15 Neutron Monitoring System .................................................. 2-91

2.3.3.16 Nitrogen and Hydrogen System ............................................ 2-91

2.3.3.17 Primary Containment Atmosphere Circulation System ......... 2-92

2.3.3.18 Process and Area Radiation Monitoring System ................... 2-92

2.3.3.19 Radwaste Liquid System ...................................................... 2-94

2.3.3.20 Radwaste Solids Handling System ....................................... 2-97

2.3.3.21 Raw W ater Treatment System ............................................. 2-97

2.3.3.22 Reactor Building Chilled W ater System ................................ 2-98

2.3.3.23 Reactor Building Closed Cooling W ater System ................. 2-100

2.3.3.24 Reactor Building HVAC System ......................................... 2-106

2.3.3.25 Reactor Nonnuclear Instrumentation System ..................... 2-107

2.3.3.26 Reactor W ater Cleanup System ......................................... 2-108

2.3.3.27 Residual Heat Removal Service W ater System .................. 2-109

2.3.3.28 Sampling System ............................................................... 2-110

2.3.3.29 Sanitary Drainage System .................................................. 2-111

2.3.3.30 Service Air System ............................................................. 2-111

2.3.3.31 Service Water System ........................................................ 2-112

2.3.3.32 Standby Liquid Control System .......................................... 2-113

2.3.3.33 Turbine Building Closed Cooling W ater System ................. 2-115

2.3.4 Steam and Power Conversion Systems .............................................. 2-116

2.3.4.1 Auxiliary Boiler System ......................................................... 2-116

vi
2.3.4.2 Bypass Steam System.......................................... 2-117

2.3.4.3 Condensate Transfer and Storage System ................... 2-117

2.3.4.4 Condenser and Air Removal System .......................... 2-120

2.3.4.5 Feedwater System .............................................. 2-121

2.3.4.6 Main Steam System............................................. 2-122

2.3.4.7 Main Turbine System ........................................... 2-127

2.3.4.8 Makeup Demnineralizer System ................................. 2-128

2.3.4.9 Makeup Transfer and Storage System ........................ 2-128

2.3.4.10 Reactor Feed Pump Turbines System ........................ 2-129

2.3.4.11 Refueling Water Transfer and Stoarge System ............. 2-129

2.4 Scopino and Screening Results: Structures........................................ 2-129

2.4.1 Primary Containment ...................................................... 2-133

2.4.1.1 Summary of Technical Information in the Application ........ 2-133

2.4.1.2 Staff Evaluation.................................................. 2-134

2.4.1.3 Conclusion ....................................................... 2-138

2.4.2 Reactor Building............................................................ 2-138

2.4.2.1 Summary of Technical Information in the Application ........ 2-138

2.4.2.2 Staff Evaluation.................................................. 2-140

2.4.2.3 Conclusion ....................................................... 2-144

2.4.3 Engineered Safeguards Service Water Pumphouse

and Spray Pond ............................................................ 2-144

2.4.3.1 Summary of Technical Information in the Application ........ 2-144

2.4.3.2 Staff Evaluation.................................................. 2-145

2.4.3.3 Conclusion ....................................................... 2-146

2.4.4 Circulating Water Pumphouse and Water Treatment Building......... 2-146

2.4.4.1 Summary of Technical Information in the Application ........ 2-146

2.4.4.2 Staff Evaluation.................................................. 2-147

2.4.4.3 Conclusion ....................................................... 2-147

2.4.5 Control Structure ........................................................... 2-147

2.4.5.1 Summary of Technical Information in the Application ........ 2-147

2.4.5.2 Staff Evaluation.................................................. 2-148

2.4.5.3 Conclusion ....................................................... 2-149

2.4.6 Diesel Generator A, B, C, and D Building................................ 2-149

2.4.6.1 Summary of Technical Information in the Application ........ 2-149

2.4.6.2 Staff Evaluation.................................................. 2-150

2.4.6.3 Conclusion ....................................................... 2-151

2.4.7 Diesel Generator E Building ............................................... 2-151

2.4.7.1 Summary of Technical Information in the Application ........ 2-151

2.4.7.2 Staff Evaluation.................................................. 2-152

2.4.7.3 Conclusion ....................................................... 2-152

2.4.8 Turbine Building ............................................................ 2-152

2.4.8.1 Summary of Technical Information in the Application ........ 2-152

2.4.8.2 Staff Evaluation .................................................. 2-154

2.4.8.3 Conclusion ....................................................... 2-155

2.4.9 Yard Structures............................................................. 2-155

2.4.9.1 Summary of Technical Information in the Application ........ 2-155

2.4.9.2 Staff Evaluation .................................................. 2-158

2.4.9.3 Conclusion ....................................................... 2-158

Vii
2.4.10 Bulk Commodities ........................................................ 2-159

2.4.10.1 Summary of Technical Information in the Application......2-159

2.4.10.2 Staff Evaluation ................................................ 2-160

2.4.10.3 Conclusion...................................................... 2-165

2.5 Scopingq and Screening Results: Electrical and Instrumentation and Controls ... 2-165

2.5.1 Electrical and Instrumentation and Controls Component

Commodity Groups ........................................................ 2-166

2.5.1.1 Summary of Technical Information in the Application ........ 2-166

2.5.1.2 Staff Evaluation.................................................. 2-168

2.5.1.3 Conclusion ....................................................... 2-170

2.6 Conclusion for Scoping and Screening ............................................. 2-170

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 1s .............................................. 3-2

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

3.0.2 Staff's Review Process....................................................... 3-4

3.0.2.1 Review of AMPs.................................................... 3-4

3.0.2.2 Review of AMR Results ........................................... 3-5

3.0.2.3 UFSAR Supplement .............................................. 3-5

3.0.2.4 Documentation and Documents Reviewed ...................... 3-6

3.0.3 Aging Management Programs............................................... 3-6

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

3.0.3.2 AMPs Consistent with the GALL Report with Exceptions or

Enhancements .................................................... 3-94

3.0.3.3 AMPs Not Consistent with or Not Addressed

in the GALL Report ....................................................... 3-180

3.0.4 QA Program Attributes Integral to Aging Management Programs ..... 3-197

3.0.4.1 Summary of Technical Information in the Application ........ 3-197

3.0.4.2 Staff Evaluation.................................................. 3-197

3.0.4.3 Conclusion ....................................................... 3-198

3.1 Aging Management of Reactor Vessel, Reactor Vessel Internals,

and Reactor Coolant System........................................................ 3-198

3.1.1 Summary of Technical Information in the Application................... 3-199

3.1.2 Staff Evaluation............................................................. 3-199

3.1.2.1 AMR Results Consistent with the GALL Report............... 3-217

3.1.2.2 AMR Results Consistent with the GALL Report for

Which Further Evaluation is Recommended.................. 3-223

3.1.2.3 AMR Results Not Consistent with or Not Addressed

in the GALL Report.............................................. 3-242

3.1.3 Conclusion .................................................................. 3-254

3.2 Aging Management of Engineered Safety Features............................... 3-255

3.2.1 Summary of Technical Information in the Application................... 3-255

3.2.2 Staff Evaluation............................................................. 3-255

3.2.2.1 AMR Results Consistent with the GALL Report............... 3-265

3.2.2.2 AMR Results Consistent with the GALL Report for

Which Further Evaluation is Recommended.................. 3-276

Viii
3.2.2.3 AMR Results Not Consistent with or Not Addressed

in the GALL Report .............................................................. 3-290

3.2.3 Conclusion .......................................................................................... 3-296

3.3 A-gingq Management of Auxiliary Systems .......................................................... 3-296

3.3.1 Summary of Technical Information in the Application ......................... 3-297

3.3.2 Staff Evaluation ................................ .................................................. 3-297

3.3.2.1 AMR Results Consistent with the GALL Report .................... 3-316

3.3.2.2 AMR Results Consistent with the GALL Report

for W hich Further Evaluation is Recommended ................... 3-328

3.3.2.3 AMR Results Not Consistent with or Not Addressed

in the GALL Report .............................................................. 3-372

3.3.3 Conclusion ......................................................................................... 3-421

3.4 Aging Managqement of Steam and Power Conversion Systems ......................... 3-422

3.4.1 Summary of Technical Information in the Application ......................... 3-422

3.4.2 Staff Evaluation ................................................................................... 3-422

3.4.2.1 AMR Results Consistent with the GALL Report .................... 3-430

3.4.2.2 AMR Results Consistent with the GALL Report

for W hich Further Evaluation is Recommended ................... 3-435

3.4.2.3 AMR Results Not Consistent with or Not Addressed

in the GALL Report .............................................................. 3-446

3.4.3 Conclusion .......................................................................................... 3-453

3.5 A-ging Management of Containments, Structures, and Component Supports .... 3-454

3.5.1 Summary of Technical Information in the Application ......................... 3-454

3.5.2 Staff Evaluation ................................................................................... 3-454

3.5.2.1 AMR Results Consistent with the GALL Report .................... 3-467

3.5.2.2 AMR Results Consistent with the GALL Report

for W hich Further Evaluation is Recommended ................... 3-471

3.5.2.3 AMR Results Not Consistent with or Not Addressed

in the GALL Report .............................................................. 3-492

3.5.3 Conclusion .......................................................................................... 3-499

3.6 Aging Management of Electrical and Instrumentation and Controls .................. 3-499

3.6.1 Summary of Technical Information in the Application ......................... 3-499

3.6.2 Staff Evaluation ................................................................................... 3-500

3.6.2.1 AMR Results Consistent with the GALL Report .................... 3-503

3.6.2.2 AMR Results Consistent with the GALL Report

or W hich Further Evaluation is Recommended .................... 3-505

3.6.2.3 AMR Results Not Consistent with or Not Addressed

in the GALL Report .............................................................. 3-512

3.6.3 Conclusion .......................................................................................... 3-515

3.7 Conclusion for Aging Management Review Results .......................................... 3-515

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 ............................................................................................. 4-4

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

4.2.1 Neutron Fluence .................................................................................... 4-5

4.2.1.1 Summary of Technical Information in the Application .............. 4-5

ix
4.2.1.2 Staff Evaluation .................................................... 4-5

4.2.1.3 UFSAR Supplement ............................................... 4-6

4..2.1.4 Conclusion ......................................................... 4-6

4.2.2 Upper Shelf Energy Evaluation.............................................. 4-6

4.2.2.1 Summary of Technical Information in the Application........... 4-6

4.2.2.2 Staff Evaluation .................................................... 4-6

4.2.2.3 UFSAR Supplement ............................................... 4-8

4.2.2.4 Conclusion ......................................................... 4-8

4.2.3 Adjusted Reference Temperature Analysis................................. 4-8

4.2.3.1 Summary of Technical Information in the Application........... 4-8

4.2.3.2 Staff Evaluation .................................................... 4-8

4.2.3.3 UFSAR Supplement ............................................... 4-9

4.2.3.4 Conclusion ......................................................... 4-9

4.2.4 Press ure-Tem perature (P-T) Limits........................................ 4-10

4.2.4.1 Summary of Technical Information in the Application.......... 4-10

4.2.4.2 Staff Evaluation ................................................... 4-10

4.2.4.3 UFSAR Supplement .............................................. 4-11

4.2.4.4 Conclusion......................................................... 4-1 1

4.2.5 Reactor Vessel Circumferential Weld Examination Relief................ 4-1 1

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

4.2.5.2 Staff Evaluation ................................................... 4-11

4.2.5.3. UFSAR Supplement .............................................. 4-13

4.2.5.4 Conclusion......................................................... 4-13

4.2.6 Reactor Vessel Axial Weld Failure Probability ............................ 4-14

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

4.2.6.2 Staff Evaluation ................................................... 4-14

4.2.6.3 UFSAR Supplement .............................................. 4-14

4.2.6.4 Conclusion......................................................... 4-15

4.2.7 Reflood Thermal Shock..................................................... 4-15

4.2.7.1 Summary of Technical Information in the Application.......... 4-15

4.2.7.2 Staff Evaluation ................................................... 4-15

4.2.7.3 UFSAR Supplement .............................................. 4-17

4.2.7.4 Conclusion......................................................... 4-17

4.3 Metal Fatigque........................................................................... 4-17

4.3.1 Reactor Pressure Vessel Fatigue Analyses ............................... 4-17

4.3.1.1 Summary of Technical Information in the Application.......... 4-17

4.3.1.2 Staff Evaluation ................................................... 4-18

4.3.1.3 UFSAR Supplement.............................................. 4-22

4.3.1.4 Conclusion......................................................... 4-22

4.3.2 Reactor Vessel Internals Fatigue Analyses................................ 4-23

4.3.2.1 Summary of Technical Information in the Application.......... 4-23

4.3.2.2 Staff Evaluation ................................................... 4-23

4.3.2.3 UFSAR Supplement.............................................. 4-24

4.3.2.4 Conclusion......................................................... 4-24

4.3.3 Effects of Reactor Coolant Environment on Fatigue Life of

Components and Piping .................................................... 4-24

4.3.3.1 Summary of Technical Information in the Application.......... 4-24

4.3.3.2 Staff Evaluation ................................................... 4-24

x
4.3.3.3 UFSAR Supplement.............................................. 4-29

4.3.3.4 Conclusion......................................................... 4-29

4.3.4 Reactor Coolant Pressure Boundary Piping and Component

Fatigue Analyses............................................................ 4-30

4.3.4.1 Summary of Technical Information in the Application.......... 4-30

4.3.4.2 Staff Evaluation ................................................... 4-30

4.3.4.3 UFSAR Supplement .............................................. 4-31

4.3.4.4 Conclusion ........................................................ 4-31

4.3.5 Non-Class 1 Component Fatigue Analyses................................ 4-31

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

4.3.5.2 Staff Evaluation ................................................... 4-31

4.3.5.3 UFSAR Supplement .............................................. 4-32,

4.3.5.4 Conclusion ......................................................... 4-32

4.4 Environmental Qualification of Electrical Equipment ................................ 4-32

4.4.1 Summary of Technical Information in the Application .................... 4-32

4.4.2 Staff Evaluation .............................................................. 4-33

4.4.3 UFSAR Supplement......................................................... 4-33

4.4.4 Conclusion ................................................................... 4-34

4.5 Concrete Containment Tendon Prestress ........................................... 4-34

4.5.1 Summary of Technical Information in the Application .................... 4-34

4.5.2 Staff Evaluation .............................................................. 4-34

4.5.3 UFSAR Supplement ......................................................... 4-35

4.5.4 Conclusion ................................................................... 4-35

4.6 Containment Liner Plate. Metal Containments, and Penetrations

Fatigue Analyses ...................................................................... 4-35

4.6.1 ASME Class MC Components.............................................. 4-35

4.6.1.1 Summary of Technical Information in the Application.......... 4-35

4.6.1.2 Staff Evaluation ................................................... 4-35

4.6.1.3 UFSAR Supplement .............................................. 4-35

4.6.1.4 Conclusion......................................................... 4-36

4.6.2 Downcomer Vents and Safety Relief Valve Discharge Piping ........... 4-36

4.6.2.1 Summary of Technical Information in the Application.......... 4-36

4.6.2.2 Staff Evaluation ................................................... 4-36

4.6.2.3 UFSAR Supplement .............................................. 4-37

4.6.2.4 Conclusion......................................................... 4-37

4.6.3 Safety Relief Valve Quenchers............................................. 4-37

4.6.3.1 Summary of Technical Information in the Application.......... 4-37

4.6.3.2 Staff Evaluation ................................................... 4-38

4.6.3.3 UFSAR Supplement .............................................. 4-38

4.6.3.4 Conclusion......................................................... 4-38

4.7 Other Plant-Specific Time-Limited Agiing Analyses.................................. 4-39

4.7.1 Main Steam Line Flow Restrictor Erosion Analyses ...................... 4-39

4.7.1.1 Summary of Technical Information in the Application.......... 4-39

4.7.1.2 Staff Evaluation ................................................... 4-39

4.7.1.3 UFSAR Supplement .............................................. 4-41

4.7.1.4 Conclusion......................................................... 4-41

4.7.2 High Energy Line Break Cumulative Fatigue Usage Factors ............ 4-41

4.7.2.1 Summary of Technical Information in the Application.......... 4-41

xi
4.7.2.2 Staff Evaluation ...................................................................... 4-41

4.7.2.3 UFSAR Supplement ............................................................... 4-42

4.7.2.4 Conclusion ............................................................................. 4-42

4.7.3 Core Plate Rim Hold-Down Bolts .......................................................... 4-42

4.7.3.1 Summary of Technical Information in the Application ............. 4-42

4.7.3.2 Staff Evaluation ...................................................................... 4-43

4.7.3.3 UFSAR Supplement .......................................................... 4-44

4.7.3.4 Conclusion ............................................................................ 4-44

4.8 Conclusion for Time-Limited Aging Analyses ...................................................... 4-45

REVIEW BY THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS ..................... 5-1

CONCLUSION ........................................................................................................................ 6-1

APPENDIX A: SSES UNITS 1 AND 2 LICENSE RENEWAL COMMITMENTS ................... A-1

APPENDIX B: CHRONOLOGY ............................................................................................ B-1

APPENDIX C: PRINCIPAL CONTRIBUTORS .................................................................... C-1

APPENDIX D: REFERENCES ........................................................................................... D-1

xii
ABBREVIATIONS

AAI applicant action item

AB auxiliary boiler

AC alternating current

ACI American Concrete Institute

ACRS Advisory Committee on Reactor Safeguards

ACSR Aluminum Conductor Steel Reinforced

ADAMS Agencywide Document Access and Management System

ADS automatic depressurization system

AEM aging effect / mechanism

AERM aging effect requiring management

AFW auxiliary feedwater

AHU air handling unit

AISC American Institute of Steel Construction

aka also known as

AMP aging management program

AMR aging management review

ANSI American National Standards Institute

APRM average power range monitor

AR action request

ARI alternate rod injection / alternate rod insertion

ART adjusted reference temperature

ASCE American Society of Civil Engineers

ASME American Society of Mechanical Engineers

AST alternate source term

ASTM American Society for Testing and Materials

ATWS anticipated transient without scram

B&PV boiler and pressure vessel

BTP APCSB Branch Technical Position Auxiliary Power Conversion Systems Branch

BWR boiling water reactor

BWRVIP Boiling Water Reactor Vessel and Internals Program

CASS cast austenitic stainless steel

CF chemistry factor

CFR Code of Federal Regulations

Cl confirmatory item

CIG containment instrument gas

CIV combined intermediate valve

CLB current licensing basis

CM condition monitoring

CMAA Crane Manufacturers Association of America

CPEI Chemistry Program Effectiveness Inspection

CPX Component Maintenance System

CR condition report

xiii
CRD

CRDH

CRDRL

CREOASS

CS

CSS

CSCW

CST

CTS

CWST

CUF

control rod drive

control rod drive hydraulics

control rod drive return line

Control Room Emergency Outside Air Supply System

carbon steel

core support structures

control structure chilled water

condensate storage tank

condensate transfer and storage

clarified water storage tank

cumulative usage factor

DAR

DBA

DBD

DBE

DC

DG

DOR

DOT

DP

design assessment report

design basis accident

design basis document

design basis event

direct current

diesel generator

Division of Operating Reactors

Department of Transportation

differential pressure

ECCS

EDG

EFPY

EHL

EOL

EPRI

EPRI-MRP

EPU

EQ

ESF

ESS

ESSW

ESW

FAC

Fen

FERC

FP

FPCCS

FPRR

FR

FSAR

FW

GALL

GDC

emergency core cooling system

emergency diesel generator

effective full-power year

emergency heat load

end of life

Electric Power Research Institute

Electric Power Research Institute Materials Reliability Program

extended power uprate

environmental qualification

engineered safety feature

Engineered Safeguard System

engineered safeguards service water

emergency service water

flow-accelerated corrosion

environmental fatigue life correction factor

Federal Energy Regulatory Commission

fire protection

Fuel Pool Cooling and Cleanup System

fire protection review report

Federal Register

final safety analysis report

feedwater

Generic Aging Lessons Learned Report

general design criteria or general design criterion

xiv
GE General Electric

GElS Generic Environmental Impact Statement

GL generic letter

GRRCCW Gaseous Radwaste Recombiner Closed Cooling Water System

GSI generic safety issue

HAZ heat-affected zone

HCU hydraulic control unit

HELB high-energy line break

HEPA high efficiency particulate air

HP high pressure

HPCI high pressure coolant injection

HVAC heating, ventilation, and air conditioning

HWC hydrogen water chemistry

HX heat exchanger

I&C instrumentation and controls

IASCC irradiation assisted stress corrosion cracking

ICTM isolated condenser treatment method

ID inside diameter

IEEE Institute of Electrical and Electronics Engineers

IGA intergranular attack

IGSCC intergranular stress corrosion cracking

IN information notice

INPO Institute of Nuclear Power Operations

IP intermediate pressure

IPA integrated plant assessment

IPE individual plant evaluation

IPEEE individual plant evaluation of external events

IR insulation resistance

IRM intermediate range monitor

ISFSI independent spent fuel storage installation

ISG interim staff guidance

ISI inservice inspection

ISO independent system operator

ISP Integrated Surveillance Program

kV kilo-volt

LLRWHF low level radwaste holding facility

LOCA loss of coolant accident

LP low pressure

LPCI low pressure coolant injection

LPCS low pressure core spray

LPRM local power range monitor

LR license renewal

LRA license renewal application

LTOP low-temperature overpressure protection

Xv
MEB

MeV

MIC

MOAB

MRDB

MS

MSS

MSIV/LCS

MTS

MWt

MWe

N/A

NCR

NDE

NEI

NFPA

Ni

NIMS

NLDAE

NMS

NPS

NRC

NSAS

NSE

NSSS

ODCM

ODSCC

OE

01

OL

OQA

P&ID

PASS

PGCC

pH

PM

PPB

PPL

PPM

P-T

PTS

PVC

PWR

PWSCC

metal-enclosed bus

million electron volts

microbiologically influenced corrosion

motor operated air break

maintenance rule database

main steam

main steam system

main steam isolation valve / leakage control system

main turbine system

megawatts-thermal

megawatts-electric

not applicable

Non-conformance Report

nondestructive examination

Nuclear Energy Institute

National Fire Protection Association

nickel

Nuclear Information Management System

new loads design adequacy evaluation

Neutron Monitoring System

nominal pipe size

US Nuclear Regulatory Commission

non-safety affecting safety

nuclear system engineering

nuclear steam supply system

offsite dose calculation manual

outside-diameter stress corrosion cracking

operating experience

open item

operating license

operational quality assurance

piping and instrumentation diagrams

Post-Accident Sampling System

Power Generation Control Complex

Concentration of Hydrogen Ions

preventive maintenance / performance monitoring

parts per billion

PPL Susquehanna, LLC

parts per million

pressure-temperature

pressurized thermal shock

polyvinyl chloride

pressurized water reactor

primary water stress corrosion cracking

xvi
QA quality assurance

QAPD quality assurance program description

RAI request for additional information

RAMA radiation analysis modeling application

RB reactor building

RBCCW reactor building closed cooling water

RBCW reactor building chilled water

RBM rod block monitor

RCIC reactor core isolation cooling

RCPB reactor coolant pressure boundary

RCS - reactor coolant system

RCSPB reactor coolant system pressure boundary

RFO refueling outage

RFP reactor feedwater pump

RG regulatory guide

RHR residual heat removal

RHRSW residual heat removal service water

RI reactor internals

RIS regulatory issue summary

ROFT reduction of fracture toughness

RPT recirculation pump trip

RPV reactor pressure vessel

RR reactor recirculation

RT radiographic testing

RTNDT reference temperature nil ductility transition

RVID reactor vessel integrity database

RWCU Reactor Water Cleanup System

RWST refueling water storage tank

SAS service air system

SBO station blackout

SC structure and component

SCC stress-corrosion cracking

SCW source of cooling water

SDS sanitary drainage system

SDV scram discharge volume

SE safety evaluation

SER safety evaluation report

SFSP spent fuel storage pool

SHE Standard Hydrogen Electrode

SGTS Standby Gas Treatment System

SJAE steam jet air ejector

SLC standby liquid control

SOC statement of consideration

SOMS Shift Operations Management System

SPE steam packing exhauster

SPLEX Susquehanna Plant Lifetime Excellence Program

xvii
SRM source range monitoring

SRP Standard Review Plan

SRP-LR Standard Review Plan for Review of License Renewal Applications for Nuclear

Power Plants

SRV safety relief valve

SS stainless steel

SSC system, structure, and component

SSE safe-shutdown earthquake

SSES Susquehanna Steam Electric Station

SW service water

TBCCW turbine building closed cooling water

TEMA Tubular Exchanger Manufacturers Association

TIP traversing incore probe

TLAA time-limited aging analysis

TRM technical requirements manual

TS technical specifications

USE upper-shelf energy

UT ultrasonic testing

UV ultraviolet

VDC volts direct current

VFLD vessel flange leak detection

VHP reactor vessel head penetration

XLPE cross-linked polyethylene

XLPO cross-linked polyolefin

WA work authorization

Zn zinc

xviii
SECTION 1

INTRODUCTION AND GENERAL DISCUSSION

1.1 Introduction

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

Susquehanna Steam Electric Station (SSES), Units 1 and 2, as filed by the PPL Susquehanna,

LLC (PPL or the applicant). By letter dated September 13, 2006, PPL submitted its application

to the U.S. Nuclear Regulatory Commission (NRC) for renewal of the SSES operating licenses

for an additional 20 years. The NRC staff (the staff) prepared this report to summarize the

results of its safety review of the LRA for compliance with Title 10, Part 54, "Requirements for

Renewal of Operating Licenses for Nuclear Power Plants," of the Code of Federal Regulations

(10 CFR Part 54). The NRC project manager for the license renewal review is Evelyn Gettys.

Ms Gettys may be contacted by telephone at 301-415-4029 or by electronic mail at

Evelyn.Gettys@nrc.gov. Alternatively, written correspondence may be sent to the following

address:

Division of License Renewal

US Nuclear Regulatory Commission

Washington, DC 20555-0001

Attention: Evelyn Gettys Mail Stop 011-F1

In its September 13, 2006, submission letter, the applicant requested renewal of the operating

licenses issued under Section 103 (Operating License Nos. NPF-14 and NPF-22) of the Atomic

Energy Act of 1954, as amended, for Units 1 and 2 for a period of 20 years beyond the current

expirations at midnight July 17, 2022, for Unit 1, and at midnight March 23, 2024, for Unit 2.

SSES is located approximately 5 miles northeast of Berwick, PA. The NRC issued the

construction permits for Units 1 and 2 on November 2, 1973. The NRC issued the operating

licenses for Unit 1 on July 17, 1982, and on March 23, 1984, for Unit 2. Units 1 and 2 are of

Mark 2 boiling-water reactor (BWR) design. General Electric supplied the nuclear steam supply

system and Bechtel originally designed and constructed the balance of the plant. The licensed

power output of each unit is 3952 megawatt thermal with a gross electrical output of

approximately 1300 megawatt electric. The updated final safety analysis report (UFSAR) shows

details of the plant and the site.

The license renewal process consists of two concurrent reviews, a technical review of safety

issues and an environmental review. The NRC regulations in 10 CFR Part 54 and

10 CFR Part 51, "Environmental Protection Regulations for Domestic Licensing and Related

Regulatory Functions," respectively, set forth requirements for these reviews. The safety review

for the SSES license renewal is based on the applicant's LRA and on its responses to the

staff's requests for additional information. The applicant supplemented the LRA and provided

clarifications through its responses to the staff's requests for additional information (RAIs) in

audits, meetings, and docketed correspondence. The public may view the LRA and all

pertinent information and materials, including the UFSAR, at the NRC Public Document Room,

located on the first floor of One White Flint North, 11555 Rockville Pike, Rockville, MD 20852-

2738 (301-415-4737 / 800-397-4209). In addition, the public may find the LRA, as well as

materials related to the license renewal review, on the NRC Web site at http://www.nrc.gov.

1-1
This SER summarizes the results of the staff's safety review of the 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 in NUREG-1 800, Revision 1,

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

(SRP-LR), dated September 2005.

SER Sections 2 through 4 address the staff's evaluation of license renewal issues considered

during the review of the application. SER Section 5 is reserved for the report of the Advisory

Committee on Reactor Safeguards (ACRS). The conclusions of this SER are in Section 6.

SER Appendix A is a table showing the applicant's commitments for renewal of the operating

licenses. SER Appendix B is a chronology of the principal correspondence between the staff

and the applicant regarding the LRA review. SER Appendix C is a list of principal contributors to

the SER and Appendix D is a bibliography of the references in support of the staff's review.

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

NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear

Plants (GELS)." This supplement discusses the environmental considerations for license

renewals for Units 1 and 2. The staff issued draft, plant-specific GElS Supplement 35 "Generic

Environmental Impact Statement for License Renewal of Nuclear Plants Regarding

Susquehanna Steam Electric Station, Units 1 and 2, Draft Report for Comment," in April 2008.

The final, plant-specific GElS Supplement 35, "Generic Environmental Impact Statement for

License Renewal of Nuclear Plants Regarding Susquehanna Steam Electric Station, Units 1

and 2, Final Report," was issued March 11, 2009.

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 and can be renewed for up to

20 additional years. The original 40-year license term was selected based on economic and

antitrust considerations rather than on technical limitations; however, some individual plant and

equipment designs may have been engineered for an expected 40-year service life.

In 1982, the staff 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. From the results of that research, a technical review group concluded that

many aging phenomena are readily manageable and pose no technical issues precluding life

extension for nuclear power plants. In 1986, the staff published a request for comment on a

policy statement that would address major policy, technical, and procedural issues related to

license renewal for nuclear power plants.

In 1991, the staff published 10 CFR Part 54, the License Renewal Rule (Volume 56,

page 64943, of the Federal Register (56 FR 64943), dated December 13, 1991). The staff

participated in an industry-sponsored demonstration program to apply 10 CFR Part 54 to a pilot

plant and to gain the experience necessary to develop implementation guidance. To establish a

scope of review for license renewal, 10 CFR Part 54 defined age-related degradation unique to

license renewal; however, during the demonstration program, the staff found that adverse aging

effects on plant systems and components are managed during the period of initial license and

that the scope of the review did not allow sufficient credit for management programs,

1-2
particularly the implementation of 10 CFR 50.65, "Requirements for Monitoring the

Effectiveness of Maintenance at Nuclear Power Plants," which regulates management of plantaging phenomena. As a result of this finding, the staff amended 10 CFR Part 54 in 1995. As

published May 8, 1995, in 60 FR 22461, amended 10 CFR Part 54 establishes a regulatory

process that is simpler, more stable, and more predictable than the previous 10 CFR Part 54. In

particular, as amended, 10 CFR Part 54 focuses on the management of adverse aging effects

rather than on the identification of age-related degradation unique to license renewal. The staff

made 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 amended 10 CFR Part 54 clarifies and simplifies the integrated plant

assessment process to be consistent with the revised focus on passive, long-lived structures

and components (SCs).

Concurrent with these initiatives, the staff pursued a separate rulemaking effort (61 FR 28467,

June 5, 1996) and amended 10 CFR Part 51 to focus the scope of the review of environmental

impacts of license renewal in order to fulfill NRC responsibilities under the National

Environmental Policy Act of 1969.

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 maintain an acceptable level of safety with the possible exceptions of

the detrimental aging effects on the functions of certain SSCs, as well as a few other

safety-related issues, 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, "Scope," defines the scope of license

renewal as including those SSCs that (1) are safety-related, (2) whose failure could affect

safety-related functions, or (3) are relied on to demonstrate compliance with the NRC's

regulations for fire protection, environmental qualification, pressurized thermal shock,

anticipated transient without scram, and station blackout.

Pursuant to 10 CFR 54.21(a), a license renewal applicant must review all SSCs within the

scope of 10 CFR Part 54 to identify SCs subject to an aging management review (AMR). Those

SCs subject to an AMR perform an intended function without moving parts or without change in

configuration or properties and are not subject to replacement based on a qualified life or

specified time period. Pursuant to 10 CFR 54.21(a), a license renewal applicant must

demonstrate that the aging effects will be managed such that the intended function(s) of those

SCs will be maintained consistent with the current licensing basis (CLB) for the period of

extended operation. However, active equipment is considered to be adequately monitored and

maintained by existing programs. In other words, detrimental aging effects that may affect

active equipment can be readily identified and corrected through routine surveillance,

performance monitoring, and maintenance. Surveillance and maintenance programs for active

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

required throughout the period of extended operation.

1-3
Pursuant to 10 CFR 54.21(d), the LRA is required to include a UFSAR supplement with a

summary description of the applicant's programs and activities for managing aging effects and

an evaluation of time-limited aging analyses (TLAAs) for the period of extended operation.

License renewal also requires TLAA identification and updating. During the plant design phase,

certain assumptions about the length of time the plant can operate are incorporated into design

calculations for several plant 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 aging

effects on these SSCs will be adequately managed for the period of extended operation.

In 2005, the NRC revised Regulatory Guide (RG) 1.188, "Standard Format and Content for

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

Energy Institute (NEI) 95-10, Revision 6, "Industry Guideline for Implementing the

Requirements of 10 CFR Part 54 - The License Renewal Rule," issued in June 2005. NEI 95-10

details an acceptable method of implementing 10 CFR Part 54. The staff also used the SRP-LR

to review the LRA.

In the LRA, the applicant fully utilized the process defined in NUREG-1801, Revision 1,

"Generic Aging Lessons Learned (GALL) Report," dated September 2005. The GALL Report

summarizes staff-approved aging management programs (AMPs) for many SCs subject to an

AMR. If an applicant commits to implementing these staff-approved AMPs, the time, effort, and

resources for LRA review can be greatly reduced, 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 is also a quick reference for both applicants and staff

reviewers to AMPs and activities that can manage aging adequately during the period of

extended operation.

1.2.2 Environmental Review

Part 51 of 10 CFR contains the environmental protection regulations. In December 1996, the

staff revised the environmental protection regulations to facilitate the environmental review for

license renewal. The staff prepared the GElS to document its evaluation of possible

environmental impacts associated with nuclear power plant license renewals. For certain types

of environmental impacts, the GElS contains generic findings that apply to all nuclear power

plants and are codified in Appendix B, "Environmental Effect of Renewing the Operating

License of a Nuclear Power Plant," to Subpart A, "National Environmental Policy Act -

Regulations Implementing Section 102(2)," of 10 CFR Part 51. Pursuant to

10 CFR 51.53(c)(3)(i), a license renewal applicant may incorporate these generic findings in its

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

must include analyses of environmental impacts that must be evaluated on a plant-specific

basis.

In accordance with the National Environmental Policy Act of 1969 and 10 CFR Part 51, the staff

reviewed the plant-specific environmental impacts of license renewal, including whether there

was new and significant information not considered in the GELS. As part of its scoping process,

the staff held a public meeting on November 15, 2006, in Berwick, PA, to identify plant-specific

environmental issues. The draft, plant-specific GElS Supplement 35 documents the results of

the environmental review and makes a preliminary recommendation as to the license renewal

action. The staff held another public meeting on May 28, 2008, in Berwick, PA, to discuss draft,

1-4
plant-specific GElS Supplement 35. After considering comments on the draft, the staff

published the final, plant-specific GElS Supplement 35 in March 2009.

1.3 Principal Review Matters

Part 54 of 10 CFR describes the requirements for renewal of operating licenses for nuclear

power plants. The staff's technical review of the LRA was in accordance with NRC guidance

and 10 CFR Part 54 requirements. Section 54.29, "Standards for Issuance of a Renewed

License," of 10 CFR sets forth the license renewal standards. This SER describes the results of

the staff's safety review.

Pursuant to 10 CFR 54.19(a), the NRC requires a license renewal applicant to submit general

information, which the applicant provided in LRA Section 1. The staff reviewed LRA Section 1

and finds that the applicant has submitted the required information.

Pursuant to 10 CFR 54.19(b), the NRC requires that the 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." On this issue, the applicant stated in the LRA:

The current indemnity agreement (No. B-90) for SSES states, in Article VII, that

the agreement shall terminate at the time of expiration of the license specified in

Item 3 of the Attachment to'the agreement, which is the last to expire. Item 3 of

the Attachment to the indemnity agreement, as revised by Amendment No. 3,

lists SSES operating licenses NPF-14 and NPF-22. PPL Susquehanna, LLC

requests that conforming changes be made to Article VII of the indemnity

agreement, and Item 3 of the Attachment to that agreement, specifying the

extension of agreement to the expiration date of the renewed SSES facility

operating licenses sought in this application. In addition, should the license

numbers be changed upon issuance of the renewal license, PPL Susquehanna,

LLC requests that conforming changes be made to Item 3 of the Attachment to

the indemnity agreement, and to other sections of the agreement as deemed

appropriate.

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

licenses, if approved. Therefore, conforming changes to the indemnity agreement need not be

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

Pursuant to 10 CFR 54.21, "Contents of Application - Technical Information," the NRC requires

that the LRA contain (a) an integrated plant assessment, (b) a description of any CLB changes

during the staff's review of the LRA, (c) an evaluation of TLAAs, and (d) an UFSAR

supplement. LRA Sections 3 and 4 and Appendix B address the license renewal requirements

of 10 CFR 54.21(a), (b), and (c). LRA Appendix A satisfies the license renewal requirements of

10 CFR 54.21(d).

Pursuant to 10 CFR 54.21(b), the NRC requires that, each year following submission of the

LRA and at least three months before the scheduled completion of the staff's review, the

applicant submit an LRA amendment identifying any CLB changes to the facility that affect the

contents of the LRA, including the UFSAR supplement. By letters dated September 12, 2007,

September 26, 2008, and May 28, 2009 the applicant submitted an LRA update which

summarize the CLB changes that have occurred during the staff's review of the LRA. These

submissions satisfy 10 CFR 54.21(b) requirements.

1-5
Pursuant to 10 CFR 54.22, "Contents of Application - Technical Specifications," the NRC

requires that the LRA include changes or additions to the technical specifications (TSs) that are

necessary to manage aging effects during the period of extended operation. In LRA

Appendix D, the applicant stated that it had not identified any TS changes necessary for

issuance of the renewed SSES operating licenses. This statement adequately addresses the

10 CFR 54.22 requirements.

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

accordance with NRC regulations and SRP-LR guidance. SER Sections 2, 3, and 4 document

the staffs evaluation of the LRA technical information.

As required by 10 CFR 54.25, "Report of the Advisory Committee on Reactor Safeguards," the

ACRS will issue a report documenting its evaluation of the staffs LRA review and SER. SER

Section 5 is reserved for the ACRS report when it is issued. SER Section 6 documents the

findings required by 10 CFR 54.29.

1.4 Interim Staff Guidance

License renewal is a living program. The staff, industry, and other interested stakeholders gain

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

address the staffs 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 staff, industry, and other interested stakeholders until

incorporated into such license renewal guidance documents as the SRP-LR and GALL Report.

Table 1.4-1 shows the current set of ISGs, as well as the SER sections in which the staff

addresses them.

Table 1.4-1 Current Interim Staff Guidance

ISG Issue Purpose SER Section

(Approved ISG Number) •

Nickel alloy components in the Cracking of nickel alloy components Not applicable (PWRs only)

reactor coolant pressure boundary in the reactor pressure boundary.

(LR-ISG-19B)

ISG under development. NEI and

EPRI-MRP will develop an

augmented inspection program for

GALL AMP XI.M1 1-B. This AMP will

not be completed until the NRC

approves an augmented inspection

program for nickel alloy base metal

components and welds as proposed

by EPRI-MRP.

Corrosion of drywell shell in Mark I To address concerns related to Not applicable

containments corrosion of drywell shell in Mark I

(LR-ISG-2006-01) containments.

1-6
ISG Issue Purpose SER Section

(Approved ISG Number)

Staff Guidance Regarding the To clarify the scoping boundary of 2.5.1.2

Station Blackout Rule (10 CFR the offsite recovery paths that must

50.63) Associated with License be included within the scope of

Renewal Applications license renewal for station blackout.

(LR-ISG-2008-01) The staff issued the proposed ISG

for public comments.

On July 7, 2009, the staff withdrew

LR-ISG-2008-01. See 74 FR 33478,

dated July 13, 2009.

Changes to Generic Aging Lesson To address the frequency of 3.0.3.1.27

Learned (GALL) Report Aging inspection of electrical cable

Management Program (AMP) XI.E6, connections not subject to 10 CFR

"Electrical Cable Connections Not 50.49 prior to the period of extended

Subject to 10 CFR 50.49 operation.

Environmental Qualification The staff has addressed industry

Requirements" comments and the ISG is in the final

(LR-ISG-2007-02) stages of approval. The staff plans

to issue it in September 2009.

1.5 Summary of Proposed License Conditions

Following the staffs review of the LRA, including subsequent information and clarifications from

the applicant, the staff identified three proposed license conditions.

The first license condition requires the applicant to include the updated final safety analysis

report (UFSAR) supplement required by 10 CFR 54.21(d) in the next UFSAR update required

by 10 CFR 50.71(e) following the issuance of the renewed licenses. The applicant may make

changes to the programs and activities described in the UFSAR supplement provided changes

are evaluated pursuant to the criteria set forth in 10 CFR 50.59.

The second license condition requires future activities described in the UFSAR supplement to

be completed prior to the period of extended operation and that the applicant notify the NRC in

writing when these activities are complete and can be verified by NRC inspection.

The third license condition requires that all capsules in the reactor vessel that are removed and

tested meet the requirements of American Society for Testing and Materials (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 staff prior to implementation. All capsules placed in storage must be maintained for future

insertion. Any changes to storage requirements must be approved by the staff, as required by

10 CFR Part 50, Appendix H.

1-7

SECTION 2

STRUCTURES AND COMPONENTS SUBJECT TO AGING

MANAGEMENT REVIEW

2.1 Scoping and Screening Methodology

2.1.1 Introduction

Title 10, Section 54.21 of the Code of Federal Regulations (10 CFR Part 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 (SOs) that are subject to an aging management review (AMR) for systems,

structures, and components (SSCs) that are within the scope of license renewal in accordance

with 10 CFR 54.4.

In license renewal application (LRA) Section 2.1, "Scoping and Screening Methodology," the

applicant described the scoping and screening methodology used to identify the SSCs at the

Susquehanna Steam Electric Station (SSES) that are within the scope of license renewal and

the SCs subject to an AMR. The staff reviewed the PPL Susquehanna, LLC (the applicant),

scoping and screening methodology to determine if it is consistent with 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 for the LRA, the applicant considered the

requirements of 10 CFR 54, "Requirements for Renewal of Operating Licenses for Nuclear

Power Plants" (the Rule), the statements of consideration related to the Rule, and the guidance

provided in Nuclear Energy Institute (NEI) 95-10, "Industry Guideline for Implementing the

Requirements of 10 CFR Part 54 - The License Renewal Rule," Revision 6. Additionally, in

developing this methodology, the applicant considered the correspondence between the U.S.

Nuclear Regulatory Commission (NRC), other applicants, and NEI.

2.1.2 Summary of Technical Information in the Application

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

10 CFR 54.21(a). In LRA Section 2.1, the applicant described the process used to identify the

SSCs that meet the license renewal scoping criteria pursuant to 10 CFR 54.4(a), and the

process used to identify the SCs that are subject to an AMR, in accordance with

10 CFR 54.21(a)(1). The applicant provided the results of the process used for identifying the

SCs subject to an AMR in the following LRA Sections:

* Section 2.2, "Plant Level Scoping Results"

* Section 2.3, "Scoping and Screening Results: Mechanical Systems"

* Section 2.4, "Scoping and Screening Results: Structures"

2-1
Section 2.5, "Scoping and Screening Results: Electrical and Instrumentation and Control

Systems"

In LRA Section 3.0, "Aging Management Review Results," the applicant described its aging

management results as follows:

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

System"

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

" Section 3.3, "Aging 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"

In LRA Section 4.0, "Time-Limited Aging Analyses," the applicant described its identification

and evaluation of time-limited aging analyses.

2.1.3 Scoping and Screening Program Review

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

guidance contained in NUREG-1800, "Standard Review Plan for Review of License Renewal

Applications for Nuclear Power Plants," Revision 1, Section 2.1, "Scoping and Screening

Methodology" (SRP-LR). The following regulations form the basis for the acceptance criteria for

the scoping and screening methodology review:

0 10 CFR 54.4(a), as it relates to identification of plant SSCs within the scope of the Rule

0 10 CFR 54.4(b), as it relates to identification of intended functions of plant structures

and systems determined to be within the scope of the Rule

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

identify plant SCs subject to an AMR

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

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

SRP-LR:

" Section 2.1, to ensure that the applicant has described a process for identifying SSCs

that are within the scope of license renewal, as required by 10 CFR 54.4(a)

" Section 2.2, to ensure that the applicant has described a process for determining the

SCs that are subject to an AMR as required by 10 CFR 54.21(a)(1) and (a)(2)

In addition, the staff conducted a scoping and screening methodology audit at SSES, located

outside Berwick, Pennsylvania, during the week December 11-15, 2006. The audit focused on

ensuring 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 LRA

and the requirements of the Rule. The staff reviewed implementation of the project level

guidelines and topical reports describing the applicant's scoping and screening methodology.

2-2
Also, 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 also reviewed training for personnel that developed the LRA and quality

practices used by the applicant to develop the LRA. Further, the staff evaluated the quality

attributes of the applicant's AMP activities described in LRA Appendix A, "Final Safety Analysis

Report Supplement," and Appendix B, "Aging Management Programs." The staff also reviewed

the training and qualification of the applicant's LRA development team. The staff reviewed

scoping and screening results report for the main steam (MS) system and the turbine building

(TB) to ensure that the applicant had appropriately implemented the methodology outlined in

the administrative controls and that the results were consistent with the current licensing basis

(CLB) documentation.

2.1.3.1 Implementation Procedures and Documentation Sources for Scoping and

Screening

The staff reviewed the applicant's scoping and screening implementing procedures as

documented in the audit report, dated May 24, 2007, to verify that the process used to identify

SCs subject to an AMR was consistent with the information contained in the LRA and the

SRP-LR. Additionally, the staff reviewed the scope of CLB documentation sources and the

process used by the applicant to ensure that CLB commitments were appropriately considered

and that the applicant adequately implemented the procedural guidance during the scoping and

screening process.

2.1.3.1.1 Summary of Technical Information in the Application

In LRA Section 2.1, "Scoping and Screening Methodology," the applicant reviewed the following

information sources during the license renewal scoping and screening process:

* Maintenance Rule Data Base

" Updated Final Safety Analysis Report (UFSAR)

" Design basis references

* Piping & Instrumentation Diagrams (P&IDs)

" Electrical drawings

" Docketed correspondence

" Technical Specifications (TSs) and Bases

" Technical Requirements Manual

" Individual Plant Examination (IPE)

" Individual Plant Examination of External Events (IPEEE)

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

systems and structures. It then compared these functions to the scoping criteria in

10 CFR 54(a)(1)-(3) to determine whether the associated plant system or structure performed a

license renewal intended function. It also used these sources to develop the list of SCs subject

to an AMR.

2.1.3.1.2 Staff Evaluation

Scopinq and Screening Implementing Procedures. The staff reviewed the applicant's scoping

and screening methodology implementing procedures, including license renewal guidelines,

2-3
documents, reports, and AMR reports, as documented in the audit report, to ensure the

guidance was consistent with the requirements of the Rule, the SRP-LR, and NEI 95-10,

"Industry Guidelines for Implementing the Requirements of 10 CFR Part 54 - The License

Renewal Rule," Revision 6. The staff found the overall process to implement the

10 CFR Part 54 requirements described in the implementing documents and AMRs was

consistent with the Rule, SRP-LR and industry guidance. Guidance for determining plant SSCs

within the scope of the Rule, including determining which component types of the SCs within

the scope of license renewal were subject to an AMR, were contained in the implementing

documents. During the review of the implementing documents, the staff focused on the

consistency of the detailed procedural guidance with information in the LRA, including the

implementation of staff positions documented in the SRP-LR and information in the staff's

request for addition information (RAI) responses dated April 17, 2007.

After reviewing the LRA and supporting documentation, the staff found that the scoping and

screening methodology instructions were consistent with the applicant's description of the

methodology contained in LRA Section 2.1. The applicant's methodology contained sufficient

detail to provide concise guidance on the scoping and screening implementation process to be

followed during the LRA activities.

Sources of Current Licensing Basis Information. The staff reviewed the scope and depth of the

applicant's CLB review to verify that the methodology was sufficiently comprehensive to identify

SSCs within the scope of license renewal, as well as component types requiring an AMR. As

defined in 10 CFR 54.3(a), the CLB is the set of staff requirements applicable to a specific plant

and a licensee's written commitments for ensuring compliance with, and operation within,

applicable staff requirements and the plant-specific design bases that are docketed and in

effect. The CLB includes certain NRC regulations, orders, license conditions, exemptions, TSs,

design-basis information documented in the most recent UFSAR, and licensee commitments

remaining in effect and made in docketed licensing correspondence such as licensee

responses to NRC bulletins, generic letters (GLs), and enforcement actions, as well as licensee

commitments documented in NRC safety evaluations or licensee event reports.

During the audit, the staff reviewed pertinent information sources utilized by the applicant that

included the UFSAR, license renewal boundary diagrams, and maintenance rule information. In

addition, the applicant's license renewal process identified additional potential sources of plant

information pertinent to the scoping and screening process, including, design basis references,

P&IDs, electrical drawings, docketed correspondence, TSs and bases, the fire hazards

analysis, safety evaluations, and design documentation such as engineering calculations and

design specifications. The staff verified that the applicant's detailed license renewal program

guidelines required use of the CLB source information in developing scoping evaluations.

The SSES component database is the applicant's primary repository for component safety

classification information. During the audit, the staff reviewed the applicant's administrative

controls for SSES component database safety classification data. These controls are described

and implementation is governed by plant administrative procedures. Based on a review of the

administrative controls, and a sample of the SSES component database safety classifications,

the staff concluded that the applicant has established adequate measures to control the

integrity and reliability of SSES component database safety classification data and therefore,

concluded that the SSES component database provided a sufficiently controlled source of

component data to support scoping and screening evaluations.

2-4
During the staff's review of the applicant's CLB evaluation process, the applicant explained the

incorporation of updates to the CLB and the process used to ensure those updates are

adequately incorporated into the license renewal process. The staff determined that LRA

Section 2.1 provided a description of the CLB and related documents used during the scoping

and screening process that is consistent with the guidance contained in the SRP-LR. In

addition, the staff reviewed technical reports the applicant used to support identification of

SSCs relied upon to demonstrate compliance with the safety-related criteria, nonsafety-related

criteria, as well as the five regulated events pursuant to 10 CFR 54.4(a)(1-3). The applicant's

license renewal program guidelines provided a comprehensive listing of documents used to

support scoping and screening evaluations. The staff found these design documentation

sources useful for ensuring that the initial scope of SSCs identified by the applicant was

consistent with the plant's CLB.

2.1.3.1.3 Conclusion

On the basis of its review of information in LRA Section 2.1, a review of the applicant's detailed

scoping and screening implementing procedures; and the results from the scoping and

screening audit, the staff concludes that the applicant's scoping and screening methodology

considered CLB information, consistent with the guidance contained in the SRP-LR and

NEI 95-10, and met the requirements of 10 CFR 54.4, and is therefore acceptable.

2.1.3.2 Quality Controls Applied to LRA Development

2.1.3.2.1 Staff Evaluation

The staff reviewed the applicant's quality controls to ensure that scoping and screening

methodologies used in the LRA were adequately implemented. The staff found that the

applicant applied the following quality assurance (QA) processes during LRA development:

* The applicant developed a project plan which was the QA guide implemented for

preparation of the LRA.

" Implementation of the scoping and screening methodology was governed by written

procedures. A tracking system was implemented to account for the dates that

procedures were originally issued and for subsequent revisions.

" The applicant reviewed previous staff RAIs to ensure that applicable issues were

addressed in the LRA.

" The SSES QA Committee performed an independent assessment of the LRA to verify

that it was developed in accordance with the requirements of 10 CFR Part 54.

" The LRA was subjected to a peer review prior to submittal to the staff.

* The LRA was reviewed by the Off-Site Review Committees prior to submittal to the staff.

2.1.3.2.2 Conclusion

On the basis of its review of information in LRA Section 2.1 and discussion with the applicant's

license renewal staff, and a review of quality assessment documents, the staff concludes that

the QA activities meet current regulatory requirements and provide assurance that LRA

2-5
development activities were consistently performed with the applicant's license renewal

program requirements.

2.1.3.3 Training

2.1.3.3.1 Staff Evaluation

The staff reviewed the applicant's training process to ensure the guidelines and methodology

for the scoping and screening activities were applied in a consistent and appropriate manner.

The license renewal project plan included the training requirements for the personnel who

developed the LRA and indicated the level of training appropriate to the license renewal task

being performed.

Training was required for the license renewal project personnel that included the contract

personnel who prepared the application and the applicant's personnel who reviewed the

application. The training was designed to vary depending on the level of the person's

involvement and responsibility. As described above, the applicant's training guidelines specified

the level of training required for the various groups participating in development of the LRA. The

training consisted of a combination of reading and attending training sessions and was

documented on a qualification card. All license renewal personnel were required to review

applicable license renewal regulations, NEI 95-10 and associated procedures. The training also

included initial training for the applicant's personnel and the contract personnel for project

definition activities, process training for production of documents, subsequent training to the

applicant's personnel to review the deliverables, and general training for the applicant's

management and plant operations review committee and others involved in the development of

the LRA. In addition, the applicant held periodic production meetings in which the license

renewal project team members shared their knowledge and experience of a given subject with

the team. Training material was developed to include lessons learned during the development

of the SSES LRA and previous license renewal projects. The staff reviewed completed

qualification and training records of several of the applicant's license renewal personnel and

also reviewed completed check lists.

2.1.3.3.2 Conclusion

On the basis of its discussions with the applicant's license renewal project personnel

responsible for the scoping and screening process, and a review of selected design

documentation in support of the process, the staff concludes that the applicant's staff and

contractor personnel understand the requirements and has adequately implemented the

scoping and screening methodology established in the applicant's renewal application. The staff

did not identify any concerns regarding the training of the applicant's license renewal project

personnel.

2.1.3.4 Conclusion of Scoping and Screening Program Review

On the basis of its review of information provided by the applicant in LRA Section 2.1, a review

of the applicant's detailed scoping and screening implementing procedures, discussions with

the applicant's license renewal personnel and the results from the scoping and screening audit,

the staff concludes that the applicant's scoping and screening program is consistent with the

guidance contained in the SRP-LR and therefore is acceptable.

2-6
2.1.4 Plant Systems, Structures, and Components Scoping Methodology

In LRA Section 2.1, the applicant described the methodology used to scope SSCs pursuant to

the requirements of the 10 CFR 54.4(a) scoping criteria. The applicant described the scoping

process for the plant in terms of systems and structures. Specifically, the scoping process

consisted of developing a list of plant systems and structures, identifying their intended

functions, and determining which functions meet one or more of the three criteria of

10 CFR 54.4(a). The systems list was developed from the SSES Maintenance Rule Database

and confirmed using the Nuclear Information Management System database and the UFSAR.

The structures list was reviewed against site civil/structural and plant layout drawings. The

license renewal evaluation boundaries include those portions of the SSCs that are necessary to

ensure that the intended functions will be performed. Structures and components needed to

support each of the system and/or structure-level intended functions identified in the scoping

process are included within the evaluation boundary. The applicant's scoping methodology, as

described in the LRA, is discussed in the sections below.

2.1.4.1 Application of the Scoping Criteria in 10 CFR 54.4(a)(1)

2.1.4.1.1 Summary of Technical Information in the Application

LRA Section 2.1.1.1, "Safety-Related Scoping, " describes the scoping methodology as it relates

to the safety-related requirements of 54.4(a)(1). With respect to the safety-related criterion, the

applicant stated that the safety-related systems and structures are initially identified based on a

review of the Maintenance Rule Database, then confirmed using Nuclear Information

Management System and the UFSAR, system design-basis documents (DBDs), P&IDs, and

SSES design standards. Systems and structures whose intended functions met one or more of

the requirements of 10 CFR 54.4(a)(1) were included within the scope of license renewal. The

staff confirmed that all plant conditions, including conditions of normal operation, design-basis

accidents (DBAs), external events, and natural phenomena for which the plant must be

designed, were considered for license renewal scoping in accordance with 10 CFR 54.4(a)(1)

criteria.

2.1.4.1.2 Staff Evaluation

Pursuant to 10 CFR 54.4(a)(1), the applicant must consider all safety-related SSCs relied upon

to remain functional during and following a design-basis event (DBE) to ensure the following

functions: (a) the integrity of the reactor coolant pressure boundary; (b) the ability to shut down

the reactor and maintain it in a safe-shutdown condition; or (c) the capability to prevent or

mitigate the consequences of accidents that could result in potential offsite exposures

comparable to those referred to in 10 CFR 50.34(a)(1), 50.67(b)(2), or 100.11.

With regard to identification of DBEs, SRP-LR Section 2.1.3 states:

The set of DBEs as defined in the Rule is not limited to Chapter 15 (or

equivalent) of the UFSAR. Examples of DBEs that may not be described in this

chapter include external events, such as floods, storms, earthquakes,

tornadoes, or hurricanes, and internal events, such as a high energy line break.

Information regarding DBEs as defined in 10 CFR 50.49(b)(1) may be found in

any chapter of the facility UFSAR, the Commission's regulations, NRC orders,

exemptions, or license conditions within the CLB. These sources should also be

2-7
reviewed to identify SSCs relied upon to remain functional during and following

DBEs (as defined in 10 CFR 50.49(b)(1)) to ensure the functions described in

10 CFR 54.4(a)(1).

During the audit, the applicant stated that it evaluated the types of events listed in NEI 95-10

(i.e., anticipated operational occurrences, DBAs, external events and natural phenomena) that

were applicable to SSES. The applicant identified the documents that described the events, all

of which are contained in the UFSAR, with the exception of fire, which is contained in separate

documentation. The applicant also reviewed the IPE and the IPEEE, as well as licensing

correspondence and DBDs. The applicant stated that as a result of this review, no additional

systems were identified and included within the scope license renewal. The staff concludes that

the applicant's evaluation of DBEs was consistent with the guidance contained in the SRP-LR.

The applicant performed scoping of SSCs pursuant to 10 CFR 54.4(a)(1) criterion in

accordance with the license renewal procedure guidelines which provide guidance for the

preparation, review, verification, and approval of the scoping evaluations to assure the

adequacy of the results of the scoping process. The staff reviewed these guidance documents

governing the applicant's evaluation of safety-related SSCs, and sampled the applicant's

scoping results reports to ensure the methodology was implemented in accordance with those

written instructions. In addition, the staff discussed the methodology and results with the

applicant's personnel who were responsible for these evaluations.

Specifically, the staff reviewed a sample of the license renewal scoping results for the MS

system, the engineered safeguards (ES) service water pumphouse, and the TB to provide

additional assurance that the applicant adequately implemented its scoping methodology in

accordance with 10 CFR 54.4(a)(1). The staff verified that the scoping results for each of the

sampled systems were developed consistent with the methodology, the SSCs credited for

performing intended functions were identified, and the basis for the results as well as the

intended functions were adequately described. The staff verified that the applicant had

identified and used pertinent engineering and licensing information to identify the SSCs

required to be within scope, in accordance with 10 CFR 54.4(a)(1).

The staff reviewed the applicant's evaluation of the Rule and CLB definitions pertaining to

10 CFR 54.4(a)(1). The SSES CLB definition of safety-related is not identical to the definition

provided in the Rule. The applicant's definition of safety-related and exceptions to the definition

in the Rule are documented in LRA Section 2.1.1.1. Based on its review, the staff confirms that

10 CFR 50.34(a)(1) is not applicable to SSES as this regulation pertains to applications for a

construction permit and 10 CFR 50. 67(b)(2) is applicable to plants using an alternate source

term. The staff noted that SSES has submitted a license amendment request, to the staff,

(which was issued by letter dated January 31, 2007) to allow the use of an alternative source

term for accident analyses in accordance with the requirements of 10 CFR 50.67(b)(2) and has

conservatively included all SSCs which would be affected by the license amendment within the

scope of license renewal. In addition, the applicant stated that certain components located in

the TB do not have an intended function but are classified by SSES as safety-related and

included within the scope of license renewal, in accordance with 10 CFR 54.4(a)(1 ). However,

the staff notes that this process is not articulated by the applicant in the LRA nor is it

documented in the license renewal procedures or guidelines. The staff's review of LRA

Section 2.1.1 identified areas in which additional information was necessary to complete the

review of the applicant's scoping and screening methodology.

2-8
In RAI 2.1-1, dated March 9, 2007, the staff requested that the applicant provide a written

evaluation that addresses the impact, if any, of the use of differing definitions of safety-related

and of not having explicitly considered in its scoping methodology for SSES, those structures,

systems, or components that are relied upon to ensure "the capability to prevent or mitigate the

consequences of accidents that could result in potential offsite exposures comparable to the

guidelines in 10 CFR 50.34(a)(1), 50.67(b)(2), or 100.11 of this chapter, as applicable,"

consistent with the CLB for SSES.

In the response to RAI 2.1-1, dated April 17, 2007, the applicant stated that the SSES source

documents used for 10 CFR 54.4(a)(1) scoping include differing definitions of safety-related

pertaining to the offsite exposure limits of 10 CFR 50.34(a)(1), 50.67(b)(2), and 100.11. The

offsite exposure criterion is included in the safety-related definition used in each of the source

documents, but refers only to the limits of 10 CFR Part 100. The applicant stated that

10 CFR 50.34(a)(1) is associated with facilities seeking a construction permit and therefore is

not applicable to SSES license renewal and the dose guidelines of 10 CFR 50.67(b) are

associated with accident source term limits which were not applicable to SSES, when the LRA

was submitted. The applicant evaluated the variations in the safety-related definitions and

concluded that there is no impact on the 10 CFR 54.4(a)(1) scoping performed for the LRA.

Based on its review, the staff finds the applicant's response to RAI 2.1-1 acceptable because

the applicant has adequately evaluated the differing definitions of safety-related contained in its

scoping source documents pertaining to the offsite exposure criterion. The staff concludes that

there was no impact on the applicant's ability to accurately identify SSCs within the scope of

license renewal, in accordance with the requirements of 10 CFR 54.4(a)(1). Therefore, the

staff's concern described in RAI 2.1-1 is resolved.

In RAI 2.1-2, dated March 9, 2007, the staff requested that the applicant discuss the process

and rationale by which it determined that certain nonsafety-related components were within the

scope of license renewal in accordance with 10 CFR 54.4(a)(1). In addition, the staff requested

that the applicant discuss how it reviewed other nonsafety-related SSCs for potential interaction

(10 CFR 54.4(a)(2)) with the nonsafety-related components located within the TB, which have

been included within the scope of license renewal pursuant to 10 CFR 54.4(a)(1).

In the response to RAI 2.1-2, dated April 17, 2007, the applicant stated that the SSES design

bases states that not all equipment designated as "Q"-class, performs a safety-related function.

PPL Design Standard GDS-06 states that "Q" items are either safety-related or are to be

"treated as safety-related" under the Operational QA Program, even though they do not perform

or prevent the performance of the safety-related function. To maintain consistency with normal

plant practices, the set of SSCs that satisfy the 10 CFR 54.4(a)(1 ) criteria conservatively

includes those components designated as "Q" that are "treated as safety-related," without

performing a safety-related function. Although, certain pressure switches located in the TB are

designated "Q" in accordance with normal plant operations and were included within the scope

of license renewal in accordance with 10 CFR 54.4(a)(1), the component's do not have a

safety-related function. The SSES CLB indicates that there are no components that perform a

safety-related function located in the TB. Because the CLB establishes that there is no

safety-related equipment in the TB, there would be no potential interaction (10 CFR 54.4(a)(2))

with the nonsafety-related components located within the TB.

Subsequent to the applicant's response to RAI 2.1-2, the LRA was amended by letter dated

September 30, 2008, which stated that the Unit 2 turbine building contained safety-related

2-9
cables associated with the high pressure coolant injection (HPCI) System pump suction transfer

between the condensate storage tank and the suppression pool for Unit 2. However, the

applicant performed an analysis which concluded that the loss of these HPCI cables would not

prevent the accomplishment of a safety-related intended function. The staff determined that this

additional information did not impact the response to RAI 2.1-2.

Based on its review, the staff finds the applicant's response to RAI 2.1-2 acceptable because

the applicant has provided a rationale for including the nonsafety-related SCs within the scope

of license renewal in accordance with 10 CFR 54.4(a)(1), as consistent with normal plant

operations. The staff's concern described in RAI 2.1-2 is resolved.

2.1.4.1.3 Conclusion

On the basis of its review of sample systems, discussions with the applicant, and review of the

applicant's scoping process, the staff concludes that the applicant's methodology for identifying

systems and structures is consistent with the scoping criteria pursuant to 10 CFR 54.4(a)(1)

and therefore is acceptable.

2.1.4.2 Application of the Scoping Criteria in 10 CFR 54.4(a)(2)

2.1.4.2.1 Summary of Technical Information in the Application

In LRA Section 2.1.1.2, "Nonsafety-Related SSCs Affecting Safety-Related SSCs Scoping," the

applicant described the scoping methodology as it related to the nonsafety-related criteria in

accordance with 10 CFR 54.4(a)(2). Also, the applicant's (a)(2) scoping methodology was

based on guidance provided in Appendix F of NEI 95-10, Revision 6. The applicant evaluated

the impacts of nonsafety-related SSCs that met 10 CFR 54.4(a)(2) criteria by using two major

categories: 1) functional failure, and 2) physical failure. A summary description of these two

categories is provided below.

Functional Failure of Nonsafety-Related SSCs. LRA Section 2.1.1.2.1, "Functional Failures of

Nonsafety-Related SSC," stated that SSCs required to perform a function in support of

safety-related components are classified as safety-related and are included in the scope of

license renewal in accordance with 10CFR 54.4(a)(1). SSCs required to remain functional in

support of safety-related components were included within the scope of license renewal in

accordance with the requirements of 10 CFR 54.4(a)(2). Engineering and licensing documents

were reviewed to determine the appropriate systems and structures in this category. The

applicable sections of the UFSAR, Maintenance Rule Database, and design basis references

provide the system and structure functional information to address these considerations.

Systems, structures, and components that perform nonsafety-related intended functions

credited in the current licensing basis and are subject to an AMR are identified in Sections 2.3,

2.4, and 2.5 of the LRA. In addition, nonsafety-related SSCs identified in the SSES alternate

source term analyses have been included within the scope of license renewal in accordance

with 10 CFR 54.4(a)(2).

Nonsafety-Related SSCs with the potential for spatial Interaction with Safety-Related SSCs.

LRA Section 2.1.1.2.2, "Spatial Failures of Nonsafety-Related SSCs," states that

nonsafety-related systems and nonsafety-related portions of safety-related systems are

identified as in-scope under 10 CFR 54.4(a)(2) if there is a potential for spatial interactions with

safety-related equipment. Spatial failures are defined as failures of nonsafety-related SSCs that

2-10
are connected to or located in the vicinity (same building) of safety-related SSCs creating the

potential for interaction between the SSCs due to physical impact, harsh environment, flooding,

spray or leakage that could impede or prevent the accomplishment of the safety-related

functions of a safety-related SSC.

Certain mitigative features, such as missile barriers, flood barriers, and spray shields, are

credited in the current licensing basis for the protection of safety-related SSCs from spatial

interaction. These protective features are included within the scope of license renewal and

evaluated as structural components.

In addition, SSES used the preventive option described in Appendix F of NEI 95-10 to

determine the scope of license renewal with respect to the protection of safety-related SSCs

from spatial interactions that are not addressed in the CLB. This scoping process required an

evaluation based on equipment location and the related SSCs and whether fluid-filled system

components are located in the same building or miscellaneous area as safety-related

equipment, unless justification is provided that failures would not impact a safety function.

Consistent with the related industry discussions in NEI 95-10, Appendix F, failure of

nonsafety-related components that do not contain a fluid would not result in spatial interaction

as there is no fluid to leak or spray onto safety-related SSCs and system pressure is such that

there is no force that could cause significant movement of the failed component. This

conclusion is confirmed by review of SSES and industry operating experience.

Nonsafety-Related SSCs directly connected to Safety-Related SSCs, The LRA stated that for

nonsafety-related piping that is directly connected to safety-related piping, the seismic Category

I design requirements are extended to the first seismic restraint beyond the defined boundaries

(the nonsafety-related and safety-related interface). The seismic design is extended to the first

point in the system which can be treated as an anchor to the plant structure. An anchor support

is defined in SSES piping design specifications as a rigid support that restrains all 6 degrees of

motion of the piping system. Anchors can include large fixed equipment such as pumps, tanks,

heat exchangers, and in some cases, larger piping. The nonsafety-related structural

components in the scope of license renewal include those that comprise seismic anchors. All

seismic anchors and the associated piping and components for nonsafety-related to

safety-related interfaces are within the scope of license renewal under 10 CFR 54.4(a)(2) using

the base-mounted equipment and flexible connection options from NEI 95-10 (Reference 2.1-

1), Appendix F, as well as including the entire length of piping that is connected on both ends to

safety-related piping.

2.1.4.2.2 Staff Evaluation

Pursuant to 10 CFR 54.4(a)(2), the applicant must consider all nonsafety-related SSCs whose

failure could prevent satisfactory accomplishment of safety-related SSCs relied upon to remain

functional during and following a DBE to ensure the following functions: (a) the integrity of the

reactor coolant pressure boundary; (b) the ability to shut down the reactor and maintain it in a

safe-shutdown condition; or (c) the capability to prevent or mitigate the consequences of

accidents that could result in potential offsite exposures comparable to those referred to in

10 CFR 50.34(a)(1), 50.67(b)(2), or 100.11.

Regulatory Guide (RG) 1.188, "Standard Format and Content for Applications to Renew

Nuclear Power Plant Operating Licenses," Revision 1, dated September 2005, provided staff

endorsement on the use of NEI 95-10, "Industry Guidelines for Implementing the Requirements

2-11
of 10 CFR Part 54 - The License Renewal Rule," Revision 6, dated June 2005. RG 1.188 states

that NEI 95 -10, Revision 6, provides methods that the staff considers acceptable for

compliance with 10 CFR Part 54, when preparing a license renewal application. NEI 95 -10,

Revision 6, discusses the staff position on 10 CFR 54.4(a)(2) scoping criteria; nonsafety-related

SSCs, typically identified in the CLB; consideration of missiles, cranes, flooding, high-energy

line breaks (HELBs); nonsafety-related SSCs connected to safety-related SSCs; nonsafetyrelated SSCs in proximity of safety-related SSCs; and the mitigative and preventative options

related to nonsafety-related and safety-related SSCs interactions.

In addition, the staff position on NEI 95-10, Revision 6, 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

such as safety operational event reports, and engineering evaluations.

The staff reviewed LRA Section 2.1.1.2, where the applicant described its scoping methodology

as it related to the nonsafety-related criteria in accordance with 10 CFR 54.4(a)(2). In addition,

the staff reviewed the applicant's 10 CFR 54(a)(2) AMR report. The staff noted that the

applicant's evaluations were performed in accordance with the guidance contained in

NEI 95-10, Revision 6, for identification and treatment of SSCs which meet 10 CFR 54.4(a)(2)

criteria. Also, as described in LRA Section 2.1.4.2.1, the applicant's evaluation of the

nonsafety-related SSCs to meet 10 CFR 54.4(a)(2) criteria is based on categories of functional

failure and physical failure.

Based on its review of the information provided by the applicant in the LRA, 10 CFR 54.4(a)(2)

AMR report criteria, and the discussions with the applicant during the audit, the staff's

evaluation pertaining to the categories described in paragraph two of this subsection

immediately follows.

Nonsafety-Related SSCs Required to Perform a Function that Supports a Safety-Related SSC.

Nonsafety-related SSCs required to remain functional to support a safety-related function were

included within the scope of license renewal as safety-related, in accordance with the

requirements of 10 CFR 54.4(a)(2). This evaluating criteria was discussed in the applicant's

10 CFR 54.4(a)(2) AMR report. The staff finds that the applicant has implemented an

acceptable method for scoping of nonsafety-related systems that perform a function that

supports a safety-related intended function.

Nonsafety-Related SSCs Directly Connected to Safety-Related SSCs. In order to identify the

nonsafety-related SSCs directly connected to safety-related SSCs and required to be

structurally sound to maintain the integrity of the safety-related SSCs, the applicant used a

bounding approach as described in NEI 95-10, Appendix F and the SSES seismic analysis. The

applicant reviewed each mechanical system safety-related to nonsafety-related interface to

identify the components located between the interface and the structural boundary or equivalent

anchor, if used. The applicant included all nonsafety-related SSCs within the analyzed structural

boundary and within the scope of license renewal, in accordance with 10 CFR 54.4(a)(2). If the

structural boundary was not indicated on the applicable drawing, the applicant identified the

portion of the nonsafety-related SSCs beyond the safety-related SSCs, to the first equivalent

2-12
anchor or seismic anchor, and included this portion of the nonsafety-related SSCs within the

scope of license renewal.

The applicant also indicated in the LRA that if the structural boundary could not be identified for

the applicable nonsafety-related/safety-related interface, the nonsafety-related SSCs were

included to a point beyond the nonsafety-related/safety-related interface to a base-mounted

component, flexible connection, or the end of the piping run. The applicant based its actions on

the guidance of NEI 95-10, Appendix F, which describes the use of "bounding criteria" as a

method of determining the portion of nonsafety-related SSCs to be included within the scope of

license renewal. This provided assurance that the nonsafety-related piping systems included in

the design-basis seismic analysis are included in the scope of license renewal. The applicant's

identification of these nonsafety-related systems and components at nonsafety-related to

safety-related boundary is depicted in its 10 CFR 54.4(a)(2) AMR report. Also listed in this

report are the AMR results of the component types with the corresponding intended function,

material, environment, and aging effects and associated programs. In addition, the staff noted

that the applicant stated in LRA Sections 2.3.3.2, 2.3.3.5, 2.3.3.9, 2.3.3.23, and 2.3.3.31,

certain components (e.g., accumulator, tank, heating and ventilation units) perform an anchor

function, but are not subject to an AMR based on evaluation of their construction, mounting and

support function.

The staff's review of LRA Section 2.1.1.2.2 identified that the applicant had not included

nonsafety-related piping attached to safety-related SSCs located within containment or

nonsafety-related piping attached to safety-related piping at containment penetrations within the

scope of license renewal. In addition, the applicant used an analysis, in lieu of it's documented

screening process, to determine whether nonsafety-related components affecting safety-related

components, as discussed in LRA Sections 2.3.3.2, 2.3.3.5, 2.3.3.9, 2.3.3.23 and 2.3.3.31,

were subject to an AMR. The staff determined that additional information would be required to

complete the review of the applicant's scoping methodology.

In RAI 2.1-3, dated March 9, 2007, the staff requested that the applicant explain the following:

(a) The rationale and basis for not including nonsafety-related piping

attached to safety-related piping at containment penetrations and

extending outside of containment, within the scope of license renewal

(b) The rationale and basis for not including nonsafety-related piping

attached to safety-related SCs inside containment, within the scope of

license renewal

(c) The rationale for the use of an analysis to determine that nonsafetyrelated SCs within the scope of license renewal were not subject to an

AMR, the details and results of the analysis, and to indicate how the

applicant's analysis met the criteria of the screening process used for

other nonsafety-related SCs and the requirements of 10 CFR 54.21

In its response to RAI 2.1-3, dated April 17, 2007, the applicant stated:

(a) The applicant had performed a re-evaluation and determined that certain

nonsafety-related components attached to safety-related piping at

containment penetrations and extending outside of containment, had not

2-13
been included within the scope of license renewal. The applicant

indicated that the nonsafety-related components are connected to, and

provide support for, the attached safety-related equipment and have

subsequently been included within the scope of license renewal as

required by 10 CFR 54.4(a)(2). The applicant provided a list of the

nonsafety-related equipment which had been included within the scope of

license renewal and the results of the aging management reviews.

(b) The applicant had performed a re-evaluation which identified nonsafetyrelated equipment, inside primary containment, that is connected to

safety-related equipment and provides the anchor for the safety-related

equipment, which had not been included within the scope of license

renewal. The applicant indicated that the nonsafety-related equipment

has subsequently been included within the scope of license renewal as

required by 10 CFR 54.4(a)(2). The applicant provided a list of the

nonsafety-related equipment which had been included within the scope of

license renewal and the results of the aging management reviews.

(c) The applicant had determined that certain nonsafety-related components

attached to safety-related SSCs and which had been included within the

scope of license renewal, had not been subject to an aging management

review. The applicant performed an evaluation to determine the extent of

condition and subsequently performed the required aging management

reviews. The applicant provided a list of the components determined to

be subject to an aging management review and the results of the aging

management reviews.

Based on its review, the staff finds the applicant's response to RAI 2.1-3 acceptable because

the applicant had performed evaluations to determine if nonsafety-related SCs should be

included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) and if AMRs

were required. The applicant's evaluations, as documented in the RAI response, resulted in (1)

the inclusion of nonsafety-related components, attached to safety-related piping at containment

penetrations and extending outside of containment within the scope of license renewal; (2) the

inclusion of nonsafety-related equipment, inside primary containment, that is connected to

safety-related equipment and provides the anchor for the safety-related equipment within the

scope of license renewal; and (3) the performance of AMRs of nonsafety-related components

attached to safety-related SSCs and which had been included within the scope of license

renewal, but which had not been previously subject to an AMR. The staff determined that the

nonsafety-related components, discussed in RAI 2.1-3, has been appropriately evaluated for

inclusion within the scope of license renewal and subjected to an AMR and that the staffs

concern in RAI 2.1-3 is resolved.

Nonsafety-Related SSCs with the Potential for Spatial Interaction with Safety-Related SSCs.

The applicant considered physical impact (i.e, pipe whip, jet impingement), harsh environments,

flooding, spray, and leakage when evaluating the potential for spatial interactions between

nonsafety-related systems and safety-related SSCs. The applicant used a spaces approach for

scoping of nonsafety-related systems with potential spatial interaction with safety-related SSCs.

The spaces approach focused on the interaction between nonsafety-related and safety-related

SSCs that are located in the same space, which was defined as a building which contains

2-14
safety-related SSCs. The space was defined such that any potential interaction between

nonsafety-related and safety-related SSCs is limited to the space.

Physical Impact or Floodinq. The applicant considered situations where nonsafety-related

supports for non-seismic (including seismic Il/I) piping systems and electrical conduit and cable

trays with potential for spatial interaction with safety-related SSCs are included in the scope of

license renewal per the Rule and subject to an AMR. These supports and components are

addressed in a commodity fashion within civil/structural AMR reports. The applicant's review of

earthquake experience identified no occurrence of welded steel pipe segments falling due to a

strong motion earthquake. The applicant concluded that as long as the effects of aging on

supports for piping systems are managed, falling of piping systems is not credible, except due

to flow accelerated corrosion. Furthermore, the piping section itself was determined not to be

in-scope for 10 CFR 54.4(a)(2), due to a physical impact hazard. The applicant evaluated

whether missiles could be generated from internal or external events such as failure of rotating

equipment or overhead-handling systems. The nonsafety-related design features which protect

safety-related SSCs from such missiles were included within the scope of license renewal.

Pipe Whip, Jet Impingement, and Harsh Environment. The applicant evaluated

nonsafety-related portions of high energy lines against the 10 CFR 54.4(a)(2) criteria. The

applicant's evaluation was based on a review of the UFSAR and relevant site documentation.

The applicant evaluated the high energy systems to ensure proper identification of components

that are part of nonsafety-related high energy lines that can effect safety-related equipment. If

the applicant's HELB analysis assumed that a nonsafety-related piping system did not fail or

assumed failure only at specific locations, then that piping system (i.e., piping, equipment and

supports) was included within the scope of license renewal pursuant to 10 CFR 54.4(a)(2)

criteria and subject to and AMR, in order to provide assurance that those assumptions remain

valid through the period of extended operation. Also, as discussed in the SSES AMR report for

10 CFR 54.4(a)(2) review, the applicant reviewed the reference documents that contained

HELB analysis for inside as well as outside containment and identified high energy lines. Many

of the identified systems were safety-related and included within the scope of license renewal in

accordance with 10 CFR 54.4(a)(1). The remaining nonsafety-related high energy lines, which

were determined to have potential interaction with safety-related SSCs, were included within the

scope of license renewal.

SLoray and Leakage. The applicant evaluated moderate and low-energy systems which have the

potential for spatial interactions of spray and leakage. Nonsafety-related systems and

nonsafety-related portions of safety-related systems with the potential for spray or leakage that

could prevent safety-related SSCs from performing their required safety function were

considered within the scope of license renewal. The applicant used a spaces approach to

identify the nonsafety-related SSCs which were located within the same space as safety-related

SSCs. As described by the applicant in the LRA, a space is defined as a building containing

safety-related SSCs. The space is defined such that any potential interaction between

nonsafety-related and safety-related SSCs is limited to the space. The applicant documented its

review of each mechanical system for potential spatial interaction with safety-related SSCs in

applicant's scoping results AMR review report, which also is documented in the audit report.

Following identification of the applicable mechanical systems, the applicant reviewed the

system functions to determine whether the system contained fluid, air or gas. Based on the

spray or leakage and also operating experience, the applicant excluded the nonsafety-related

SSCs containing air or gas from the scope of license renewal. The applicant then reviewed the

mechanical systems to determine whether the system had any components located within a

2-15
structure containing safety-related SSCs. Those nonsafety-related SSCs determined to contain

fluid and located within a space containing safety-related SSCs, were included within the scope

license renewal.

Protective Features. The applicant evaluated protective features such as whip restraints, spray

shields, supports, and missile and flood barriers, installed to protect safety-related SSCs

against spatial interaction with nonsafety-related SSCs due to fluid leakage, spray, or flooding.

Such protective features credited in the plant design were included within the scope of license

renewal.

2.1.4.2.3 Conclusion

On the basis of its review of sample systems, discussions with the applicant, and review of the

applicant's scoping process, the staff concludes that the applicant's methodology for identifying

systems and structures is consistent with the scoping criteria of 10 CFR 54.4(a)(2) and

therefore is acceptable.

2.1.4.3 Application of the Scoping Criteria in 10 CFR 54.4(a)(3)

2.1.4.3.1 Summary of Technical Information in the Application

In LRA Section 2.1.1.3, "Regulated Events Scoping," the applicant described the methodology

for identifying systems and structures that are in the scope of license renewal based on the

regulated events criteria. The SSCs that perform intended functions required for compliance

with a regulated event and subject to an AMR are identified in LRA Sections 2.3, 2.4, and 2.5.

Mechanical and structural systems that perform a fire protection, anticipated transients without

scram (ATWS), and/or station blackout (SBO) intended function are included in the scope of

license renewal. All plant electrical and instrumentation and control (I&C) systems and electrical

equipment in mechanical systems were included in-scope of license renewal.

Fire Protection. In LRA Section 2.1.1.3.1, "Fire Protection (10 CFR 50.48)," the applicant

described the scoping of mechanical systems and structures required to demonstrate

compliance with the fire protection requirements. In the LRA, the applicant stated that the SSES

was licensed after January 1, 1979 and is therefore not bound to the provisions of

10 CFR 50.48(b). However, as a result of licensing commitments and standard fire protection

licensing condition for plants licensed after January 1, 1979, the SSES generated a Fire

Protection Review Report which addresses compliance with pertinent regulations. The

applicant's CLB includes the Fire Protection Review Report, which contains a safe-shutdown

analysis (to demonstrate compliance with Appendix R), description of the fire protection system,

the fire hazard analysis (to demonstrate that a single postulated fire will not affect the ability of

both units to be brought to and maintained in cold shutdown condition), and any deviation

requirements. Section 2.1.1.3.1 further states, based on its review of its CLB for fire protection,

the applicant identified systems and structures and determined the corresponding intended

functions that meet the requirements of 10 CFR 50.48 in addition to 10 Part 50, Appendix R.

This determination included both the features required for fire protection of safety-related

equipment and any system function that was included in, or provides necessary support for,

one or more of the three safe-shutdown paths credited for compliance with 10 CFR Part 50,

Appendix R. Mechanical systems and structures credited with fire prevention, detection,

mitigation in areas containing equipment important to safe operation of the plant, and

2-16
equipment credited with safe-shutdown in the event of a fire were included within the scope of

license renewal.

Environmental Qualification (EQ). The applicant described the EQ requirements of

10 CFR 50.49 in LRA Section 2.1.1.3.2, "Environmental Qualification (10 CFR 50.49)." The

electrical equipment at SSES, which is required to be environmentally qualified for a "harsh"

environment by 10 CFR 50.49, is identified in the SSES - Nuclear Information Management

System database. In the LRA, the applicant stated that EQ at SSES applies to electrical

equipment installed in mechanical systems, instruments or valve operators in a fluid system,

and also the electrical equipment installed in electrical systems. Electrical equipment that is

required to be environmentally qualified is identified to be within the scope of license renewal.

Pressurized Thermal Shock. These requirements are not applicable because SSES units are of

boiling-water reactor (BWR) design.

Anticipated Transient Without Scram. The applicant described the scoping of mechanical

systems and structures required to demonstrate compliance with the ATWS requirements of

10 CFR 50.62 in LRA Section 2.1.1.3.4, "Anticipated Transients without Scram

(10 CFR 50.62)." Mechanical systems and structures that perform a 10 CFR 50.62 intended

function were included within the scope of license renewal.

Station Blackout. The applicant described the scoping criteria in LRA Section 2.1.1.3.5, "Station

Blackout (10 CFR 50.63)." The applicant's licensing basis requires an SBO coping duration of

four hours, and therefore the mechanical systems and structures required to support the

four-hour coping duration are included within the scope of license renewal. The applicant stated

that, at SSES, all plant equipment which includes systems and instrumentation necessary to

cope with the SBO was identified and investigated to assure that all items necessary for the

equipment to function would be available for at least four-hours. This is the equipment relied

upon for compliance with 10 CFR 50.63 requirements. Also, the applicant stated that based on

its CLB for SBO, the intended functions for each system and structure supporting the

10 CFR 50.63 requirements were determined, and the SSCs that perform an intended function

for SBO were included in the scope of license renewal.

2.1.4.3.2 Staff Evaluation

The staff reviewed the applicant's approach to identifying the mechanical systems and

structures relied upon to perform functions related to regulated events applicable to BWRs in

accordance with 10 CFR 54.4(a)(3). As part of this review and during its scoping and screening

audit at SSES, the staff discussed the methodology with the applicant, reviewed the

documentation developed to support the license renewal, and evaluated a sample of the

resultant mechanical systems and structures identified as within scope pursuant to

10 CFR 54.4(a)(3) criteria. The staff's review of the applicant's documentation included, but

was not limited to: (a) license renewal project guidelines, (b) license renewal project

documents, (c) plant drawings, (d) UFSAR, (e) maintenance rule design-basis documentation,

and (f) the applicant's Fire Protection Review Report.

The license renewal project guidelines described the applicant's process for identifying systems

and structures that are within the scope of license renewal. As described in the license renewal

project guidelines, all mechanical systems and structures that perform an intended function

pursuant to 10 CFR 54.4(a)(3), were included within the scope of license renewal, and the

2-17
results of scoping are documented in the applicant's license renewal project document scoping

results reports. The license renewal project documents stated that the scope of license renewal

includes all SSCs relied on in safety analyses or plant evaluations to perform a function that

demonstrates compliance with the 10 CFR 54.4(a)(3) regulated events. The staff reviewed the

applicant's evaluation of mechanical systems and structures for compliance with the scoping

criteria of 10 CFR 54.4(a)(3) and discussed the results of applicant's evaluation with the

applicant's license renewal project team members. The staff's review of the applicant's

evaluation and results of scoping requirements pursuant to 10 CFR 54.4(a)(3), for each

regulated event, is described below.

Fire Protection. As described in the LRA and the license renewal project documents, based on

a review of the Fire Protection Review Report for SSES, fire hazards analysis, topical design

basis documents, and other CLB documents, the applicant identified systems and structures

and determined the corresponding intended functions that meet the requirements of fire

protection license renewal scoping requirements of 10 CFR 54.4(a)(3). In a sample review of

the applicant's methodology for meeting 10 CFR 54.4(a)(3) regulation for fire protection, the

staff verified that the license renewal project document report identified the mechanical systems

that are within the scope of license renewal because they perform intended functions pursuant

to 10 CFR 50.48. The license renewal project documents summarized the scoping results for

mechanical systems and identified several mechanical systems that have one or more intended

functions pursuant to 10 CFR 50.48. The staff performed a sample review of the residual heat

removal service water (RHRSW) system, core spray system (CSS), and circulating water pump

house (CWPH) systems and structure for their inclusion as in-scope for fire protection. Based

on its review of the applicant's documentation and discussions with the applicant's license

renewal project team members, the staff finds that the applicant has implemented an

acceptable method for identifying systems and structures that perform a function that meets the

fire protection requirements of 10 CFR 54.4(a)(3) and has included those systems and

structures within the scope of license renewal.

Environmental Qualification. During the scoping and screening audit, the staff reviewed the LRA

and the applicant's implementing procedures and results reports (license renewal project

documents) for the EQ regulated event. Also, the staff discussed with the applicant's license

renewal project team, the details of the applicant's EQ scoping process and the information

sources used, to determine compliance with 10 CFR 50.49. The staff confirmed that the

applicant's primary sources of information for scoping electrical components for license renewal

was the Nuclear Information Management System database and the CLB, which identified

electrical equipment required by 10 CFR 50.49 to be environmentally qualified for harsh

environments, and the intended functions of those systems. The staff reviewed selected

portions of Nuclear Management System database and the SSCs identified within the scope of

license renewal in accordance with 10 CFR 54.4(a)(3). The staff determined that the applicant

had appropriately identified SSCs supporting environmental qualification and had accurately

identified the intended functions.

Anticipated Transient Without Scram. The three primary systems at SSES, that perform

intended functions pursuant to 10 CFR 50.62 to mitigate an ATWS event, are: standby liquid

control (SLC), alternate rod insertion, and reactor recirculation pump trip systems. Also, several

other SSCs support these systems in performing intended functions in accordance with

10 CFR 50.62. The applicant's scoping results report identified these mechanical systems as

included within the-scope of license renewal, because they perform a 10 CFR 50.62 intended

function. During the audit, the staff reviewed the applicant's license renewal implementing

2-18
procedures and results documents. The staff performed a sample review of the above three

systems that perform 10 CFR 50.62 intended functions. The staff also reviewed the primary

sources of information that the applicant used for identifying these intended functions. Sources

the applicant reviewed for scoping the systems and structures pursuant to 10 CFR 50.62

included topical design basis documents for ATWS, Maintenance Rule Database

documentation, the UFSAR, and SERs related to compliance with 10 CFR 50.62. Based on its

review of the source documentation and the system functions, the applicant included those

SSCs that perform an intended function for ATWS within the scope of license renewal.

Station Blackout. In accordance with the CLB, the coping period for SSES is four hours, during

which time, all systems and structures relied on in safety analyses or plant evaluations to

perform a function that demonstrates compliance with 10 CFR 50.63 for SBO, be included

within the scope of license renewal. The staff reviewed the LRA, as well as the applicant's

implementing procedures and the results reports in accordance with the criteria found in

10 CFR 50.63 and the applicant's results report which identified mechanical systems and

structures that are included within the scope of license renewal because they perform an

intended function pursuant to 10 CFR 50.63. The staff reviewed selected portions of the

sources of information used by the applicant for the scoping of systems and structures in

compliance with 10 CFR 50.63 including the UFSAR, site technical report for coping

assessment for the SSES during an SBO, and site calculations (UFSAR Section 15.8). Based

on review of these information sources and the CLB, the staff determined that the applicant had

correctly identified the intended functions for each system and structure meeting the

requirements of 10 CFR 50.63, had identified the SSCs that perform an intended function for a

SBO and included them within the scope of license renewal.

2.1.4.3.3 Conclusion

On the basis of the sample review, discussions with the applicant, and review of the applicant's

scoping process, the staff concludes that the applicant's methodology for identifying systems

and structures meets the scoping criteria pursuant to 10 CFR 54.4(a)(3) and therefore is

acceptable.

2.1.4.4 Plant-Level Scoping of Systems and Structures

2.1.4.4.1 Summary of Technical Information in the Application

System and Structure Level ScopinQ. The applicant documented its methodology for scoping of

SSCs in accordance with 10 CFR 54.4(a) in the license renewal project guidelines and license

renewal project documents, as documented in the audit report. The applicant's approach to

system and structure scoping provided in the site guidance was consistent with the

methodology described in LRA Section 2.1. Specifically, the license renewal project guidelines

specified that the personnel performing license renewal scoping use CLB documents and

describe the system or structure including a list of functions that the system or structure is

required to accomplish. Sources of information regarding the CLB for systems included the

Maintenance Rule Database, UFSAR, DBDs, P&IDs, electrical drawings, and docketed

correspondence. The applicant then compared identified system or structures function lists to

the scoping criteria to determine whether the functions met the scoping criteria of

10 CFR 54.4(a). The applicant documented the results of the plant-level scoping process in

accordance with the license renewal project guidelines. These results were provided in the

systems and structures license renewal project documents. The license renewal project

2-19
documents contained information including a description of the structure or system, a listing of

functions performed by the system or structure, identification of intended functions, the

10 CFR 54.4(a) scoping criteria met by the system or structure, references, and the basis for

the classification of the system or structure intended functions. During the audit, the staff

reviewed a sampling of license renewal project document reports and concluded that the

applicant's scoping results in the license renewal project documents contained an appropriate

level of detail to document the scoping process.

Component Level Scoping. After the applicant identified the intended functions of systems or

structures within the scope of license renewal, a review determined which components of each

in-scope system and structure support license renewal intended functions. The components

that support intended functions were considered within the scope of license renewal and

screened to determine whether an AMR was required. The applicant considered three

component/commodity groups during this stage of the scoping methodology: (1) mechanical,

(2) structural commodity, and (3) electrical commodity.

Commodity Groups Scopinq. The applicant applied commodity group scoping to structural and

electrical SCs as discussed in Sections 2.1.4.6 and 2.1.4.7.

Insulation. LRA Section 2.1.2.6, "Treatment of Insulation," stated that at SSES, piping and

equipment insulation is classified as nonsafety-related and is required to maintain its structural

integrity for nonsafety affecting safety considerations. Insulating materials that function to limit

heat transfer, serve as fire barriers, or are required to maintain their structural integrity are

included within the scope of license renewal and are addressed as structural commodities in

Section 2.4 of the LRA.

Consumables. LRA Section 2.1.2.4, "Treatment of Consumables," states that the guidance in

Section 4.1 of NEI 95-10 was used to categorize and evaluate consumables. Consumables

were divided into the following five categories for the purpose of license renewal: (a) packing,

gaskets, component seals, and O-rings; (b) structural sealants; (c) oil, grease, and component

filters; (d) system filters, fire extinguishers, fire hoses, and air packs; and, (e) mechanical

sealants.

Group (a) subcomponents are not relied upon to form a pressure-retaining function and,

therefore, are not subject to an AMR. Group (b) subcomponents are structural sealants for

structures within the scope of license renewal that require an AMR. Group (c) subcomponents

are periodically replaced according to plant procedures and, therefore, are not subject to an

AMR. Group (d) consumables are subject to replacement based on National Fire Protection

Association standards and Department of Transportation standards according to plant

procedures and, therefore, are not subject to an AMR. Group (e) mechanical sealants in the

heating, ventilation, and air conditioning (HVAC) system include duct tape, and gaskets. Upon

evaluation, the applicant determined that these consumables did not have an intended function

for license renewal and therefore is not subject to an AMR.

2.1.4.4.2 Staff Evaluation

The staff reviewed the applicant's methodology for performing the scoping of plant systems and

components to ensure compliance with 10 CFR 54.4(a). The methodology used to determine

the mechanical systems and components within the scope of license renewal was documented

in license renewal project documents, and plant level scoping results for mechanical systems

2-20
were identified in LRA Table 2.2-1. The scoping process defined the plant in terms of systems

and structures. Specifically, the license renewal project guidelines (a) identified the systems

and structures that are subject to review in accordance with 10 CFR 54.4, (b) described the

processes for capturing the results of the review, and (c) were used to determine whether the

system or structure performed intended functions consistent with the requirements of

10 CFR 54.4(a). The process was completed for all systems and structures to ensure that the

entire plant was addressed. The applicant's personnel performed initial reviews on systems and

structures identified in the CLB.

2.1.4.4.3 Conclusion

Based on its review of the LRA, scoping and screening implementing procedures, and a

sampling of system scoping results during the audit, the staff concludes that the applicant's

methodology reasonably identifies SSCs and commodity groups within the scope of license

renewal and their intended functions. The staff also concludes that the applicant's scoping

methodology for plant SSCs, commodity groups, insulation, and consumables meets the

scoping criteria pursuant to 10 CFR 54.4(a)(3) and therefore is acceptable.

2.1.4.5 Mechanical Component Scoping

2.1.4.5.1 Summary of Technical Information in the Application

LRA Section 2.1 describes the methodology for identifying license renewal evaluation

boundaries. For mechanical systems, the mechanical components include those portions of the

system that are necessary to ensure that the intended functions will be performed. Structures

and components needed to support each of the system/structure-level intended functions

identified in the scoping process are included within the evaluation boundary.

The evaluation boundaries for mechanical systems are documented on license renewal

boundary drawings created by marking mechanical piping and instrumentation diagrams

to indicate the components within the scope of license renewal. Components within the

evaluation boundary are reviewed to determine whether they perform an intended function.

Typically, components in mechanical systems perform a pressure boundary function. Some

components may perform other functions such as heat transfer, filtration, or flow control.

Intended functions are established based on whether a particular function of a component is

necessary to support the system functions that meet the scoping criteria.

2.1.4.5.2 Staff Evaluation

The staff evaluated LRA Section 2.1 and the guidance in license renewal project documents,

license renewal project guidelines, and AMR reports to complete the review of mechanical

scoping process. The project document and guidelines provided instructions for identifying the

evaluation boundary. Determination of the mechanical system evaluation boundary requires an

understanding of system operations in support of intended functions. This process was based

on review of P&IDs, DBDs, Maintenance Rule basis documents, component databases, and

CLB documents such as the Environmental Protection Plan, the UFSAR, the Fire Protection

Review Report, the Offsite Dose Calculation Manual, the QA Program Description, the

Technical Requirements Manual, and the TSs and Bases. The evaluation boundaries for

mechanical systems are documented on license renewal boundary drawings created by

2-21
marking mechanical piping and instrumentation diagrams to indicate the components within the

scope of license renewal.

Components within the evaluation boundary were reviewed to determine whether they perform

an intended function. Intended functions are established based on whether a particular function

of a component is necessary to support the system functions that meet the scoping criteria.

Mechanical components were grouped, where practical, by component type.

The staff reviewed the implementation guidance and the CLB documents associated with

mechanical system scoping, and found that the guidance and CLB source information noted

above were acceptable to identify mechanical components and support structures in

mechanical systems that are within the scope of license renewal. The staff conducted detailed

discussions with the applicant's license renewal project management personnel and reviewed

documentation pertinent to the scoping process. The staff assessed whether the applicant had

appropriately applied the scoping methodology outlined in the LRA and implementing

procedures and whether the scoping results were consistent with CLB requirements. The staff

determined that the applicant's procedural methodology was consistent with the description

provided in LRA Section 2.1 and the guidance contained in SRP-LR Section 2.1, and was

adequately implemented.

The staff reviewed the applicant's methodology for identifying MS mechanical component types

meeting the scoping criteria as defined in the Rule. The staff also reviewed the scoping

methodology implementation procedures and discussed the methodology and results with the

applicant. The staff verified that the applicant has identified and used pertinent engineering and

licensing information in order to determine the MS mechanical component types required to be

within the scope of license renewal. As part of the review process, the staff evaluated each

system intended function identified for the MS system, the basis for inclusion of the intended

function, and the process used to identify each of the system component types. The staff

verified that the applicant has identified and highlighted system P&IDs to develop the license

renewal evaluation boundaries in accordance with the procedural guidance. The applicant was

knowledgeable about the process and conventions for establishing boundaries as defined in the

license renewal implementing procedures. Additionally, the staff verified that the applicant's

results are in accordance with the governing procedures. Specifically, other license renewal

personnel knowledgeable about the system had independently reviewed the marked-up

drawings to ensure accurate identification of system intended functions. The applicant

performed additional cross-discipline verification and independent reviews of the resultant

highlighted drawings before final approval of the scoping effort.

2.1.4.5.3 Conclusion

Based on its review of the LRA, scoping implementing procedures, and the system sample and

discussions with the applicant, the staff concludes that the applicant's methodology for

identifying mechanical systems meets the scoping criteria pursuant to 10 CFR 54.4(a) and

therefore is acceptable.

2-22
2.1.4.6 Structural Component Scoping

2.1.4.6.1 Summary of Technical Information in the Application

In LRA Section 2.1, the applicant described the methodology for identifying structures that are

in the scope of license renewal. Initially, all plant structures were reviewed to determine whether

they were in-scope for license renewal. The list of structures was identified using CLB

documents such as the UFSAR, the Maintenance Rule document for structures, the Fire

Protection Review Report, topical design basis documents, and plant drawings. Structures that

have an intended function for 10 CFR 54.4(a) were included in the scope of license renewal

and listed in LRA Table 2.2-3. LRA Section 2.4 described the scoping results for the individual

structures that are in-scope of license renewal.

2.1.4.6.2 Staff Evaluation

The staff reviewed the applicant's approach for identifying structures relied upon to perform the

functions pursuant to 10 CFR 54.4(a). As part of this review, the staff discussed the

methodology with the applicant, reviewed the documentation developed to support the review,

and evaluated the scoping results for several structures that were identified as within the scope

of license renewal.

The license renewal project guidelines described the applicant's process for identifying

structures that are within the scope of license renewal and stated that all structures that perform

an intended function are to be included within the scope of license renewal and that the scoping

results are to be documented in the scoping results report. The scoping results report listed all

the structures that were evaluated, and also described the procedures the applicant used to

identify structures.

The staff reviewed the applicants implementing procedures and scoping results reports. The

applicant performed structural scoping in a manner to ensure that all plant buildings, yard

structures, and SBO related non-plant structures were considered. The scoping results report

identified the intended functions for each structure required for compliance with one or more

criteria pursuant to 10 CFR 54.4(a). The structural component intended functions were

identified based on the guidance provided in NEI 95-10, and the SRP-LR. For structures, the

applicant determined the evaluation boundaries by developing a complete description of each

structure with respect to the intended functions performed by the structure. The results of the

review were documented in the scoping results report which contained a list of structures,

evaluation results for each structure pursuant to 10 CFR 54.4(a) criteria, a description of

structural intended functions, and source reference information for the functions. The applicant

identified 16 structures and or buildings as within the scope of license renewal.

The staff conducted detailed discussions with the applicant's license renewal team and

reviewed documentation pertinent to the scoping process. The staff assessed whether the

scoping methodology outlined in the LRA and procedures were appropriately implemented and

whether the scoping results were consistent with CLB requirements. The staff also reviewed

structural scoping evaluation results for the ES service water (SW) pump-house and the TB to

verify proper implementation of the scoping process. Based on these audit activities, the staff

did not identify any discrepancies between the methodology documented and the

implementation results.

2-23
2.1.4.6.3 Conclusion

On the basis of the staffs review of information in the LRA, the applicant's detailed scoping

procedures, and a sampling review of structural scoping results, the staff concludes that the

applicant's methodology for identification of the structures within the scope of license renewal

meets the scoping criteria pursuant to 10 CFR 54.4(a) and therefore is acceptable.

2.1.4.7 Electrical Component Scoping

2.1.4.7.1 Summary of Technical Information in the Application

LRA Section 2.1.1.4.3, "Electrical and Instrumentation and Control Systems" and Section 2.5,

"Scoping and Screening Results: Electrical and Instrumentation and Control Systems,"

describes the scoping process associated with electrical systems and components. A bounding

scoping approach was used for electrical equipment. All electrical components were determined

to be within the scope of license renewal and subject to an AMR unless they were scoped out at

the system level or are screened out at the component level by commodity group. Therefore,

detailed evaluation boundaries were not depicted for electrical scoping.

2.1.4.7.2 Staff Evaluation

The staff evaluated LRA sections 2.1.1.4.3 and 2.5 and the applicant's implementing

procedures and AMR reports, as documented in the audit report governing the electrical

scoping methodology. The applicant reviewed the electrical and I&C systems in accordance

with the requirements of 10 CFR 54.4 and determined which systems were to be included within

the scope of license renewal. The applicant used the Maintenance Rule Data Base, the UFSAR

and systems DBDs to determine whether systems met the requirements for inclusion pursuant

to 10 CFR 54.4(a)(1), (2) or (3). All electrical components contained in plant systems within the

scope of license renewal and non-plant electrical systems, including switchyard components

required to support SBO, were included within the scope of license renewal. In addition, the

applicant identified 20 fuse boxes as included within the scope of license renewal. The staff

reviewed selected portions of the data sources and selected several examples of components

including switchyard components required to support SBO and fuse boxes, for which the

applicant demonstrated the process used to determine whether electrical components were

within the scope of license renewal.

2.1.4.7.3 Conclusion

On the basis of its review of information contained in the LRA, the applicant's scoping

implementing procedures, and a sampling review of electrical scoping results, the staff

concludes that the applicant's methodology for identification of electrical components within the

scope of license renewal meets the scoping criteria pursuant to 10 CFR 54.4(a), and therefore

is acceptable.

2.1.4.8 Conclusion for Scoping Methodology

On the basis of its review of the LRA and the scoping implementing procedures, the staff

determines that the applicant's scoping methodology is consistent with the guidance contained

in the SRP-LR. The staff further determines that the applicant has identified those SSCs that

are safety-related, whose failure could affect safety-related functions, and are necessary to

2-24
demonstrate compliance with staff regulations for fire protection, EQ, ATWS, and SBO. The

staff concludes that the applicant's methodology is consistent with the requirements of

10 CFR 54.4(a) and therefore is acceptable.

2.1.5 Screening Methodology

2.1.5.1 General Screening Methodology

After determining the systems and structures within the scope of license renewal, the applicant

implemented a process for determining which SSCs were subject to an AMR, in accordance

10 CFR 54.21.

2.1.5.1.1 Summary of Technical Information in the Application

In LRA Section 2.1.2, "Screening Methodology," the applicant discussed the method of

identifying components from in-scope systems and structures that are subject to an AMR. The

screening process consisted of the following steps:

Identification of components, long-lived or passive, for each in-scope mechanical system,

structure and electrical commodity group

Identification of the license renewal intended function(s) for all mechanical and structural

component types and electrical commodity groups

Active components were screened out and therefore, did not require AMR. The screening

process also identified short lived components and consumables. The short lived components

are not subject to an AMR. Consumables are a special class of items that include packing,

gaskets, component seals, O-rings, oil, grease, component filters, system filters, fire

extinguishers, fire hoses, and air packs. Sealants for structures were the only consumables

within the scope of license renewal that require an AMR

2.1.5.1.2 Staff Evaluation

Pursuant to 10 CFR 54.21, the staff requires that each LRA contain an integrated plant

assessment (IPA) that identifies SCs within the scope of license renewal and subject to an

AMR. The IPA must identify components that perform an intended function without moving

parts or a change in configuration or properties (passive), as well as components that are not

subject to periodic replacement based on a qualified life or specified time period (long-lived).

The IPA includes a description and justification of the methodology used to determine the

passive and long-lived SCs, and a demonstration that the effects of aging on those SOs will be

adequately managed so that the intended function(s) will be maintained under all design

conditions imposed by the plant-specific CLB, for the period of extended operation.

The staff reviewed the methodology used by the applicant to determine whether mechanical

and structural component types, and electrical commodity groups within the scope of license

renewal should be subject to an AMR. The applicant implemented a process for determining

which SCs were subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

In LRA Section 2.1.2, the applicant discussed these screening activities as they related to

component types and commodity groups within the scope of license renewal.

2-25
The screening process evaluated these in-scope component types and commodity groups to

determine which ones were long-lived and passive and therefore, subject to an AMR. The staff

reviewed LRA Sections 2.3, 2.4, and 2.5, which documented the results of the process the

applicant used to identify component types and commodity groups subject to an AMR. The staff

also reviewed the screening results reports for the MS system and the TB.

The applicant provided the staff with a detailed discussion of the processes used for each

discipline and provided administrative documentation that described the screening

methodology. Specific methodology for mechanical, electrical, and structural is discussed

below.

2.1.5.1.3 Conclusion

On the basis of its review of the LRA, the screening implementing procedures and a sampling

of screening results, the staff concludes that the applicant's screening methodology is

consistent with the guidance contained in the SRP-LR and is capable of identifying passive,

long-lived components within the scope of license renewal and subject to an AMR. The staff

concludes that the applicant's process for determining which component types and commodity

groups are subject to an AMR is consistent with the requirements of 10 CFR 54.21 and

therefore, is acceptable.

2.1.5.2 Mechanical Component Screening

2.1.5.2.1 Summary of Technical Information in the Application

LRA Section 2.1.2.1, "Screening of Mechanical Systems," discusses the screening

methodology for identifying passive and long-lived mechanical components and their support

structures that are subject to an AMR. License renewal drawings were prepared to indicate

portions of systems that support system intended functions within the scope of license renewal

(with the exception of those systems in-scope for 10 CFR 54.4(a)(2) for physical interactions, as

discussed below).

2.1.5.2.2 Staff Evaluation

The staff evaluated the mechanical screening methodology in LRA 2.1.2.1, the license renewal

project documents, license renewal project guidelines, and the AMR reports. The mechanical

system screening process began with the results from the scoping process. The applicant

reviewed each system evaluation boundary, as illustrated on P&IDs, to identify passive and

long-lived components. Within the system evaluation boundaries, all passive, long-lived

components that perform or support an intended function are subject to an AMR. To streamline

the AMR process, the applicant grouped components into component types. The component

types were then reviewed against the list contained in NEI 95-10, Appendix B. The results of

the review are documented in the AMR reports. The AMR reports contain system intended

functions, system evaluation boundaries, component materials and environments, component

intended functions, and AMR results.

The staff reviewed the results of the boundary evaluations and further discussed the process

with the applicant. The staff confirmed that mechanical system evaluation boundaries were

established for each system within the scope of license renewal. These boundaries were

determined by mapping the pressure boundary associated with system-level license renewal

2-26
intended functions onto the P&IDs. A preparer and an independent reviewer performed a

comprehensive evaluation of the boundary drawings to ensure the completeness and accuracy

of the review results.

Additionally, the staff reviewed the screening activities associated with the MS system. The staff

reviewed the system intended functions and associated source documents identified for the

system, the MS flow diagrams, and the associated results documented in the AMR report. The

staff did not identify any discrepancies with the evaluation, and determined that the applicant

has adequately followed the process documented in the license renewal project documents,

and adequately documented the results in the AMR reports.

2.1.5.2.3 Conclusion

Based on its review of the LRA, the screening implementing procedures, and a sample of MS

system screening results, the staff concludes that the applicant's mechanical component

screening methodology is consistent with SRP-LR guidance. The staff further concludes that

the applicant's methodology for identifying passive, long lived mechanical components within

the scope of license renewal and subject to an AMR meets the requirements of

10 CFR 54.21(a)(1) and therefore, is acceptable.

2.1.5.3 Structural Component Screening

2.1.5.3.1 Summary of Technical Information in the Application

LRA Section 2.1.2.2, "Screening of Structures," states that for each structure within the scope

of license renewal, the screening process identified those structural components that were

subject to an AMR. LRA Section 2.4, "Scoping and Screening Results: Structures," presents

the results for structures. The screening process for structural components involved a review of

design documents (UFSAR, drawings) to identify the specific structural components that make

up the structure. Structural components typically do not have unique identifiers similar to those

provided for mechanical components. Therefore, grouping structural components and

commodities were first based on materials of construction and then subdivided based on

component design and function which provided a means of categorizing them for an AMR.

Commodity groups were based on materials of construction, such as steel, concrete,

elastomers, or earthen. Once the structural commodity groups were identified within an inscope structure or building, the commodity groups were subdivided into discrete structural

component types based on design, such as walls, floors, fire doors, and equipment supports.

Structures contain inherently passive, long-lived structural components and therefore the

structural components within the scope of license renewal that perform an intended function

were identified as subject to an AMR.

2.1.5.3.2 Staff Evaluation

The staff reviewed the applicant's methodology for identifying structural components that are

subject to an AMR as required in 10 CFR 54.21(a)(1). As part of this review, the staff discussed

the methodology with the applicant, reviewed the documentation developed to support the

activity, and evaluated the screening results for several structures that were identified as within

the scope of license renewal.

2-27
The applicant's AMR reports, as described in the audit report, provided detailed implementation

guidance on the applicant's process for identifying and screening structural components that

are subject to an AMR. The report stated that all structural components that perform an

intended function and are passive and long-lived are subject to an AMR. In addition, the

applicant described the screening results for each system in separate AMR reports for each

system.

The staff reviewed the applicant's methodology used for structural screening described in

LRA sections noted above, and in the applicants implementing guidance and AMR reports. The

applicant performed the screening review in accordance with the implementation guidance and

captured pertinent structure design information, component, materials, environments, and aging

effects. The staff confirmed that the applicant used the lists of passive SCs embodied in the

regulatory guidance as an initial starting point and supplemented that list with additional items

unique to the site or for which a direct match to the generic lists did not exist (i.e., material

and/or environment combinations). The boundary for a structure was the entire building

including base slabs, foundations, walls, beams, slabs, and steel superstructure. The applicant

provided the staff with a detailed discussion that described the screening methodology, as well

as the screening reports for a selected group of structures.

The staff conducted detailed discussions with the applicant's license renewal team and

reviewed documentation pertinent to the screening process. The staff assessed whether the

screening methodology outlined in the LRA and procedures was appropriately implemented and

whether the scoping results were consistent with CLB requirements. The staff also reviewed

structural screening results for SCs contained in the ES SW pump-house and the TB to verify

proper implementation of the screening process. Based on these audit activities, the staff did

not identify any discrepancies between the methodology documented and the implementation

results.

2.1.5.3.3 Conclusion

On the basis of its review of information contained in the LRA, the applicant's detailed

screening implementing procedures, and a sampling review of structural screening results, the

staff concludes that the applicant's methodology for identification of structural components

subject to an AMR met the requirements of 10 CFR 54.21(a)(1) and therefore, is acceptable.

2.1.5.4 Electrical Component Screening

2.1.5.4.1 Summary of Technical Information in the Application

In the LRA section 2.1.2.3, "Screening of Electrical and Instrumentation and Control Systems,"

the applicant discussed the screening of electrical and instrumentation and control system

components. For each electrical system within the scope of license renewal, the screening

process identified those electrical components and commodities that are subject to an AMR.

Electrical components in mechanical systems were included in the scope of license renewal

and were addressed under the electrical screening process.

The process of electrical screening differed from the mechanical and structural processes

because the electrical components were addressed completely within their respective

commodity groups. Each electrical component within the scope of license renewal is assigned

to an electrical component commodity group for the screening evaluation. The screening of

2-28
electrical components for license renewal was performed utilizing a commodity group basis. An

electrical commodity group is a group of electrical components grouped by type of equipment

and/or function. The listing of electrical component commodity groups included in Appendix B to

NEI 95-10 is used as the starting point for establishing commodity groups. Review of SSES

documents (FSAR, single-line drawings, and electrical layout drawings) was used to validate

the listing as complete.

For the electrical equipment within the scope of license renewal, the passive, long-lived

components that perform or support an intended function are subject to an AMR. NEI 95-10,

Appendix B, identifies the electrical commodities considered to be passive and potentially

requiring an AMR. For SSES, electrical commodity groups were identified and cross-referenced

to the appropriate NEI 95-10 commodity, which identifies the passive commodity groups.

Electrical commodities determined to be active were not subject to an AMR. Electrical

commodities that are not subject to replacement based on a qualified life or specified time

period were considered long-lived. Components that are subject to replacement are addressed

in replacement programs, such as the Environmental Qualification Program, or other controlled

programs that establish a specific service life, qualified life, or replacement frequency.

Components that are not long-lived are not subject to an AMR.

2.1.5.4.2 Staff Evaluation

The staff reviewed the applicant's methodology used for electrical screening in LRA

Section 2.1.2.3 and the applicant's implementation procedures and AMR reports. Based on a

review of the LRA, applicant's implementing procedures and screening reports, the staff

determined that the applicant used the screening process described in these documents to

identify the electrical commodity groups subject to AMR and that the applicant used the

component database, the stations single-line drawings, and cable procurement specifications

as data sources to identify the electrical and I&C components, including fuses-holders. The

applicant determined there were 20 fuse-holders located outside of active devices and subject

to an AMR.

The staff determined that the applicant assembled a table of four commodities which were

determined to meet the passive criteria which were grouped in accordance with NEI 95-10 as

(a) non-insulated cables and connections, (b) non-insulated metal enclosed (phase) bus, (c)

high-voltage insulators, and (d) transmission conductors and connections. Based on the review

of the applicant's screening reports, the staff determined that the applicant evaluated the

identified, passive commodities to determine whether they were subject to replacement based

on a qualified life or specified time period (short-lived), or not subject to replacement based on

a qualified life or specified time period (long-lived). The remaining passive, long lived

components were determined to be subject to an AMR. The staff reviewed the applicant's

screening of selected components including switchyard components required to support SBO

and fuse boxes, to verify the correct implementation of the methodology.

2.1.5.4.3 Conclusion

The staff reviewed the LRA, procedures, electrical drawings, and a sample of the results of the

screening methodology and concludes that the applicant's methodology is consistent with the

description provided in LRA and the applicant's implementing procedures. On the basis of its

review of information contained in the LRA, the applicant's screening implementing procedures,

and a sampling review of electrical screening results, the staff further concludes that the

2-29
applicant's methodology for identification of electrical commodity groups subject to an AMR is

consistent with the requirements of 10 CFR 54.21(a)(1) and therefore, is acceptable.

2.1.5.5 Conclusion for Screening Methodology

On the basis of its review of the LRA, the screening implementing procedures, discussions with

the applicant's staff, and a sample review of screening results, the staff determines that the

applicant's screening methodology is consistent with the guidance contained in the SRP-LR and

that the applicant has identified those passive, long-lived components within the scope of

license renewal that are subject to an AMR. The staff concludes that the applicant's

methodology is consistent with the requirements of 10 CFR 54.21 (a)(1 ) and therefore, is

acceptable.

2.1.6 Summary of Evaluation Findings

The staff review of the information presented in LRA Section 2.1, the supporting information in

the scoping and screening implementing procedures and reports, the information presented

during the scoping and screening methodology audit, and the applicant's responses to the

staff's RAIs dated March 9, 2007, formed the basis of the staff's determination. The staff

confirmed that the applicant's scoping and screening methodology is consistent with the

requirements of the Rule. From this review, the staff concludes 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) and therefore,

is acceptable.

2.2 Plant-Level Scoping Results

2.2.1 Staff Evaluation

In LRA Section 2.1, the applicant described its methodology for identifying systems and

structures within the scope of license renewal and subject to an AMR. The staff verified that the

applicant properly implemented its methodology, the staff's review focused on the

implementation results shown in LRA Tables 2.2-1, 2.2-2, and 2.2-3, to confirm that there were

no omissions of plant-level systems and structures within the scope of license renewal.

The staff determined whether the applicant properly identified the systems and structures within

the scope of license renewal in accordance with 10 CFR 54.4. The staff reviewed selected

systems and structures that the applicant did not identify as within the scope of license renewal

to verify whether the systems and structures have any intended functions requiring their

inclusion within the scope of license renewal. The staff's review of the applicant's

implementation was conducted in accordance with the guidance in SRP-LR Section 2.2, "PlantLevel Scoping Results."

The staff's review of LRA Section 2.2 identified areas where additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staff's RAIs as discussed below.

In RAI 2.2-1, dated August 27, 2007, the staff noted that LRA Table 2.2-1 defines the

electro-hydraulic control and logic system and the electro-hydraulic control hydraulic power

2-30
system as not within the scope of license renewal. Electro-hydraulic control systems assist to

provide holdup and plate-out of fission products that may leak through the closed main steam

isolation valves (MSIVs). This is a function performed by components located in the main

condenser and MSIV leakage pathway. In doing so, they fulfill intended functions pursuant to

10 CFR 54.4(a)(2). The staff requested that the applicant provide additional information to

justify exclusion of the electro-hydraulic control and logic system and the electro-hydraulic

control hydraulic power system from the scope of license renewal.

In its response to RAI 2.2-1, dated October 18, 2007, the applicant stated:

The Electro-Hydraulic Control and Logic System, and the Electro-Hydraulic

Control Hydraulic Power System are not within the scope of license renewal and

are not subject to Aging Management Review (AMR). Control of fission products

that may leak through a closed MSIV is provided by directing the leakage to the

condenser prior to release to atmosphere. This function is performed by the Main

Steam System, as discussed in LRA Section 2.3.4.6. The Susquehanna FSAR,

Section 6.7 states: "The MSIV leakage Isolated Condenser Treatment Method

(ICTM) controls and minimizes the release of fission products which could leak

through the closed main steam isolation valves (MSIVs) after a LOCA. The

treatment method provides this control by processing MSIV leakage prior to

release to the atmosphere. This is accomplished by directing the leakage

through the main steam drain line to the condenser." The primary path for the

ICTM method as used at Susquehanna depends on the drain line pathway to the

condenser. The primary path is in-scope and subject to AMR and is depicted on

LR-M-141/2141-1 and LR-M-205/2105-1. The secondary path depends on the

Main Steam line drip legs, is in-scope and subject to AMR, and is depicted on

LR-M-101/2101-1. The ICTM does not depend on either the Electro-Hydraulic

Control and Logic System, or the Electro-Hydraulic Control Hydraulic Power

System to maintain any valves open to provide the pathway from the MSIVs to

the condenser for either the primary or the secondary paths.

Per FSAR Section 6.7.2.1.1, the primary pathway to the condenser is the main

steam drain line through the HV-1(2)41F020 and HV-1(2)41 F021 motor-operated

valves. The HV-1(2)41F020 valve is normally open and will not need to be

operated. The HV-1(2)41 F021 valve is normally closed and will need to be

opened by an operator by means of a hand switch in the control room. There are

three normally open motor-operated valves that will need to be closed by an

operator to prevent leakage to other areas of the TB. These boundary valves are

HV-1(2)0107 to steam jet air ejector, HV-1 (2)0109 to steam seal evaporator, and

HV-1(2)0111, to reactor feed pump turbines. The hand switches for these valves

are in the control room.

Per FSAR Section 6.7.2.1.2, alternate orificed pathways (which do not require

the opening of any valves) exist as a backup to direct MSIV leakage to the

condenser should the HV-1(2)41 F021 valve not open as expected. These

pathways include: the orificed bypass line around the HV-1 (2)041 F021 valve; the

four orificed drain lines from the main steam line eight inch drip legs; and the one

orificed drain line from the main steam line twelve inch drip leg.

2-31
The Electro-Hydraulic Control and Logic System and the Electro-Hydraulic

Control Hydraulic Power System do not perform any safety-related functions and

therefore do not meet the criteria of 10 CFR 54.4(a)(1).

The Electro-Hydraulic Control and Logic System and the Electro-Hydraulic

Control Hydraulic Power System do not have the potential to adversely affect

safety-related systems or components through spatial interaction and therefore

do not meet the criteria of 10 CFR 54.4(a)(2). As stated in LRA Section 2.1.1.2.2,

there are no components located in the TB that either perform or would prevent

a safety-related function from occurring.

The Electro-Hydraulic Control and Logic System and the Electro-Hydraulic

Control Hydraulic Power System are not relied upon to demonstrate compliance

with, nor satisfy the 10 CFR 54.4(a)(3) scoping criteria for, any regulated event.

Based on its review, the staff finds the applicant's response to RAI 2.2-1 acceptable because

the applicant clarified why the electro-hydraulic control and logic system and the electrohydraulic control hydraulic power system are not within the scope of license renewal. Therefore,

the staff's concern described in RAI 2.2-1 is resolved.

In RAI 2.2-2, dated August 27, 2007, the staff noted that LRA Table 2.2-1 defines the

circulating water system (CWS) as not within the scope of license renewal. Applicants with

similar plant designs have included the CWS within the scope of license renewal in accordance

with 10 CFR 54.4(a)(2). The staff requested that the applicant provide additional information to

justify exclusion of the CWS from scope with respect to the applicable requirements pursuant to

10 CFR 54.4(a).

In its response to RAI 2.2-2, dated October 18, 2007, the applicant stated:

As described in Section 10.4.5 of the FSAR, the Circulating Water System for

SSES has no safety-related functions and is designed to remove the latent heat

from the main condenser and sensible heat from the Service Water System and

dissipate both in a hyperbolic natural draft cooling tower. Failure of the

Circulating Water System will not prevent the satisfactory accomplishment of any

safety-related functions and therefore, does not meet the criteria of

10 CFR 54.4(a)(1).

In addition, failure of the Circulating Water System will not adversely affect any

safety-related systems or components through spatial interaction and system

piping is not connected to any safety-related piping. There is no potential for

spatial interaction of the Circulating Water System with safety-related

components, because circulating water piping is not routed in structures or

outdoor areas that contain safety-related components. Portions of the Circulating

Water System are routed in the Turbine Building. However, as described in

Section 2.1.1.2.2 of the LRA (pg. 2.1-6) there are no components located in the

Turbine Building that either perform or would prevent a safety-related function

from occurring. Therefore, the Circulating Water System does not meet the

criteria of 10 CFR 54.4(a)(2).

2-32
As evaluated in FSAR Section 10.4.1.3.3, flooding due to the rupture of a

circulating water expansion joint in the Turbine Building will not affect any safetyrelated equipment. The Circulating Water System is not relied upon to

demonstrate compliance with any regulated event and, therefore, does not meet

the criteria of 10 CFR 54.4(a)(3).

In a telephone conference call, "Summary of Telephone Conference Call Held

December 28, 2007, between the U.S. Nuclear Regulatory Commission and PPL

Susquehanna, LLC, Concerning Requests for Additional Information Pertaining to the

Susquehanna Steam Electric Station, Unit 1 and 2, License Renewal Application," (see

Appendix B) the staff noted that UFSAR Section 10.4.5 identifies the cooling towers and its

piping as part of the CWS. The UFSAR identifies the cooling towers and the piping from the

cooling towers as a secondary source of fire protection water, making this portion of the CWS

within the scope of license renewal, based on criterion pursuant to 10 CFR 54.4(a)(3).

Furthermore, boundary drawings LR-M-1 15, "Unit 1 License Renewal Boundary Drawings

Circulating Water," and LR-M-2115, "Unit 2 License Renewal Boundary Drawing Circulating

Water," identify the cooling tower basins and a portion of the pipes from the cooling tower

basins as within the scope of license renewal, based on criterion in accordance with

10 CFR 54.4(a)(3).

The applicant replied as follows:

The 108-inch piping exiting the Unit 1 cooling tower basin and the 78-inch line

exiting the Unit 2 cooling tower basin provide water to both the circulating water

system and the service water system. Therefore, this piping is functionally part of

two systems. Within the SSES maintenance program this piping is considered

part of the cooling tower system. The LRA system designation is based on the

"functional" purpose of the cooling tower basins and piping rather than the FSAR

description.

Based on its review, the staff finds the applicant's response to RAI 2.2-2 acceptable because

the applicant has clarified that the LRA system designation is based on the functional purpose

of the cooling tower basins and piping rather than the UFSAR system designation and that

within the SSES maintenance program, this piping is considered part of the cooling tower

system, which is within the scope of license renewal. Therefore, the staff's concern described in

RAI 2.2-2 is resolved.

In RAI 2.2-1, dated July 25, 2007, the staff requested that the applicant provide justification for

the exclusion of the miscellaneous HVAC systems (Chlorination Building HVAC, Circulating

Water Pump Room HVAC, Intake Works HVAC, Service and Administration Building HVAC,

Service Water Pump Room HVAC, Turbine Building HVAC, and Water Treatment Room

HVAC) and their applicable components and passive functions from the scope of license

renewal. If these systems and their applicable components are within the scope of license

renewal, in accordance with 10 CFR 54.4(a), and subject to an AMR pursuant to

10 CFR 54.21(a)(1), update the LRA by providing the applicable information in the appropriate

LRA sections, tables, and boundary drawings.

2-33
In its response to RAI 2.2-1, dated August 23, 2007, the applicant stated:

Chlorination Building HVAC - The Chlorination Building is part of the structure

that is identified in the LRA as the Chlorination and Acid Storage Building. As

stated in LRA Table 2.2-3, the Chlorination and Acid Storage Building is not

within the scope of license renewal. There are no safety-related components

located in the building. Therefore, the HVAC components located in the building

are not in-scope based upon the criteria of 10 CFR 54.4(a)(1) and

10 CFR 54.4(a)(2). In addition, no components located in the building support

any regulated events for a BWR. Therefore, the HVAC components are also not

in-scope based on the criterion of 10 CFR 54.4(a)(3). The Chlorination Building

HVAC System does not provide a supporting function applicable to equipment

within the scope of license renewal, therefore it is not within the scope of license

renewal.

Circulating Water Pump Room HVAC - The Circulating Water Pump Room is

part of the structure identified in the LRA as the Circulating Water Pumphouse

and Water Treatment Building. As stated in LRA Table 2.2-3, the Circulating

Water Pumphouse and Water Treatment Building is within the scope of license

renewal. LRA Section 2.4.4 states that the building is relied upon to demonstrate

compliance with the regulation 10 CFR 50.48 for Fire Protection by providing

physical support and protection to the fire water pumps. There are no safetyrelated components located in the Circulating Water Pumphouse and Water

Treatment Building, which contains the Circulating Water Pump Room.

Therefore, the HVAC components located in the Circulating Water Pump Room

are not in-scope based upon the criteria of 10 CFR 54.4(a)(1) and

10 CFR 54.4(a)(2). While there is fire protection equipment located in Circulating

Water Pumphouse and Water Treatment Building that is in-scope, based on

criterion of 10 CFR 54.4(a)(3), this equipment does not require support from the

Circulating Water Pump Room HVAC. Therefore, the HVAC components located

in Circulating Water Pump Room are not in-scope based upon the criterion of

10 CFR 54.4(a)(3). The Circulating Water Pump Room HVAC System does not

provide a supporting function for any equipment within the scope of license

renewal, therefore, it is not within the scope of license renewal.

Intake Works HVAC - The Intake Works is part of the structure identified in the

LRA as the River Intake Structure. As stated in LRA Table 2.2-3, the River Intake

Structure is not within the scope of license renewal. There are no safety-related

components located in the structure. Therefore, the HVAC components located

in the structure are not in-scope based upon the criteria of 10 CFR 54.4(a)(1)

and 10 CFR 54.4(a)(2). In addition, no components located in the structure

support any regulated events for a BWR. Therefore, the HVAC components are

also not in-scope based on the criterion of 10 CFR 54.4(a)(3). The Intake Works

HVAC System does not provide a supporting function applicable to equipment

within the scope of license renewal, therefore, it is not within the scope of license

renewal.

Service and Administration Building HVAC - As stated in LRA Table 2.2-3, the

Service and Administration Building is not within the scope of license renewal.

There are no safety-related components located in the Service and

2-34
Administration Building. Therefore, the HVAC components located in the Service

and Administration Building are not in-scope based upon the criteria of

10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2). In addition, no components located in

the Service and Administration Building support any regulated events for a BWR.

Therefore, the HVAC components are also not in-scope based on the criterion of

10 CFR 54.4(a)(3). The Service and Administration Building HVAC System does

not provide a supporting function applicable to equipment within the scope of

license renewal, therefore it is not within the scope of license renewal.

Service Water Pump Room HVAC - The Service Water Pump Room is part of

the structure identified in the LRA as the Circulating Water Pumphouse and

Water Treatment Building. As stated in LRA Table 2.2-3, the Circulating Water

Pumphouse and Water Treatment Building is within the scope of license

renewal. LRA Section 2.4.4 states that the building is relied upon to demonstrate

compliance with the regulation 10 CFR 50.48 for Fire Protection by providing

physical support and protection to the fire water pumps. There are no safetyrelated components located in the Circulating Water Pumphouse and Water

Treatment Building, which contains the Service Water Pump Room. Therefore,

the HVAC components located in the Service Water Pump Room are not inscope based upon the criteria of 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2).

While there is fire protection equipment located in Circulating Water Pumphouse

and Water Treatment Building that is in-scope based on criterion of

10 CFR 54.4(a)(3), this equipment does not require support from the Service

Water Pump Room HVAC. Therefore, the HVAC components located in the

Service Water Pump Room are not in-scope based upon the criterion of

10 CFR 54.4(a)(3). The Service Water Pump Room HVAC System does not

provide a supporting function applicable to equipment within the scope of license

renewal, therefore it is not within the scope of license renewal.

Turbine Building HVAC - As stated in LRA Table 2.2-3, the Turbine Building is

within the scope of license renewal. LRA Section 2.4.8 provides the reasons for

the building being in-scope. There are no safety-related components located in

the Turbine Building. Therefore, the HVAC components located in the Turbine

Building are not in-scope based upon the criterion of 10 CFR 54.4(a)(1). While

there is equipment in the Turbine Building that is in-scope based on the criteria

of 10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3), this equipment does not require

support from the Turbine Building HVAC. Therefore, the HVAC components

located in the Turbine Building are not in-scope based upon the criteria of

10 CFR 54.4(a)(2) and 10 CFR 54.4(a)(3). The Turbine Building HVAC System

does not provide a supporting function for the equipment within the scope of

license renewal, therefore it is not within the scope of license renewal.

Water Treatment Room HVAC - The Water Treatment Room is part of the

structure identified in the LRA as the Circulating Water Pumphouse and Water

Treatment Building. As stated in LRA Table 2.2-3, the Circulating Water

Pumphouse and Water Treatment Building is within the scope of license

renewal. LRA Section 2.4.4 states that the building is relied upon to demonstrate

compliance with the regulation 10 CFR 50.48 for Fire Protection by providing

physical support and protection to the fire water pumps. There are no safetyrelated components located in the Circulating Water Pumphouse and Water

2-35
Treatment Building, which contains the Water Treatment Room. Therefore, the

HVAC components located in the Water Treatment Room are not in-scope

based upon the criteria of 10 CFR 54.4(a)(1) and 10 CFR 54.4(a)(2). While there

is fire protection equipment located in the Circulating Water Pumphouse and

Water Treatment Building that is in-scope based on criterion of

10 CFR 54.4(a)(3), this equipment does not require support from the Water

Treatment Room HVAC. Therefore, the HVAC components are also not in-scope

based on the criterion of 10 CFR 54.4(a)(3). The Water Treatment Room HVAC

System does not provide a supporting function applicable to equipment within

the scope of license renewal, therefore it is not within the scope of license

renewal.

Based on its review, the staff finds the applicant's response to staffs RAI 2.2-1 acceptable

because the applicant clarified why the miscellaneous HVAC systems (Chlorination Building

HVAC, Circulating Water Pump Room HVAC, Intake Works HVAC, Service and Administration

Building HVAC, Service Water Pump Room HVAC, Turbine Building HVAC, and Water

Treatment Room HVAC systems) are not within the scope of license renewal. Therefore, the

staff's concern described in RAI 2.2-1 is resolved.

2.2.2 Conclusion

The staff reviewed LRA Section 2.2, the RAI responses, and the UFSAR supporting information

to determine whether the applicant failed to identify any systems and structures within the

scope of license renewal. On the basis of its review, the staff concludes that the applicant has

appropriatelyidentified the systems and structures within the scope of license renewal in

accordance with 10 CFR 54.4 and therefore, is acceptable.

2.3 Scoping and Screening Results: Mechanical Systems

This section documents the staff's review of the applicant's scoping and screening results for

mechanical systems. Specifically, this section discusses:

" Reactor vessel (RV), RV internals, and reactor coolant system (RCS)

" Engineered safety features (ESF)

" Auxiliary systems

* Steam and power conversion systems

The staff evaluation of the mechanical system scoping and screening results applies to all

mechanical systems reviewed. Those systems that required RAIs to be generated (if any)

include an additional staff evaluation which specifically addresses the applicant's response to

the RAI(s).

In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant must list passive,

long-lived SCs within the scope of license renewal and subject to an AMR. To verify that the

applicant properly implemented its methodology, the staff's review focused on the

implementation results. This focus allowed the staff to confirm that the applicant has identified

the mechanical system structures and components that meet the scoping criteria and are

subject to an AMR, and to confirm that there were no omissions.

2-36
The staff's evaluation was performed using the evaluation methodology described here, in SER

Section 2.3 and the guidance in SRP-LR Section 2.3, and took into account (where applicable)

the system function(s) described in the UFSAR. The objective was to determine whether the

applicant identified, in accordance with 10 CFR 54.4, components and supporting structures for

mechanical systems that meet the license renewal scoping criteria. Similarly, the staff evaluated

the applicant's screening results to verify that all passive, long-lived components were subject

to an AMR in accordance with 10 CFR 54.21 (a)(1).

In the scoping evaluation, the staff reviewed the LRA, UFSAR, license renewal boundary

drawings, and other licensing basis documents, as appropriate, for each mechanical system

within the scope of license renewal. The staff reviewed the licensing basis documents to

confirm that the LRA specified all intended functions pursuant to 10 CFR 54.4(a). The review

then focused on identifying components with intended functions in accordance with

10 CFR 54.4(a) that had not been identified as within the scope of license renewal.

After reviewing the scoping results, the staff evaluated the applicant's screening results. For

those SCs with intended functions delineated under 10 CFR 54.4(a), the staff verified the

applicant properly screened out only: (1) SCs that have functions performed with moving parts

or a change in configuration or properties or (2) SCs that are subject to replacement after a

qualified life or specified time period, as described in 10 CFR 54.21(a)(1). For SCs not meeting

either of these criteria, the staff confirmed the remaining SCs received an AMR, as required by

10 CFR 54.21 (a)(1). The staff requested additional information to resolve any omissions or

discrepancies identified.

The staff performed an alternate review of selected systems contained in Section 2.3.3,

Auxiliary Systems, and Section 2.3.4, Steam and Power Conversion Systems. The systems

selected for an alternate review were determined to have the following characteristics:

* Low safety or low risk significance

* Little operating experience indicating likely passive failures

* No previous LRA experience indicating a need to perform a detailed review

For the systems selected for alternate review, the staff evaluated the system's function(s)

described in the LRA and UFSAR to verify that the applicant included in the scope of license

renewal all component types identified by 10 CFR 54.4(a). The staff reviewed the LRA and

UFSAR to confirm that the applicant has identified the component types that are typically found

within the scope of license renewal. The staff also verified that the applicant has identified the

component types subject to an AMR in accordance with the requirements stated in 10 CFR

54.21 (a)(1).

Those systems that received an alternate review are as follows:

• 2.3.3.10 Domestic Water System

• 2.3.3.16 Nitrogen and Hydrogen System

" 2.3.3.20 Radwaste Solids Handling System

• 2.3.3.21 Raw Water Treatment System

" 2.3.3.29 Sanitary Drainage System

" 2.3.4.1 Auxiliary Boiler System

" 2.3.4.2 Bypass Steam System

2-37
* 2.3.4.8 Makeup Demineralizer System

* 2.3.4.9 Makeup Transfer and Storage System

* 2.3.4.11 Refueling Water Transfer and Storage System

2.3.1 Reactor Vessel, Reactor Vessel Internals, and Reactor Coolant System

In LRA Section 2.3.1, the applicant identified the RV, RV internals, and RCS SCs subject to an

AMR for license renewal. The applicant described the supporting SCs of the RV, RV internals,

and RCS in the following LRA sections:

" 2.3.1.1 Reactor pressure vessel

" 2.3.1.2 Reactor vessel internals

" 2.3.1.3 Reactor coolant system pressure boundary

2.3.1.1 Reactor Pressure Vessel

2.3.1.1.1 Summary of Technical Information in the Application

LRA Section 2.3.1.1 describes the reactor pressure vessel (RPV), which provides a high

integrity barrier against the leakage of radioactive materials, contains and supports the reactor

core, RV internals, and coolant moderator, and provides a floodable volume in which the core

can be adequately cooled in the event of a break in a line external to the vessel. The RPV

contains safety-related components relied upon to remain functional during and following DBEs.

LRA Table 2.3.1-1 identifies RPV component types within the scope of license renewal and

subject to an AMR.

2.3.1.1.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the RPV system mechanical components within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

system components subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2.3.1.2 Reactor Vessel Internals

2.3.1.2.1 Summary of Technical Information in the Application

LRA Section 2.3.1.2 describes the RV internals, which provide a high integrity barrier against

the leakage of radioactive materials, support the reactor core and RV internals, provide a

floodable volume in which the core can be adequately cooled in the event of a break in a line

external to the vessel, and distribute flow as designed to promote mixing. The RV internals

contain safety-related components relied upon to remain functional during and following DBEs.

The failure of nonsafety-related SSCs in the RV internals potentially could prevent the

satisfactory accomplishment of a safety-related function. In addition, the RV internals performs

functions that support ATWS. LRA Table 2.3.1-2 identifies RV internals component types within

the scope of license renewal and subject to an AMR.

2-38
2.3.1.2.2 Staff Evaluation:

The staff reviewed LRA Section 2.3.1.2 and UFSAR Section 3.9.5 using the evaluation

methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3. The

staff's review identified areas requiring additional information to complete the review of the

applicant's scoping and screening results. The applicant responded to the staff's RAIs as

discussed below.

In RAI 2.3.1-1, dated October 24, 2007, the staff noted in LRA Table 2.3.1-1, the nozzle N9 and

cap for N9 were listed as in-scope as a pressure boundary. The staff identified boundary

drawing LR-M-141-2 as showing nozzle N9 as out of scope. The staff requested that the

applicant confirm that N9 nozzle and cap were in-scope.

In its response to RAI 2.3.1-1, dated November 14, 2007, the applicant stated:

The highlighting of nozzle N9 and the cap for N9 on boundary drawing LR-M141-2 was inadvertently omitted. As listed in LRA Table 2.3.1-1, nozzle N9 and

the associated cap are within the scope of license renewal and subject to an

AMR. The highlighting on LR-M-141-2 has been corrected to highlight nozzle N9

from the vessel wall to and including the associated cap. The highlighting of the

Unit 2 N9 nozzle on LR-M-2141-2 has also been clarified to clearly show

highlighting from the vessel wall to and including the cap. These were

highlighting omissions on the boundary drawings and no changes to the LRA are

required.

The staff confirms that the applicant has submitted revised boundary drawings

LR-M-141-2 and LR-M-2141-2. Based on its review, the staff finds the

applicant's response to RAI 2.3.1-1 acceptable because the applicant has

clarified that the highlighting for nozzle N9 and the cap for N9 were inadvertently

omitted and appropriate revisions were made to boundary drawings LR-M-141-2

and LR-M-2141-2. Therefore, the staff's concern described in RAI 2.3.1-1 is

resolved.

In RAI 2.3.1-2, dated October 24, 2007, the staff noted boundary drawing LR-M-146 depicted

valve 146-F004, and associate piping for a drive water pressure control station as out of scope.

However, isolation valves between the out of scope and in-scope piping were not shown. The

staff believes that this bypass line and valve should be within the scope of license renewal as a

pressure boundary. The staff requested the applicant clarify whether the subject components

were in-scope, thus, requiring an AMR and; if excluded, provide a justification.

In its response to RAI 2.3.1-2, dated November 14, 2007, the applicant stated:

The highlighting of valve 146-F004 and the associated piping on boundary

drawing LR-M-146-1 was inadvertently omitted. Valve 146-F004 and the

associated piping are within the scope of license renewal and subject to aging

management review. These components meet the scoping criteria for

10 CFR 54.4(a)(2) and are included in LRA Section 2.3.3.3, Table 2.3.3-3 and

Table 3.3.2-3. The Unit 2 boundary drawing, LR-M-2146-1 shows the correct

highlighting. This was a highlighting error and no changes to the LRA are

required.

2-39
The staff confirmed that the applicant has submitted revised boundary drawing LR-M-146-1.

Based on its review, the staff finds the applicant's response to RAI 2.3.1-2 acceptable because

the applicant clarified that valve 146-F004 and associated piping are within the scope of license

renewal and the highlighting was inadvertently omitted. The staff confirms that the applicant has

made appropriate revisions to boundary drawings LR-M-141-2 and LR-M-2141-2. Therefore,

the staff's concern described in RAI 2.3.1-1 is resolved.

2.3.1.2.3 Conclusion

The staff reviewed the LRA, UFSAR, boundary drawings (original and revised), and

RAI responses to determine whether the applicant failed to identify any components within the

scope of license renewal. In addition, the staff's review determined whether the applicant failed

to identify any components subject to an AMR. On the basis of its review, the staff concludes

that the applicant has appropriately identified the RV internals mechanical components within

the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has

adequately identified the RV internals components subject to an AMR, in accordance with the

requirements of 10 CFR 54.21(a)(1) and therefore, the response is acceptable.

2.3.1.3 Reactor Coolant System Pressure Boundary

2.3.1.3.1 Summary of Technical Information in the Application

LRA Section 2.3.1.3 describes the RCS pressure boundary, which includes the ASME Code

Class 1 portions of these systems:

* Control Rod Drive Hydraulic System (Class 1 portions only)

* Core Spray System (Class 1 portions only)

" Feedwater System (Class 1 portions only)

* High-Pressure Coolant Injection System (Class 1 portions only)

* Main Steam System (Class 1 portions only)

* Reactor Core Isolation Cooling System (Class 1 portions only)

• Reactor Nonnuclear Instrumentation System (Class 1 portions only)

• Reactor Recirculation System

* Reactor Vessel and Auxiliaries (vent line and flange leak detection line only)

• Residual Heat Removal System (Class 1 portions only)

• Reactor Water Cleanup System (Class 1 portions only)

• Standby Liquid Control System (Class 1 portions only)

• In-scope portions of the reactor recirculation system are included for purposes of license

renewal evaluation.

The RCS pressure boundary contains safety-related components relied upon to remain

functional during and following DBEs. The failure of nonsafety-related SSCs in the RCS

pressure boundary potentially could prevent the satisfactory accomplishment of a safety-related

2-40
function. In addition, the RCS pressure boundary performs functions that support fire protection,

ATWS, SBO, and EQ. LRA Table 2.3.1-3 identifies RCS pressure boundary component types

within the scope of license renewal and subject to an AMR.

2.3.1.3.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the RCS system mechanical components within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

system components subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2.3.2 Engineered Safety Features

In LRA Section 2.3.2, the applicant identified the ESFs SCs subject to an AMR for license

renewal. The applicant described the supporting SCs of the ESF in the following LRA sections:

* 2.3.2.1 Residual heat removal (RHR) system

* 2.3.2.2 Reactor core isolation cooling (RCIC) system

* 2.3.2.3 Core spray system (CSS)

* 2.3.2.4 High-pressure coolant injection (HPCI) system

* 2.3.2.5 Containment and suppression system

* 2.3.2.6 Containment atmosphere control system

* 2.3.2.7 Standby gas treatment system (SGTS)

2.3.2.1 Residual Heat Removal System

2.3.2.1.1 Summary of Technical Information in the Application

LRA Section 2.3.2.1 describes the RHR system, which is comprised of two independent loops,

each with two motor-driven pumps, a heat exchanger, piping, valves, instrumentation, and

controls. The RHR system contains safety-related components relied upon to remain functional

during and following DBEs. The failure of nonsafety-related SSCs in the RHR system potentially

could prevent the satisfactory accomplishment of a safety-related function. In addition, the RHR

system performs functions that support fire protection, ATWS, and EQ. LRA Table 2.3.2-1

identifies RHR system component types within the scope of license renewal and subject to an

AMR.

2.3.2.1.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the RHR system mechanical components within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

system components subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2-41
2.3.2.2 Reactor Core Isolation Cooling System

2.3.2.2.1 Summary of Technical Information in the Application

LRA Section 2.3.2.2 describes the RCIC system, which consists of a steam-driven turbinepump unit, valves, and piping capable of delivering water from either the condensate storage

tank (CST) or the suppression pool to the RV via one of the feedwater lines. The RCIC system

contains safety-related components relied upon to remain functional during and following DBEs.

The failure of nonsafety-related SSCs in the RCIC system potentially could prevent the

satisfactory accomplishment of a safety-related function. In addition, the RCIC system performs

functions that support fire protection, ATWS, SBO, and EQ. LRA Table 2.3.2-2 identifies RCIC

system component types within the scope of license renewal and subject to an AMR.

2.3.2.2.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.2 and UFSAR Section 5.4.6 using the evaluation

methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3. The

staff's review identified areas where additional information was necessary to complete the

review of the applicant's scoping and screening results. The applicant responded to the staff's

RAIs as discussed below.

In RAI 2.3.2.2-1, dated October 24, 2007, the staff noted boundary drawings LR-M-150

and -2150 of the LRA depicted piping between the RCIC vacuum tank and the barometric

condenser vacuum pump as not in-scope. The staff identified that Table 2.3.2-2 listed the

piping and piping components function (under the vacuum tank) as structural integrity.

Additionally, Tanks 1/2 T219 were depicted as in-scope in boundary drawing LR-M-150-1; but

they were not listed in Table 2.3.2-2. The staff requested the applicant to confirm the

connecting piping was included within the scope of license renewal and subjected to AMR as

structural boundary or to justify its exclusion. In addition, the staff requested the applicant to

modify Table 2.3.2-2 to reflect the response.

In its response dated November 14, 2007, the applicant stated:

The piping between the RCIC Barometric Condenser Vacuum Tank air space

and the suction of the RCIC Barometric Condenser Vacuum Pump is not inscope because these lines are not fluid filled. The RCIC Barometric Condenser

Vacuum Pump is primarily removing air and non-condensables from the steam

that is condensed in the RCIC Barometric Condenser. Therefore, this segment of

piping does not contain sufficient liquid that would leak or spray on adjacent

equipment.

The RCIC Barometric Condenser Vacuum Pump and associated discharge

piping is highlighted in magenta because it provides a structural integrity function

for safety-related connected piping as indicated in license renewal Note C on the

subject drawings. The piping between the RCIC Barometric Condenser Vacuum

Tank air space and the suction of the RCIC Barometric Condenser Vacuum

Pump does not provide structural integrity for either the RCIC Barometric

Condenser or Barometric Condenser Vacuum Pump, which also supports the

piping not included in-scope for license renewal. Based on the above, LRA

2-42
drawings LR-M-150 and LR-M-2150, Sheet 1, H7 are correct and no change is

required.

Review of LRA Table 2.3.2-2 and Table 3.2.2-2 identified that the RCIC

Barometric Condenser Vacuum Pump (1/2P219) was inadvertently omitted from

these tables. In addition, it was identified that the piping between the RCIC

Barometric Condenser Vacuum Pump discharge and the suppression pool was

inadvertently omitted from Table 3.2.2-2. The license renewal application was

amended to include the RCIC Barometric Condenser Vacuum Pump and

associated discharge piping as subject to aging management review.

The applicant submitted revised LRA Tables 2.3.2-2 and 3.2.2-2.

Based on its review, the staff finds the applicant's response to RAI 2.3.2.2-1 acceptable

because the applicant explained that the piping in question is not fluid filled and the RCIC

Barometric Condenser Vacuum Pump removes air and non-condensables from steam. The

applicant also explained that the piping in question does not provide structural integrity for any

required components. The applicant identified several items that were inadvertently omitted

from LRA Tables 2.3.2-2, "Reactor Core Isolation Cooling System Components Subject to

Aging Management Review," and Table 3.2.2-2, "Aging management review Results - Reactor

Core Isolation Cooling System." The applicant amended the LRA to include these revised

tables. Therefore, the staff's concern described in RAI 2.3.2.2-1 is resolved.

2.3.2.2.3 Conclusion

The staff reviewed the LRA, UFSAR, boundary drawings, RAI responses, and revised LRA

tables to determine whether the applicant failed to identify any components within the scope of

license renewal. In addition, the staff's review determined whether the applicant failed to identify

any components subject to an AMR. On the basis of its review, the staff concludes that the

applicant has appropriately identified reactor core isolation cooling system mechanical

components within the scope of license renewal, as required by 10 CFR 54.4(a), and that the

applicant has adequately identified the reactor core isolation cooling system components

subject to an AMR in accordance with the requirements stated in 10 CFR 54.21(a)(1).

2.3.2.3 Core Spray System

2.3.2.3.1 Summary of Technical Information in the Application

LRA Section 2.3.2.3 describes the CSS, which, as part of the overall emergency core cooling

system, is designed to provide cooling to the reactor core only when the RV pressure is low, as

for a large-break loss-of-coolant accident (LOCA). However, when operating with the automatic

depressurization system, the effective CSS core cooling capability extends to all break sizes as

the automatic depressurization system rapidly reduces the RV pressure to the CSS operating

range. The CSS contains safety-related components relied upon to remain functional during

and following DBEs. The failure of nonsafety-related SSCs in the CSS potentially could prevent

the satisfactory accomplishment of a safety-related function. In addition, the CSS performs

functions that support fire protection and EQ. LRA Table 2.3.2-3 identifies CSS component

types within the scope of license renewal and subject to an AMR.

2-43
2.3.2.3.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the CSS system mechanical components within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

system components subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2.3.2.4 High Pressure Coolant Injection System

2.3.2.4.1 Summary of Technical Information in the Application

LRA Section 2.3.2.4 describes the HPCI system, which consists of a steam-driven turbinepump unit, valves, and piping that can deliver water from the CST or from the suppression pool

to the RV via one of the feedwater lines. The HPCI system contains safety-related components

relied upon to remain functional during and following DBEs. The failure of nonsafety-related

SSCs in the HPCI system potentially could prevent the satisfactory accomplishment of a safetyrelated function. In addition, the HPCI system performs functions that support fire protection,

ATWS, SBO, and EQ. LRA Table 2.3.2-4 identifies HPCI system component types within the

scope of license renewal and subject to an AMR.

2.3.2.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.4 and UFSAR Section 6.3.2.2.1 using the evaluation

methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3. The

staff's review identified areas where additional information was necessary to complete the

review of the applicant's scoping and screening results. The applicant responded to the staff's

RAIs as discussed below.

In RAI 2.3.2.4-1, dated October 24, 2007, the staff noted that in boundary drawing LR-M-1 56-1,

the drive shaft from the HPCI turbine to the HPC1 pump was shown in-scope, however, the

drive shaft between the HPCI pump and booster pump was not. The staff requested that the

applicant clarify whether the drive shafts were in-scope, thus, requiring an AMR and; if

excluded, provide justification.

In its response to RAI 2.3.2.4-1, dated November 14, 2007, the applicant stated:

The highlighting of the drive shaft between the HPCI pump and booster pump on

boundary drawing LR-M-156-1 was inadvertently omitted. The entire drive shaft

is within the scope of license renewal. The highlighting has been corrected to

show this drive shaft highlighted in green. The unit 2 boundary drawing, LR-M2156-1 shows the correct highlighting.

The drive shafts and gearbox between the HPCI booster pump and the HPCI

pump and the drive shafts between the HPCI pump and the HPCI turbine are

within the scope of license renewal. The drive shafts and gear box are

considered to be active components and therefore are not subject to aging

management review.

2-44
This was a highlighting omission on a boundary drawing and no changes to the

LRA are required.

The staff confirmed that the applicant has submitted revised boundary drawing LR-M-156-1.

Based on its review, the staff finds the applicant's response to RAI 2.3.2.4-1 acceptable

because the applicant clarified that the highlighting of the drive shaft between the HPCI pump

and booster pump was in error and the drive shaft is in-scope. The staff confirms that the

applicant has submitted a corrected boundary drawing LR-M-1 56-1. Therefore, the staff's

concern described in RAI 2.3.2.4-1 is resolved.

2.3.2.4.3 Conclusion

The staff reviewed the LRA, UFSAR, boundary drawings (original and revised), and

RAI responses to determine whether the applicant failed to identify any components within the

scope of license renewal. In addition, the staff's review determined whether the applicant failed

to identify any components subject to an AMR. On the basis of its review, the staff concludes

that the applicant has appropriately identified the HPCI system mechanical components within

the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has

adequately identified the HPCI system components subject to an AMR, in accordance with the

requirements of 10 CFR 54.21(a)(1) and therefore, the response is acceptable.

2.3.2.5 Containment and Suppression System

2.3.2.5.1 Summary of Technical Information in the Application

LRA Section 2.3.2.5 describes the containment and suppression system, which maintains the

structural and functional integrity of the primary containment during and following a

design-basis LOCA. The system also monitors suppression pool level, pressure, and

temperature and provides for suppression pool cleanup. The containment and suppression

system contains safety-related components relied upon to remain functional during and

following DBEs. The failure of nonsafety-related SSCs in the containment and suppression

system potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the containment and suppression system performs functions that support fire

protection, ATWS, SBO, and EQ. LRA Table 2.3.2-5 identifies containment and suppression

system component types within the scope of license renewal and subject to an AMR.

2.3.2.5.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.5 and UFSAR Section 6.2.1 using the evaluation

methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3. The

staff's review identified areas where additional information was required to complete the

scoping and screening results. The applicant responded to the staff's RAIs as discussed below.

In RAI 2.3.2.5-1 dated July 25, 2007, the staff noted that on boundary drawing LR-M-1 57,

Sheet 4, one-inch valve 157011 at penetration X-234A and one-inch valve 157023 at

penetration X-232A, which belong to suppression pool level monitoring system, are shown as

not within the scope of license renewal. The staff requested that the applicant provide

justification for the exclusion of these valves from the scope of license renewal. If these valves

2-45
are within the scope of license renewal, in accordance with 10 CFR 54.4(a), and subject to an

AMR in accordance with 10 CFR 54.21(a)(1), the staff requested that the applicant update the

LRA by providing the applicable information in the appropriate LRA sections, tables, and

boundary drawings.

In its response to RAI 2.3.2.5-1, dated August 23, 2007, the applicant stated:

Boundary drawing LR-M-157 Sheet 4 contained an error related to

highlighting. Valve 157011 at penetration X-234A and valve 157023 at

penetration X-232A are both in-scope and subject to aging management review,

but they were inadvertently not highlighted. Both valves have been highlighted in

green on the revised boundary drawing LR-M-157 Sheet 4, included as

Attachment 1.

In the course of addressing this RAI, it was also noticed that the highlighting at

penetration X-90D for one-inch line HCB-1 12 was slightly different from the

highlighting for the other pipelines at penetrations X-90A and X-90D. The short

length of piping between valve 157077 and the penetration should have been

highlighted. This piping is in-scope and subject to aging management review, but

was inadvertently not highlighted. This piping has been highlighted in green on

the revised boundary drawing LR-M-157 Sheet 4, included as Attachment 1.

No changes to the LRA are required as valves 157011 and 157023 are

addressed in Table 2.3.2-5, and the material/environment combinations for the

valve bodies are addressed in Table 3.2.2-5. The additional piping component

associated with one-inch line HCB-1 12 belongs to the Containment Atmosphere

Control System. No changes to the LRA are required as the piping is included in

Table 2.3.2-6 and the material/environment combinations for the piping are

addressed in Table 3.2.2-6.

Based on its review, the staff finds the applicant's response to RAI 2.3.2.5-1 acceptable

because the applicant clarified that the that one-inch valve 157011 at penetration X-234A and

one-inch valve 157023 at penetration X-232A are within the scope of license renewal and were

inadvertently not highlighted. The staff confirms that the applicant has provided revised

boundary drawing LR-M-1 57, Sheet 4, with correct highlighting. Therefore, the staff's concern

described in RAI 2.3.2.5-1 is resolved.

In RAI 2.3.2.5-2, dated July 25, 2007, the staff noted that LRA Section 2.3.2.5, "Containment

and Suppression System" under "License Renewal Drawings" lists boundary drawings

LR-M-151 Sheet 1, and LR-M-155 Sheet 1 for Unit 1, and LR-M-2151 Sheet 1, and LR-M-2155,

Sheet 1 for Unit 2. The staff requested that the applicant clarify which functions or items shown

in these boundary drawing belong to the containment and suppression system.

In its response to RAI 2.3.2.5-2, dated August 23, 2007, the applicant stated:

The evaluation boundaries of the Containment and Suppression System that are

shown on drawing LR-M-151 Sheet 1 for Unit 1 (LR-M-2151 Sheet 1 for Unit 2)

are within the Non Safety Affecting Safety (NSAS) boundaries highlighted in

magenta and extend from valve 151089 in zone B-1 for Unit 1 (valve 251088 in

zone B-1 for Unit 2) through four-inch pipeline HBD-173 (4-inch HBD-273 for

2-46
Unit 2) and continuing on drawing LR-M-157 Sheet 1 for Unit 1 (LR-M2157

Sheet 1 for Unit 2). Components within these boundaries, subject to aging

management review, are included as piping and piping components with a

structural integrity function, as listed in Table 2.3.2-5 in LRA Section 2.3.2.5.

The evaluation boundaries of the Containment and Suppression System that are

shown on drawing LR-M-155 Sheet 1 for Unit 1 (LR-M-2155 Sheet 1 for Unit 2)

extend from penetrations X-219A and X-219B in zone G-3/H-3 to and including

level switches LSH-E41-1N015A & B for Unit 1 (E41-2N015A & B for Unit 2) and

continuing to drawing LR-M-157 Sheet 8 for Unit 1 (LR-M-2157 Sheet 8 for

Unit 2). Components within these boundaries, subject to aging management

review, include condensing pots, piping, tubing, and valve bodies, all of which

are listed in Table 2.3.2-5 in LRA Section 2.3.2.5 with a pressure boundary

function.

Based on the discussion above, no changes to the LRA are required.

Based on its review, the staff finds the applicant's response to RAI 2.3.2.5-2 acceptable

because the applicant clarified which components are parts of the containment and suppression

system. Therefore, the staff's concern described in RAI 2.3.2.5-2 is resolved.

2.3.2.5.3 Conclusion

The staff reviewed the LRA, UFSAR, boundary drawings (original and revised), and

RAI responses to determine whether the applicant failed to identify any components within the

scope of license renewal. In addition, the staff's review determined whether the applicant failed

to identify any components subject to an AMR. On the basis of its review, the staff concludes

that the applicant has appropriately identified the containment and suppression system

mechanical components within the scope of license renewal, as required by 10 CFR 54.4(a),

and that the applicant has adequately identified the containment and suppression system

components subject to an AMR, in accordance with the requirements of 10 CFR 54.21(a)(1)

and therefore, the response is acceptable.

2.3.2.6 Containment Atmosphere Control System

2.3.2.6.1 Summary of Technical Information in the Application

LRA Section 2.3.2.6 describes the containment atmosphere control (CAC) system, which is

designed to control the concentration of hydrogen within the primary containment following a

LOCA. The CAC system contains safety-related components relied upon to remain functional

during and following DBEs. The failure of nonsafety-related SSCs in the CAC system potentially

could prevent the satisfactory accomplishment of a safety-related function. In addition, the CAC

system performs functions that support fire protection, SBO, and EQ. LRA Table 2.3.2-6

identifies CAC system component types within the scope of license renewal and subject to an

AMR.

2.3.2.6.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.6 and UFSAR Section 6.2.5 using the evaluation

methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3. The

2-47
staff's review identified areas where additional information was required to complete the

scoping and screening results. The applicant responded to the staff's RAIs as discussed below.

In RAI 2.3.2.6-1, dated July 25, 2007, the staff noted that LRA Section 2.3.2.6 identifies the

Combustible Gas Control System described in UFSAR Section 6.2.5 as Containment

Atmosphere Control System for license renewal. The description and functions of Containment

Atmospheric Control System as described in LRA Section 2.3.2.6 is not consistent with the

description given in UFSAR Section 6.2.5 for Units 1 and 2. According to UFSAR

Section 6.2.5.2, the combustible gas control depends on the following functions and

subsystems:

(a) Hydrogen mixing

(b) Hydrogen and oxygen monitoring system

(c) Hydrogen recombiner system

(d) Containment hydrogen purge system

(e) Containment nitrogen inerting system

The LRA Section 2.3.2.6 does not mention the Containment Nitrogen Inerting System which

maintains the primary containment inerted with nitrogen during power operation, with oxygen

concentration not to exceed 4% by volume. The staff requested the applicant either add the

description of Containment Nitrogen Inerting System in LRA Section 2.3.2.6 or add another

section to the LRA describing this system and its license renewal function.

In its response to RAI 2.3.2.6-1, dated August 23, 2007, the applicant stated:

While FSAR Section 6.2.5 identifies containment nitrogen inerting as a function

of the combustible gas control system, identified as Containment Atmosphere

Control in the LRA, nitrogen inerting is not an engineered safety feature (ESF)

function.

The Nitrogen and Hydrogen System is described in LRA Section 2.3.3.16. As

stated in Section 2.3.3.16, a nonsafety-related portion of this system is identified

as in-scope based on the scoping criteria of 10 CFR 54.4(a)(2). This is illustrated

on license renewal drawings LR-M-157 Sheet 1 for Unit 1 and LR-M-2157

Sheet 1 for Unit 2 at zone C-8 by the piping and components shown in magenta.

The piping and components related to the function of containment nitrogen

inerting and makeup that are highlighted in green on LR-M-157 Sheet 1 and

LR-M-2157 Sheet 1 have a safety-related function to provide primary

containment isolation and maintain containment integrity. These components are

addressed in LRA Section 2.3.2.6 as in-scope based on the scoping criteria of

10 CFR 54.4(a)(1 ) because they support either the functional or structural

integrity of the primary containment. Both LRA Sections 2.3.3.16 and 2.3.2.6

reference drawings LR-M-157 Sheet 1 and LR-M-2157 Sheet 1 which depict the

in-scope portions of the Nitrogen and Hydrogen System and the Containment

Atmosphere Control System.

Based on a teleconference between PPL and the NRC Staff on July 10, 2007,

revisions discussed for LRA Sections 2.3.2.5 and 2.3.2.6 are provided in

2-48
Attachments 2 and 3. The revisions to both attachments consist of added text

which is shown in bold italics.

Based on its review, the staff finds the applicant's response to RAI 2.3.2.6-1 acceptable

because the applicant clarified what is included in the containment and suppression system.

The staff confirms that the applicant has provided revised LRA Sections 2.3.2.5 and 2.3.2.6.

Therefore, the staff's concern described in RAI 2.3.2.6-1 is resolved.

In RAI 2.3.2.6-2, dated July 25, 2007, the staff noted that UFSAR Table 6.2-12,

"Containment Penetration Data," shows the 24-inch butterfly valve HV1 5722 as a

containment isolation safety-related valve located at drywell penetration X-25. This valve

located in zone C-5 of boundary drawing LR-M-1 57 Sheet No. 1 is shown as not within

the scope of license renewal. The staff requested that applicant provide justification for

the exclusion of this valve from the scope of license renewal. If this valve is within the

scope of license renewal, in accordance with 10 CFR 54.4(a), and subject to an AMR in

accordance with 10 CFR 54.21 (a)(1), the staff requested that the applicant update the

LRA by providing the applicable information in the appropriate LRA sections, tables, and

boundary drawings.

In its response, dated August 23, 2007, the applicant stated:

Boundary drawing LR-M-157 Sheet 1 contained an error related to

highlighting. Valve 157022 and the short length of piping between the valve

and penetration X-25 are in-scope and subject to aging management review,

but they were inadvertently not highlighted. The valve and the piping have

been highlighted in green on the revised boundary drawing LR-M-157 Sheet 1,

included as Attachment 4.

No changes to the LRA are required as the valve and piping are included

Table 2.3.2-6 and the material/environment combinations for the valve and

piping are addressed in Table 3.2.2-6.

Based on its review, the staff finds the applicant's response to RAI 2.3.2.6-2 acceptable

because the applicant clarified that valve 157022 and the short length of piping between the

valve and penetration X-25 are in-scope and subject to an AMR. The staff confirms that the

applicant has provided a revised boundary drawing LR-M-157, Sheet 1. Therefore, the staff's

concern described in RAI 2.3.2.6-2 is resolved.

In RAI 2.3.2.6-3, dated July 25, 2007, the staff noted that LRA Section 2.3.2.6, "Containment

Atmosphere Control System," under the heading "License Renewal Drawings," lists LR-M-157,

Sheets 6 and 7 for Unit 1, and LR-M-2157, Sheets 6 and 7 for Unit 2. These boundary drawings

provide containment radiation monitoring details that appear to not have any item described in

LRA Section 2.3.2.6. The staff requested that the applicant provide justification for listing these

boundary drawings in LRA Section 2.3.2.6. If any of the system components in these boundary

drawings belong to the LRA Section 2.3.2.6, the staff requested that the applicant provide a list

of these components and revise LRA Table 2.3.2-6, as required. (Note that suppression pool

level and temperature functions are covered in the containment and suppression system in LRA

Section 2.3.2.5, which lists these boundary drawings under "License Renewal Drawings" and

the containment radiation monitoring system is covered in LRA Section 2.3.3.18, which lists

these under the heading "License Renewal Drawing").

2-49
In its response to RAI 2.3.2.6-3, dated August 23, 2007, the applicant stated:

The Containment Radiation Monitoring (CRM) Panels (1C291A/B for Unit 1 and

2C291A/B for Unit 2) and all components within them (shown on drawings

LR-M-157 Sheets 6 and 7 for Unit 1 and LR-M-2157 Sheets 6 and 7 for Unit 2)

are within the evaluation boundaries of the Process and Area Radiation

Monitoring System. In accordance with the guidance provided in NEI 95-10

Appendix B, radiation monitors are considered to be active components and,

therefore, not subject to aging management review. This conclusion is

presented, along with a description of the Process and Area Radiation

Monitoring System and reference to the above mentioned drawings, in LRA

Section 2.3.3.18.

Drawings LR-M-157 Sheets 6 and 7 for Unit 1 (LR-M-2157 Sheets 6 and 7 for

Unit 2) are also included in LRA Section 2.3.2.6 because components that are

within the evaluation boundaries of the Containment Atmosphere Control (CAC)

System are depicted. The CAC System evaluation boundaries extend from

penetrations X-5 and X-91A for Unit 1 (X-5 and X-31B for Unit 2) to the pipe-totubing interface at CRM Panels 1C291A/B for Unit 1 (2C291ANB for Unit 2), and

include the piping and valve bodies. The piping and valve bodies are evaluated

in LRA Section 2.3.2.6, and the tubing is evaluated with the Process and Area

Radiation Monitoring System in LRA Section 2.3.3.18.

Based on the discussion above, no changes to the LRA are required.

Based on its review, the staff finds the applicant's response to RAI 2.3.2.6-3 acceptable

because the applicant clarified that LR-M-157 Sheets 6 and 7 contain components that are in

the CAC system; thus, boundary drawing LR-M-157 Sheets 6 and 7 are listed in LRA

Section 2.3.2.6. Therefore, the staff's concern described in RAI 2.3.2.6-3 is resolved.

In RAI 2.3.2.6-4, dated July 25, 2007, the staff noted that LRA Section 2.3.2.6,

"Containment Atmosphere Control System," under the heading "License Renewal

Drawings," lists LR-M-157 Sheet 8 for Unit 1, and LR-M-2157 Sheet 8 for Unit 2. These

boundary drawings provide details of suppression pool level and pressure monitoring that

appears to not have any items described in LRA Section 2.3.2.6. The staff requested that

the applicant provide justification for listing the above boundary drawings in LRA

Section 2.3.2.6. If any of the system components in these boundary drawings belong to the

LRA Section 2.3.2.6, the staff requested that the applicant provide a list of these

components and revise LRA Table 2.3.2-6, as required. (Note that suppression pool level

and temperature functions are covered in the containment and suppression system in LRA

Section 2.3.2.5, which lists these boundary drawings under the heading "License Renewal

Drawings").

In its response to RAI 2.3.2.6-4, dated August 23, 2007, the applicant stated:

All tubing and valve bodies associated with level transmitters LT-1 5775A and LT25775A, as shown on drawings LR-M-157 Sheet 8 and LR-M-2157 Sheet 8,

respectively, are within the evaluation boundaries of the Containment and

Suppression System and are listed in Table 2.3.2-5 in LRA Section 2.3.2.5. All

2-50
other components that are shown on drawings LR-M-157 Sheet 8 and LR-M2157 Sheet 8 are within the evaluation boundaries of the Containment

Atmosphere Control (CAC) System and are listed in Table 2.3.2-6 in LRA

Section 2.3.2.6 (tubing and valve bodies).

Based on the discussion above, no changes to the LRA are required.

Based on its review, the staff finds the applicant's response to RAI 2.3.2.6-4 acceptable

because the applicant provided a list of components in LR-M-157, Sheet 8 and LR-M-21 57,

Sheet 8 that are in the CAC system. Therefore, the staff's concern described in RAI 2.3.2.6-4

is resolved.

In RAI 2.3.2.6-5, dated July 25, 2007, the staff noted boundary drawing LR-M-1 57, Sheet 1,

zone F-3, at primary containment penetration X-221A, shows the piping component at the

upstream side of valve 157201 as not within the scope for license renewal. The staff

requested that the applicant provide justification for the exclusion of this piping component

from the scope of license renewaL If this component is within the scope of license renewal,

in accordance with 10 CFR 54.4(a), and subject to an AMR, in accordance with

10 CFR 54.21(a)(1), the staff requested that the applicant update the LRA by providing the

applicable information in the appropriate LRA sections, tables, and boundary drawings.

In its response to RAI 2.3.2.6-5, dated August 23, 2007, the applicant stated:

Boundary drawing LR-M-1 57 Sheet 1 contained an error related to

highlighting. Valve 157201 at penetration X-221A has a two-inch by one-inch

reducer that is in-scope and subject to aging management review, but it was

inadvertently not highlighted. The reducer has been highlighted in green on the

revised boundary drawing LR-M-1 57 Sheet 1, included as Attachment 4.

No changes to the LRA are required as the reducer is included in Table 2.3.2-6

and the material/environment combinations for the reducer are addressed in

Table 3.2.2-6.

Based on its review, the staff finds the applicant's response to RAI 2.3.2.6-5 acceptable

because the applicant has clarified that boundary drawing LR-M-1 57, Sheet 1, contained a

highlighting error regarding valve 157201 at penetration X-221A. The staff confirms that the

applicant has submitted revised boundary drawing LR-M-157 Sheet 1. Therefore, the staff's

concern described in RAI 2.3.2.6-5 is resolved.

2.3.2.6.3 Conclusion

The staff reviewed the LRA, UFSAR, boundary drawings (original and revised), and

RAI responses to determine whether the applicant failed to identify any components within the

scope of license renewal. In addition, the staff's review determined whether the applicant failed

to identify any components subject to an AMR. On the basis of its review, the staff concludes

that the applicant has appropriately identified CAC system mechanical components within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the CAC system components subject to an AMR, in accordance with the requirements

of 10 CFR 54.21(a)(1) and therefore, the response is acceptable.

2-51
2.3.2.7 Standby Gas Treatment System

2.3.2.7.1 Summary of Technical Information in the Application

LRA Section 2.3.2.7 describes the SBGT common to both units. The system is designed for two

purposes: (1) to exhaust filtered air from the Reactor Building to maintain a negative pressure in

the affected volumes following secondary containment isolation for a spent fuel handling

accident or for a LOCA and (2) to filter the exhausted air to remove radioactive particulates and

both radioactive and nonradioactive forms of iodine to limit offsite dose. The SGTS contains

safety-related components relied upon to remain functional during and following DBEs. In

addition, the SGTS performs functions that support EQ. LRA Table 2.3.2-7 identifies SGTS

component types within the scope of license renewal and subject to an AMR.

2.3.2.7.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the SBGT system mechanical components within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

system components subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2.3.3 Auxiliary Systems

In LRA Section 2.3.3, the applicant identified the auxiliary systems SCs subject to an AMR for

license renewal. The applicant described the supporting SCs of the auxiliary systems in the

following LRA sections:

" 2.3.3.1 Building drains nonradioactive system

* 2.3.3.2 Containment instrument gas system

" 2.3.3.3 Control rod drive hydraulics system

* 2.3.3.4 Control structure chilled water system

" 2.3.3.5 Control structure HVAC systems

" 2.3.3.6 Cooling tower system

" 2.3.3.7 Diesel fuel oil system

* 2.3.3.8 Diesel generator buildings HVAC systems

" 2.3.3.9 Diesel generator system

" 2.3.3.10 Domestic water system

" 2.3.3.11 Emergency service water system

" 2.3.3.12 Engineered safeguards service water pumphouse HVAC system

* 2.3.3.13 Fire protection system

* 2.3.3.14 Fuel pool cooling and cleanup system and fuel pools and auxiliaries

* 2.3.3.15 Neutron monitoring system

* 2.3.3.16 Nitrogen and hydrogen system

" 2.3.3.17 Primary containment atmosphere circulation system

" 2.3.3.18 Process and area radiation monitoring system

" 2.3.3.19 Radwaste liquid system

* 2.3.3.20 Radwaste solids handling system

* 2.3.3.21 Raw water treatment system

* 2.3.3.22 Reactor building chilled water system

2-52
" 2.3.3.23 Reactor building closed cooling water system

" 2.3.3.24 Reactor building HVAC system

" 2.3.3.25 Reactor nonnuclear instrumentation system

* 2.3.3.26 Reactor water cleanup system

" 2.3.3.27 RHR service water system

* 2.3.3.28 Sampling system

* 2.3.3.29 Sanitary drainage system

" 2.3.3.30 Service air system

" 2.3.3.31 Service water system

* 2.3.3.32 Standby liquid control system

* 2.3.3.33 Turbine building closed cooling water system

Auxiliary Systems Generic Requests for Additional Information

As part of the staff's review, the following RAIs identified instances of boundary drawing errors

where the continuation notation for piping from one boundary drawing to another boundary

drawing could not be identified or was incorrect:

* RAI 2.3.3.14-1

• RAI 2.3.3.14-2

* RAI 2.3.3.14-11

* RAI 2.3.3.27-1

" RAI 2.3.3.27-2

" RAI 2.3.3.31-2

In its response, dated October 18, 2007, the applicant noted these were typographical errors

and submitted revised the boundary drawings.

Based on its review, the staff finds the applicant's responses to these RAIs acceptable because

the applicant revised the boundary drawings to correct the errors. Therefore, the staffs

concerns described in the RAIs noted above are resolved.

2.3.3.1 Building Drains Nonradioactive System

2.3.3.1.1 Summary of Technical Information in the Application

LRA Section 2.3.3.1 describes the building drains nonradioactive system operating throughout

the plant. The failure of nonsafety-related SSCs in the building drains nonradioactive system

potentially could prevent the satisfactory accomplishment of a safety-related function. LRA

Table 2.3.3-1 identifies building drains nonradioactive system component types within the scope

of license renewal and subject to an AMR.

2.3.3.1.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the building drains nonradioactive system mechanical components

within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has

adequately identified the system components subject to an AMR in accordance with the

requirements stated in 10 CFR 54.21 (a)(1).

2-53
2.3.3.2 Containment Instrument Gas System

2.3.3.2.1 Summary of Technical Information in the Application

LRA Section 2.3.3.2 describes the containment instrument gas system, which provides filtered,

dry, oil-free instrument gas to the pneumatic devices located inside the drywell and suppression

chamber. The failure of nonsafety-related SSCs in the containment instrument gas system

potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the containment instrument gas system performs functions that support fire protection,

SBO, and EQ. LRA Table 2.3.3-2 identifies containment instrument gas system component

types within the scope of license renewal and subject to an AMR.

2.3.3.2.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the containment instrument gas system mechanical components within

the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has

adequately identified the system components subject to an AMR in accordance with the

requirements stated in 10 CFR 54.21(a)(1).

2.3.3.3 Control Rod Drive Hydraulics System

2.3.3.3.1 Summary of Technical Information in the Application

LRA Section 2.3.3.3 describes the control rod drive hydraulic system (CRDHS), which controls

gross changes in core reactivity by incrementally positioning neutron-absorbing control rods

within the reactor core in response to manual control signals initiated by the reactor manual

control system. The CRDHS also must shut down the reactor quickly (scram) in response to

manual or automatic signals in emergency situations by rapidly inserting withdrawn control rods

into the core. The CRDHS contains safety-related components relied upon to remain functional

during and following DBEs. The failure of nonsafety-related SSCs in the CRDHS potentially

could prevent the satisfactory accomplishment of a safety-related function. In addition, the

CRDHS performs functions that support fire protection, ATWS, and EQ. LRA Table 2.3.3-3

identifies CRDHS component types within the scope of license renewal and subject to an AMR.

2.3.3.3.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the CRDHS mechanical components within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

system components subject to an aging management review in accordance with the

requirements stated in 10 CFR 54.21 (a)(1).

2-54
2.3.3.4 Control Structure Chilled Water System

2.3.3.4.1 Summary of Technical Information in the Application

LRA Section 2.3.3.4 describes the control structure chilled-water system, which supplies chilled

water to the cooling coils in the control room floor cooling unit, computer room floor cooling unit,

and control structure heating and ventilation unit. The CSCW System also provides chilled

water to the emergency cooling coils in the Unit 1 emergency switchgear and load

center room air handling units. The control structure chilled-water system contains safetyrelated components relied upon to remain functional during and following DBEs. The failure of

nonsafety-related SSCs in the control structure chilled-water system potentially could prevent

the satisfactory accomplishment of a safety-related function. In addition, the control structure

chilled-water system performs functions that support EQ. LRA Table 2.3.3-4 identifies control

structure chilled-water system component types within the scope of license renewal and subject

to an AMR.

2.3.3.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.4, UFSAR Section 9.2.12.1, and the licensing renewal

boundary drawings using the evaluation methodology described in SER Section 2.3 and the

guidance in SRP-LR Section 2.3. The staff's review 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 RAIs as discussed below.

In RAIs 2.3.3.4-1, 2.3.3.4-2, and 2.3.3.4-3, dated August 27, 2007, the staff noted instances

where boundary drawings identified portions of piping as within the scope of license renewal

that are continued on other boundary drawings, where the piping is not shown to be within the

scope of license renewal on the continuation boundary drawings. The staff requested that the

applicant clarify why the continuations are not within the scope of license renewal.

In its response to RAIs 2.3.3.4-1, 2.3.3.4-2, and 2.3.3.4-3, dated October 18, 2007; the

applicant stated that the subject piping was within the scope of license renewal. The applicant

submitted revised boundary drawings to reflect the piping as being within the scope of licensing

renewal.

Based on its review of the applicant's revised boundary drawings, the staff finds the applicant's

response to RAIs 2.3.3.4-1, 2.3.3.4-2, and 2.3.3.4-3 acceptable because the applicant has

clarified that the piping in question was within the scope of license renewal and has made the

appropriate revisions to the subject boundary drawings. Therefore, the staff's concerns

described in RAIs 2.3.3.4-1, 2.3.3.4-2, and 2.3.3.4-3 are resolved.

In RAI 2.3.3.4-4, dated August 27, 2007, the staff noted that the safety-related control

structure HN unit cooling coils were within the scope of license renewal, pursuant to

10 CFR 54.4(a)(1). However, these cooling coils were omitted from LRA Table 2.3.3-4 for

components subject to an AMR. The staff requested that the applicant explain why these

cooling coils are not included in LRA Table 2.3.3-4.

2-55
In its response, dated October 18, 2007, the applicant stated:

The control structure HN units OVI 03A and OVI 03B, including cooling coils

0E146A1 through B2 are within the scope of license renewal and are subject to

AMR. Based on PPL's scoping methodology, these cooling coils have been

scoped with the control structure HVAC systems and are included in LRA

Section 2.3.3.5 and Table 2.3.3-5.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.4-4 acceptable

because the applicant adequately explained that the AMR for the cooling coils in question is

covered in LRA Section 2.3.3.5 and Table 2.3.3-5. Therefore, the staff's concern described in

RAI 2.3.3.4-4 is resolved.

In RAIs 2.3.3.4-5 and 2.3.3.4-6, dated August 27, 2007, the staff noted that the safety-related

control room floor recirculation unit cooling coils were within the scope of license renewal in

accordance with 10 CFR 54.4(a)(1) criterion. However, these cooling coils were omitted from

LRA Table 2.3.3-4 for components subject to an AMR. The staff requested that the applicant

explain why these cooling coil components are not included in LRA Table 2.3.3-4.

In its response to RAIs 2.3.3.4-5 and 2.3.3.4-6, dated October 18, 2007, the applicant stated:

The control room floor recirculation units OV1 17A and OVI 17B, including cooling'

coils 0E151A1 through B2, are within the scope of license renewal and are

subject to AMR. Based on PPL's scoping methodology, these cooling coils have

been scoped with the Control Structure HVAC Systems and are included in LRA

Section 2.3.3.5 and Table 2.3.3-5.

Based on its review, the staff finds the applicant's response to RAIs 2.3.3.4-5 and 2.3.3.4-6

acceptable because the applicant explained that the cooling coils in question are covered in

LRA Section 2.3.3.5 and Table 2.3.3-5. Therefore, the staff's concern described in

RAIs 2.3.3.4-5 and 2.3.3.4-6 is resolved.

2.3.3.4.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and boundary drawings to determine

whether the applicant failed to identify any components within the scope of license renewal. In

addition, the staff's review determined whether the applicant failed to identify any components

subject to an AMR. On the basis of its review, the staff concludes the applicant has

appropriately identified the control structure chilled-water system mechanical components within

the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has

adequately identified the control structure chilled-water system mechanical components subject

to an AMR, in accordance with the requirements of 10 CFR 54.21(a)(1) and therefore, the

response is acceptable.

2-56
2.3.3.5 Control Structure Heating, Ventilation, and Air Conditioning (HVAC) Systems

2.3.3.5.1 Summary of Technical Information in the Application

LRA Section 2.3.3.5 describes the control structure HVAC systems. The control structure HVAC

systems contain safety-related components relied upon to remain functional during and

following DBEs. The failure of nonsafety-related SSCs in the control structure HVAC system

potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the control structure HVAC systems perform functions that support EQ. LRA

Table 2.3.3-5 identifies control structure HVAC systems component types within the scope of

license renewal and subject to an AMR.

2.3.3.5.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the control structure HVAC systems mechanical components within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the system components subject to an AMR in accordance with the requirements

stated in 10 CFR 54.21(a)(1 ).

2.3.3.6 Cooling Tower System

2.3.3.6.1 Summary of Technical Information in the Application

LRA Section 2.3.3.6 describes the single-loop cooling tower system consisting of a hyperbolic

natural draft cooling tower, cooling tower basin, blowdown and makeup water systems, and

chemical and blowdown treatment systems. The cooling tower system dissipates both latent

heat from the main condenser and sensible heat from the service water system (SWS). The

cooling tower system performs functions that support fire protection. LRA Table 2.3.3-6

identifies cooling tower system component types within the scope of license renewal and

subject to an AMR.

2.3.3.6.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.6, UFSAR Sections 9.2.1 and 10.4.5, and the licensing

renewal boundary drawings using the evaluation methodology described in SER Section 2.3

and the guidance in SRP-LR Section 2.3. The staff's review 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 RAIs as discussed below.

In RAI 2.3.3.6-1, dated August 27, 2007, the staff noted that one of the stated purposes of the

cooling tower system is to supply water to the fire protection system and therefore, complies

with the scoping criteria of 10 CFR 54.4(a)(3). Boundary drawings LR-M-1 15-1, LR-M-2115-1,

and LR-M-109-1 show supply lines from the cooling tower basin to the fire pumps within the

scope of license renewal, with a pressure boundary intended function. However, connected

piping is not within the scope of license renewal up to the first isolation valve, where it connects

to the SW and circulating water pumps. The staff requested that the applicant explain why

these sections of pipe and components are not within scope for license renewal.

2-57
In its response to RAI 2.3.3.6-1, dated October 18, 2007, the applicant stated:

The highlighted piping depicts the supply path for water from the cooling tower

basins to the fire protection pumps. This supply path meets the criteria of

10 CFR 54.4(a)(3) for fire protection. Inclusion of the connected piping up to the

service water and circulating water pump isolation valves in the scope of license

renewal is not necessary to ensure that the intended function is maintained.

As described in Section 2.3.3.6 of the LRA, each cooling tower basin contains

6,000,000 gallons of water, and is capable of meeting the largest expected water

demands of the fire protection system. As described in Section 4.1 of the Fire

Protection Review Report (FPRR), the largest single (fire protection) demand

can be satisfied by one fire pump, rated at 2500 gpm. Operability of the fire

suppression water supply is controlled in accordance with the SSES Technical

Requirements Manual (TRM). The TRM ensures at least one flow path capable

of taking suction from any two designated water supplies and an available supply

of water, from either the Unit 1 or Unit 2 cooling tower basin or the clarified water

storage tank, with a minimum volume of 300,000 gallons. Due to the large

volume available from a single cooling tower basin, in relation to the fire

protection demand, inclusion of the connected piping up to the service water and

circulating water pump isolation valves is not necessary to ensure this secondary

supply of fire protection water.

As the fire suppression water supply is maintained operable the connected

sections of piping will not affect the intended function of the Cooling Tower

System. Therefore, the subject piping is not included within the scope of license

renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.6-1 acceptable

because the applicant has clarified that the highlighted piping depicts the supply path for water

from the cooling tower basins to the fire protection pumps and is the total piping required for

compliance with 10 CFR 54.4(a)(3) for fire protection. The staff reviewed the UFSAR and the

Fire Protection Review Report and confirms the applicant's statement. The staff also confirms

that there are no hypothetical failures resulting from system interdependencies that would affect

this piping identified in the CLB and none has been previously experienced. Therefore, the

staff's concern described in RAI 2.3.3.6-1 is resolved.

In RAI 2.3.3.6-2, dated August 27, 2007, the staff noted that one of the stated purposes of the

cooling tower system is to supply water to the fire protection system and therefore, complies

with the scoping criteria of 10 CFR 54.4(a)(3). Boundary drawings LR-M-1 15-1, LR-M-2115-1,

and LR-M-109-1 show supply lines from the cooling tower basin to the fire pumps as within the

scope of license renewal, with a pressure boundary intended function. However, boundary

drawing LR-M-2115-1, location A4, and the continuation onto boundary drawing LR-M-2109-1,

location D1, shows the supply line to the SWS is not within the scope of license renewal. The

staff requested that the applicant explain why these sections of pipe and components are not

within scope of license renewal.

2-58
In its response to RAI 2.3.3.6-2, dated October 18, 2007, the applicant stated:

The highlighted piping depicts the supply path for water from the cooling tower

basins to the fire protection pumps. This supply path meets the criteria of

10 CFR 54.4(a)(3) for fire protection.

As described in response to RAI 2.3.3.6-1, each cooling tower basin contains a

large volume (6,000,000 gallons) of water available for fire protection. This

secondary volume is significantly more than is required for fire suppression since

the largest single (fire protection) demand can be satisfied by one fire pump,

rated at 2500 gpm. As such, the volume contained in the connected piping up to

the service water and circulating water pump isolation valves is inconsequential

to the fire water supply and only the path from the cooling tower basin to the fire

pumps is required for the intended function. Therefore, the path is included in the

license renewal evaluation boundary but the connected piping to service water

and circulating water pump isolation valves are not.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.6-2 acceptable

because the applicant has clarified that the highlighted piping depicts the supply path for water

from the cooling tower basins to the fire protection pumps and is the total piping required for

compliance with 10 CFR 54.4(a)(3) for fire protection. The staff's review of the UFSAR and Fire

Protection Review Report confirms the applicant's clarification. The staff also confirms that

there are no hypothetical failures resulting from system interdependencies that would affect this

piping identified in the current licensing bases and none has been previously experienced.

Therefore, the staff's concern described in RAI 2.3.3.6-2 is resolved.

2.3.3.6.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and boundary drawings to determine

whether the applicant failed to identify any components within the scope of license renewal. In

addition, the staff's review determined whether the applicant failed to identify any components

subject to an AMR. On the basis of its review, the staff concludes the applicant has

appropriately identified the cooling tower system mechanical components within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the control cooling tower system mechanical components subject to an AMR in

accordance with the requirements of 10 CFR 54.21(a)(1) and therefore, the response is

acceptable.

2.3.3.7 Diesel Fuel Oil System

2.3.3.7.1 Summary of Technical Information in the Application

LRA Section 2.3.3.7 describes the diesel fuel oil system, which stores onsite and delivers fuel

oil to the DGs for at least seven days of operation. The diesel fuel oil system contains safetyrelated components relied upon to remain functional during and following DBEs. The failure of

nonsafety-related SSCs in the diesel fuel oil system potentially could prevent the satisfactory

accomplishment of a safety-related function. In addition, the diesel fuel oil system performs

functions that support fire protection, ATWS, and SBO. LRA Table 2.3.3-7 identifies diesel fuel

oil system component types within the scope of license renewal and subject to an AMR.

2-59
2.3.3.7.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.7, UFSAR Section 9.5.4, and the licensing renewal

boundary drawings using the evaluation methodology described in SER Section 2.3 and the

guidance in SRP-LR Section 2.3. The staff's review 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 RAIs as discussed below.

In RAI 2.3.3.7-1, dated August 27, 2007, the staff noted that the injector housing is a

component for the diesel fuel oil system that is usually included within the scope of license

renewal and subject to an AMR. The impulse pumps shown on boundary drawings LR-M-134-1,

location E5, and LR-M-134-7, location A2, are not shown within the scope of license renewal

and the impulse pump housing is not listed in LRA Table 2.3.3-7 for components subject to an

AMR. The staff requested that the applicant explain why the impulse pumps and fuel injector

housings are not within the scope of license renewal and not included in LRA Table 2.3.3-7 as a

component type subject to AMR.

In its response to RAI 2.3.3.7-1, dated October 18, 2007, the applicant stated that a

re-evaluation of the fuel injection pumps determined that these pumps are subject to an AMR.

LRA Tables 2.3.3-7 and 3.3.2-7 were amended to include the fuel injection pumps. The

applicant explained that the fuel injectors are mounted in the engine cylinder and considered

active components; therefore, the fuel injectors are not subject to AMR.

The staff finds the applicant's response to RAI 2.3.3.7-1 acceptable because the applicant has

amended the LRA to add the fuel injection pump housing as a component type subject to AMR

and has adequately explained why the fuel injectors are not a component type subject to AMR.

Therefore, the staff's concern described in RAI 2.3.3.7-1 is resolved.

In RAI 2.3.3.7-2, dated August 27, 2007, the staff noted that the DG day tank flame arrestors

shown on boundary drawings LR-M-1 34-1, location F8, and LR-M-1 34-7, location A8, are within

the scope of license renewal, but are not included in LRA Table 2.3.3-7 for component types

subject to an AMR. The flame arrestor is typically a component type subject to an AMR. The

flame arrestors are shown within the scope of license renewal for different reasons on these

two boundary drawings. The staff requested that the applicant explain why the flame arrestors

are shown within the scope of license renewal, but not included in LRA Table 2.3.3-7, and why

the flame arrestors are shown within the scope of license renewal for different reasons.

In its response to RAI 2.3.3.7-2, dated October 18, 2007, the applicant stated in part:

As shown on license renewal drawings LR-M-134-1 and LR-M-134-7-4, the vent

line piping for the diesel fuel oil day tanks is within the scope of license renewal.

The vent lines for day tanks for diesels A-D on drawing LR-M-134-1 are shown

as cross-hatched, which indicates a safety-related process line per the legend

drawing LR-M-100-2. This is supported by the HBC line designation which

indicates that the piping is classified as ASME Section III Class 3. Therefore, the

vent lines are within the scope of license renewal and are highlighted in green

per LR-M-100-4 Note A2.

2-60
The flame arrestors on the A-D diesel day tank vent lines on drawing LR-M-1 34-

1 are not classified as safety-related. Drawing LR-M-134-1 has been revised to

include the flame arrestors within the scope of license renewal per the criteria of

10 CFR 54.4(a)(2).

The vent lines for the E diesel day tank on drawing LR-M-1 34-7 are nonsafetyrelated but are seismically qualified. This is supported by the HBD line

designation which indicates that the piping is classified as ANSI B31.1.0. FSAR

Table 3.2-1 supports the determination that the day tank vent lines are not

safety-related. Per FSAR Section 9.5.4.3, the diesel generator fuel oil system is

Seismic Category I. Therefore, the vent lines are within the scope of license

renewal and are highlighted in pink (magenta) per LR-M-100-4 Note A2 up to the

point where they exit the diesel generator building as they have the potential for

spatial interaction with safety-related components. The boundary is extended

through the end of the vent piping for the day tank, including the flame arrestor.

The vent piping and flame arrestors perform a structural integrity function and

are evaluated under the component type of "piping and piping components." In

PPL's response to RAI 2.1-3, LRA Table 2.3.3-7 was amended to include a line

item for piping and piping components which perform a structural integrity

function. The PPL response to RAI 2.1-3, (Reference 3), also amended LRA

Table 3.3.2-7 to include the aging management evaluation for carbon steel

piping and piping components subject to an internal ventilation environment and

an external outdoor air environment. No further changes to LRA Table 2.3.3-7 or

Table 3.3.2-7 are required in response to this RAI.

The staff confirms that the applicant has submitted revised boundary drawings

LR-M-134-1 and LR-M-134-7 and also a revision to Note 0361 in LRA

Section 3.3 to address the response to this RAI.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.7-2 acceptable

because the applicant satisfactorily explained why in-scope flame arrestors are not included in

LRA Table 2.3.3-7 and why flame arrestors are shown within the scope of license renewal for

different reasons. The staff confirms that the applicant has made appropriate revisions to

boundary drawings LR-M-134-1 and LR-M-134-7 and added plant-specific Note 0361 to the

LRA. Therefore, the staff's concern described in RAI 2.3.3.7-2 is resolved.

In RAI 2.3.3.7-3, dated August 27, 2007, the staff noted that DG fuel oil storage tank flame

arrestors are shown on boundary drawings LR-M-120-1, locations B3, D3, E3, and G3, and LRM-120-2, location F3 to C3. The flame arrestors are not shown within the scope of license

renewal. Flame arrestors are typically included within the scope of license renewal because

they are classified as a component subject to an AMR within the pressure boundary for the

diesel fuel oil tanks. The staff requested that the applicant explain why the flame arrestors are

not within the scope of license renewal.

In its response to RAI 2.3.3.7-3, dated October 18, 2007, the applicant stated:

As shown on license renewal drawings LR-M-120-1 and LR-M-120-2, the vent

line piping and the associated flame arrestors for the diesel fuel oil storage tanks

are not within the scope of license renewal. The vent lines extend from the top of

2-61
the storage tank within the buried vault to above ground where the piping is

goose-necked and provided with flame arrestors. The vent piping is located

above the fuel oil level within the storage tanks and therefore does not provide a

pressure boundary function.

The vent lines for the diesel fuel oil storage tanks on drawing LR-M-1 20-1 and

LR-M-120-2 are nonsafety-related but are seismically qualified. This is supported

by the HBD line designation which indicates that the piping is classified as ANSI

B31.1.0. FSAR Table 3.2-1 supports the determination that the storage tank vent

lines are not safety-related. Per FSAR Section 9.5.4.3, the diesel generator fuel

oil system is Seismic Category I.

The flame arrestors on the diesel storage tank vent lines are not classified as

safety-related. FSAR Section 9.5.4.2 states for the fuel oil storage tank vent line

that if the above grade section of the vent is damaged, it would not render the

fuel oil storage tank inoperable. This determination also applies to the flame

arrestors located above grade on the vent piping. The flame arrestors do not

perform a license renewal intended function. In addition, the vent line and flame

arrestor do not provide any support for the safety-related tank to which they are

attached. Therefore, the flame arrestors on the diesel fuel oil storage tank vent

lines are not within the scope of license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.7-3 acceptable

because the applicant satisfactorily explained why these diesel fuel oil tank vent lines and flame

arrestors are not within the scope of license renewal. Therefore, the staff's concern described in

RAI 2.3.3.7-3 is resolved.

In RAI 2.3.3.7-4, dated August 27, 2007, the staff noted that the DG storage tank manhole

covers shown in boundary drawing LR-M-120-1, locations 82, D2, F3, and G3, are not shown

within the scope of license renewal. The staff requested that the applicant explain why the

manhole covers are not shown within the license renewal scope boundary.

In its response to RAI 2.3.3.7-4, dated October 18, 2007, the applicant stated:

The diesel generator storage tank manholes and covers shown on drawing LRM-120-1 are within the scope of license renewal. A highlighting error resulted in

the manholes and covers on drawing LR-M-120-1 not being indicated as within

the scope of license renewal.

The manholes and covers are considered to be part of the pressure boundary of

the storage tanks. This is reflected by the highlighting of the manholes and

covers for the E diesel generator storage tank on drawing LR-M-120-2.

No changes are required to Table 2.3.3-7 or Table 3.3.2-7, the manholes are

included in the line item for "Tanks (0T527A-E, OT528A-E)." The component

types are therefore subject to aging management review and have been

evaluated with the storage tanks.

2-62
The staff confirms that the applicant has submitted revised boundary drawing LR-M-120-1.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.7-4 acceptable

because the applicant has clarified that the manhole covers are within the scope of license

renewal and has made the appropriate revisions to boundary drawing LR-M-120-1. Therefore,

the staff's concern described in RAI 2.3.3.7-4 is resolved.

In RAI 2.3.3.7-5, dated August 27, 2007, the staff noted that boundary drawing LR-M-1 20-1,

locations B7, D7, E7, and G7, indicate that there are manhole covers on top of the DG day

tanks A, B, C, and D. However, boundary drawing LR-M-1 34-1, location F8, does not show a

manhole cover on the top of DG day tanks A, B, C, and D. The staff requested that the

applicant explain whether or not there are manhole covers on the four tanks and whether there

are manhole covers on these tanks, explain why they are not shown on boundary drawing LRM-1 34-1 and why they are not within the scope of license renewal.

In its response to RAI 2.3.3.7-5, dated October 18, 2007, the applicant stated:

As stated in FSAR Section 9.5.4.2, a manhole is provided on each diesel

generator fuel oil day tank for inspection. The manholes are depicted on license

renewal drawing LR-M-120-1 due to space limitations on drawing LR-M-134-1.

The dashed lines for tanks 0T528 A, B, C, and D on drawing LR-M-120-1

indicate that the components are represented on another drawing (LR-M-134-1).

The manholes and covers associated with the diesel generator fuel oil day tanks

on LR-M-120-1 are solid lines indicating that they are represented on drawing

LR-M-120-1.

It was determined that the diesel generator day tank manholes and covers

shown on drawing LR-M-120-1 should be shown as within the scope of license

renewal. The manholes and covers are part of the pressure boundary of the

storage tanks.

No changes are required to Table 2.3.3-7 or Table 3.3.2-7. The manholes and

covers for the diesel generator day tank shown in drawing LR-M-134-7 are

shown within the license renewal evaluation boundary. The component types are

therefore subject to aging management review and have been evaluated with the

tanks.

The staff confirms that the applicant has submitted revised boundary drawing LR-M-120-1.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.7-5 acceptable

because the applicant: (a) clarified that the manhole covers are within the scope of license

renewal, (b) explained why the manhole covers were not shown on boundary drawing

LR-M-134-7, and (c) made the appropriate revisions to boundary drawing LR-M-120-1.

Therefore, the staff's concern described in RAI 2.3.3.7-5 is resolved.

In RAI 2.3.3.7-6, dated August 27, 2007, the staff noted that boundary drawing LR-M-1 34-7,

location A6, indicates that there is a manhole cover on top of the DG day tank E and that it is

within the scope of license renewal. The staff requested that the applicant explain why the

manhole cover is not listed in LRA Table 2.3.3-7 for components subject to an AMR.

2-63
In its response to RAI 2.3.3.7-6, dated October 18, 2007, the applicant stated:

The manhole and cover depicted on license renewal drawing LR-M-1 34-7 is

within the scope of license renewal. The manhole and cover are considered to

be an integral part of the tank component. Therefore, the "Tanks (0T527A-E,

0T528A-E)" entry in Table 2.3.3-7 includes the associated manholes and covers.

The manhole and cover perform the same pressure boundary function as the

tank.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.7-6 acceptable

because the applicant has explained that the manholes and covers are within the scope of

license renewal and are an integral part of the tank component type listed in LRA Table 2.3.3-7.

Therefore, the staff's concern described in RAI 2.3.3.7-6 is resolved.

2.3.3.7.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and boundary drawings to determine

whether the applicant failed to identify any components within the scope of license renewal. In

addition, the staff's review determined whether the applicant failed to identify any components

subject to an AMR. On the basis of its review, the staff concludes the applicant has

appropriately identified the diesel fuel oil system mechanical components within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the control diesel fuel oil system mechanical components subject to an AMR in

accordance with the requirements of 10 CFR 54.21(a)(1) and therefore, the response is

acceptable.

2.3.3.8 Diesel Generator Building HVAC Systems

2.3.3.8.1 Summary of Technical Information in the Application

LRA Section 2.3.3.8 describes the diesel generator (DG) building HVAC systems, which

maintain a suitable environment for the DGs during all modes of operation. The DG buildings

HVAC systems contain safety-related components relied upon to remain functional during and

following DBEs. In addition, the DG buildings HVAC systems perform functions that support fire

protection. LRA Table 2.3.3-8 identifies DG buildings HVAC systems component types within

the scope of license renewal and subject to an AMR.

2.3.3.8.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that the applicant has

appropriately identified the DG building HVAC systems mechanical components within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the system components subject to an AMR in accordance with the requirements

stated in 10 CFR 54.21(a)(1).

2-64
2.3.3.9 Diesel Generator System

2.3.3.9.1 Summary of Technical Information in the Application

LRA Section 2.3.3.9 describes the DGs system consisting of five DGs, only four of which can

be aligned to the safety-related load groups. The DGs system contains safety-related

components relied upon to remain functional during and following DBEs. The failure of

nonsafety-related SSCs in the DGs system potentially could prevent the satisfactory

accomplishment of a safety-related function. In addition, the DGs system performs functions

that support fire protection, ATWS, SBO, and EQ. LRA Table 2.3.3-9 identifies DGs system

component types within the scope of license renewal and subject to an AMR.

2.3.3.9.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the DG system mechanical components within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

system components subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2.3.3.10 Domestic Water System

2.3.3.10.1 Summary of Technical Information in the Application

LRA Section 2.3.3.10 describes the domestic water system, which provides cold and hot water

acceptable for human consumption to plumbing fixtures for the entire plant. The failure of

nonsafety-related SSCs in the domestic water system potentially could prevent the satisfactory

accomplishment of a safety-related function. LRA Table 2.3.3-10 identifies domestic water

system component types within the scope of license renewal and subject to an AMR.

2.3.3.10.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, and UFSAR, the staff concludes that applicant has appropriately identified the domestic

water system mechanical component types within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the system component types

subject to an AMR in accordance with the requirements stated in 10 CFR 54.21(a)(1).

2.3.3.11 Emergency Service Water System

2.3.3.11.1 Summary of Technical Information in the Application

LRA Section 2.3.3.11 describes the ESW system consisting of two loops, each designed to

supply simultaneously 100 percent of the ESW requirements to both units and to the common

emergency DGs. The ESW system contains safety-related components relied upon to remain

functional during and following DBEs. The failure of nonsafety-related SSCs in the ESW system

potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the ESW system performs functions that support fire protection, ATWS, SBO, and EQ.

2-65
LRA Table 2.3.3-11 identifies ESW system component types within the scope of license

renewal and subject to an AMR.

2.3.3.11.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.11, UFSAR Section 9.2.5, and the licensing renewal

boundary drawings using the evaluation methodology described in SER Section 2.3 and the

guidance in SRP-LR Section 2.3. The staff's review 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 RAIs as discussed below.

In RAI 2.3.3.11-1, dated August 27, 2007, the staff noted that boundary drawings LR-M-186-3

and LR-M-186-4 depict ESW piping to and from the ESW bundles (OS117A2 and OS117B2).

LRA Section 2.3.3.11, "Emergency Service Water System," paragraph titled "Drawings" does

not include LR-M-186-3 or LR-M-186-4 for Unit 1, as applicable boundary drawings. The staff

requested that the applicant clarify that ESW piping to and from the ESW bundles (OS117A2

and OS1 17B2) is within the ESW system and whether boundary drawings LR-M-186-3 and

LR-M-186-4 are applicable references in LRA Section 2.3.3.11.

In its response to RAI 2.3.3.11-1, dated October 18, 2007, the applicant stated in part:

The ESW piping to and from the ESW bundles (OS1i17A2 and OS1i17B2) shown

on LR-M-186-3 and LR-M-186-4, respectively, is within the scope of license

renewal and subject to AMR. This ESW piping to and from the ESW bundles is

scoped as part of the Control Structure Chilled Water System, rather than as

part of ESW, and is included in LRA Section 2.3.3.4 and associated Table 2.3.3-

4. Therefore, drawings LR-M-186-3 and LR-M-186-4 are not applicable

references for LRA Section 2.3.3.11.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.11-1 acceptable

because the applicant has clarified that the piping in question is within the scope of license

renewal as part of the control structure chilled water system rather than the ESW system.

Therefore, the staff's concern described in RAI 2.3.3.11-1 is resolved.

In RAI 2.3.3.11-2, dated August 27, 2007, the staff noted that LRA Table 2.3.3-11, "Emergency

Service Water System Components Subject to Aging Management Review," does not contain

flexible connectors as a component type subject to AMR. The staff requested that the applicant

explain why the flexible connectors are not listed as components subject to an AMR in LRA

Table 2.3.3-11.

In its response to RAI 2.3.3.11-2, dated October 18, 2007, the applicant stated in part that the

room unit coolers listed in RAI 2.3.3.11-2:

... are in the scope of license renewal and are subject to AMR. The flexible

connections associated with each unit cooler are scoped in the same system as

the unit cooler itself, not in the ESW system. Based on PPL's scoping

methodology, these unit coolers, including the flexible connections associated

with them, are all scoped with the Reactor Building HVAC System. The flexible

connections are included in LRA Section 2.3.3.24 and the associated

Table 2.3.3-23.

2-66
Based on its review, the staff finds the applicant's response to RAI 2.3.3.11-2 acceptable

because the applicant has clarified that the flexible connections in question are within the scope

of license renewal and subject to AMR, but are part of the RB HVAC system rather than the

ESW system. Therefore, the staff's concern described in RAI 2.3.3.11-2 is resolved.

2.3.3.11.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and boundary drawings to determine

whether the applicant failed to identify any components within the scope of license renewal. In

addition, the staff's review determined whether the applicant failed to identify any components

subject to an AMR. On the basis of its review, the staff concludes the applicant has

appropriately identified the emergency SWS mechanical components within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the emergency SWS mechanical components subject an AMR in accordance with the

requirements of 10 CFR 54.21(a)(1) and therefore, the response is acceptable.

2.3.3.12 Engineered Safeguards Service Water Pumphouse HVAC System

2.3.3.12.1 Summary of Technical Information in the Application

LRA Section 2.3.3.12 describes the ESSW pumphouse HVAC system, which maintains a

suitable environment in the pumphouse for the emergency service water (ESW) and RHRSW

system pumps and their appurtenances. The ESSW pumphouse HVAC system contains safetyrelated components relied upon to remain functional during and following DBEs. In addition, the

ES SW pumphouse HVAC system performs functions that support fire protection. LRA

Table 2.3.3-12 identifies ES SW pumphouse HVAC system component types within the scope

of license renewal and subject to an AMR.

2.3.3.12.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the ESSW pumphouse HVAC system mechanical components within

the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has

adequately identified the system components subject to an AMR in accordance with the

requirements stated in 10 CFR 54.21(a)(1).

2.3.3.13 Fire Protection System

2.3.3.13.1 Summary of Technical Information in the Application

LRA Section 2.3.3.13 describes the fire protection system, which minimizes both the probability

and consequences of postulated fires. The fire protection system contains nonsafety-related

components relied upon to remain functional during and following DBEs. The failure of

nonsafety-related SSCs in the fire protection system potentially could prevent the satisfactory

accomplishment of a safety-related function. In addition, the fire protection system performs

functions that support fire protection. LRA Table 2.3.3-13 identifies fire protection system

component types within the scope of license renewal and subject to an AMR.

2-67
2.3.3.13.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.13, UFSAR Section 9.5.1, the Fire Protection Review

Report and the following fire protection CLB documents, using the evaluation methodology

described in SER Section 2.3 and the guidance in SRP-LR Section 2.3:

" NUREG-0776, "Safety Evaluation Report Related to the Operation of Susquehanna

Steam Electric Station, Units 1 and 2," April 1981

" NUREG-0776, Supplement No. 1, June 1981

* NUREG-0776, Supplement No. 2, September 1981

" NUREG-0776, Supplement No. 3, July 1982

" NUREG-0776, Supplement No. 4, November 1982

" NUREG-0776, Supplement No. 6, March 1984

" Safety Evaluation of Fire Protection Report, August 9, 1989

" Safety Evaluation of Revision 4 to the Fire Protection Review Report, March 29, 1993

" Safety Evaluation of Fire Protection Program Issues, Safe-Shutdown Methodology and

Analysis of Associated Circuits dated October 21, 1997

" Safety Evaluation of the Licensees' Amendment No. 177, June 24, 1989

In conducting its review, the staff evaluated the system functions described in the LRA and

UFSAR in accordance with the requirements of 10 CFR 54.4(a), to verify that the applicant had

not omitted from the scope of license renewal any components with intended functions pursuant

to 10 CFR 54.4(a). The staff then reviewed those components the applicant identified as being

within the scope of license renewal to verify that the applicant had not omitted any passive or

long-lived components subject to an AMR in accordance with 10 CFR 54.21(a)(1).

The staff also reviewed the applicant's commitments to 10 CFR 50.48, "Fire protection" (i.e.,

approved fire protection program), using the applicant's commitment documents to the Branch

Technical Position (BTP) Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1,

"Guidelines for Fire Protection for Nuclear Power Plants," May 1, 1976, and Appendix A to BTP

APCSB 9.5-1, August 23, 1976, documented in the Fire Protection Review Report.

The staff's review of LRA Section 2.3.3.13 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 RAIs as discussed below.

In RAI 2.3.3.13-1, dated June 22, 2007, the staff noted the LRA boundary drawing LR-M-122,

Sheet No. 1, "Fire Pumphouse, North & South Gatehouse & Security Control Center Buildings,"

shows the jockey pump and associated components as not within the scope of license renewal

(i.e., not colored in green). SER Section 9.5.1.1 (NUREG-0776), dated April 1981, states that a

separate jockey pump automatically maintains the yard fire main pressure. The jockey pump

and its associated components appear to have fire protection intended functions required for

compliance with 10 CFR 50.48, pursuant to 10 CFR 54.4(a)(3). The staff requested that the

applicant verify whether the jockey pump and its associated components are within the scope of

license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR, in accordance with

10 CFR 54.21 (a)(1 ) and; if excluded, provide justification.

2-68
In its response to RAI 2.3.3.13-1, dated July 24, 2007, the applicant stated in part:

The jockey fire pump and associated components, shown on LRA boundary

drawing LR-M-122, Sheet 1, are not in the scope of license renewal and,

therefore, are not subject to an AMR. The jockey pump does not have fire

protection intended functions required for compliance with 10 CFR 50.48.

In evaluating the applicant's response to RAI 2.3.3.13-1, the staff found it was incomplete and

that review of LRA Section 2.3.3.13 could not be completed. The staff notes the applicant's

statement that the jockey pump does not have fire protection intended functions required for the

compliance with 10 CFR 50.48. However, the staff finds this statement contrary to the

applicant's fire protection commitment to BTP APCSB 9.5-1, Appendix A, documented in SER

Section 9.5.1.1 (April 1981), which is used as the CLB. The commitment states in part, "a

separate jockey pump automatically maintains yard main pressure from 105 to 125 psi. The fire

pumps start automatically on low header pressure."

The applicant indicated in its response to RAI 2.3.3.13-1 that the jockey pump in question, was

not within the scope of license renewal because the jockey pump is not required to function to

suppress a fire or supply required fire protection water. Therefore, the applicant used criteria

pursuant to 10 CFR 54.4(a)(2) to exclude the jockey pump. Since there is no adverse effect due

to the jockey pump failure, the applicant excludes this component on that basis, and has

neglected the fact that this component is relied upon to comply with 10 CFR 50.48 (pursuant to

the CLB), as stated in 10 CFR 54.4(a)(3).

The staff held a telephone conference with the applicant on October 3, 2007, to discuss

information necessary to resolve its concern in RAI 2.3.3.13-1. During the teleconference, the

staff explained that the scope of SSCs required for compliance with 10 CFR 50.48 and

10 CFR Part 50, Appendix A, General Design Criteria (GDC) 3, goes beyond preserving the

ability to maintain safe-shutdown in the event of a fire. The staff stated that exclusion of fire

protection SSCs, on the basis that the intended function is not required for the protection of

safe-shutdown equipment or safety-related equipment, is not acceptable, whether the SSC is

required for compliance with 10 CFR 50.48.

The applicant's CLB demonstrates that, in accordance with GDC 3, this component was

credited to meet the guidance of BTP APCSB 9.5-1, Appendix A. Therefore, the jockey pump in

question should not be excluded from the scope of license renewal. In addition, this component

should not be excluded on the basis that it is not required to function to suppress a fire, without

factoring in the CLB, nor is it required for compliance with 10 CFR 50.48.

By letter dated October 24, 2007, the applicant responded in part that "Based on discussion

with the NRC, the jockey fire pump and associated components, shown on LRA boundary

drawing LR-M-122, Sheet 1, have been included within the scope of license renewal, and are

subject to an AMR."

The staff confirms that the applicant has submitted revised boundary drawing LR-M-122-1 and

has amended LRA Tables 2.3.3-13 and 3.3.2-13 to include the jockey fire pump and associated

components as within the scope of license renewal and subject to an AMR.

2-69
Based on its review, the staff finds the applicant's response to RAI 2.3.3.13-1 acceptable

because the applicant has committed to meet the CLB based on the guidance of Appendix A of

BTP APCSB 9.5-1. The staff is adequately assured that the jockey pump and associated

components used for the fire suppression will be appropriately considered during aging

management activities. Therefore, the staff's concern described is RAI 2.3.3.13-1 is resolved.

In RAI 2.3.3.13-2, dated June 22, 2007, the staff noted the following LRA boundary drawings

show fire protection system components as not within the scope of license renewal (i.e., not

colored in green):

LR-M-122 Sheet 1, "Fire Pumphouse, North & South Gatehouse & Security Control

Center Buildings," shows Diesel Oil Day Tank (0T508) vent line and the fill capassembly line, piping, fittings, and drains as out of scope (i.e., not colored in green)

" LR-M-122 Sheet 2, "Turbine Bldg. (TB), Control Structure and Radwaste Building,"

shows several fire suppression systems and components in TB for Units 1 and 2 as out

of scope (i.e., not colored in green)

" LR-M-122 Sheet 3, "Reactor Bldg., Standby D G, River Intake Structure Service and

Admin. Bldg. & Circ. Water Pumphouse " shows several fire suppression systems and

components in TB for Units 1 and 2, as out of scope (i.e., not colored in green)

" LR-M-122 Sheet 4, "Carbon Dioxide System," shows several components as out of

scope (i.e., not colored in green)

The staff requested that the applicant verify whether the above fire suppression systems and

components are within the scope of license renewal, in accordance with 10 CFR 54.4(a) and

subject to an AMR, in accordance with 10 CFR 54.21(a)(1) and; if not, provide justification for

the exclusion.

In its response to RAI 2.3.3.13-2, dated July 24, 2007, the applicant stated:

LR-M-122 Sheet 1

The Diesel Oil Day Tank (0T508) vent line and the fill cap-assembly line, piping,

fittings, and drains have no license renewal function, are not in license renewal

scope and are not subject to AMR. These vent and fill lines, as well as the return

(drain) line from the diesel engine to the tank, are above the tank's normal oil

level and the tank is vented to atmosphere. As described in the FPRR, the tank

contains enough diesel fuel oil for 8 hours of operation in accordance with NFPA

20. Failure of these components will not create a leakage path that would drain

the tank and will not prevent the diesel fire pump from accomplishing its

Appendix R function.

The components that do have a license renewal intended function in support of

the diesel engine driven fire pump, the day tank, tubing and flexible connections,

as well as the drain line and valve for the day tank, are in the scope of license

renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in

accordance with 10 CFR 54.21(a)(11), as listed

in LRA Table 2.3.3-13 and shown (highlighted in green) on LRA drawing LR-M122 Sheet 1.

2-70
LR-M-122 Sheet 2

As stated in LRA Section 2.1.1.2.2, no components in the TB either perform a

safety function or would prevent a safety-related function from occurring. With

few exceptions, there are no fire suppression systems or components in the TB

that are credited with protection of safety-related or safe shutdown equipment.

LRA Section 2.1.1.3.1 discusses scoping of the fire protection system to achieve

and maintain safe shutdown; that is features required for fire protection of safetyrelated equipment and any system function that were included in, or provide

necessary support for, one or more of the three (3) safe shutdown paths credited

for compliance with Appendix R. SSCs that perform an intended function for fire

protection are included in the scope of license renewal. These include certain

hose stations (1/2HR-101 and 1/2HR-156) and sprinkler systems (e.g., DS-0 15,

PA-091, PA-092, and PA-1/26 1), which are shown as being located in the TB on

LRA drawing LR-M-122 Sheet 2, and are credited with protection of control

structure and transformer yard components. Section 3.7.3.5 and 3.7.3.2 of the

Technical Requirements Manual (TRM) identify the fire hose stations and the

spray and sprinkler systems, respectively, that are credited for safety-related and

safe-shutdown protection.

Except for the header piping and components and those suppression systems

and components discussed above, the remaining suppression systems and

components in the TB are not credited for safety-related or safe-shutdown fire

protection. Therefore, except as indicated above and on LRA Drawing LR-M-122

Sheet 2, the fire suppression systems and components located in the TB are not

in license renewal scope and are not subject to an AMR.

LR-M-122 Sheet 3

As described above in response to the question on LR-M-1 22, Sheet 2, the

suppression systems and components that are credited for safety-related and

safe-shutdown protection are in the scope of license renewal. This includes fire

hydrant FH-104, which is credited with protection of diesel generator building

components, and suppression station DS-014, which is credited for protection of

a transformer adjacent to the Circ. Water Pumphouse. Except as noted, neither

the Turbine Building, Circ. Water Pumphouse nor River Intake Structure facilities

contain safety-related equipment nor equipment relied upon by the safe

shutdown analysis. The applicant stated that, therefore, except as noted above,

the fire suppression systems and components in these structures do not satisfy

the requirements of 10 CFR 54.4, are not in license renewal scope and are not

subject to an AMR.

LR-M-122 Sheet 4

While it is briefly mentioned in NUREG-0776 Section 9.5.1.3, the generator

purge portion of the carbon dioxide system is not credited with safety-related or

safe-shutdown protection. As such, there are two pipe sections in the lower, left

hand comer of drawing LR-M-1 22, Sheet 4, that are not in the scope of license

renewal. The "fill line" and the "equalizing line" for generator purge are isolated

from the CO2 storage tank by normally closed valves and do not have a license

renewal function. The applicant stated that, therefore, neither portion of the

2-71
piping and associated components is in license renewal scope (i.e., is not

highlighted in green).

Valves PSV02269, PSV02270, PSV02271 and the piping between those valves

and valve 022978 have conservatively been highlighted green as in-scope and

subject to an AMR. The piping is carbon steel and the valves are bronze. In

addition the piping from valve 022979 through 0CB650 is in-scope and subject to

an AMR, but was inadvertently not highlighted. Both portions of pipe have been

highlighted green on the revised boundary drawing in the attachment to this

letter. No changes to the LRA are required as the material/environment

combinations of this additional highlighting are already covered in

Table 3.3.2-13.

In evaluating the applicant's response to RAI 2.3.3.13-2, the staff found it was incomplete and

that review of LRA Section 2.3.3.13 could not be completed. The applicant explained in its

response that the fire protection SSCs in question are not credited for safety-related and

safe-shutdown. Exclusion of fire protection SSCs on the basis that its intended function is not

required for the protection of safe-shutdown equipment or safety-related equipment is not

acceptable, whether that SSC is required for compliance with 10 CFR 50.48 (i.e., required to

meet Appendix A to BTP APSCB 9.5-1). Therefore, the staff concludes that these components

should be included within the scope of license renewal and subject to an AMR. The staff held a

telephone conference with the applicant on October 3, 2007, to discuss information necessary

to resolve the staff's concern described in RAI 2.3.3.13-2.

The staff explained that the scope of fire protection SSCs discussed above were excluded on

the basis that they were not "protecting" safety-related or safe-shutdown equipment, even

though they were accepted for compliance with the provisions of Appendix A to BTP APSCB

9.5-1. Furthermore, the scoping requirements of 10 CFR 54.4 states that SSCs are included

in-scope, which demonstrate compliance with 10 CFR 50.48. Therefore, if the SSCs were

installed in compliance with 10 CFR 50.48, then they should be included within the scope of

license renewal.

The staff finds that the applicant's analysis of fire protection regulation does not completely

capture the fire protection SSCs required for compliance with 10 CFR 50.48. The scope of

SSCs required for compliance with 10 CFR 50.48 and GDC 3 goes beyond preserving the

ability to maintain safe-shutdown in the event of a fire. GDC 3 states in part, that "fire detection

and fighting systems of appropriate capacity and capability shall be provided and designed to

minimize the adverse effects of fires on structures, systems, and components important to

safety." Furthermore, the general requirements provided in GDC 3 to "minimize the adverse

effects of fires on SSCs important to safety" are stated to provide a general level of protection

which is afforded to all systems, not only where required to prevent a loss of safe-shutdown

capability. 10 CFR 50.48(a) states that "each operating nuclear power plant must have a fire

protection plan that satisfies Criterion 3 of Appendix A of this part." The term "important to

safety" encompasses a broader scope of equipment beyond safety-related and safe-shutdown.

Though there is a focus on the protection of safety-related equipment or safe-shutdown

equipment, this does not imply that there is an exclusion of any equipment which protects

nonsafety-related equipment. For example, in accordance with 10 CFR 50.48, some portions of

suppression systems may be required in plant areas where a fire could result in the release of

radioactive materials to the environment, even if no safety-related or safe-shutdown equipment

is located in that particular fire area.

2-72
In its response, dated October 24, 2007, the applicant stated, in part, that in LRA boundary

drawing LR-M-122, Sheet 1, "The Diesel Oil Day Tank (0T508) vent line and the fill

cap-assembly line, piping, fittings, and drains have no license renewal function, are not in

license renewal scope and are not subject to AMR." Further, the applicant stated that the LRA

boundary drawings LR-M-1 22, Sheet 2 and LR-M-122, Sheet 3 (Turbine Building, Circ. Water

Pumphouse, and River Intake Structure fire suppression systems and components) in question

were for loss prevention and insurance purposes. Turbine Building fire suppression systems do

not protect safety-related equipment, nor are addressed in PPL's response to BTP APSCB 9.5-

1, Revision 0, Appendix A, and are not credited in the 10 CFR Part 50, Appendix R safeshutdown analysis.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.13-2 acceptable

because the applicant has adequately explained that the fire suppression systems and

components in question are not credited for 10 CFR 50.48 and GDC 3. The staff confirms that

these fire water suppression systems are for property protection and for loss prevention. The

staff determines that the applicant correctly excluded the fire suppression systems and

components in question on the basis that they are not required for compliance with

10 CFR 50.48. The staff notes the applicant's interpretation of these components as active

(short-lived components), which necessarily will result in more vigorous oversight of the

condition and performance of the components. The applicant concurs. Further, the staff notes

that the applicant has considered certain fire protection systems and components as only

required to protect nonsafety-related equipment and; thus, satisfies requirements of the plant

insurance carrier. The staff concludes that these fire protection systems and components were

correctly excluded from the scope of license renewal and from being subject to an AMR.

Therefore, the staff's concerns described in RAI 2.3.3.13-2 are resolved.

In RAI 2.3.3.13-3, dated June 22, 2007, the staff stated that SER Section 9.5.1.2

(NUREG-0776, dated April 1981), listed sprinkler and standpipe systems provided in the plant

areas for fire suppression activities. These systems were installed in the following areas:

* Reactor Core Isolation Cooling Pump Room

* High Pressure Coolant Injection Pump Room

• Heating, Ventilation, and Air-Conditioning Filter Rooms

* Railroad Airlock

* Control Building Auxiliary Rooms

* Condenser Area

* Reactor Feed Pump Turbine

* Turbine Central Area

* Turbine Condenser Gallery

* Turbine Hydro Control Power Room

* North Railroad Bay

* Turbine Condenser Mezzanine

* Diesel Engine Fire Pump Room

* Lower Cable Spreading Room (CSR)

* Upper CSR

* RFP Turbine Room

• Diesel Generator Building

" Charcoal Filters

* Standby Gas Treatment Filters

2-73
* Emergency Outside Air Filters

* Centrifuge & Conditioner

* Turbine Pump Area

* Turbine Hydro Seal Oil Unit

* Turbine Lube Oil Area

* Turbine Motor Generator Area

" Turbine Filter Room

" Turbine Moisture Separation Area

* Radwaste Tank Vent Filter Room

* Radwaste Auxiliary Rooms

* Radwaste Controlled Zone Shop

The staff requested that the applicant verify whether the sprinkler and standpipe systems

installed in the above areas of the plant are within the scope of license renewal, in accordance

with 10 CFR 54.4(a) and subject to an AMR, in accordance with 10 CFR 54.21(a)(1) and; if

excluded, provide justification.

In its response to RAI 2.3.3.13-3, dated July 24, 2007, the applicant stated:

The fire sprinkler and standpipe systems installed in the locations noted by this

RAI are listed in two groups below. The first group includes those systems which

are in the scope of license renewal and subject to an AMR. The second group

includes those systems that are not within the scope of license renewal and are

not subject to an AMR, for which justification is provided.

The sprinkler and standpipe systems for the following areas are in the license

renewal scope, and are subject to an AMR. The fire protection components

associated with these systems are addressed in the LRA in Sections 2.3.3.13,

3.3.2.1.13, Tables 2.3.3-13 and 3.3.2-13. In addition, the table below lists the

boundary drawing, with coordinates, on which the related sprinkler and/or

standpipe is shown as in-scope (highlighted in green).

Location

Reactor Core Isolation Cooling Pump Room

High Pressure Coolant Injection Pump Room

Heating, Ventilation, and Air-Conditioning Filter

Rooms

Railroad Airlock

Control Building Auxiliary Rooms

Lower Cable Spreading Room (CSR)

Upper CSR

LRA Drawing

(Coordinates)

LR-M-122, Sheet 3

(B4, B5)

LR-M-122, Sheet 3

(C4, B5)

LR-M-122, Sheets 3

(A4, B4, A5, B5)

LR-M-122, Sheet 3

(D5)

LR-M-122, Sheet 2

(F4, F5)

LR-M-1 22, Sheet 2

(F3, F5)

LR-M-122, Sheet 2

(F3, F6)

2-74
Diesel Generator Building LR-M-122, Sheet 3

(C8, D8, E7)

Charcoal Filters LR-M-122, Sheet 3

(A4, B4, A5, B5)

Standby Gas Treatment Filters LR-M-122, Sheet 2

(G6), LR-VC-175,

Sheet 3

Emergency Outside Air Filters LR-M-122, Sheet 2

(G6), LR-VC-178,

Sheet 1

The sprinkler and standpipe systems for the following areas are not in the

license renewal scope and are not subject to an AMR. Except for the diesel

engine fire pump room, these sprinkler and standpipe systems are located in the

TB and the radwaste building. Consistent with the guidelines of Appendix A to

BTP APSCB 9.5-1, the diesel engine driven and motor driven fire pumps are

located in rooms separated by a three hour fire wall. In particular, the diesel

engine driven fire pump is located in a room enclosed by three hour fire rated

walls, doors, and duct penetrations; whereas the motor driven fire pump is

located in the main pump room with the service water pumps and circulating

water pumps. This area (fire area A-I) has a low combustible loading. The

sprinkler and standpipe systems in following areas do not protect safety-related

equipment and are not credited in the Appendix R safe shutdown analysis:

" Condenser Area

" Reactor Feed Pump Turbine

* Turbine Central Area

" Turbine Condenser Gallery

" Turbine Hydro Control Power Room

• North Railroad Bay

* Turbine Condenser Mezzanine

" Diesel Engine Fire Pump Room

" PFP Turbine Room*

* Centrifuge & Conditioner

* Turbine Pump Area

* Turbine Hydro Seal Oil Unit

* Turbine Lube Oil Area

* Turbine Motor Generator Area

* Turbine Filter Room

" Turbine Moisture Separation Area

" Radwaste Tank Vent Filter Room

* Radwaste Auxiliary Rooms

* Radwaste Controlled Zone Shop

Evaluated as the "Reactor Feed Pump (RFP) Turbine Room"

In evaluating the applicant's response to RAI 2.3.3.13-3, the staff found that it was incomplete

and that review of LRA Section 2.3.3.13 could not be completed. The staff notes the applicant's

explanation that the sprinkler and standpipe systems in the areas listed above do not support

SSES post-fire safe-shutdown requirements. The staff finds the applicant's explanation contrary

to the April 1981 SSES fire protection SER, as the CLB. The staff held a telephone conference

2-75
with the applicant on October 3, 2007, to discuss information necessary to resolve the staff's

concern described in RAI 2.3.3.13-3. During the teleconference, the staff noted that the

applicant had committed to satisfy BTP APCSB 9.5-1, Appendix A, Regulatory Position A.4,

"Fire Suppression Systems," by providing certain equipment for the fire protection program that

is also considered "important to safety."

The staff found that the applicant's analysis of fire protection regulations does not completely

capture the fire protection SSCs required for compliance with 10 CFR 50.48. The scope of

SSCs required for compliance to 10 CFR 50.48 and GDC 3 goes beyond preserving the ability

to maintain safe-shutdown in the event of a fire. GDC 3 states in part, that "fire detection and

fighting systems of appropriate capacity and capability shall be provided and designed to

minimize the adverse effects of fires on structures, systems, and components important to

safety." Furthermore, the general requirements provided in GDC 3 to "minimize the adverse

effects of fires on SSCs important to safety" are stated to provide a general level of protection

which is afforded to all systems, not only where required to prevent a loss of safe-shutdown

capability." 10 CFR 50.48(a) states that "each operating nuclear power plant must have a fire

protection plan that satisfies Criterion 3 of Appendix A of this part."

The term "important to safety" encompasses a broader scope of equipment than safety-related

and safe-shutdown equipment. Though there is a focus on the protection of safety-related

equipment or safe-shutdown equipment, this does not imply that there is an exclusion of any

equipment which protects nonsafety-related equipment. For example, in accordance with

10 CFR 50.48, some portions of suppression systems may be required in plant areas where a

fire could result in the release of radioactive materials to the environment, even if no

safety-related or safe-shutdown equipment is located in that particular fire area.

In its response dated October 24, 2007, the applicant stated that as identified in RAI 2.3.3.13-3,

sprinkler and standpipe systems in the Condenser Area, Turbine Central Area, Turbine

Condenser Gallery, Turbine Hydro Control Power Room, North Railroad Bay, Turbine

Condenser Mezzanine, Diesel Engine Fire Pump Room, Turbine Pump Area, Turbine Filter

Room, Turbine Moisture Separation Area, Radwaste Tank Vent Filter Room, Radwaste

Auxiliary Rooms, and Radwaste Controlled Zone Shop are not within the scope of license

renewal. The applicant verified that these systems are used for property protection. The

applicant further stated that these sprinkler and standpipe systems do not protect safety-related

equipment, are not addressed in PPL's response to Appendix A to BTP APSCB 9.5-1, nor are

they credited in the 10 CFR Part 50, Appendix R safe-shutdown analysis.

In addition, the applicant stated that after further review, the sprinkler and standpipe systems

for the Turbine Building areas, Reactor Feed Pump Turbine (RFP Lube Oil Reservoir), PFP

Turbine Room (RFP Turbine Room), Centrifuge & Conditioner (Lube Oil Conditioner Room),

Turbine Hydro Seal Oil Unit (Hydrogen Seal Oil Unit), Turbine Lube oil Area (Turbine Lube oil

Reservoir), and Turbine Motor Generator Area (Turbine generator bearings) are included in the

Fire Protection Review Report for SSES. They also are included in the response to Appendix A

to BTP APSCB 9.5-1, because they protect areas containing combustible liquid.

The staff confirmed that the applicant has provided revised boundary drawings LF-M-122-2,

-11, -12, -13 and -14.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.13-3 acceptable

because the applicant has explained that the sprinkler and standpipe systems listed below are

2-76
not required for compliance with fire protection regulations. The staff determines that the

following fire water suppression systems are for property protection and for loss prevention:

" Condenser Area

" Turbine Central Area

" Turbine Condenser Gallery

• Turbine Hydro Control Power Room

" North Railroad Bay

" Turbine Condenser Mezzanine

" Diesel Engine Fire Pump Room

* Turbine Pump Area

" Turbine Filter Room

" Turbine Moisture Separation Area

" Radwaste Tank Vent Filter Room

" Radwaste Auxiliary Rooms

• Radwaste Controlled Zone Shop

The staff concludes that sprinkler and standpipe systems are correctly excluded from the scope

of license renewal and from being subject to an AMR. In addition, the staff finds that the

applicant has committed to include the following sprinkler and standpipe systems within the

scope for the license renewal and subject to an AMR:

* Reactor Feed Pump Turbine (RFP Lube Oil Reservoir)

* PFP Turbine Room (RFP Turbine Room)

" Centrifuge & Conditioner (Lube Oil Conditioner Room)

" Turbine Hydro Seal Oil Unit (Hydrogen Seal Oil Unit)

* Turbine Lube oil Area (Turbine Lube oil Reservoir)

" Turbine Motor Generator Area (Turbine generator bearings)

The staff is adequately assured that the above sprinkler and standpipe systems for fire

suppression will be appropriately considered during aging management activities. Therefore,

the staff's concern described is RAI 2.3.3.13-3 is resolved.

In RAI 2.3.3.13-4, dated June 22, 2007, the staff stated that SER Section 9.5.1.3

(NUREG-0776, dated April 1981), describes the low-pressure carbon dioxide (CO 2) fire

extinguishing systems for electrical equipment rooms, generator purging, concealed floor and

ceiling spaces. This SER section also discusses self-contained Halon 1301 fire extinguishing

systems for power generation complex modules. The staff noted that the total flooding C02 fire

extinguishing systems for electrical equipment rooms, generator purging, concealed floor and

ceiling spaces and self-contained Halon 1301 fire extinguishing systems for power generation

complex modules do not appear in LRA Section 2.3.3.13 as being in the scope of the license

renewal and subject to an AMR.

The staff requested that the applicant verify whether the CO 2 fire extinguishing systems for

electrical equipment rooms, generator purging, concealed floor and ceiling spaces and Halon

1301 fire extinguishing systems for power generation complex modules are within the scope of

license renewal, in accordance with 10 CFR 54.4(a) and subject to an AMR, in accordance with

10 CFR 54.21(a)(1) and; if excluded, provide justification.

2-77
In its response to RAI 2.3.3.13-4, dated July 24, 2007, the applicant stated:

The C02 and Halon fire extinguishing systems are in the scope of license

renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in

accordance with 10 CFR 54.21 (a)(1). "Spray nozzles, C02 and Halon" and

"Tank, low pressure C02 storage tank (0T102)" are explicitly listed in LRA

Table 2.3.3-13 and are subject to an AMR. These suppression systems also

include piping, tubing, valve bodies, and bolting, which are also listed in LRA

Table 2.3.3-13 as subject to an AMR.

As shown on LRA drawing LR-M-122, Sheet 4, "Fire Protection Carbon Dioxide

Systems," normally closed valves isolate the generator purging portion of the

C02 extinguishing system from the storage tank. The storage tank, attached

piping, and isolation valves are within the scope of license renewal and subject to

an AMR, as described above. The remainder of the generator purging portion of

the C02 fire extinguishing system is not in the scope of license renewal. The C02

fire extinguishing systems for safety-related and safe-shutdown system

protection include those in the electrical equipment rooms and floor and ceiling

spaces (concealed) of the control room. In addition, Power Generation Control

Complex (PGCC) modules are provided with self-contained Halon 1301 fire

extinguishing systems as described in Section 4.9 of the FPRR, Revision 15, and

in Section 9.5.1.3 of NUREG-0776, dated April 1981. These systems are selfcontained in the individual modules and, as such, are not shown on an LRA

drawing.

In evaluating the applicant's response, the staff found that it was incomplete and that review of

LRA Section 2.3.3.13 could not be completed. The staff noted the applicant's explanation that

the C02 and Halon 1301 fire extinguishing systems are within the scope of license renewal, in

accordance with 10 CFR 54.4(a) and subject to an AMR, pursuant to 10 CFR 54.21(a)(1 ). The

staff also noted that a part of the generator purging portion of the C02 extinguishing system is

not within the scope of license renewal. The staff further noted that the Power Generation

Control Complex (PGCC) modules are provided with self-contained Halon 1301 fire

extinguishing systems.

The applicant indicated in its response to RAI 2.3.3.14-4 that the C02 and Halon fire

extinguishing system in question is within the scope of license renewal, but a portion of the C02

system was not highlighted on LRA boundary drawing LR-M-122, Sheet 4. This resulted in the

staff holding a telephone conference with the applicant on October 3, 2007, to discuss

information necessary to resolve its concern described in RAI 2.3.3.13-4. During the

teleconference, the staff asked the applicant to explain why a portion of the C02 system was

not highlighted on LRA boundary drawing LR-M-122, Sheet 4. Further, the staff requested that

the applicant verify whether the PGCC modules self-contained Halon 1301 fire extinguishing

systems are within the scope of license renewal, in accordance with 10 CFR 54.4(a) and

subject to an AMR, in accordance with 10 CFR 54.21(a)(1).

The applicant clarified that a portion of the C02 system for the generator purging system is not

within the scope of license renewal, because a malfunction of that portion of the system will not

prevent the C02 fire extinguishing system from accomplishing its 10 CFR Part 50, Appendix R

function. The staff determines that the portion of the C02 system in question could not affect

the actuation of the C02 system, and was correctly excluded from the scope of license renewal

2-78
and is not subject to an AMR. The staff also determines that the applicant has considered the

PGCC self-contained Halon 1301 units as active components and therefore, excluded them

from the scope of license renewal and subject to an AMR. Therefore, the staff's concern

described in RAI 2.3.3.13-4 is resolved.

In RAI 2.3.3.13-5, dated June 22, 2007, the staff noted that the LRA Table 2.3.3-13 excludes

several types of fire protection components that appear in the April 1981 SER (NUREG-0776)

for SSES, and/or the applicant's Fire Protection Review Report. These components are listed

below:

" Hose stations

" Spray nozzles (water, C02/Halon 1301)

" Dikes for oil spill confinement

• Floor drains and curbs for fire-fighting water

* Filter housing

" Strainer housing

" Heater housing

" Chamber housing

" Actuator housing

* Pipe supports

* Halon storage bottles

* Water storage tanks

* Buried outside diesel fuel storage tanks

* Heat exchanger (bonnet)

* Turbocharger

* Lubricating oil collecting system components (reactor coolant pump)

* Engine intake and exhaust silencers/muffler (diesel driven fire pump)

* Manual smoke removal systems and their associated components (control structure

including CSRs)

The staff requested that the applicant verify whether the components listed above should be

included in LRA Table 2.3.3.13 and: if excluded, provide justification.

In its response to RAI 2.3.3.13-5, dated July 24, 2007, the applicant stated in part:

Fire protection system components that provide safety-related and safeshutdown system protection (i.e., that are required for compliance with

10 CFR 50.48) are in the scope of license renewal and subject to an AMR unless

justification is provided otherwise.

With certain exceptions, the components listed above do not need to be included

in LRA Table 2.3.3-13 in that they are already included in the table (as clarified

2-79
below), included in a separate LRA Table excluded from the scope of license

renewal or not subject to an AMR. Each type of component listed above is

addressed in the following table. The corresponding LRA location is identified for

components subject to an AMR and justification is provided, as applicable.

The applicant provided a table as part of its response that identified:

... certain components of the Fire Protection System were incorrectly omitted

from Section 2.3.3.13 and subsequent portions of the LRA. These components

are attached to and support the function of the diesel engine driven fire pump

(0P51 1), shown on LRA drawing LR-M-1 22, Sheet 1. For the most part, these

supporting components are not shown on the boundary drawing. An evaluation

was performed to determine the extent of this condition...

Based on this evaluation, the applicant identified additional components as being subject to an

AMR. In addition, the applicant amended the applicable boundary drawings and the LRA to

include the applicable components.

In evaluating the applicant's response to RAI 2.3.3.13-5, the staff found that it was incomplete

and review of LRA Section 2.3.3.13 could not be completed. The staff noted that although the

applicant states that it considered some components to be included in other line items, the

descriptions of the line items in the LRA do not specifically list all the components. Further, the

applicant has committed to interpret some components (e.g., hose stations, curbs for fire

fighting water, and pipe supports), as included in "Bulk Commodity" in LRA Table 2.4-10.

The applicant included the following items within the scope of license renewal and subject to an

AMR, because of their intended functions as part of the pressure boundary:

* filter bodies

* heater housing

* muffler

* heat exchanger (oil cooler) shell and end cover

* heat exchanger (oil cooler) tubes

" pump casing (diesel fuel oil)

" pump casing (diesel lubricating oil)

* pump casing (diesel cooling water)

" tank (oil pan)

" turbocharger casing

The applicant explained that only components with an intended function other than "pressure

boundary" are listed separately from the line item. Because the applicant has committed to

interpret these components as included in the line item and the intended function is as a

pressure boundary only, the staff is adequately assured that these components will be

appropriately considered during plant aging management activities.

The staff found that the actuator housing and turbocharger were not included in the line item

descriptions in the LRA. The staff confirms the applicant's interpretation of these components

as active, which necessarily will result in more vigorous oversight of the condition and

performance of the components. However, the staff disagreed with the applicant that the spray

nozzles for fire hoses are considered to be integral to the fire hose, and the applicant's

2-80
evaluation that fire hose nozzles are not subject to an AMR. The staff determines that the fire

hose nozzle function is not pressure tested like hoses and therefore, should be considered as a

passive component and subject to an AMR, in accordance with 10 CFR 54.21(a)(1). The staff

noted that LRA Table 2.3.3-13 identified nozzles as within the scope of license renewal and

subject to an AMR. Based on its review, the staff is adequately assured that the applicant will

appropriately consider fire hose nozzles during plant aging management activities.

The applicant stated that the auxiliary boilers for SSES are electric and do not have fuel oil

tanks and therefore, do not require dikes. The staff believes that the turbine lube oil reservoir

room, hydraulic control power room, and lube oil centrifuge and conditioner room may contain

dikes for oil spill confinement and requested that the applicant verify whether the dikes for oil

spill confinement are above areas that are in-scope, in accordance with 10 CFR 54.4(a) and

subject to an AMR, pursuant to 10 CFR 54.21 (a)(1 ).

During the conference call on October 3, 2007, and by letter dated October 24, 2007, the

applicant stated that the LRA does not distinguish dikes for oil spill containment from flood

curbs. Flood curbs are within the scope of license renewal and subject to an AMR, addressed

as a bulk commodity, and listed in LRA Table 2.4-10.

Based on its review, the staff finds the applicant's response acceptable. The applicant stated

that LRA does not distinguish dikes for oil spill containment from flood curbs. Flood curbs are

within the scope of license renewal and subject to an AMR and included as a bulk commodity in

LRA Section 2.4.10, Table 2.4-10. Because the applicant has committed to interpret dikes for

oil spill containment as included in the "flood curbs" line item, with the intended function only

being that of pressure boundary, the staff is adequately assured the dikes for oil spill

containment will be appropriately considered during plant aging management activities.

The applicant stated that the Halon cylinders are stamped DOT and are considered

consumables that are replaced periodically and therefore, not subject to an AMR. The staff

disagreed with the applicant interpretation of consumables and noted that SRP-LR, Table 2.1-5,

listed tanks as passive components. The staff believes that Halon tanks are part of the Halon

fire extinguishment system and therefore, should be within the scope of license renewal, in

accordance with 10 CFR 54.4(a) and subject to an AMR, pursuant to 10 CFR 54.21(a)(1).

During the conference call on October 3, 2007 and by letter dated October 24, 2007, the

applicant stated that the SSES Halon cylinders are relatively small spheres, approximately

12 inches in diameter. The technical requirements manual TRS 3.7.3.4.1 for Units 1 and 2,

directs the applicant to perform periodic weight and pressure verifications of Halon cylinders.

These inspections are implemented under plant procedures 9SM-1 13-014, SM-1 13-015,

SM-213-014, and SM-213-015 and include inspection of the Halon cylinders for any sign of

damage and deterioration. These inspection activities collectively fall under the category of

condition monitoring and determine whether the Halon cylinders are at the end of their qualified

lives. The staff determined that SRP-LR, Table 2.1-3, page 2.1-15 under "consumable," item

"(d)," allows for the exclusion of these components from and AMR, due to required condition

monitoring activities.

Although in other license renewal reviews, components similar to the Halon cylinders are

considered to be passive and, therefore, included in the scope of license renewal and subject to

an AMR, the staff confirms the applicant's interpretation of this component as active. On a

plant-specific basis, the applicant has excluded Halon cylinders from an AMR, pursuant to

2-81
10 CFR 54.21(a)(1)(ii). The staff also confirms that the applicant has routinely monitored Halon

cylinders based on performance or condition criteria specified in Technical Requirements

Manual (TRS) 3.7.3.4.1 of the TRM, thus, ensuring that the cylinders maintain their intended

function.

Because the applicant has interpreted the Halon cylinders as part of an active component

(condition monitoring to determine whether the Halon cylinders are at the end of their qualified

lives) the staff concludes that the component was correctly excluded from the scope of license

renewal and is not subject to an AMR.

Further, the staff requested that the applicant verify whether following line items listed in the

above table are in-scope, in accordance with 10 CFR 54.4(a) and subject to an AMR, in

accordance with 10 CFR 54.21(a)(1):

* Filter housing

* Strainer housing

* Actuator housing

During the conference call on October 3, 2007 and by letter dated October 24, 2007, the

applicant stated that filter and actuator housings are within the scope of license renewal, in

accordance with 10 CFR 54.4(a) and subject to an AMR pursuant to 10 CFR 54.21(a)(1). The

filter and actuator housings are listed in LRA Table 2.3.3-13. The strainer has dual intended

functions; namely, the strainer housing performs the pressure boundary function and the

strainer internals provide the filtration function.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.13-5 acceptable

because the applicant has adequately explained its interpretation of the component

characterization. The staff confirms the applicant's interpretation of this component as active,

which necessarily will result in more vigorous oversight of the condition and performance of the

component. The staff is adequately assured that these components will be appropriately

considered as within the scope of license renewal and subject to an AMR. Therefore, the staff's

concerns described in RAI 2.3.3.13-5 are resolved.

In RAI 2.3.3.13-6, dated June 22, 2007, the staff noted that in LRA Section 2.3.3.13, the

applicant discussed requirements for the fire water supply system, but does not mention trash

racks and traveling screens for the fire pump suction water supply. Trash racks and traveling

screens are located upstream of the fire pump suctions to remove any major debris from the

fresh or raw water. Trash racks and traveling screens are necessary to remove debris from and

prevent clogging of the fire protection water supply system. Trash racks and traveling screens

are typically considered as passive and long-lived components. Both trash racks and traveling

screens are located in a fresh or raw water and/or air environment and are typically constructed

of carbon steel. Carbon steel located in a fresh or raw water environment or water and/or air

environment is subject to loss of material, pitting, crevice formation, microbiologically influenced

corrosion, and fouling. The staff requested that the applicant explain the apparent exclusion of

the trash racks and traveling screens located upstream of the fire pump suctions from the

scope of license renewal, in accordance with 10 CFR 54.4(a) and subject to an AMR, in

accordance with 10 CFR 54.21 (a)(1).

2-82
In its response to RAI 2.3.3.13-6, dated July 24, 2007, the applicant stated:

As described in LRA Section 2.3.3.13, System Description, Water Supplies, the

primary source of fire protection water is the Clarified Water Storage Tank,

addressed in LRA Section 2.3.3.21, and the second and third sources are the

basins of hyperbolic natural draft cooling towers for Units 1 and 2, addressed in

LRA Section 2.3.3.6. Accordingly, the fire pumps at SSES are horizontal,

centrifugal type pumps as described in FPRR Section 4.1, rather than vertical

wet pit pumps, and do not take suction from an open bay. Since the pumps do

not take suction from a natural source or bay, trash racks and traveling screens

are neither required nor installed at SSES.

Boundary drawings LR-M-115, Sheet 1 and LR-M-2115, Sheet 1, which are

identified in LRA Section 2.3.3.6, show the outlet screens for the cooling tower

basin in the scope of license renewal (highlighted green). As described in LRA

Section 2.4.9.6, LRA Table 2.4-9, and LRA Table 3.5.2-9, the Cooling Tower

Basin Outlet Screens are in license renewal scope and are subject to an AMR as

structural commodities. They are constructed of stainless steel and are fixed

screens.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.3-6 acceptable

because the applicant adequately described that the intended function supporting the fire pump

suction supply is accomplished from the water storage tank and basins of the hyperbolic natural

draft cooling towers for Units 1 and 2. The fire pumps at SSES do not take suction from a

natural source or bay, therefore, trash racks and traveling screens are not required. In addition,

the staff confirms that the applicant has placed cooling tower basin outlet screens within the

scope of license renewal and subject to an AMR, as structural commodities. Therefore, the

staff's concern described in RAI 2.3.3.13-6 is resolved.

2.3.3.13.3 Conclusion

The staff reviewed the LRA, UFSAR, LRA boundary drawings (original and revised), and

RAI responses to determine whether the applicant failed to identify any components within the

scope of license renewal. In addition, the staff's review determined whether the applicant failed

to identify any components subject to an AMR. On the basis of its review, the staff concludes

the applicant has appropriately identified the fire protection system and components within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the fire protection mechanical components subject an AMR, in accordance with the

requirements of 10 CFR 54.21(a)(1) and therefore, the response is acceptable.

2.3.3.14 Fuel Pool Cooling and Cleanup System and Fuel Pools and Auxiliaries

2.3.3.14.1 Summary of Technical Information in the Application

LRA Section 2.3.3.14 describes the fuel pool cooling and cleanup system (FPCCS) system and

fuel pools and auxiliaries that cool the fuel storage pool water by transferring decay heat of the

irradiated fuel through heat exchangers to the SWS. The FPCCS and fuel pools and auxiliaries

contain safety-related components relied upon to remain functional during and following DBEs.

The failure of nonsafety-related SSCs in the SSCs in the FPCCS and fuel pools and auxiliaries

2-83
could prevent satisfactory performance of a safety-related function. LRA Table 2.3.3-14

identifies FPCCS and fuel pools and auxiliaries component types within the scope of license

renewal and subject to an AMR.

2.3.3.14.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.14, UFSAR Sections 9.1.3 and 9.1.2, and the licensing

renewal boundary drawings using the evaluation methodology described in SER Section 2.3

and the guidance in SRP-LR Section 2.3. The staff's review of LRA Section 2.3.3.14 identified

areas in which additional information was necessary to complete the review of the applicant's

scoping and screening results. In addition to RAls 2.3.3.14-1, 2.3.3.14-2, and 2.3.3.14-11

related to boundary drawing continuation errors described in LRA Section 2.3.3, the applicant

responded to the staff's RAIs as discussed below.

In RAI 2.3.3.14-3, dated August 27, 2007, the staff noted that boundary drawing LR-M-154-1,

locations C3, C6, and C9, show the boundary (pursuant to 10 CFR 54.4(a)(2)) at the top of the

fuel pool filter demineralizers. Though not within the scope of license renewal, two-inch vent

pipes are shown exiting the top of the filter demineralizers and going to the vent header

two-inch HBD-87 piping, which also is not within scope of licensing renewal. Boundary drawing

LR-M-154-1, location Al, shows a continuation from the out-of-scope vent header two-inch

HBD-87 piping to boundary drawing LR-M-166-2, location A2, where the two-inch HBD-87

piping is shown within the scope of license renewal. The staff requested that the applicant

explain why the two-inch vent piping and two-inch HBD-87 vent header piping are not within the

scope of license renewal.

In its response to RAI 2.3.3.14-3, dated October 18, 2007, the applicant stated in part:

License renewal Note E on drawing LR-M-166-2 states that component vents

routed to a tank are considered to potentially contain liquid and are included in

the evaluation boundaries.

The vent piping from the fuel pool filter demineralizers on drawing LR-M-1 54-1

up to the vent header and continuing onto drawing LR-M-1 66-2 at location A2

and to the connection to the fuel pool backwash receiving tank is within the

scope of license renewal per the criteria of 10 CFR 54.4(a)(2). The drawings

were revised to highlight the piping [as 10 CFR 54.4(a)(2)].

Because the components being added are addressed under the "piping and piping

components" line item in LRA Table 2.3.3-14, the applicant stated that no changes are required

to this table.

The applicant further stated that the LRA:

... was amended to address the materials for the components added to the scope

of license renewal per this response. The internal environment for the carbon

and stainless steel vent piping is evaluated as a ventilation environment. In

addition it was noted that there is carbon steel piping subject to the treated water

environment. Evaluation of that piping was also added to LRA Table 3.3.2-14.

2-84
The staff confirms that the applicant has submitted revised boundary drawings LR-M-154-1 and

LR-M-166-2, and has revised LRA Table 3.3.2-14.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-3 acceptable

because the applicant has clarified that the piping in question is within the scope of license

renewal and has made appropriate revisions to boundary drawings LR-M-154-1 and

LR-M-166-2 and LRA Table 3.3.2-14. Therefore, the staff's concern described in RAI 2.3.3.14-3

is resolved.

In RAI 2.3.3.14-4, dated August 27, 2007, the staff noted that boundary drawing LR-M-153-2,

location F4, shows the continuation of one-inch HBD piping to boundary drawing LR-M-161-1,

location El, which is within the scope of license renewal, pursuant to 10 CFR 54.4(a)(2).

Boundary drawing LR-M-153-2 did not provide the complete pipe identification number. Review

of the continuation boundary drawing LR-M-161-1, location El, did not show the one-inch HBD

piping specifically identified or show the continuation of the in-scope piping from boundary

drawing LR-M-1 53-2. The staff requested that the applicant provide additional information to

include the complete one-inch HBD pipe identification number on boundary drawings

LR-M-153-2 and LR-M-161-1 and explain why the continuation of the in-scope boundary from

boundary drawing LR-M-153-2 is not shown as within the scope of license renewal on boundary

drawing LR-M-161-1.

In its response, dated October 18, 2007, the applicant stated:

The continuation of the one-inch HBD drain line from the refueling bellows area

of the primary containment on drawing LR-M-1 53-2 is included in the listing of

sources draining to the drywell equipment drain tank on drawing LR-M-161-1,

location El. The line from LR-M-1 53-2, location F4, is addressed by the listing

"Bellows Drain (M-153)."

The subject 1-inch drain line on LR-M-153-2 that continues to LR-M-161-1

should not be highlighted as within the scope of license renewal for

10 CFR 54.4(a)(2) because it is located inside containment where the equipment

is designed to get wet. Drawing LR-M-153-2 was revised to reflect this change.

The staff confirms that the applicant has submitted revised boundary drawing LR-M-153-2.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-4 acceptable

because the applicant has clarified that the piping in question on boundary drawing

LR-M-1-153-2 is not within the scope of license renewal and has made appropriate revisions to

boundary drawing LR-M-153-2. Therefore, the staff's concern described in RAI 2.3.3.14-4 is

resolved.

In RAI 2.3.3.14-5, dated August 27, 2007, the staff noted that boundary drawings LR-M-153-2,

location F5, shows the continuation of two-inch HBD-1052 piping to boundary drawing

LR-M-161-1, location El, which is within the scope of license renewal, pursuant to

10 CFR 54.4(a)(2). Review of the continuation boundary drawing LR-M-161-1, location El, did

not show the two-inch HBD-1 052 piping specifically identified or show the continuation of the

in-scope piping from boundary drawing LR-M-1 53-2. The staff requested that the applicant

provide additional information that indicates where the two-inch HBD-1052 pipe continuation is

located on boundary drawing LR-M-161-1 and explain why the continuation of the in-scope

2-85
boundary from boundary drawing LR-M-1 53-2 is not shown as within the scope of license

renewal on boundary drawing LR-M-161-1.

In its response to RAI 2.3.3.14-5, dated October 18, 2007, the applicant stated:

The continuation of the 2" HBD-1052 drain line from the refueling bellows area of

the primary containment on drawing LR-M-153-2 is included in the listing of

sources draining to the drywell equipment drain tank on drawing LR-M-161-1 at

location El. The line from LR-M-1 53-2 at location F5 is addressed by the listing

"Bellows Drain (M-153)."

The subject two-inch drain line on LR-M-153-2 that continues to LR-M-161-1

should not be highlighted as within the scope of license renewal for

10 CFR 54.4(a)(2) because it is located inside containment where the equipment

is designed to get wet.

The staff confirms that the applicant has submitted revised boundary drawing LR-M-153-2.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-5 acceptable

because the applicant has clarified that the piping in question on boundary drawing

LR-M-1-153-2 is not within the scope of license renewal and has made appropriate revisions to

boundary drawing LR-M-153-2. Therefore, the staffs concern described in RAI 2.3.3.14-5 is

resolved.

In RAI 2.3.3.14-6, dated August 27, 2007, the staff noted that boundary drawing LR-M-2153-2,

location F4, shows the continuation of one-inch HBD piping to boundary drawing LR-M-2161-1,

location F1, which is within the scope of license renewal, pursuant to 10 CFR 54.4(a)(2). The

LR-M-2153-2 boundary drawing did not provide the complete pipe identification number. Review

of the continuation boundary drawing LR-M-2161-1, location F1, did not show the one-inch HBD

piping specifically identified or show the continuation of the in-scope piping from boundary

drawing LR-M-2153-2. The staff requested that the applicant provide additional information that

includes the complete one-inch HBD pipe identification number on boundary drawings

LR-M-2153-2 and LR-M-2161 and explain why the continuation of the in-scope boundary from

boundary drawing LR-M-2153-2 is not shown as within the scope of license renewal on

boundary drawing LR-M-2161.

In its response to RAI 2.3.3.14-6, dated October 18, 2007, the applicant stated in part:

The continuation of the one-inch HBD drain line from the refueling bellows area

of the primary containment on drawing LR-M-2153-2 is included in the listing of

sources draining to the drywell equipment drain tank on drawing LR-M-2161-1,

location Fl. The line from LR-M-2153-2 at location F4 is addressed by the listing

"Bellows Leakage Drain (M-2153)."

The subject one-inch drain line on LR-M-2153-2 that continues to LR-M-2161-1

should not be highlighted as within the scope of license renewal for

10 CFR 54.4(a)(2) because it is located inside containment where the equipment

is designed to get wet. Refer to LRA Section 2.1.1.2.2 and the enclosed

response to RAI 2.3.3.23-3 for an explanation.

2-86
The staff confirms that the applicant has submitted revised boundary drawing LR-M-2153-2.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-6 acceptable

because the applicant has clarified that the piping in question on boundary drawing

LR-M-1-2153-2 is not within the scope of license renewal and has made appropriate revisions

to boundary drawing LR-M-2153-2. Therefore, the staff's concern described in RAI 2.3.3.14-6 is

resolved.

In RAI 2.3.3.14-7, dated August 27, 2007, the staff noted that boundary drawing

LR-M-2153-2, location F5, shows the continuation of two-inch HBD-2052 piping to boundary

drawing LR-M-2161-1, location F1, which is within the scope of license renewal, pursuant to

10 CFR 54.4(a)(2). Review of the continuation boundary drawing LR-M-2161-1, location F1,

did not show the two-inch HBD-2052 piping specifically identified or show the continuation of

the in-scope piping from boundary drawing LR-M-2153-2. The staff requested that the

applicant provide additional information that indicates where the two-inch HBD-2052 piping

continuation is located on boundary drawing LR-M-2161-1 and explain why the continuation of

the in-scope boundary from boundary drawing LR-M-2153-2 is not shown as within the scope

of license renewal on boundary drawing LR-M-2161-1.

In its response to RAI 2.3.3.14-7, dated October 18, 2007, the applicant stated in part:

The continuation of the 2 inch HBD-2052 drain line from the refueling bellows

area of the primary containment on drawing LR-M-2153-2 is included in the

listing of sources draining to the drywell equipment drain tank on drawing LR-M2161-1 at location Fl. The line from LR-M-2153-2 at location F5 is addressed by

the listing "Bellows Leakage Drain (M-2153)."

The subject 2 inch drain line on LR-M-2153-2 that continues to LR-M-2161-1

should not be highlighted [as 10 CFR 54(a)2)]. This drain line is located inside

primary containment where the equipment is designed to get wet. Refer to LRA

Section 2.1.1.2.2 and the enclosed response to RAI 2.3.3.23-3 for an

explanation.

The staff confirms that the applicant has submitted revised boundary drawing LR-M-2153-2.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-7 acceptable

because the applicant has clarified that the piping in question on boundary drawing

LR-M-1-2153-2 is not within the scope of license renewal and has made appropriate revisions

to boundary drawing LR-M-2153-2. Therefore, the staff's concern described in RAI 2.3.3.14-7 is

resolved.

In RAI 2.3.3.14-8, dated August 27, 2007, the staff noted that boundary drawing LR-M-153-2

shows six weirs with screens at locations D1, D2, D3, D5, and D6 at the ends of four-inch

HCD-143 piping; diffusers at locations E2 and E6 at the ends of six-inch HCD-158 piping, and

location E9 at the end of six-inch HCD-3023 piping; and a grate at location F9 at the start of

six-inch HCD-3024 piping that are within the scope of license renewal, pursuant to

10 CFR 54.4(a)(2). Boundary drawing LR-M-2153-2 shows six weirs with screens at locations

D1, D2, D3, D5, and D6 at the ends of four-inch HCD-243 piping; diffusers at locations E2 and

E6 at the ends of six-inch HCD-258 piping; and grates at location E3 at the start of three-inch

HBC-220 piping that are within the scope of license renewal, pursuant to 10 CFR 54.4(a)(2).

2-87
None of these component types are listed in LRA Table 2.3.3-14 for components subject to an

AMR. The staff requested that the applicant explain why these component types are not

included in LRA Table 2.3.3-14.

In its response to RAI 2.3.3.14-8, dated October 18, 2007, the applicant stated in part:

The weirs (with screens) and diffusers on drawing LR-M-153-2 all perform a

structural integrity function. As such, they are evaluated as component type "piping and piping components", which is included with a structural integrity

function in LRA Table 2.3.3-14. The grate at location F9 is embedded in the floor

of the shipping cask storage pit does not have the potential for affecting safetyrelated components through spatial interaction and therefore does not meet the

criteria of 10 CFR 54.4(a)(2). Drawing LR-M-153-2 has been revised to indicate

that the grate at location F9 is not within the scope of license renewal.

The weirs (with screens) and diffusers on drawing LR-M-2153-2 all perform a

structural integrity function. As such, they are evaluated as component type "piping and piping components", which is included with a structural integrity

function in LRA Table 2.3.3-14.

The piping within the primary containment, including the grates at location E3,

was removed from the scope of license renewal on drawing LR-M-2153-2. Refer

to LRA Section 2.1.1.2.2 and the enclosed response to RAI 2.3.3.23-3 for the

explanation.

The staff confirms that the applicant has submitted revised boundary drawing LR-M-153-2.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-8 acceptable

because the applicant has explained that the components in question are included as a

component type within "piping and piping components" in LRA Table 2.3.3-14 and that

boundary drawing LR-M-153-2 was revised because the grate at location F9 is not in-scope.

Therefore, the staff's concern described in RAI 2.3.3.14-8 is resolved.

In RAI 2.3.3.14-9, dated August 27, 2007, the staff noted that boundary drawing LR-M-153-2

shows grates at locations El, E3, E5, E6, E7, E8, E9, and F9, with only the F9 grate at the start

of 6" HCD-3024 piping shown within the scope of licensing renewal. Boundary drawing

LR-M-2153-2 shows grates at locations El, E3, E5, E6, E7, and E8, with only two of the E3

grates at the start of three-inch HBC-1 20 piping shown within the scope of license renewal. All

of the grates are shown located at the entrance to the drain piping within the scope of license

renewal, pursuant to 10 CFR 54.4(a)(2). The staff requested that the applicant explain why

some grates are within the scope of license renewal and some are not, when they all flow into

piping that is within the scope of licensing renewal.

In its response to RAI 2.3.3.14-9, dated October 18, 2007, the applicant stated in part:

Based on the response to RAI 2.3.3.14-8, drawing LR-M-1 53-2 has been revised

to indicate the grate at location F9 at the start of six-inch HCD-3024 piping as not

within the scope of license renewal. This change was based on the grate being

embedded in the floor of the shipping cask storage pit; therefore, not having the

2-88
potential for affecting safety-related components through spatial interaction and

not meeting the criteria of 10 CFR 54.4(a)(2).

The piping within the primary containment, including the grates at location E3,

was removed from the scope of license renewal on drawing LR-M-2153-2. Refer

to LRA Section 2.1.1.2.2 and the enclosed response to RAI 2.3.3.23-3 for the

explanation. Note that revised boundary drawing LR-M-2153-2 was prepared in

response to RAI 2.3.3.14-11.

All of the grates are embedded in concrete and therefore do not have the

potential for affecting safety-related components through spatial interaction.

Therefore, the grates do not meet the criteria of 10 CFR 54.4(a)(2) and are not

within the scope of license renewal.

The staff confirms that the applicant has submitted revised boundary drawing LR-M-2153-2.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-9 acceptable

because the applicant has explained that all the grate components in question are not within the

scope of license renewal, since they are embedded in concrete and that boundary drawing

LR-M-2153-2 was revised to indicate that none of the grates are within the scope of license

renewal. Therefore, the staff's concern described in RAI 2.3.3.14-9 is resolved.

In RAI 2.3.3.14-10, dated August 27, 2007, the staff noted that boundary drawing LR-M-153-2,

location E3, shows two grates, which are identified as not within the scope of license renewal,

that drain into three-inch HBC-120 piping that is within the scope of license renewal, pursuant to

10 CFR 54.4(a)(2). Boundary drawing LR-M-2153-2, also at location E3, shows essentially the

same two grates, which are identified as within the scope of license renewal, that drain into

three-inch HBC-220 piping within the scope of license renewal, pursuant to 10 CFR 54.4(a)(2)

and also draining to the liquid radwaste system. The staff requested that the applicant explain

why there is a difference of grate scope classification between Unit 1 and Unit 2, when the

grates essentially have the same location, piping size, function, and destination.

In its response to RAI 2.3.3.14-10, dated October 18, 2007, the applicant stated in part:

The piping within the primary containment, including the grates at location E3 on

drawing LR-M-2153-2, was removed from the scope of license renewal. This

change to drawing LR-M-2153-2 was identified as Revision 1. The basis for the

removal of the piping within primary containment on drawings LR-M-1 53-2 and

LR-M-2153-2 from the scope of license renewal was that safety-related

components inside containment are designed for a harsh environment, including

spray, and are not plausible targets for spatial interaction. The subject

components are not connected to safety-related piping. Refer to LRA

Section 2.1.1.2.2 and the enclosed response to RAI 2.3.3.23-3 for the

explanation.

The staff confirms that the applicant has submitted revised boundary drawings LR-M-153-2 and

LR-M-2153-2.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-10 acceptable

because the applicant has explained that all piping and grate components in question were

2-89
removed from the scope of license renewal, and that boundary drawings LR-M-2153-1 and

LR-M-2153-2 were appropriately revised. Therefore, the staff's concern described in

RAI 2.3.3.14-10 is resolved.

In RAI 2.3.3.14-12, dated August 27, 2007, the staff noted that boundary drawing LR-M-2153-1,

location F6, shows orifice FE 25234 highlighted in green, indicating that it is within the scope of

license renewal, pursuant to 10 CFR 54.4(a)(1). Boundary drawing LR-M-153-1, location F6,

orifice FE 15324 is highlighted in pink, indicating that it is within the scope of license renewal,

pursuant to 10 CFR 54.4(a)(2). The staff requested that the applicant explain why different

scoping criterion was used for the Unit 1 versus Unit 2 orifices.

In its response to RAI 2.3.3.14-12, dated October 18, 2007, the applicant stated in part that:

Orifice FE 15324, like FE 25324, is a Q-Class component (i.e., safety-related)

and therefore meets the scoping criteria of 10 CFR 54.4(a)(1). The highlighting

error on LR-M-153-1 was revised to include orifice FE15324 as within the scope

of license renewal for criteria 10 CFR 54.4(a)(1 ).

The staff confirms that the applicant has submitted revised boundary drawing LR-M-1 53-1.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-12 acceptable

because the applicant has clarified that the orifices in question are both within the scope of

license renewal, pursuant to 10 CFR 54.4(a)(1) and has revised boundary drawing LR-M-153-1.

Therefore, the staffs concern described in RAI 2.3.3.14-12 is resolved.

In RAI 2.3.3.14-13, dated August 27, 2007, the staff noted that boundary drawings LR-M-1 53-1,

location C6 and boundary drawing LR-M-2153, location C3, show 10-inch HBC-1 14/214 within

the scope of license renewal, pursuant to 10 CFR 54.4(a)(2), as nonsafety-related for spatial

interaction. The piping numbering system of boundary drawing LR-M-100 indicates that these

piping components are American Society of Mechanical Engineers (ASME) Boiler and Pressure

Vessel Code, Section III, Class 3. ASME Code, Section III, Class 3 components typically are

safety-related and fall within the scope of license renewal, pursuant to 10 CFR 54.4(a)(1). The

staff also noted other similar occurrences on these boundary drawings. The staff requested that

the applicant explain why portions of ASME Code, Section III, Class 3 components on boundary

drawings LR-M-153/2153-1 are not safety-related and why they are not within the scope of

license renewal, pursuant to 10 CFR 54.4(a)(1).

In its response to RAI 2.3.3.14-13, dated October 18, 2007, the applicant stated:

The FSAR Table 3.2-1 under the Fuel Pool Cooling and Cleanup System, shows

that the principal construction code for the piping downstream of valve 1(2)53001

(10" HBC-1 14/214) is ASME Section III, Class 3. The same table shows that this

piping is not within the scope of 10 CFR 50, Appendix B. Hence, the pipe is

ASME III, Class 3, but is not safety-related. Reference LR-M-100-2 at E3, PPL's

drawing convention is to "cross-hatch" pipelines that are safety-related. The lack

of "cross-hatching" indicates that HBC-1 14/214, as well as other similar

instances of ASME Section III pipes, are not safety-related.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-13 acceptable

because the applicant has verified that UFSAR Table 3.2-1 shows that this piping is not within

2-90
the scope of 10 CFR Part 50, Appendix B and is not safety-related. Therefore, the staff's

concern described in RAI 2.3.3.14-13 is resolved.

2.3.3.14.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and boundary drawings to determine

whether the applicant failed to identify any components within the scope of license renewal. In

addition, the staff's review determined whether the applicant failed to identify any components

subject to an AMR. On the basis of its review, the staff concludes the applicant has

appropriately identified the fuel pool cooling and cleanup system and fuel pools and auxiliaries

mechanical components within the scope of license renewal, as required by 10 CFR 54.4(a),

and that the applicant has adequately identified the FPCCS and fuel pools and auxiliaries

mechanical components subject to an AMR, in accordance with the requirements of

10 CFR 54.21(a)(1) and therefore, the response is acceptable.

2.3.3.15 Neutron Monitoring System

2.3.3.15.1 Summary of Technical Information in the Application

LRA Section 2.3.3.15 describes the neutron monitoring system (NMS). The NMS contains

safety-related components relied upon to remain functional during and following DBEs. In

addition, the NMS performs functions that supportATWS and EQ. LRA Table 2.3.3-15

identifies NMS component types within the scope of license renewal and subject to an AMR.

2.3.3.15.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the NMS mechanical components within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the system

components subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2.3.3.16 Nitrogen and Hydrogen System

2.3.3.16.1 Summary of Technical Information in the Application

LRA Section 2.3.3.16 describes the nitrogen and hydrogen system, which provides gaseous

nitrogen for containment makeup and hydrogen for cooling the main generator during normal

plant operation. The failure of nonsafety-related SSCs in the nitrogen and hydrogen system

potentially could prevent the satisfactory accomplishment of a safety-related function. Although

connected to safety-related components for makeup and purge of the nitrogen in containment,

no nitrogen and hydrogen system mechanical components are subject to an AMR.

2.3.3.16.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, and UFSAR, the staff concludes that applicant has appropriately identified the nitrogen

and hydrogen system mechanical component types within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the system

2-91
component types subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2.3.3.17 Primary Containment Atmosphere Circulation System

2.3.3.17.1 Summary of Technical Information in the Application

LRA Section 2.3.3.17 describes the primary containment atmosphere circulation system. The

primary containment atmosphere circulation system contains safety-related components relied

upon to remain functional during and following DBEs. In addition, the primary containment

atmosphere circulation system performs functions that support EQ. LRA Table 2.3.3-16

identifies primary containment atmosphere circulation system component types within the scope

of license renewal and subject to an AMR.

2.3.3.17.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the primary containment atmosphere circulation system mechanical

components within the scope of license renewal, as required by 10 CFR 54.4(a), and that the

applicant has adequately identified the system components subject to an AMR in accordance

with the requirements stated in 10 CFR 54.21(a)(1).

2.3.3.18 Process and Area Radiation Monitoring System

2.3.3.18.1 Summary of Technical Information in the Application

LRA Section 2.3.3.18 describes the process and area radiation monitoring system, which

monitors releases of radioactive material in the plant gaseous and liquid process and effluent

streams to detect, alarm, indicate, and generate appropriate automatic actions to control

releases exceeding predetermined limits. The process and area radiation monitoring system

contains safety-related components relied upon to remain functional during and following DBEs.

The failure of nonsafety-related SSCs in the process and area radiation monitoring system

potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the process and area radiation monitoring system performs functions that support EQ.

LRA Table 2.3.3-17 identifies process and area radiation monitoring system component types

within the scope of license renewal and subject to an AMR.

2.3.3.18.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.18, UFSAR Sections 7.6 and 11.5, and the license

renewal boundary drawings using the methodology described in SER Section 2.3 and the

guidance in SRP-LR Section 2.3. The staff's review 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 RAIs as discussed below.

In a phone call with the applicant on November 19, 2008, the staff requested clarification of

information contained in the license renewal boundary drawings. LRA Section 2.3.3.18 lists the

license renewal boundary drawings that depict components of the process and area radiation

monitoring system (RMS). During its review of drawing LR-M-178, Sheet 1, the staff was unable

2-92
to discern the components that were part of the process and area RMS. The applicant was able

to identify components AN07801 and FE07801, in this drawing, as the parts of the process and

area RMS and in-scope for their pressure boundary function, only.

In RAI 2.3.3.18-1, dated December 3, 2008, the staff noted that the process and area RMS was

composed of a number of subsystems identified in the UFSAR for SSES. These subsystems

include both safety-related and nonsafety-related systems. The LRA did not specifically address

the scoping and screening results for each of the subsystems listed in the UFSAR. The staff

requested that the applicant clarify the scoping and screening of each subsystem and provide

drawing locations for subsystem components, if applicable.

In its response to RAI 2.3.3.18-1, dated December 12, 2008, the applicant stated that the

following subsystems were within the scope of license renewal:

* Standby Gas Treatment Vent Duct Exhaust RMS

* Standby Gas Treatment Vent Stack Exhaust Monitor and Sample RMS

* Refueling Floor Wall Duct Exhaust RMS

• Refueling Floor High Exhaust Duct RMS

* Railroad Access Exhaust Duct RMS

* Outside Air Intake Duct (Influent) RMS

* Service Water Discharge/Supplemental Decay Heat Removal RMS

* Main Steamline RMS

* RHR Service Water RMS

* Reactor Building Closed Cooling Water RMS

* Primary Containment Atmospheric Monitoring

* Primary Containment RMS (High Range)

The staff confirms that the applicant's response also provided the screening results for the

in-scope components of each of these systems.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.18-1 acceptable

because the applicant has clarified with sufficient detail, its scoping and screening review of the

subsystems that make up the process and area RMS. Therefore, the staff's concern described

in RAI 2.3.3.18-1 is resolved.

2.3.3.18.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI response, and boundary drawings to determine

whether the applicant failed to identify any components within the scope of license renewal. In

addition, the staff's review determined whether the applicant failed to identify any components

subject to an AMR. On the basis of its review, the staff concludes the applicant has

appropriately identified the process and area RMS components within scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the process and

area RMS components subject to an AMR review, in accordance with the requirements of

10 CFR 54.21(a)(1) and therefore, the response is acceptable.

2-93
2.3.3.19 Radwaste Liquid System

2.3.3.19.1 Summary of Technical Information in the Application

LRA Section 2.3.3.19 describes the radwaste liquid system, which collects, processes, stores,

and monitors, for reuse and disposal, the radioactive liquid wastes generated by plant

operation. The radwaste liquid system contains safety-related components relied upon to

remain functional during and following DBEs. The failure of nonsafety-related SSCs in the

radwaste liquid system potentially could prevent the satisfactory accomplishment of a safetyrelated function. In addition, the radwaste liquid system performs functions that support EQ.

LRA Table 2.3.3-18 identifies radwaste liquid system component types within the scope of

license renewal and subject to an AMR.

2.3.3.19.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.19, UFSAR Section 11.2, and the licensing renewal

boundary drawings using the evaluation methodology described in SER Section 2.3 and the

guidance in SRP-LR Section 2.3. The staff's review 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 RAIs as discussed below.

In RAI 2.3.3.19-1, dated August 27, 2007, the staff noted that boundary drawings LR-M-161-2

and LR-M-2161-2, locations Cl to El, provide a list of items (components, drains, vents, etc.)

that are contained in a non-boundary continuation box that interfaces directly with two four-inch

XBD pipelines within the scope of license renewal. The list does not show details about the

boundary drawing, sheet, and location numbers for the listed items in order to review and

evaluate the license renewal scope boundaries. The staff requested that the applicant identify

these license renewal boundaries.

In its response to RAI 2.3.3.19-1, dated October 18, 2007, the applicant stated:

The boxes on LR-M-161-2 and LR-M-2161-2 do not represent specific

components and are not highlighted. The boxes represent that numerous drain

lines from the listed systems and drawings are coming together into the lines

continued from the box. Most of the piping making up the drain lines coming into

the "box" is embedded in the building's floor and wall concrete. As the concrete

forms a tight seal around the embedded drain line, spatial interaction is not

reasonable for embedded piping. Therefore, the embedded portions of the drain

lines coming into the box are not subject to AMR. The portions of these drain

lines not embedded in concrete are within the scope of license renewal, are

subject to AMR and are included in LRA Section 2.3.3.19 and Table 2.3.3.18, as

"Piping and Piping Components" with the intended function of "Structural

Integrity." The piping from the box is addressed on LR-M-161-2 and LR-M-2161-

2, the liquid radwaste drawings.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.19-1 acceptable

because the applicant has adequately explained how the boxes on boundary drawings

LR-M-161-2 and LR-M-2161-2 do not represent components and why they are not in-scope.

The applicant further clarified that portions of pipelines are in concrete to prevent spatial

interaction and therefore, are not subject to an AMR, while those pipe sections not embedded in

2-94
concrete are subject to AMR and are included in LRA Section 2.3.3.19 and Table 2.3.3.18.

Therefore, the staff's concern described in RAI 2.3.3.19-1 is resolved.

In RAI 2.3.3.19-2, dated August 27, 2007, the staff noted that boundary drawings LR-M-161-1

and LR-M-2161-1, locations E5 and F5, and boundary drawings LR-M-161-2 and LR-M-2161-2,

locations A4, B4, C4, D4, E4, E5, E3, F3, G3, and H3, show drum traps (e.g., P-25-6, P-29-6,

etc.) within the scope of license renewal. However, the drum trap is not included in LRA

Table 2.3.3-19 as a component subject to an AMR. The staff requested that the applicant

explain why the drum traps are not included in LRA Table 2.3.3-19.

In its response to RAI 2.3.3.19-2, dated October 18, 2007, the applicant stated:

As stated in LRA Section 2.1.2.1.3, screening of mechanical components for

nonsafety affecting safety (NSAS) considerations was performed on a

commodity group basis. The commodity group of "piping and piping

components" includes all in-line piping components except for major equipment

such as tanks and heat exchangers.

The components identified on the Radwaste Liquid System drawings as drum

traps are evaluated as the component type of "cleanout" and are included in the

Table 2.3.3-19 line item "Piping and piping components - cleanouts and pump

casings (1/2P225A/B)."

Based on its review, the staff finds the applicant's response to RAI 2.3.3.19-2 acceptable

because the applicant has verified that PPL evaluates drum traps as a line item in the

commodity group of "piping and piping components - cleanouts and pump casings" that is

included in LRA Table 2.3.3-19. Therefore, the staff's concern described in RAI 2.3.3.19-2 is

resolved.

In RAI 2.3.3.19-3, dated August 27, 2007, the staff noted that boundary drawings LR-M-161-1

and LR-M-2161-1, location H8 show a cooling coil in the RB sump that is connected to two-inch

JBD-139 and two-inch JBD-140 piping that is shown within the scope of license renewal.

However, the cooling coil is not included within the scope of license renewal. The staff

requested that the applicant explain why the cooling coil is not within the scope of license

renewal.

In its response to RAI 2.3.3.19-3, dated October 18, 2007, the applicant stated:

The cooling coil does not perform a safety-related function; therefore, is not inscope for criterion 10 CFR 54.4(a)(1). The cooling coil is completely enclosed

within the reactor building sump and, therefore, can not have any spatial

interaction with safety-related equipment and the sump itself does not perform a

safety-related function. Thereby the cooling coil is not in-scope for criterion

10 CFR 54.4(a)(2). The coil does not support any of the regulated event

functions and, therefore, the cooling coil is not in-scope for criterion

10 CFR 54.4(a)(3).

2-95
Based on its review, the staff finds the applicant's response to RAI 2.3.3.19-3 acceptable

because the applicant has verified that the cooling coil is not within the scope of license renewal

for license renewal because: (a) it does not perform a safety-related function, (b) it cannot have

any spatial interaction with safety-related equipment, and (c) the coil does not support any of

the regulated event functions. Therefore, the staff's concern described in RAI 2.3.3.19-3 is

resolved.

In RAI 2.3.3.19-4, dated August 27, 2007, the staff noted that boundary drawing LR-M-2161-2,

location B1, shows a continuation from demineralized water distribution on boundary drawing

LR-M-118-2, location C2. The staff was unable to find boundary drawing LR-M-118-2 in the

LRA-provided boundary drawing package. The only boundary drawing found from

demineralized water distribution was LR-M-1 18-3, which included the correct continuation from

location C2 to boundary drawing LR-M-2161-2, location BI. The staff requested that the

applicant clarify that boundary drawing LR-M-1 18-3, rather than boundary drawing LR-M-1 18-2,

was the correct continuation boundary drawing to boundary drawing LR-M-2161-2 at location

B1.

In its response to RAI 2.3.3.19-4, dated October 18, 2007, the applicant stated that the

continuation from boundary drawing LR-M-2161-2, at location B1 should be to boundary

drawing LR-M-1 18-3 at location C2.

The staff confirms that the applicant has corrected and submitted revised boundary drawing

LR-M-2161-2.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.19-4 acceptable

because the applicant has revised the continuation arrow on boundary drawing LR-M-2161-2 to

refer to the correct boundary drawing LR-M-1 18-3, location C2. Therefore, the staff's concern

described in RAI 2.3.3.19-4 is resolved.

In RAI 2.3.3.19-5, dated August 27, 2007, the staff noted that boundary drawings LR-M-161-1

and -2161-1, locations B3 and G3, show nonsafety-related to safety-related piping components

at penetrations X72A and X72B. LRA Section 2.1.1.2.2, "Spatial Failures of Nonsafety-Related

SSCs," page 2.1-8 states in part: "With respect to nonsafety-related piping that is directly

connected to safety-related piping, the seismic Category I design requirements are extended to

the first seismic restraint beyond the defined boundaries." The staff requested that the applicant

provide additional information showing the location of the seismic restraint for the

nonsafety-related three-inch HBD-157/257 connected to the safety-related three-inch

HBB-1 19/219 piping, which is within the license renewal boundary.

In its response to RAI 2.3.3.19-5, dated October 18, 2007, the applicant stated:

PPL's response to RAI 2.1-3, part b, (Reference 3), identified nonsafety-related

(NSR) piping and components, inside primary containment and connected to

safety-related (SR) piping and components, that are required to remain intact to

ensure the structural integrity of the attached SR piping and components. The 3"

HBD-155/255 line connected to SR containment penetration X-72B and the 3"

HBD-157/257 line connected to penetration X-72A are not highlighted. The

penetrations themselves serve as anchor points, and the HBD lines inside the

2-96
drywell are not within the boundaries of the seismic analyses that contain the

containment boundary valves.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.19-5 acceptable

because the applicant has verified that containment penetrations serve as anchor points and

the HBD lines inside the drywell are not within the boundaries of the seismic analyses.

Therefore, the staff's concern described in RAI 2.3.3.19-5 is resolved.

2.3.3.19.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and boundary drawings (originals and

revised) to determine whether the applicant failed to identify any components within the scope

of license renewal. In addition, the staff's review determined whether the applicant failed to

identify any components subject to an AMR. On the basis of its review, the staff concludes the

applicant has appropriately identified the radwaste liquid system mechanical components within

the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has

adequately identified the radwaste liquid system mechanical components subject to an AMR, in

accordance with the requirements of 10 CFR 54.21 (a)(1), and therefore, the response is

acceptable.

2.3.3.20 Radwaste Solids Handling System

2.3.3.20.1 Summary of Technical Information in the Application

LRA Section 2.3.3.20 describes the radwaste solids handling system, which controls, collects,

handles, processes, packages, and temporarily stores prior to offsite shipping, the wet waste

sludge generated by the liquid waste management system, the reactor water cleanup system,

fuel pool cleanup system, the condensate cleanup system, and the condensate filtration

system. The failure of nonsafety-related SSCs in the radwaste solids handling system

potentially could prevent the satisfactory accomplishment of a safety-related function. LRA

Table 2.3.3-19 identifies radwaste solids handling system component types within the scope of

license renewal and subject to an AMR.

2.3.3.20.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the LRA

and UFSAR, the staff concludes that applicant has appropriately identified the radwaste solids

handling system mechanical component types within the scope of license renewal, as required

by 10 CFR 54.4(a), and that the applicant has adequately identified the system component

types subject to an AMR in accordance with the requirements stated in 10 CFR 54.21(a)(1).

2.3.3.21 Raw Water Treatment System

2.3.3.21.1 Summary of Technical Information in the Application

LRA Section 2.3.3.21 describes the raw water treatment system, which includes a clarified

water storage tank that is the primary source of water for the fire protection system. The raw

water treatment system performs functions that support fire protection. LRA Table 2.3.3-20

identifies raw water treatment system component types within the scope of license renewal and

subject to an AMR.

2-97
2.3.3.21.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the LRA

and UFSAR the staff concludes that applicant has appropriately identified the raw water

treatment system mechanical component types within the scope of license renewal, as required

by 10 CFR 54.4(a), and that the applicant has adequately identified the system component

types subject to an AMR in accordance with the requirements stated in 10 CFR 54.21(a)(1).

2.3.3.22 Reactor Building Chilled Water System

2.3.3.22.1 Summary of Technical Information in the Application

LRA Section 2.3.3.22 describes the RB chilled water system, which supplies chilled water

during normal plant operation to coolers in various areas of the reactor building (including the

Unit 1 and Unit 2 emergency switchgear and load center rooms) and drywell and to the reactor

recirculation pump motor coolers. The RB chilled water system contains safety-related

components relied upon to remain functional during and following DBEs. The failure of

nonsafety-related SSCs in the RB chilled water system potentially could prevent the satisfactory

accomplishment of a safety-related function. In addition, the RB chilled water system performs

functions that support EQ. LRA Table 2.3.3-21 identifies RB chilled water system component

types within the scope of license renewal and subject to an AMR.

2.3.3.22.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.22, UFSAR Section 9.2.12.3, and the licensing renewal

boundary drawings using the evaluation methodology described in SER Section 2.3 and the

guidance in SRP-LR Section 2.3. The staff's review 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 2.3.3.22-1, dated August 27, 2007, the staff noted boundary drawings LR-M-187-2 and

LR-M-2187-2 show several one-inch lines and associated isolation valves as not within the

scope of license renewal. These lines are directly connected to the RB chilled water system

lines that are within the scope of license renewal. The staff requested that the applicant explain

why the sections of pipe and components are not within the scope of license renewal.

In its response to RAI 2.3.3.22-1, dated October 18, 2007, the applicant stated:

PPL's response to RAI 2.1-3, (Reference 3), identified nonsafety-related (NSR)

piping and components, inside primary containment and connected to safetyrelated (SR) piping and components, that are required to remain intact to ensure

the structural integrity of the attached SR piping and components. The identified

nonsafety-related piping and components are in-scope for license renewal based

on the criteria of 10 CFR 54.4(a)(2). The scoping determination for the

nonsafety-related piping and components is based upon review of the governing

piping design analyses. The in-scope portion of the nonsafety-related piping

extends from the nonsafety-related -to-safety-related interface to the analytical

boundaries of the piping analysis which contains the SR piping and components.

2-98
As part of the response to RAI 2.1-3, boundary drawings LR-M-187-2, Revision 1

and LR-M-2187-2, Revision 1 were included to show the revised evaluation

boundaries. The piping and valves that are highlighted in pink (magenta) and

identified with a reference to LR NOTE D are in-scope for the 10 CFR 54.4(a)(2)

function discussed above.

The nonsafety-related piping and valves identified by this RAI are not included in

the piping analyses which include the SR valves HV1 8792B2/HV28792B2,

HV18792B1/HV28792B1, HV18782A2/HV28782A2, HV18782A1/HV28782A1,

HV18792A2/HV28792A2, HV18792A1/HV28792A1, HV18782B2/HV28782B2,

HV18782B1/HV28782B1. The piping and valves are not included in the analyses

because they are small diameter branch lines extending from large diameter

headers. In the governing piping analyses, small diameter branch lines, such as

vents and drains, may be decoupled from the analysis of the headers. This is an

acceptable piping design practice that is employed when it is determined that the

small diameter branch lines do not significantly affect the loads and stresses on

a large diameter header. Therefore, in all cases, the applicable piping analyses,

which are part of the current design basis, support the conclusion that the

nonsafety-related piping and valves identified by this RAI are not required to

remain intact to ensure the structural integrity of the safety-related valves.

As discussed in LRA Section 2.1.1.2.2, and further discussed in the response to

RAI 2.3.3.23-3, nonsafety-related piping inside containment is not required to

satisfy the 10 CFR 54.4(a)(2) criteria for spatial considerations since the SR

equipment inside containment is designed for all potential spatial interactions.

Therefore, the nonsafety-related piping and valves identified by this RAI are not

in-scope for any criteria of 10 CFR 54.4(a)(2).

The staff confirms that the applicant has submitted revised boundary drawings

LR-M-187-2 and LR-M-2187-2.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.22-1 acceptable

because the applicant has clarified that the nonsafety-related piping sections inside

containment and in question are not within the scope of license renewal because they are

outside the analytical boundaries of the piping analysis, and that the safety-related equipment

inside containment is designed for all potential spatial interactions. Therefore, the staff's

concern described in RAI 2.3.3.22-1 is resolved.

2.3.3.22.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI response, and boundary drawings (original and

revised) to determine whether the applicant failed to identify any components within the scope

of license renewal. In addition, the staff's review determined whether the applicant failed to

identify any components subject to an AMR. On the basis of its review, the staff concludes the

applicant has appropriately identified the RB chilled water system mechanical components

within the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has

adequately identified the RB chilled water system mechanical components subject to an AMR,

in accordance with the requirements of 10 CFR 54.21(a)(1) and therefore, the response is

acceptable.

2-99
2.3.3.23 Reactor Building Closed Cooling Water System

2.3.3.23.1 Summary of Technical Information in the Application

LRA Section 2.3.3.23 describes the reactor building closed-cooling water (RBCCW) system,

which provides cooling water in the reactor and radwaste buildings to nonsafety-related

equipment that could carry radioactive fluids or that requires a clean water supply to minimize

long-term corrosion. The RBCCW system contains safety-related components relied upon to

remain functional during and following DBEs. The failure of nonsafety-related SSCs in the

RBCCW system potentially could prevent the satisfactory accomplishment of a safety-related

function. In addition, the RBCCW system performs functions that support EQ. LRA

Table 2.3.3-22 identifies RBCCW system component types within the scope of license renewal

and subject to an AMR.

2.3.3.23.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.23, UFSAR Section 9.2.2, and the licensing renewal

boundary drawings using the evaluation methodology described in SER Section 2.3 and the

guidance in SRP-LR Section 2.3. The staff's review 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 RAIs as discussed below.

In RAI 2.3.3.23-1, dated August 27, 2007, the staff noted boundary drawings LR-M-1 13-1 and

LR-M-2113-1, locations A&B2, A&B3, and A&B4, show RBCCW supply and return to pump seal

heat exchangers within the scope of license renewal; however, the RBCCW supply and return

piping to the motor bearing coils are not shown within the scope of license renewal. The staff

requested that the applicant explain why the piping upstream and/or downstream, including

valves 113012, 213012, 113009, 213009, 113017, and 113020, is not within the scope of

license renewal. Additionally, the applicant was asked to explain why the sensing lines and root

valves connected to the piping bounded by these isolation valves are not within the scope of

license renewal.

In its response to RAI 2.3.3.23-1, dated October 18, 2007, the applicant stated in part:

PPL's response to RAI 2.1-3, part b, sent to the NRC via PLA-6177 dated

April 17, 2007, identified nonsafety-related (NSR) piping and components, inside

primary containment and connected to safety-related (SR) piping and

components, that are required to remain intact to ensure the structural integrity

of the attached SR piping and components. The identified nonsafety-related

piping and components are in-scope for license renewal based on the criteria of

10 CFR 54.4(a)(2). The scoping determination for the nonsafety-related piping

and components is based upon review of the governing piping design analyses.

The in-scope portion of the nonsafety-related piping extends from the nonsafetyrelated -to-safety-related interface to the analytical boundaries of the piping

analysis which contains the safety-related piping and components.

As part of the response to RAI 2.1-3, boundary drawings LR-M-113-1, Revision 1

and LR-M-2113-1, Revision 1 were included to show the revised evaluation

boundaries. The piping and valves that are highlighted in pink (magenta) and

2-100
identified with a reference to "SEE LR NOTE C" are in-scope for the

10 CFR 54.4(a)(2) function discussed above.

The nonsafety-related piping and valves identified by this RAI are not included in

the piping analyses which include the safety-related valves HV1 1345, HV1 1346,

HV21345, and HV21346. The piping and valves are not included in the analyses

for one of two possible reasons: 1) the piping and valves are located on the

unanalyzed side of a physical pipe support anchor which defines the boundary of

the analysis, or 2) the piping and valves are part of small diameter branch lines

extending from the 3" HBD-129/229 and 3" HBD-130/230 headers. In the

governing piping analyses, the small diameter branch lines, including vents and

drains, may be decoupled from the analysis of the headers. This is an

acceptable piping design practice that is employed when it is determined that the

small diameter branch lines do not significantly affect the loads and stresses on

a large diameter header. Therefore, in all cases, the applicable piping analyses,

which are part of the current design basis, support the conclusion that the

nonsafety-related piping and valves identified by this RAI are not required to

remain intact to ensure the structural integrity of the safety-related valves

HV11345, HV11346, HV21345, and HV21346.

As discussed in LRA Section 2.1.1.2.2, and further discussed in the response to

RAI 2.3.3.23-3, nonsafety-related piping inside containment is not required to

satisfy the 10 CFR 54.4(a)(2) criteria for spatial considerations since the safetyrelated equipment inside containment is designed for all potential spatial

interactions. Therefore, the nonsafety-related piping and valves identified by this

RAI are not in-scope for any criteria of 10 CFR 54.4(a)(2).

The staff confirms that the applicant has submitted revised boundary drawings LR-M-1 13-1 and

LR-M-2113-1.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.23-1 acceptable

because the applicant has clarified that the nonsafety-related piping sections inside

containment and in question are not within the scope of license renewal, because they are

outside the analytical boundaries of the piping analysis. Therefore, the staff's concern

described in RAI 2.3.3.23-1 is resolved.

In RAI 2.3.3.23-2, dated August 27, 2007, the staff noted boundary drawing LR-M-1 13-1 and

LR-M-2113-1 show several one-inch lines and associated isolation valves not within the scope

of license renewal. These lines are directly connected to RBCCW main lines that are within the

scope of license renewal. The staff requested that the applicant explain why these listed

sections of pipe and components are not within the scope of license renewal.

In its response to RAI 2.3.3.23-2, dated October 18, 2007, the applicant stated in part:

The RBCCW piping discussed in this RAI is shown on boundary drawings LR-M113-1 and LR-M-2113-1. The reference to drawing LR-M-2143-1 in the first

sentence of the RAI is considered to be a typographical error.

PPL's response to RAI 2.1-3, part b, sent to the NRC via PLA-6177 dated

April 17, 2007, identified nonsafety-related (NSR) piping and components, inside

2-101
primary containment and connected to safety-related (SR) piping and

components, that are required to remain intact to ensure the structural integrity

of the attached safety-related piping and components. The identified nonsafetyrelated piping and components are in-scope for license renewal based on the

criteria of 10 CFR 54.4(a)(2). The scoping determination for the nonsafetyrelated piping and components is based upon review of the governing piping

design analyses. The in-scope portion of the nonsafety-related piping extends

from the nonsafety-related -to-safety-related interface to the analytical

boundaries of the piping analysis which contains the safety-related piping and

components.

As part of the response to RAI 2.1-3, boundary drawings LR-M-1 13-1, Revision 1

and LR-M-2113-1, Revision 1 were included to show the revised evaluation

boundaries. The piping and valves that are highlighted in pink (magenta) and

identified with a reference to "SEE LR NOTE C" are in-scope for the

10 CFR 54.4(a)(2) function discussed above.

The nonsafety-related piping and valves identified by this RAI are not included in

the piping analyses which include the safety-related valves HV1 1345, HV1 1346,

HV21345, and HV21346. The piping and valves are not included in the analyses

for one of two possible reasons: 1) the piping and valves are located on the

unanalyzed side of a physical pipe support anchor which defines the boundary of

the analysis, or 2) the piping and valves are part of small diameter branch lines

extending from the 3" HBD-129/229 and 3" HBD-130/230 headers. In the

governing piping analyses, the small diameter branch lines, including vents and

drains, may be decoupled from the analysis of the headers. This is an

acceptable piping design practice that is employed when it is determined that the

small diameter branch lines do not significantly affect the loads and stresses on

a large diameter header. Therefore, in all cases, the applicable piping analyses,

which are part of the current design basis, support the conclusion that the

nonsafety-related piping and valves identified by this RAI are not required to

remain intact to ensure the structural integrity of the safety-related valves

HV11345, HV11346, HV21345, and HV21346.

As discussed in LRA Section 2.1.1.2.2, and further discussed in the response to

RAI 2.3.3.23-3, nonsafety-related piping inside containment is not required to

satisfy the 10 CFR 54.4(a)(2) criteria for spatial considerations since the safetyrelated equipment inside containment is designed for all potential spatial

interactions. Therefore, the nonsafety-related piping and valves identified by this

RAI are not in-scope for any criteria of 10 CFR 54.4(a)(2).

The staff confirms that the applicant has submitted revised boundary drawings LR-M-1 13-1 and

LR-M-2113-1.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.23-2 acceptable

because the applicant has clarified that the nonsafety-related piping sections inside

containment and in question are not within the scope of license renewal, because they are

outside the analytical boundaries of the piping analysis. Therefore, the staff's concern

described in RAI 2.3.3.23-2 is resolved.

2-102
In RAI 2.3.3.23-3, dated August 27, 2007, the staff noted boundary drawing LR-M-1 13-1,

license renewal Note B states, "Safety-Related components inside containment (designed for

harsh environment) are not plausible targets for spatial interaction." The staff requested that the

applicant provide additional information to support the implausibility of safety-related

components within containment being impacted by failure of nonsafety-related systems.

In its response to RAI 2.3.3.23-3, dated October 18, 2007, the applicant stated:

FSAR Sections 3.6.1.1 and 3.11.1 state that essential systems and equipment

required to mitigate the consequences of a design-basis accident, or to affect a

safe shutdown of the reactor, are designed to remain functional after exposure to

the applicable accident environmental conditions and are qualified for service in

harsh environments, including spray and/or steam. As such, the safety-related

components in the primary containment are designed to remain functional for

conditions that bound any potential leakage, spray, or flooding and the

corresponding environmental effects (e.g., elevated temperatures and

pressures), and are not reasonable targets-for spatial interaction, upon failure of

nonsafety-related components in that structure. Also, based on FSAR Sections

3.6.1.2 - 3.6.2, safety-related components inside containment are protected from

the effects of pipe whip and/or jet impingement (from a high-energy line failure)

by separation, barriers or pipe whip restraints. The portions of high-energy piping

that are inside containment are all safety-related and in the scope of license

renewal based on 10 CFR 54.4(a)(1) scoping criterion. Therefore, nonsafetyrelated mechanical components inside the containment do not have a plausible

potential for failure to impair or prevent the accomplishment of a safety-related

SSC's intended function.

As such, they do not satisfy 10 CFR 54.4(a)(2), scoping criterion and are not

within the scope of license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.23-3 acceptable

because the applicant has provided additional information to support the Note B statement

concerning the implausibility of safety-related components within containment being impacted

by failure of nonsafety-related systems. Therefore, the staff's concern described in

RAI 2.3.3.23-3 is resolved.

In RAI 2.3.3.23-4, dated August 27, 2007, the staff noted boundary drawing LR-M-1 13-1,

location B2, refers to Note C which states "Highlighted nonsafety-related piping is within

analytical boundaries of the seismic analyses for the attached safety-related components."

Given the placement of the note and the highlighting approach, it is unclear as to what specific

components and/or piping is addressed by Note C. The staff requested that the applicant clarify

which specific components and/or piping is within the analytical boundaries of the seismic

analyses.

In its response to RAI 2.3.3.23-4, dated October 18, 2007, the applicant stated:

As discussed in the responses to RAIs 2.3.3.23-1 and 2.3.3.23-2 above, the

evaluation boundaries of the nonsafety-related piping and components inside

containment are based upon the analytical boundaries of the governing piping

design analyses. The in-scope portion of the nonsafety-related piping extends

2-103
from the nonsafety-related -to-safety-related interface to the analytical

boundaries of the piping analysis which contains the safety-related piping and

components.

LR Note "C" applies to all of the pink (magenta)-highlighted piping and valves

inside the primary containment that are part of the HBD-1 29 and HBD-1 30

pipelines. The highlighted piping and valves are required to remain intact to

ensure the structural integrity of the attached safety-related piping and

components and are, therefore, in-scope for license renewal based on the

criteria of 10 CFR 54.4(a)(2).

The note to "SEE LR NOTE C" on drawings LR-M-113-1 and LR-M-2113-1 at

location B2 should be closer to the 4" HBD-130 and 4" HBD-230 lines in location

BI. This would then be similar to the "SEE LR NOTE C" beside the 4" HBD-129

and 4" HBD-229 lines in location B3 of the drawings.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.23-4 acceptable

because the applicant has clarified which components and/or piping is within the analytical

boundaries of the seismic analyses, per Note C. Therefore, the staff's concern described in

RAI 2.3.3.23-4 is resolved.

In RAI 2.3.3.23-5, dated August 27, 2007, the staff noted boundary drawing LR-M-143-2,

locations E7 and E8 show RBCCW three-inch supply to pump seal heat exchangers upstream

of a three-inch to two-inch reducer as being within the scope of license renewal. The RBCCW

piping and components downstream of the reducer are not within the scope of license renewal.

The distinction is unclear between the in-scope piping upstream of the reducer and the out-ofscope piping downstream of the reducer. The staff requested that the applicant explain why the

piping downstream of the three to two-inch reducer is not within the scope of license renewal.

In its response, dated October 18, 2007, the applicant stated:

As discussed in the responses to RAIs 2.3.3.23-1 and 2.3.3.23-2 above, the

evaluation boundaries of the nonsafety-related piping and components inside

containment are based upon the analytical boundaries of the governing piping

design analyses. The in-scope portion of the nonsafety-related piping extends

from the nonsafety-related -to-safety-related interface to the analytical

boundaries of the piping analysis which contains the safety-related piping and

components.

The analytical boundary associated with the piping analysis that includes the

safety-related containment boundary valve HV1 1346 ends at the 3"-to-2" reducer

at the end of the run of 3" HBD-129 piping on LR-M-143-2 at location E7. Since

the piping downstream of the reducer is not part of the piping analysis that

includes valve HV1 1346, it is not required to remain intact to ensure the

structural integrity of the safety-related valve. Therefore, it is not within the scope

of license renewal based on the criteria of 10 CFR 54.4(a)(2).

Based on its review, the staff finds the applicant's response to RAI 2.3.3.23-5 acceptable

because the applicant has clarified that the nonsafety-related piping sections inside

containment and in question are not within the scope of license renewal because they are

outside the analytical boundaries of the piping analysis. Therefore, the staff's concern

described in RAI 2.3.3.23-5 is resolved.

2-104
In RAI 2.3.3.23-6, dated August 27, 2007, the staff noted boundary drawing LR-M-143-2,

location E8, shows RBCCW three-inch supply to pump seal heat exchangers upstream of a

three-inch to two-inch reducer as being within scope of license renewal. The same section of

piping identified in Unit 2 and shown on boundary drawing LR-M-2143-2, is identified as not

within the scope of license renewal. The reason for this difference in RBCCW system scope

between Unit 1 and Unit 2 is unclear. The staff requested that the applicant explain why

boundary locations for these sections of piping are defined differently between Units 1 and 2.

In its response to RAI 2.3.3.23-6, dated October 18, 2007, the applicant stated

As discussed in the response to RAI 2.3.3.23-5 above, the evaluation boundaries

of the nonsafety-related piping and components inside containment are based

upon the analytical boundaries of the governing piping design analyses. The inscope portion of the nonsafety-related piping extends from the nonsafety-related

-to-safety-related interface to the analytical boundaries of the piping analysis

which contains the safety-related piping and components.

The analytical boundary associated with the Unit 1 piping analysis that includes

the safety-related containment boundary valve HV1 1346 ends at the 3"-to-2"

reducer at the end of the run of 3" HBD-129 piping on LR-M-143-2 at location

E7. The analytical boundary associated with the Unit 2 piping analysis that

includes the safety-related containment boundary valve HV21346 ends at a point

just downstream of valve 213008 on the 3" HBD-229 piping on LR-M-2113-1 at

location B2. Thus, the pink-(magenta) highlighted boundary for the Unit 2

RBCCW line ends at valve 213008, which correctly reflects the analytical

boundary as the evaluation boundary for license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.23-6 acceptable

because the applicant has clarified that the nonsafety-related piping sections inside

containment and in question are not within the scope of license renewal, because they are

outside the analytical boundaries of the piping analysis. Therefore, the staff's concern

described in RAI 2.3.3.23-6 is resolved.

In RAI 2.3.3.23-7, dated August 27, 2007, the staff noted boundary drawing LR-M-143-2,

locations E7 and E8 show RBCCW supply to pump seal heat exchangers pipe section

three-inch HBD-129 within the scope of license renewal. The RBCCW pump seal heat

exchangers return line identified as three-inch HBD-130 is not within scope for license renewal

on boundary drawing LR-M-143, but identified as within the scope of license renewal on

boundary drawing LR-M-1 13, locations A2 and A4. It is unclear why three-inch HBD-129, on

boundary drawing LR-M-143 is within scope for license renewal, whereas three-inch HBD-130

on boundary drawing LR-M-143 is not within the scope of license renewal. The staff requested

that the applicant explain why the return piping from the RBCCW pump seal heat exchangers is

not within the scope of license renewal.

In its response to RAI 2.3.3.23-7, dated October 18, 2007, the applicant stated:

As discussed in the response to RAI 2.3.3.23-5 above, the evaluation boundaries

of the nonsafety-related piping and components inside containment are based

2-105
upon the analytical boundaries of the governing piping design analyses. The inscope portion of the nonsafety-related piping extends from the nonsafety-related

-to-safety-related interface to the analytical boundaries of the piping analysis

which contains the safety-related piping and components.

The analytical boundaries associated with the piping analysis that includes the

safety-related containment boundary valve HV1 1345 end just upstream of

FE1 1343A and FE1 1343B on the 3" HBD-130 piping on LR-M-1 13-1 at locations

A2 and A4. The analytical boundary does not encompass any components

shown on LR-M-143-2. Thus, the pink-highlighted boundary ends just upstream

of the FE's on LR-M-1 13-1 and is not continued to any piping represented on

LR-M-143-2. The highlighting provides an accurate representation of all piping

and piping components that are within the boundaries of the piping analysis and,

therefore, within the scope of license renewal.

Since the 3" HBD-130 piping shown on LR-M-143-2 at location E8 is beyond the

analytical boundary of the piping analysis that includes valve HV1 1345, it is not

required to remain intact to ensure the structural integrity of the safety-related

valve, and, therefore, it is not within the scope of license renewal based on the

criteria of 10 CFR 54.4(a)(2).

Based on its review, the staff finds the applicant's response to RAI 2.3.3.23-7 acceptable

because the applicant has clarified that the nonsafety-related piping sections inside

containment and in question are not within the scope of license renewal, because they are

outside the analytical boundaries of the piping analysis. Therefore, the staff's concern

described in RAI 2.3.3.23-7 is resolved.

2.3.3.23.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and boundary drawings to determine

whether the applicant failed to identify any components within the scope of license renewal. In

addition, the staff's review determined whether the applicant failed to identify any components

subject to an AMR. On the basis of its review, the staff concludes the applicant has

appropriately identified the RBCCW system mechanical components within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

RBCCW system mechanical components subject to an AMR, in accordance with the

requirements of 10 CFR 54.21(a)(1), and therefore, the response is acceptable.

2.3.3.24 Reactor Building HVAC System

2.3.3.24.1 Summary of Technical Information in the Application

LRA Section 2.3.3.24 describes the reactor building (RB) HVAC system, which during normal

plant operation serves three ventilation zones. In addition to ventilating three separate zones

during normal plant operation, the RB HVAC system also serves during DBA conditions, various

air cooling systems. The RB HVAC system contains safety-related components relied upon to

remain functional during and following DBEs. The failure of nonsafety-related SSCs in the RB

HVAC system potentially could prevent the satisfactory accomplishment of a safety-related

function. In addition, the RB HVAC system performs functions that support fire protection and

2-106
EQ. LRA Table 2.3.3-23 identifies RB HVAC system component types within the scope of

license renewal and subject to an AMR.

2.3.3.24.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the RB HVAC system mechanical components within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the system components subject to an AMR in accordance with the requirements

stated in 10 CFR 54.21(a)(1).

2.3.3.25 Reactor Nonnuclear Instrumentation System

2.3.3.25.1 Summary of Technical Information in the Application

LRA Section 2.3.3.25 describes the reactor non-nuclear instrumentation (NIS) system, which

consists of the instrumentation for operation of the nuclear boiler for normal power generation,

shutdown and refueling operations, and transient and accident conditions. The reactor non-NIS

system contains safety-related components relied upon to remain functional during and

following DBEs. In addition, the reactor non-NIS system performs functions that support fire

protection, ATWS, SBO, and EQ. LRA Table 2.3.3-24 identifies reactor non-NIS system

component types within the scope of license renewal and subject to an AMR.

2.3.3.25.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.25 and UFSAR Sections 6.2 and 7.0 using the evaluation

methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to

verify that the applicant has not omitted from the scope of license renewal any components with

intended functions, pursuant to 10 CFR 54.4(a). The staff then reviewed those components that

the applicant has identified as within the scope of license renewal to verify that the applicant

has not omitted any passive and long-lived components subject to an AMR, in accordance with

the requirements of 10 CFR 54.21(a)(1).

In RAI 2.3.3.25-1, dated October 24, 2007, the staff requested that the applicant provide

additional information regarding boundary drawing LR-M-1 23-12, which depicts multiple

"insulated couplings or unions." The staff also asked the applicant to clarify how these

components are included in LRA Table 2.3.3-24 for components subject to an AMR, as a

pressure boundary and; if excluded, provide justification.

In its response to RAI 2.3.3.25-1, dated November 14, 2007, the applicant stated:

Boundary drawing LR-M-123-12 contains the component type "insulated

couplings or unions." The couplings and unions on LR-M-123-12 that are within

the scope of license renewal are those that contains fluids and are located in the

* Reactor Building, therefore having the potential for spatial interaction with safetyrelated components. These components are nonsafety-related and meet the

scoping criteria of 10 CFR 54.4(a)(2).

2-107
In accordance with PPL's scoping methodology, those components are included

within the evaluation boundary of the Sampling System instead of the Reactor

Non-nuclear Instrumentation System. As described in LRA Section 2.1.2.1.3, inline components that are in-scope for 10 CFR 54.4(a)(2), which would include

"insulated couplings or unions," are evaluated on a commodity group basis as

piping and piping components. The insulated couplings and unions are included

in LRA Section 2.3.3.28, Sampling System, and were identified as subject to

aging management review in Table 2.3.3-27 under the component type "Piping

and Piping Components." The couplings and unions that are subject to aging

management review perform an intended function of Structural Integrity.

No changes to the LRA or boundary drawings were required per this response.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.25-1 acceptable

because the applicant has provided the requested clarification that these components were

included in LRA Section 2.3.3.28 and in Table 2.3.3-27, as components subject to an AMR.

Therefore, the staff's concern described in RAI 2.3.3.25-1 is resolved.

2.3.3.25.3 Conclusion

The staff reviewed the LRA, UFSAR, boundary drawings, and RAI response to determine

whether the applicant failed to identify any SSCs within the scope of license renewal. In

addition, the staff's review determined whether the applicant failed to identify any components

subject to an AMR. On the basis of its review, the staff concludes that the applicant has

adequately identified the reactor non-NIS components within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the reactor

non-NIS components subject to an AMR in accordance with the requirements of

10 CFR 54.21(a)(1) and therefore, the response is acceptable.

2.3.3.26 Reactor Water Cleanup System

2.3.3.26.1 Summary of Technical Information in the Application

LRA Section 2.3.3.26 describes the reactor water cleanup (RWCU) system, which continuously

purifies the reactor water. The RWCU system contains safety-related components relied upon

to remain functional during and following DBEs. The failure of nonsafety-related SSCs in the

RWCU system potentially could prevent the satisfactory accomplishment of a safety-related

function. In addition, the RWCU system performs functions that support fire protection, ATWS,

and EQ. LRA Table 2.3.3-25 identifies RWCU system component types within the scope of

license renewal and subject to an AMR.

2.3.3.26.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that applicant has

appropriately identified the RWCU system mechanical components within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

system components subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2-108
2.3.3.27 Residual Heat Removal Service Water System

2.3.3.27.1 Summary of Technical Information in the Application

LRA Section 2.3.3.27 describes the RHRSW System, which is a safety-related system that is

designed to provide a reliable source of cooling water to support RHR system operation and for

post-accident core and containment flooding. The RHRSW system contains safety-related

components relied upon to remain functional during and following DBEs. The failure of

nonsafety-related SSCs in the RHRSW system potentially could prevent the satisfactory

accomplishment of a safety-related function. In addition, the RHRSW system performs

functions that support fire protection, ATWS, and EQ. LRA Table 2.3.3-26 identifies RHRSW

system component types within the scope of license renewal and subject to an AMR.

2.3.3.27.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.27, UFSAR Section 9.2.6, and the licensing renewal

boundary drawings using the evaluation methodology described in SER Section 2.3 and the

guidance in SRP-LR Section 2.3. The staff's review identified areas in which additional

information was necessary to complete the review of the applicant's scoping and screening

results. In addition to RAIs 2.3.3.27-1 and 2.3.3.27-2 related to boundary drawing continuation

errors discussed in SER Section 2.3.3, the applicant responded to the staff's RAts as discussed

below.

In RAI 2.3.3.27-3, dated August 27, 2007, the staff noted that boundary drawing LR-M-2112-1,

location F7 depicts pipe sections downstream of PSV21213B and PSV21212B that are not

within the scope of license renewal. However, similar components downstream of PSV21213A

and PSV21212A are within the scope of license renewal. the staff requested that the applicant

explain why these nonsafety-related piping and components connected to safety-related

components downstream of PSV21213B and PSV21212B are not within the scope of license

renewal.

In its response to RAI 2.3.3.27-3, dated October 18, 2007, the applicant stated:

The pipe sections downstream of PSV21213B and PSV21212B, labeled as

going to "LRW", are within the scope of license renewal based on

10 CFR 54.4(a)(2) as nonsafety-related for spatial interaction and are subject to

AMR. The highlighting was inadvertently missed and these two pipe sections

have been highlighted in Revision 1 to drawing LR-M-2112-1. Since this is a

highlighting omission, and the materials and environments are already included

in LRA Section 2.3.3.27, no LRA changes are needed.

The staff confirms that the applicant has submitted revised boundary drawing

LR-M-2112-1.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.27-3 acceptable

because the applicant has clarified that these pipe sections are within scope of license renewal

and has revised the applicable boundary drawings. Therefore, the staff's concern described in

RAI 2.3.3.27-3 is resolved.

2-109
In RAI 2.3.3.27-4, dated August 27, 2007, the staff noted that boundary drawing LR-M-1 12-2,

Revision 1, locations D3 and D8 show RHRSW piping from three-inch JRD-31 and three-inch

JRD-32 to the vault sump and to valves 012040 and 012041, respectively, as not within the

scope of license renewal. The staff requested that the applicant explain why these sections of

piping are not within the scope of license renewal.

In its response to RAI 2.3.3.27-4, dated January 3, 2008, the applicant stated:

The three-inch pipe lines JRD-31 and JRD-32 have been abandoned in place.

These pipe sections do not contain any fluid that could interact with surrounding

equipment. These three-inch lines are in-scope because they are connected to

and provide structural support for the connected safety-related piping. The oneinch piping and the valves 012031, 013030, 012038, and 012041 that are

connected to the three-inch pipe lines JRD-31 and JRD-32 do not provide any

structural support function for the three-inch JRD-31 and JRD-32 piping or the

safety-related piping connected to the three-inch pipe lines JRD-31 and JRD-32.

Therefore, neither the one-inch piping nor the associated valves are within the

scope of license renewal for license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.27-4 acceptable

because the applicant has clarified that this piping does not contain any fluid that could interact

with surrounding equipment and that the one-inch lines and valves off of three-inch JRD-31 and

three-inch JRD-32 do not provide any structural support function. Therefore, the staff's concern

described in RAI 2.3.3.27-4 is resolved.

2.3.3.27.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and boundary drawings (original and

revised) to determine whether the applicant failed to identify any components within the scope

of license renewal. In addition, the staff's review determined whether the applicant failed to

identify any components subject to an AMR. On the basis of its review, the staff concludes the

applicant has appropriately identified the RHRSW system mechanical components within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the RHRSW system mechanical components subject to an AMR, in accordance with

the requirements of 10 CFR 54.21 (a)(1) and therefore, the response is acceptable.

2.3.3.28 Sampling System

2.3.3.28.1 Summary of Technical Information in the Application

LRA Section 2.3.3.28 describes the sampling system, which monitors the operation of plant

equipment for information needed to make operational decisions. The failure of

nonsafety-related SSCs in the sampling system potentially could prevent the satisfactory

accomplishment of a safety-related function. LRA Table 2.3.3-27 identifies sampling system

component types within the scope of license renewal and subject to an AMR.

2-110
2.3.3.28.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that the applicant has

appropriately identified the sampling system mechanical components within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the system components subject to an AMR in accordance with the requirements

stated in 10 CFR 54.21(a)(1).

2.3.3.29 Sanitary Drainage System

2.3.3.29.1 Summary of Technical Information in the Application

LRA Section 2.3.3.29 describes the sanitary drainage system (SDS), which collects liquid

wastes from all plumbing fixtures of the plant outside restricted access areas. The drain lines

were designed to accommodate fire protection system design flow when actuated. The failure

of nonsafety-related SSCs in the SDS potentially could prevent the satisfactory accomplishment

of a safety-related function. LRA Table 2.3.3-28 identifies SDS component types within the

scope of license renewal and subject to an AMR.

2.3.3.29.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the LRA

and UFSAR, the staff concludes that applicant has appropriately identified the SDS mechanical

component types within the scope of license renewal, as required by 10 CFR 54.4(a), and that

the applicant has adequately identified the system component types subject to an AMR in

accordance with the requirements stated in 10 CFR 54.21(a)(1).

2.3.3.30 Service Air System

2.3.3.30.1 Summary of Technical Information in the Application

LRA Section 2.3.3.30 describes the service air system (SAS), which provides compressed air

for service air outlets located throughout the plant and a backup system for instrument air. The

failure of nonsafety-related SSCs in the SAS potentially could prevent the satisfactory

accomplishment of a safety-related function. LRA Table 2.3.3-29 identifies SAS component

types within the scope of license renewal and subject to an AMR.

2.3.3.30.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that the applicant has

appropriately identified the SAS mechanical components within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the system

components subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2-111
2.3.3.31 Service Water System

2.3.3.31.1 Summary of Technical Information in the Application

LRA Section 2.3.3.31 describes the SWS, which removes heat from heat exchangers in the

control structure and turbine, reactor, and radwaste buildings, and transfers it to the cooling

towers where it is dissipated. The failure of nonsafety-related SSCs in the SWS potentially

could prevent the satisfactory accomplishment of a safety-related function. LRA Table 2.3.3-30

identifies SWS component types within the scope of license renewal and subject to an AMR.

2.3.3.31.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.31, UFSAR Section 9.2.1.2, and the licensing renewal

boundary drawings using the evaluation methodology described in SER Section 2.3 and the

guidance in SRP-LR Section 2.3. The staff's review identified areas in which additional

information was necessary to complete the review of the applicant's scoping and screening

results. In addition to RAI 2.3.3.31-2 related to boundary drawing continuation errors discussed

in LRA Section 2.3.3, the applicant responded to the staff's RAIs as discussed below.

In RAI 2.3.3.31-1, dated August 27, 2007, the staff noted that boundary drawing LR-M-1 10-1,

locations G2 and G3 show pipe tunnel coolers (1A, 1B, IC, and 1D), that are not within the

scope of license renewal. The staff requested that the applicant explain why the pipe tunnel

coolers are not within the scope of license renewal.

In its response to RAI 2.3.3.31-1, dated October 18, 2007, the applicant stated:

The pipe tunnel coolers (1A, 1B, 1C, and 1D) are within the scope of license

renewal under criteria 10 CFR 54.4(a)(2). The components which are subject to

aging management review are those that may contain a liquid and have the

potential for spatial interaction. Therefore, the channels/heads for the unit

coolers are subject to aging management review. The pipe tunnel unit cooler

channels/head are addressed as components of the Reactor Building HVAC

System and are included in LRA Table 2.3.3-23 under the line item "Unit coolers,

drain pans, drain piping, channels/heads" with an intended function of structural

integrity.

The staff confirms that the applicant has submitted revised boundary drawing LR-M-1 10-1 to

indicate that pipe tunnel coolers (1A, 1V, 1C, and 1 D) are within the scope of license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.31-1 acceptable

because the applicant has clarified that the pipe tunnel coolers are within the scope of license

renewal and subject to AMR. The staff confirms that the applicant has revised the boundary

drawing to reflect this change. Therefore, the staff's concern described in RAI 2.3.3.31-1 is

resolved.

In RAI 2.3.3.31-3, dated August 27, 2007, the staff noted boundary drawing LR-M-21 10-1,

locations G2 and G3 show pipe tunnel coolers (2A, 2B, 2C, and 2D) that are within the scope of

license renewal. LRA Table 2.3.3-30, "Service Water System Components Subject to Aging

Management Review," does not list coolers as a component subject to an AMR. The staff

2-112
requested that the applicant explain why these pipe tunnel coolers are not included in LRA

Table 2.3.3-30.

In its response to RAI 2.3.3.31-3, dated October 18, 2007, the applicant stated:

Pipe Tunnel Coolers (2A, 2B, 2C, and 2D), shown on drawing LR-M-21 10-1 at

G2 and G3, are within the scope of license renewal and are subject to AMR.

Based on PPL's scoping methodology, these cooling coils have been scoped as

part of the Reactor Building HVAC Systems and are included, based on

10 CFR 54.4(a)(2), in LRA Section 2.3.3.24 and associated Table 2.3.3-23.

These pipe tunnel coolers are included on LRA page 2.3-99 as part of the last

line item of Table 2.3.3-23, with a component type of "Unit Coolers, drain pans,

drain piping, channels/heads" with an intended function of "Structural Integrity."

Based on its review, the staff finds the applicant's response to RAI 2.3.3.31-3 acceptable

because the applicant has clarified that the pipe tunnel coolers are within the scope of license

renewal and subject to AMR. Therefore, the staff's concern described in RAI 2.3.3.31-3 is

resolved.

2.3.3.31.3 Conclusion

The staff reviewed the LRA, UFSAR, boundary drawings, and RAI responses to determine

whether the applicant failed to identify any components within the scope of license renewal. In

addition, the staff's review determined whether the applicant failed to identify any components

subject to an AMR. On the basis of its review, the staff concludes the applicant has

appropriately identified the SWS mechanical components within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the SWS

mechanical components subject to an AMR, in accordance with the requirements of

10 CFR 54.21(a)(1 ) and therefore, the response is acceptable.

2.3.3.32 Standby Liquid Control System

2.3.3.32.1 Summary of Technical Information in the Application

LRA Section 2.3.3.32 describes the SLC system, an independent, diverse backup to the control

rod drive system. The SLC system function is to inject a neutron-absorbing solution into the

reactor to achieve and maintain sub-criticality if control rods cannot be inserted manually. The

SLC system contains safety-related components relied upon to remain functional during and

following DBEs. The failure of nonsafety-related SSCs in the SLC system potentially could

prevent the satisfactory accomplishment of a safety-related function. In addition, the SLC

system performs functions that support ATWS and EQ. LRA Table 2.3.3-31 identifies SLC

system component types within the scope of license renewal and subject to an AMR.

2.3.3.32.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.32 and UFSAR Section 9.3.5 using the evaluation

methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3. The

staff's review identified areas in which additional information was necessary to complete the

2-113
review of the applicant's scoping and screening results. The applicant responses to the staff's

RAls as discussed below.

In RAI 2.3.3.32-1, dated October 24, 2007, the staff noted boundary drawing LR-M-148-1

shows the ventilation lines from the test tanks and storage tanks as not within the scope of

license renewal. The staff requested that the applicant clarify whether the lines are within the

scope of license renewal and subject to an AMR and; if excluded, provide justification.

In its response to RAI 2.3.3.32-1, dated November 14, 2007, the applicant stated:

The standby liquid control test tank (1/2T203) and ventilation line are nonsafetyrelated. The test tank provides support for nonsafety-related piping attached to

safety-related piping and is therefore within the scope of license renewal. The

ventilation line for the test tank is not attached to safety-related piping and does

not contain a fluid that could cause a spatial interaction with safety-related

equipment. Therefore, the test tank ventilation line is not within the scope of

license renewal.

The standby liquid control storage tank (1/2T204) is safety-related. Further

evaluation has been determined that the ventilation line for the storage tank

should be within the scope of license renewal and subject to AMR. The

ventilation line is evaluated as part of the storage tank pressure boundary and is

therefore addressed under the "Tanks, SLC storage tanks (1/2T204)" in

Table 2.3.3-31. The evaluation for the storage tank in Table 3.3.2-31

encompasses the vent line. No changes to the LRA were required.

The staff confirms that the applicant has submitted revised boundary drawings LR-M-148-1 and

LR-M-2148-1.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.32-1 acceptable

because the applicant has justified not including the test tank ventilation line within the scope of

license renewal and has identified the ventilation line for the standby liquid control storage tank

as within the scope of license renewal and subject to an AMR. Therefore, the staff's concern

described in RAI 2.3.3.31-3 is resolved.

In RAI 2.3.3.32-2, dated October 24, 2007, that staff noted boundary drawing LR-M-148-1

shows what appears to be a hatch on the SLC storage tank (1/2T204). It was unclear to the

staff whether the hatch and closure mechanism were included as part of the tank. The staff

requested that the applicant clarify whether the tank hatches and closure mechanisms are

within the scope of license renewal and subject to an AMR. Also, the staff requested that the'

applicant revise LRA Table 2.3.3-31, as necessary, to reflect its response or explain under what

component they were included.

In its response to RAI 2.3.3.32-2, dated November 14, 2007, the applicant stated:

The SLC storage tank hatches shown on boundary drawings LR-M-148-1 and

LR-M-2148-1 are within the scope of license renewal. The highlighting of the

hatches on drawings LR-M-148-1 and LR-M-2148-1 was inadvertently omitted.

2-114
The hatches, including the closure mechanisms, are considered to be part of the

pressure boundary of the storage tanks. The hatches are included in the line

item "Tanks, SLC storage tanks (1/2T204)" in LRA Table 2.3.3-31 as subject to

AMR. The closure mechanisms are included in the line item "Bolting" in LRA

Table 2.3.3-31 as subject to AMR. No changes to the LRA were required.

The staff confirms that the applicant has revised boundary drawings LR-M-148-1 and

LR-M-2148-1.

2.3.3.32.3 Conclusion

The staff reviewed the LRA, UFSAR, drawings (original and revised), and RAI responses to

determine whether the applicant failed to identify any components within the scope of license

renewal. In addition, the staff's review determined whether the applicant failed to identify any

components subject to an AMR. On the basis of its review, the staff concludes the applicant

has appropriately identified the SLC system mechanical components within the scope of license

renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately identified the

SLC mechanical components subject to an AMR, in accordance with the requirements of

10 CFR 54.21(a)(1 ) and therefore, the response is acceptable.

2.3.3.33 Turbine Building Closed Cooling Water System

2.3.3.33.1 Summary of Technical Information in the Application

LRA Section 2.3.3.33 describes the TB closed cooling water (TBCCW) system, which is a

closed-loop cooling system that transfers heat from miscellaneous turbine plant components to

the SWS through the TBCCW heat exchangers. The failure of nonsafety-related SSCs in the

TBCCW system potentially could prevent the satisfactory accomplishment of a safety-related

function. LRA Table 2.3.3-32 identifies TBCCW system component types within the scope of

license renewal and subject to an AMR.

2.3.3.33.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.33, UFSAR Section 9.2.3, and the licensing renewal

boundary drawings using the evaluation methodology described in SER Section 2.3 and the

guidance in SRP-LR Section 2.3. The staff's review 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 2.3.3.33-1 dated August 27, 2007, the staff noted that the TBCCW system was

determined to meet the scoping criteria pursuant to 10 CFR 54.4(a)(2) to maintain the integrity

of nonsafety-related piping components required to support the safety-related functional

boundary of the SWS. This is shown in SWS boundary drawings LR-M-109-2 and

LR-M-2109-2. However, boundary drawings defining the license renewal boundaries and

components subject to an AMR were not provided. The staff requested that the applicant

provide boundary drawings or documentation for the TBCCW system licensing renewal

boundaries and components identified in LRA Section 2.3.3.33.

2-115
In its response dated October 18, 2007, the applicant stated:

The only components in-scope for the TBCCW system are the heat exchanger

shell (including channels/heads), connected piping and bolting which provide a

nonsafety affecting safety anchor for the Emergency Service Water System. The

TBCCW components within the scope of license renewal (highlighted pink

(magenta)) are depicted on Service Water System boundary drawings LR-M109-2 and on LR-M-2109-2 which best illustrates the connection to the

Emergency Service Water System Piping 4" HRC-1 14/214 and 4" HRC-134/234.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.33-1 acceptable

because the applicant has clarified that the TBCCW components within the scope of license

renewal are adequately identified in SWS boundary drawings. Therefore, the staff's concern

described in RAI 2.3.3.33-1 is resolved.

2.3.3.33.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI response, and boundary drawings (original and

revised) to determine whether the applicant failed to identify any components within the scope

of license renewal. In addition, the staff's review determined whether the applicant failed to

identify any components subject to an AMR. On the basis of its review, the staff concludes the

applicant has appropriately identified the TBCCW system mechanical components within the

scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the TBCCW system mechanical components subject to an AMR in accordance with

the requirements of 10 CFR 54.21(a)(1) and therefore, the response is acceptable.

2.3.4 Steam and Power Conversion Systems

LRA Section 2.3.4 identifies the steam and power conversion systems SCs subject to an AMR

for license renewal. The applicant described the supporting SCs of the steam and power

conversion systems in the following LRA sections:

* 2.3.4.1 Auxiliary boiler system

* 2.3.4.2 Bypass steam system

* 2.3.4.3 Condensate transfer and storage system

* 2.3.4.4 Condenser and air removal system

* 2.3.4.5 Feedwater system

* 2.3.4.6 Main steam system

* 2.3.4.7 Main turbine system

* 2.3.4.8 Makeup demineralizer system

* 2.3.4.9 Makeup transfer and storage system

* 2.3.4.10 Reactor feed pump turbines system

* 2.3.4.11 Refueling water transfer and storage system

2.3.4.1 Auxiliary Boiler System

2.3.4.1.1 Summary of Technical Information in the Application

LRA Section 2.3.4.1 describes the auxiliary boiler (AB) system, which has two boilers that

supply steam to various plant processes. The failure of nonsafety-related SSCs in the AB

2-116
system potentially could prevent the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.4-1 identifies AB system component types within the scope of license renewal

and subject to an AMR.

2.3.4.1.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, and UFSAR, the staff concludes that the applicant has appropriately identified the AB

system mechanical component types within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the system component types

subject to an AMR in accordance with the requirements stated in 10 CFR 54.21(a)(1).

2.3.4.2 Bypass Steam System

2.3.4.2.1 Summary of Technical Information in the Application

LRA Section 2.3.4.2 describes the bypass steam system, which bypasses MS directly to the

condenser to control reactor pressure under certain normal operating conditions. The failure of

nonsafety-related SSCs in the bypass steam system potentially could prevent the satisfactory

accomplishment of a safety-related function. LRA Table 2.3.4-2 identifies bypass steam system

component types within the scope of license renewal and subject to an AMR.

2.3.4.2.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, and UFSAR, the staff concludes that the applicant has appropriately identified the bypass

steam system mechanical component types within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the system component types

subject to an AMR in accordance with the requirements stated in 10 CFR 54.21(a)(1).

2.3.4.3 Condensate Transfer and Storage System

2.3.4.3.1 Summary of Technical Information in the Application

LRA Section 2.3.4.3 describes the condensate transfer and storage (CTS) system, which

consists of an atmospheric condensate storage tank for each unit, two condensate transfer

pumps, a common atmospheric refueling water storage tank for both units, and two refueling

water pumps. The failure of nonsafety-related SSCs in the CTS system potentially could

prevent the satisfactory accomplishment of a safety-related function. The CTS system also

performs functions that support fire protection, ATWS, and SBO. LRA Table 2.3.4-3 identifies

CTS system component types within the scope of license renewal and subject to an AMR.

2.3.4.3.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.3, UFSAR Section 9.2.10, and the licensing renewal

boundary drawings using the evaluation methodology described in SER Section 2.3 and the

guidance in SRP-LR Section 2.3. The staff's review 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 RAIs as discussed below.

2-117
In RAIs 2.3.4.3-1 and 2.3.4.3-2, dated August 27, 2007, the staff noted instances where certain

piping was shown within the scope of license renewal on one boundary drawing but shown not

within the scope of license renewal when continued on another boundary drawing.

The staff requested that the applicant explain why the sections of pipe in question are not within

the scope of license renewal on both boundary drawings.

In its response to RAls 2.3.4.3-1 and 2.3.4.3-2, dated October 18, 2007, the applicant corrected

the inconsistency by clarifying what portion of the piping is within the scope of license renewal.

The staff confirms that the applicant has submitted corrected boundary drawings which

highlight sections of piping that are within the scope of license renewal.

Based on its review, the staff finds the applicant's response to the RAIs 2.3.4.3-1 and 2.3.4.3-2

acceptable because the applicant has clarified that the piping in question is within the scope of

license renewal and subject to AMR and has revised the affected boundary drawings to identify

the license renewal boundaries. Therefore, the staff's concern described in RAIs 2.3.4.3-1 and

2.3.4.3-2 is resolved.

In RAI 2.3.4.3-3, dated August 27, 2007, the staff noted boundary drawing LR-M-1 18-3,

location A7, shows demineralized water piping 4-inch JCD-59 as not within the scope of license

renewal. Its continuation on boundary drawing LR-M-1 08-1, location C10, is shown as within the

scope of license renewal. The staff requested that the applicant explain why this section of pipe

is not within the scope of license renewal.

In its response to RAI 2.3.4.3-3, dated October 18, 2007, the applicant stated in part:

The inconsistency in highlighting the portion of piping 4" JCD-59 located on

LR-M-108-2 at C10 was identified during a previous drawing review and the

highlighting has been corrected. The portion of 4" JCD-59 that is within the

scope of license renewal and subject to AMR extends from condensate storage

tank 0T522B, shown on LR-M-108-1 at B8, back to the penetration from the

turbine building, shown at C9. The portion upstream of that penetration, back to

the continuation arrow from "M-1 18-3 A7", shown at C10, is in the turbine

building and therefore, as described in LRA Section 2.1.1.2.2, is not within the

scope of license renewal. The portion of JCD-59 between the continuation arrow

and the penetration from the turbine building should not have been highlighted.

4" JCD-59, from and including the continuation arrow on LR-M-108-1 at C10 to

the penetration at C9, is no longer highlighted.

The staff confirms that the applicant has submitted revised boundary drawing LR-M-1 08-1.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.3-3 acceptable

because the applicant has clarified that the piping within the TB is not within the scope of

license renewal and has revised boundary drawing LR-M-108-1. Therefore, the staff's concern

described in RAI 2.3.4.3-3 is resolved.

In RAI 2.3.4.3-4, dated August 27, 2007, the staff noted boundary drawing LR-M-108-1,

location B2, includes license renewal Note C regarding RWST 0T501. It states, "Refueling

2-118
Water Storage Tank could flood the adjacent condensate storage area containing safetyrelated instruments." The tank is shown within the scope of license renewal; however, none of

the piping penetrations or piping connected to the tank is within the scope of license renewal.

The staff requested that the applicant explain why piping penetrations and connected piping are

not within the scope of license renewal.

In its response to RAI 2.3.4.3-4, dated October 18, 2007, the applicant stated:

The refueling storage area and Unit 1 condensate storage area are located

outdoors and surrounded by walls that form a common berm/retention basin.

The berm/retention basin is designed to retain the total volume of water

contained in both the refueling water storage tank (RWST) and the Unit 1 CST if

both tanks rupture simultaneously. The basin includes a sump along the west

wall, near the RWST, and the safety-related SCs in the condensate storage area

(i.e., level instrumentation associated with HPCI/RCIC supply) are located in the

southeast corner, with the CST between them and the RWST and associated

piping. As such, spray or leakage from the RWST and associated piping in the

storage areas will not impair or prevent the accomplishment of a safety-related

function, but would drain to the sump. However, rupture of the RWST would

flood the retention basin to a level that could, conservatively, result in spatial

interaction with the safety-related SCs in the condensate storage area.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.3-4 acceptable

because the applicant has clarified that a berm and/or retention basin is designed to retain the

total volume of water contained in both the RWST and the Unit 1 CST, if both tanks

simultaneously rupture. Therefore, the staff's concern described in RAI 2.3.4.3-4 is resolved.

In RAI 2.3.4.3-5, dated August 27, 2007, the staff noted boundary drawing LR-M-108-1,

locations G6 and H6, shows condensate transfer pump discharge lines as being within the

scope of license renewal; however, the recirculation lines, two-inch HCD-1 3, between check

valves 008043 and 008053 and four-inch HCD-13 are shown as not within the scope of license

renewal. The staff requested that the applicant explain why these pipe sections are not within

the scope of license renewal.

In its response to RAI 2.3.4.3-5, dated October 18, 2007, the applicant stated:

The condensate transfer pumps and the associated discharge lines are within

the scope of license renewal because they are required to supply the ECCS and

RCIC keep fill system to prevent water hammer whenever operation of these

systems is initiated for mitigation of fire and station blackout events, thus

meeting the scoping criteria of 10 CFR 54.4(a)(3). However, the flowpath from

the condensate transfer pumps back to the condensate storage tank (0T522A) is

not required to support this (a)(3) function. It has also been determined that

failure of this flowpath will not prevent the accomplishment of an (a)(1) function,

as it is not connected to nor located near safety-related SSCs.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.3-5 acceptable

because the applicant has clarified that the piping in question is not required to support the fire

protection function for SBO events, pursuant to 10 CFR 54.4(a)(3). Therefore, the staff's

concern described in RAI 2.3.4.3-5 is resolved.

2-119
In RAI 2.3.4.3-6, dated August 27, 2007, the staff noted boundary drawing LR-M-108-1,

location H5, shows piping one-inch HCD-9 from six-inch HCD-9 to valve 008051 as being not

within the scope of license renewal. The staff requested that the applicant explain why this

section of pipe is not within the scope of license renewal.

In its response to RAI 2.3.4.3-6, dated October 18, 2007, the applicant stated the one-inch

HCD-9 piping from the six-inch HCD-9 piping line to valve 008051 is within the scope of license

renewal. The staff confirms that the applicant has submitted revised boundary drawing

LR-M-108-1 placing this piping within the scope of license renewal, in accordance with

10 CFR 54.4(a)(3).

Based on its review, the staff finds the applicant's response to RAI 2.3.4.3-6 acceptable

because the applicant has clarified that the subject piping is within the scope of license renewal

and subject to an AMR and has revised boundary drawing LR-M-108-1 to identify the revised

license renewal boundary. Therefore, the staff's concern described in RAI 2.3.4.3-6 is resolved.

2.3.4.3.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and boundary drawings (original and

revised) to determine whether the applicant failed to identify any components within the scope

of license renewal. In addition, the staff's review determined whether the applicant failed to

identify any components subject to an AMR. On the basis of its review, the staff concludes the

applicant has appropriately identified the CTS system mechanical components within the scope

of license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the CTS system mechanical components subject to an AMR, in accordance with the

requirements of 10 CFR 54.21(a)(1) and therefore, the response is acceptable.

2.3.4.4 Condenser and Air Removal System

2.3.4.4.1 Summary of Technical Information in the Application

LRA Section 2.3.4.4 describes the condenser and air removal system. The failure of

nonsafety-related SSCs in the condenser and air removal system potentially could prevent the

satisfactory accomplishment of a safety-related function. LRA Table 2.3.4-4 identifies

condenser and air removal system component types within the scope of license renewal and

subject to an AMR.

2.3.4.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.4, UFSAR Sections 10.4.1 and 10.4.2, and the licensing

renewal boundary drawings using the evaluation methodology described in SER Section 2.3

and the guidance in SRP-LR Section 2.3. The staff's review 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 2.3.4.4-1, dated August 27, 2007, the staff noted that boundary drawing LR-M-141-1

(2141-1), location E9 shows this line highlighted in green as it exits the steam tunnel and enters

the TB. However, the downstream line is not highlighted on LR-M-105-2 (2105-2), location B1,

2-120
where it connects to condenser [shell 1A penetration 88]. The staff requested that the applicant

explain why these pipe sections and components are not within scope for license renewal.

In its response to RAI 2.3.4.4-1, dated October 18, 2007, the applicant stated that the piping in

question, four-inch EAD-1 14 on boundary drawing LR-M-105-2, from continuation arrow

M-141-1 E9 located at B1 to HP condenser [shell-i A, penetration 88] is within the scope of

license renewal and is subject to AMR. The staff confirms that the applicant has submitted

revised boundary drawings LR-M-105-2 and LR-M-2105-2 that show this piping within the scope

of license renewal, pursuant to 10 CFR 54.4(a)(1).

Based on its review, the staff finds the applicant's response to RAI 2.3.4.4-1 acceptable

because the applicant has clarified that the piping in question is within the scope of license

renewal and subject to AMR and has submitted two revised boundary drawings that identify the

license renewal boundaries. Therefore, the staff's concern described in RAI 2.3.4.4-1 is

resolved.

2.3.4.4.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI response, and boundary drawings (original and

revised) to determine whether the applicant failed to identify any components within the scope

of license renewal. In addition, the staff's review determined whether the applicant failed to

identify any components subject to an AMR. On the basis of its review, the staff concludes the

applicant has appropriately identified the condenser and air removal system mechanical

components within the scope of license renewal, as required by 10 CFR 54.4(a), and that the

applicant has adequately identified the condenser and air removal system mechanical

components subject to an AMR, in accordance with the requirements of 10 CFR 54.21(a)(1)

and therefore, the response is acceptable.

2.3.4.5 Feedwater System

2.3.4.5.1 Summary of Technical Information in the Application

LRA Section 2.3.4.5 describes the feedwater system (FWS), which supplies high-purity,

preheated feedwater to the RV at the flow and pressure required to maintain the desired RV

water level throughout the entire operating range from startup to full load to shutdown. The

FWS contains safety-related components relied upon to remain functional during and following

DBEs. The failure of nonsafety-related SSCs in the FWS potentially could prevent the

satisfactory accomplishment of a safety-related function. In addition, the FWS performs

functions that support fire protection, ATWS, SBO, and EQ. LRA Table 2.3.4-5 identifies FWS

component types within the scope of license renewal and subject to an AMR.

2.3.4.5.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that the applicant has

appropriately identified the FWS mechanical components within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the system

components subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2-121
2.3.4.6 Main Steam System

2.3.4.6.1 Summary of Technical Information in the Application

LRA Section 2.3.4.6 describes the MSS, which transports high-pressure steam generated in the

RPV to the main turbine through four MS lines, each line with a main stop and turbine control

valve. The MSS contains safety-related components relied upon to remain functional during and

following DBEs. The failure of nonsafety-related SSCs in the MSS potentially could prevent the

satisfactory accomplishment of a safety-related function. In addition, the MSS performs

functions that support fire protection, ATWS, SBO, and EQ. LRA Table 2.3.4-6 identifies MSS

component types within the scope of license renewal and subject to an AMR.

2.3.4.6.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.6, UFSAR Section 10.3, and the licensing renewal

boundary drawings using the evaluation methodology described in SER Section 2.3 and the

guidance in SRP-LR Section 2.3. The staff's review 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 RAIs as discussed below.

In RAI 2.3.4.6-1, dated August 27, 2007, the staff noted that the boundary drawings

LR-M-141-1, LR-M-101-1, LR-M-101-3 and LR-M-2141-1, LR-M-2101-1, LR-M-2101-3 show

several ASME Code Section III, Class 2 lines that are identified within scope of license renewal

but are not shown as safety-related, in accordance with the notation legend on boundary

drawing LR-M-1 00-4, Note A2. The staff requested that the applicant clarify whether these lines

are within the scope of license renewal, pursuant to 10 CFR 54.4(a) (1) and; if not, provide an

explanation.

In its response to RAI 2.3.4.6-1, dated October 18, 2007, the applicant stated:

The piping noted in this RAI on license renewal drawings LR-M-141-1,

LR-M-101-1, and LR-M-101-3 includes the 4 main steam lines from the

outermost isolation valves to the turbine stop valves, 24" DBB-1 01, 102, 103 &

104, and the turbine bypass lines, 24"DBB-105 and 18" DBB-1 05. License

renewal boundary drawings LR-M-2141-1, LR-M-2101-1, LR-M-2101-3 include

24" DBB-201, 202, 203 & 204, and the turbine bypass lines, 24" DBB-205 and

18" DBB-205. Reference LR-M-100-2 at E3, PPL's drawing convention is to "cross-hatch" pipelines that are safety-related. Note, the lack of "cross-hatching"

indicates that these lines are not safety-related.

As stated in FSAR Section 10.3.1, Design Bases, the main steam supply system

has no safety-related function, but is designed to supply required steam to the

turbine generator and bypass steam to the condenser. FSAR Section 10.3.2

states the main steam piping is designed to ASME Section III Class 2. FSAR

Table 3.2-1 classifies the main steam piping beyond the outermost isolation

valve to the turbine stop valves as ASME Section III, Class 2, but shows that this

piping is not within the scope of 10 CFR 50 Appendix B.

FSAR Section 10.4.4 likewise notes the bypass system has no safety-related

function and the piping is designed in accordance with ASME Section III,

Class 2.

2-122
Therefore, as indicated in the FSAR, the main steam piping, through to the main

stop valves and to the bypass valve chest is designed as ASME Section III,

Class 2, but is not classified as safety-related.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.6-1 acceptable

because the applicant has clarified that the piping in question is nonsafety-related and within

the scope of license renewal, pursuant to 10 CFR 54.4(a)(2) and in agreement with UFSAR

Sections 10.3.1 and 10.4.4. Therefore, the staff's concern described in RAI 2.3.4.6-1 is

resolved.

In RAI 2.3.4.6-2, dated August 27, 2007, the staff noted that the boundary drawings

LR-M-141-1, and LR-M-2141-1, locations A-7 upstream of 141 F029A and 241 F029A show

sections of ASME Code Section III, Class 3 pipe as within scope of license renewal for

nonsafety-related spatial effects, in accordance with 10 CFR 54.4(a)(2) and as described in

boundary drawing LR-M-100, Note A2 on Sheet 4. Since ASME Code Class 3 components

are described in RG 1.26, Quality Group C as safety-related, the staff requested that the

applicant explain why these sections of pipe are not within the scope of license renewal,

pursuant to 10 CFR 54.4(a)(1).

In its response to RAI 2.3.4.6-2, dated October 18, 2007, the applicant stated in part:

FSAR Table 3.2-1 under the "Nuclear Boiler System" heading indicates the air

supply check valves and the piping downstream of the air supply check valves is

safety-related. The piping upstream of the air supply check valves is not safetyrelated and has no safety-related function. The short section of stainless steel

piping attached to the air supply check valve allows use of an insulating flange to

connect two different materials. A portion of the nonsafety-related piping

upstream of the check valve is in-scope as it contains an anchor that provides

support for the safety-related valve and is thus within the scope of license

renewal based on 10 CFR 54.4(a)(2), and subject to AMR.

The staff confirms that the applicant has submitted revised boundary drawings LR-M-141-1 and

LR-M-214-1.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.6-2 acceptable

because the applicant has clarified that the piping in question is nonsafety-related and within

the scope of license renewal, pursuant to 10 CFR 54.4(a)(2) and is in agreement with UFSAR

Table 3.2-1. Therefore, the staff's concern described in RAI 2.3.4.6-2 is resolved.

In RAI 2.3.4.6-3, dated August 27, 2007, the staff noted that the boundary drawing

LR-M-101-1, locations A6, C6, E6, F6, and G-2, and LR-M-2101-1, locations A6, C6, E6, F6,

and G-2 show one-inch instrumentation pipes and the first normally open manual isolation

valve within the scope of license renewal. Boundary drawing LRM-1 00, Sheet 4, Note A2

suggests that the intended function of these pipes is pressure boundary. However, the

connecting downstream piping is not shown as within the scope of license renewal. Since

failure of the downstream pipe will have the same effect as failure of the in-scope piping, the

staff requested that the applicant explain why the downstream piping also is not included

within the scope of license renewal.

2-123
In its response to RAI 2.3.4.6-3, dated October 18, 2007, the applicant stated:

The main stop valves on license renewal drawings LR-M-101-1 and LR-M-2101-

1 form the boundary associated with providing an alternate pathway for main

steam isolation valve (MSIV) leakage, as described in LRA Section 2.3.4.6. The

MSIV Leakage Isolated Condenser Treatment Method (ICTM) directs any

leakage through a closed MSIV to the main condenser. This is a nonsafetyrelated function in accordance with 10 CFR 54.4(a)(2).

The intended function is to provide a flow path rather than a pressure boundary.

Therefore, the ICTM boundary is established at the first isolation valve

associated with instrumentation for the stop valves, drip legs, and sensing lines

in order to depict the boundaries of the path. Flow is not expected in the

instrument lines and any leakage from the instrument lines would be

inconsequential to the overall volume available for hold-up and plate-out of

fission products.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.6-3 acceptable

because the applicant has clarified that the intended function of the piping in question is to

provide a flow path rather than a pressure boundary. Therefore, the staff's concern described in

RAI 2.3.4.6-3 is resolved.

In RAI 2.3.4.6-4, dated August 27, 2007, the staff noted that the boundary drawing

LR-M-101-1, locations B-8, D-8, E-8, and G-8, and LR-M-2101-1, locations B-8, D-8, E-8, and

G-8, show the 28-inch lines as nonsafety-related and are considered within the scope of

license renewal for spatial effects. However, no portion of the nonsafety-related lines

connecting the 28-inch lines to control valve MS lead drain is shown as within the scope of

license renewal for the same spatial effects. The staff requested that the applicant explain

why these lines are not included within the scope of license renewal, in accordance with the

requirements of 10 CFR 54.4(a)(2).

In its response to RAI 2.3.4.6-4, dated October 18, 2007, the applicant stated:

LRA Section 2.3.4.7, Main Turbine, states that the High Pressure (HP) Turbine

Casing and associated bolting are in-scope. The HP Turbine Casing and bolting

are in-scope because they provide structural support (anchor to plant structure)

for Main Steam System piping extending from the reactor building into the

turbine building. As such, the casing of the HP turbine has the potential for

interaction (connected to) with safety-related components and is in-scope based

on 10 CFR 54.4(a)(2). Because the HP Turbine Casing serves as an anchor, the

Main Steam System piping is brought into scope based on the seismic analysis

boundary extending all the way back to the containment penetration. The small

branch piping off the Main Steam System was not included in the seismic

evaluation of the Main Steam piping because this piping is non-Q and by

specification, Bechtel Specification M406, Piping Stress Analysis for SSES,

Section 5.11) it is too small to have a significant effect. Also, refer to boundary

drawing LR-M-101-1, LR Note D which addresses anchors for pipelines less than

2 1⁄2" in diameter. In addition, the Main Steam System small branch piping is not

2-124
in-scope due to spatial interaction (wetting, spray, leakage, flooding) based on

SSES LRA Section 2.1.1.2.2.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.6-4 acceptable

because the applicant has verified that the small branch piping off the MSS was not included in

the seismic evaluation of the MS piping because this piping is non-Q and was not included in

the piping stress analysis. Therefore, the staff's concern described in RAI 2.3.4.6-4 is resolved.

In RAI 2.3.4.6-5, dated August 27, 2007, the staff noted that the boundary drawing

LR-M-101-1, locations B-7, C-7, E-7, and F-7, and LR-M-2101-1, locations B-7, C-7, E-7, and

F-7, show CV-1, CV-2, CV-3, and CV-4 as nonsafety-related and within the scope of license

renewal, pursuant to 10 CFR 54.4(a)(2). There are several nonsafety-related lines that are

connected to the CV-1, CV-2, CV-3, and CV-4 valve pressure boundaries; however, no

portion of these connecting lines are shown as within the scope of license renewal. The staff

requested that the applicant explain why these lines are not included within the scope of

license renewal, in accordance with the requirements of 10 CFR 54.4(a)(2).

In its response to RAI 2.3.4.6-5, dated October 18, 2007, the applicant stated:

LRA Section 2.3.4.7, Main Turbine, states that the High Pressure (HP) Turbine

Casing and associated bolting are in-scope. The HP Turbine Casing and bolting

are in-scope because they provide structural support (anchor to plant structure)

for Main Steam System piping extending from the reactor building into the

turbine building. As such, the casing of the HP turbine has the potential for

interaction (connected to) with safety-related components and is in-scope based

on 10 CFR 54.4(a)(2). Because the HP Turbine Casing serves as an anchor, the

Main Steam System piping is brought into scope based on the seismic analysis

boundary extending all the way back to the containment penetration. The small

branch piping off the Main Steam System was not included in the seismic

evaluation of the Main Steam piping because this piping is non-Q and by

specification, Bechtel Specification M406, Piping Stress Analysis for SSES,

Section 5.11, it is too small to have a significant effect. Also, refer to boundary

drawing LR-M-101-1, LR Note "D" which addresses anchors for pipelines less

than 2 1/2" in diameter. In addition, the Main Steam System small branch piping is

not in-scope due to spatial interaction (wetting, spray, leakage, flooding) based

on SSES LRA Section 2.1.1.2.2.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.6-5 acceptable

because the applicant has verified that the small branch piping off the MSS was not included in

the seismic evaluation of the MS piping because this piping is non-Q and was not included in

the piping stress analysis. Therefore, the staff's concern described in RAI 2.3.4.6-5 is resolved.

In RAI 2.3.4.6-6, dated August 27, 2007, the staff noted that the boundary drawings

LR-M-141-1 and LR-M-2141-1, Revision 1, location C-8, show piping downstream of normally

closed manual isolation valves 14101 OA and 24101 OA as ASME Code Section III, Class 2 pipe.

However, this piping is identified as within the scope for license renewal as a nonsafety-related

pipe, pursuant to 10 CFR 54.4(a)(2). The staff requested that the applicant explain why these

sections of pipe are not within the scope of license renewal, in accordance with

10 CFR 54.4(a)(1).

2-125
In its response to RAI 2.3.4.6-6, dated October 18, 2007, the applicant stated:

As stated in FSAR Section 10.3.1, Design Bases, the main steam supply system

has no safety-related function, but is designed to supply required steam to the

turbine generator and bypass steam to the condenser. FSAR Section 10.3.2

states the main steam piping is designed to ASME Section III Class 2. FSAR

Table 3.2-1 classifies the main steam piping beyond the outermost isolation

valve to the turbine stop valves, including the piping to and the normally closed

isolation valves 14101 OA and 241010A, as ASME Section III, Class 2, but shows

that this piping is not within the scope of 10 CFR 50 Appendix B.

FSAR Section 10.4.4 likewise notes the bypass system has no safety-related

function and the piping is designed in accordance with ASME Section III,

Class 2.

The piping downstream of normally closed manual isolation valves 141010A and

241010A is ASME Section III Class 2 pipe, and has no safety-related function.

Therefore, this piping does not meet 10 CFR 54.4(a)(1) scoping criteria. This

piping could contain water and is therefore within the scope of license renewal

based on 10 CFR 54.4(a)(2), due to the potential for spatial interaction.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.6-6 acceptable

because the applicant has clarified that the piping in question is nonsafety-related and within

the scope of license renewal, pursuant to 10 CFR 54.4(a)(2) and is in agreement with UFSAR

Table 3.2-1 and Section 10.4.4. Therefore, the staff's concern described in RAI 2.3.4.6-6 is

resolved.

In RAI 2.3.4.6-7, dated August 27, 2007, the staff noted that the boundary drawings

LR-M-141-1, and LR-M-2141-1, Revision 1, locations C-7 and F-7 show piping downstream of

normally closed manual isolation valves 14138A/24138A, 14101A/24101A, and 14101 B/241011B

that appear to be ASME Code Section III, Class 2 pipe. However, these piping components are

identified within the scope of license renewal as nonsafety-related, pursuant to

10 CFR 54.4(a)(2). The staff requested that the applicant explain why these sections of pipe

are not within the scope of license renewal, in accordance with 10 CFR 54.4(a)(1).

In its response to RAI 2.3.4.6-7, dated October 18, 2007, the applicant stated:

As stated in FSAR Section 10.3.1, Design Bases, the main steam supply system

has no safety-related function, but is designed to supply required steam to the

turbine generator and bypass steam to the condenser. FSAR Section 10.3.2

states the main steam piping is designed to ASME Section III Class 2. FSAR

Table 3.2-1 classifies the main steam piping beyond the outermost isolation

valve to the turbine stop valves, including the piping to and the normally closed

isolation valves 14138A/24138A, 14101A/24101A, and 14101B/24101B, as

ASME Section III Class 2, but shows that this piping is not within the scope of

10 CFR 50 Appendix B.

FSAR Section 10.4.4, likewise, notes the bypass system has no safety-related

function and the piping is designed in accordance with ASME Section III Class 2.

2-126
The piping downstream of normally closed manual isolation valves

14138A/24138A, 14101A/24101A, and 14101B/24101B is ASME Section III

Class 2 pipe, and has no safety-related function. Therefore, this piping does not

meet 10 CFR 54.4(a)(1) scoping criteria. This piping could contain water and is

therefore within the scope of license renewal based on 10 CFR 54.4(a)(2), due to

the potential for spatial interaction.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.6-7 acceptable,

because the applicant has clarified that the piping in question is nonsafety-related and within

the scope of license renewal, pursuant to 10 CFR 54.4(a)(2) and is in agreement with UFSAR

Table 3.2-1 and Section 10.4.4. Therefore, the staff's concern described in RAI 2.3.4.6-7 is

resolved.

In RAI 2.3.4.6-8, dated August 27, 2007, the staff noted that boundary drawings LR-M-141-1

and LR-M-2141-1, locations A-7 show the nonsafety-related (line class JDD) ANSI B31.1 piping

connected to safety-related (line class HCC) ASME Code Section III, Class 3 piping not within

the scope of license renewal. In LRA Section 2.1.1.2.2, "Spatial Failures of Nonsafety-Related

SSCs," Page 2.1-8 the applicant states in part: "With respect to nonsafety-related piping that is

directly connected to safety-related piping, the seismic Category I design requirements are

extended to the first seismic restraint beyond the defined boundaries." The staff requested that

the applicant provide the location of the license renewal boundary (seismic restraint) for the

nonsafety-related piping connected to the safety-related piping.

In its response to RAI 2.3.4.6-8, dated October 18, 2007, the applicant verified that the seismic

anchor is located between the check valve and insulating flange.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.6-8 acceptable

because the applicant has verified the location of the seismic anchor. Therefore, the staff's

concern described in RAI 2.3.4.6-8 is resolved.

2.3.4.6.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and boundary drawings (original and

revised) to determine whether the applicant failed to identify any components within the scope

of license renewal. In addition, the staff's review determined whether the applicant failed to

identify any components subject to an AMR. On the basis of its review, the staff concludes the

applicant has appropriately identified the MSS mechanical components within the scope of

license renewal, as required by 10 CFR 54.4(a), and that the applicant has adequately

identified the MSS mechanical components subject to an AMR, in accordance with the

requirements of 10 CFR 54.21(a)(1) and therefore, the response is acceptable.

2.3.4.7 Main Turbine System

2.3.4.7.1 Summary of Technical Information in the Application

LRA Section 2.3.4.7 describes the main turbine system (MTS), which consists of one doubleflow, high-pressure turbine and three double-exhaust flow, low-pressure turbines. The failure of

nonsafety-related SSCs in the MTS potentially could prevent the satisfactory accomplishment of

2-127
a safety-related function. LRA Table 2.3.4-7 identifies MTS component types within the scope

of license renewal and subject to an AMR.

2.3.4.7.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that the applicant has

appropriately identified the MTS mechanical components within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the system

components subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2.3.4.8 Makeup Demineralizer System

2.3.4.8.1 Summary of Technical Information in the Application

LRA Section 2.3.4.8 describes the makeup demineralizer system, which provides an adequate

supply of demineralized water for the plant operating requirements. The failure of nonsafetyrelated SSCs in the makeup demineralizer system potentially could prevent the satisfactory

accomplishment of a safety-related function. LRA Table 2.3.4-8 identifies makeup demineralizer

system component types within the scope of license renewal and subject to an AMR.

2.3.4.8.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, and UFSAR, the staff concludes that the applicant has appropriately identified the makeup

demineralizer system mechanical component types within the scope of license renewal, as

required by 10 CFR 54.4(a), and that the applicant has adequately identified the system

component types subject to an AMR in accordance with the requirements stated in

10 CFR 54.21 (a)(1).

2.3.4.9 Makeup Transfer and Storage System

2.3.4.9.1 Summary of Technical Information in the Application

LRA Section 2.3.4.9 describes the makeup transfer and storage system, which provides

demineralized water makeup to various plant services from the makeup demineralizer system.

The failure of nonsafety-related SSCs in the makeup transfer and storage system potentially

could prevent the satisfactory accomplishment of a safety-related function. LRA Table 2.3.4-9

identifies makeup transfer and storage system component types within the scope of license

renewal and subject to an AMR.

2.3.4.9.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, and UFSAR, the staff concludes that the applicant has appropriately identified the makeup

transfer and storage system mechanical component types within the scope of license renewal,

as required by 10 CFR 54.4(a), and that the applicant has adequately identified the system

component types subject to an AMR in accordance with the requirements stated in

10 CFR 54.21(a)(1).

2-128
2.3.4.10 Reactor Feed Pump Turbines System

2.3.4.10.1 Summary of Technical Information in the Application

LRA Section 2.3.4.10 describes the reactor feed pump turbines system, which is driven by

variable-speed, multistage turbines that receive steam from either the MS cross-connection

header or the crossover piping downstream of the moisture separators. The reactor feed pump

turbines system performs functions that support fire protection. The only components of the

reactor feed pump turbines system within the scope of license renewal are the reactor feed

pump turbine low-pressure and high-pressure stop valves. The valve bodies and their internal

pilot valves and oil piping/tubing perform no passive intended function. Therefore, there are no

reactor feed pump turbines system components subject to an AMR.

2.3.4.10.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, UFSAR, and applicable boundary drawings, the staff concludes that the applicant has

appropriately identified the reactor feed pump turbines system mechanical components within

the scope of license renewal, as required by 10 CFR 54.4(a), and that the applicant has

adequately identified the system components subject to an AMR in accordance with the

requirements stated in 10 CFR 54.21(a)(1).

2.3.4.11 Refueling Water Transfer and Storage System

2.3.4.11.1 Summary of Technical Information in the Application

LRA Section 2.3.4.11 describes the refueling water transfer and storage system, which stores

the water that fills the reactor wells and dryer-separator pools of either Unit 1 or 2. During

refueling operations, water inventory is transferred from the storage tank to the reactor wells

and dryer-separator pools. The failure of nonsafety-related SSCs in the refueling water transfer

and storage system potentially could prevent the satisfactory accomplishment of a safetyrelated function. LRA Table 2.3.4-10 identifies refueling water transfer and storage system

component types within the scope of license renewal and subject to an AMR.

2.3.4.11.2 Conclusion

Based on the results of the staff evaluation discussed in Section 2.3 and on a review of the

LRA, and UFSAR, the staff concludes that the applicant has appropriately identified the SDS

mechanical component types within the scope of license renewal, as required by

10 CFR 54.4(a), and that the applicant has adequately identified the system component types

subject to an AMR in accordance with the requirements stated in 10 CFR 54.21(a)(1).

2.4 Scoping and Screening Results: Structures

This section documents the staff's review of the applicant's scoping and screening results for

structures. Specifically, this section discusses:

" Primary containment

" Reactor building

" .ESSW pumphouse and spray pond

2-129
* CWPH and water treatment building

* Control structure

* DG A, B, C, and D building

* DG E building

* Turbine building

* Yard structures

" Bulk commodities

In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant must list passive,

long-lived SCs within the scope of license renewal and subject to an AMR. To verify that the

applicant properly implemented its methodology, the staff's review focused on the

implementation results. This focus allowed the staff to confirm that there were no omissions of

structures and components that meet the scoping criteria and are subject to an AMR.

The staff's evaluation of the information in the LRA was the same for all structures. The

objective was to determine whether the applicant has identified, in accordance with

10 CFR 54.4, components and supporting structures for structures that appear to meet the

license renewal scoping criteria. Similarly, the staff evaluated the applicant's screening results

to verify that all passive, long-lived SCs were subject to an AMR, in accordance with

10 CFR 54.21(a)(1).

In its scoping evaluation, the staff reviewed the applicable LRA sections and drawings, focusing

on components that have not been identified as within the scope of license renewal. The staff

reviewed relevant licensing basis documents, including the UFSAR, for each structure to

determine whether the applicant has omitted from the scope of license renewal components

with intended functions pursuant to 10 CFR 54.4(a). The staff also reviewed the licensing basis

documents to determine whether the LRA specified all intended functions in accordance with

10 CFR 54.4(a). The staff requested additional information to resolve any lack of clarity,

omissions or discrepancies identified.

After its review of the scoping results, the staff evaluated the applicant's screening results. For

those SCs with intended functions, the staff sought to determine whether (a) the functions are

performed with moving parts or a change in configuration or properties or (b) the SCs are

subject to replacement after a qualified life or specified time period, as described in

10 CFR 54.21(a)(1). For those meeting neither of these criteria, the staff sought to confirm that

these SCs were subject to an AMR, as required by 10 CFR 54.21 (a)(1 ). The staff requested

additional information to resolve any lack of clarity, omissions or discrepancies identified.

The staff's review of the introductory scoping portion of LRA Section 2.4 identified areas in

which additional information was necessary to complete the review of the applicant's scoping

and screening results and determine whether the applicant properly applied the scoping criteria

of 10 CFR 54.4(a). The applicant responded to the staff's RAIs as discussed below.

In RAI 2.4-1, dated August 3, 2007, the staff noted that LRA Section 2.4, fourth paragraph, first

sentence, stated that the major structures included within the scope of license renewal were as

listed therein. Pursuant to 10 CFR 54.4, all structures (including major structures) that perform

an intended function stated in 10 CFR 54.4(a) are required to be included within the scope of

license renewal. The staff requested that the applicant to: (a) confirm that the in-scope

structures and structure categories listed in LRA Section 2.4 are all inclusive; (b) clarify the

language used in that section of the LRA, "The major structures in the scope..."; and (c) include

2-130
any remaining structures that may be within the scope of license renewal and provide

corresponding scoping, screening and AMR results.

In its response to RAI 2.4-1, dated August 28, 2007, the applicant stated:

The in-scope structures and structure categories listed in Section 2.4 are all

inclusive of the in-scope License Renewal structures required by 10 CFR 54.4

for SSES. The term "major" was used to categorize the structures to be

addressed in different sections of the SSES LRA. All in-scope structures for

SSES are listed in the LRA with the Yard Structures category encompassing all

the miscellaneous in-scope Yard Structures identified in Section 2.4.9. The inscope Yard Structures are:

• Clarified Water Storage Tank Foundation

* Condensate Storage Tank Foundation and Retention Basin

(Units 1 and 2)

• Diesel Generator Fuel Oil Storage Tanks 'A, B, C, D & E'

Foundations and Vaults

" Refueling Water Storage Tank Foundation (Unit 1)

• Station Blackout component foundations and structures (Startup

Transformers T-10 and T-20 and associated disconnect switches,

Engineered Safeguards Systems (ESS) Transformers)

" Cooling Tower Basins (Units 1 and 2)

" Duct banks, manholes, valve vaults, instrument pits, piping

trenches

The first sentence in the fourth paragraph of the license renewal application

(LRA) Section 2.4 "Scoping and Screening Results: Structures" is revised in bold

italics as shown in Attachment 1 of the applicant's letter dated August 28, 2007,

to read as follows:

"The structures in the scope of license renewal are the:"

Based on its review, the staff finds the applicant's response to RAI 2.4-1 acceptable because

the applicant has clarified that the structures listed as within the scope of license renewal are all

inclusive and has accordingly revised the language in LRA Section 2.4, fourth paragraph, first

sentence. Therefore, the staff's concern described in RAI 2.4-1 is resolved.

In RAI 2.4-2, dated August 3, 2007, the staff noted that UFSAR Section 3.8.4 describes the

radwaste building as a safety-related non-seismic Category 1 structure. UFSAR Page 3.8-45

states that the reinforced concrete walls and floor and the concrete block masonry walls meet

structural as well as radiation shielding requirements. LRA Sections 2.3.3.19 and 2.3.3.20

include the radwaste liquid system and the radwaste solids handling system within the scope of

license renewal and subject to an AMR. LRA Section 2.3.3.20, first paragraph states that all

radwaste solids handling system equipment serves both reactor units and is located in the

radwaste building. However, LRA Table 2.2-3 excludes the radwaste building from the scope of

license renewal. Since the above mentioned in-scope systems are located inside the radwaste

2-131
building, the staff requested that the applicant confirm whether this would bring the radwaste

building within the scope of license renewal and subject to an AMR and; if so, include the

radwaste building in the LRA and describe its scoping, screening and AMR results. If the

radwaste building is excluded, provide the technical basis for the exclusion.

In its response to RAI 2.4-2, dated August 28, 2007, the applicant stated:

The FSAR Section 3.8.4, title heading is a hold-over from earlier versions of the

FSAR, listing of the Radwaste Building as a Safety-Related structure is

inconsistent with the reduced quality group classification described in FSAR

Table 3.2-1. A Condition Report (CR 893711) has been issued to rectify the

FSAR text.

The Radwaste Building is not in the scope of License Renewal at SSES, or

subject to aging management review, since it does not contain in-scope

components and does not perform an intended function. As shown in FSAR

Table 3.2-1, the Radwaste Building and associated components have a Safety

Class of "Other," the definition of which is shown in FSAR Section 3.2.3.4. As

described in Notes 22 and 31 of FSAR Table 3.2-1, a lower quality group

classification, associated construction codes and seismic category were

determined to be appropriate for Radwaste Treatment Systems (and building) as

a result of analysis per Regulatory Guides 1.26 and 1.29, which demonstrated

that the site boundary dose would not exceed .5 Rem due to a loss of effluent

from system components. This quality group classification conforms to Quality

Group D (Augmented) as defined in NRC Branch Technical Position ETSB 11-1.

Table 2.3.3-18 of the LRA identifies the piping, valves, and piping components

(e.g., cleanouts and pump casings) of the Radwaste Liquid System that are in

the scope of License Renewal and subject to aging management review. These

components provide containment isolation or are nonsafety-related components

that are required to maintain integrity to prevent spatial interaction with, or

support for attached, safety-related components. These components are located

in the Reactor Building or Control Structure, as shown on the LR drawings listed

in LRA Section 2.3.3.19 (e.g. LR-M-161 Sheet 2), and not in the Radwaste

Building. With respect to the Radwaste Solids Handling System, the system

description in LRA Section 2.3.3.20 identifies that only the system tanks and

associated piping and piping components in the Reactor Building, as shown on

drawings LR-M-1 54, Sheet 1 and LR-M-166, Sheets 1 and 2 are in-scope and

subject to aging management review as identified in LRA Table 2.3.3-19.

Based on its review, the staff finds the applicant's response to RAI 2.4-2 acceptable because

the applicant has verified that the safety-related description of the radwaste building in UFSAR

Section 3.8.4 was in error and has appropriately revised the FSAR text. The staff confirms that

the applicant has also verified that its analysis of the radwaste treatment systems (and

building), pursuant to RGs 1.26 and 1.29, demonstrated that the site boundary dose would not

exceed 0.5 rem due to a loss of effluent from system components. The applicant clarified that

the components of the radwaste liquid system and the radwaste solids handling system,

described in LRA Sections 2.3.3.19 and 2.3.3.20, that are included within the scope of license

renewal and subject to an AMR, are located in the RB or control structure and not in the

radwaste building. Since the radwaste building does not serve an intended function pursuant to

2-132
10 CFR 54.4(a), the staff agrees with the applicant's conclusion that the radwaste building is

not within the scope of license renewal. Therefore, the staff's concerns described in RAI 2.4-2

are resolved.

Based on the applicant's response to RAIs 2.4-1 and 2.4-2, the staff finds that the applicant's

list of structures within the scope of license renewal, in the introductory part of LRA Section 2.4,

is all inclusive.

2.4.1 Primary Containment

2.4.1.1 Summary of Technical Information in the Application

In LRA Section 2.4.1, the applicant describes the primary containments, which are GE BWR,

Mark II (over/under) type seismic Category I structures. The primary containment is an

enclosure for the RV, the reactor coolant recirculation loops, and branch connections of the

RCS. Essential elements of the primary containment are the drywell, the suppression chamber

that stores a large volume of water, the drywell floor separating the drywell and the suppression

chamber, the connecting vent pipe system between the drywell and the suppression chamber,

isolation valves, the vacuum relief system, the containment cooling systems, and other service

equipment. Primary containment takes the form of a truncated cone over a cylinder, with the

drywell in the upper conical section and the suppression chamber in the lower cylindrical

section. These two sections comprise a structurally-integrated, reinforced concrete pressure

vessel, lined with welded steel plate and with a steel domed head for closure at the top of the

drywell. The drywell floor is a reinforced concrete slab, structurally connected to the

containment wall.

The primary containment contains safety-related components relied upon to remain functional

during and following DBEs. In addition, the primary containment performs functions that support

SBO.

LRA Table 2.4-1 identifies primary containment component types within the scope of license

renewal and subject to an AMR:

" containment liner

* containment wall

" control rod drive removal hatch

* drywell floor

* drywell floor liner

" drywell head (includes manhole and double gaskets)

" drywell sumps

* foundation

* penetrations

" permanent drywell shielding

" personnel airlock and equipment hatches

* reactor pedestal

" reactor pedestal liner

" reactor shield doors (includes hinged doors and removable plugs)

" reactor shield wall

* reactor shield wall inner and outer plates

* reactor vessel thermal insulation

2-133
" refueling bellows

" refueling seal plate

" refueling seal lead shield plates

* seismic truss and seismic stabilizer

* structural steel: beams, columns, plates, and trusses

• suppression chamber

" suppression chamber access hatches

* suppression chamber columns

• suppression chamber liner

The intended functions of the primary containment component types within the scope of license

renewal include:

" spray shield or curb to direct flow

" thermal expansion, seismic separation, or both

" flood protection barrier

* SBO or DBA heat sink

" missile barrier

" safety-related equipment shelter or protection

" shielding against radiation

" pressure boundary or essentially leak-tight barrier in postulated design-basis events to

protect public health and safety

" structural or functional support to safety-related components

" structural support to nonsafety-related components whose failure could prevent

satisfactory accomplishment of required safety functions

" structural or functional support required for any of the 10 CFR 54.4(a)(3) regulated

events

2.4.1.2 Staff Evaluation

The staff reviewed LRA Section 2.4.1 and UFSAR Sections 3.8.1 through 3.8.3, using the

evaluation methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review, the staff evaluated the structural component functions described in the LRA

and UFSAR to verify that the applicant has not omitted from the scope of license renewal any

SCs with intended functions, pursuant to 10 CFR 54.4(a). The staff then reviewed those SCs

that the applicant has identified as within the scope of license renewal to verify that the

applicant has not omitted any passive and long-lived SCs subject to an AMR, in accordance

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

The staff's review of LRA Section 2.4.1 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results, and

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 applicant responded to the staff's RAIs as

discussed below.

2-134
In RAI 2.4.1-1, dated August 3, 2007, the staff noted LRA Table 2.4-1 lists the drywell head (the

term "Drywell Head Assembly" used in the UFSAR is more appropriate) as a primary

containment component type subject to an AMR. The staff was not clear from Tables 2.4-1 and

2.4-10 whether: (a) the mating flange bolts that secure the head to the lower flange; (b) the

manhole bolts; and (c) the double rubber gaskets that help prevent loss of joint leak-tightness at

the head-to-lower flange connection and at the manhole, are included within the scope of

license renewal and subject to an AMR. The staff requested that the applicant confirm whether

these components are within the scope of license renewal and if they were not included as a

result of an oversight, provide a description of their scoping, screening and an AMR. If these

components are excluded from the scope of license renewal, provide the technical basis for the

exclusion.

In its response to RAI 2.4.1-1, dated August 28, 2007, the applicant stated:

The mating flange bolts that secure the Drywell Head to the lower flange; the

manhole bolts that secure the Manhole to the Drywell Head; and the gaskets that

help prevent loss of joint leak-tightness at the Drywell Head to lower flange

connection and at the manhole to Drywell Head are included in the scope of

License Renewal for SSES and subject to aging management review. The

manhole and gaskets are considered as part of the host component "Drywell

Head" and are included under Component Type "Drywell Head" in Table 2.4-1.

The mating flange bolts and the manhole bolts are included under Component

Type "Anchor bolts (ASME Class 1, 2, 3 and MC supports bolting)" in

Table 2.4-10.

Table 2.4-1 specific component type and Table 3.5.2-1 specific

component/commodity are revised as shown in bold italics in Attachment 2 (of

the applicant's response letter dated August 28, 2007) to describe the

component type as: Drywell head (drywell head assembly includes manhole and

double gaskets)

Based on its review, the staff finds the applicant's response to RAI 2.4.1-1 acceptable because

the applicant has clarified that the mating flange bolts, the manhole, the manhole bolts and the

gaskets of the drywell head assembly are included in the scope of license renewal and subject

to an AMR. The applicant verified that the manhole and gaskets are considered as part of the

host component "Drywell head" and are included under component type "Drywell head" in LRA

Table 2.4-1. The applicant revised the drywell head component type description in LRA

Tables 2.4-1 and 3.5.2-1 to read: Drywell head (drywell head assembly includes manhole and

double gaskets). The staff confirms that the mating flange bolts and the manhole bolts are

included under component type "Anchor bolts (ASME Code Class 1, 2, 3 and MC supports

bolting)" in LRA Table 2.4-10. Table 2.4-10 of the LRA has an abbreviation, among others, of

"SSR" in the intended function column against the component type "Anchor bolts (ASME

Code Class 1, 2, 3 and MC supports bolting)" which is intended to include components that

provide structural or functional support to safety-related equipment (see LRA Table 2.0-1 for the

definition of intended function abbreviated as "SSR") and, therefore, include the mating flange

bolts and the manhole bolts of the drywell head assembly. Therefore, the staff's concern

described in RAI 4.2.1-1 is resolved.

2-135
In RAI 2.4.1-2, the staff noted LRA Table 2.4-1 lists penetrations (mechanical and electrical,

primary containment boundary), as components subject to an AMR. This does not seem to

include the penetrations through the reactor shield wall with hinged doors or removable plugs

that facilitate piping (i.e., feedwater, reactor recirculation, recirculation inlet, etc.) connections to

the RV which provide access for in-service inspection (see UFSAR Section 3.8.3.1.3 and

drawings C-1 932 Sheets 3 & 5). The staff requested that the applicant confirm whether these

penetrations and their doors and/or plugs are within the scope of license renewal and subject to

an AMR and if they were not included as a result of an oversight, provide a description of their

scoping, screening and AMR. If they are excluded from the scope of license renewal, provide

the technical basis for the exclusion.

In its response to RAI 2.4.1-2, dated August 28, 2007, the applicant stated:

The penetrations through the Reactor Shield Wall with hinged doors or

removable plugs are in the scope of License Renewal for SSES and subject to

aging management review. These penetrations are included under Component

Type "Penetrations (Mechanical and Electrical, non Primary Containment

boundary)" in Table 2.4-10. The Reactor Shield Wall hinged doors/removable

plugs are in the scope of License Renewal for SSES and subject to aging

management review. These doors/plugs are included under Component Type

"Reactor shield doors" in Table 2.4-1.

Table 2.4-1 specific component type and Table 3.5.2-1 specific

component/commodity are revised as shown in bold italics in Attachment 3 (of

the applicant's response letter dated August 28, 2007) to describe the

component type as: Reactor shield doors (includes hinged doors and removable

plugs).

Based on its review, the staff finds the applicant's response to RAI 2.4.1-2 acceptable because

the applicant has confirmed that the penetrations through the reactor shield wall are included

within the scope of license renewal and subject to an AMR, and are included under the

component type "Penetrations (Mechanical and Electrical, non Primary Containment boundary)"

in LRA Table 2.4-10. The staff confirms that these penetrations are part of the non-primary

containment boundary and appropriately belong in LRA Table 2.4-10. The applicant also

verified that the reactor shield wall hinged doors and removable plugs also are within the scope

of license renewal and subject to an AMR, and are included under the component type "Reactor

shield doors" in LRA Table 2.4-1. The applicant revised the corresponding component type

description in LRA Tables 2.4-1 and 3.5.2-1 to read: Reactor shield doors (includes hinged

doors and removable plugs). Therefore, the staff's concerns described in RAI 2.4.1-2 are

resolved.

In RAI 2.4.1-3, the staff noted LRA Section 2.4.1 and Table 2.4-1 list access hatches

(equipment hatch, personnel airlock, suppression chamber access hatches, and the control rod

drive removal hatch) as primary containment components subject to an AMR. The staff is

unclear from LRA Tables 2.4-1 and 2.4-10 whether the flange double-gaskets, hatch locks,

hinges and closure mechanisms that help prevent loss of sealing and/or leak-tightness for

these listed hatches are included within the scope of license renewal and subject to an AMR.

The staff requested that the applicant confirm whether these components are within the scope

of license renewal, and if they were not included as a result of an oversight, please provide a

2-136
description of their scoping, screening and AMR. If they are excluded from the scope of license

renewal, provide the technical basis for the exclusion.

In its response to RAI 2.4.1-3, dated August 28, 2007, the applicant stated:

The Component Types "Control rod drive (CRD) removal hatch," "Personnel

airlock and equipment hatches" and "Suppression chamber access hatches" in

Table 2.4-1 include the flange gaskets, hatch locks, hinges and closure

mechanisms. These subcomponents (flange gaskets, hatch locks, hinges and

closure mechanisms) are considered as part of the host component and are in

the scope of License Renewal for SSES and subject to aging management

review. Under the Discussion column for LRA Table Items 3.5.1-16 and 3.5.1-17

these subcomponents are listed as part of the host component.

Based on its review, the staff finds the applicant's response to RAI 2.4.1-3 acceptable because

the applicant has clarified that the flange gaskets, hatch locks, hinges and closure mechanisms

are included as subcomponents considered as part of the corresponding host components (the

access hatches) and are within the scope of license renewal and subject to an AMR. The

applicant also clarified that in the discussion column for LRA Table 3.5.1-16 and 3.5.1-17, these

subcomponents are listed as part of the host component. The staff determines that these

subcomponents can be considered as part of the host components within the scope of license

renewal and subject to an AMR. Therefore, the staff's concern described in RAI 2.4.1-3 is

resolved.

In RAI 2.4.1-4, the staff noted, based on information in LRA Section 2.4.1 and Tables 2.4-1 and

2.4-10, it is not clear whether all drywell pipe restraints and/or whip restraints are within the

scope of license renewal. The staff requested that the applicant confirm whether these

components are within the scope of license renewal, and if they were not included as a result of

an oversight, please provide a description of their scoping, screening and AMR. If they are

covered somewhere else in the LRA, please indicate the location, and if they are excluded from

the scope of license renewal, provide the technical basis for the exclusion.

In its response to RAI 2.4.1-4, dated August 28, 2007, the applicant stated:

The drywell pipe restraints/whip restraints are in the scope of License Renewal

for SSES and subject to aging management review. These pipe restraints/whip

restraints are included under Component Type "HELB barriers" in Table 2.4-10.

HELB barriers provide jet impingement protection to various in-scope

components. HELB barriers include pipe whip restraints, jet impingement shields

or plate barriers, and crushable energy absorbers.

Table 2.4-10 specific component type and Table 3.5.2-10 specific

component/commodity are revised as shown in bold italics in Attachment 4 (of

the applicant's response letter dated August 28, 2007) to describe the

component type as: HELB barriers (includes pipe restraints, whip restraints, jet

impingement shields/plate barriers, and crushable energy absorbers).

Based on its review, the staff finds the applicant's response to RAI 2.4.1-4 acceptable because

the applicant has clarified that the drywell pipe restraints and/or whip restraints are within the

scope of license renewal and subject to an AMR. The drywell pipe restraints and/or whip

2-137
restraints are included under component type "HELB barriers" in LRA Table 2.4-10, since HELB

barriers provide jet impingement protection to various in-scope components. The applicant

further clarified that HELB barriers include pipe whip restraints, jet impingement shields or plate

barriers, and crushable energy absorbers. The staff confirms that the applicant has

appropriately revised the component type description in LRA Tables 2.4-10 and 3.5.2-10.

Therefore, the staff's concern described in RAI 2.4.1-3 is resolved.

In RAI 2.4.1-5, the staff noted LRA Section 2.4.1, Page 2.4-5 states that the suppression

chamber vent pipe system is evaluated as a mechanical component in LRA Section 2.3.2.5.

LRA Table 2.3.2-5 includes downcomers and piping and piping components as component

types subject to an AMR. It is not clear whether the vent pipe support assemblies and

downcomer (vent) pipe bracing system (see drawing C-1 932 Sheet 4 and UFSAR Figure 6.2-

56) are included within the scope of license renewal and subject to an AMR. The staff

requested that the applicant state whether these components are within the scope of license

renewal and subject to an AMR, and if they were not included as a result of an oversight,

provide a description of their scoping, screening, and AMR. If these components are excluded

from the scope of license renewal, provide the technical basis for the exclusion.

In its response to RAI 2.4.1-5, dated August 28, 2007, the applicant stated:

The suppression chamber vent pipe system supports are in the scope of License

Renewal for SSES and subject to aging management review. These supports

are included under Component Type "Component and piping supports (Class 1,

2, 3 and MC)" in Table 2.4-10.

Based on its review, the staff finds the applicant's response to RAI 2.4.1-5 acceptable because

the applicant has verified that the vent pipe system supports are within the scope of license

renewal and subject to an AMR, and are included under the component type "Component and

piping supports (Class 1, 2, 3 and MC)" in LRA Table 2.4-10. The staff determines that the vent

system supports are appropriately classified and described in the LRA Table 2.4-10. Therefore,

the staff's concern described in RAI 2.4.1-5 is resolved.

2.4.1.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and related structural components to

determine whether the applicant failed to identify any SSCs within the scope of license renewal.

The staff finds no such omissions. In addition, the staff's review determined whether the

applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On

the basis of its review, the staff concludes that the applicant has adequately identified the

primary containment SCs within the scope of license renewal, as required by 10 CFR 54.4(a),

and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.4.2 Reactor Building

2.4.2.1 Summary of Technical Information in the Application

In LRA Section 2.4.2, the applicant described the RB, a seismic Category I structure that

encloses the primary containment, and provides secondary containment when the primary

containment is in service during power operation and also serves as containment during reactor

refueling and maintenance operations when the primary containment is open. It houses the

2-138
auxiliary systems of the nuclear steam supply system, new fuel storage vaults, the refueling

facility, and equipment essential to the safe reactor shutdown. The RB consists of the following

major structural components: (a) foundation mat, (b) walls, (c) floors, (d) superstructure, and (e)

refueling floor.

The RB contains safety-related components relied upon to remain functional during and

following DBEs. In addition, the RB performs functions that support fire protection, ATWS, and

SBO.

LRA Table 2.4-2 identifies RB component types within the scope of license renewal and subject

to an AMR:

• blowout panels

* cranes, including bridge and trolley, rails, and girders

* exterior precast concrete panels (above grade)

* exterior walls (above grade)

• exterior walls (below grade)

• floor decking

• foundations

• fuel shipping cask storage pool gates

* fuel shipping cask storage pool liner

* masonry block walls

* metal siding

• new fuel racks

• new fuel storage vault

* new fuel storage vault watertight covers

• permanent reactor building shielding

• reactor well and steam dryer and separator storage pool gates

• reactor well and steam dryer and separator storage pool liners

* reactor well shield plugs

* reinforced concrete: girders, walls, floors, and ceilings

• roof decking * spent fuel pool gates

" spent fuel pool liners

• spent fuel pool racks

• spent fuel rack neutron absorbers

• structural steel: beams, columns, plates, and trusses

" sump liners

* sumps

The intended functions of the RB component types within the scope of license renewal include:

* thermal expansion, seismic separation, or both

• rated fire barrier to confine or retard fire spread in adjacent plant areas

• flood protection barrier

" shielding against high-energy line breaks

* missile barrier

2-139
" pipe whip restraint

* safety-related equipment shelter or protection

* shielding against radiation

" pressure boundary or essentially leak-tight barrier in postulated design-basis events to

protect public health and safety

" structural or functional support to safety-related components

* structural support to nonsafety-related components whose failure could prevent

satisfactory accomplishment of required safety functions

structural or functional support required for any of the 10 CFR 54.4(a)(3) regulated

events

2.4.2.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2 and UFSAR Section 3.8.4 using the evaluation

methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review, the staff evaluated the structural component functions described in the LRA

and UFSAR to verify that the applicant has not omitted from the scope of license renewal any

SCs with intended functions, pursuant to 10 CFR 54.4(a). The staff then reviewed those SCs

that the applicant has identified as within the scope of license renewal to verify that the

applicant has not omitted any passive and long-lived SCs subject to an AMR, in accordance

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

During its review of the LRA Section 2.4.2, the staff identified areas in which additional

information was necessary to complete the evaluation of the applicant's scoping and screening

results for structures. Therefore, the staff issued RAIs concerning the specific issues, to

determine whether the applicant properly applied the scoping criteria pursuant to

10 CFR 54.4(a) and the screening criteria in accordance with 10 CFR 54.21(a)(1). The following

discussion describes the staff's RAIs related to LRA Section 2.4.2 and the corresponding

applicant responses.

In RAI 2.4.2-1, dated August 3, 2007, the staff noted LRA Table 2.4-2 lists "Reinforced

concrete: walls, floors, and ceilings," within the RB, as a component type subject to an AMR.

The staff requested that the applicant confirm whether the two reinforced concrete girders (see

last paragraph of UFSAR Page 3.8-41) supporting the refueling facility within the Reactor

Building are within the scope of license renewal and subject to an AMR and; if so, revise the

LRA table, accordingly. If they are not within the scope of license renewal, provide the technical

basis for the exclusion.

In its response to RAI 2.4.2-1, dated August 28, 2007, the applicant stated:

The two reinforced concrete girders that support the refueling facility within the

Reactor Building are in the scope of License Renewal for SSES and subject to

aging management review. They are considered floor beams/walls for the

refueling pools and are integral to the Reactor Building concrete structure. The

reinforced concrete girders are included under Component Type "Reinforced

concrete: walls, floors, and ceilings" in Table 2.4-2.

2-140
Table 2.4-2 specific component type and Table 3.5.2-2 specific

component/commodity are revised as shown in bold italics in Attachment 5 (of

the applicant's response letter dated August 28, 2007) to describe the

component type as:

Reinforced concrete: girders, walls, floors, and ceilings

Based on its review, the staff finds the applicant's response to RAI 2.4.2-1 acceptable because

the applicant has verified that the two reinforced concrete girders supporting the refueling floor

girders facility within the RB are within the scope of license renewal and subject to an AMR. The

applicant further verified that these components are integral to the RB concrete structure and

are included under component type "Reinforced concrete: walls, floors, and ceilings" in the LRA

Table 2.4-2. The staff confirms that the applicant has revised the component type description in

LRA Tables 2.4-2 and 3.5.2-2 to read as: "Reinforced concrete: girders, walls, floors, and

ceilings." Therefore, the staff's concern described in RAI 2.4.2-1 is resolved.

In RAI 2.4.2-2, dated August 3, 2008, the staff noted LRA Table 2.4-2 lists "Reactor well shield

plugs," within the RB, as a component type subject to an AMR. It was not clear to the staff

whether the spent fuel pool plugs and dryer/separator pool plugs (see drawing C-1932 Sheet 5)

are included within the scope of license renewal. The staff requested that the applicant confirm

that these components are within the scope of license renewal and subject to an AMR and; if

so, revise the LRA table, accordingly. If they are not within the scope of license renewal,

provide the technical basis for the exclusion.

In its response to RAI 2.4.2-2, dated August 28, 2007, the applicant stated:

The plugs that separate the Reactor Well and the Spent Fuel Storage Pool and

the plugs that separate the Reactor Well and the Steam Dryer and Separator

Storage Pool are in the scope of License Renewal for SSES and subject to aging

management review. These plugs are included under Component Types "Spent

fuel pool gates" and "Reactor well and steam dryer and separator storage pool

gates" in Table 2.4-2. These slot plugs are concrete enclosed in welded stainless

steel.

Table 2.4-2 specific component type and Table 3.5.2-2 specific

component/commodity are revised as shown in bold italics in Attachment 6 (of

the applicant's response letter dated August 28, 2007) to describe the

component types as:

Reactor well and steam dryer and separator storage pool gates (includes steam

dryer/ separator pool plugs" and "Spent fuel pool gates (includes spent fuel pool

plugs)

Based on its review, the staff finds applicant's response to RAI 2.4.2-2 acceptable because the

applicant has verified that the plugs that separate the reactor well and the spent fuel storage

pool and the plugs that separate the reactor well and the steam dryer and separator storage

pool are within the scope of license renewal and subject to an AMR. The applicant further

verified that these plugs are included under component types "Spent fuel pool gates" and

"Reactor well and steam dryer and separator storage pool gates" in the LRA Table 2.4-2. The

2-141
staff confirms that the applicant has appropriately revised the component type descriptions in

LRA Table 2.4-2 to include these plugs. Therefore, the staff's concern described in RAI 2.4.2-2

is resolved.

In RAI 2.4.2-3, dated August 3, 2008, the staff noted LRA Tables 2.4-2, 2.4-4, 2.4-6, 2.4-7, and

2.4-8, list "Cranes, including bridge and trolley, rails, and girders," within the respective

structures, as a component type subject to an AMR. It is not clear to the staff which cranes

have been included within the scope of license renewal and whether all relevant

subcomponents ("...including bridge and trolley, rails, and girders") have been screened as

items subject to an AMR. The staff requested that the applicant (a) identify the specific cranes

in each of these structures that are included within the above component type as within the

scope of license renewal and subject to an AMR and those that are excluded and; if excluded,

provide the technical basis for the exclusion; (b) confirm whether fasteners and rail hardware

associated with this component type are within the scope of license renewal and subject to an

AMR and; if not, provide the technical basis for the exclusion and; (c) verify whether there are

any other hoists and lifting devices (e.g. reactor coolant pump lifting slings, lifting rigs, etc.) that

should be included within the scope of license renewal and subject to an AMR and; if so,

include these components in the LRA tables and provide the associated scoping, screening and

an AMR results.

In its response to RAI 2.4.2-3, dated August 28, 2007, the applicant stated:

For SSES all material handling equipment specified in the response to

NUREG-0612, Control of Heavy Loads, is in the scope of License Renewal for

SSES and subject to an AMR. (Refer to SSES Unit 1 Control of Heavy Loads -

Phase 1 - Safety Evaluation Report from NRC to PPL (August 2, 1983) and

SSES Unit 2 Control of Heavy Loads - Phase 1 - Safety Evaluation Report from

NRC to PPL (November 22, 1983). In addition, other monorails, hoists and

miscellaneous cranes within License Renewal in-scope structures are also in the

scope of License Renewal for SSES and subject to an AMR. Relevant

subcomponents ("...including bridge and trolley, rails, and girders") are in the

scope of License Renewal for SSES and subject to an AMR. These

subcomponents are included under Component Type "Cranes, including bridge

and trolley, rails, and girders" in Tables 2.4-2, 2.4-4, 2.4-6, 2.4-7, and 2.4-8.

Fasteners and rail hardware associated are in the scope of License Renewal for

SSES and subject to an AMR. These fasteners and rail hardware included under

Component Type "Anchorage / Embedments and Anchor Bolts" in Table 2.4-10.

Lifting devices (e.g. lifting slings, lifting rigs, etc.) are tools/rigging that are not

within License Renewal scope at SSES.

All the cranes, monorails, hoists and miscellaneous cranes within the in-scope

License Renewal SSES structures are in the scope of License Renewal for

SSES and subject to an AMR.

The following is a list of License Renewal in-scope Cranes, Monorails, Hoists

and Miscellaneous Cranes for SSES.

2-142
SSES Cranes and Monorails, Hoists (NUREG-0612)

Building Description

Reactor Reactor Building Crane

Reactor Refueling Platform

Diesel Generator A to E Diesel Generator Bridge Cranes

Monorails, Hoists and Miscellaneous Cranes

Reactor Recirculation Pump Hoist

Reactor RHR Heat Exchanger Hoists

Reactor HPCI Hoist

Reactor Core Spray Pump & Cooling Water Heat Exchanger

Hoists

Reactor Equipment Shaft Crane

Reactor Reactor Building Concrete Shielding Block Hoists

Reactor Drywell Equipment Hatch Hoist

Primary Containment Drywell Main Steam Relief Valve Hoist

Primary Containment Main Steam Isolation Valve Hoist

SSES Monorails, Hoists and Miscellaneous Cranes (Not within NUREG-0612)

Building Description

Circulating Water Circulating Water Pump Bridge Crane

Pumphouse

Turbine 220 Ton Overhead Cranes

Various in-scope Miscellaneous monorails/hoists within in-scope structures

structures

Based on its review, the staff finds the applicant's response to RAI 2.4.2-3 acceptable because

the applicant has verified that all material handling equipment specified in the response to

NUREG-0612, "Control of Heavy Loads," is within the scope of license renewal and subject to

an AMR. In addition, other monorails, hoists and miscellaneous cranes within in-scope

structures are also within the scope of license renewal and subject to an AMR. The applicant

also verified that:

" Relevant subcomponents ("...including bridge and trolley, rails, and girders") are within

the scope of license renewal and subject to an AMR, and are included under component

type "Cranes, including bridge and trolley, rails, and girders" in LRA Tables 2.4-2, 2.4-4,

2.4-6, 2.4-7, and 2.4-8.

" All the cranes, monorails, hoists and miscellaneous cranes within the in-scope

structures are within the scope of license renewal and subject to an AMR and are

tabulated in a comprehensive list of in-scope cranes, monorails, hoists and

miscellaneous cranes for SSES.

" Fasteners and rail hardware associated are within the scope of license renewal and

subject to an AMR, and are included under component type "Anchorage / Embedments

and Anchor Bolts" in LRA Table 2.4-10.

2-143
Lifting devices (e.g. lifting slings, lifting rigs, etc.) are tools/rigging and not within the

scope of license renewal.

The staff confirms that lifting devices such as slings and rigs are not within the scope of license

renewal, since they are tools/rigging and do not serve an intended function pursuant to

10 CFR 54.4(a), are not passive nor long-lived, and are routinely inspected and replaced as

needed. The staff finds that the applicant has appropriately applied the scoping criteria

pursuant to 10 CFR 54.4(a) and screening criteria in accordance with 10 CFR 54.21(a)(1) and

has identified all the cranes and associated subcomponents that are within the scope of license

renewal and subject to an AMR. Therefore, the staffs concerns described in RAI 2.4.2-3 are

resolved.

2.4.2.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and related structural components to

determine whether the applicant failed to identify any SSCs within the scope of license renewal.

The staff finds no such omissions. In addition, the staff's review determined whether the

applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On

the basis of its review, the staff concludes that the applicant has adequately identified the RB

SOs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to

an AMR, as required by 10 CFR 54.21(a)(1). The staff notes that RAI 2.4.2-3, the applicant's

response, and the staff's evaluation of the response also apply to the staff's evaluation of LRA

Sections 2.4.2, 2.4.4, 2.4.6, 2.4.7, and 2.4.8.

2.4.3 Engineered Safeguards Service Water Pumphouse and Spray Pond

2.4.3.1 Summary of Technical Information in the Application

In LRA Section 2.4.3, the applicant described the ESSW pumphouse and spray pond, both

seismic Category I structures. The ESSW pumphouse contains the ESW and RHRSW pumps

and the weir and discharge conduit for the spray pond. It is a two-story reinforced concrete

structure on a mat foundation. The first level of the structure is below grade with the following

major compartments: (a) pump intake chambers, (b) overflow weir, and (c) discharge header

compartments. Pumps, valving, and electrical switchgear are in the second level of the

structure at grade. HVAC equipment is located on a steel-framed mezzanine level. A

mezzanine floor supports the heating and ventilating equipment. The ESSW pumphouse

consists of the following major structural components: (a) foundation mat, (b) floors, (c) roof, (d)

walls, and (e) chambers.

The spray pond (ultimate heat sink) provides cooling water to support operation of the ESW

and RHRSW systems during system testing, normal shutdown, and accident conditions. The

ultimate heat sink can provide sufficient cooling water without makeup to the spray pond for at

least 30 days, to permit simultaneous safe-shutdown and cool-down of both reactor units and

can maintain them in a safe-shutdown condition. The spray pond can provide enough cooling

water without makeup for a design-basis LOCA in one unit with the simultaneous shutdown of

the other for 30 days, assuming a concurrent safe-shutdown earthquake, single failure, and

loss of offsite power. The spray pond consists of the following major structural components: (a)

spray pond liner, (b) spillway, (c) spray system, and (d) earthen embankment. The ESSW

pumphouse and spray pond contain safety-related components relied upon to remain functional

2-144
during and following DBEs. In addition, the ESSW pumphouse and spray pond perform

functions that support fire protection, ATWS, and SBO.

LRA Table 2.4-3 identifies ESSW pumphouse and spray pond component types within the

scope of license renewal and subject to an AMR:

" bulkhead closure plates

" bulkhead fixed screens

" bulkhead screen guides

* earthen embankment

* exterior walls (above grade)

* exterior walls (below grade)

* foundations

* masonry block walls

• overflow weir and chamber

* pump intake chambers

" reinforced concrete: walls, floors, and ceilings

" roof and floor decking

" roof slabs

• spray pond emergency spillway

" spray pond liner

" spray pond riser concrete encasements

" structural steel: beams, columns, plates, and trusses

" trash racks

* sumps

The intended functions of the ESSW pumphouse and spray pond component types within the

scope of license renewal include:

• rated fire barrier to confine or retard fire spread in adjacent plant areas

" flood protection barrier

* SBO or DBA heat sink

" missile barrier

" safety-related equipment shelter or protection

" plant shutdown cooling water source

* structural or functional support to safety-related components

" structural support to nonsafety-related components whose failure could prevent

satisfactory accomplishment of required safety functions

" structural or functional support required for any of the 10 CFR 54.4(a)(3) regulated

events

2.4.3.2. Staff Evaluation

The staff reviewed LRA Section 2.4.3 and UFSAR Sections 3.8.4 and 9.2.7 using the evaluation

methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.

2-145
During its review, the staff evaluated the structural component functions described in the LRA

and UFSAR to verify that the applicant has not omitted from the scope of license renewal any

SCs with intended functions, pursuant to 10 CFR 54.4(a). The staff then reviewed those SCs

that the applicant has identified as within the scope of license renewal to verify that the

applicant has not omitted any passive and long-lived SCs subject to an AMR, in accordance

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

2.4.3.3 Conclusion

The staff reviewed the LRA, UFSAR, and related structural components to determine whether

the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no

such omissions. In addition, the staff's review determined whether the applicant failed to identify

any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the

staff concludes that the applicant has adequately identified the ES SW pumphouse and spray

pond SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those

subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.4.4 Circulating Water Pumphouse and Water Treatment Building

2.4.4.1 Summary of Technical Information in the Application

In LRA Section 2.4.4, the applicant described the CWPH and water treatment building, which is

not a seismic Category I structure. The water treatment building is attached to the CWPH,

which contains electric and diesel-driven fire-water pumps separated by a structural fire barrier.

The water treatment building contains no equipment within the scope of license renewal but

shares with the CWPH a common wall, foundation, and roof, the structural components of

which are within the scope of license renewal, but not the remainder of the water treatment

building. The CWPH and water treatment building consist of the following major structural

components: (a) foundation mat, (b) floors, (c) walls, and (d) roof.

The CWPH and water treatment building perform functions that support fire protection.

LRA Table 2.4-4 identifies CWPH and water treatment building component types within the

scope of license renewal and subject to an AMR:

* battery racks

• cranes, including bridge and trolley, rails, and girders

• exterior precast concrete panels (above grade)

• exterior walls (above grade)

• exterior walls (below grade)

• floor decking

• foundations

• masonry block walls

• metal siding

" reinforced concrete: walls, floors, and ceilings

• roof decking

" structural steel: beams, columns, plates, and trusses

" sumps

2-146
The intended functions of the CWPH and water treatment building component types within the

scope of license renewal include:

* rated fire barrier to confine or retard fire spread in adjacent plant areas

" flood protection barrier

" safety-related equipment shelter or protection

" structural or functional support required for any of the 10 CFR 54.4(a)(3) regulated

events

2.4.4.2 Staff Evaluation

The staff reviewed LRA Section 2.4.4 using the evaluation methodology described in SER

Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review, the staff evaluated the structural component functions described in the LRA

and UFSAR to verify that the applicant has not omitted from the scope of license renewal any

SCs with intended functions, pursuant to 10 CFR 54.4(a). The staff then reviewed those SCs

that the applicant has identified as within the scope of license renewal to verify that the

applicant has not omitted any passive and long-lived SCs subject to an AMR, in accordance

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

The staff notes that RAI 2.4.2-3, the applicant's response and staff evaluation in LRA

Section 2.4.2 (regarding the "cranes" component type) also applies to this LRA Section 2.4.4.

2.4.4.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and related structural components to

determine whether the applicant failed to identify any SSCs within the scope of license renewal.

The staff finds no such omissions. In addition, the staff's review determined whether the

applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On

the basis of its review, the staff concludes that the applicant has adequately identified the

CWPH and water treatment building SCs within the scope of license renewal, as required by

10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.4.5 Control Structure

2.4.5.1 Summary of Technical Information in the Application

In LRA Section 2.4.5, described the control structure, a seismic Category I structure that

houses the control room, the cable spreading rooms, computer and relay room, the battery

room, heating and ventilation equipment room, off-gas treatment room, and the control room

visitors' gallery. The control structure consists of the following major structural components: (a)

foundation mat, (b) walls, (c) floors and roof, and (d) power generation control complex.

The control structure contains safety-related components relied upon to remain functional

during and following DBEs. In addition, the control structure performs functions that support fire

protection, ATWS, and SBO.

2-147
LRA Table 2.4-5 identifies control structure component types within the scope of license

renewal and subject to an AMR:

" battery racks

* control room ceiling

• exterior walls (above grade)

" exterior walls (below grade)

" floor decking

" foundations

" masonry block walls

" power generation control complex flooring

" reinforced concrete: walls, floors, and ceilings

" roof slabs

" structural steel: beams, columns, plates, and trusses

The intended functions of the control structure component types within the scope of license

renewal include:

* thermal expansion, seismic separation, or both

* rated fire barrier to confine or retard fire spread in adjacent plant areas

" flood protection barrier

" missile barrier

" safety-related equipment shelter or protection

" shielding against radiation

" pressure boundary or essentially leak-tight barrier in postulated design-basis events to

protect public health and safety

• structural or functional support to safety-related components

• structural support to nonsafety-related components whose failure could prevent

satisfactory accomplishment of required safety functions

* structural or functional support required for any of the 10 CFR 54.4(a)(3) regulated

events

2.4.5.2 Staff Evaluation

The staff reviewed LRA Section 2.4.5 and UFSAR Section 3.8.4 using the evaluation

methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review, the staff evaluated the structural component functions described in the LRA

and UFSAR to verify that the applicant has not omitted from the scope of license renewal any

SCs with intended functions, pursuant to 10 CFR 54.4(a). The staff then reviewed those SCs

that the applicant has identified as within the scope of license renewal to verify that the

applicant has not omitted any passive and long-lived SCs subject to an AMR, in accordance

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

2-148
2.4.5.3 Conclusion

The staff reviewed the LRA, UFSAR, and related structural components to determine whether

the applicant failed to identify any SSCs within the scope of license renewal. The staff finds no

such omissions. In addition, the staff's review determined whether the applicant failed to identify

any SCs subject to an AMR. The staff finds no such omissions. On the basis of its review, the

staff concludes that the applicant has adequately identified the control structure SCs within the

scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as

required by 10 CFR 54.21(a)(1).

2.4.6 Diesel Generator A, B, C, and D Building

2.4.6.1 Summary of Technical Information in the Application

In LRA Section 2.4.6, the applicant described the Diesel Generator (DG) A, B, C, and D

building, a seismic Category I structure housing DGs A, B, C, and D, which are essential for

safe shutdown of the plant. The DGs are separated from each other by concrete walls. A

concrete overhang on the east side of the building serves as an air intake plenum. A concrete

plenum for diesel exhaust is on the roof. The DG A, B, C and D building consists of the

following major structural components: (a) foundation mat, (b) walls, and (c) floors and roof.

The DG A, B, C, and D building contains safety-related components relied upon to remain

functional during and following DBEs. In addition, the building performs functions that support

fire protection and SBO.

LRA Table 2.4-6 identifies DG A, B, C, and D building component types within the scope of

license renewal and subject to an AMR:

" cranes, including bridge and trolley, rails, and girders

" diesel generator exhaust plenums

" diesel generator intake plenums

" exterior precast concrete panels (above grade)

" exterior walls (above grade)

* exterior walls (below grade)

* floor decking

• foundations

* masonry block walls

* metal siding

* reinforced concrete: walls, floors, and ceilings

* roof slabs

* structural steel: beams, columns, plates, and trusses

• sumps

The intended functions of the DG A, B, C, and D building component types within the scope of

license renewal include:

* thermal expansion, seismic separation, or both

* rated fire barrier to confine or retard fire spread in adjacent plant areas

2-149
" flood protection barrier

* missile barrier

* safety-related equipment shelter or protection

" structural or functional support to safety-related components

" structural support to nonsafety-related components whose failure could prevent

satisfactory accomplishment of required safety functions

* structural or functional support required for any of the 10 CFR 54.4(a)(3) regulated

events

2.4.6.2 Staff Evaluation

The staff reviewed LRA Section 2.4.6 and UFSAR Section 3.8.4 using the evaluation

methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review, the staff evaluated the structural component functions described in the LRA

and UFSAR to verify that the applicant has not omitted from the scope of license renewal any

SCs with intended functions, pursuant to 10 CFR 54.4(a). The staff then reviewed those SCs

that the applicant has identified as within the scope of license renewal to verify that the

applicant has not omitted any passive and long-lived SCs subject to an AMR, in accordance

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

During its review of the LRA Sections 2.4.6 and 2.4.7, the staff identified areas in which

additional information was necessary to complete the evaluation of the applicant's scoping and

screening results for structures. Therefore, the staff issued RAIs concerning the specific issues,

to determine whether the applicant properly applied the scoping criteria pursuant to

10 CFR 54.4(a) and the screening criteria in accordance with 10 CFR 54.21(a)(1). The following

discussion describes the staff's RAIs related to the LRA Sections 2.4.6 and 2.4.7 and the

corresponding applicant responses.

The staff notes that RAI 2.4.2-3, the applicant's response and staff evaluation in LRA

Section 2.4.2 (regarding the "cranes" component type) also applies to this LRA Section 2.4.6.

In RAI 2.4.6-1, dated August 3, 2007, the staff noted LRA Tables 2.4-6 and 2.4-7 list the

components of the DG A, B, C, D, and E buildings that are subject to an AMR. The staff

requested that the applicant confirm that the DG pedestals are components requiring an AMR

and are included in the referenced LRA tables and; if not, provide the technical basis for the

exclusion.

In its response to RAI 2.4.6-1, dated August 28, 2007, the applicant stated:

Diesel Generator Pedestals are an integral part of the Diesel Generator building

concrete structure and are in the scope of License Renewal for SSES and

subject to aging management review. The Diesel Generator Pedestals are

included under Component Type "Reinforced concrete: walls, floors, and

ceilings" in Table 2.4-6 and Table 2.4-7.

Based on its review, the staff finds the applicant's response to RAI 2.4.6-1 acceptable because

the applicant has verified that the DG pedestals are an integral part of the DG building concrete

2-150
structure, within the scope of license renewal, subject to an AMR, and included under

component type "Reinforced concrete: walls, floors, and ceilings" in LRA Tables 2.4-6 and

2.4-7. Since the pedestals are an integral part of the DG building concrete floor, staff finds that

the applicant has appropriately included the DG pedestals under the component type

"Reinforced concrete: walls, floors, and ceilings." Therefore, the staff's concern described in

RAI 2.4.6-1 is resolved. The staff notes that RAI 2.4.6-1, the applicant's response, and the

above staff evaluation also applies to the LRA Section 2.4.7.

2.4.6.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and related structural components to

determine whether the applicant failed to identify any SSCs within the scope of license renewal.

The staff finds no such omissions. In addition, the staff's review determined whether the

applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On

the basis of its review, the staff concludes that the applicant has adequately identified the DG

A, B, C, and D building SCs within the scope of license renewal, as required by 10 CFR 54.4(a),

and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.4.7 Diesel Generator E Building

2.4.7.1 Summary of Technical Information in the Application

In LRA Section 2.4.7, the applicant described the DG E building, a seismic Category I structure

that houses DG E, which replaces one of the A, B, C, and D DGs. Openings for air intake and

diesel exhaust are flush with the north and south exterior walls, respectively. Interior plenums

are for missile protection. The DG E building consists of the following major structural

components: (a) foundation mat, (b) walls, and (c) floors and roof.

The DG E building contains safety-related components relied upon to remain functional during

and following DBEs. In addition, the DG E building performs functions that support fire

protection and SBO.

LRA Table 2.4-7 identifies DG E building component types within the scope of license renewal

and subject to an AMR:

" battery racks

" cranes, including bridge and trolley, rails, and girders

" diesel generator exhaust plenums

* diesel generator intake plenums

" exterior walls (above grade)

" exterior walls (below grade)

" foundations

" metal siding

" reinforced concrete: walls, floors, and ceilings

" roof slabs

" sumps

2-151
The intended functions of the DG E building component types within the scope of license

renewal include:

* rated fire barrier to confine or retard fire spread in adjacent plant areas

* flood protection barrier

" missile barrier

" safety-related equipment shelter or protection

" structural or functional support to safety-related components

* structural support to nonsafety-related components whose failure could prevent

satisfactory accomplishment of required safety functions

" structural or functional support required for any of the 10 CFR 54.4(a)(3) regulated

events

2.4.7.2 Staff Evaluation

The staff reviewed LRA Section 2.4.7 and UFSAR Section 3.8.4 using the evaluation

methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review, the staff evaluated the structural component functions described in the LRA

and UFSAR to verify that the applicant has not omitted from the scope of license renewal any

SCs with intended functions, pursuant to 10 CFR 54.4(a). The staff then reviewed those SCs

that the applicant has identified as within the scope of license renewal to verify that the

applicant has not omitted any passive and long-lived SCs subject to an AMR, in accordance

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

The staff notes that RAI 2.4.2-3, applicant's response, and the staff evaluation in LRA

Section 2.4.2 (regarding the "cranes" component type) also applies to LRA Section 2.4.7.

The staff also notes that RAI 2.4.6-1 (regarding DG pedestals), the applicant's response, and

the staff evaluation of the same in LRA Section 2.4.6 applies to LRA Section 2.4.7.

2.4.7.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and related structural components to

determine whether the applicant failed to identify any SSCs within the scope of license renewal.

The staff finds no such omissions. In addition, the staff's review determined whether the

applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On

the basis of its review, the staff concludes that the applicant has adequately identified the DG E

building SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those

subject to an AMR, as required by 10 CFR 54.21(a)(1)

2.4.8 Turbine Building

2.4.8.1 Summary of Technical Information in the Application

In LRA Section 2.4.8, the applicant described the Turbine Building (TB), not a seismic Category

I structure, which is divided into two units with an expansion joint separating them. It houses two

2-152
in-line turbine generator units and the following auxiliary equipment: condensers, condensate

pumps, moisture separators, air ejectors, feedwater heaters, reactor feed pumps, motor

generator sets for reactor recirculation pumps, recombiners, interconnecting piping and valves,

and switchgears. (Note: The basement elevation (656 feet) of the TB is an area accessed

through the TB; with walls, floor, and foundation belonging to the control structure, but not part

of the control structure pressurization envelope.) The TB consists of the following major

structural components: (a) foundation mat, (b) walls, (c) floors and roof, (d) MS tunnel, and (e)

turbine generator pedestals

The failure of nonsafety-related SSCs in the TB potentially could prevent the satisfactory

accomplishment of a safety-related function. The TB also performs functions that support fire

protection and SBO.

LRA Table 2.4-8 identifies TB component types within the scope of license renewal and subject

to an AMR:

* blowout panels

" cranes, including bridge and trolley, rails, and girders

* exterior precast concrete panels (above grade)

" exterior walls (above grade)

" exterior walls (below grade)

" floor decking

" foundations

* main steam tunnels

" masonry block walls

* metal siding

* reinforced concrete: walls, floors, and ceilings

" roof decking

" shield plugs

" structural steel: beams, columns, plates, and trusses

" sump liners

" sumps

" turbine generator pedestals

" turbine generator pedestal structural bearing pads

The intended functions of the TB component types within the scope of license renewal include:

" thermal expansion, seismic separation, or both

" rated fire barrier to confine or retard fire spread in adjacent plant areas

* flood protection barrier

* missile barrier

* safety-related equipment shelter or protection

* shielding against radiation

* pressure boundary or essentially leak-tight barrier in postulated design-basis events to

protect public health and safety

structural or functional support to safety-related components

2-153
* structural support to nonsafety-related components whose failure could prevent

satisfactory accomplishment of required safety functions

" structural or functional support required for any of the 10 CFR 54.4(a)(3) regulated

events

2.4.8.2 Staff Evaluation

The staff reviewed LRA Section 2.4.8 and UFSAR Section 3.8.4 using the evaluation

methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review, the staff evaluated the structural component functions described in the LRA

and UFSAR to verify that the applicant has not omitted from the scope of license renewal any

SCs with intended functions, pursuant to 10 CFR 54.4(a). The staff then reviewed those SCs

that the applicant has identified as within the scope of license renewal to verify that the

applicant has not omitted any passive and long-lived SCs subject to an AMR, in accordance

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

During its review of the LRA Sections 2.4.8, the staff identified areas in which additional

information was necessary to complete the evaluation of the applicant's scoping and screening

results for structures. Therefore, the staff issued RAIs concerning the specific issues, to

determine whether the applicant properly applied the scoping criteria pursuant to

10 CFR 54.4(a) and the screening criteria in accordance with 10 CFR 54.21(a)(1). The following

discussion describes the staff's RAIs related to the LRA Section 2.4.8 and the corresponding

applicant responses.

The staff notes that RAI 2.4.2-3, applicant response, and the staff evaluation in LRA

Section 2.4.2 (regarding the "cranes" component type) also applies to LRA Section 2.4.6.

In RAI 2.4.8-1, dated August 3, 2007, the staff noted LRA Table 2.4-8 lists the components of

the TB that are subject to an AMR. The staff requested that the applicant confirm whether the

pipe tunnels at the foundation level for the off-gas piping (see third paragraph under the title

"Turbine Building" on page 3.8-44 of the UFSAR and drawing A-1 1 Sheet 1) are within the

scope of license renewal, subject to an AMR, and included in the referenced LRA table, and; if

not, provide the technical basis for the exclusion.

In its response to RAI 2.4.8-1, dated August 28, 2007, the applicant stated:

The pipe tunnels at the foundation level for the off-gas piping are an integral part

of the Turbine building concrete structure and in the scope of License Renewal

for SSES and subject to aging management review. The pipe tunnels are

included under Component Type "Reinforced concrete: walls, floors, and

ceilings" in Table 2.4-8.

Based on its review, the staff finds the applicant's response to RAI 2.4.8-1 acceptable because

the applicant has verified that the pipe tunnels at the foundation level for the off-gas piping are

an integral part of the TB concrete structure, within the scope of license renewal, and subject to

an AMR. The staff confirms that the applicant has included these pipe tunnels under

component type "Reinforced concrete: walls, floors, and ceilings" in LRA Table 2.4-8.

Therefore, the staff's concern described in RAI 2.4.8-1 is resolved.

2-154
2.4.8.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and related structural components to

determine whether the applicant failed to identify any SSCs within the scope of license renewal.

The staff finds no such omissions. In addition, the staff's review determined whether the

applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On

the basis of its review, the staff concludes that the applicant has adequately identified the TB

SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to

an AMR, as required by 10 CFR 54.21(a)(1).

2.4.9 Yard Structures

2.4.9.1 Summary of Technical Information in the Application

LRA Section 2.4.9.1 describes the yard structures, which include:

" clarified water storage tank foundation

" condensate storage tank foundation and retention basin

* DG fuel oil storage tank A, B, C, D, and E foundations and vaults

" refueling water storage tank foundation

" SBO component foundations and structures in the yard (startup transformers T-10 and

T-20 and associated disconnect switches, engineered safeguards systems

transformers, and transmission towers)

" cooling tower basins

* duct banks, manholes, valve vaults, instrument pits, and piping trenches in the yard

* 230kV and 500kV switchyard SBO component foundations and structures located

outside the security fence

The clarified water storage tank foundation is not a seismic Category I structure. The

500,000-gallon clarified water storage tank in the yard is the primary water source for fire

protection with a standpipe in the tank which reserves 300,000 gallons of the stored water for

fire protection. The tank is also a source of domestic water to the plant site. The clarified water

storage tank foundation is a reinforced concrete slab that supports the tank bottom resting on

an oiled sand pad.

The condensate storage tank foundation and retention basin are not seismic Category I

structures. The condensate storage tanks are the preferred water sources for the HPCI and

RCIC pumps for both operating and testing and they supply water to the core spray pumps for

testing. Each condensate storage tank maintains a minimum storage of 135,000 gallons to

serve HPCI and RCIC pumps during plant operation by standpipes and locked closed valves on

all other lines. The condensate storage tank foundation supporting the tank is a reinforced

concrete slab approximately 3 feet thick. Waterstops are in construction joints abutting the

retention basin slab. The condensate storage tank bottom rests on an oiled sand pad.

2-155
The DG fuel oil storage tank A, B, C, D, and E foundations and vaults are seismic Category I

structures. There are four 50,000-gallon nominal capacity fuel oil storage tanks for DGs A, B, C

and D and one 80,000-gallon nominal capacity fuel oil storage tank for DG E. The DG A, B, C,

and D tanks are underground adjacent to the DG building. The DG E tank is underground

adjacent to the DG E building. Diesel generator fuel oil storage tanks A, B, C and D share a

common reinforced concrete slab foundation. Diesel generator fuel oil storage tank E has its

own reinforced concrete slab foundation. The concrete tank foundation slab for DG fuel oil

storage tanks A, B, C and D is approximately 2 feet 6 inches thick. The concrete tank

foundation slab for DG fuel oil storage tank E is approximately 5 feet thick. Each tank has a

concrete vault from grade to tank connection for access, maintenance, inspection, repair, and

missile protection of the connection. The vault cover at grade level is steel plate.

The refueling water storage tank foundation is not a seismic Category I structure. One 680,000-

gallon refueling water storage tank common to both units stores the water that fills the reactor

well and dryer separator pool of either Unit 1 or 2. The refueling water storage tank foundation

supporting the tank is a reinforced concrete slab approximately 3 feet thick. Waterstops are in

construction joints abutting the retention basin slab. The refueling water storage tank bottom

rests on an oiled sand pad.

The SBO component foundations and structures in the yard (startup transformers T-10 and

T-20, disconnect switches, engineered safeguards systems transformers, and transmission

towers) are not seismic Category I structures. Startup transformers T-10 and T-20, associated

disconnect switches (motor-operated Air Break Switches 1 R105 and 2R1 05) and transmission

towers provide an offsite alternating current source for recovery from an SBO regulated event.

The startup transformers and disconnect switches, as well as the engineered safeguards

systems transformers, are supported by reinforced concrete pads. The disconnect switches are

supported by steel frame structures and the transmission conductors are supported by tapered

steel transmission towers and related foundations.

The cooling tower basins are not seismic Category I structures. The basins are designed to be

completely watertight with a capacity of six million gallons of water. Secondary sources of water

for the plant's two main automatic fire pumps, the two cooling tower basins have a minimum

depth of 7 feet 6 inches and the top of each is approximately 2 feet above the finished grade.

The cooling tower basins are constructed of reinforced concrete. Their foundations are situated

on bedrock.

Duct banks, manholes, valve vaults (including the spray pond valve vault), instrument pits, and

piping trenches are routed in the yard for physical support and shelter for in-scope mechanical

components (e.g., piping and valves) and in-scope electrical components (e.g., electric cables

and conduits). The duct banks, manholes, valve vaults, instrument pits, and piping trenches are

seismic Category I when they support or contain safety-related equipment, but not equipment

required for regulated events.

The T-10 230kV switchyard and the SSES 230kV switchyard SBO component foundations and

structures are located outside the security fence. The dead end structure and breakers (2S and

2T) support supplying power from the T-10 230kV switchyard to the 13.8kV bus 10 providing

offsite AC sources for recovery from an SBO. The dead end structure and breakers (2T and

2W) support supplying power from the 230kV switchyard to the 13.8kV bus 20 providing offsite

AC sources for recovery from an SBO. The dead end structures and breakers (2S & 2T and 2T

2-156
& 2W) are supported by reinforced concrete foundations. The control cubicles support/protect

the circuitry and controls.

The 500kV switchyard SBO component foundations and structures are located outside the

security fence. The 230kV dead end structure, the 230kV capacitive-coupled voltage

transformer and line trap, the 230kV switch, the 230kV current transformer, and the 230kV

breaker and control cubicle support supplying power from the 500kV switchyard to the 13.8kV

bus 20 providing offsite AC sources for recovery from an SBO. The 230kV dead end structure,

230kV capacitive-coupled voltage transformer and line trap, 230kV switch, 230kV current

transformer, and 230kV breaker are supported by reinforced concrete foundations and/or steel

piles.

The yard structures contain safety-related components relied upon to remain functional during

and following DBEs. The failure of nonsafety-related SSCs in the SSCs in the yard structure

potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the yard structures perform functions that support fire protection, ATWS, and SBO.

The yard structures also include structural components located outside the security fence that

are associated with SBO offsite power recovery pursuant to the guidance in the SRP-LR.

LRA Table 2.4-9 identifies yard structures component types within the scope of license renewal

and subject to an AMR:

" Battery racks (SBO)

" condensate storage tank retention basins

* cooling tower basic outlet screen guides

* cooling tower basin outlet screens

* cooling tower basin outlet structures

* cooling tower basins

* diesel generator fuel oil tank foundations

* diesel generator fuel oil tank vaults

* disconnect switch/capacitive-coupled voltage transformer and line trap/switch/current

transformer/breaker support structures (SBO)

" duct banks

" manhole covers

" manholes

" masonry block walls (SBO)

" metal siding (SBO)

" outdoor tank foundations: condensate storage tank, clarified water storage tank,

refueling water storage tank

" piles (500 kV switchyard) (SBO)

* piping trenches

* raised flooring (includes support system (SBO)

2-157
* roof decking

*. reinforced concrete (floors) (SBO)

* structural steel: beams, columns, plates, and trusses (includes welds and bolt

connections) (SBO)

transformer/disconnect switch/capacitive-coupled voltage transformer and line

trap/switch/current transformer/breaker/control cubicle foundations (SBO)

* transmission towers and dead end structures (SBO)

* trenches (SBO cables)

" valve vault and instrument pit hatches

* valve vaults and instrument pits

The intended functions of the yard structures component types within the scope of license

renewal include:

" flood protection barrier

* missile barrier

" safety-related equipment shelter or protection

* structural or functional support to safety-related components

" structural support to nonsafety-related components whose failure could prevent

satisfactory accomplishment of required safety functions

* structural or functional support required for any of the 10 CFR 54.4(a)(3) regulated

events

2.4.9.2 Staff Evaluation

The staff reviewed LRA Section 2.4.9, revised LRA Section 2.4.9 from SBO Scope Addition

PLA-6362 dated May 7, 2008, revised LRA Section 2.4.9 from SBO Scope Addition PLA-6413

dated August 29, 2008, and UFSAR Sections 9.2.8.2, 9.2.10, and 9.5.4, using the evaluation

methodology described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review, the staff evaluated the structural component functions described in the LRA

and UFSAR to verify that the applicant has not omitted from the scope of license renewal any

SCs with intended functions, pursuant to 10 CFR 54.4(a). The staff then reviewed those SCs

that the applicant has identified as within the scope of license renewal to verify that the

applicant has not omitted any passive and long-lived SCs subject to an AMR, in accordance

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

2.4.9.3 Conclusion

The staff reviewed the LRA, LRA SBO Scope Addition PLA-6362, LRA SBO Scope Addition

PLA-6413, UFSAR, and related structural components to determine whether the applicant failed

to identify any SSCs within the scope of license renewal. The staff finds no such omissions. In

addition, the staff's review determined whether the applicant failed to identify any SCs subject

to an AMR. The staff finds no such omissions. On the basis of its review, the staff concludes

2-158
that the applicant has adequately identified the yard structures SCs within the scope of license

renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by

10 CFR 54.21(a)(1).

2.4.10 Bulk Commodities

2.4.10.1 Summary of Technical Information in the Application

In LRA Section 2.4.10, the applicant described the bulk commodities, structural component

groups that support in-scope structures and mechanical/electrical systems (e.g., anchorages,

embedments, instrument panels, racks, cable trays, conduits, fire seals, fire doors, hatches,

monorails, equipment and component supports) for multiple SSCs, and share material and

environment properties which allow a common program or inspection to manage their aging

effects.

The bulk commodities contain safety-related components relied upon to remain functional

during and following DBEs. The failure of nonsafety-related SSCs in the SSCs in the bulk

commodities potentially could prevent the satisfactory accomplishment of a safety-related

function. In addition, bulk commodities perform functions that support fire protection, ATWS,

and SBO.

LRA Table 2.4-10 identifies bulk commodities component types within the scope of license

renewal and subject to an AMR:

" concrete components

* elastomeric components

* fire barrier commodities

* insulating materials

" steel and other metals

" threaded fasteners

The intended functions of the bulk commodities component types within the scope of license

renewal include:

* thermal expansion, seismic separation, or both

* rated fire barrier to confine or retard fire spread in adjacent plant areas

" flood protection barrier

" shielding against high-energy line breaks

" insulation to reduce heat transfer

* moisture absorption prevention and thermal insulation physical support

" missile barrier

* safety-related equipment shelter or protection

* shielding against radiation

* pressure boundary or essentially leak-tight barrier in postulated design-basis events to

protect public health and safety

2-159
" structural or functional support to safety-related components

* structural support to nonsafety-related components whose failure could prevent

satisfactory accomplishment of required safety functions

" structural or functional support required for any of the 10 CFR 54.4(a)(3) regulated

events

2.4.10.2 Staff Evaluation

The staff reviewed LRA Section 2.4.10 and the UFSAR using the evaluation methodology

described in SER Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review, the staff evaluated the structural component functions described in the LRA

and UFSAR to verify that the applicant has not omitted from the scope of license renewal any

SCs with intended functions, pursuant to 10 CFR 54.4(a). The staff then reviewed those SCs

that the applicant has identified as within the scope of license renewal to verify that the

applicant has not omitted any passive and long-lived SCs subject to an AMR, in accordance

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

During its review of LRA Sections 2.4.10, the staff identified areas in which additional

information was necessary to complete the evaluation of the applicant's scoping and screening

results for structures. Therefore, the staff issued RAIs concerning the specific issues, to

determine whether the applicant properly applied the scoping criteria, pursuant to

10 CFR 54.4(a) and the screening, in accordance with 10 CFR 54.21(a)(1). The following

discussion describes the staffs RAls related to LRA Section 2.4.10 and the corresponding

applicant responses.

In RAI 2.4.10-1, dated August 3, 2007, the staff noted Sections 2.4.1 thru 2.4.9 state that the

structural commodities for these respective structures are addressed in the bulk commodities

evaluation in LRA Section 2.4.10. LRA Table 2.4-10 lists the bulk commodities components

subject to an AMR in categories based on the material of the component type. This LRA Table

does not identify the specific structures addressed in LRA Sections 2.4.1 thru 2.4.9 in which

these individual component types are located. The staff requested that the applicant add a

column to LRA Table 2.4-10 listing the structure(s) in which each bulk commodity component

type is located, and clearly state whether the intent of the LRA Table is identify every

occurrence (all inclusive) for which these component types, in each of the applicable structures,

are within the scope of license renewal and subject to an AMR. In addition, the staff requested

that the applicant specifically identify those component types which are within the scope of

license renewal and subject to an AMR and those that are not and; if excluded, provide

technical justification for the exclusion. Also, the staff requested that the applicant confirm and

address whether or not there are any Lubrite sliding support bearings and/or surfaces within the

scope of license renewal and subject to an AMR, and whether these components will be

included in LRA Table 2.4-10.

In its response to RAI 2.4.10-1, dated August 28, 2007, the applicant stated:

As stated in Section 2.4.10, the Bulk Commodities common to SSES in-scope

License Renewal structures are listed in Table 2.4-10. They are common to

multiple SSCs and share material and environment properties which allow a

common program or inspection to manage their aging effects. Commodities

2-160
unique to a specific structure are included in the review of that structure

(Sections 2.4.1 through 2.4.9). All commodities within the SSES in-scope

License renewal structures are in-scope and are subject to aging management

review and are listed in Table 2.4-10. Commodities classified as Bulk

Commodities typically have no unique component identification number.

Therefore, a comprehensive listing of components and location is not feasible.

LRA Table 3.5.2-10 describes and indicates Aging Management Programs for

the components listed in Section 2.4.10.

There are no in-scope License Renewal Lubrite sliding support

bearings/surfaces at SSES.

Based on its review, the staff finds the applicant's response to RAI 2.4.10-1 acceptable

because the applicant has verified that the bulk commodities common to in-scope license

renewal structures are listed in LRA Table 2.4-10, are common to multiple SSCs, and share

material and environment properties which allow a common program or inspection to manage

their aging effects. The applicant also verified that commodities unique to a specific structure

are included in the review of that structure (LRA Sections 2.4.1 through 2.4.9); and that all

commodities not unique to a specific structure are within the scope of license renewal, subject

to an AMR, and listed in LRA Table 2.4-10. The applicant stated that a comprehensive listing of

components and location is not feasible, since these commodities have no unique component

identification number. Since the applicant basically stated that the commodities listed in LRA

Table 2.4-10 include "all" bulk commodities in the in-scope structures that are not uniquely

identified in LRA Sections 2.4.1 through 2.4.9, the staff finds that the applicant's list of common

bulk commodities in LRA Table 2.4-10 is all-inclusive of those in the in-scope structures

described in LRA Sections 2.4.1 through 2.4.9. The staff confirms that the applicant also has

verified that there are no Lubrite sliding support bearings and/or surfaces at SSES within the

scope of license renewal. Therefore, the staff's concerns described in RAI 2.4.10-1 are

resolved.

In RAI 2.4.10-2, dated August 3, 2007, the staff noted based on information provided in LRA

Table 2.4-10, that it could not specifically identify the insulation and insulation jacketing included

within the scope of license renewal nor the specific subsets of insulation and insulation

jacketing included in LRA Table 2.4-10. It was also unclear to the staff whether insulation and

jacketing on the RV, RCS, MS system, and FWS have been included. In order to help complete

its screening review for insulation and insulation jacketing, the staff requested that the applicant

provide the following information:

(a) Identify the structures and structural components designated within the scope of license

renewal that have insulation and/or insulation jacketing, and identify their location in the

plant. Identify locations of the thermal insulation that serves an intended function in

accordance with 10 CFR 54.4(a)(2) and describe the scoping and screening results of

thermal insulation and provide technical basis for its exclusion from the scope of license

renewal.

(b) For insulation and insulation jacketing materials associated with item (a) above that do

not require aging management, submit the technical basis for this conclusion, including

plant-specific operating experience.

2-161
(c) For insulation and insulation jacketing materials associated with item (a) above that

require aging management, indicate the applicable LRA sections that identify the AMPs

credited to managing aging.

In its response to RAI 2.4.10-2, dated August 28, 2007, the applicant stated:

The component type "Reactor vessel thermal insulation" is in the scope of

License Renewal for SSES and subject to aging management review as listed in

LRA Table 2.4-1. Insulation for Reactor Coolant, Main Steam, and Feedwater

System components in the scope of License Renewal is also in-scope at SSES

and subject to aging management review as listed in LRA Table 2.4-10 under

Component Types "Insulation" and "Insulation jacketing."

(a) LRA Section 2.1.2.6 describes the treatment of insulation, including the

identification of the various materials, indication of scope, and evaluation of

degradation potential. Thermal insulation provides nonsafety-related insulating

characteristics and personnel protection for both safety-related and nonsafetyrelated mechanical components that contain fluid (liquid or steam).

Piping and equipment insulation is not classified as safety-related and has the

intended function to maintain its structural integrity for nonsafety affecting safety

(NSAS) considerations, in accordance with 10 CFR 54.4(a)(2), if located in a

structure that contains safety-related equipment and components. Insulating

materials (insulation and insulation jacketing) that function to limit heat transfer

or are required to maintain their structural integrity are in the scope of License

Renewal at SSES and subject to aging management review.

Similar to numerous structural components that are not uniquely identified, for

which a comprehensive listing of components and location is not feasible, the

various in-scope insulation and insulation jacketing materials are addressed as

bulk commodities.

(b) Aging management reviews have determined that no aging management is

required for insulation and insulation jacketing materials associated with item (a).

As described in LRA Section 2.1.2.6, only stainless steel reflective metal or

stainless steel jacketed insulation is used inside containment. In other structures,

aluminum or aluminum jacketing is also used. Both stainless steel and aluminum

insulating materials are listed in LRA Table 3.5.2-10. These metallic insulating

materials are exposed to uncontrolled indoor air and no aging management is

required consistent with NUREG-1801 Items VII.J-15 and V.F-2, as addressed in

LRA Items 3.2.1-50 and 3.3.1-94. Furthermore, while aluminum exposed to

uncontrolled indoor air is not listed in NUREG-1801 Volume II, Chapters IV or

VII, stainless steel and steel exposed to uncontrolled indoor air requires no aging

management as listed in item NUREG-1801 Items IV.E-2, VIII.I-10 and VIII.1-13.

Similarly, in-scope metallic insulation materials for the Reactor Coolant, Main

Steam and Feedwater systems do not require aging management. This was not

reflected in LRA Items 3.1.1-85 or 3.4.1-41.

2-162
With respect to other evaluated insulating materials, such as calcium silicate,

fiberglass, Flexible "Min-K" (ceramic), woven glass fiber, and ceramic fiber listed

in LRA Table 3.5.2-10, aging management is also not required. Operating

experience has not identified any age-related degradation of insulation and

typical insulation problems are event driven (e.g., mechanical damage), and not

considered for license renewal.

The potential for degradation of insulation is described in LRA Section 2.1.2.6.

The only plausible aging effects that could result in degradation and failure,

affecting the intended function or creating a potential for spatial interaction are

those which may cause reaction or corrosion of barriers and coverings or that

could impact the insulating materials themselves. The relevant conditions do not

exist in the indoor air environment of the subject NSAS component group for the

following aging effect(s) to occur:

Loss of Material due to Corrosion - The SSES site is a location that is

rural rather than industrial or coastal and the air is not salt-laden nor does

it contain sufficient contaminants (e.g., sulfur) to concentrate and attack

the insulation barriers/coverings.

Loss of Material, Cracking, and/or Change in Material Properties due to

ultra-violet (UV) Radiation and/or Oxidation - UV radiation and the

oxidizing effects of the air may also cause deterioration of insulation

barriers and coverings. However, the only insulation at SSES that is not

either encapsulated in aluminum or stainless steel jacketing, or is

reflective metal (stainless steel or aluminum), are for the diesel engine

exhaust lines, where "Fibrefrax" cloth blanket is an acceptable alternate

jacketing material, and locations that have "Temp-mat" (fiberglass

blanket) or "Min-K" (ceramic fiber) insulation. Stainless steel and

aluminum jacket materials are resistant to the oxidizing effect of the air,

due to the passive layer and are considered impervious to ultraviolet

radiation (e.g., plant lighting).

With respect to "Temp-mat," "Min-K," and Fibrefrax (cloth coated

alternative) insulation, the limited uses of these insulation types (e.g.,

diesel exhaust lines, pipe whip restraints, etc.) are not expected to

experience sufficient UV radiation (plant lighting) exposure or ambient air

oxidation to result in degradation.

Loss of Material due to Wear - Wear (abrasion) is an applicable aging

mechanism for insulation whenever there is relative movement between a

surface and an insulation barrier or cover that is in contact. However,

wear occurs during the performance of active functions; as a result of

improper design, application, or operation; or to a very small degree with

insignificant consequences.

Degradation of Insulating Materials - The insulating materials are

fabricated of calcium silicate, glass fiber, or ceramic fiber. As described in

LRA Item 3.3.1-93, and others, no aging management is required for

glass exposed to uncontrolled indoor air. The thermal resistance

(insulating) characteristics of mass insulation systems are not expected

2-163
to naturally degrade over the course of their service life as proper

selection, design and installation for the specific service and condition is

assumed. Unless protective coverings of mass insulation systems are

damaged, loss/degradation of insulating material is not a concern. Mass

insulation systems used in nuclear plant applications typically are sealed

and include a combination of insulating material and a weather barrier,

vapor barrier, condensate barrier, or covering for the specific service.

This outer covering (or barrier) protects mass insulation from the

weather, solar/UV radiation, or atmospheric contaminants, and

mechanical damage, but permits the evaporation of any moisture vapor.

Furthermore, SSES operating experience supports a lack of degradation

in insulating characteristics over the service life of insulation, except as

the result of event-driven mechanical damage of coatings/barriers.

Details of the operating experience review and aging management review

of non-metallic insulating materials are contained in auditable format and

available for onsite review.

(c) There are no aging effects requiring management for any subject insulating

material component group that is exposed to indoor air, in order to preclude

spatial interaction with safety-related SCs, or for an intended (insulation) function

credited in heating analyses.

Based on its review, the staff finds the applicant's response to RAI 2.4.10-2 acceptable

because the applicant has verified that the RV insulation is within the scope of license renewal,

subject to an AMR, and included under component type "Reactor vessel thermal insulation" in

LRA Table 2.4-1. The applicant also verified that insulation for RCS, Main Steam system, and

feedwater system components within the scope of license renewal is also within the scope of

license renewal, subject to an AMR, and listed under component types "Insulation" and

"Insulation jacketing," in LRA Table 2.4-10. The staff confirms that the applicant has provided a

detailed review of the various insulating materials in use, the potential for degradation effects,

and operating experience. The staff also confirms the applicant's conclusion that, consistent

with the GALL Report, Volume II, none of the insulating material used in SSES requires any

management for aging affects, because of the applicant's favorable operating experience and

because these materials are exposed to an indoor air environment, only. Therefore, the staff's

concerns described in RAI 2.4.10-2 are resolved.

In RAI 2.4.10-3, dated August 3, 2007, the staff noted LRA Table 2.4-10 lists "Monorails, hoists

and miscellaneous cranes" as a bulk commodity component type subject to an AMR. It is not

clear to the staff which specific monorails, hoists and miscellaneous cranes have been

identified as within the scope of license renewal, and whether all relevant subcomponents

(including bridge and trolley, rails, girders, etc.) of these in-scope items have been screened in

as items requiring an AMR. The staff requested that the applicant identify the specific

monorails, hoists, and cranes included within the above component type as in-scope and

subject to an AMR and those that are excluded, and provide the technical basis for the

decision. In addition, the staff requested that the applicant confirm whether there are any bridge

and trolley, rails, and girders associated with these miscellaneous cranes and whether they are

included within the scope of license renewal and subject to an AMR. The staff also requested

that the applicant confirm whether fasteners and rail hardware associated with this component

2-164
type are within the scope of license renewal and subject to an AMR and; if not, provide the

technical basis for the exclusion.

In its response to RAI 2.4.10-3, dated August 28, 2007, the applicant stated:

Monorails, hoists and miscellaneous cranes within License Renewal in-scope

structures are also in the scope of License Renewal for SSES and subject to an

aging management review. (Refer to response to RAI

2.4.2-3 above)

Relevant subcomponents (including bridge and trolley, rails, and girders) are in

the scope of License Renewal for SSES and subject to aging management

review. These subcomponents are included under Component Type "Monorails,

hoists and miscellaneous cranes" in Table 2.4-10.

Fasteners and rail hardware associated are in the scope of License Renewal for

SSES and subject to aging management review. These fasteners and rail

hardware included under Component Type "Anchorage / Embedments and

Anchor Bolts" in Table 2.4-10.

Based on its review and .the applicant's response to and staff evaluation of RAI 2.4.2-3 in

SER Section 2.4.2, the staff finds the applicant's response to RAI 2.4.10-3 acceptable because

the applicant has verified that all monorails, hoists and miscellaneous cranes and the relevant

subcomponents are in-scope structures within the scope of license renewal and those subject

to an AMR. Therefore, the staff's concern described in RAI 2.4.10-3 is resolved.

2.4.10.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and related structural components to

determine whether the applicant failed to identify any SSCs within the scope of license renewal.

The staff finds no such omissions. In addition, the staff's review determined whether the

applicant failed to identify any SCs subject to an AMR. The staff finds no such omissions. On

the basis of its review, the staff concludes that the applicant has adequately identified the bulk

commodities SCs within the scope of license renewal, as required by 10 CFR 54.4(a), and

those subject to an AMR, as required by 10 CFR 54.21(a)(1).

2.5 Scoping and Screening Results: Electrical and Instrumentation and Controls

This section documents the staff's review of the applicant's scoping and screening results for

electrical and I&C systems. Specifically, this section discusses electrical and I&C component

commodity groups

In accordance with the requirements of 10 CFR 54.21(a)(1), the applicant must list passive,

long-lived SSCs within the scope of license renewal and subject to an AMR. To verify that the

applicant properly implemented its methodology, the staff's review focused on the

implementation results. This focus 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.

2-165
The staff's evaluation of the information in the LRA was the same for all electrical and I&C

systems. The objective was to determine whether the applicant has identified, in accordance

with 10 CFR 54.4, components and supporting structures for electrical and I&C systems that

appear to meet the license renewal scoping criteria. Similarly, the staff evaluated the applicant's

screening results to verify that all passive, long-lived components were subject to an AMR in

accordance with 10 CFR 54.21(a)(1).

In its scoping evaluation, the staff reviewed the applicable LRA sections, focusing on

components that have not been identified as within the scope of license renewal. The staff

reviewed relevant licensing basis documents, including the UFSAR, for each electrical and I&C

system to determine whether the applicant has omitted from the scope of license renewal

components with intended functions pursuant to 10 CFR 54.4(a). The staff also reviewed the

licensing basis documents to determine whether the LRA specified all intended functions in

accordance with 10 CFR 54.4(a). The staff requested additional information to resolve any

omissions or discrepancies identified.

After its review of the scoping results, the staff evaluated the applicant's screening results. For

those SCs with intended functions, the staff sought to determine whether (a) the functions are

performed with moving parts or a change in configuration or properties or (b) the SSCs are

subject to replacement after a qualified life or specified time period, pursuant to

10 CFR 54.21(a)(1). For those meeting neither of these criteria, the staff sought to confirm that

these SSCs were subject to an AMR, as required by 10 CFR 54.21 (a)(1). The staff requested

additional information to resolve any omissions or discrepancies identified.

2.5.1 Electrical and Instrumentation and Controls Component Commodity Groups

2.5.1.1 Summary of Technical Information in the Application

In LRA Section 2.5, the applicant described the electrical and I&C component commodity

groups, which include the following:

" Non-EQ Insulated Cables and Connections

" Non-Segregated Metal-Enclosed (Phase) Bus

* High-Voltage Insulators

* Transmission Conductors and Connections

The non-EQ insulated cables and connections commodity group includes all in-scope electric

power cables, control cables, and instrumentation cables and in-scope connections not

addressed by the EQ program. An insulated cable is an assembly consisting of a conductor

(aluminum or copper) with an insulated covering, fillers, and a jacket to cover the entire

assembly; however, the insulation is the only portion subject to evaluation. Cable connectors

connect the cable conductors with other cables or with motors, instruments, and a variety of

electrical devices. Insulated cables and connections connect specified portions of electrical

circuits to deliver voltage, current, or signals.

The nonsegregated metal-enclosed bus under review for license renewal is within its own

passive enclosure and not part of any switchgear, a load center, motor control center, or other

active component. According to Institute of Electrical and Electronic Engineers 100-1984, "The

IEEE Standard Dictionary of Electrical and Electronics Terms," a nonsegregated phase bus is

constructed with all phase conductors in a common metal enclosure without barriers (i.e., with

2-166
only air space) between the phases. Nonsegregated metal-enclosed buses connect two or

more elements of electric power circuits like switchgear, transformers, switches, and other

active electrical components. The license renewal review of nonsegregated metal-enclosed

buses includes only the bus sections between the active electrical components. The distribution

bus and the connections inside the enclosures of the active components are inspected and

maintained as parts of active components and therefore excluded from any AMR.

Nonsegregated metal-enclosed buses provide electrical connections to specified portions of

electrical circuits to deliver voltage and current.

A high-voltage insulator is a component uniquely designed to support a high-voltage conductor

physically and to separate the conductor electrically from another conductor or object. The

applicant's high-voltage insulators evaluated for license renewal include those supporting and

insulating high-voltage electrical components (i.e., transmission conductors and connections,

particularly those for offsite power supplies). There are two basic types of insulators: (1) station

post and (2) strain (or suspension) insulators. Station post insulators are large and rigid. They

support stationary equipment (e.g., short lengths of transmission conductors and disconnect

switches). Strain insulators are for applications where movement of the supported conductor is

expected and allowed, for example, to maintain tensional support of transmission conductors

between towers or other supporting structures. The high-voltage insulators within the scope of

license renewal are the station post insulators and strain insulators associated with the offsite

power supplies.

Transmission conductors are in the category of aluminum conductor steel-reinforced,

aluminum-strand conductors wrapped around a steel core. They are uninsulated, high-voltage

conductors that carry loads in plant switchyards and in distribution applications. Transmission

conductor connections are cast aluminum. The sections of transmission-type conductors at

SSES within the scope of license renewal are conductors associated with the offsite power

supplies. The transmission conductor sections are included to follow the guidance of Revision 1

of the SRP-LR for offsite power restoration after an SBO.

LRA Table 2.5-1 identifies electrical and I&C component commodity group component types

within the scope of license renewal and subject to an AMR:

* cable connections (metallic parts)

* fuse holders (insulation, metallic clamp)

• medium-voltage power cables

* metal-enclosed bus, non-segregated (bus and connections)

* metal-enclosed bus, non-segregated (enclosure assemblies)

* metal-enclosed bus, non-segregated (insulation and insulators)

* non-EQ insulated cables and connections

* non-EQ low-current instrument cables and connections

* high-voltage insulators

* transmission conductors and connections

2-167
The intended functions of the electrical and I&C component commodity group component types

within the scope of license renewal include:

* electrical connection to specified electrical circuit portions for voltage, current, or signal

delivery

" electrical conductor insulation and support

2.5.1.2 Staff Evaluation

The staff reviewed LRA Section 2.5 and UFSAR Sections 8.1, 8.2, and 8.3, using the evaluation

methodology described in SER Section 2.5 and the guidance in SRP-LR Section 2.5.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to

verify that the applicant has not omitted from the scope of license renewal any components with

intended functions, pursuant to 10 CFR 54.4(a). The staff then reviewed those components that

the applicant has identified as within the scope of license renewal to verify that the applicant

has not omitted any passive and long-lived components subject to an AMR, in accordance with

the requirements of 10 CFR 54.21(a)(1).

In RAI 2.5-1 dated July 30, 2007, the staff noted that according to LRA Section 2.5, the highvoltage switchyard circuit breakers that connect to the offsite sources, the circuits connecting

the startup transformers to the switchyard, and the associated components and structures are

not presently included within the scope of license renewal. GDC 17 requires that electric power

from the transmission network to the onsite electric distribution system be supplied by two

physically independent circuits to minimize the likelihood of their simultaneous failure. In

addition, the staff noted that the guidance provided by letter dated April 1, 2002, "Staff

Guidance on Scoping of Equipment Relied on to Meet the Requirements of the Station Blackout

Rule (10 CFR 50.63) for License Renewal (10 CFR 54.4(a)(3))," and later incorporated in SRPLR Section 2.5.2.1.1, states:

For purposes of the license renewal rule, the staff has determined that 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. This

path typically includes switchyard circuit breakers that connect to the offsite

system power transformers (startup transformers), the transformers themselves,

the intervening overhead or underground circuits between circuit breaker and

transformer and transformer and onsite electrical system, and the associated

control circuits and structures. Ensuring that the appropriate offsite power

system long-lived passive SSCs that are part of this circuit path are subject to an

AMR will assure that the bases underlying the SBO requirements are maintained

over the period of extended license.

The staff determined that the offsite power recovery path from the switchyard to the plant

Class 1 E safety buses, includes:

" switchyard circuit breakers that connect to the offsite power system (i.e., grid)

" offsite system power transformers

2-168
* the intervening overhead or underground circuits (i.e., cables, buses and connections,

transmission conductors and connections, insulators, disconnect switches, and

associated components)

* circuits between the circuit breakers and power transformers

" circuits between the power transformers and onsite electrical distribution system

" the associated control circuits and structures

The staff believes that the switchyard is part of the plant system and that the SBO recovery

paths, up to the switchyard circuit breakers that connect to the offsite system power

transformers, should be within the scope of license renewal, in accordance with the staff

guidance in SRP-LR Section 2.5.2.1.1. The SSCs within the scope of license renewal should

include a circuit breaker at transmission voltage, to ensure adequate protection of the safety

bus and ensure recovery of offsite sources. The staff believes that the circuit breaker should be

within the scope of license renewal because its intended function is to maintain electrical

continuity. The circuit breaker maintains independence of offsite power sources, affords

selective protection to minimize the probability of loss of offsite power, and reduces transients

from affecting the onsite distribution system. For these reasons, a circuit breaker remains as

the scoping boundary. Using a disconnect switch or other component downstream of the

breaker is not consistent with the staff position for compliance with the SBO rule and is not

acceptable for meeting the SBO scoping requirements for license renewal. Therefore, the staff

concludes that the SBO recovery paths that should be included in the scope of license renewal

is circuits up to and including the switchyard circuit breakers, at transmission voltage.

Furthermore, the associated control circuits and structures for the circuit breakers also should

be included within the scope of license renewal.

The staff clarified that both paths used to control the offsite circuits to the plant should be within

the scope of license renewal. The staff requested that the applicant justify why these

components are not within the scope of license renewal and explain, in detail, which highvoltage breakers and other components in the switchyard will be connected from the startup

transformers T10 and T20 up to the offsite power system for the purpose of SBO recovery.

In its response to RAI 2.5-1, dated August 23, 2007, the applicant stated that the 230 kV

equipment on the transmission system side of the motor-operated disconnects is not within the

scope of license renewal because they are part of the transmission system grid and not part of

the plant system. During a telephone conference, dated October 3, 2007, the staff informed the

applicant that its response to RAI 2.5-1 was not acceptable because it is not consistent with

staff guidance. The staff determined that the switchyard is part of the plant system and that the

SBO recovery paths should be within the scope of license renewal, in accordance with the

SRP-LR Section 2.5.2.1.1.

In a letter dated May 7, 2008, the applicant modified the SBO recovery paths for SSES, as

shown in LRA Figure 2.5-1, "Graphical Representation of the SSES SBO License Renewal

Boundary." The SSES SBO recovery paths include the transmission conductors from startup

transformers T10 and T20 to circuit breakers in the switchyard as well as the circuit breakers

themselves. The scoping boundary is at the transmission system side of the circuit breakers.

From startup transformer T10, the scoping boundary is 230 kV circuit breakers 2T and 2S. For

the SBO recovery path with startup transformer T20, the boundary is 230kV circuit breakers 2T

2-169
and 2W and also, a 230kV circuit breaker on the 230kV-500kV tie line, as shown in LRA Figure

2.5-1.

Based on its review, the staff finds the applicant's response to RAI 2.5-1 acceptable because

the applicant has verified that both SBO recovery paths are within the scope of license renewal.

The staff finds the applicant's response acceptable since the licensee has included switchyard

circuit breakers that connect to the offsite system power transformers (startup transformers),

the transformers themselves, the intervening overhead or underground circuits between circuit

breaker and transformer and transformer and onsite electrical system, and the associated

control circuits and structures in the scope of license renewal, in accordance with SRP-LR

Section 2.5.2.1.1. The staff confirms the applicant's change from motor-operated disconnects

to circuit breakers at transmission system voltage in the SBO recovery path, is consistent with

the proposed SRP-LR Section 2.5.2.1.1. Therefore, the staff's concern described in RAI 2.5-1 is

resolved.

In RAI 2.5-2 dated July 30, 2008, the staff requested confirmation that the control circuits and

structures associated with the 230 kV circuit breakers are within the scope of license renewal,

consistent with the requirements of 10 CFR 54.4(a)(3) and the guidance found in SRP-LR

Sections 2.1.3.1.3 and 2.5.2.1.1.

In its response to RAI 2.5-2, dated August 29, 2008, the applicant revised the LRA to include

the control circuits within the scope of license renewal.

Based on its review, the staff finds the applicant's response to RAI 2.5-2 acceptable because

the applicant has revised the LRA to include the control circuits within the scope of license

renewal, consistent with staff guidance. Therefore, the staff's concern described in RAI 2.5-2 is

resolved.

2.5.1.3 Conclusion

The staff reviewed the LRA, USAR, and RAI responses to determine whether the applicant

failed to identify any SSCs within the scope of license renewal. The staff finds no such

omissions. In addition, the staff's review determined whether the applicant failed to identify any

components subject to an AMR. The staff finds no such omissions. On the basis of its review,

the staff concludes that the applicant has adequately identified the electrical and I&C

component commodity groups components within the scope of license renewal, as required by

10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1) and

therefore is acceptable.

2.6 Conclusion for ScoDing and Screening

The staff reviewed the information in LRA Section 2, "Scoping and Screening Methodology for

Identifying Structures and Components Subject to AMR and Implementation Results" and

determines that the applicant's scoping and screening methodology was consistent with

10 CFR 54.21(a)(1) and the staff's positions on the treatment of safety-related and nonsafetyrelated SSCs within the scope of license renewal and on SCs subject to an AMR is consistent

with the requirements of 10 CFR 54.4 and 10 CFR 54.21(a)(1).

2-170
On the basis of its review, the staff concludes, that the applicant has adequately identified those

systems and components within the scope of license renewal, as required by 10 CFR 54.4(a),

and those subject to an AMR, as required by 10 CFR 54.21(a)(1).

The staff concludes that there is reasonable assurance that the applicant will continue to

conduct the activities authorized by the renewed license in accordance with the CLB and any

changes to the CLB in order to comply with 10 CFR 54.21 (a)(1), in accordance with the Atomic

Energy Act of 1954, as amended, and NRC regulations.

2-171

SECTION 3

AGING MANAGEMENT REVIEW RESULTS

This section of the safety evaluation report (SER) evaluates aging management programs

(AMPs) and aging management reviews (AMRs) for Susquehanna Steam Electric Station

(SSES) Units 1 and 2, by the staff of the United States (US) Nuclear Regulatory Commission

(NRC) (the staff). In Appendix B of its license renewal application (LRA), PPL Susquehanna,

LLC (PPL or the applicant) described the 51 AMPs that it relies on to manage or monitor the

aging of passive, long-lived structures and components (SCs).

In LRA Section 3, the applicant provided the results of the AMRs for those SCs identified in

LRA Section 2 as within the scope of license renewal and subject to an AMR.

3.0 Applicant's Use of the Generic Aging Lessons Learned Report

In preparing its LRA, the applicant credited NUREG-1 801, Revision 1, "Generic Aging Lessons

Learned (GALL) Report," dated September 2005. The GALL Report contains the staff's 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 period of extended 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 license renewal SCs. 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 its

programs correspond to those reviewed and approved in the report.

The purpose of the GALL Report is to provide a summary of staff-approved AMPs to manage or

monitor the aging of SCs subject to an AMR. If an applicant commits to implementing these

staff-approved AMPs, the time, effort, and resources for LRA review will be greatly reduced,

improving the efficiency and effectiveness of the license renewal review process. The GALL

Report also serves as a quick reference for applicants and staff reviewers to 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) structures, systems, and components (SSCs), (2) SC materials,

(3) environments to which the SCs are exposed, (4) the aging effects of the materials and

environments, (5) the AMPs credited with managing or monitoring the aging effects, and (6)

recommendations for further applicant evaluations of aging management for certain component

types.

The staff's review was in accordance with Title 10, Part 54, of the Code of Federal Regulations

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

and the guidance of the Standard Review Plan for Review of License Renewal Applications for

Nuclear Power Plants (SRP-LR) and the GALL Report.

In addition to its review of the LRA, the staff conducted an onsite audit of selected AMRs and

associated AMPs, during the week of May 5, 2008. The onsite audits and reviews are designed

to maximize efficiency of the staff's LRA review. The applicant can respond to questions, the

3-1
staff can readily evaluate the applicant's responses, the need for formal correspondence

between the staff and the applicant is reduced, and the result is an improvement in review

efficiency. The results of this audit were documented in the report of January 16, 2009.

3.0.1 Format of the License Renewal Application

The applicant submitted an application that follows the standard LRA format agreed to by the

staff and the Nuclear Energy Institute (NEI) by letter dated April 7, 2003 (ML030990052). This

revised LRA format incorporates lessons learned from the staff's reviews of the previous five

LRAs, which used a format developed from information gained during a staff-NEI demonstration

project conducted to evaluate the use of the GALL Report in the LRA review process.

The organization of LRA Section 3 parallels that of SRP-LR Chapter 3. LRA Section 3 presents

AMR results information in the following two table types:

(1) Table ls: 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 table type is the

first in LRA Section 3.

(2) Table 2s: Table 3.x.2-y - where "3" indicates the LRA section number, "x" indicates the

subsection number from the GALL Report, "2" indicates that this table type is the second

in LRA Section 3, and "y" indicates the system table number.

The content of the previous LRAs and of the SSES application is essentially the same. The

intent of the revised format of the LRA was to modify the tables in LRA Section 3 to provide

additional information that would assist in the staff's review. In its Table 1s, the applicant

summarized the portions of the application that it considered to be consistent with the GALL

Report. In its Table 2s, the applicant identified the linkage between the scoping and screening

results in LRA Section 2 and the AMRs in LRA Section 3.

3.0.1.1 Overview of Table Is

Each Table 1 compares in summary how the facility aligns with the corresponding tables in the

GALL Report. The tables are essentially the same as Tables 1 through 6 in the GALL Report,

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 "Item Number"

column is a means for the staff reviewer to cross-reference Table 2s with Table is. In the

"Discussion" column the applicant provided clarifying information. The following are examples of

information that might be contained within this column:

further evaluation recommended - information or reference to where that information is

located

* The name of a plant-specific program

* exceptions to GALL Report assumptions

* discussion of how the line is consistent with the corresponding line item in the GALL

Report when the consistency may not be obvious

discussion of how the item is different from the corresponding line item in the GALL

Report (e.g., when an exception is taken to a GALL Report AMP)

3-2
The format of each Table 1 allows the staff to align a specific row in the table with the

corresponding GALL Report table row so that the consistency can be checked easily.

3.0.1.2 Overview of Table 2s

Each Table 2 provides the detailed results of the AMRs for components identified in LRA

Section 2 as subject to an AMR. The LRA has a Table 2 for each of the systems or structures

within a specific system grouping (e.g., reactor coolant system, engineered safety features,

auxiliary systems, etc.). For example, the engineered safety features group has tables specific

to the core spray system, high-pressure coolant injection (HPCI) system, and residual heat

removal (RHR) system. Each Table 2 consists of nine columns:

Component Type - The first column lists LRA Section 2 component types subject to an

AMR in alphabetical order.

Intended Function - The second column identifies the license renewal intended

functions, including abbreviations, where applicable, for the listed component types.

Definitions and abbreviations of intended functions are in LRA Table 2.0-1.

Material - The third column lists the particular construction material(s) for the

component type.

Environment - The fourth column lists the environments to which the component types

are exposed. Internal and external service environments are indicated with a list of these

environments in LRA Tables 3.0-1 and 3.0-2.

Aging Effect Requiring Management - The fifth column lists aging effects requiring

management (AERMs). As part of the AMR process, the applicant determined any

AERMs for each combination of material and environment.

" Aging Management Programs - The sixth column lists the AMPs that the applicant uses

to manage the identified aging effects.

" NUREG-1801 Volume 2 Item - The seventh column lists the GALL Report item(s)

identified in the LRA as similar to the AMR results. The applicant compared each

combination of component type, material, environment, AERM, and AMP in LRA

Table 2 with the GALL Report items. If there are no corresponding items in the GALL

Report, the applicant leaves the column blank or N/A in order to identify the AMR results

in the LRA tables corresponding to the items in the GALL Report tables.

Table 1 Item - The eighth column lists the corresponding summary item number from

LRA Table 1. If the applicant identifies in each LRA Table 2 AMR results consistent with

the GALL Report, the Table 1 line item summary number should be listed in LRA

Table 2. If there is no corresponding item in the GALL Report, column eight is left blank

or N/A. In this manner, the information from the two tables can be correlated.

Notes - The ninth column lists the corresponding notes used to identify how the

information in each Table 2 aligns with the information in the GALL Report. The notes,

identified by letters, were developed by an NEI work group and will be used in future

LRAs. Any plant-specific notes identified by numbers provide additional information

about the consistency of the line item with the GALL Report.

3-3
3.0.2 Staff's Review Process

The staff conducted three types of evaluations of the AMRs and AMPs:

(1) For items that the applicant had stated were consistent with the GALL Report, the staff

conducted either an audit or a technical review to determine consistency.

(2) For items that the applicant had stated were consistent with the GALL Report with

exceptions, enhancements, or both, the staff conducted either an audit or a technical

review of the item to determine consistency. In addition, the staff conducted either an

audit or a technical review of the applicant's technical justifications for the exceptions or

the adequacy of the enhancements.

The SRP-LR states that an applicant may take one or more exceptions to specific GALL

AMP elements; however, any deviation from or exception to the GALL AMP should be

described and justified. Therefore, the staff considers exceptions as being portions of

the GALL AMP that the applicant does not intend to implement.

In some cases, an applicant may choose an existing plant program that does not meet

all the program elements defined in the GALL AMP. However, the applicant may make a

commitment to augment the existing program to satisfy the GALL AMP prior to the

period of extended operation. Therefore, the staff considers these augmentations or

additions to be enhancements. Enhancements include, but are not limited to, activities

needed to ensure consistency with the GALL Report recommendations. Enhancements

may expand, but not reduce, the scope of an AMP.

(3) For other items, the staff conducted a technical review to verify conformance with

10 CFR 54.21(a)(3) requirements.

Staff audits and technical reviews of the applicant's AMPs and AMRs determine whether the

aging effects on SCs can be adequately managed to maintain their intended function(s)

consistent with the plant's current licensing basis (CLB) for the period of extended operation, as

required by 10 CFR Part 54.

3.0.2.1 Review of AMPs

For AMPs which the applicant claimed consistency with the GALL AMPs, the staff conducted

either an audit or a technical review to verify the claim. For each AMP with one or more

deviations, the staff evaluated each deviation to determine whether the deviation was

acceptable and whether the modified AMP would adequately manage the aging effect(s) for

which it was credited. For AMPs not evaluated in the GALL Report, the staff performed a full

review to determine their adequacy. 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 SCs 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 function(s).

(4) Detection of Aging Effects - Detection of aging effects should occur before there is a

loss of structure or component intended function(s). This includes aspects such as

3-4
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.

(5) Monitoring and Trending - Monitoring and trending should provide predictability of the

extent of degradation, as well as 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.

(9) Administrative Controls - Administrative controls should provide for a formal review and

approval process.

(10) Operating Experience - Operating experience of the AMP, 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 adequately

managed so that the SC 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) are documented in

SER Section 3.0.3.

The staff reviewed the applicant's quality assurance (QA) program and documented its

evaluations in SER Section 3.0.4. The staff's evaluation of the QA program included

assessment of program element (7) "corrective actions," (8) "confirmation process," and

(9) "administrative controls" program elements.

The staff reviewed the information on the "operating experience" program element and

documented its evaluation in SER Section 3.0.3.

3.0.2.2 Review of AMR Results

Each LRA Table 2 contains information concerning whether or not the AMRs identified by the

applicant align with the GALL Report AMRs. For a given AMR in a Table 2, the staff reviewed

the intended function, material, environment, AERM, and AMP combination for a particular

system component type. Item numbers in column seven of the LRA, "NUREG-1801 Volume 2

Item," correlates to an AMR combination as identified in the GALL Report. The staff also

conducted onsite audits to verify these correlations. A blank or N/A in column seven indicates

that the applicant was unable to identify an appropriate correlation in the GALL Report. The

staff also conducted a technical review of combinations not consistent with the GALL Report.

The next column, "Table 1 Item," refers to a number indicating the correlating row in Table 1.

3.0.2.3 UFSAR Supplement

Consistent with the SRP-LR for the AMRs and AMPs that it reviewed, the staff also reviewed

the updated final safety analysis report (UFSAR) supplement, which summarizes the applicant's

3-5
programs and activities for managing aging effects for the period of extended operation, as

required by 10 CFR 54.21(d).

3.0.2.4 Documentation and Documents Reviewed

In its review, the staff used the LRA, LRA supplements, the SRP-LR, and the GALL Report.

During the onsite audit, the staff also examined the applicant's justifications 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

SER Table 3.0.3-1 presents the AMPs credited by the applicant and described in LRA

Appendix B. The table also indicates the SSCs that credit the AMPs and the GALL AMP with

which the applicant claimed consistency and shows the section of this SER in which the staff's

evaluation of the program is documented.

Table 3.0.3-1 SSES Aging Management Programs

SSESAMP Nw: or GALL Rert GL LA Sysitems ber Structures Saf

(LRASection) ,Ekistting ComparisOn epr That Credit the AMP SER Section

:''AM P AM~s

Inservice Inspection Existing Consistent with XI.M1 reactor vessel, reactor vessel 3.0.3.2.1

(ISI) Program exception internals, and reactor coolant

(B.2.1) system

BWR Water Existing Consistent XI.M2 reactor vessel, reactor vessel 3.0.3.1.1

Chemistry Program internals, and reactor coolant

(B.2.2) system / engineered safety

features / auxiliary systems I

steam and power conversion

systems / containments,

structures, and component

supports

Reactor Head Existing Consistent XI.M3 reactor vessel, reactor vessel 3.0.3.1.2

Closure Studs internals, and reactor coolant

Program system

(B.2.3)

BWR Vessel ID Existing Consistent XI.M4 reactor vessel, reactor vessel 3.0.3.1.3

Attachment Welds internals, and reactor coolant

Program system

(B.2.4)

BWR Feedwater Existing Consistent XI.M5 reactor vessel, reactor vessel 3.0.3.1.4

Nozzle Program internals, and reactor coolant

(B.2.5) system

BWR CRD Return Existing Consistent with XI.M6 reactor vessel, reactor vessel 3.0.3.2.2

Line Nozzle Program exception internals, and reactor coolant

(B.2.6) I system

3-6
SSES AMP New or GALL Report GALL LRA Systems or Structures Staff's

(LRA Section) Existing Comparison Report That Credit the AMP SER Section

AMP AMPs

BWR Stress Existing Consistent XI.M7 reactor vessel, reactor vessel 3.0.3.1.5

Corrosion Cracking internals, and reactor coolant

(SCC) Program system

(B.2;7)

BWR Penetrations Existing Consistent with XI.M8 reactor vessel, reactor vessel 3.0.3.2.3

Program exception internals, and reactor coolant

(B.2.8) system

BWR Vessel Existing Consistent with XI.M9 reactor vessel, reactor vessel 3.0.3.2.4

Internals Program enhancement internals, and reactor coolant

(B.2.9) system

Thermal Aging and New Consistent XI.M13 reactor vessel, reactor vessel 3.0.3.1.6

Neutron internals, and reactor coolant

Embrittlement of system

Cast Austenitic

Stainless Steel

(CASS) Program

(B.2.10)

Flow-Accelerated Existing Consistent XI.M17 reactor vessel, reactor vessel 3.0.3.1.7

Corrosion (FAC) internals, and reactor coolant

Program system / engineered safety

(B.2.11) features / auxiliary systems!

steam and power conversion

systems

Bolting Integrity Existing Consistent with XI.M18 reactor vessel, reactor vessel 3.0.3.2.5

Program exceptions and internals, and reactor coolant

(B.2.12) enhancement system / engineered safety

features/ auxiliary systems /

steam and power conversion

systems

Piping Corrosion Existing Consistent with XI.M20 engineered safety features I 3.0.3.2.6

Program exceptions auxiliary systems

(B.2.13)

Closed Cooling Existing Consistent with XI.M21 reactor vessel, reactor vessel 3.0.3.2.7

Water Chemistry exceptions intemals, and reactor coolant

Program system / auxiliary systems

(8.2.14)

Crane Inspection Existing Consistent XI.M23 containments, structures, and 3.0.3.1.8

Program component supports

(B.2.15)

Fire Protection Existing Consistent with XI.M26 containments, structures, and 3.0.3.2.8

Program. exceptions component supports

(B.2.16)

Fire Water System Existing Consistent with XI.M27 engineered safety features I 3.0.3.2.9

Program enhancements auxiliary systems

(B.2.17)

Buried Piping New Consistent with XI.M28 auxiliary systems 3.0.3.2.10

Surveillance exception

Program

(B.2.18)

3-7
SSESAMP NeworGALL Reportl .GALL,- LRA Systems or Structures Staff's

(LRA Section) Eilsting Comparison Report, That Credit the AMP SER Section

AMP Amps;

Condensate and New Consistent XI.M29 steam and power conversion 3.0.3.1.9

Refueling Water systems

Storage Tanks

Inspection

(B.2.19)

Fuel Oil Chemistry Existing Consistent with XI.M30 auxiliary systems 3.0.3.2.11

Program exceptions

(B.2.20)

Reactor Vessel Existing Consistent with XI.M31 reactor vessel, reactor vessel 3.0.3.2.12

Surveillance exception internals, and reactor coolant

Program system

(B.2.21)

Chemistry Program New Consistent XIM32 engineered safety features / 3.0.3.1.10

Effectiveness auxiliary systems / steam and

Inspection power conversion systems

(B.2.22)

Cooling Units New Consistent XI.M32 auxiliary systems 3.0.3.1.11

Inspection

(B.2.23)

Heat Exchanger New Consistent XI.M32 engineered safety features / 3.0.3.1.12

Inspection auxiliary systems

(B.2.24)

Lubricating Oil New Consistent XI.M32 engineered safety features / 3.0.3.1.13

Inspection auxiliary systems

(B.2.25)

Main Steam Flow New Consistent XI.M32 reactor vessel, reactor vessel 3.0.3.1.14

Restrictor Inspection internals, and reactor coolant

(B.2.26) system

Monitoring and New Consistent XI.M32 auxiliary systems 3.0.3.1.15

Collection System

Inspection

(B.2.27)

Supplemental New Consistent XI.M32 engineered safety features 3.0.3.1.16

Piping/Tank auxiliary systems / steam and

Inspection power conversion systems

(B.2.28)

Selective Leaching New Consistent XI.M33 engineered safety features / 3.0.3.1.1.7

Inspection auxiliary systems / steam and

(B.2.29) power conversion systems

Buried Piping and New Consistent with XI.M34 auxiliary systems / steam and 3.0.3.2.13

Tanks Inspection exceptions power conversion systems

Program

(B.2.30)

Small Bore Class 1 New Consistent XI.M35 reactor vessel, reactor vessel 3.0.3.1.18

Piping Inspection internals, and reactor coolant

(B.2.31) system

3-8
SSES AMP New6or GALLReport GALL LRA Systems or Structures. Staffs

(LRA Section)- Existing Comparison Report That;Credit the AMP SERSection

AMP AMPs

System Walkdown Existing Consistent with XI.M36 reactor vessel, reactor vessel 3.0.3.2.14

Program enhancements internals, and reactor coolant

(B.2.32) system / engineered safety

features / auxiliary systems I

steam and power conversion

systems

Lubricating Oil Existing Consistent with XI.M39 engineered safety features/ 3.0.3.2.15

Analysis Program exception and auxiliary systems

(B.2.33) enhancement

Inservice Inspection Existing Consistent XI.S1 containments, structures, and 3.0.3.1.19

(ISl) Program - IWE component supports

(B.2.34)

Inservice Inspection Existing Consistent XI.S2 containments, structures, and 3.0.3.1.20

(ISI) Program - IWL component supports

(B.2.35)

Inservice Inspection Existing Consistent XI.S3 containments, structures, and 3.0.3.1.21

(ISI) Program - IWF component supports

(B.2.36)

Containment Existing Consistent XI.S4 containments, structures, and 3.0.3.1.22

Leakage Rate Test component supports

Program

(B.2.37)

Masonry Wall Existing Consistent with XI.S5 structures, and component 3.0.3.2.16

Program enhancement supports

(B.2.38)

Structures Existing Consistent with XI.S6 containments, structures, and 3.0.3.2.17

Monitoring Program enhancements component supports /

(B.2.39) electrical and instrumentation

and controls

RG 1.127 Water- Existing Consistent with XI.S7 structures, and component 3.0.3.2.18

Control Structures enhancements supports

Inspection

(B.2.40)

Non-EQ Electrical New Consistent XI.E1 electrical and instrumentation 3.0.3.1.23

Cables and and controls

Connections Visual

Inspection Program

(B.2.41)

Non-EQ Cables and New Consistent XI.E2 electrical and instrumentation 3.0.3.1.24

Connections Used in and controls

Low-Current

Instrumentation

Circuits Program

(B.2.42)

Non-EQ Inaccessible New Consistent XI.E3 electrical and instrumentation 3.0.3.1.25

Medium-Voltage and controls

Cables Program

(B.2.43)

3-9
S:SSES AMPý,-- ,, ":Newý,or: GALL Report,. GALL LRASystems or Structures Staff's

(LRA Section). Existing Comparison, Report That Credit the AMP SER Section

Metal-Enclosed Bus New Consistent XI.E4 electrical and instrumentation 3.0.3.1.26

Inspection Program and controls

(B.2.44)

Non-EQ Electrical New Consistent XI.E6 electrical and instrumentation 3.0.3.1.27

Cable Connections and controls

Program

(B.2.45)

Area-Based NSAS New Plant-specific N/A auxiliary systems 3.0.3.3.1

Inspection

(B.2.46)

Leak Chase Channel Existing Plant-specific N/A structures, and component 3.0.3.3.2

Monitoring Activities supports

(B.2.47)

Preventive Existing Plant-specific N/A steam and power conversion 3.0.3.3.3

Maintenance systems

Activities -

RCIC/HPCI Turbine

Casings

(8.2.48)

Preventive Existing Plant-Specific N/A engineered safety features 3.0.3.3.4

Maintenance

Activities - Main

Turbine

(B2.49)

Fuse Holders New Consistent with XI.E5 electrical and instrumentation 3.0.3.2.20

Program exceptions and controls

(B.2.50)

Fatigue Monitoring Existing Consistent with X.M1 reactor vessel, reactor vessel 3.0.3.2.19

Program enhancements internals, and reactor coolant

(8.3.1) system / engineered safety

features / auxiliary systems /

steam and power conversion

systems / containments,

structures, and component

supports

EQ Program Existing Consistent X.E1 electrical and instrumentation 3.0.3.1.28

(B.3.2) and controls

3.0.3.1 AMPs Consistent with the GALL Report

In LRA Appendix B, the applicant identified the following AMPs as consistent with the GALL

Report:

* Boiling Water Reactor (BWR) Water Chemistry Program

* Reactor Head Closure Studs Program

* BWR Vessel Inside Diameter (ID) Attachment Welds Program

* BWR Feedwater Nozzle Program

* BWR Stress Corrosion Cracking (SCC) Program

3-10
Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS)

Program

* Flow-Accelerated Corrosion (FAC) Program

* Crane Inspection Program

* Condensate and Refueling Water Storage Tanks Inspection

* Chemistry Program Effectiveness Inspection

* Cooling Units Inspection

* Heat Exchanger Inspection

* Lubricating Oil Inspection

* Main Steam Flow Restrictor Inspection

" Monitoring and Collection System Inspection

* Supplemental Piping/Tank Inspection

* Selective Leaching Inspection

* Small Bore Class 1 Piping Inspection

* Inservice Inspection (ISI) Program - IWE

* Inservice Inspection (ISI) Program - IWL

* Inservice Inspection (ISI) Program - IWF

* Containment Leakage Rate Test Program

* Non-EQ Electrical Cables and Connections Visual Inspection Program

* Non-EQ Cables and Connections Used in Low-Current Instrumentation Circuits Program

* Non-EQ Inaccessible Medium-Voltage Cables Program

* Metal-Enclosed Bus Inspection Program

* Non-EQ Electrical Cable Connections Program

* Environmental Qualification (EQ) Program

3.0.3.1.1 BWR Water Chemistry Program

Summary of Technical Information in the Application. In LRA Section B.2.2, the applicant

described the existing BWR Water Chemistry Program as consistent with GALL AMP XI.M2,

"Water Chemistry." The applicant stated that the BWR Water Chemistry Program is a mitigation

program that manages potential aging effects for plant components in a treated water

environment. The applicant also stated that the program manages loss of material and cracking

through monitoring and control of relevant water chemistry parameters, such as sulfates,

halogens, dissolved oxygen, and conductivity, consistent with applicable Electric Power

Research Institute (EPRI) water chemistry guidelines.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff reviewed the applicant's AMP evaluation report for the BWR Water

Chemistry Program, together with implementing procedures and supporting documentation

related to the program. The staff noted that the program elements in the AMP that the applicant

claimed as consistent with the GALL Report are consistent with the corresponding program

3-11
element criteria recommended in GALL AMP XI.M2, with the exception of two program element

aspects which the staff determined a need for additional clarification and for which a request for

additional information (RAI) was issued. The staff evaluates these aspects of the AMP in the

following discussion.

In RAI B.2.2-1, item 1, dated June 23, 2008, the staff noted the following on program elements

that the applicant claimed to be consistent with GALL AMP XI.M2:

Item 1 (on "parameters monitored/inspected") - In the GALL Report, this program

element refers to BWRVIP-29 (EPRI TR-103515), "BWR Water Chemistry

Guidelines - 1996 Revision," or later revisions, which recommends continuous

monitoring of local electrochemical corrosion potential. However, in lieu of direct

electrochemical corrosion potential monitoring, the applicant currently relies on

monitoring of dissolved oxygen for indication of relevant conditions for corrosion.

The staff requested that the applicant provide a technical justification as to why

this deviation from the EPRI guidelines is acceptable and explain why this is not

considered to be an exception to the GALL Report.

In its response to RAI B.2.2-1, item 1, dated July 17, 2008, the applicant provided the following

discussion:

EPRI TR-103515 recommends continuous monitoring of local electrochemical

corrosion potential (ECP) during reactor power operation (greater than 10

percent rated power) as a method to demonstrate the effectiveness of hydrogen

water chemistry (HWC). EPRI TR-103515 also describes alternative techniques

using predictive models to verify the effectiveness of HWC. In such instances,

TR-103515 recommends models be benchmarked against ECP measurements

in radiolytically identical and operationally similar applications and a correlation

be developed between protective chemistry conditions, e.g., ECP, and other

plant (secondary) parameters that respond to hydrogen injection and are

normally continuously monitored. As described in TR-103515, secondary plant

parameters such as feedwater hydrogen flow rate or concentration, normalized

main steam line radiation or main steam line oxygen concentration, and reactor

coolant oxygen or hydrogen concentration can be directly related to primary

parameters such as ECP. The correlation between ECP and secondary

parameters, such as dissolved oxygen, is essential since the useful life for the

ECP probes can be less than a fuel cycle.

The BWR Water Chemistry program continuously monitors reactor water for

dissolved oxygen concentration and uses hydrogen injection to reduce dissolved

oxygen to protective levels (equivalent to ECP of less than -230 mV SHE

[standard hydrogen electrode]). ECP measurements were taken during initial

implementation of HWC and correlated with secondary parameters, including

dissolved oxygen. When dissolved oxygen is not available, other secondary

parameter correlations may be used to determine that protection is being

achieved. Therefore, since the use of dissolved oxygen in lieu of continuous

monitoring of ECP is consistent with the EPRI TR-103515 guidelines, no

exception to GALL is required.

3-12
In evaluating the applicant's response, the staff reviewed EPRI TR-103515-R2, Section 2.10.3,

"Secondary Monitoring Parameters," and Section 5.4, "Alternate ECP Estimation Techniques."

The staff confirms that the EPRI guidelines include provisions for using secondary plant

parameters, such as dissolved oxygen, in lieu of continuous electrochemical corrosion potential

monitoring. The EPRI guidelines state that plant-specific correlations should be developed to

relate secondary parameter values to electrochemical corrosion potential measurements and

can be used when direct electrochemical corrosion potential monitoring is not available.

Based on its review, the staff finds the applicant's response to RAI B.2.2-1, item 1 acceptable

because the applicant has developed plant-specific correlations relating continuously monitored

parameters to measured electrochemical corrosion potential values, which are consistent with

the EPRI TR-103515 that is endorsed by the GALL Report, and the applicant uses those

monitored parameters to control electrochemical corrosion potential at recommended protective

levels. The staff determines that the applicant's response is acceptable and that this aspect of

the applicant's program is consistent with the recommendations in the GALL Report. Therefore,

the staff's concern described in RAI B.2.2-1, item 1 is resolved.

In RAI B.2.2-1, item 2, dated June 23, 2008, the staff noted the following on program elements

that the applicant claimed to be consistent with GALL AMP XI.M2:

Item 2 (on "monitoring and trending") - In the GALL Report, this program element

refers to the EPRI water chemistry guidelines, TR-1 03515, or later revisions,

which recommends weekly monitoring of conductivity, chlorides, and sulfate in

the condensate storage tank (CST); however, the applicant currently measures

conductivity, chlorides, and sulfate in the CST on a monthly basis. The staff

requested that the applicant provide a technical justification as to why this

deviation from the EPRI guidelines is acceptable and explain why this is not

considered to be an exception to the GALL Report.

In its response to RAI B.2.2-1, item 2, dated July 17, 2008, the applicant provided the following

discussion:

EPRI TR-103515 recommends weekly monitoring of conductivity, chlorides, and

sulfates in the condensate storage tank but allows for reduced monitoring if the

sources of water are monitored. During normal power operation, all source water

to the condensate storage tanks is routinely monitored for conductivity, chlorides,

and sulfates. Therefore, the BWR Water Chemistry Program is consistent with

the EPRI guidance and the monitoring frequency is not considered to be an

exception to GALL.

In evaluating the applicant's response, the staff reviewed EPRI TR-103515-R2, Table B-i,

"Diagnostic Parameters for Demineralized Water Storage Tank (DWST) and Condensate

Storage Tank (CST)." The staff confirms that a note associated with this table states that the

frequency of CST analyses may be reduced or eliminated if all source water is routinely

monitored for conductivity, chlorides, and sulfates parameters. The staff noted that the

applicant's response states that during normal power operation all source water to the CST is

routinely monitored. The staff also noted that EPRI TR-103515-R2 states that each plant

should use the guidelines to develop site-specific procedures identifying parameters to be

monitored, along with recommended frequencies and limits. Because the applicant provides

routine monitoring for all source water to the CST during normal power operation and the EPRI

guidelines describe the monitoring frequencies as recommendations, rather than requirements,

3-13
the staff finds the reduction in CST monitoring frequency from weekly to monthly to be

acceptable and to be consistent with the recommendations in EPRI TR-1 03515, which is

endorsed by the GALL Report. On this basis, the staff finds the applicant's response to

RAI B.2.2-1, item 2 to be acceptable and this aspect of the applicant's program to be consistent

with the recommendations in the GALL Report.

Based on its review, and resolution of the related RAI as described above, the staff finds the

applicant's BWR Water Chemistry Program consistent with the program elements of GALL

AMP XI.M2 and therefore, the response is acceptable.

Operatingq Experience. The staff reviewed the applicant's operating experience (OE) described

in LRA Section B.2.2. The applicant stated that the BWR Water Chemistry Program

incorporates EPRI and Institute of Nuclear Power Operations (INPO) guideline documents as

well as lessons learned from site and other utility OE. The applicant stated that the program has

been and continues to be subject to internal and external assessments of the performance to

identify strengths and potential adverse trends. The applicant further stated that plant-specific

OE did not reveal a loss of component intended function for components exposed to reactor

coolant, feedwater (FW), condensate, control rod drive (CRD) hydraulic water, or accident

mitigation water (i.e., suppression pool water) that could be attributed to an inadequacy of the

BWR Water Chemistry Program.

During the onsite audit, the staff reviewed the applicant's OE reports for the BWR Water

Chemistry Program. The staff reviewed selected corrective action condition reports (CRs)

related to the BWR Water Chemistry Program and interviewed the applicant's technical staff to

confirm that the plant-specific OE did not reveal any degradation not bounded by industry

experience.

The staff noted that the applicant has a history of CRs related to high sulfate levels in reactor

water for a period of several days following refueling outages (RFOs), and that the applicant

has undertaken root cause evaluations and programmatic changes to reduce and control the

high sulfate levels. The applicant stated that there have been no component failures attributed

to the transient elevation of sulfate in the reactor following refueling.

In RAI B.2.2-2, dated June 23, 2008, the staff requested that the applicant explain its activities

related to understanding and mitigating this chemistry program issue, addressing the cause of

the problem, corrective actions and comparisons with other BWRs having similar condensate

demineralizers.

In its response to RAI B.2.2-2, dated July 17, 2008, the applicant provided the following

discussion:

The elevated sulfate levels following refueling outages were determined to be the

result of operational actions, such as removing a condensate pump from service,

which disturbed or upset the condensate demineralizer resin bed and allowed the

cation resin, which releases sulfate and organic sulfonates, to migrate to near

the outlet (bottom) of the resin bed. When the condensate demineralizers were

restarted after an outage, the sulfates and sulfonates that had concentrated in

the bed during the outage washed out of the cation resin at the bottom of the

demineralizer bed and caused the elevated sulfate levels. The elevated sulfate

levels continued for a week or two, until the excess was rinsed off the beds or

new anion resin heels were added to the vessels.

3-14
PPL undertook two corrective actions to mitigate the elevated sulfate level issue.

One included a change in operation of the condensate demineralizers and/or

condensate pumps as they are taken out of service. The procedures were

changed to bypass the condensate demineralizer so as to not upset the beds

during initial startup or final shutdown of the condensate pumps. Another

corrective action rinses the resin bed with demineralized water before starting

the condensate demineralizer. The out of service condensate demineralizer resin

bed is covered with demineralized water which is flushed to radwaste, taking any

excess sulfates with it, thus mitigating the elevated sulfate level. The condensate

demineralizer is placed in service after the rinse is completed.

In addition, PPL installed a condensate filtration system in the late 1990s. Since

then, PPL has experienced a continually improving trend in sulfate levels,

including the elevated sulfate levels following each outage. PPL maintains

sulfate data as a monthly average, as reported to INPO. The data shows that

monthly average sulfate levels following outages have not exceeded 5 ppb since

completion of the Unit 2 outage in 2003.

These actions have resulted in monthly average sulfate levels that are typically

below 2 ppb and often below 1 ppb. Comparison of SSES with other BWRs

having similar filters and condensate demineralizers, based on October 2007

data, places both SSES units above the median value, but below the EPRI

recommended goal of 2 ppb.

Based on the review, that staff finds the applicant's response to RAI B.2.2-2 acceptable

because the applicant has verified that its OE is within the envelope of industry experience and

the applicant's BWR Water Chemistry Program has demonstrated its ability to detect and

correct operational problems. Therefore, the staff's concern described in RAI B.2.2-2 is

resolved.

Based on this review, the staff finds that the OE for this AMP demonstrates that the applicant's

BWR Water Chemistry Program is achieving its objective of mitigating loss of material due to

general, crevice and pitting corrosion and cracking caused by SSC in steel and/or stainless

steel exposed to treated water; and that the applicant is taking appropriate corrective actions

through implementation of this program.

The staff confirms that the "operating experience" program element satisfies the criterion

defined in the GALL Report and the guidance found in SRP-LR Section A.1.2.3.10. Therefore,

the staff finds this program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement for the BWR Water

Chemistry Program in LRA Section A.1.2.11. The staff notes that the UFSAR supplement's

description for the BWR Water Chemistry Program conforms to the recommended UFSAR

supplement for this type of program as described in the SRP-LR. The staff also notes that in

LRA Table A-i, Commitment No. 2, the applicant committed to ongoing implementation of the

BWR Water Chemistry Program for aging management of applicable components, during the

period of extended operation.

Based on the review, the staff finds that the UFSAR supplement summary in LRA

Section A.1.2.11 provides an acceptable description of the applicant's BWR Water Chemistry

3-15
Program because it is consistent with the UFSAR supplement summary description in the

SRP-LR for the BWR Water Chemistry Program. The staff also finds that the information in the

UFSAR supplement is an adequate summary description of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of the review of the applicant's BWR Water Chemistry Program and

the applicant's responses and resolutions of the related RAls, the staff finds all program

elements consistent with the GALL Report. The staff concludes that the applicant has

demonstrated that the effects of aging will be adequately managed so that the intended

function(s) will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this

AMP and concludes that it provides an adequate summary description of the program, as

required by 10 CFR 54.21(d) and therefore is acceptable.

3.0.3.1.2 Reactor Head Closure Studs Program

Summary of Technical Information in the Application. In LRA Section B.2.3, the applicant

described the existing Reactor Head Closure Studs AMP as consistent with the GALL

AMP XI.M3, "Reactor Head Closure Studs." The Reactor Head Closure Studs Program

provides for condition monitoring and preventive actions to manage stud cracking. The program

is implemented through plant procedures based on the inspection requirements specified in the

American Society of Mechanical Engineers (ASME) Code, Section XI, Subsection IWB,

Table IWB 2500-1, and the preventive measures described in Regulatory Guide (RG) 1.65.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff reviewed the applicant's onsite documentation supporting the

applicant's conclusion that the program elements are consistent with the elements in GALL

AMP XI.M3.

The staff compared the elements in the applicant's program with the GALL Report program

elements. The staff confirmed that the maximum reported ultimate tensile strength for the

reactor head closure studs and nuts is 163.5 ksi, which is less than the 170 ksi specification

cited in the GALL Report "scope of program" program element.

The staff noted that the applicant had indicated that the current scope of the program applies to

the ASME Code Section XI, 1998 Edition, inclusive of the 2000 Addenda. The program

description in the GALL AMP XI.M3 states that the GALL Report applies to inspection, repair,

and replacement activities for ASME Code components covered in ASME Code Section XI, the

2001 Edition, inclusive of the 2003 Addenda. The staff noted that the applicant had clarified that

the use of ASME Code Section Xl, the 1998 Edition, inclusive of the 2000 Addenda, is

consistent with the program description statement in the GALL AMP XI.M3 because the

Statements of Consideration (SOC) on 10 CFR Part 54 clarifies that acceptable editions of the

ASME Code Section XI are those up through the most recently endorsed edition of the Code

mentioned in 10 CFR 50.55a. The staff verified that the SOC on 10 CFR Part 54 does include

this clarification, and on that basis, the applicant's use of ASME Code Section XI, 1998 Edition,

inclusive of the 2000 Addenda, is consistent with the Code edition mentioned in the program

description of GALL AMP XI.M3. Based on this review, the staff finds the applicant's crediting of

the ASME Code Section XI, 1998 edition, inclusive of the 2000 Addenda (for aging

management) is consistent with the criteria in GALL AMP XI.M3.

3-16
The staff confirmed that, in LRA Commitment No. 3, the applicant has committed to the

ongoing implementation of the Reactor Head Closure Stud Program for aging management of

those in-scope components that the AMP is credited. The staff also confirmed that the applicant

has placed this commitment in LRA A.1.2.40 for the Reactor Head Closure Stud Program.

In comparing the seven program elements in the applicant's program to those in

GALL AMP XI.M3, the staff noted that the program elements for which the applicant claimed

consistency with the GALL Report were consistent with the corresponding program element

criteria recommended in GALL AMP XI.M3. The "operating experience" program element is

discussed separately below.

Operatingq Experience. The staff reviewed the applicant's OE described in the LRA

Section B.2.3. The applicant stated that plant-specific OE did not reveal any degradation. The

staff reviewed the OE reports provided in the LRA and in the plant basis documents, the staff

confirmed that the plant-specific OE reviewed did not reveal any reactor head closure stud

cracking or loss of material, or any other age related degradation with the reactor pressure

vessel (RPV) head studs, nuts, or washers.

The staff confirms that the "operating experience" program element satisfies the criterion

defined in the GALL Report and the guidance found in SRP-LR A.1.2.3.10. Therefore, the staff

finds this program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement summary for the Reactor

Head Closure Studs Program in LRA section A.1.2.40. The staff reviewed this section and finds

it acceptable because it is consistent with the corresponding program description in SRP-LR

Table 3.1-2. The staff determines that the information in the UFSAR supplement is an adequate

summary description of the program, as required by 10 CFR 54.21(d).

The staff confirms that, in LRA Commitment No. 3, the applicant has committed to the ongoing

implementation of the Reactor Head Closure Stud Program for aging management of those inscope components for which the AMP is credited. The staff also confirms that the applicant has

placed this commitment for the Reactor Head Closure Stud Program in LRA Section A. 1.2.40.

Conclusion. On the basis of the review of the applicant's Reactor Head Closure Stud Aging

Management Program, the staff finds all program elements consistent with the GALL Report.

The staff concludes that the applicant has demonstrated that the effects of aging will be

adequately managed so that the intended functions will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also

reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d) and therefore, is

acceptable.

3.0.3.1.3 BWR Vessel Inside Diameter Attachment Welds Program

Summary of Technical Information in the Application. In LRA Section B.2.4, the applicant

described the BWR Vessel ID Attachment Welds Program as an existing program that is

consistent with GALL Report AMP XI.M4, "BWR Vessel ID Attachment Welds." The applicant

stated that the program includes inspection and flaw evaluation, pursuant to the guidelines of

the staff-approved Boiling Water Reactor Vessel and Internals Project (BWRVIP) report

BWRVIP-48; and monitoring and control of reactor coolant water chemistry, pursuant to the

3-17
guidelines of BWRVIP-29. The program helps to ensure the long-term integrity and safe

operation of the vessel ID attachment welds.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff also confirmed that the plant program contains all of the elements of

the referenced GALL Report. The staff also conducted onsite interviews with the applicant to

confirm these results.

The staff noted that the applicant's BWR Vessel ID Attachment Welds Program is based on the

augmented inspection and flaw evaluation guideline criteria in Boiling Water Reactor Vessel

and Internals Project (BWRVIP) Proprietary Topical Report No. TR-108724, "BWR Vessel and

Internals Project, Vessel [Inner Diameter] ID Attachment Weld Inspection and Flaw Evaluation

Guidelines (BWRVIP-48)." The staff approved the topical report to be credited for license

renewal in a safety evaluation (SE) dated January 17, 2001. The approved version of the topical

report is Topical Report BWRVIP-48-A.

In the SE on Topical Report BWRVIP-48-A, the staff issued three renewal applicant action

items for BWR applicants crediting BWRVIP-48-A for aging management of reactor vessel (RV)

ID attachment welds. The applicant provided the staff's renewal applicant action item

descriptions and its responses to these actions items in LRA Appendix C, Table BWRVIP-48-A.

The three action items follow:

(1) The staff's first renewal applicant action item required that applicants identify those

guideline criteria aspects in BWRVIP-48-A that they might deviate from. The staff noted

that the applicant would not deviate from the recommended inspection and flaw

evaluation criteria provided in BWRVIP-48-A and; thus, determined that the applicant

adequately addressed the staff's action item. Based on this review, the staff concludes

that the applicant has adequately addressed the staff's first renewal applicant action

item on BWRVIP-48-A. Therefore, this renewal applicant action item is resolved.

(2) The staff's second renewal applicant action item required that BWR applicants provide a

UFSAR supplement summary description of the AMP based on the BWRVIP-48-A

recommended criteria. The applicant stated that LRA Appendix A includes the UFSAR

supplement for the BWR Vessel ID Attachment Welds Program. The staff confirms that

the applicant has provided its UFSAR supplement summary description for the BWR

Vessel ID Attachment Welds Program in LRA Section A. 1.2.9. The staff's evaluation of

the applicant's UFSAR supplement for this program follows later in this evaluation.

Based on this review, the staff concludes that the applicant has adequately addressed

the staff's second renewal applicant action item on BWRVIP-48-A. Therefore, this

renewal applicant action item is resolved.

(3) The staff's third renewal applicant action item required that BWR applicants ensure that

the inspection criteria in BWRVIP-48-A will not conflict with or result in changes to the

plant's Technical Specifications (TSs). The applicant stated that its implementation of

the inspection strategy in BWRVIP-48-A will not result in the need for any changes to

the TS for either Unit 1 or Unit 2. The staff reviewed the TSs for Units 1 and 2 and

confirms that, while the methods in BWRVIP-48-A may constitute alternative staffapproved inspection guidelines for the ASME Code Class 1 RV ID attachment welds,

the TSs for Units 1 and 2 do not include any requirements to implement the ASME Code

Section XI, ISI Programs requirements for the facility. The staff also confirms that the

applicant's TSs center on operational-based, surveillance-based, and administrative

3-18
control-based TS requirements and that the ISI Program and requirements are

implemented through the applicant's ASME Code Section XI, ISI Program, pursuant to

10 CFR 50.55a. Thus, based on this review, the staff concludes that the applicant has

provided an adequate basis for concluding that its implementation of the guidelines in

BWRVIP-48-A will not conflict with or result in any necessary changes in the TSs. Based

on this review, the staff concludes that the applicant has adequately addressed the

staff's third renewal applicant action item on BWRVIP-48-A. Therefore, this renewal

applicant action item is resolved.

Based on its review, the staff finds the applicant's BWR Vessel Inside Diameter Attachment

Welds Program consistent with the program elements of GALL AMP XI.M4 and therefore, is

acceptable.

Operating Experience. The staff reviewed the applicant's OE basis document for safety

significant OE relevant to the aging management of BWR Vessel ID attachment weld

components. The staff noted that the applicant only provided an overall OE summary statement

in the "operating experience" program element for BWR Vessel ID Attachment Weld Program

and did not provide any examples of SSES-specific or generic OE demonstrating that the

AMP accomplishes its intended objective. However, the staff noted that the license renewal

program basis document for the BWR Vessel ID Attachment Welds Program did include the ISI

outage summary reports for the Units 1 and 2 refueling and inspection outages (U1-13RIO and

U2-1 1 RIO, respectively). The staff confirmed that, in these outage summaries, the applicant did

not identify any recordable flaw indications resulting from its augmented inspections of the RV

ID attachment welds.

Based on this review, the staff confirms that the applicant has been implementing the

inspections of its RV ID attachment welds in accordance with the ISI requirements of the ASME

Code Section XI, as modified by the recommended augmented inspection criteria in Topical

Report No. BWRVIP-48-A and approved in the staff's SE on BWRVIP-48-A, dated

January 17, 2001. The staff finds that the applicant's RFOs and inspection reports (IRs) provide

acceptable confirmation that currently there is no plant-specific OE for the RV ID attachment

welds inspected during outages U1-13RIO and U2-1 1RIO.

The staff confirms that the OE program element satisfies the criterion defined in the GALL

Report and the guidance found in SRP LR Section A. 1.2.3.10. Therefore, the staff finds this

program element acceptable.

UFSAR Supplement. The applicant provided an UFSAR supplement for its BWR Vessel ID

Attachment Welds Program in LRA Section A.1.2.9 and Commitment No. 4 in Table A-I. The

staff confirms that the UFSAR supplement summary description for the BWR Vessel ID

Attachment Welds Program conforms to the staff's recommended UFSAR supplement for these

type of programs as described in SRP-LR Table 3.1-2. The staff also confirms that in UFSAR

Supplement Table A-i, the applicant committed (Commitment No. 4) to ongoing

implementation of its BWR Vessel ID Attachment Welds Program for aging management of

those Units 1 and 2 in-scope components that the AMP is credited for. Further, the staff

confirms that the applicant has linked this commitment to UFSAR Supplement A.1.2.9 for the

BWR Vessel ID Attachment Welds Program. Based on this review, the staff finds that UFSAR

Supplement A. 1.2.9, when coupled to LRA Commitment No. 4, provides an acceptable UFSAR

supplement summary description of the applicant's BWR Vessel ID Attachment Welds

Program. The staff determines that the information in the UFSAR supplement is an adequate

summary description of the program, as required by 10 CFR 54.21(d).

3-19
Conclusion. On the basis of the audit and review of the applicant's BWR Vessel ID Attachment

Welds Program, the staff finds all program elements consistent with the GALL Report. The staff

concludes that the applicant has demonstrated that effects of aging will be adequately

managed so that the intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed the

UFSAR supplement for this AMP and concludes that it provides an adequate summary

description of the program, as required by 10 CFR 54.21(d) and therefore, is acceptable.

3.0.3.1.4 BWR Feedwater Nozzle Program

Summary of Technical Information in the Application. In LRA Section B.2.5, the applicant

described the BWR Feedwater Nozzle Program as an existing program that is consistent with

GALL Report AMP XI.M5, "BWR Feedwater Nozzle." The applicant stated that this program

includes enhanced ISI pursuant to ASME Code Section XI, Subsection IWB, Table IWB 2500-1

and the recommendations of report GE-NE-523-A71-0594; and system modifications to

mitigate cracking.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff also confirmed that the plant program contains all of the elements of

the referenced GALL Report. The staff conducted onsite interviews with the applicant to confirm

these results.

In the "acceptance criteria" program element of the program basis document, the applicant

stated that it may use acceptance criteria in staff-approved BWRVIP guideline documents as an

alternative to the acceptance criteria for the FW nozzles required by the ASME Code

Section XI, Subsection IWB. This is a similar statement to the one provided by the applicant in

LRA B.2.1, "lnservic.e Inspection Program."

In RAI B.2.1-2, dated June 12, 2008, the staff requested that the applicant clarify whether

proposals to use alternative BWRVIP guideline criteria in lieu of ASME Code Section XI

requirements would be submitted for relief.

In its response to RAI B.2.1-2, dated July 14, 2008, the applicant stated that all proposals to

use staff-approved BWRVIP guideline criteria in lieu of applicable ASME Code Section XI

requirements will be submitted for staff approval as part of each 10-year ISI plan, pursuant to

10 CFR 50.55a. The staff noted that the applicant clarified that the use of the ASME Code

Section Xl, 1998 Edition, inclusive of the 2000 Addenda, is consistent with the program

description statement in GALL AMP XI.M1 because the SOC on 10 CFR Part 54 clarifies that

acceptable editions of the ASME Code Section XI are those acceptable endorsed editions of

the ASME Code Section XI up through the most recently endorsed edition of the Code

mentioned in 10 CFR 50.55a. The staff verified that the SOC on 10 CFR Part 54 does include

this clarification, and that based on this clarification, use of the ASME Code Section XI, 1998

Edition, inclusive of the 2000 Addenda, is consistent with the Code edition mentioned in the

program description of GALL AMP XI.M1. Based on this review, the staff finds the applicant's

crediting of the ASME Code Section XI, 1998 Edition, inclusive of the 2000 Addenda (for aging

management) is consistent with the criteria in GALL AMP XI.M1. The staff evaluated the

applicant's response to this RAI in SER Section 3.0.3.2.1.

Based on the review, the staff finds the applicant's BWR Feedwater Nozzle Program consistent

with the program elements of GALL AMP XI.M5 and therefore, is acceptable.

3-20
Operatingj Experience. The staff reviewed the applicant's OE basis document for safety

significant OE relevant to the aging management of FW nozzles. The staff noted that the

applicant had conducted pre-service examinations of the six Unit 1 FW nozzles and inner radii

and found no indications of cracking. Subsequent inspections of the Units 1 and 2 FW nozzles

resulted in no recordable indications of cracking. The staff noted that the program basis

document provided OE events resulting from augmented examinations that were performed on

the FW nozzles during the last refueling and inspection outage for Unit 1. Specifically, the staff

noted that the applicant's augmented ultrasonic testing (UT) examinations of Unit 1 FW nozzle

N4A indicated the presence of eight recordable flaw indications that were dispositioned as

acceptable for further service, pursuant to ASME Code Section XI, IWB-3000. However, the

applicant did not cite these flaw indications as relevant OE for this AMP.

In RAI B.2.5-1, dated June 12, 2008, the staff requested that the applicant amend the "operating experience" program element for LRA Section B.2.5 to identify cracking of the Unit 1

N4A FW nozzle as relevant OE for the AMP and to explain in detail which augmented UT

reinspection frequency the applicant will use in the future for the Unit 1 FW nozzle N4A.

In its response to RAI B.2.5-1, dated July 14, 2008, the applicant amended the "operating

experience" program element to state that subsequent inspections of the Units 1 and 2 FW

nozzles have resulted only in one recordable indication, and consistent with industry OE and

corresponding staff-approved recommendations, the inspection frequency for the FW nozzles is

once per 10-year interval. The applicant also provided the following OE:

During the fourteenth Unit 1 refueling outage in March 2006, all critical regions of

the six Unit 1 feedwater nozzles were ultrasonically (UT) inspected as part of the

ISI Program. No recordable indications were detected in five of the six nozzles.

The UT results for Nozzle N4A indicated one recordable flaw and seven other

indications that were too small to characterize as flaws. The one recordable flaw

was evaluated against the criteria in ASME Section XI Table IWB 3510-1. It was

determined to be acceptable for continued service, since the flaw size was less

than half of that allowed by IWB-3510. This flaw indication did not represent a

noticeable change from the previous inspection results. Since the flaw indication

is within the acceptance criterion established in ASME Section XI, no change in

the inspection frequency for the N4A or any other feedwater nozzle at SSES is

required by the ISI Program or ASME Section Xl.

During the thirteenth Unit 2 refueling outage in March 2007, all critical regions of

the six Unit 2 feedwater nozzles were ultrasonically (UT) inspected as part of the

ISI Program. No recordable indications were detected in any of the six nozzles.

Based on its review, the staff finds the applicant's response to RAI B.2.5-1 acceptable because

the applicant has identified the flaw indications on the FW nozzle as part of its OE input,

provided the inspection frequency, and provided the results of further inspections of the Unit 1

and 2 FW nozzles, which showed no recordable indications of cracking. Therefore, the staff's

concern described in RAI B.2.5-1 is resolved.

The staff confirms that the OE program element satisfies the criterion defined in the GALL

Report and the guidance found in SRP LR Section A. 1.2.3.10. Therefore, the staff finds this

program element acceptable.

3-21
UFSAR Supplement. The applicant provided the UFSAR supplement for its BWR Feedwater

Nozzle Program in LRA Section A.1.2.6, Commitment No. 5. The staff reviewed this section and

finds it acceptable because it is consistent with the corresponding program description in

SRP-LR Table 3.1-2. The staff also confirms that the applicant has committed to ongoing

implementation of its BWR Feedwater Nozzle Program for aging management of those inscope components for which the AMP is credited. Further, the staff confirms that the applicant

has linked this commitment to UFSAR Supplement Section A. 1.2.6 for the BWR Feedwater

Nozzle Program.

The staff notes that the description for the applicant's BWR Feedwater Nozzle Program states

that the UT methodology for the augmented inspections of the FW nozzles will be implemented

in accordance with the recommendations of BWR Owners Group Topical Report No. GENE523-71-0594. In contrast, the UFSAR supplement summary description for this AMP indicates

that the augmented UT inspections of the nozzles will be implemented in accordance with the

recommendations in applicable BWRVIP guidelines.

In RAI B.2.5-2, dated June 12, 2008, the staff requested that the applicant clarify which UT

methodology would be used in the BWR Feedwater Nozzle Program.

In its response to RAI B.2.5-2, dated July 14, 2008, the applicant stated that the BWR

Feedwater Nozzle Program is a part of the ISI Program. The applicant further stated that the ISI

requirements for the FW nozzles comply with ASME Code Section XI, Subsection IWB,

Table 2500-1, and staff-approved BWR Owners Group Topical Report, GENE-523-A71-0594,

Revision 1, which provides guidance for inspecting the FW nozzle bore region using UT

methodologies. The applicant also stated that this is consistent with GALL AMP XI.M5 and that

its BWR Feedwater Nozzle Program is committed to following the GENE-523-A71-0594,

Revision 1 guidelines, during the period of extended operation. The applicant amended the LRA

to delete the references to BWRVIP guidelines from the LRA Section B.2.5 program description

and from LRA Section A. 1.2.6.

Based on its review, the staff finds the applicant's response to RAI B.2.5-2 acceptable because

the applicant has sufficiently clarified that its ISI Program includes the BWR FW nozzles, and

the applicant has committed to following the staff-approved GENE-523-A71-0594, Rev. 1

guidelines during the period of extended operation, which makes the program consistent with

GALL AMP XI.M5. Therefore, the staff's concern described in RAI B.2.5-2 is resolved.

Based on this review, the staff finds that UFSAR Supplement Section A. 1.2.6, as amended, and

coupled to LRA Commitment No. 5, provides an acceptable UFSAR supplement summary

description of the applicant's BWR Feedwater Nozzle Program because it is consistent with the

UFSAR supplement summary guidance for BWR Feedwater Nozzle Programs in the SRP-LR.

The staff determines that the information in the UFSAR supplement is an adequate summary

description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of the review of the applicant's BWR Feedwater Nozzle Program and

the applicant's response to the staff's RAls, the staff finds all program elements consistent with

the GALL Report. The staff concludes that the applicant has demonstrated that effects of aging

will be adequately managed so that the intended function(s) will be maintained consistent with

the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff also

reviewed the UFSAR supplement for this AMP and concludes that, as amended, it provides an

3-22
adequate summary description of the program, as required by 10 CFR 54.21(d) and therefore,

is acceptable.

3.0.3.1.5 BWR Stress Corrosion Cracking Program

Summary of Technical Information in the Application. In LRA Section B.2.7, the applicant

described the BWR Stress Corrosion Cracking (SCC) Program as an existing program that is

consistent with GALL AMP XI.M7, "BWR Stress Corrosion Cracking." The applicant stated that

the program includes preventive measures to mitigate intergranular stress corrosion cracking

(IGSCC) and inspection and flaw evaluation to monitor IGSCC and its effects. The applicant

also stated that the staff-approved BWRVIP-75 report allows for modifications of inspection

scope in the Generic Letter (GL) 88-01 program.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff also confirmed that the plant program contains all of the elements of

the referenced GALL Report. The staff conducted onsite interviews with the applicant to confirm

these results.

In comparing the elements in the applicant's program to those in GALL AMP XI.M7, the staff

noted that the program elements in the applicant's AMP claim of consistency with the GALL

Report were consistent with the corresponding program element criteria recommended in GALL

AMP XI.M7, with the exception of two program element aspects identified below that the staff

determined required additional clarification.

The staff noted in the program basis document that applicant's "preventive actions" program

element for the BWR SCC Program indicated that two welds scheduled for stress relief had not

received a post-weld heat treatment consistent with GL 88-01 and NUREG-0313

recommendations and were unacceptable for stress relief credit by the staff. The staff also

noted that the applicant identified that the plant had initiated HWC control as a basis for

reducing the electro-chemical potentials of the Class 1 stainless steel welds below the potential

associated with the onset of SCC.

In RAI B.2.7-1, dated June 12, 2008, the staff requested that the applicant discuss whether

there is any established link between the findings identified in the staff's SE on the applicant's

response to GL 88-01 and the circumferential SCC induced flaw indications detected in the

Unit 1 N2J recirculation outlet nozzle safe-end weld and in the Unit 1 N1 B recirculation inlet

nozzle safe end weld. Specifically, the staff requested that the applicant identify whether these

safe-end nozzle welds were among the Class 1 stainless steel piping welds scheduled for

induction heat stress relief treatments and whether the N1 B and N2J nozzle safe-end welds

were the same welds that had not received the recommended post-weld heat treatments as

part of this stress relief process. The staff further requested that the applicant ýidentify the dates

for initiation of HWC at Units 1 and 2.

In its response to RAI B.2.7-1, dated July 14, 2008, the applicant stated:

The discussion in the license renewal basis document for the "preventive

actions" program element for the BWR Stress Corrosion Cracking Program

incorrectly stated that there are "two SI-treated welds that were not given postweld heat treatment." The correct statement is that there are "two SI-treated

welds that were not completely ultrasonically examined post-Sl."

3-23
The two welds in question are identified in the PPL letter to the NRC, PLA-3263,

dated October 2, 1989, as DCA1081-FW-5 and DCA1 102-FW-6. These welds

are piping welds on the Unit 1 Residual Heat Removal System, not the SSES

Unit 1 N1B and N2J recirculation nozzle-safe end welds. And, these piping welds

did, in fact, have the Induction Heating Stress Improvement Process (IHSI)

performed within two years of commercial operation, consistent with the NRC

Generic Letter (GL) 88-01/NUREG-0313 recommendations. However, the postIHSI ultrasonic examination (UT) of the welds could not be performed, as

required by NUREG-0313, due to the weld configuration. In PLA-3263, PPL

classified these two welds as IGSCC Category G and committed to inspect the

welds during the next refueling outage. In the NRC's SE on the SSES response

to GL 88-01, it was the classification of these two welds as IGSCC Category G

that the NRC found to be unacceptable. Subsequently, PPL inspected these

welds during the Unit 1 [fifth] refueling outage in 1990, and the welds are now

classified as IGSCC Category B. The Unit 1 N1B and N2J nozzle-safe end welds

did not have IHSI within two years of commercial operation. As these are

dissimilar metal welds, IHSI is not an appropriate stress improvement method.

Instead, these welds had the Mechanical Stress Improvement Process (MSIP)

applied after approximately ten years of commercial operation. There is no link

between the findings identified in the NRC's SE on the PPL response to GL 88-

01 and the flaw indications detected in the Unit 1 N1B and N2J recirculation

nozzle safe-end welds.

The staff reviewed the applicant's response and determines that the two welds in question were

on the RHR system and that those welds did receive the post-weld heat treatment. The staff

further determines that the applicant's recirculation nozzle safe-end welds also received the

post-weld heat treatment.

Based on its review, the staff finds the applicant's response to RAI B.2.7-1 acceptable because

the applicant has adequately clarified that the welds in question have been post-weld heat

treated, consistent with the GL 88-01 and NUREG-0313 recommendations, and have been

appropriately classified and inspected. Therefore, the staff's concerns described in RAI B.2.7-1

are resolved.

The staff noted that staff-approved guidelines in BWRVIP Topical Report BWRVIP-75A provide

the latest recommendations for augmented SCC ISIs. However, the staff noted that the

applicant had only credited the BWRVIP-75A criteria for expansion of the sample size upon

detection of a relevant SCC-induced flaw indication and that the applicant continued to use the

recommended augmented ISI criteria in GL 88-01 and NUREG-0313 to perform the augmented

ISI examinations (i.e., augmented UT examinations) of these stainless steel Class 1 pipe welds.

In RAI B.2.7-2, dated June 12, 2008, the staff requested that the applicant clarify whether the

updated staff-approved guidelines in Topical Report BWRVIP-75A would be used as an option

for performing other aspects of the augmented ISI Program for these ASME Code Class 1

stainless steel pipe welds; and whether the flaw acceptance criteria in staff-approved Topical

Report BWRVIP-75A or Topical Report BWRVIP-14 will be used for the acceptance criteria of

any crack indications that might be detected in these ASME Code Class I stainless steel pipe

welds.

3-24
In its response to RAI B.2.7-2, dated July 14, 2008, the applicant stated that it does not use

BWRVIP-75-A for flaw acceptance criteria, since the report contains no flaw acceptance criteria

guidance. The applicant further stated that:

... flaw evaluation and acceptance criteria are in accordance with the ASME

Code, Section XI, IWB-3640, as specified in NUREG-0313, Revision 2. PPL is

committed to follow all requirements of NUREG-0313, Revision 2, except for the

inspection criteria and schedule. The NRC-approved BWRVIP-14 addresses

crack growth evaluation of flawed BWR shroud welds and other stainless steel

internals. As part of the ASME Code flaw evaluation, a crack growth analysis is

required. While PPL may use certain data and evaluation methods from

BWRVIP-14 in a crack growth analysis, the evaluation and acceptance criteria

will be in accordance with the ASME Code, Section XI, IWB-3640.

The staff reviewed, BWRVIP-75-A, which provides the criteria and inspection schedule for

different categories of welds. Because BWRVIP-75-A does not contain flaw acceptance criteria,

the staff finds it acceptable to use ASME Code, Section Xl, IWB-3640 for flaw evaluation and

acceptance criteria, which includes the requirement of crack growth analysis because the

components within the scope of this AMP are ASME Code Class 1 components. The ASME

Code Section XI provides the necessary information to perform the crack growth analysis,

which could be further supplemented by certain data and evaluation methods from BWRVIP-1 4.

Based on its review, the staff finds the applicant's response to RAI B.2.7-2 acceptable because

the applicant has adequately explained why its does not use the BWRVIP-75-A as a basis for

flaw acceptance, but, rather, ASME Code, Section XI, IWB-3640. Therefore, the staff's concern

described in RAI B.2.7-2 is resolved.

Based on its review, the staff finds the applicant's BWR Stress Corrosion Cracking Program

consistent with the program elements of GALL AMP XI.M7 and therefore, is acceptable.

Operating Experience. The staff reviewed the applicant's OE described in the license renewal

basis document for the BWR Stress Corrosion Cracking Program. The staff confirmed that the

applicant appropriately identified the circumferential crack indications in the Unit 1 N2J

recirculation nozzle outlet safe-end weld and the Unit 1 N1 B recirculation inlet nozzle safe-end

weld as relevant OE for this AMP. The staff also confirmed that the applicant implemented the

inspections of these stainless steel welds through an augmentation of its ISI Program and that

the applicant provided the condition reports (CRs) on these events in the license renewal basis

binder for the AMP.

The staff noted that the applicant also listed a CR on flaw indications in 12 small-bore Class 1

piping components as relevant OE for this AMP. The staff reviewed these CRs as part of its

onsite review of the AMP. The staff determined that the CRs demonstrated that the detection of

these flaw indications were the result of the non-destructive test examinations implemented

through an augmentation of the applicant's ISI Program, and that the CRs indicated that the

applicant had performed appropriate Code repairs of the flaw indications in the small bore

nozzle welds. Based on this review, the staff found that the applicant had taken appropriate

actions to address these small bore Class 1 pipe flaw indications.

Based on this review, the staff finds that: (1) the listing of relevant OE for this

AMP demonstrates that the applicant's BWR Stress Corrosion Cracking Program, as

implemented through an augmentation of the applicant's ISI Program, achieves its objective of

3-25
detecting relevant flaw indications (cracks) that may be induced by SCC, and (2) the applicant

is taking appropriate corrective actions for recordable flaw indications detected through

implementation of this program.

The staff confirms that the OE program element satisfies the criterion defined in the GALL

Report and the guidance found in SRP LR Section A. 1.2.3.10. Therefore, the staff finds this

program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement for the BWR Stress

Corrosion Cracking Program in LRA Section A.1.2.8, Commitment No. 7. The staff reviewed

this section and finds it acceptable because it is consistent with the corresponding program

description in SRP-LR Table 3.1-2. The staff also confirms that the applicant has committed

(Commitment No. 7) in UFSAR Supplement Table A-1, to ongoing implementation of its BWR

Stress Corrosion Cracking Program for aging management of those in-scope components for

which the AMP is credited.

Based on this review, the staff finds that the UFSAR supplement summary description, when

coupled with Commitment No. 7, provides an acceptable description of the applicant's BWR

Stress Corrosion Cracking Program because it is consistent with UFSAR supplement summary

description for Stress Corrosion Cracking Programs found in the SRP-LR.

The staff determines that the information in the UFSAR supplement is an adequate summary

description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review of the applicant's BWR Stress Corrosion Cracking

Program and its responses to the staff's RAIs; the staff finds all program elements consistent

with the GALL Report. The staff concludes that the applicant has demonstrated that effects of

aging will be adequately managed so that the intended function(s) will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff

also reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d) and therefore, is

acceptable.

3.0.3.1.6 Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS)

Program

Summary of Technical Information in the Application. In LRA Section B.2. 10, the applicant

described the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless

Steel (CASS) Program as a new program that will be consistent with the program elements in

GALL AMP XI.M13, "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic

Stainless Steel." The applicant stated that the program is credited to manage loss of fracture

toughness in RV internal components that are fabricated from CASS.

Staff Evaluation. During the audit, the staff reviewed the applicant's claim of consistency with

the GALL Report. The staff also confirmed that the plant program contains all of the elements

of the referenced GALL Report. The staff conducted onsite interviews with the applicant to

confirm these results.

In comparing the elements in the applicant's program to those in GALL AMP XI.M13, the staff

noted that the program elements in the applicant's AMP claim of consistency with the GALL

Report were consistent with the corresponding program element criteria recommended in GALL

3-26
AMP XI.M1 3, with the exception of five program elements aspects identified below that the staff

determined required additional clarification.

The "scope of program" program element for the Thermal Aging and Neutron Irradiation

Embrittlement of Cast Austenitic Stainless Steel Program, states that the CASS RV internal

components will be screened for their susceptibility to loss of fracture toughness by thermal

aging embrittlement and neutron irradiation embrittlement. However, the program element does

not establish which staff-approved guideline(s) or basis document(s) will be used to screen the

CASS RV internal components for susceptibility to these aging phenomena. Furthermore, the.

staff noted an inconsistency between the applicant's "scope of program" and the "parameters

monitored/inspected" program element descriptions in the license renewal basis document for

the AMP. The staff noted that the applicant did not identify and distinguish between the specific

parameter criteria used to screen the CASS RV internal components for reduction of fracture

toughness by thermal aging embrittlement and by neutron irradiation embrittlement.

In RAI B.2.10-1, dated June 12, 2008, the staff requested (part A) that the applicant clarify

which staff-approved guidance or basis document it will use for susceptibility screening for loss

of fracture toughness by thermal aging embrittlement and neutron irradiation embrittlement.

The staff also requested (part B) that the applicant explain the discrepancy between the "scope

of program" and the "parameters monitored/inspected" program elements for specific

parameters used for susceptibility screening.

In its response to RAI B.2.10-1, part A, dated July 14, 2008, the applicant amended the LRA

and revised the "scope of program" element to delete the specific parameters identified and

instead added the staff-approved guideline that will be used for screening. The following

statement was added to LRA Section B.2.10:

Screening for thermal aging will be based on casting method, molybdenum

content, and ferrite content, in accordance with the criteria found in the

May 19, 2000, letter from Christopher Grimes (NRC) to D. J. Walters (NEI),

"Thermal Aging Embrittlement of Cast Austenitic Steel Components," and in

EPRI Technical Report 100976, "Evaluation of Thermal Aging Embrittlement for

Cast Austenitic Steel Components," January 2001. Screening for neutron

embrittlement will use the fluence threshold of IE+17 n/cm 2 (E>lMev).

Similarly, in response to RAI B.2.10-1 part B, the applicant deleted the specific parameters from

the "parameters monitored/inspected" element and instead added the following statement to

LRA Section B.2.10:

Those components screened as susceptible to Reduction of Fracture Toughness

(either due to thermal aging or neutron embrittlement) will require inspection

unless it is determined by component-specific evaluations that inspection is not

required. The component specific evaluation will include a mechanical loading

assessment to determine the maximum tensile loading on the component. If the

loading is low enough to preclude fracture, then supplemental inspection of the

component is not required.

Based on its review, the staff finds the applicant's response to RAI B.2.10-1 acceptable

because the applicant has correctly identified the staff-approved document it will use for

susceptibility screening, and has amended the "parameters monitored/inspected" program

element in the LRA that identifies how susceptible components will be inspected. The staff

3-27
determines that this action provides assurance that the applicant's program is consistent with

GALL AMP XI.M13. Therefore, the staff's concern described in RAI B.2.10-1 is resolved.

The staff noted in the program basis document that the "detection of aging effects" program

element indicates that the applicant may use UT as one of the inspection techniques to detect

cracking in these CASS components. However, the current state-of-the-art UT inspection

methods have not yet been qualified as being capable of detecting cracks in CASS materials.

In RAI B.2.10-2, dated June 12, 2008, the staff requested (part A) that the applicant clarify

whether the state-of-the-art UT techniques are capable of detecting cracks in CASS materials,

and; if not, verify the alternate inspection technique or method that will be implemented to

monitor for cracking, if condition monitoring was chosen as the process for aging management

of fracture toughness. The staff also requested (part B) that the applicant justify the basis for

the "detection of aging effects" or "monitoring or trending" program elements for the AMP not

crediting a supplemental flaw tolerance analysis as an alternative for managing reduction of

fracture toughness in these CASS RV internal components.

In its response to RAI B.2.10-2, part A, dated July 14, 2008, the applicant acknowledged that it

was not aware of any staff-approved UT techniques for detecting cracking in CASS

components. The applicant stated that the statements made in the LRA were intended to

preserve the option to include new examination techniques, such as UT, only if they are

developed and approved in the future. The applicant further stated that at present, the

enhanced visual examination (EVT-1) is the only staff-approved inspection technique, as

recommended by GALL AMP XI.M13. The staff confirms that the applicant has revised the

"detection of aging effects" program element to delete the phrase "including visual, ultrasonic,

and surface techniques," and replaced it with "enhanced visual."

In response to part B, the applicant stated that it did not credit a supplemental flaw tolerance

evaluation because the CASS RV internals covered by this program are not reactor coolant

pressure boundary (RCPB) components; consequently, a classic critical flaw size analysis is not

directly applicable. Once the susceptible components are identified, the applicant may perform

a component-specific evaluation as discussed in the "detection of aging effects" program

element in GALL AMP XI.M13. The staff confirms that the applicant has amended the LRA to

include a statement in the "detection of aging effects" program element that for those

components screened as susceptible to reduction of fracture toughness that a componentspecific evaluation may be performed to determine whether supplemental inspection of the

component is required, as discussed under the "parameters monitored or inspected" program

element.

Based on its review, the staff finds the applicant's response to RAI B.2.10-2 acceptable

because the applicant has adequately justified an alternate basis for managing the aging

effects by performing component-specific evaluation supplemental evaluation when required.

Additionally, the staff finds the applicant's response acceptable because the applicant has

confirmed that it will perform enhanced visual technique examinations, by qualified personnel,

consistent with the recommendations provided in the GALL Report, following procedures

pursuant to ASME Code Section XI and 10 CFR Part 50, Appendix B. The staff determines that

the applicant will employ these alternate methods, if, based on screening, the material is

deemed susceptible and the aging effect is managed by inspection of the component.

Therefore, the staff's concerns described in RAI B.2.10-2 are resolved.

3-28
The staff noted that the BWRVIP in the "scope of program" program element states (in part)

that the program is credited for limited management of loss of material and reduction of fracture

toughness in the RV internal components at SSES.

In RAI B.2.10-3, dated June 12, 2008, the staff requested that the applicant clarify whether it is

crediting the BWRVIP as a option for managing reduction of fracture toughness in CASS RV

internal components and; if so, identify the BWRVIP as an exception to the CASS Program,

identify the staff-approved BWRVIP-based guideline reports that will be credited and used, and

revise the UFSAR supplement, accordingly.

In its response to RAI 8.2.10-3, dated July 14, 2008, the applicant clarified that as shown in

LRA Table 3.1.2-2, the BWRVIP is credited for managing reduction of fracture toughness for

components made of either stainless steel (non-cast) or nickel-based alloy. The applicant also

stated that the BWRVIP is not credited for managing reduction of fracture toughness for any

CASS RV internal components. The applicant further stated that as shown in LRA Table 3.1.2-

2, the Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel (CASS)

Program is credited for managing reduction of fracture toughness for all CASS RV internals and

therefore, there is no exception to GALL AMP XI.M13.

The staff reviewed LRA Table 3.1.2-2 for CASS components and noted that applicant has

credited the Thermal Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel

(CASS) Program to manage the aging effect of reduction of fracture toughness for all CASS RV

internal components. The staff also confirmed that the non-CASS internal components are

managed by the BWRVIP.

Based on its review, the staff finds the applicant's response to RAI B.2.10-3 acceptable

because the applicant has adequately clarified that the BWRVIP is credited for managing

reduction of fracture toughness for components made of either stainless steel (non-cast) or

nickel-based alloy, only. Therefore, the staff's concern described in RAI B.2.10-3 is resolved.

Based on its review, the staff finds the applicant's Thermal Aging and Neutron Irradiation

Embrittlement of Cast Austenitic Stainless Steel Program consistent with the program elements

of GALL AMP XI.M13 and therefore, is acceptable.

Operatinq Experience. The staff reviewed the applicant's OE described in the license renewal

basis document for the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic

Stainless Steel Program. The applicant has identified the Thermal Aging and Neutron

Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program as a new program

for Units 1 and 2, and did not report any OE events on reduction of fracture toughness in CASS

RV internal components as being relevant to the "operating experience" program element for

the AMP. However, for this program, and for other new AMPs where the applicant provided no

current plant-specific OE, the staff issued a generic RAI.

In RAI B.2-1, dated June 10, 2008, the staff requested that the applicant commit to provide

documentation of plant-specific OE for staff review after the program has been implemented,

but, prior to entering the period of extended operation.

In its response to RAI B.2.1, dated July 8, 2008, the applicant stated that OE will be gained for

new AMPs described in LRA Appendix B as these programs are implemented during the period

of extended operation. The applicant stated that results of tests, inspections, and other aging

management activities conducted in accordance with these programs will be subject to

3-29
confirmation and corrective action elements of the Susquehanna 10 CFR Part 50, Appendix B,

Quality Assurance Program. Results will be subject to staff review during regional inspections,

under existing staff inspection modules. Test and inspection results that do not meet

acceptance criteria will be evaluated under the Units 1 and 2 Corrective Action Program, which

includes requirements to identify appropriate corrective actions and verify the effectiveness of

those actions. Items entered into the SSES Corrective Action Program are available for review

by the NRC Resident Inspector.

The staff noted the applicant's statement that inspection methods will be consistent with

industry practices and are consistent with the "operating experience" program element for GALL

AMP XI.M13. The staff also noted that regional staff site-inspections provide an opportunity for

staff review and assessment of the effectiveness of the applicant's Thermal Aging and Neutron

Irradiation Embrittlement of Cast Austenitic Stainless Steel Program, after the applicant has

developed OE with that program. The staff concludes that the corrective action program, based

on internal and external plant OE, will capture OE to support the conclusion that the effects of

aging are adequately managed. On this basis, the staff finds this program element acceptable

and concludes that a separate commitment is not necessary.

The staff confirms that the OE program element satisfies the criterion defined in the GALL

Report and the guidance found in SRP-LR Section A.1.2.3.10. Therefore, the staff finds this

program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement summary for the Thermal

Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel Program in LRA

Section A.1.2.48 and Commitment No. 10 in Table A-I. The staff reviewed this section and

finds it acceptable because it is consistent with the corresponding program description in

SRP-LR Table 3.1-2. The staff also confirms that the applicant has committed to implement the

new Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel

Program prior to entering the period of extended operation.

Based on this review, the staff finds that UFSAR Supplement Section A. 1.2.48, when coupled

with Commitment No. 10, provides an acceptable UFSAR supplement summary description of

the applicant's Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic

Stainless Steel Program because it is consistent with the guidance in the SRP-LR for Thermal

Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel Programs.

The staff determines that the information in the UFSAR supplement is an adequate summary

description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review of the applicant's Thermal Aging and Neutron Irradiation

Embrittlement of Cast Austenitic Stainless Steel Program and the applicant's response to the

staff's RAIs, the staff finds all program elements consistent with the GALL Report. The staff

concludes that the applicant has demonstrated that effects of aging will be adequately

managed so that the intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the

UFSAR supplement for this AMP and concludes that it provides an adequate summary

description of the program, as required by 10 CFR 54.21(d) and, therefore, is acceptable.

3-30
3.0.3.1.7 Flow-Accelerated Corrosion Program

Summary of Technical Information in the Application. In LRA Section B.2. 11, the applicant

described the Flow-Accelerated Corrosion (FAC) Program as an existing program that is

consistent with the GALL Report AMP XI.M17, "Flow-Accelerated Corrosion." The applicant

stated that this program follows the guidance and recommendations of EPRI Nuclear Safety

Analysis Center (NSAC)-202L and combines the elements of predictive analysis, inspections (to

baseline and monitor wall thinning), industry experience, station information gathering and

communication, and engineering judgment to monitor and predict FAC wear rates.

Staff Evaluation. During its audit the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff also confirmed that the plant program contains all of the elements of

the referenced GALL Report. The staff conducted onsite interviews with the applicant to confirm

these results.

The staff reviewed the applicant's license renewal basis document and confirmed that the

program scope includes the systems and components that could be affected by FAC. In

comparing the elements in the applicant's program to those in GALL AMP XI.M17, the staff

noted that the program elements in the applicant's AMP claiming consistency with the GALL

Report were consistent with the corresponding program element criteria recommended in GALL

AMP XI.M1 7, with the exception of two program element aspects identified below that the staff

determined required additional clarification.

In the "scope of program" program element, the applicant identified the systems and

components within the scope of this program. However, the staff noted that the carbon steel

condensers (shell) from LRA Table 3.4.2-4, the condenser and air removal system; the carbon

steel turbine casings from LRA Table 3.4.2-7, and the main turbine system were not included in

the program element, "scope of the program." The staff further noted that the FAC Program is

credited to manage the aging effect for both of these components in LRA Table 3.4.2-4 and

3.4.2-7.

In RAI B.2. 11-1, dated May 30, 2008, the staff requested that the applicant confirm that these

components are included in the scope of the existing FAC Program and; if not, justify why LRA

Section B.2.11 is not enhanced to include these components.

In its response to RAI B.2.1 1-1, dated June 30, 2008, the applicant stated that the condenser

and air removal system and the main turbine system are included in the scope of license

renewal because they are non-related safety systems impacting safety-related systems. The

condenser shell was credited as the anchor for the safety-related piping and provided a

structural integrity function. However, the applicant stated that another anchor has been

identified for this pipe line before it reaches the condenser. The staff determined that with the

elimination of the structural integrity function, there are no aging effects that require

management for the condenser shell, and the FAC Program need not be credited. Therefore,

the applicant revised LRA Tables 2.3.4-4, 3.4.1, and 3.4.2-4 to remove the condenser shell

from the scope of license renewal.

The applicant stated the main turbine continues to be credited for structural integrity. However,

since the main turbine is not within the scope of the current FAC Program, the applicant

proposes to use a plant-specific program to manage loss of material due to FAC for the HP

turbine. The "Preventive Maintenance Activities - Main Turbine Casing Program" is an existing

3-31
plant-specific program proposed by the applicant. The staff's evaluation of this program is

documented in SER Section 3.0.3.3.4.

The staff reviewed the applicant's response and concludes that because the applicant proposes

a plant-specific program to manage the aging effect of loss of material due to FAC, the staff

finds it acceptable that the applicant does not include the main turbine casing in the scope of

the FAC Program.

Based on its review, the staff finds the applicant's response to RAI B.2.1 1-1 acceptable

because the applicant has verified and the staff confirms that the condenser shell is no longer

used for structural integrity to support a safety-related system and as a result, need not be

within the scope of license renewal. The staff also confirms that the applicant has revised the

appropriate LRA tables to remove the condenser shell from the scope of license renewal.

Therefore, the staff's concern described in RAI B.2.1 1-1 is resolved.

In the "monitoring and trending" program element, it was not clear to the staff what criterion the

applicant used to increase sample size. GALL AMP XI.M17 states that inspection results are

evaluated to determine whether additional inspections are needed to assure that the extent of

wall thinning is adequately determined.

In RAI B.2.11-2, dated May 30, 2008, the staff requested that the applicant explain how it

expands sample size and what acceptance criterion is used for sample expansion.

In its response to RAI B.2.11-2, dated June 30, 2008, the applicant stated that the FAC

Program procedure requires an inspection sample expansion "if the remaining life of an

inspected component cannot be calculated to be at least one operating cycle." The applicant

further stated that the remaining life calculation is based on the measured component wall

thickness and the calculated wear rate. The applicant also stated that this procedure provides

additional guidance when the remaining life is adequate for another operating cycle, but

inspection results are other than what was expected. The applicant indicated that expanded

sample inspections are specified to capture locations with the highest probability of significant

wear. The applicant noted that this guidance is consistent with EPRI NSAC-202L, and requires

an updated FAC analysis and additional inspections, as appropriate, if inspection results are

unexpected and inconsistent with predictions.

Based on its review, the staff finds the applicant's response to RAI B.2.11-2 acceptable

because the applicant has adequately explained how it expands sample size and what

acceptance criterion is used for sample expansion.

The staff concludes that because this guidance ensures that if unexpected results occur, a

review of the systems is performed, and sample expansion is considered to capture the

locations with the highest probability of significant wear. Therefore, the staff's concern

described in RAI B.2.11-2 is resolved.

Based on its review, the staff finds the applicant's FAC Program consistent with the program

elements of GALL AMP XI.M17 and therefore is acceptable.

Operating Experience. The staff reviewed the applicant's OE described in LRA Section B.2.11

and interviewed the applicant's technical personnel to confirm that the plant-specific OE did not

reveal any aging effects not bounded by the GALL Report. The staff also confirmed that

3-32
applicable aging effects and industry and plant-specific OE have been reviewed by the

applicant and are evaluated in the GALL Report.

The staff also reviewed the applicant's "operating experience" discussion provided in the

applicant's license renewal basis document for the FAC Program. The staff reviewed a sample

of condition reports and confirmed that the applicant has identified FAC and implemented

appropriate corrective actions. The staff noted that in the last Unit 1 and Unit 2 outages, over

120 locations in each unit were inspected and eleven additional examinations in each unit were

performed as expanded scope. The applicant identified planned replacements and performed

emergent replacements. The staff reviewed the results of the outages for Units 1 and 2 and

confirmed that appropriate corrective actions were implemented.

Furthermore, the staff confirmed that the applicant has addressed OE identified after the

issuance of the GALL Report. The staff finds that the applicant's FAC Program, with the

corrective actions discussed in the LRA, has been effective in identifying, monitoring, and

correcting the effects of FAC and can be expected to ensure that piping wall thickness will be

maintained above the minimum required by design.

The staff confirms that the OE program element satisfies the criterion described in the GALL

Report and the guidance found in SRP-LR Section A.1.2.3.10. Therefore, the staff finds this

program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement for the FAC Program in

LRA Section A1.2.20 and Commitment No. 11 in Table A-1. The staff reviewed this section and

finds it acceptable because it is consistent with the corresponding program description in

SRP-LR Table 3.4-2. The staff confirms that the applicant has committed to implement the FAC

Program through the period of extended operation.

Based on this review, the staff determines that UFSAR Supplement Section A1.2.20 provides

an acceptable UFSAR supplement summary description of the applicant's FAC Program

because it is consistent with the UFSAR supplement summary description for FAC Program in

the SRP-LR.

The staff determines that the information in the UFSAR supplement is an adequate summary

description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review of the applicant's FAC Program and the applicant's

response to the staff's RAIs, the staff finds all program elements consistent with the GALL

Report. The staff concludes that the applicant has demonstrated that the effects of aging will be

adequately managed so that the intended function(s) will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also

reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d) and therefore is

acceptable.

3.0.3.1.8 Crane Inspection Program

Summary of Technical Information in the Application. In LRA Section B.2.15, the applicant

described the existing Crane Inspection Program as consistent with GALL AMP XI.M23,

"Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems."

The Crane Inspection Program manages the effects of general corrosion on the crane and

3-33
trolley structural components for those cranes that are within the scope of 10 CFR 54.4, and the

effects of wear on the rails in the rail system. The program utilizes guidance found in American

National Standards Institute (ANSI) B30.2 "Overhead and Gantry Cranes (Top Running Bridge,

Single or Multiple Girder, Top Running Trolley Hoist)," ANSI B30.11 "Monorails and Underhung

Cranes," and ANSI B30.16 "Overhead Hoists (Underhung)."

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff confirmed that the plant program contains all of the elements of the

referenced GALL Report. The staff conducted onsite interviews with the applicant to confirm

these results.

In RAI B.2.15-1, dated June 30, 2008, the staff requested that the applicant explain the scope

of its Crane Inspection Program. In comparing the elements in the applicant's program to those

in GALL AMP XI.M23, the staff found that the applicant did not explicitly identify "the effects of

wear on the rails in the rail system" in their basis document for the program element, "scope of

program." It was unclear to the staff whether this item should have been identified as an

exception.

In its response to RAI B.2.15-1, dated July 28, 2008, the applicant stated that although "the

effects of wear on the rails in the rail system" was not explicitly identified in the program basis

documents, it is indeed an aging effect which is managed by the Crane Inspection Program.

The staff confirms that the applicant has revised LRA Section B.2.15 to clarify the intent of the

program to specifically include wear of the crane rails.

Based on its review, the staff finds the applicant's response to RAI B.2.15-1 acceptable

because the applicant has clarified that "the effects of wear on the rails in the rail system" is an

aging effect which is managed by the Crane Inspection Program and has revised the LRA to

clarify the intent of this AMP. Therefore, the staff's concern described in RAI B.2.15-1 is

resolved.

Similarly, the staff found that the applicant did not explicitly identify "wear" in its basis document

for the GALL report program element, "acceptance criteria." It is unclear to the staff whether

this item should have been identified as an exception.

In RAI B.2.15-2, dated June 30, 2008, the staff requested that the applicant further explain the

scope its Crane Inspection Program.

In its response to RAI B.2.15-2, dated July 28, 2008, the applicant stated that although wear of

the crane rails was not explicitly identified in the GALL Report acceptance criteria program

element, it is indeed an aging effect which is managed by the Crane Inspection Program. The

staff confirms that the applicant has also revised LRA Section B.2.15, Crane Inspection

Program to clarify the intent of the program to specifically include wear of the crane rails.

Based on its review, the staff finds the applicant's response to RAI B.2.15-2 acceptable

because the applicant has clarified that "wear" is an aging effect which is managed by the

SSES Crane Inspection Program and has revised the LRA to clarify the intent of this AMP.

Therefore, the staff's concern described in RAI B.2.15-2 is resolved.

On the basis of its onsite review and discussions with the applicant, the staff determined that

the applicant's Crane Inspection Program is implemented through SSES's procedures based on

staff-approved guidance. Inspections to detect degradation are visual in nature, and are

3-34
conducted on a routine basis, which include annual inspections for the reactor building crane

and refueling platform, and bi-annual inspections for the diesel generator bridge cranes. In

addition, the staff noted, through review of station procedures, that some more infrequently

used cranes are inspected either every two years or prior to use.

In comparing the seven program elements in the applicant's program, the staff finds that the

applicant has addressed the elements in a satisfactory manner. Furthermore, the staff finds that

these elements were consistent with GALL AMP XI.M23.

Operating Experience. The staff also reviewed the applicant's OE described in LRA

Section B.2.15. The applicant stated that "Related crane/hoist inspections have found no

age-related degradation problems." Through the review of QE reports, including a sample of

condition reports and interviews of the applicant's technical staff, the staff confirmed that the

plant-specific OE did not reveal any degradation not bounded by industry experience. During an

onsite audit review of plant-specific documentation, the staff found that in 2007, a crack was

detected in a structural load-bearing weld. This incident was not reported in the LRA OE

summary. The staff determined more information was needed to assess the severity of the

incident.

In RAI B.2.15-3, dated June 30, 2008, the staff requested that the applicant provide a detailed

explanation on the 2007 crane incident.

In its response to RAI B.2.15-3, dated July 28, 2008, the applicant stated that follow up

corrective actions were completed in a timely manner to adequately address the issue. These

actions included inspection of the weld, an engineering evaluation, consultation with the crane

vendor's engineer, repair of the weld, load testing, and finally a re-inspection. The applicant

returned the crane to service after it had determined that all tests were satisfactory. The staff

determined that the crack in a structural load-bearing weld is OE already bounded by industry

experience, and was properly addressed by the applicant's AMP.

Based on its review, the staff finds the applicant's response to RAI B.2.15-3 acceptable

because the applicant has provided a satisfactory explanation of the incident involving a crack

detected in a structural load-bearing weld and the corrective actions taken to address the issue.

Therefore, the staff's concern described in RAI B.2.15-3 is resolved.

The staff confirms that the "operating experience" program element satisfies the criterion

defined in the GALL Report and the guidance found in SRP-LR A.1.2.3.10. Therefore, the staff

finds this program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement for the Crane Inspection

Program in LRA section A. 1.2.17 and Commitment No. 14 in TableA-1. The staff reviewed this

section and finds it acceptable because it is consistent with the corresponding program

description in SRP-LR Table 3.3-2.

The staff determines that the information in the UFSAR supplement is an adequate summary

description of the program, as required by 10 CFR 54.21(d).

The staff confirmed that the applicant has committed to the ongoing implementation of the

Crane Inspection Program for aging management of those in-scope components for which the

AMP is credited. The staff also confirmed that the applicant has placed this commitment for the

Crane Inspection Program in UFSAR Supplement Summary Section A. 1.2.17.

3-35
Conclusion. On the basis of its review of the applicant's Crane Inspection Aging Management

Program, as well as the applicant's RAI responses, the staff finds all program elements

consistent with the GALL Report. The staff concludes that the applicant has demonstrated that

effects of aging on crane and trolley structural components for those cranes within the scope of

10 CFR 54.4, and the effects of wear on the rails in the rail system will be adequately managed

so that the intended functions of these components 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 UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d) and therefore is

acceptable.

3.0.3.1.9 Condensate and Refueling Water Storage Tanks Inspection Program

Summary of Technical Information in the Application. In LRA B.2.19, the applicant described

the Condensate and Refueling Water Storage Inspections Program as a new one-time

inspection that, in conjunction with the Systems Walkdown Program, will be consistent with the

GALL AMP XI.M29, "Aboveground Steel Tanks."

The applicant stated that this program, in conjunction with the Systems Walkdown Program,

includes the inspection of the condensate storage tank (CST) and refueling water storage tank

(RWST) inaccessible surfaces (i.e. tank bottoms) and accessible external surfaces.

Furthermore, the applicant stated that this program includes volumetric and/or visual

inspections that will be used to provide an indication of loss of material due to crevice, general

or pitting corrosion that has occurred or may likely occur.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff reviewed the applicant's AMP evaluation for the Condensate and

Refueling Water Storage Tanks Inspection Program, together with the applicant's program

basis documents. The applicant claims that the Condensate and Refueling Water Storage

Tanks Inspection Program, in conjunction with the Systems Walkdown Program, will be

consistent with GALL AMP XI.M29.

In comparing the seven program elements in the applicant's program to those in

GALL AMP XI.M29, the staff noted that the applicant claimed that the program elements in the

applicant's AMP were consistent with the GALL Report. However the staff required additional

information to complete its review of two program elements; "scope of program" and

"acceptance criteria."

The staff further noted that, based on GALL AMP XI.M29, paints, coatings, sealants and

caulking are to be monitored for degradation. In the Condensate and Refueling Water Storage

Tanks Inspection Program, the applicant stated that these materials will be monitored under the

Systems Walkdown Program. Upon review of the Systems Walkdown Program basis

documents, the staff noted that these materials were not included in the scope of program for

this AMP.

In RAI B.2.19-1, dated June 13, 2008, the staff requested that the applicant explain the basis

for not scoping in paints, coatings, sealants and caulking as materials that should be monitored

for degradation, in either the Condensate and Refueling Water Storage Tanks Inspection

Program or the Systems Walkdown Program. The staff also requested that the applicant

3-36
explain the method in which the applicant will visually inspect these materials under the

Systems Walkdown Program.

The staff noted in the applicant's response to RAI B.2.19-1, dated July 24, 2008, that the

applicant has taken an exception to GALL XI.M29 for the "scope of program," "preventative

actions," "parameters monitored or inspected," "detection of aging effects," and "acceptance

criteria" program elements. The staff evaluation of this exception follows.

Based on GALL AMP X1.29, the staff determined that corrective actions are initiated upon the

detection of any degradation of paints, coatings, sealants and caulking. However, the staff

noted that in the applicant's Condensate and Refueling Water Storage Tanks Inspection

Program and the Systems Walkdown Program, the corresponding program element

"acceptance criteria" states that there shall be no unacceptable loss of material.

In RAI B.2.19-2, dated June 13, 2008, the staff requested that the applicant explain the

discrepancy between the GALL AMP XI.M29 and the applicant's Condensate and Refueling

Water Storage Tanks Inspection Program and the Systems Walkdown Program and; justify its

basis for taking actions only upon the detection of an unacceptable loss of material.

Additionally, the staff requested that the applicant explain why the program element for the

Condensate and Refueling Water Storage Tanks Inspection Program and Systems Walkdown

Program differs from GALL AMP XI.M29.

In its response to RAI B.2.19-2, dated July 24, 2008, the applicant stated that it has clarified

and amended LRA Section B.2.19 to state that any indications of loss of material detected

during the inspection of the tank bottoms will be reported and evaluated. The staff confirmed

that the applicant has amended LRA Section B.2.19 to state that the results of the volumetric

test performed on the tank bottom will be evaluated against the design thickness, and any

indication of loss of material will be reported through the corrective actions process and then

evaluated against the design corrosion allowance. The staff also confirmed that the applicant

had amended LRA Section B.2.19 to state that indications of corrosion on the accessible

external surface of the tanks will be reported and will require further evaluation.

Based on its review, the staff finds the applicant's response acceptable because the applicant

has amended LRA Section B.2.19 to state that any indication of degradation on the tanks

bottoms and corrosion on the accessible external surfaces will be reported and evaluated,

consistent with recommendations in GALL AMP XI.M29. Therefore, the staff's concerns

described in RAI B.2.19-2 are resolved.

Exception 1. Based on the applicant's response to RAI B.2.19-1, the following exception was

taken which affects the "scope of program," "preventative actions," "parameters monitored or

inspected," "detection of aging effects," and "acceptance criteria" program elements:

Coatings of the tanks surfaces are not credited for preventing corrosion. The

coatings do not perform an intended function for license renewal, aging

management is not required, and degradation is not reported.

Sealant at the interface between the tanks and the concrete pedestal is

evaluated as a structural commodity and is not within the scope of the

Condensate and Refueling Water Storage Tanks Inspection.

3-37
The staff noted in the applicant's response to RAI B.2.19-1, dated July 24, 2008, that the

applicant does not credit paints and coating for prevention and mitigation of corrosion on the

external surfaces of the CST and RWST. The staff further noted that since paints, coatings,

sealants and caulking are not credited for aging management as part of license renewal, the

applicant is not required to manage aging effects that may affect paints, coating, sealants and

caulking as part of the Systems Walkdown Program. However, the applicant stated that

caulking and sealants will be inspected by the Structures Monitoring Program. The staff

confirms that the scope of the applicant's Structures Monitoring Program includes the CST and

RWST and inspection of the associated caulking and sealants at the foundation and support

pedestals. The staff notes that visual inspections of the condition of paints and coatings on the

external surfaces of the CST and RWST will indicate whether degradation and corrosion is

occurring on the underlying material, even though paints and coatings are not credited.

Based on its review, the staff finds the applicant's response to RAI B.2.19-1 acceptable

because: (a) the applicant has not credited paints and coatings with preventing and mitigating

aging of the underlying materials, and therefore does not require aging management; (b) the

applicant will perform periodic visual inspections of the external surfaces of the tanks to

determine the condition of the underlying metallic material; and (c) the staff confirmed that

sealants and caulking are inspected and monitored by the applicant's Structures Monitoring

Program. Therefore, the staff's concern described in RAI B.2.19-1 is resolved.

The staff finds the applicant's exception acceptable because the applicant will perform its

periodic visual inspections of the external surfaces of the CST and RWST for indications of

corrosion of the underlying material, and the staff has confirmed that the applicant will inspect

and monitor sealants and caulking by the Structures Monitoring Program.

Operatinq Experience. The staff reviewed the applicant's OE described in the license renewal

basis document for the Condensate and Refueling Water Storage Tanks Inspection Program.

The applicant stated that the Condensate and Refueling Water Storage Tanks Inspection

Program is a new one-time inspection activity for which there is no OE and that inspection

methods will be consistent with accepted industry practices. For this program and for other new

AMPs where the applicant provided no current plant-specific OE, the staff issued a generic RAI.

In RAI B.2. 1, dated June 10, 2008, the staff requested that the applicant commit to provide

documentation of plant-specific OE, for staff review, after the program has been implemented,

but prior to entering the period of extended operation.

In its response to RAI B.2.1, dated July 8, 2008, the applicant stated that OE for new AMPs

described in LRA Appendix B will be gained as these new programs are implemented during

the period of extended operation. The applicant further stated that results of tests, inspections,

and other aging management activities conducted in accordance with these programs will be

subject to confirmation and corrective action elements of the Susquehanna 10 CFR Part 50,

Appendix B, Quality Assurance Program and that results will be subject to staff review during

regional inspections under existing staff inspection modules. The applicant also stated that it

will perform one-time inspections, prior to entry to the period of extended operation, to confirm

the effectiveness of existing AMPs, and that these programs are subject to review under NRC

Inspection Procedure 71003, "Post-Approval Site Inspection for License Renewal."

The staff notes that the applicant's statement that inspection methods will be consistent with

industry practices is consistent with the "operating experience" program element for GALL

AMP XI.M29. The staff also notes that post-approval site inspections provide an opportunity for

3-38
staff review and assess the effectiveness of the applicant's Condensate and Refueling Water

Storage Tanks Inspection Program, after the applicant has developed OE with that program.

The staff concludes that the corrective action program, based on industry and plant-specific

OE, will capture future OE to support the conclusion that the effects of aging are adequately

managed.

During its review, the staff noted that even though the applicant states OE does not currently

exist for this program, the applicant reviewed its CRs Database for indications of degradation of

the CSTs and RWSTs and did not find any indications. During its onsite review, the staff

reviewed the CRs for the Systems Walkdown Program provided in the license renewal basis

documents, in order to determine whether there have been indications of degradation to the

protective coatings, sealants, caulking and tank bottoms of the CSTs and RWSTs. Based on its

review, the staff did not identify any CRs related of the degradation to the protective coatings,

sealants, caulking and tank bottoms of the CSTs and RWSTs.

On this basis, the staff confirms that the "operating experience" program element satisfies the

criterion defined in the GALL Report and the guidance in SRP-LR Section A.1.2.3.10.

Therefore, the staff finds this program element acceptable and concludes that a separate

commitment is not necessary.

UFSAR Supplement. The staff reviewed the UFSAR Supplement summary description that was

provided in LRA Section A.1.2.14 for the Condensate and Refueling Water Storage Tanks

Inspection Program. The staff verified that, in LRA Commitment No. 17 of UFSAR Supplement

Table A-i, the applicant committed to perform a volumetric examination of the tank bottom and

visual examinations of the bottom surface to the foundation pad interface of the Condensate

and Refueling Water Storage Tanks within a 10-year period prior to the period of extended

operation. The staff also verified that the applicant has placed this commitment in UFSAR

Supplement summary description A. 1.2.14 for the Condensate and Refueling Water Storage

Tanks Inspection Program.

The staff reviewed this section and finds it acceptable because it is consistent with the

corresponding description in SRP-LR Table 3.3-2 and because the summary description

includes the bases for determining that aging effects will be managed.

The staff determines that the UFSAR supplement for this AMP provides an adequate summary

description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its audit and review of the applicant's Condensate and Refueling

Water Storage Tanks Inspection Program and the applicant's responses to the RAIs, the staff

finds all program elements consistent with the GALL Report. In addition, the staff reviewed the

exception and its justification and determines that the AMP, with the exception, is adequate to

manage the aging effects for which its credited.

The staff concludes that the applicant has demonstrated that the effects of aging will be

adequately managed so that the intended function(s) will be maintained consistent with the CLB

for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also

reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d), and therefore is

acceptable.

3-39
3.0.3.1.10 Chemistry Program Effectiveness Inspection

Summary of Technical Information in the Application. In LRA Section B.2.22, the applicant

described the new Chemistry Program Effectiveness Inspection (CPEI) as consistent with GALL

AMP XI.M32, "One-Time Inspection." The applicant stated that the program is a one-time

inspection program to detect and characterize the condition of materials in representative

low-flow and stagnant areas of plant systems influenced by the BWR Water Chemistry

Program, the Closed Cooling Water Chemistry Program, and the Fuel Oil Chemistry Program,

all of which are mitigation programs. The applicant also stated that the inspection provides

direct evidence as to whether, and to what extent, a loss of material due to crevice, general, or

pitting corrosion and to microbiologically influenced corrosion (MIC) in fuel oil, as well as

cracking due to SCC of susceptible materials in susceptible locations has occurred. The

applicant further stated that implementation of the program (Commitment No. 19), which is

scheduled to be completed during the 10-year period prior to the period of extended operation,

will provide confirmation of chemistry program effectiveness and assure that the integrity of

susceptible components is maintained consistent with the CLB during the period of extended

operation.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff reviewed the applicant's AMP evaluation for the Chemistry Program

Effectiveness Inspection, together with the applicant's program outline which provides specific

guidance for preparation of implementing procedures related to this new program. The staff

noted the program elements in the AMP that the applicant claimed were consistent with the

GALL Report are consistent with GALL AMP XI.M32, with the exception of two program

element aspects for which the staff required additional information.

The staff noted that the applicant's description of the "monitoring and trending" program

element for the CPEI refers to using engineering evaluations to determine sample size and

inspection locations, but provides no details of the methodology to be used.

In RAI B.2.22-1, dated June 23, 2008, the staff requested that the applicant describe the

methodology it will use to select sample sizes and sample locations for various components and

also explain what methodology or basis will be used for sample size expansion, if unanticipated

aging effects are found.

In its response to RAI B.2.22-1, dated July 17, 2008, the applicant stated the following:

The sample population will be selected such that it is representative of each

material and environment combination within the scope of the inspection.

Consideration will be given in the sample selection to the variations among the

treated water environments that could affect the potential for aging effects to

occur. Each material type exposed to fuel oil will also be included in the sample

population. The sample selection will focus on those locations determined to be

subject to low flow or stagnant conditions, as these locations are expected to be

the most likely to first experience the effects of degradation should it be

evidenced. Identification of the inspection locations will be based on engineering

knowledge of the system(s), supported by walkdowns of the systems as

necessary, including the time in service and severity of operating condition. The

inspection will focus on those systems, or portions of systems, most subject to

stagnant or low flow condition.

3-40
The results of the inspection of the sample population will be reviewed for any

evidence of degradation. If degradation is detected the results will be entered

into the SSES corrective action program. The corrective action program requires

evaluation of the extent of the degradation, the effect on the component intended

function, and the necessary corrective actions. The need to perform inspections

of a larger portion of the total population of components within the scope of the

activity will also be considered.

The staff confirms that the applicant has amended LRA Section B.2.22 and revised the second

paragraph in the discussion of "monitoring and trending." to read as follows:

Sample size will be determined by engineering evaluation, as described for the

"detection of aging effects" program element above. Unacceptable inspection

findings will be evaluated using the SSES corrective action process. The

evaluation done under the SSES corrective action program will identify

appropriate corrective actions including the need to perform additional

inspections.

In evaluating the applicant's response, the staff noted that the applicant provided additional

qualitative information with regard to the methodology it used to select sample sizes and

locations. The applicant also provided a link between its corrective action program and its

methodology and basis for sample size expansion. The staff noted that the additional

information provided by the applicant with regard to the "monitoring and trending" program

element is at a level of detail consistent with the description of this program element in GALL

AMP XI.M32.

Based on its review, the staff finds the applicant's response to RAI B.2.22-1 acceptable

because the applicant has provided an adequate description of its CPEI which is consistent with

the program element as described in the GALL Report. Therefore, the staff's concern described

in RAI B.2.22-1 is resolved.

The staff noted that the applicant's description of the "acceptance criteria" program

element for the CPEI states that there shall be "no unacceptable loss of material, or

cracking of stainless steel exposed to temperatures above 1400F, that could result in a loss

of component intended function during the period of extended operation, as determined by

engineering evaluation." However, the "acceptance criteria" program element in the GALL

Report states that any indication or relevant conditions of degradation detected are to be

evaluated.

In RAI B.2.22-2, dated June 23, 2008, the staff requested that the applicant explain why

the acceptance criteria in the applicant's program is different from the recommendation in

the GALL Report and clarify what is meant by "no unacceptable loss of material or

cracking," as used in the acceptance criteria for the applicant's program.

In its response to RAI B.2.22-2, dated July 17, 2008, the applicant stated the following:

Any indications or relevant conditions of degradation detected during the

inspections will be evaluated. Similar to the example provided in the GALL text,

the inspection observations will be compared to predetermined acceptance

criteria. Inspection results that do not meet the acceptance criteria will be

entered into the corrective action program for evaluation.

3-41
The staff confirms that the applicant has amended LRA B.2.22 to provide consistency with the

description of the "acceptance criteria" program element in GALL AMP XI.M32 and has revised

the text to read as follows:

Any indications or relevant conditions of degradation detected during the

inspections will be compared to pre-determined acceptance criteria. If the

acceptance criteria are not met, then the indications/conditions will be evaluated

under the SSES corrective action program to determine whether they could

result in a loss of component intended function during the period of extended

operation.

In evaluating the applicant's response, the staff notes that that the applicant's revision to the

LRA brings its description for the "acceptance criteria" in the Chemical Program Effectiveness

Inspection into conformance with the "acceptance criteria" program element in GALL

AMP XI.M32.

Based on its review, the staff finds the applicant's response to RAI B.2.22-2 acceptable

because the applicant has adequately explained the basis for why the acceptance criteria in the

CPEI differs from the recommendation in the GALL Report and has revised the LRA to correct

the discrepancy. The staff determines that with this revision, the "acceptance criteria" program

element of the applicant's program is consistent with the same program element in the GALL

Report. Therefore, the staff concern described in RAI B.2.22-2 is resolved.

In a letter dated December 11, 2008, the applicant amended the description of the Chemical

Program Effectiveness Inspection in LRA Section B.2.22. The applicant revised the "scope of

program" description to state that the Chemical Program Effectiveness Inspection includes the

surfaces of nickel alloy components, in addition to aluminum, copper alloy, carbon, and low

alloy steel, cast iron, and stainless steel components, which were already listed as within the

scope of the AMP. The applicant also made a similar revision to LRA Commitment No. 19 to

add surfaces of nickel alloy components, in addition to the other previously listed materials of

construction.

The applicant stated that it had reviewed an LRA change made in response to RAI B.2.14-2,

dated August 12, 2008, and identified that its earlier change with respect to components in the

diesel generator system was incomplete. The applicant further stated that in its earlier change,

corrosion monitoring probes in the diesel jacket cooling water system would be used to monitor

actual corrosion rates as part of the Closed Cooling Water Chemistry Program and that the

Chemical Program Effectiveness Inspection would not be used to monitor corrosion in the

diesel jacket cooling water system. The applicant also stated that a subsequent review

determined that the corrosion probes are used only to monitor corrosion of steel components,

and that the Chemical Program Effectiveness Inspection will be used to confirm that loss of

material is not occurring in other diesel jacket cooling water system components, including

nickel alloy (Monel) heat exchanger tube plugs.

The staff reviewed the applicant's changes to the Chemical Program Effectiveness Inspection "scope of program" program element and commitment as described above. The staff

determines that surface examinations provided by the applicant's Chemical Program

Effectiveness Inspection for other materials are also capable of detecting loss of material due to

pitting or crevice corrosion in nickel alloy components. On the basis that the CPEI AMP includes

surface examinations that can detect loss of material in nickel alloy components, the staff finds

3-42
the applicant's addition of nickel alloy components to the "scope of program" program element

and to LRA Commitment No. 19 to be acceptable.

Based on its staff's review, and resolution of the related RAIs as described above, the staff

finds the CPEI consistent with the program elements of GALL AMP XI.M32 and therefore is

acceptable.

Operatingq Experience. The staff reviewed the applicant's OE described in LRA Section B.2.22.

The applicant stated that the CPEI is a new one-time inspection activity for which there is no

OE and that inspection methods will be consistent with accepted industry practices. For this

program and for other new AMPs where the applicant provided no current plant-specific OE, the

staff issued generic RAI B.2.1.

In RAI B.2.1, dated June 10, 2008, the staff requested that the applicant commit to provide

documentation of plant-specific operating for staff review, after the program has been

implemented, but prior to entering the period of extended operation.

In its response to RAI B.2. 1, dated July 8, 2008, the applicant stated that OE for new AMPs

described in LRA Appendix B will be gained as these programs are implemented during the

period of extended operation. The applicant further stated that results of tests, inspections, and

other aging management activities, conducted in accordance with these programs, will be

subject to confirmation and corrective action elements of the Susquehanna 10 CFR Part 50,

Appendix B, Quality Assurance Program. The results will be subject to staff review during

regional inspections under existing staff inspection modules. The applicant also stated that, to

confirm the effectiveness of existing AMPs, one-time inspections will be performed prior to entry

into the period of extended operation, and that these programs are subject to review under

NRC Inspection Procedure 71003, "Post-Approval Site Inspection for License Renewal."

The staff notes the applicant's statement that inspection methods will be consistent with

industry practices is consistent with the "operating experience" program element for GALL

AMP XI.M32. The staff also notes that post-approval site inspections provide an opportunity for

staff review and assessment of the effectiveness of the applicant's Chemistry Program

Effectiveness Inspection, after the applicant has developed OE with that program. The staff

concludes that the corrective action program, based on internal and external plant OE, will

capture OE to support the conclusion that the effects of aging are adequately managed. On this

basis, the staff confirms that the "operating experience" program element satisfies the criterion

defined in the GALL Report and the guidance found in SRP-LR Section A.1.2.3.10. Therefore,

the staff finds this program element acceptable and concludes that a separate commitment is

not necessary.

UFSAR Supplement. The applicant provided the UFSAR supplement for the CPEI in LRA

Section A.1.2.12 and Commitment No. 19 in Table A-1. The staff also notes that the applicant

has committed to implement theCPEI for aging management of applicable components during

the 10 years prior to the period of extended operation.

Based on this review, the staff finds that the UFSAR supplement summary in LRA

Section A. 1.2.12 provides an acceptable description of the applicant's CPEI because it is

consistent with the UFSAR supplement summary description for the One-Time Inspection

program in the SRP-LR.

3-43
The staff determines that the information in the UFSAR supplement is an adequate summary

description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review of the applicant's CPEI and resolution of the relevant

RAIs as described above, the staff finds all program elements consistent with the GALL Report.

The staff concludes that the applicant has demonstrated that effects of aging will be adequately

managed so that the intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the

UFSAR supplement for this AMP and concludes that it provides an adequate summary

description of the program, as required by 10 CFR 54.21(d) and therefore is acceptable.

3.0.3.1.11 Cooling Units Inspection

Summary of Technical Information in the Application. In LRA Section B.2.23, the applicant

described the Cooling Units Inspection Program as a new program that will be consistent with

GALL AMP XI.M32, "One-Time Inspection." The applicant stated that this program will detect

and characterize the condition of aluminum, carbon steel, copper alloy, and stainless steel

cooling unit components that are exposed to a ventilation environment or to an uncontrolled raw

water environment from cooling unit drain pans, and of certain heat exchanger components

exposed to treated water or ventilation environments. The applicant further stated that the

inspection provides direct evidence as to whether and to what extent, loss of material or

reduction of heat transfer has occurred, or may likely occur and result in a loss of intended

function.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. In comparing the elements in the applicant's program to those in GALL

AMP XI.M32, the staff noted that the program elements in the applicant's AMP claim of

consistency with the GALL Report were consistent with GALL AMP XI.M32, with the exception

of four program element aspects identified below that the staff determined required additional

clarification. The staff also confirmed that the plant program contains all of the elements of the

referenced GALL Report. The staff conducted onsite interviews with the applicant to confirm

these results.

In the "scope of program" program element, the applicant stated that this program detects loss

of material due to crevice and pitting corrosion and selective leaching of the copper-alloy cooler

channel in the control structure heating, ventilation, and air conditioning (HVAC) system. GALL

AMP XI.M33, "Selective Leaching of Materials," states that selective leaching generally does

not cause changes in dimensions and is difficult to detect. The examination techniques used by

the Cooling Units Inspection Program to detect degradation are visual and/or volumetric.

Neither one of these techniques by itself will detect selective leaching.

In RAI B.2.23-1, dated June 23, 2008, the staff requested that the applicant justify how this

program will manage selective leaching and explain why these components are not included in

the Selective Leaching Inspection Program.

In its response to RAI B.2.23-1, dated July 25, 2008, the applicant amended the LRA to credit

the Selective Leaching Inspection Program, in place of the Cooling Units Inspection Program,

to manage loss of material due to selective leaching of the copper control structure HVAC

cooler channels.

3-44
Based on its review, the staff finds the applicant's response to RAI B. 2.23-1 acceptable

because the applicant has amended the LRA to manage these components for loss of material

due to selective leaching with the Selective Leaching Inspection Program, which contains

appropriate techniques to manage this aging effect. Therefore, the staff's concern described in

RAI B.2.23-1 is resolved.

In the "detection of aging effects" program element, the applicant stated that a combination of

established volumetric or visual examination techniques will be used to identify evidence of loss

of material or to confirm a lack thereof. However, GALL AMP XI.M32 recommends specific

inspection methods which are dependent on aging effects and mechanisms.

In RAI B.2.23-2, dated June 23, 2008, the staff requested that the applicant clarify the

inspection techniques that it will use.

In its response to RAI B.2.23-2, dated July 25, 2008, the applicant stated that visual inspection

(VT-1 or equivalent) and/or volumetric inspection (radiographic test (RT) or UT) techniques will

be used to determine whether crevice or pitting corrosion is occurring; visual inspection (VT-3

or equivalent) and/or volumetric inspection (RT or UT) techniques will be used to determine

whether galvanic or general corrosion is occurring; and visual inspection (VT-3 or equivalent)

techniques will be used to determine whether reduction in heat transfer is occurring. The

applicant also stated that the specific inspection technique will be determined prior to the

inspection activities and will be consistent with the recommendations in GALL AMP XI.M32.

Based on its review, the staff finds the applicant's response to RAI B. 2.23-2 acceptable

because the applicant has identified specific inspection techniques it will use for detection of the

aging mechanisms that are consistent with the recommendations in GALL AMP XI.M32.

In the "monitoring and trending" program element, the applicant stated that no actions are taken

as part of this program, since it is a one-time inspection activity. In the "monitoring and trending"

program element, GALL AMP XI.M32 states that "unacceptable inspection findings are

evaluated in accordance with the site corrective action process to determine the need for

subsequent (including periodic) inspections..."

In RAI B.2.23-3, dated June 23, 2008, the staff requested that the applicant confirm whether

the corrective action program will increase the sample size, in the event aging effects are

detected.

In its response to RAI B.2.23-3, dated July 25, 2008, the applicant responded that unacceptable

inspection findings will be evaluated under the SSES Corrective Action Program. The

evaluation performed under this program will identify appropriate corrective actions, including

the need to perform additional inspections.

Based on its review, the staff finds the applicant's response to RAI B.2.23-3 acceptable

because the applicant has confirmed that it will evaluate unacceptable inspection findings under

the SSES Corrective Action Program and take appropriate corrective action, including the need

to perform additional inspections. The staff further finds the response acceptable because the

applicant's actions are consistent with the recommendations of the GALL AMP XI.M32

"monitoring and trending" program element. Therefore, the staff's concern described in

RAI 2.23-3 is resolved.

3-45
In the "acceptance criteria" program element, GALL AMP XI.M32 states that any indication or

relevant conditions of degradation detected are evaluated. However, in LRA Section B.2.28, the

applicant stated under the acceptance criteria that: "no unacceptable loss of material (or wall

thinning), could result in a loss of component intended function, during the period of extended

operation, as determined by engineering evaluation."

In RAI B.2.23-4, dated June 23, 2008, the staff requested that the applicant explain why the

acceptance criteria for the Cooling Units Inspection Program differ from the recommendations

of the GALL Report and clarify what is meant by "no unacceptable loss of material (or wall

thinning)."

In its response to RAI B.2.23-4, dated July 25, 2008, the applicant amended LRA Cooling

Unit Inspection Program "acceptance criteria" element to state:

Any indications or relevant conditions of degradation detected during the

inspections will be compared to pre-determined acceptance criteria. If the

acceptance criteria are not met, then the indications/conditions will be evaluated

under the SSES Corrective Action Program to determine whether they could

result in a loss of component intended function during the period of extended

operation.

Based on its review, the staff finds the applicant's response to RAI B.2.23-4 acceptable

because the applicant has adequately explained why the acceptance criteria for the Cooling

Units Inspection Program differ from the recommendations of the GALL Report and has

sufficiently clarified what is meant by "no unacceptable loss of material (or wall thinning)." The

staff also finds the applicant's response acceptable because the applicant has amended the "acceptance criteria" program element for this AMP to be consistent with the recommendations

in GALL AMP XI.M32. Therefore, the staff's concern described in RAI B.2.23-4 is resolved.

Based on its review, the staff finds the applicant's Cooling Units Inspection Program consistent

with the program elements of GALL AMP XI.M32 and therefore is acceptable.

Operatingq Experience. The staff reviewed the applicant's OE described in LRA Section B.2.23

and interviewed the applicant's technical personnel to confirm that the plant-specific OE did not

reveal any aging effects not bounded by the GALL Report. The staff also confirmed that

applicable aging effects and industry and plant-specific OE have been reviewed by the

applicant and are evaluated in the GALL Report.

The "operating experience" program element states that the Cooling Units Inspection Program

is a new program and there is no plant-specific program OE indicating the need for an aging

management progam. However, the staff noted that the applicant has generated several CRs

during walkdowns, surveillance and maintenance activities on the cooling units that are included

in the scope of this program.

In RAI B.2.23-5, dated June 23, 2008, the staff requested that the applicant identify whether

there exists, any age related degradation documentation for these cooling units.

In its response to RAI B.2.23-5, dated July 25, 2008, the applicant stated that CRs associated

with the cooling units within the scope of the Cooling Units Inspection Program have been

generated during various routine plant activities. The applicant also stated that a review of

3-46
those CRs did not identify any age-related degradation for the specific subcomponents

addressed by the Cooling Units Inspection Program.

Based on its review, the staff finds the applicant's response to RAI B.2.23-5 acceptable

because the applicant has reviewed the condition reports for OE and did not identify any

age-related degradation for the specific subcomponents addressed by the Cooling

Unit Inspection Program. Therefore, the staff's concern described in RAI B.2.23-5 is resolved.

Furthermore, the staff confirms that the applicant has addressed OE identified after the

issuance of the GALL Report. The staff finds that the applicant's Cooling Units Inspection

Program can be expected to ensure that the effects of aging will be adequately managed during

the period of extended operation.

The staff also confirms that the OE program element satisfies the criterion defined in the GALL

Report and the guidance found in SRP-LR Section A.1.2.3.10. Therefore, the staff finds this

program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement for the Cooling Units

Inspection Program in LRA Section A.1.2.16 and Commitment No. 20 in Table A-1. The staff

reviewed this section and finds that it is acceptable because it is consistent with the

corresponding program description in SRP-LR Table 3.3-2 and because the applicant has

committed to implement the Cooling Units Inspection Program within the 10-year period prior to

the period of extended operation.

The staff determines that the information in the UFSAR supplement is an adequate summary

description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of the review of the applicant's Cooling Units Inspection Program and

the applicant's response to the staff's RAIs, the staff finds all program elements consistent with

the GALL Report. The staff concludes that the applicant has demonstrated that the effects of

aging will be adequately managed so that the intended functions will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff

also reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d), and therefore is

acceptable.

3.0.3.1.12 Heat Exchanger Inspection

Summary of Technical Information in the Application. In LRA Section B.2.24, the applicant

described the Heat Exchanger Inspection Program as a new program that will be consistent

with GALL Report AMP XI.M32, "One-Time Inspection." The applicant stated that this program

will detect and characterize cracking due to SCC and reduction in heat transfer due to fouling of

heat exchanger tubes exposed to treated water.

The applicant further stated that the inspection provides direct evidence as to whether, and to

what extent, cracking due to SCC or reduction in heat transfer due to fouling has occurred or is

likely to occur that may result in a loss of intended function.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff also confirmed that the plant program contains all of the elements of

the referenced GALL Report and that the conditions at the plant are bounded by the conditions

3-47
for which the GALL Report is evaluated. The staff conducted onsite interviews with the

applicant to confirm these results.

The staff noted the applicant stated that instead of focusing on a representative sample

population, the Heat Exchanger Inspection Program will be applied to all heat exchangers within

the scope of the program. The inspection and test techniques will be as recommended by

GALL AMP XI.M32 for detecting the aging effect of concern.

The staff reviewed the applicant's license renewal basis document and confirmed that the

program scope includes all the heat exchangers likely to be affected by the heat exchanger

inspection. In its response to RAI B.2.17-2, dated June 30, 2008, and as identified in the SER

Section 3.0.3.2.9, the applicant stated that this program will detect and characterize reduction in

heat transfer due to fouling of heat exchanger tubes exposed to raw water or a lubricating oil

environment, which brought additional components into the scope of this program. The

applicant added the diesel-engine driven fire pump heat exchangers and oil coolers in the

program scope. The staff noted that the additional components the applicant has brought into

the scope of program are appropriate, and are heat exchanger components that require aging

management as part of this program.

Based on its review, the staff finds the applicant's Heat Exchanger Inspection Program

consistent with the program elements of GALL AMP XI.M32 and therefore is acceptable.

Operating Experience. The staff reviewed the applicant's OE described in LRA Section B.2.24

and interviewed the applicant's technical personnel to confirm that the plant-specific OE did not

reveal any aging effects not bounded by the GALL Report. The staff also confirmed that

applicable aging effects and industry and plant-specific OE have been reviewed by the

applicant and are evaluated in the GALL Report.

The applicant stated for the "operating experience" program element that the Heat Exchanger

Inspection Program is a new program and there is no plant-specific program OE. However, the

applicant further stated that during performance of surveillance tests or preventive

maintenance, any observed degradation of tubes would have been documented.

In RAI B.2.24-1, dated June 23, 2008, the staff requested that the applicant identify examples

of issues that may have been documented to address age-related degradation of the heat

exchanger tubes within the scope of this program, and include them in the OE element.

In its response to RAI B.2.24-1, dated July 25, 2008, the applicant stated that a review of

documentation generated during various routine plant activities associated with the heat

exchangers was performed within the scope of the Heat Exchanger Inspection Program. The

review did not identify any age-related degradation of the heat exchanger tubes within the

scope of this inspection.

Based on its review, the staff finds the applicant's response to RAI B.2.24-1 acceptable

because the applicant has verified and the staff confirms that the applicant's review of plant OE

related to the heat exchangers within the scope of the Heat Exchanger Inspection Program did

not identify any age related degradation. Therefore, the staff's concern described in

RAI B.2.24-1 is resolved.

3-48
The staff finds that the applicant's Heat Exchanger Inspection Program can be expected to

ensure that effects of aging will be adequately managed during the period of extended

operation.

The staff confirms that the OE program element satisfies the criterion defined in the GALL

Report and the guidance found in SRP-LR Section A.1.2.3.10. Therefore, the staff finds this

program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement for the Heat Exchanger

Inspection Program in LRA Section A.1.2.22 and Commitment No. 21 in Table A-i, amended

by letter dated June 30, 2008. The staff reviewed this section and finds it acceptable because it

is consistent, with the amendment, with the corresponding program description in SRP-LR

Table 3.3-2. The staff confirms that the applicant has amended the UFSAR supplement to

include the diesel engine driven fire pump heat exchangers and oil coolers in the UFSAR

supplement and had committed to implement the Heat Exchanger Inspection Program within

the 10-year period, prior to the period of extended operation.

The staff determines that the information in the UFSAR supplement is an adequate summary

description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review of the applicant's Heat Exchanger Inspection Program

and the applicant's response to the RAls, the staff finds all program elements consistent with

the GALL Report. The staff concludes that the applicant has demonstrated that the effects of

aging will be adequately managed so that the intended functions will be maintained consistent

with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3). The staff

also reviewed the UFSAR supplement for this AMP and concludes that it provides an adequate

summary description of the program, as required by 10 CFR 54.21(d) and therefore is

acceptable.

3.0.3.1.13 Lubricating Oil Inspection

Summary of Technical Information in the Application. In LRA Section B.2.25, the applicant

described the "Lubricating Oil Inspection Program" as a new program consistent with GALL

AMP XI.M32, "One-Time Inspection Program." The applicant stated that this program will verify

the effectiveness of Lubricating Oil Analysis Program by sampling systems and components

exposed to lubricating oil. The program will test for a loss of material due to crevice, galvanic,

general or pitting corrosion. In addition, this program will also test for selective leaching or

reduction in heat transfer due to fouling.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff also confirmed that the plant program contains all of the elements of

the referenced GALL Report and that the conditions at the plant are bounded by the conditions

for which the GALL Report is evaluated. The staff conducted onsite interviews with the

applicant to confirm these results.

In comparing the seven program elements in the applicant's program to those in

GALL AMP XI.M32, the staff noted the program elements in the applicant's AMP claim of

consistency with the GALL Report were consistent with GALL AMP XI.M32, with the exception

of one program element; namely, the "scope of program." The staff determined a need for

additional clarification which resulted in the issuance of RAIs. The "operating experience"

program element is discussed separately below.

3-49
The staff noted that the Lubricating Oil Inspection and Lubricating Oil Analysis Programs

manage components in the diesel generator, control structure chilled water, RHR, reactor core

isolation cooling (RCIC), and HPCI systems. It was not clear to the staff whether there are

additional systems that require management by these two AMPs because of their exposure to

lubricating oil.

In RAI B.2.25-1, dated July 10, 2008, the staff requested that the applicant identify whether

there are any other systems exposed to lubricating oil that are within the scope of license

renewal.

In its response to RAI B.2.25-1, dated August 12, 2008, the applicant stated that during its

review of LRA Section B.2.25, it had identified that the reactor building chilled water system was

omitted from the systems that are within the scope of the programs that manage aging for

lubricating oils. The staff confirmed that the applicant amended LRA Section B.2.25 to include

the reactor building chilled water system within the scope of this program.

Based on its review, the staff finds the applicant's response to RAI B.2.25-1 acceptable

because the applicant has identified the reactor building chilled water system as a system

exposed to lubricating oil and has amended the LRA to reflect the addition of this system within

the scope of the Lubricating Oil Inspection Program.

Operatinq Experience. The staff reviewed the applicant's OE discussion described in the

license renewal basis document for the Lubricating Oil Analysis Inspection Program. The

applicant stated that this AMP is a new one-time inspection activity for which there is no OE and

that inspection methods will be consistent with accepted industry practices. For this program

and for other new AMPs where the applicant provided no current plant-specific OE, the staff

issued generic RAI B.2.1

In RAI B.2.1, dated June 10, 2008, the staff requested that the applicant commit to provide

documentation of plant-specific OE for staff review, after the program has been implemented,

but prior to entering the period of extended operation.

In its response to RAI B.2.1, dated July 8, 2008, the applicant stated that OE for new AMPs

described in LRA Appendix B will be gained as these new programs are implemented, during

the period of extended operation. The applicant further stated that results of tests, inspections,

and other aging management activities conducted in accordance with these programs, will be

subject to confirmation and corrective action elements of the Susquehanna 10 CFR Part 50,

Appendix B, Quality Assurance Program and that results will be subject to staff review during

regional inspections under existing staff inspection modules. The applicant also stated that

one-time inspections will be performed prior to entry to the period of extended operation to

confirm the effectiveness of existing AMPs, and that these programs are subject to review

under NRC Inspection Procedure 71003, "Post-Approval Site Inspection for License Renewal."

The staff noted the applicant's statement that inspection methods will be consistent with

industry practices is consistent with the "operating experience" program element for GALL

AMP XI.M32. The staff also noted that post-approval site inspections provide an opportunity for

staff to review and assess the effectiveness of the applicant's Lubricating Oil Inspection

Program, after the applicant has developed OE with that program. The staff concludes that the

corrective action program, based on industry and plant-specific OE, will capture OE to support

the conclusion that the effects of aging are adequately managed. On this basis, the staff

3-50
confirms that the applicant's "operating experience" program element satisfies the criterion

defined in the GALL Report and the guidance found in SRP-LR Section A.1.2.3.10. Therefore,

the staff finds this program element acceptable and concludes that a separate commitment is

not necessary.

UFSAR Supplement. The applicant provided the UFSAR supplement summary of the

Lubricating Oil Inspection Program in LRA Section A.1.2.29 and Commitment No. 49 in Table

A-i. The staff reviewed this section and finds it acceptable because it is consistent with the

corresponding program description in SRP-LR Table 3.2-1. The staff confirms that the applicant

has committed to implementing this program prior to the period of extended operation, and that

the applicant has amended the LRA to include the reactor building chilled water system within

the scope of the Lubricating Oil Inspection Program. The staff also confirms that the applicant

has placed this commitment for the Lubricating Oil Inspection Program in UFSAR Supplement

Summary Section A.1 .2.29.

The staff determines that the information in the UFSAR supplement is an adequate summary

description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of the audit and review of the applicant's Lubricating Oil Inspection

Program and the applicant's responses to the RAIs, the staff finds all program elements

consistent with the GALL Report. Also, the staff confirms that the applicant has committed

(Commitment No. 49) to implement this program prior to the period of extended operation. The

staff concludes that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the

UFSAR supplement for this AMP and concludes that it provides an adequate summary

description of the program, as required by 10 CFR 54.21(d) and therefore is acceptable.

3.0.3.1.14 Main Steam Flow Restrictor Inspection

Summary of Technical Information in the Application. In LRA Section B.2.26, the applicant

described the Main Steam (MS) Flow Restrictor Inspection Program as a new program that will

be consistent with GALL AMP XI.M32, "One-Time Inspection." The applicant stated that this

program will detect and characterize reduction of fracture toughness of the CASS

subcomponents of the MS flow restrictors. The applicant also stated that the inspection will

detect cracking that is symptomatic of reduction of fracture toughness. The applicant further

stated that reduction of fracture toughness does not cause cracking, but the reduced toughness

allows existing cracks to propagate at higher rates.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. In comparing the elements in the applicant's program to those in GALL

AMP XI.M32, the staff noted the program elements in the applicant's AMP claim of consistency

with the GALL Report were consistent with GALL AMP XI.M32, with the exception of the three

program element aspects identified below, for which the staff determined required additional

clarification. The staff confirmed that the applicant's plant program contains all of the elements

of the referenced GALL Report. Further, the staff conducted onsite interviews with the applicant

to confirm these results.

In the "detection of aging effects" program element, the applicant stated that it will use a

combination of established visual examination techniques to detect reduction of fracture

3-51
toughness as evidenced by cracking. However, GALL AMP XI.M32 recommends specific

inspection methods dependent on aging mechanisms.

In RAI B.2.26-1, dated June 23, 2008, the staff requested that the applicant clarify the

inspection techniques it will use to detect evidence of cracking.

In its response to RAI B.2.26-1, dated July 25, 2008, the applicant stated that pursuant to its

response to RAI B.2.26-2, which is provided below, the MS Flow Restrictor Inspection Program

has been deleted.

In the "acceptance criteria" program element, GALL AMP XI.M32 states that any indication or

relevant conditions of degradation detected are evaluated. In LRA Section B.2.26, the applicant

stated that the acceptance criterion is: "no cracking that could result in a loss of component

intended function(s) during the period of extended operation, as determined by engineering

evaluation."

In RAI B.2.26-2, dated June 23, 2008, the staff requested that the applicant (a) confirm whether

the CASS MS flow restrictors were screened for thermal aging; (b) indicate whether the CASS

MS flow restrictors are susceptible to thermal aging; (c) indicate whether flaw tolerance

evaluations will be performed, if cracking is detected; and (d) explain what type of corrective

actions and monitoring will be implemented, if cracking is detected.

In the response to RAI B.2.26-2, dated July 25, 2008, the applicant stated that consistent with

GALL AMP XI.M12, "Thermal Embrittlement of Cast Austenitic Stainless Steel (CASS)," PPL

has performed a screening of the CASS portions of the MS flow restrictors to determine their

susceptibility for thermal aging. The applicant determined that the CASS portions of the flow

restrictors are not susceptible to reduction of fracture toughness due to thermal embrittlement

on the following basis:

The applicant stated that the CASS portions of the flow restrictors were cast by a

centrifugal casting method. PPL reviewed the QA documentation packages for

the flow restrictors and determined that the castings were constructed from cast

austenitic stainless steel, in conformance with material specification SA-351

CF8. This material is a low-molybdenum grade of CASS, as opposed to a highmolybdenum grade (i.e., "M" grade) of CASS material, such as SA- 351 CF8M,

which requires 2-3% molybdenum content. Therefore, the steam line flow

restrictor castings for SSES are considered to be constructed of low

molybdenum (0.5% maximum) content material. In accordance with the guidance

provided in the GALL Section XI.M12, the centrifugally-cast, low molybdenum

CASS portions of the flow restrictors are not susceptible to thermal

embrittlement. As such, the AMP B.2.26 "Main Steam Flow Restrictor Inspection"

which was intended to manage reduction of fracture toughness due to thermal

embrittlement for CASS portions of the MS flow restrictors is not an aging

management program required for license renewal because, as described

above, the CASS portions of the MS flow restrictors are not susceptible to

reduction of fracture toughness due thermal embrittlement.

3-52
In addition to the screening for susceptibility for thermal aging, the applicant re-evaluated the

other conclusions from the AMR of the MS flow restrictors. The applicant provided the following

results and conclusions of the re-evaluation in its response to RAI B.2.26-2:

" The flow restrictors in the Main Steam system are not pressure boundary

components. Therefore, neither ASME Section III nor ANSI B31.1, which

typically require a fatigue analysis or the use of stress range reduction factors for

7000 cycles, are applicable. As such, fatigue cracking of the main steam flow

restrictors is not an applicable aging effect.

" The ISI Program was credited to confirm the effectiveness

of the BWR Water Chemistry Program to manage a loss of material for the main

steam flow restrictors. The basis for crediting the ISI program was that similar

materials and environments were inspected by ISI. However, the Chemistry

Program Effectiveness Inspection (CPEI) confirms the effectiveness of the BWR

Water Chemistry Program. While ISI results may be considered in the

development and implementation of the CPEI one-time inspection, the ISI

Program is not an aging management program for the main steam flow restrictors.

* Stress Corrosion Cracking (SCC) is not an aging effect requiring management for

the main steam flow restrictors because there is no tensile stress in the CASS

portions of the flow restrictors to promote SCC. Also, the flow restrictors do not have a

pressure boundary function that could be affected by cracking, and cracking will not

affect the flow restriction function of the flow restrictors. Extreme cracking that could

result in the loss of flow restrictor structural integrity could affect its flow restriction

function; however, such a failure is not plausible, given the lack of a driving mechanism

for crack initiation and/or crack growth.

The applicant revised LRA Section 3.1.2.1.3, Table 3.1.1, Table 3.1.2-3, Appendix A (Table of

Contents, Section A. 1.2.30, and Table A-1), and Appendix B (Table of Contents, Table B-i,

Table B-2, and Section B.2.26) to reflect these results that reduction in fracture toughness due

to thermal embrittlement is not an AERM for license renewal.

The staff reviewed the applicant's response and confirmed that based on the screening criteria

provided in GALL AMP XI.M12, the CASS portion of the flow restrictors are not susceptible to

reduction of fracture toughness because all centrifugal-cast low-molybdenum steels are not

susceptible to this aging effect. Furthermore, based on a review of the drawings provided by the

applicant during the audit, the staff determined that these flow restrictors are in-line flow

restrictors and therefore, are not pressure boundary components.

Based on its review, the staff finds the applicant's response to RAI B.26-2 acceptable because

the applicant has verified and the staff confirms that: (a) the CASS flow restrictors are not

susceptible to reduction of fracture toughness due to thermal embrittlement; (b) the flow

restrictors are not pressure boundary components; and (c) the BWR Water Chemistry Program

and CPEI Program are credited for similar material and environments to manage the aging

effects of loss of material. The staff agrees with the deletion of the Main Steam Line Flow

Restrictor Inspection Program from the LRA. Therefore, the staff's concern described in

RAI B.2.26-2 is resolved.

3-53
In the "detection of aging effects" program element, the applicant stated that the Main Steam

Flow Restrictor Inspection Program will be applied to all eight (four per unit) MS flow restrictors.

In RAI B.2.26-3, the staff requested that the applicant clarify whether this means that all eight

flow restrictors will be inspected and; if not, please provide the sample size, and identify

whether the program will provide for increasing the sample size in the event that aging effects

are detected.

In its response to RAI B.2.26-3, dated July 25, 2008, the applicant stated that pursuant to its

response to RAI B.2.26-2 above, the Main Steam Flow Restrictor Inspection Program has been

deleted.

Based on its review, the staff finds the applicant's response to RAI B.2.26-3 acceptable

because the applicant has verified and the staff confirms that the Main Steam Flow Restrictor

Inspection Program has been deleted. Therefore, the staff's concern described in RAI B.2.26-3

is resolved.

UFSAR Supplement. In its letter dated July 25, 2008, the applicant deleted UFSAR Summary

Section A.1.2.30 and Commitment No. 22 in Table A-i, because the Main Steam Flow

Restrictor Inspection Program has been deleted. The staff's evaluation of the applicant's

deletion of the Main Steam Flow Restrictor Inspection Program is described above.

Conclusion. In the letter dated July 25, 2008, the applicant responded that pursuant to its

response to RAI B.2.26-2 above, the Main Steam Flow Restrictor Inspection Program has been

deleted. On the basis that the CASS flow restrictors are not susceptible to reduction of fracture

toughness due to thermal embrittlement, the flow restrictors are not pressure boundary

components, and LRA Section B.2.2, BWR Water Chemistry Program and Section B.2.22,

CPEI Program are credited for similar material and environments to manage the aging effects

of loss of material, the staff finds the applicant response acceptable and agrees with the

deletion of the Main Steam Line Flow Restrictor Inspection Program from the LRA. The staff

concurs with the deletion and the staff's basis for agreement is described above.

3.0.3.1.15 Monitoring and Collection System Inspection

Summary of Technical Information in the Application. In LRA Section B.2.27, the applicant

described the Monitoring and Collection System Inspection Program as a new program that will

be consistent with GALL AMP XI.M32, "One-Time Inspection." The applicant stated that this

program will detect and characterize the condition of the internal surfaces of subject

components that are exposed to equipment and/or area drainage water and other potential

contaminants or fluids. The applicant further stated that the inspection provides direct evidence

as to whether, and to what extent, a loss of material due to crevice, general or pitting corrosion,

or to MIC has occurred or is likely to occur in the liquid waste management system that may

result in a loss of intended function.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. In comparing the elements in the applicant's program to those in GALL

AMP XI.M32, the staff noted the program elements in the applicant's AMP claim of consistency

with the GALL Report were consistent with GALL AMP XI.M32, with the exception of three

program element aspects identified below that the staff determined required additional

clarification. The staff also confirmed that the plant program contains all of the elements of the

3-54
referenced GALL Report. The staff conducted onsite interviews with the applicant to confirm

these results.

In the "detection of aging effects" program element, the applicant stated that a combination of

established volumetric or visual examination techniques will be used to identify evidence of loss

of material or to confirm a lack thereof. However, GALL AMP XI.M32 recommends specific

inspection methods dependent on aging mechanisms.

In RAI B.2.27-1, dated June 23, 2008, the staff requested that the applicant clarify which

inspection techniques it will use.

In its response to RAI B.2.27-1, dated July 25, 2008, the applicant stated that visual inspection

(VT-1 or equivalent) and/or Volumetric inspection (RT or UT) techniques will be used to

determine whether crevice or pitting corrosion is occurring; visual inspection (VT-3 or

equivalent) and/or Volumetric inspection (RT or UT) techniques will be used to determine

whether galvanic or general corrosion is occurring; and visual inspection (VT-3 or equivalent)

techniques will be used to determine whether reduction in heat transfer is occurring. The

specific inspection technique will be determined prior to inspection activities and will be

consistent with the recommendations in GALL AMP XI.M32.

Based on its review, the staff finds the applicant's response to RAI B.2.27-1 acceptable

because the applicant has provided specific inspection techniques for detection of the aging

effects and the mechanisms are consistent with the recommendations in GALL AMP XI.M32.

Therefore, the staffs concern described in RAI B.2.27-1 is resolved.

In the "monitoring and trending" program element, the applicant stated that no actions are taken

as part of this program, since it is a one-time inspection activity. In the "monitoring and trending"

program element, the GALL AMP XI.M32 states that "unacceptable inspection findings are

evaluated in accordance with the site corrective action process to determine the need for

subsequent (including periodic) inspections..."

In RAI B.2.27-2, dated June 23, 2008, the staff requested that the applicant confirm whether

the corrective action program will increase the sample size, in the event aging effects are

detected.

In its response to RAI B.27-2, dated July 25, 2008, the applicant stated that unacceptable

inspection findings will be evaluated under the SSES Corrective Action Program, which will

identify appropriate corrective actions, including the need to perform additional inspections.

Based on its review, the staff finds the applicant's response to RAI B.2.27-2 acceptable

because the applicant will evaluate unacceptable inspection findings under its corrective action

program and take appropriate corrective action, including performance of additional

inspections, which is consistent with the recommendations of the GALL AMP XI.M32

"monitoring and trending" program element. Therefore, the staff's concern described in

RAI B.2.27-2 is resolved.

In the "acceptance criteria" program element, GALL AMP XI.M32 states that any indication or

relevant conditions of degradation detected are evaluated. In LRA Section B.2.27, the applicant

stated the following acceptance criteria: "no unacceptable loss of material (or wall thinning) that

could result in a loss of component intended function during the period of extended operation,

as determined by engineering evaluation."

3-55
In RAI B.2.27-3, dated June 23, 2008, the staff requested that the applicant explain why the

acceptance criteria for the Monitoring and Collection System Inspection Program differ from the

recommendations of the GALL Report, and clarify what is meant by "no unacceptable loss of

material (or wall thinning)."

In its response to RAI B.2.27-3, dated July 25, 2008, the applicant amended the Monitoring and

Collection System Inspection Program acceptance criteria" program element to state:

Any indications or relevant conditions of degradation detected during the

inspections will be compared to pre-determined acceptance criteria. If the

acceptance criteria are not met, then the indications/conditions will be evaluated

under the SSES Corrective Action Program to determine whether they could

result in a loss of component intended function during the period of extended

operation.

Based on its review, the staff finds the applicant's response to RAI B.2.27-3 acceptable

because the applicant has appropriately amended the Monitoring and Collection System

Inspection Program "acceptance criteria" program element to be consistent with the

recommendations provided in GALL AMP XI.M32. Therefore, the staff's concern described in

RAI B.2.27-3 is resolved.

Based on its review, the staff finds the Monitoring and Collection System Inspection Program

consistent with the program elements of GALL AMP XI.M32 and therefore is acceptable.

Operating Experience. The staff reviewed the applicant's OE described in LRA Section B.2.27

and interviewed the applicant's technical personnel to confirm that the plant-specific OE did not

reveal any aging effects not bounded by the GALL Report. The staff also confirmed that

applicable aging effects and industry and plant-specific OE have been reviewed by the

applicant and are evaluated in the GALL Report.

The "operating experience" program element in the LRA states that the Monitoring and

Collection System Inspection Program is a new program and there is no plant-specific program

OE. Furthermore, the staff confirmed that the applicant has addressed OE identified after the

issuance of the GALL Report. However, for this program and for other new AMPs where the

applicant provided no current plant-specific OE, the staff issued a generic RAI.

In RAI B.2-1, dated June 10, 2008, the staff requested that the applicant commit to provide

documentation of plant-specific OE for staff review, after the program has been implemented,

but, prior to entering the period of extended operation.

In its response to RAI B.2. 1, dated July 8, 2008, the applicant stated that OE for new AMPs

described in LRA Appendix B will be gained as these new programs are implemented during

the period of extended operation. The applicant further stated that results of tests, inspections,

and other aging management activities conducted in accordance with these programs will be

subject to confirmation and corrective action elements of the Susquehanna 10 CFR Part 50,

Appendix B, Quality Assurance Program and that results will be subject to staff review during

regional inspections under existing staff inspection modules. The applicant also stated that onetime inspections will be performed prior to entry to the period of extended operation, to confirm

the effectiveness of existing AMPs, and that these programs are subject to review under NRC

Inspection Procedure 71003, "Post-Approval Site Inspection for License Renewal."

3-56
The staff noted the applicant's statement that inspection methods will be consistent with

industry practices is consistent with the "operating experience" program element for GALL

AMP XI.M32. The staff also noted that post-approval site inspections provide an opportunity for

staff to review and assess the effectiveness of the applicant's Monitoring and Collection System

Inspection Program, after the applicant has developed OE with that program. The staff

concludes that the corrective action program, based on internal and external plant OE, will

capture OE to support the conclusion that the effects of aging are adequately managed. On this

basis, the staff finds this program element acceptable and concludes that a separate

commitment is not necessary.

The staff confirms that the "operating experience" program element satisfies the criterion

defined in the GALL Report and the guidance found in SRP-LR Section A.1.2.3.10. Therefore,

the staff finds, this program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement summary for the

Monitoring and Collection System Inspection Program in LRA Section A.1.2.33 and

Commitment No. 23 in Table A-I. The staff reviewed this section and finds it acceptable

because it is consistent with the corresponding program description in SRP-LR Table 3.3-2.

The staff also finds that the applicant has committed to implement the Monitoring and Collection

System Inspection Program within the 10-year period, prior to the period of extended operation.

The staff determines that the information in the UFSAR supplement is an adequate summary

description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of the review of the applicant's Monitoring and Collection System

Inspection Program and the applicant's response to the staff's RAIs, the staff finds all program

elements consistent with the GALL Report. The staff concludes that the applicant has

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this

AMP and concludes that it provides an adequate summary description of the program, as

required by 10 CFR 54.21(d), and therefore is acceptable.

3.0.3.1.16 Supplemental Piping/Tank Inspection Program

Summary of Technical Information in the Application. In LRA Section B.2.28, the applicant

described the Supplemental Piping/Tank Inspection Program as a new program that will be

consistent with GALL Report AMP XI.M32, "One-Time Inspection." The applicant stated that

this program will detect and characterize the condition of carbon and stainless steel

components that are exposed to moist air environments, particularly the aggressive wet and/or

dry environment that exists at air-water interfaces. The applicant further stated that the

inspection provides direct evidence as to whether and to what extent, loss of material due to

crevice, galvanic, general and pitting corrosion, has occurred or is likely to occur that could

result in a loss of intended function.

Staff Evaluation. During its audit, the staff confirmed the applicant's claim of consistency with

the GALL Report. In comparing the elements in the applicant's program to those in GALL AMP

XI.M32, the staff noted that the program elements in the applicant's AMP claimed to be

consistent with GALL were consistent with the corresponding program element criteria

recommended in the program elements of GALL AMP XI.M32 with the exception of below

3-57
identified four program element aspects that the staff determined were in need of additional

clarification. The staff also confirmed that the plant program contains all of the elements of the

referenced GALL Report program. On-site interviews were also held to confirm these results.

In the "scope of program" program element, the LRA identifies systems and components within

the scope of the program. In Table 3.2.2-9, diesel generator starting air system, the

Supplemental Piping/Tank Inspection Program is credited for managing the aging effect of loss

of material for stainless steel drain trap bodies and carbon steel moisture separators. However,

this system and components are not included in the scope of this program. The staff issued RAI

B.2.28-1 by letter dated June 23, 2008, to request the applicant to justify why this system is not

included in the program scope.

In its letter dated July 25, 2008, the applicant responded to RAI B.2.28-1 stating that the carbon

steel moisture separators and stainless steel drain trap bodies in the diesel generator starting

air system are within the scope of the Supplemental Piping/Tank Inspection. The applicant

further stated the Diesel Generators system should have been included in the listing of systems

within the scope of this inspection, but was inadvertently omitted. The applicant revised the LRA

Section B.2.28 "scope of program" element to include diesel generators system in the list of

systems within the scope of this program.

On the basis that the diesel generators system is added to the scope of the program and thus

accurately identifying components and systems in the scope of this program, the staff finds the

response acceptable. Therefore, the staff's concern described in RAI B.2.28-1 is resolved.

In the letter dated October 21, 2008, in response to the NRC regional inspection of the LRA, the

applicant revised the "scope of program" program element to include diesel fuel oil system in

the list of systems within the scope of the program.

On the basis that the diesel fuel oil system is added to the scope of the program and thus

accurately identifying components and systems in the scope of this program, the staff finds the

revision acceptable.

In the letter dated September 30, 2008, in response to the NRC regional inspection of the LRA,

the applicant revised the "scope of program" program element to include aging management of

loss of material due to crevice, galvanic, general, and pitting corrosion within the air space of

diesel generator starting air receiver tanks and E diesel compressor skid air receiver tanks. The

applicant also revised the "detection of aging effects" program element to include at least 2 of

these tanks in the sample population for inspection.

On the basis that the diesel generator starting air receiver tanks and E diesel compressor skid

air receiver tanks are included in the sample population, the staff finds the response acceptable

because the applicant has included these tanks in the program scope and two of these tanks

will be part of the sample population that will be inspected, which will provide inspection results

that could be evaluated and applied to the other tanks.

In the "detection of aging effects" program element, the LRA states that a combination of

established volumetric or visual examination techniques will be used to identify evidence of loss

of material or to confirm a lack thereof. However, the GALL AMP XI.M32, "One-Time

Inspection," recommends specific inspection methods dependent on aging effects and

mechanisms. The staff issued RAI B.2.28-2 by letter dated June 23, 2008, to request the

3-58
applicant to clarify the inspection techniques that will be used for the different aging effects and

mechanisms.

In the letter dated July 25, 2008, the applicant responded to RAI B.2.28-2 stating that visual

inspection (VT-1 or equivalent) and/or Volumetric inspection (RT or UT) techniques will be used

to determine whether crevice or pitting corrosion is occurring; visual inspection (VT-3 or

equivalent) and/or Volumetric inspection (RT or UT) techniques will be used to determine

whether galvanic or general corrosion is occurring; and visual inspection (VT-3 or equivalent)

techniques will be used to determine whether reduction in heat transfer is occurring. The

applicant stated the specific inspection technique will be determined prior to the inspection

activities and will be consistent with the recommendations in GALL AMP XI.M32.

The staff reviewed the applicant's response and finds the specific inspection techniques

provided by the applicant for detection of the aging effects and mechanisms are consistent with

the recommendations provided by GALL AMP XI.M32 and are acceptable. On this basis, the

staff finds the applicant response acceptable.

In the "monitoring and trending" program element, the LRA states that no actions are taken as

part of this program, since it is a one-time inspection activity. In the "monitoring and trending"

program element, GALL AMP XI.M32 states that unacceptable inspection findings are

evaluated in accordance with the site corrective action process to determine the need for

subsequent (including periodic) inspections. The staff issued RAI B.2.28-3 by letter dated June

23, 2008, to request the applicant to confirm if the corrective action program will increase the

sample size in the event aging effects are detected.

In the letter dated July 25, 2008, the applicant responded to RAI B.2.28-3 stating that

unacceptable inspection findings will be evaluated under the SSES corrective action program.

The evaluation done under the SSES corrective action program will identify appropriate

corrective actions, including the need to perform additional inspections.

On the basis that the applicant will evaluate unacceptable inspection findings under the SSES

corrective action program and take appropriate corrective action including the need to perform

additional inspections, the staff finds the response acceptable because the applicant is

consistent with the recommendations of the GALL AMP XI.M32 "monitoring and trending"

program element.

In the "acceptance criteria" program element, the GALL AMP XI.M32 states that any indication

or relevant conditions of degradation detected are evaluated. The LRA Section B.2.28 identifies

acceptance criteria as: no unacceptable loss of material (or wall thinning) that could result in a

loss of component intended function during the period of extended operation, as determined by

engineering evaluation. The staff issued RAI B.2.28-4 by letter dated June 23, 2008, to request

the applicant to explain why the acceptance criteria for AMP B.2.28 differ from the

recommendations of the GALL Report and to clarify what "no unacceptable loss of material (or

wall thinning)" means.

In the letter dated July 25, 2008, the applicant amended LRA Section B.2.28, Supplemental

Piping/Tank Inspection Program "acceptance criteria" program element to state:

Any indications or relevant conditions of degradation detected during the

inspections will be compared to pre-determined acceptance criteria. If the

acceptance criteria are not met, then the indications/conditions will be evaluated

3-59
under the SSES Corrective Action Program to determine whether they could

result in a loss of component intended function during the period of extended

operation.

The staff reviewed the applicant's response and finds that the amended "acceptance criteria"

program element is consistent with the recommendations provided in GALL AMP XI.M32, and

therefore the staff finds the response acceptable.

In a letter dated January 12, 2009, the applicant amended the scope of the Supplemental

Piping and Tanks Inspection Program to include the internal steel and stainless steel

emergency diesel generator exhaust piping, piping component, and piping element surfaces

that are exposed to the diesel exhaust environment (which is identified in LRA Table 3.0-1 as a

subsection of the ventilation air environment). The staff noted that the applicant made the

applicable amendment of this AMP in order to conform to the staff's recommendations in SRPLR Section 3.3.2.2.3.3 and the GALL AMR VII.H2-1, for the management of stress corrosion

cracking in stainless steel diesel generator exhaust piping components and in SRP-LR Section

3.3.2.2.7.3 and GALL AMR VII.H2-2, for the management of loss of material in steel stainless

steel emergency diesel generator exhaust piping components. The staff finds that the applicant

amendment of the LRA to include the internal surfaces of these components is acceptable

because it conforms to the staff's aging management recommendations in these SRP-LR and

GALL AMR sections that a valid AMP be credited to manage cracking and loss of material in

these diesel generator exhaust piping components. The staff's evaluations in SER Sections

3.3.2.2.3.3 and 3.3.2.2.7.3 provide additional details on why it is acceptable to credit this AMP

for aging management of these emergency diesel generator exhaust piping components.

Based on its review, the staff finds the Supplementary Piping/Tank Inspection Program

consistent with the program elements with the program elements of GALL AMP XI.32, and

therefore acceptable.

Operating Experience. The staff reviewed the operating experience described in LRA Section

B.2.28 and interviewed the applicant's technical personnel to confirm that the plant-specific

operating experience did not reveal any aging effects not bounded by the GALL Report. The

staff also confirmed that applicable aging effects and industry and plant-specific operating

experience have been reviewed by the applicant and are evaluated in the GALL Report.

The "operating experience" program element in the LRA states that the Supplementary

Piping/Tank Inspection is a new program and there is no plant-specific program operating

experience. Furthermore, the staff confirmed that the applicant has addressed operating

experience identified after the issuance of the GALL Report. However, for this program and for

other new AMPs where the applicant provided no current plant-specific operating experience,

the staff issued generic RAI B.2-1 by letter dated June 10, 2008, asking that the applicant

commit to provide documentation of plant-specific operating experience for staff review after the

program has been implemented, but prior to entering the period of extended operation.

In the letter dated July 8, 2008, the applicant responded to RAI B.2-1 and stated that operating

experience for new aging management programs described in LRA Appendix B will be gained

as these new programs are implemented during the period of extended operation. The

applicant stated that results of tests, inspections, and other aging management activities

conducted in accordance with these programs will be subject to confirmation and corrective

action elements of the SSES 10 CFR 50, Appendix B, quality assurance program and that

results will be subject to NRC review during regional inspections under existing NRC inspection

3-60
modules. The applicant further stated that one-time inspections will be performed prior to entry

to the period of extended operation to confirm the effectiveness of existing AMP and that these

programs are subject to review under NRC Inspection Procedure 71003, Post-Approval Site

Inspection for License Renewal.

The staff noted that the applicant's statement that inspection methods will be consistent with

industry practices is consistent with the "operating experience" program element for GALL AMP

XI.M32. The staff also noted that post-approval site inspections provide an opportunity for staff

review and assessment of the effectiveness of the applicant's Supplementary Piping/Tank

Inspection Program after the applicant has developed operating experience with that program.

The staff concludes that the corrective action program, based on internal and external plant

operating experience, would capture operating experience in the future to support the

conclusion that the effects of aging are adequately managed. On this basis, the staff finds this

program element acceptable and concludes that a separate commitment is not necessary.

The staff confirmed that the "operating experience" program element satisfies the criterion

defined in the GALL Report and in SRP-LR Section A.1.2.3.10. The staff finds this program

element acceptable.

UFSAR Supplement: In LRA Section A. 1.2.46 and Commitment No. 24 in Table A-i, the

applicant provided the UFSAR supplement for the Supplementary Piping/Tank Inspection

Program. The staff verified that the UFSAR supplement summary description for the

Supplementary Piping/Tank Inspection Program was in conformance with the staff's

recommended UFSAR supplement for the One-Time Inspection Program provided in Table 3.3-

2 of the SRP-LR.

Based on this review, the staff finds that UFSAR supplement Section A.1.2.46 provides an

acceptable UFSAR Supplement summary description of the applicant's Supplementary

Piping/Tank Inspection Program because it is consistent with the UFSAR supplement summary

description in the SRP-LR for the One-Time Inspection Program and because the applicant has

included in Table A-i, Commitment No. 24 to implement the Supplementary Piping/Tank

Inspection Program within the 10-year period prior to the period Of extended operation.

The staff reviewed this section and determines that the information in the UFSAR supplement

provides an adequate summary description of the program consistent with the SRP-LR, as

required by 10 CFR 54.21(d).

Conclusion. On the basis of its review of the applicant's Supplementary Piping/Tank Inspection

Program and the applicant's response to the staff's RAIs, the staff finds all program elements

consistent with the GALL Report. The staff concludes that the applicant has demonstrated that

the effects of aging will be adequately managed so that the intended functions will be

maintained consistent with the CLB for the period of extended operation, as required by 10 CFR

54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP and concludes that it

provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

3.0.3.1.17 Selective Leaching Inspection Program

Summary of Technical Information in the Application. In LRA Section B.2.29, the applicant

described the new Selective Leaching Program as consistent with GALL AMP XI.M33,

"Selective Leaching of Materials." This program combines the use of a visual inspection with a

hardness test on the external and internal surfaces of materials susceptible to selective

3-61
leaching, to determine whether the aging effect of loss of material due to selective leaching has

occurred.

Staff Evaluation. During its audit, the staff confirmed the applicant's claim of consistency with

the GALL Report. In comparing the elements in the applicant's program to those in GALL

AMP XI.M33, the staff noted the program elements in the applicant's AMP claim of consistency

with the GALL Report were consistent with GALL AMP XI.M33, with the exception of the one

program element aspect identified below that the staff determined required additional

clarification. The staff also confirmed that the plant program contains all of the elements of the

referenced GALL Report. The staff conducted onsite interviews with the applicant to confirm

these results.

The staff reviewed the applicant's Program Basis Document and confirmed that the program

scope includes all systems that could be susceptible to selective leaching. The staff noted that

this includes copper alloys (brass and bronze), cast iron, and ductile iron exposed to raw water,

treated water, groundwater (buried), indoor air with condensation, outdoor air, and fuel oil

environments. The staff further noted that twenty-five plant systems have this combination of

material and environment and include susceptible components that include piping and tubing,

valve bodies, pump and turbocharger casings, heat exchangers, coolers, chillers, hydrants,

sprinkler heads, strainers, level gauges, orifices, and heater sheaths. The staff finds the

applicant's Selective Leaching Program acceptable because it conforms to the

recommendations in GALL AMP XI.M33.

During the review of the applicant's Cooling Unit Inspection Program (SER Section 3.0.3.1.11),

the staff noted that the "scope of program" element in the LRA states that loss of material due

to crevice corrosion, pitting corrosion, and selective leaching of the copper-alloy cooler channel

in the control structure HVAC system. As stated in the GALL Report, selective leaching does

not cause a noticeable change in dimensions and is difficult to detect using visual and/or

volumetric detection techniques, which are the techniques used in the Cooling Unit Inspection

Program.

In RAI B.2.23-1, dated June 23, 2008, the staff requested that the applicant justify the use of

the Cooling Unit Inspection Program to manage loss of material due to selective leaching in the

control structure HVAC system. The staff also requested that the applicant explain why the

copper-alloy cooler channel was not included within the scope of the Selective Leaching

Inspection Program.

In the response to RAI B.2.23-1, dated July 25, 2008, the applicant stated that the LRA has

been amended to credit the Selective Leaching Inspection Program, in place of the Cooling

Unit Inspection Program, to manage loss of material due to selective leaching for the copper

alloy cooler channel in the control structure HVAC system.

Based on the review, the staff finds the applicant's response to RAI B.2.23-1 acceptable

because the applicant has amended the LRA to credit the Selective Leaching Program to

manage loss of material due to selective leaching for the copper-alloy cooler channel in the

control structure HVAC system. Therefore, the staff's concern described in RAI B.2.23-1 is

resolved.

Based on the review, the staff finds the Selective Leaching Program consistent with the

program elements in GALL AMP XI.M33 and therefore is acceptable.

3-62
Operatinq Experience. The applicant stated that the Selective Leaching Program is a new

program for which there is no OE and that inspection methods will be consistent with accepted

industry practices. For this program and for other new AMPs where the applicant provided no

current plant-specific OE, the staff issued a generic RAI.

In RAI B.2.1, dated June 10, 2008, the staff requested that the applicant commit to provide

documentation of plant-specific operating for staff review, after the program has been

implemented, but, prior to entering the period of extended operation.

In the response to RAI B.2.1, dated July 8, 2008, the applicant stated that OE for new AMPs

described in LRA Appendix B will be gained as these new programs are implemented during

the period of extended operation. The applicant stated that results of tests, inspections, and

other aging management activities conducted in accordance with these programs will be

subject to confirmation and corrective action elements of the Susquehanna 10 CFR Part 50,

Appendix B, Quality Assurance Program. Results will be subject to staff review during regional

inspections under existing staff inspection modules. The applicant stated that these new

programs will be implemented prior to, and continue through, the period of extended operation

and that OE will be gained for these programs as they are implemented. The applicant further

stated that test and inspection results that do not meet acceptance criteria for these new

programs will be evaluated under the applicant's corrective action program, which includes

requirements for identification of appropriate corrective actions and verification of the

effectiveness of corrective actions.

The staff noted the applicant's statement that inspection methods will be consistent with

industry practices is consistent with the "operating experience" program element for GALL

AMP XI.M33. The staff also noted that post-approval site inspections provide an opportunity for

the staff to review and assess the effectiveness of the applicant's Selective Leaching Program,

after the applicant has developed OE with that program. The staff concludes that the corrective

action program, based on internal and external plant OE, will capture OE to support the

conclusion that the effects of aging are adequately managed.

On this basis, the staff confirms that the "operating experience" program element satisfies the

criterion defined in the GALL Report and the guidance found in SRP-LR Section A.1 .2.3.10.

The staff finds this program element acceptable and concludes that a separate commitment is

not necessary.

UFSAR Supplement. The applicant provided the UFSAR supplement summary for the Selective

Leaching Program in LRA Section A.1.2.43 and Commitment No. 25 in Table A-1. The staff

reviewed this section and determines that the information in the UFSAR supplement provides

an adequate summary description of the program consistent with the SRP-LR, as required by

10 CFR 54.21(d). The staff confirms that the applicant has made a commitment to implement

this new program, after issuance of the renewed license and prior to entering the period of

extended operation.

Conclusion. On the basis of the review of the applicant's Selective Leaching Program and the

applicant's RAI responses, the staff finds all program elements consistent with the GALL

Report. The staff concludes that the applicant has demonstrated that effects of aging the will be

adequately managed so that the intended functions of these components 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 UFSAR supplement for this AMP and

3-63
concludes that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d) and therefore is acceptable.

3.0.3.1.18 Small Bore Class 1 Piping Inspection Program

Summary of Technical Information in the Application. In LRA Section B.2.31, the applicant

described the new Small Bore Class 1 Piping Inspection as consistent with GALL AMP XI.M35,

"One-Time Inspection of ASME Code Class 1 Small-Bore Piping." The applicant stated that the

program is a one-time inspection program to confirm the effectiveness of the BWR Water

Chemistry Program in mitigating loss of material and cracking for small bore Class 1 piping and

also to verify, by inspections for cracking, that reduction of fracture toughness due to thermal

embrittlement requires no additional aging management for small bore Class 1 piping. The

applicant also stated that the program is applicable to small bore ASME Code Class 1 piping

and piping components less than four inches nominal pipe size (<NPS 4), which includes pipes,

fittings, and branch connections, and that the inspection provides additional assurances that

either aging of small bore ASME Code Class 1 piping is not occurring or that the aging is

insignificant. The applicant further stated that implementation of the program is scheduled to be

completed during the 10-year period, prior to the period of extended operation (Commitment

No. 27, LRA Table A-1).

Staff Evaluation. During the audit, the staff reviewed the applicant's claim of consistency with

the GALL Report. The staff reviewed the applicant's AMP evaluation for the Small Bore Class 1

Piping Inspection Program, together with the applicant's program outline which provides

specific guidance for preparation of implementing procedures related to this new program. In

comparing the program description and elements in the applicant's AMP to those in GALL

AMP XI.M35, the staff noted a number of instances where the program description and

elements that the applicant claimed to be consistent with the GALL Report did not appear to be

consistent with the corresponding program element criteria recommended in GALL

AMP XI.M35. Furthermore, it appeared to the staff that for the one-time inspection of small-bore

Code Class 1 piping, the applicant combined recommendations in GALL AMP XI.M35 with

recommendations in GALL AMP XI.M32, "One-Time Inspection." The applicant's AMP resulting

from this combination was substantially different from GALL AMP XI.M35, with which the

applicant claimed consistency. The staff identified a need for additional clarification and issued

four RAls to support the staffs evaluation of the applicant's Small Bore Class 1 Piping

Inspection program. The staff evaluates the applicant's responses to these RAIs in the following

discussions.

The applicant stated in the LRA that the Small Bore Class 1 Piping Inspection Program, is

a new program that will be consistent with GALL AMP XI.M35. The applicant further stated

that the GALL AMP XI.M35 is credited only with managing the aging effect of cracking, and

the only examination technique used is volumetric examination. However, in the LRA, both

in the program description and in several aging management review line items, the Small

Bore Class 1 Piping Inspection is credited with confirming effectiveness of the BWR Water

Chemistry Program in mitigating the aging effect of loss of material using "nondestructive

examinations (including volumetric techniques)."

In RAI B.2.31-1, dated June 23, 2008, the staff requested that the applicant provide the

basis for categorizing the Small Bore Class 1 Piping Inspection Program as being

consistent with the GALL AMP XI.M35 when the Small Bore Class 1 Piping Inspection

Program implies that non-volumetric examination techniques may be used as an alternate

basis for performing the one-time inspections of the small bore Class 1 piping components

3-64
and when this AMP is credited with managing an aging effect (i.e., loss of material) that is

not within the scope of the GALL AMP XI.M35. The staff also requested that the applicant

clarify whether the LRA will be amended to identify these aspects of the program as

exceptions to GALL AMP XI.M35 and; if so, justify the basis for crediting these exceptions

for aging management of small bore Class 1 piping components.

In its response to RAI B.2.31-1, dated July 25, 2008, the applicant stated the following:

The SSES LRA is amended [as shown in a multi-page attachment] to

demonstrate that AMP B.2.31, Small Bore Class 1 Piping Inspection, is

consistent with GALL AMP XI.M35 with no exceptions.

AMP B.2.31 is credited for managing the aging effect of cracking, as a result of

stress corrosion or thermal or mechanical loading, and one-time volumetric

examination is the acceptable method for confirming that cracking of ASME

Code Class 1 small-bore piping is not occurring.

AMP B.2.22, Chemistry Program Effectiveness Inspection, is credited with

verifying the effectiveness of AMP B.2.2, BWR Water Chemistry Program, to

mitigate loss of material.

The applicant provided a multi-page attachment (Attachment 3 to PLA-6391, LRA Revisions in

Response to RAIs B.2.31-1 and B.2.31-3) as part of the response, in which the applicant

described revisions to LRA text and tables affected by its responses to RAls B.2.31-1 and

B.2.31-3.

The staff noted the changes affecting text related to AMP descriptions and the AMR results

tables as well as evaluations in the LRA.

The AMP related text sections in the LRA affected by the applicant's changes are as

follows:

Section A.1.2.44, the UFSAR supplement describing the Small Bore Class 1

Piping Inspection was revised to delete aging management for loss of material

and to state: "Small Bore Class 1 Piping Inspection is a one-time inspection to

detect cracking resulting from thermal and mechanical loading or intergranular

stress corrosion. The inspection will provide assurance that either cracking of

small bore Class 1 piping is not occurring or the cracking is insignificant, such

that an aging management program (AMP) is not warranted. The inspection will

also confirm the effectiveness of the BWR Water Chemistry Program in

mitigating cracking due to intergranular stress corrosion."

Table A-1, "SSES License Renewal Commitments," was revised to state in

Commitment No. 27 that the Small Bore Class 1 Piping Inspection will verify that

cracking is not occurring and thereby validate the effectiveness of the Chemistry

Program to mitigate cracking.

Section B.2.22, "Chemistry Program Effectiveness Inspection," was revised to

include reactor coolant system (RCS) pressure boundary components within the

scope of the program.

3-65
Section B.2.31, Small Bore Class 1 Piping Inspection, was revised in multiple

places consistent with removing management of loss of material from the scope

of the program and relocating it into the Chemistry Program Effectiveness

Inspection program. The changes clarified that the focus of the Small Bore

Class 1 Piping Inspection Program is to detect cracking resulting from thermal

and mechanical loading or intergranular stress corrosion and that the

non-destructive examination will use volumetric techniques, consistent with the

recommendations in GALL AMP XI.M35. The applicant stated that the program

may also include destructive examinations.

LRA Appendix C, "Response to BWRVIP Applicant Action Items, Discussion of

BWRVIP-74-A," was revised to state that effectiveness of the BWR Water

Chemistry Program to mitigate cracking in the flange leak detection lines will be

verified by the Chemistry Program Effectiveness Inspection (rather than the

previously identified Small Bore Class 1 Piping Inspection Program).

The AMR results tables and evaluations in the LRA affected by the applicant's changes are as

follows:

" Table 3.1.1, "Summary of Aging Management Programs for Reactor Vessel, Internals,

and Reactor Coolant System"

" Table 3.1.2-3, "Aging Management Review Results - Reactor Coolant System Pressure

Boundary"

" Section 3.1.2.2.2.1, "BWR Top Head and Top Head Nozzles, PWR Steam

Generator Shell Assembly"

" Section 3.1.2.2.2.3, "Flanges, Nozzles, Penetrations, Pressure Housings, Safe

Ends, and Vessel Shells, Heads, and Welds"

" Section 3.1.2.2.4.1, "BWR Top Head Enclosure Vessel Flange Leak Detection

Lines"

" Section 3.1.2.2.8.1, "Stainless Steel Jet Pump Sensing Lines"

The staff reviewed all of the applicant's LRA changes, noting that the changes removed the

activities associated with monitoring for loss of material from the scope of the Small Bore

Class 1 Piping Inspection Program and reassigned them to the Chemistry Program

Effectiveness Inspection, consistent with the GALL AMP XI.M32. By making these changes, the

applicant fully addressed and resolved the staff's concerns with the applicant's Small Bore

Class 1 Piping Inspection program, as initially described in the LRA, combined elements of the

GALL AMP XI.M32 with elements of GALL AMP XI.M35. However, in its review of the

applicant's LRA changes, the staff noted the following three instances in which the as-revised

LRA did not appear to conform with the applicant's general approach of removing activities

associated with monitoring for loss of material from the scope of the Small Bore Class 1 Piping

Inspection Program and reassigning them to the Chemistry Program Effectiveness Inspection:

The change in LRA Section 3.1.2.2.4.1, "BWR Top Head Enclosure Vessel Flange Leak

Detection Lines," that replaced use of the Small Bore Class 1 Piping Inspection Program

with the CPEI for monitoring the aging effect of cracking due to SCC in stainless steel

lines exposed to treated water, did not appear to be appropriate.

3-66
" The change in LRA Section 3.1.2.2.8.1, "Stainless Steel Jet Pump Sensing Lines," that

replaced use of the Small Bore Class 1 Piping Inspection Program with the CPEI for

monitoring the aging effect of cracking in the stainless steel lines external to the vessel,

did not appear to be appropriate.

" The change in LRA Appendix C, "Response to BWRVIP Applicant Action Items," which

was made for consistency with the change in LRA Section 3.1.2.2.4.1, also did not

appear to be appropriate.

In RAI B.2.31-5, the staff requested that the applicant explain the basis for these changes.

In addition, the staff noted that in making the changes to the LRA, the applicant introduced

wording that referred to "significant" and "insignificant" cracking.

In RAI B.2.31-6, the staff requested that the applicant clarify the meaning of "significant" and

"insignificant" cracking or eliminate the problematic wording.

In its response to RAI B.2.31-5, dated September 11, 2008, the applicant reversed the changes

that had been made in LRA Sections 3.1.2.2.4.1 and 3.1.2.2.8.1 and Appendix C, and restored

these affected parts of the LRA to the version originally submitted by the applicant.

Based on the review, the staff finds the applicant's response to RAI B.2.31-5 acceptable

because the applicant has reversed the changes to the LRA that were made in error and

restored the LRA text affected by these changes to the originally submitted version of these

LRA Sections, so that monitoring for loss of material will be performed by the CPEI and

monitoring for cracking will be performed by the Small Bore Class 1 Piping Inspection Program.

Therefore, the staff's concern described in RAI B.2.31-5 is resolved.

In the response to RAI B.2.31-6, dated September 11, 2008, the applicant revised text in LRA

Section A.1.2.44 to state that the Small Bore Class 1 Piping Inspection will provide assurance

that cracking of small bore Class 1 piping is not occurring or an evaluation of any detected

crack indications will be performed to justify continued operation with no further monitoring,

such that an AMP is not warranted. The applicant also revised the "program description" in LRA

Section B.2.31 to include a similar statement and also to state that should cracking be revealed

by a one-time inspection or previous OE, periodic inspection will be performed under a

plant-specific AMP, unless cracking is evaluated and determined to be acceptable for continued

operation during the period of extended operation, with no further monitoring. The applicant

also revised the "monitoring and trending" program element in LRA Section B.2.31 to include a

similar statement.

Based on the review, the staff finds the applicant's response to RAI B.2.31-6 acceptable

because the applicant has removed problematic wording from the LRA and has provided

acceptable criteria for the disposition of crack indications, if found by the Small Bore Class 1

Piping Inspection Program. Therefore, the staff's concern described in RAI B.2.31-6 is resolved.

The staff reviewed the composite of LRA changes made by the applicant in response to

RAI B.2.31-1, as amended by the applicant's responses to RAIs B.2.31-5 and B.2.31-6, and

determines that the as-revised program description and program elements for the applicant's

Small Bore Class 1 Piping Inspection Program are consistent with GALL AMP XI.M35.

3-67
Based on the review, the staff finds the applicant's response to RAI B.2.31 -1 acceptable

because the applicant has appropriately revised the LRA sections and table to ensure

consistency with GALL AMP XI.M35. Therefore, the staff's concerns described in RAI B.2.31-1

are resolved.

The applicant stated in the LRA that the Small bore Class 1 Piping Inspection Program will be

used to monitor both the aging effect of cracking and the aging effect of loss of material in

Class 1 small bore piping. However, the environmental stressors that may lead to cracking are

not necessarily the same as the environmental stressors that may lead to loss of material.

In RAI B.2.31-2, dated June 23, 2008, the staff requested that the applicant clarify the selection

processes and criteria that will be applied to ensure that the program will select and schedule

inspections for the most limiting small bore Class 1 piping locations for both of these aging

effects.

In the response to RAI B.2.31-2, dated July 25, 2008, the applicant stated:

The Small Bore Class 1 Piping Inspection, as amended in the response to

RAI B.2.31-1, is credited to manage only cracking. As such, in the selection of

the small bore Class 1 piping locations for the one-time inspection, there is no

need to consider environmental stressors that may lead to loss of material.

The selection criteria to be applied as part of this program are provided in the

"Monitoring and Trending" program element discussion in LRA Section B.2.31.

The staff notes that the applicant's revision to the LRA eliminated management of loss of

material from the scope of the Small Bore Class 1 Piping Inspection Program. Because the

revised AMP manages only the aging effect of cracking, which is consistent with the

recommendations in GALL AMP XI.M35, the potential issue addressed in RAI B.2.31-2 was

eliminated by the LRA amendment that resulted from RAI B.2.31-1.

Based on the review, the staff finds the applicant's response to RAI B.2.31-2 acceptable

because the applicant has revised the Small Bore Class 1 Piping Inspection Program to

manage only the aging effect of cracking, consistent with the recommendations in the GALL

AMP XI.M35. Therefore, the staff's concern described in RAI B.2.31-2 is resolved.

In describing the Small Bore Class 1 Piping Inspection Program, under the program

element "monitoring and trending" in LRA Section B.2.31, the applicant stated that actual

inspection locations will be based on physical accessibility, exposure levels, nondestructive

examination techniques, and locations identified in NRC Information Notice (IN) 97-46.

IN 97-46 was written relative to cracking that was detected in small bore unisolable

high-pressure injection piping at Oconee Unit 2, which is a pressurized water reactor

(PWR).

In RAI B.2.31-3, dated June 23, 2008, the staff requested that the applicant justify the

basis for applying the Oconee Unit 2 experience as applicable OE for the Small Bore

Class 1 Piping Inspection Program, and clarify how the information contained in IN 97-46

will be applied in the selection process in order to ensure that the small bore Class 1 piping

locations most susceptible to cracking, as a result of thermal and mechanical loading or

SCC, will be selected for the one-time inspection.

3-68
In the response to RAI B.2.31-3, dated July 25, 2008, that applicant stated:

The considerations in determining the inspection for AMP B.2.31, Small Bore

Class 1 Piping Inspection, include operating experience and related industry

guidance documents. Operating experience to date includes NRC Information

Notice (IN) 97-46, which was issued to all holders of operating licenses or

construction permits for power reactors (BWRs and PWRs). IN 97-46 states that

a gap between a thermal sleeve and the associated safe-end allowed

intermittent mixing of the hot reactor coolant and the cooler makeup water

flowing through the pipeline, resulting in alternating heating and cooling of the

weld between the pipe and the safe-end. This phenomenon was a likely

contributor to the fatigue cracking that occurred at the weld. PPL will consider

the potential for piping locations to experience intermittent mixing between hot

and cold flows in the sample selection of inspection locations for AMP B.2.31.

The SSES LRA is amended to state, more generally, that operating experience

will be considered, without referencing a specific document such as IN-97-46.

In evaluating the applicant's response, the staff reviewed the changes made by the applicant in

the LRA description of program element "monitoring and trending" for the Small Bore Class 1

Piping Inspection Program. The staff notes that the applicant's changes replace the previous

reference to IN 97-46 with a more general statement that applicable OE will be included in

determining the actual inspection locations.

Based on its review, the staff finds the applicant's response to RAI B.2.31-3 acceptable

because the applicant has amended the LRA to eliminate the reference to IN 97-46, but

continue to state that applicable OE will be considered. Therefore, the staff's concern described

in RAI B.2.31-3 is resolved.

In describing the Small Bore Class 1 Piping Inspection, under program element "detection

of aging effects" in LRA Section B.2.31, the applicant stated that it found cracking due to

vibrational fatigue of small bore piping and is performing augmented inspections as part of

the ISI Program.

In RAI B.2.31-4, dated June 23, 2008, the staff requested that the applicant identify the

small bore piping components that experienced the vibrational-induced cracks and the

augmented inspection techniques that resulted in the detection of the cracking in the piping

components. Additionally, the staff requested that the applicant clarify whether it has taken

appropriate corrective actions either to repair the flaw indications in the components or to

replace the impacted components, and identify whether those components' locations will be

reinspected in the future. If these components will be reinspected in the future, identify and

provide technical justification for the inspection technique and frequency that will be used.

In the response to RAI B.2.31-4, dated July 25, 2008, the applicant stated:

SSES experienced nine socket weld failures (leaks) between 1992 and 2005. All

of the leaks were on small bore piping attached to the Unit 2 reactor recirculation

system. No socket weld failures have been experienced on Unit 1. All of the

leaking welds were cut out and replaced, or entirely eliminated by modification of

the pipeline.

3-69
In response to the socket weld failures experienced at SSES and other plants,

the SSES ISI group developed a shear wave ultrasonic (UT) inspection

technique to volumetrically inspect socket welds. The shear wave UT is an

augmented technique that has been used extensively during plant outages since

2000 to inspect welds that had been determined to be at-risk for vibrational

fatigue due to their proximity to a vibration source (e.g., a recirculation pump).

Every weld with a crack-like indication was either cut-out and replaced or

eliminated by a piping modification. Numerous modifications were made to

replace socket-welded fittings with solid pipe (using pipe bends, instead of

fittings) and to after the natural frequency of the piping to avoid excitation by the

vibration source. All new socket welds were made with the EPRI 2x1

configuration to improve fatigue resistance. To date, none of the 2x1 welds have

resulted in a leaking crack at SSES.

Recent inspection results have indicated a substantial reduction in the number of

indications. PPL is confident that vibrational fatigue on the subject piping welds

has been successfully addressed. As such, the necessity to continue volumetric

inspections under the augmented ISI program is currently being evaluated.

Based on its review, the staff finds the applicant's response to RAI B.2.31-4 acceptable

because the applicant has provided detailed summary information about its methodology for

and history of small bore pipe examination, and because the applicant's response supports a

conclusion that previous problems with vibrational fatigue on small bore piping welds have been

successfully addressed. Therefore, the staff's concern described in RAI B.2.31-4 is resolved.

The staff notes that in a letter dated September 30, 2008, the applicant revised LRA

Section B.2.31 by deleting the discussions related to small bore piping failures attributed to

vibrational (high-cycle) fatigue. The applicant made this change because the Small Bore

Class 1 Piping Inspection Program is credited with managing age-related cracking due to stress

corrosion or thermal and mechanical loading, but not with managing cracking due to high-cycle,

vibrational fatigue, which is a short-term failure mechanism, not a long term aging mechanism.

The staff finds this LRA change acceptable because it deletes from the LRA the discussion of a

short-term failure mechanism that is not managed by the Small Bore Class 1 Inspection

Program, and because the Small Bore Class 1 Inspection Program, including all revisions to the

LRA, is consistent with the corresponding AMP as described in the GALL Report.

Based on its review, and resolution of the related RAIs as described above, the staff finds the

Small-Bore Class 1 Piping Inspection Program consistent with program elements of GALL

AMP XI.M35 and therefore is acceptable.

Operating Experience. The applicant stated that the Small Bore Class 1 Piping Inspection

Program is a new one-time inspection activity for which there is no OE and that inspection

methods will be consistent with accepted industry practices. For this program and for other new

AMPs where the applicant provided no current plant-specific OE, the staff issued a generic RAI.

In RAI B.2.1, dated June 10, 2008, the staff requested that the applicant commit to provide

documentation of plant-specific operating for staff review, after the program has been

implemented, but, prior to entering the period of extended operation.

3-70
In the response to RAI B.2.1, dated July 8, 2008, the applicant stated that OE for new AMPs

described in LRA Appendix B will be gained as these new programs are implemented during

the period of extended operation. The applicant further stated that results of tests, inspections,

and other aging management activities conducted in accordance with these programs will be

subject to confirmation and corrective action elements of the Susquehanna 10 CFR Part 50,

Appendix B, Quality Assurance Program. Results will be subject to staff review during regional

inspections, under existing staff inspection modules. The applicant also stated that one-time

inspections will be performed prior to entry into the period of extended operation to confirm the

effectiveness of existing AMPs, and that these programs are subject to review under NRC

Inspection Procedure 71003, "Post-Approval Site Inspection for License Renewal."

The staff noted the applicant's statement that inspection methods will be consistent with

industry practices is consistent with the "operating experience" program element for GALL

AMP XI.M35. The staff also noted that post-approval site inspections provide an opportunity for

staff to review and assess the effectiveness of the applicant's Small Bore Class 1 Piping

Inspection Program, after the applicant has developed OE with that program. The staff

concludes that the corrective action program, based on internal and external experience, will

capture OE to support the conclusion that the effects of aging are adequately managed.

On this basis, the staff confirms that the "operating experience" program element satisfies the

criterion defined in the GALL Report and the guidance found in SRP-LR Section A.1.2.3.10.

Therefore, the staff finds this program element acceptable and concludes that a separate

commitment is not necessary.

UFSAR Supplement. The applicant provides the UFSAR supplement summary for the Small

Bore Class 1 Piping Inspection Program in LRA Section A.1.2.44 and Commitment No. 27 in

Table A-I. The staff reviewed this section, as revised in response to RAI B.2.31-1, and finds it

acceptable because it is consistent with the corresponding program description in SRP-LR

Table 3.1-2. The staff also notes that the applicant has committed to implement the Small Bore

Class 1 Piping Inspection Program for aging management of applicable components during the

10 years prior to the period of extended operation.

The staff determines that the information in the UFSAR supplement is an adequate summary

description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of the review of the applicant's Small Bore Class 1 Piping Inspection

Program, the staff finds that, after incorporation of all LRA and program revisions made in

response to the staff's RAIs, all program elements are consistent with the GALL Report. The

staff concludes that the applicant has demonstrated that effects of aging will be adequately

managed so that the intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the

UFSAR supplement for this AMP and concludes that it provides an adequate summary

description of the program, as required by 10 CFR 54.21(d) and therefore is acceptable.

3.0.3.1.19 Inservice Inspection (ISI) Program - IWE

Summary of Technical Information in the Application. In LRA Section B.2.34, the applicant

described the existing ISI Program - IWE as consistent with GALL AMP XI.S1 "ASME

Section X1, Subsection IWE."

3-71
The applicant stated that the ISI Program - IWE is implemented through plant procedures which

provide for ISI of Class MC and metallic liners of Class CC components. Section 50.55a of

10 CFR requires the use of the examination requirements in the ASME Code, Section XI,

Subsection IWE, for steel liners of concrete containments and other containment components.

The applicant also stated that it has implemented ASME Code Section XI, Subsection

IWE, 1998 Edition with the 2000 Addenda, and will adopt new ASME Code editions and

addenda, consistent with the provisions of 10 CFR 50.55a, during the period of extended

operation.

Staff Evaluation. During the onsite review, the staff reviewed the applicant's claim of

consistency with the GALL Report. The staff interviewed the applicant's technical staff and

reviewed the applicant's ASME Code Section XI, Subsection IWE Program onsite basis

documents to determine their consistency with GALL AMP XI.S1. Specifically, the staff

reviewed the program elements and associated onsite documents and found that they are

consistent with the GALL Report. On the basis of its review, the staff concludes that the

applicant's ISI Program - IWE provides assurance that the steel containments (Class MC) and

steel liners for concrete containments (Class CC) will be adequately managed.

Based on its review, the staff finds the applicant's ISI Program - IWE consistent with the

program elements of GALL AMP XI.S1 and therefore is acceptable.

Operatingq Experience. The staff also reviewed the applicant's OE described in LRA

Section B.2.34 and some of the applicant's onsite basis documents, including some samples of

condition reports, and interviewed the applicant's technical staff to confirm that the plantspecific OE did not reveal any degradation not bounded by industry experience. In the

application and during the onsite review, the applicant explained that the OE of the ISI Program

- IWE activities shows no adverse trend of program performance. The staff noted that previous

SSES IWE inspections have identified age-related degradation including flaking, discoloration,

light to heavy pitting, and corrosion. The staff also noted that underwater containment

suppression chambers were inspected by VT-3 certified divers. Metal loss appears to have

progressed slowly and localized pitting is below the threshold values. The staff further noted

that deficiencies were further evaluated and corrected by the applicant in accordance with the

ISI Program - IWE. The documents reviewed by the staff provided assurance that the program

is capturing degradation and correcting it in accordance with ASME Code Section XI. The

applicant also established periodic IWE inspections in which all accessible surfaces of the steel

containments and steel liners for concrete containments are visually inspected for the duration

of plant operation. The staff's OE review has concluded that administrative controls are

effective in detecting age-related degradation and in initiating corrective action. The staff did not

identify any age-related related issues not bounded by the industry OE.

On this basis, the staff confirms that the "operating experience" program element satisfies the

criterion defined in the GALL Report and the guidance found in SRP-LR Section A.1.2.3.10.

Therefore, the staff finds this program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement summary for the ISI

Program - IWE in LRA Section A.1.2.24, Commitment No. 29. The staff reviewed this section

and determines that the information in the UFSAR supplement is an adequate summary

description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of its review of the applicant's ISI Program - IWE, the staff finds all

program elements consistent with the GALL Report. The staff concludes that the applicant has

3-72
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 UFSAR supplement for this

AMP and concludes that it adequately describes the program, as required by 10 CFR 54.21(d)

and therefore is acceptable.

3.0.3.1.20 ISI Program - IWL

Summary of Technical Information in the Application. In LRA Section B.2.35, the applicant

described the existing ISI Program - IWL as consistent with GALL AMP XI.S2, "ASME

Section XI, Subsection IWL."

The ISI Program - IWL consists of periodic visual inspections of the reinforced concrete

containment structures for Units 1 and 2. The applicant stated in the LRA that no significant

aging effects have been identified for the concrete containment structures.

Staff Evaluation. During its review, the staff reviewed the applicant's claim of consistency with

the GALL Report. The staff interviewed the applicant's technical staff and reviewed the

applicant's ISI Program - IWL onsite basis documents to determine their consistency with GALL

AMP XI.S2. Specifically, the staff reviewed the program elements and associated onsite

documents and found that they are consistent with the GALL Report. On the basis of its review,

the staff concludes that the applicant's ISI Program -IWL provides assurance that the reinforced

concrete containment structures will be adequately managed.

Based on its review, the staff finds the applicant's ISI Program - IWL consistent with the

program elements of GALL AMP XI.S2 and therefore is acceptable.

Operating Experience. The staff also reviewed the applicant's OE described in LRA

Section B.2.35 and some of the applicant's onsite basis documents, including inspection data

and summaries, and interviewed the applicant's technical staff to confirm that the plant-specific

OE did not reveal any degradation not bounded by industry experience. In the application and

during the onsite review, the applicant explained that the OE of the ISI Program - IWL activities

shows no adverse trend of program performance. The staff noted that previous IWL inspections

have identified minor exterior surface cracks on the containment surface. The staff also noted

that deficiencies were documented, further evaluated, and corrected, if necessary, in

accordance with the ISI Program - IWL. For example, visual examinations in 2000 discovered

surface cracking on the containment exterior. The applicant provided documentation showing

the cracking to be less than the allowable values in accordance with American Concrete

Institute (ACl) 224R, Table 4.1 and acceptable pursuant to its applicable plant specification.

The staff further noted that the applicant established periodic containment concrete IWL

inspections in which all accessible external surfaces containment buildings are visually

inspected for the duration of plant operation. The staff's OE review has concluded that

administrative controls are effective in detecting age-related degradation and initiating

corrective action. The staff did not identify any age-related issues not bounded by the industry

OE.

On this basis, the staff confirms that the "operating experience" program element satisfies the

criterion defined in the GALL Report and the guidance found in SRP-LR Section A.1.2.3.10.

Therefore, the staff finds this program element acceptable.

3-73
UFSAR Supplement. The applicant provided the UFSAR supplement summary for the ISI

Program - IWL in LRA Section A.1.2.26 and Commitment No. 31 in Table A-1. The staff

reviewed this section and determines that the information in the UFSAR supplement is an

adequate summary description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of the review of the applicant's ISI Program - IWL, the staff finds all

program elements consistent with the GALL Report. The staff concludes that the applicant has

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21 (a)(3). The staff also reviewed the UFSAR supplement for this

AMP and concludes that it provides an adequate summary of the program, as required by

10 CFR 54.21(d) and therefore, is acceptable.

3.0.3.1.21 ISI Program - IWF

Summary of Technical Information in the Application. In LRA Section B.2.36, the applicant

described the existing ISI Program - IWF as consistent with GALL AMP XI.S3, "ASME

Section XI, Subsection IWF."

The applicant stated that the ISI Program - IWF is implemented through plant procedures,

which provide for periodic visual ISI of Class 1, 2, and 3 component supports for loss of

mechanical function and material. Section 50.55a of 10 CFR requires the use of the

examination requirements pursuant to ASME Code, Section XI, Subsection IWF, for ASME

Code Class 1, 2, 3, and MC piping and components and their associated supports. The

applicant also stated that it has implemented ASME Code Section XI, Subsection IWF, 1998

Edition with the 2000 Addenda, and will adopt new ASME Code editions and addenda,

consistent with the provisions of 10 CFR 50.55a, during the period of extended operation.

Staff Evaluation. During its onsite review, the staff reviewed the applicant's claim of consistency

with the GALL Report. The staff interviewed the applicant's technical staff and reviewed the

applicant's ISI Program - IWF onsite basis documents to determine their consistency with the

GALL AMP XI.S3. Specifically, the staff reviewed the program elements and associated onsite

documents and found that they are consistent with the GALL Report. On the basis of the

review, the staff concludes that the applicant's ISI Program - IWF provides assurance that the

ASME Code Class 1, 2, and 3 component supports will be adequately managed.

Based on its review, the staff finds the applicant's ISI Program - IWF consistent with the

program elements of GALL AMP XI.S3 and therefore is acceptable.

Operatinq Experience. The staff also reviewed the applicant's OE described in the LRA

Section B.2.36 and some of the applicant's onsite basis documents, including some samples of

condition reports (CR), and interviewed the applicant's technical staff to confirm that the plantspecific OE did not reveal any degradation not bounded by industry experience. In the

application and during the onsite review, the applicant explained that the OE of the ISI Program

- IWF activities shows no adverse trend of program performance. The staff noted in the LRA

OE that previous IWF inspections have identified non aging-related degradation such as bent

rods on spring can supports and sway struts. Deficiencies were further evaluated and corrected

in accordance with the ISI Program - IWF. During its onsite review, the staff requested that the

applicant provide more information about the bent spring can supports described in the OE of

the LRA. The applicant provided the CRs which detailed the finding and the resolution. The staff

reviewed the documents which provided assurance that the applicant's program captures

3-74
degradation and corrects it, in accordance with ASME Code Section XI. The applicant has

established periodic IWF inspections in which ASME Code Class 1, 2, and 3 component

supports are visually inspected for the duration of plant operation. The staff's OE review

concludes that the applicant's administrative controls are effective in detecting age-related

degradation and initiating corrective action. The staff did not identify any age-related related

issues not bounded by the industry OE.

On this basis, the staff confirms that the "operating experience" program element satisfies the

criterion defined in the GALL Report and the guidance found in SRP-LR Section A.1.2.3.10.

Therefore, the staff finds this program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement summary for the ISI

Program - IWF in LRA Section A.1.2.25 and Commitment No. 30 in Table A-I. The staff

reviewed this section and determines that the information in the UFSAR supplement is an

adequate summary description of the program, as required by 10 CFR 54.21(d).

Conclusion. On the basis of the review of the applicant's IS[ Program - IWF, the staff finds all

program elements consistent with the GALL Report. The staff concludes that the applicant has

demonstrated that the effects of aging will be adequately managed so that the intended

functions will be maintained consistent with the CLB for the period of extended operation, as

required by 10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this

AMP and concludes that it adequately describes the program, as required by 10 CFR 54.21(d)

and therefore is acceptable.

3.0.3.1.22 Containment Leakage Rate Test Program

Summary of Technical Information in the Application. In LRA Section B.2.37, the applicant

described the existing Containment Leakage Rate Test Program as consistent with the GALL

AMP XI.S4, "10 CFR Part 50, Appendix J." The applicant uses Option B, the performancebased approach, to implement the requirement of containment leak rate monitoring and testing.

The 10 CFR Part 50, Appendix J Program monitors leakage rates through the containment

pressure boundary, including penetrations and access openings. Containment leak rate tests

assure that leakage through the primary containment and systems and components penetrating

primary containment does not exceed the acceptance criteria limits.

Staff Evaluation. During its onsite review, the staff reviewed the applicant's claim of consistency

with the GALL Report. The staff interviewed the applicant's technical staff and reviewed the

applicant's Containment Leakage Rate Test Program onsite basis documents to determine their

consistency with the GALL AMP XI.S4. Specifically, the staff reviewed the program elements

and associated onsite documents and found that they are consistent with the GALL Report. On

the basis of the review, the staff concludes that the applicant's Containment Leakage Rate Test

Program provides assurance that leakage through primary containment and system and

components penetrating primary containment will be adequately managed.

Based on the review, the staff finds the applicant's Containment Leakage Rate Test Program

consistent with the program elements of GALL AMP XI.S4 and therefore is acceptable.

Operatinq Experience. The staff also reviewed the applicant's OE described in LRA

Section B.2.37 and some of the applicant's onsite documents, including some samples of

condition reports, and interviewed the applicant's technical staff to confirm that the plant3-75
specific OE did not reveal any degradation not bounded by industry experience. The staff found

that the most recent containment structure integrated leak rate tests were performed in

April 2006 and 2007 for Units 1 and 2, respectively. The results were below the plant limits

found in the technical specifications, and demonstrate the leak tightness of the containments.

The staff noted that there were no instances of Appendix J test failures due to causes other

than valve or flange seat leakage. For these failures, all conditions were evaluated and

corrected. The staff also reviewed a CR which the applicant documented corrosion discovered

on an access hatch during the IWE inspection. The corrosion was removed and all four door

seals were replaced. The staff did not identify any age-related issues not bounded by the

industry OE.

On this basis, the staff confirms that the "operating experience" program element satisfies the

criterion defined in the GALL Report and in SRP-LR Section A.1.2.3.10. Therefore, the staff

finds this program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement summary for the

Containment Leakage Rate Test Program in LRA Section A. 1.2.15 and Commitment No. 32 in

Table A-1. The staff reviewed this section and determines that the information in the UFSAR

supplement is an adequate summary description of the program, as required by

10 CFR 54.21(d).

Conclusion. On the basis of the review of the applicant's Containment Leakage Rate Test

Program, the staff finds all program elements consistent with the GALL Report. The staff

concludes that the applicant has demonstrated that the effects of aging will be adequately

managed so that the intended functions will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the

UFSAR supplement for this AMP and concludes that it adequately describes the program, as

required by 10 CFR 54.21(d) and therefore is acceptable.

3.0.3.1.23 Non-EQ Electrical Cables and Connections Visual Inspection Program

Summary of Technical Information in the Application. In LRA Section B.2.41, the applicant

described the Non-Environmental Qualification (EQ) Electrical Cables and Connections Visual

Inspection Program as a new program that is consistent with the GALL AMP XI.E1, "Electrical

Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification

Requirements." The applicant stated that the applicable electrical components will perform their

intended function(s) for the period of extended operation. The applicant also stated that the

program provides for the periodic visual inspection of accessible, non-EQ electrical cables and

connections, in order to determine if age-related degradation is occurring, particularly in plant

areas with high temperatures and/or high radiation levels.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff reviewed and compared the "scope of program," "preventative actions," "parameters monitored/detected," "detection of aging effects," "monitoring and trending," "acceptance criteria," and "operating experience" program elements of the AMP to the

corresponding program element criteria in the GALL AMP XI.E1.

The staff compared the program elements in the applicant's program to those in

GALL AMP XI.E1 to verify that the program elements in the applicant's AMP, which the LRA

identified as consistent with the GALL Report, were consistent with the corresponding program

3-76
element criteria recommended in the program elements of the GALL AMP XI.E1. The staff

determined that additional information was required to complete its review.

The GALL AMP XI.E1 considers the technical information and guidance provided in

NUREG/CR-5643, Institute for Electrical and Electronic Engineers (IEEE) Standard P1205,

SAND 96-0344, and EPRI TR-109619.

In LRA Section B.2.41, the applicant stated that this program is consistent with the GALL

Report; however, the applicant did not provide technical information and guidance as

referenced in the GALL AMP XI.E1.

In RAI B.2.41-1, dated July 3, 2008, the staff requested that the applicant provide the specific

industry guidance or explain why the guidance was not necessary.

In its response to RAI B.2.41-1, dated August 5, 2008, the applicant stated that the technical

documents listed in GALL AMP XI.E1 (e.g., NUREG/CR-5643, IEEE Standard P1205,

SAND96-0344, and EPRI TR-109619) provide information pertinent to plant environmental

conditions, environmental effects (particularly with regard to adverse environmental conditions),

evaluation of environmental conditions and effects, degradation mechanisms, and aging

effects. The applicant also stated that the information is relevant to the understanding of

electrical cable aging mechanisms and effects, and is also relevant to potential inspection

methods necessary to identify degradation. The applicant further stated that the technical

guidance contained in these staff and industry reports will be used as input to develop this

AMP.

Based on the review, the staff finds the applicant's response to RAI B.2.41-1 acceptable

because the applicant has identified the appropriate references that are consistent with those in

the GALL AMP XI.E1. Therefore, the staff's concern described in RAI B.2.41-1 is resolved.

The GALL XI.E1 states that an adverse localized environment is a condition in a limited plant

area that is significantly more severe than the specified service environment for the cable. The

staff reviewed the plant basis document associated with the Non-EQ Electrical Cables and

Connections Visual Inspection Program and noted that the applicant did not define the criteria

for an adverse localized environment.

In RAI B.2.41-2, dated July 3, 2008, the staff requested that the applicant discuss how an

adverse localized environment is determined based on the most limiting service environment of

cables (i.e., radiation, temperature, and moisture) within the scope of the GALL AMP XI.E1.

The GALL AMP XI.E1 states conductor insulation material used in electrical cables and

connection may degrade in adverse localized environments. The exposure of electrical cables

and connections to adverse localized environments caused by heat, or radiation can result in

reduced insulation resistance.

In the response to RAI B.2.41-2, dated August 5, 2008, the applicant stated that adverse

localized environments are identified by using a combination of existing information and plant

walk downs. The applicant further stated that an adverse localized environment typically occurs

when cables are routed in proximity to a source of heat or radiation, or are exposed to

significant moisture. The applicant also stated that information sources that can be used to

identify potential adverse localized environments include, plant design information, experience

and knowledge of plant personnel, radiological survey maps, and plant OE records. Plant walk

3-77
downs guided by the information from these sources, along with the use of thermography to

identify heat sources, will determine the adverse localized environments.

The staff found the applicant's response unacceptable because the applicant did not clearly

identify the threshold condition (i.e. temperature, radiation) at which the localized environment is

considered adverse. In a follow up conference call on October 10, 2008, the staff requested

that the applicant define the most limiting temperature and radiation dose values that will be

used to identify an adverse localized environment.

In a letter dated November 11, 2008, the applicant responded with a supplement to RAI

B.2.41-2 and stated that the most restrictive 60-year service limiting temperature for electrical

insulating materials in use at SSES is 11 20F for polyvinyl chloride. The most restrictive 60-year

service limiting radiation dose for electrical insulating materials in use at SSES is 5 x 104 rads

for fluorinated ethylene propylene. These values will be used as the thresholds for evaluation to

identify adverse localized environments.

Based on the review, the staff finds the applicant's response to RAI B.2.41-2, in addition to the

supplemental response acceptable because the applicant has clearly identified the threshold

condition (i.e. temperature, radiation) at which the localized environment is considered adverse.

Therefore, the staff's concern described in RAI B.2.41-2 is resolved.

In addition to the requirements of 10 CFR Part 50, Appendix B, the "corrective actions" program

element in the electrical GALL Report AMPs recommends certain actions, such as making a

determination of whether the same condition or situation is applicable to other accessible or

inaccessible cables and connections. In the LRA, the applicant stated that the AMPs are

consistent with the GALL Report and referred to a corrective action element in LRA

Section B.1.3 that is common to all AMPs. The corrective actions described in LRA

Section B.1.3 do not contain certain recommendations described in GALL AMP XI.E1.

In RAI Q3, dated July 3, 2008, the staff requested that the applicant explain in detail how the

generic corrective actions in LRA Section B.1.3 are consistent with GALL AMP XI.E1.

In the response to RAI Q3, dated August 5, 2008, the applicant stated that for the Non-EQ

Electrical Cables and Connections Visual Inspection Program, all unacceptable visual

indications of cable and connection jacket surface anomalies will be subject to an engineering

evaluation. The applicant further stated that evaluation will consider the age and OE of the

component, as well as the severity of the anomaly and whether the anomaly has previously

been correlated to degradation of the conductor insulation or connections. The applicant also

stated that corrective actions may include, but are not limited to, testing, shielding or otherwise

changing the environment, or relocation and/or replacement of the affected cable or connection.

When an unacceptable condition or situation is identified, the applicant stated that it determines

whether the same condition or situation is applicable to other cables or connections within the

scope of license renewal.

Based on the review, the staff finds the applicant's response to RAI Q3 acceptable because the

applicant has adequately explained that the corrective actions it has identified will include

actions as described in GALL AMP XI.EI. Therefore, the staff concern described in RAI Q3 is

resolved.

Based on the review of the information contained in the LRA and the applicant's responses to

RAIs B.2.41-1, B.2.41-2 and Q3, the staff determines that the Non-EQ Electrical Cable &

3-78
Connections Visual Inspection Program is consistent with the program elements of GALL

AMP XI.E1 and therefore, is acceptable.

Operating Experience. The staff also reviewed the applic~nt's OE in the onsite plant basis

document. The staff confirmed that the applicant has correctly identified the appropriate root

causes of cable aging and has taken appropriate corrective actions.

However, under the "operating experience" program element in the Non-EQ Electrical Cables

and Connections Visual Inspection Program, the applicant stated that the AMP is a new

program for which there is no SSES plant-specific OE.

In RAI Q1, dated July 3, 2008, the staff requested that the applicant describe plant-specific OE

associated with cables and connections in this AMP and explain how the new program will

manage the aging effects of cable and connection insulation.

In the response to RAI Q1, dated August 5, 2008, the applicant included the following OE:

(a) during routine preventive maintenance activities in 2000, cables connected to moisture

separator level switches were found to be brittle and cracked due to excessive heat and the

damaged cables were replaced and (b) in 2002, instrumentation cables connected to a

thermocouple in the MS tunnel were found to be heat damaged and brittle. The damaged

section of cable was replaced.

Based on the review, the staff finds the applicant's response to RAI Q1 acceptable because the

applicant has provided an adequate description of plant-specific OE associated with the cables

and connectors in the Non-EQ Electrical Cables and Connections Visual Inspection Program.

The staff determines that the OE is consistent with and bounded by those in the GALL

AMP XI.E1. Therefore, the staffs concern described in RAI Q1 is resolved.

On this basis, the staff determines that the "operating experience" program element satisfies

the criterion defined in the GALL Report and the guidance found in SRP-LR Section A. 1.2.3.10.

Therefore, the staff finds this program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement summary for the Non-EQ

Electrical Cable and Connections Visual Inspection Program in LRA Section A.1.2.35, and

Commitment No. 36 in Table A-1. The staff notes that SRP-LR Table 3.6-2 identifies when an

inspection will be implemented and how often the inspection will be performed. The UFSAR

supplement for the Non-EQ Electrical Cables and Connections Visual Inspection Program does

not provide the frequency of inspection.

In RAI Q2, dated July 3, 2008, the staff requested that the applicant provide the frequency of

inspection in the UFSAR supplement.

In the response to RAI Q2, dated August 5, 2008, the applicant included the inspection

frequency in the UFSAR supplement, in agreement with the Non-EQ Electrical Cables and

Connections Visual Inspection Program.

Based on the review, the staff finds the applicant's response to RAI Q2 acceptable because the

applicant had revised the UFSAR supplement to include the frequency of inspection. Therefore,

the staff's concern described in RAI Q2 is resolved.

3-79
On this basis, the staff determines that the UFSAR supplement provides an adequate summary

description of the applicant's Non-EQ Electrical Cable and Connections Visual Inspection, as

required by 10 CFR 54.21(d). The staff notes that the applicant has committed (Commitment

No. 36) to implement this AMP prior to the period of extended operation.

Conclusion. On the basis of the review of the applicant's Non-EQ Electrical Cable and

Connections Visual Inspection Program and the applicant's responses to RAIs B.2.41-1,

B.2.41-2, Q1, Q2, and Q3, the staff finds all program elements consistent with the GALL

Report. The staff concludes that the applicant has demonstrated that effects of aging will be

adequately managed so that the intended function(s) will be maintained consistent with the CLB

for the period of extended operation as required by 10 CFR 54.21(a)(3). The staff also reviewed

the UFSAR supplement for this AMP and concludes that it provides an adequate summary

description of the program, as required by 10 CFR 54.21(d) and therefore is acceptable.

3.0.3.1.24 Non-EQ Cables and Connections Used in Low-Current Instrumentation Circuits

Program

Summary of Technical Information in the Application. In LRA Section B.2.42' the applicant

described the Non-EQ Cables and Connections Used in Low-Current Instrumentation Circuits

Program as a new program consistent with the GALL AMP XI.E2, "Electrical Cables and

Connections Not Subject to 10 CFR50.49 Environmental Qualification Requirements Used in

Instrumentation Circuits." The applicant stated that the purpose of this AMP is to manage the

age-related degradation associated with non-EQ, low current instrumentation cables and

connections within the scope of license renewal. The applicant also stated that this program

applies to in-scope, non-EQ electrical cables and connections used in neutron monitoring

circuits with sensitive, low-current signals. The sensitive nature of these circuits is such that

visual inspection alone may not detect degradation to the insulation resistance function of the

conductor insulation.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff reviewed and compared the "scope of program," "preventive actions," "parameters monitored/detected," "detection of aging effects," "monitoring and trending," "acceptance criteria," and "operating experience" program elements of the AMP to the

corresponding program element criteria in GALL AMP XI.E2.

The staff compared the programs elements in the applicant's AMP to those in the GALL

AMP XI.E2. The staff verified that the program elements, which the LRA identified as consistent

with the GALL Report, were consistent with the corresponding program element criteria

recommended in GALL AMP XI.E2. However, the staff determined that additional information

was required to complete its review.

The GALL AMP XI.E2 considers the technical information and guidance provided in

NUREG/CR-5643, IEEE Standard P1205, SAND96-0344 and EPRI TR-109619. In LRA

Section B.2.42, the applicant stated that its program is consistent with the GALL Report, but did

not provide any information on industrial technical guidance.

In RAI B.2.42-1, dated July 3, 2008, the staff requested that the applicant provide specific

technical guidance which it will use to develop this AMP.

In its response to RAI B.2.42-1, dated August 5, 2008, the applicant stated that the technical

documents listed in GALL AMP XI.E2 (e.g., NUREG/CR-5643, IEEE Standard P1205,

3-80
SAND 96-0344, and EPRI TR-109619) provide information pertinent to plant environmental

conditions, environmental effects (i.e., adverse environmental conditions), evaluation of

environmental conditions and effects, degradation mechanisms, and aging effects. The

applicant also stated that the information is relevant to the understanding of electrical cable

aging mechanisms and effects, and is also relevant to potential inspection methods to identify

degradation. The applicant further stated that technical guidance contained in these staff and

industry reports will be used as input to develop this AMP.

Based on the review, the staff finds the applicant's response to RAI B.2.42-1 acceptable

because the applicant has confirmed that it will use industry guidance to develop the AMP and

that the guidance identified by the applicant is consistent with that in GALL AMP XI.E2.

Therefore, the staff's concern described in RAI B.2.42-1 is resolved.

The GALL AMP XI.E2 states that a proven cable system test for detecting deterioration of the

insulation system such as insulation resistance tests, time domain reflectometry tests, or other

testing judged to be effective in determining cable insulation condition as justified in the

application, should be performed. In LRA Section B.2.42, under the same element, the

applicant stated that the testing methodology will be specified prior to the first test.

In RAI B.2.42-2, dated July 3, 2008, the staff requested that the applicant provide the type of

tests that it will use to detect degradation of insulation in high-voltage, and in low-level signal

instrumentation circuits.

In its response to RAI B.2.42-2, dated August 05, 2008, the applicant stated that this is a new

program that will be implemented consistent with the GALL Report. Therefore, as

recommended in the GALL Report, a proven cable system test for detecting degradation of

insulation such as, insulation resistance testing, time domain reflectometry, or other suitable

test, will be used. The applicant further stated that the test method will be selected prior to

performance of the first test and will be a test type consistent with the recommendations in the

GALL Report.

Based on its review, the staff finds the applicant's response to RAI B.2.42-2 acceptable

because the applicant has identified proven methods of testing that it will use and that these

methods are consistent with those recommended in the GALL AMP XI.E2. Therefore, the staff's

concern described in RAI B.2.42-2 is resolved.

In addition to the requirements of 10 CFR Part 50, Appendix B, the "corrective actions" program

element in the electrical GALL Report AMPs recommends certain actions, such as making a

determination of whether the same condition or situation is applicable to other accessible or

inaccessible cables and connections. In the LRA, the applicant stated that its AMPs are

consistent with the GALL Report and referred to a corrective action element in LRA

Section B.1.3, common to all AMPs. The staff determined that the corrective actions described

in this LRA section may not contain certain recommendations described in the GALL

AMP XI.E2.

In RAI Q3, dated July 3, 2008, the staff requested that the applicant explain in detail how the

generic corrective actions in LRA Section B.1.3 are consistent with GALL AMP XI.E2.

In its response to RAI Q3, dated August 5, 2008, the applicant stated for the Non-EQ Cables

and Connections Used in Low-Current Instrumentation Circuits Program, corrective actions

such as recalibration and circuit trouble-shooting are implemented when calibration or

3-81
surveillance results do not meet the acceptance criteria. The applicant performs an engineering

evaluation when the test results do not meet the acceptance criteria. The applicant also stated

that the evaluation will consider the significance of the test results, the operability of the

component, the reportability of the event, the extent of the concern, the potential root causes,

the corrective actions required, and the likelihood of recurrence.

Based on its review, the staff finds the applicant's response to RAI Q3 acceptable because the

applicant has identified corrective actions that are consistent with those in GALL AMP XI.E2.

Therefore, the staff's concern described in RAI Q3 is resolved.

Based on its review of the information contained in the LRA and the applicant's responses to

RAIs B.2.42-1, B.2.42-2 and Q3, the staff finds the applicant's Non-EQ Cables and

Connections Used in Low-Current Instrumentation Circuits Program consistent with the

program elements of GALL AMP XI.E2 and therefore is acceptable.

Operating Experience. The staff reviewed CRs as part of its onsite review of the Non-EQ

Cables and Connections Used in Low-Current Instrumentation Circuits Program. The staff

determined that the CRs demonstrate that the applicant has implemented appropriate

corrective actions. However, the applicant states that the Non-EQ Cables and Connections

Used in Low-Current Instrumentation Circuits Program is a new program for which there is no

plant-specific OE.

In RAI Q1, dated July 3, 2008, the staff requested that the applicant describe plant-specific OE

associated with cables and connections in this AMP and explain how the new program will

manage the aging effects of cable and connection insulations used in low-current

instrumentation circuits.

In its response to RAI Q1, dated August 5, 2008, the applicant stated that the Non-EQ Cables

and Connections Used in Low-Current Instrumentation Circuits Program has not been

implemented, but the following example of OE demonstrates that the aging effect of interest in

this AMP (i.e., reduction in insulation resistance), can be, and has been, successfully detected.

During routine plant maintenance activities in 2003, two Unit 2 local power range monitoring

cables were identified with lower than acceptable insulation resistance. The applicant replaced

those cables. GALL AMP XI.E2 states that exposure of electrical cables to adverse localized

environments caused by heat, radiation, or moisture can result in reduced insulation resistance.

Reduced insulation resistance caused an increase in leakage currents between conductors and

from individual conductor to ground. A reduction in insulation resistance is a concern for circuits

with sensitive, high-voltage, low-level signals such as radiation monitoring and nuclear

instrumentation circuits, because a reduced insulation resistance may contribute to signal

inaccuracies.

Based on its review, the staff finds the applicant's response to RAI Q1 acceptable because the

applicant has adequately described the plant-specific OE associated with cables and

connections in this AMP and has sufficiently explained how the new program will manage the

aging effects of cable and connection insulations used in low-current instrumentation circuits.

The staff determines that reduced insulation resistance is the aging effect of sensitive

instrumentation cables installed in an adverse localized environment. This aging effect is

bounded by that in the GALL AMP XI.E2. Therefore, the staff's concern described in RAI Q1 is

resolved.

3-82
On the basis of its review, the staff determines that the "operating experience" program element

satisfies the criterion defined in the GALL Report and the guidance found in SRP-LR

Section A.1.2.3.10. Therefore, the staff finds this program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement summary description for

the Non-EQ Cables and Connections Used in Low-Current Instrumentation Circuits Program in

LRA Section A. 1.2.34 and Commitment No. 37 in Table A-1. The staff notes that SRP-LR

Table 3.6-2 identifies when an inspection will be implemented and how often the inspection will

be performed. The applicant's UFSAR supplement for the Non-EQ Cables and Connections

Used in Low-Current Instrumentation Circuits Program does not provide the frequency of

inspection.

In RAI Q2, dated July 3, 2008, the staff requested that the applicant provide the frequency of

inspection in the UFSAR supplement.

In its response to RAI Q2, dated August 5, 2008, the applicant provided the inspection

frequency, as described in the Non-EQ Cables and Connections Used in Low-Current

Instrumentation Circuits Program, in the UFSAR supplement. The staff finds that UFSAR

supplement summary description in LRA Section A. 1.2.34 provides an adequate summary

description of the applicant's Non-EQ Cables and Connections Used in Low-Current

Instrumentation Circuits Program, as required by 10 CFR 54.21(d). The staff confirms the

applicant's commitment (Commitment No. 37) to implement this AMP prior to the period of

extended operation.

Conclusion. On the basis of its technical review of the applicant's Non-EQ Cables and

Connections Used in Low-Current Instrumentation Circuits Program, the staff finds all program

elements consistent with the GALL Report. Upon reviewing the LRA and the applicant's

responses to RAIs B.2.42-1 B.2.42-2, Q1, Q2, and Q3, the staff finds all program elements

consistent with the GALL Report. The staff concludes that the applicant has demonstrated that

effects of aging will be adequately managed so that the intended function(s) will be maintained

consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP and

concludes that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d) and. therefore, is acceptable.

3.0.3.1.25 Non-EQ Inaccessible Medium-Voltage Cables Program

Summary of Technical Information in the Application. In LRA Section B.2.43, the applicant

described the new Non-EQ Inaccessible Medium-Voltage Cables Program as consistent with

GALL AMP XI.E3, "Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 EQ

Requirements." The applicant also stated that this AMP will manage the aging of non-EQ

inaccessible medium-voltage electrical cables subject to wetting, within the scope of license

renewal. The applicant further stated that the program provides for the periodic testing of nonEQ inaccessible medium-voltage electrical cables, in order to determine if age-related

degradation is occurring, and includes provisions for the inspection of associated manholes to

identify any collection of water.

Staff Evaluation. During the audit, the staff reviewed the applicant's claim of consistency with

the GALL Report. The staff reviewed and compared the "scope of program," "preventive

actions," "parameters monitored/detected," "detection of aging effects," "monitoring and

3-83
trending," "acceptance criteria," and operating experience" program elements of the AMP to

GALL AMP XI.E3.

The staff compared the program elements in the applicant's program to those in the

GALL AMP XI.E3 and verified that the program elements in the applicant's AMP, which the

applicant identified as consistent with the GALL Report, were consistent with the GALL

AMP XI.E3. However, the staff determined that additional information was required to complete

its review.

In LRA Section B.2.43, under the "scope of program" element, the applicant stated that this

program applies to six cables associated with the offsite power supply for SSES. The applicant

also stated that these are the only inaccessible medium-voltage cables that are within the

scope of license renewal and are exposed to significant moisture and significant voltage.

Significant voltage is defined by the GALL Report as any device or cable that is energized more

than 25% of the time. The staff noted that the RHR and emergency service water (ESW) pump

cables could be subjected to significant moisture and significant voltage.

In RAI B.2.43-1, dated July 3, 2008, the staff requested that the applicant explain why these

cables are not within the scope of the Non-EQ Inaccessible Medium-Voltage Cables Program.

In the response to RAI B. 2.43-1, dated August 5, 2008, the applicant stated that the cables for

the RHR pump motors are not within the scope of the Non-EQ Inaccessible Medium-Voltage

Cables Program because they are not routed underground and are not exposed to significant

moisture. The cables for the RHR service water (RHRSW) and ESW pump motors are not

included in the scope of the Non-EQ Inaccessible Medium-Voltage Cables Program because

they are energized less than 25% of the time. The applicant also stated that as described in the

GALL AMP XI.E3, this AMP applies to inaccessible medium-voltage cables within the scope of

license renewal that are exposed to significant moisture, simultaneously with significant voltage.

The GALL Report states that significant moisture is defined as periodic exposures to moisture

that last more than a few days, and significant voltage is defined as being subject to system

voltage more than 25% of the time. The applicant concluded that, because the RHR, RHRSW,

and ESW pump motor cables are either not exposed to significant moisture, or to significant

voltage, they are excluded from the scope of the Non-EQ Inaccessible Medium-Voltage Cables

Program.

Based on the review, the staff finds the applicant's response to RAI B.2.43-1 acceptable

because the applicant has adequately explained that the RHR, RHRSW, and ESW pump motor

cables are either not exposed to significant moisture or to significant voltage; therefore, they are

not required to be within the scope of the Non-EQ Inaccessible Medium-Voltage Cables

Program. Therefore, the staffs concern described in RAI B.2.43-1 is resolved.

The GALL AMP XI.E3 considers the technical information and guidance provided in

NUREG/CR-5643, IEEE Standard P1 205, SAND96-0344 and EPRI TR-1 09619. In LRA

Section B.2.43, the applicant stated that the program is consistent with the GALL Report and

yet, it did not provide any information on industrial technical guidance.

In RAI B.2.43-3, dated July 3, 2008, the staff requested that the applicant provide technical

guidance for the Non-EQ Inaccessible Medium-Voltage Cables Program or provide a

justification for why this guidance is not necessary.

3-84
In the response to RAI B.2.43-3, dated August 5, 2008, the applicant stated that the technical

documents listed in GALL AMP XI.E3 (e.g., NUREG/CR-5643, IEEE Standard P1205,

SAND96-0344, and EPRI TR-1 09619) provide information pertinent to plant environmental

conditions, environmental effects (i.e., adverse environmental conditions), evaluation of

environmental conditions and effects, degradation mechanisms, and aging effects. The

applicant further stated that the information is relevant to understanding electrical cable aging

mechanisms and effects, and is also relevant to potential testing methods to identify

degradation. The technical guidance contained in these staff and industry reports will be used

as input to develop this AMP.

Based on the review, the staff finds the applicant's response to RAI B.2.43-3 acceptable

because the applicant has provided the technical documents listed in the GALL AMP XI.E3 as

its references. Therefore, the staff's concern described in RAI B.2.43-3 is resolved.

The GALL AMP XI.E3, under the "detection of aging effects" program element, states that the

specific type of test is to be a proven test for detecting deterioration of the insulation system

due to wetting (i.e., power factor, partial discharge, or polarization index), as described in EPRI

TR-1 03834-Pl -2, or other testing that is state-of-the-art at the time of the test is performed. In

LRA Section B.2.43, under the same attribute, the applicant stated that the program will utilize a

proven test for detecting deterioration of the cable insulation due to wetting and energization,

and will reflect the actual test methodology prior to the initial performance of the cable testing.

In RAI B.2.43-4, dated July 3, 2008, the staff requested that the applicant describe the testing

methodology for detecting deterioration of the cable insulation under this AMP.

In the response to RAI B.2.43-4, dated August 5, 2008, the applicant stated that this is a new

program that will be implemented consistent with the GALL Report. The applicant further stated

that, as recommended in the GALL Report, a proven test for detecting deterioration of the

insulating system (i.e., such as, power factor, partial discharge, polarization index), as

described in EPRI TR103834-P1-2, or other state-of-the-art testing, will be used. The test

method will be selected prior to performance of the first test and will be a test-type consistent

with the recommendations of the GALL Report.

Based on its review, the staff finds the applicant's response to RAI B.2.43-4 acceptable

because the applicant has reasonably described the testing methodology for detecting

deterioration of the cable insulation under this AMP, which is consistent with those

recommended in the GALL AMP XI.E3. Therefore, the staff's concern described in

RAI B.2.43-4 is resolved.

In addition to the requirements of 10 CFR Part 50, Appendix B, the "corrective actions" program

element in the electrical GALL AMPs recommends certain actions, such as making a

determination of whether the same condition or situation is applicable to other accessible or

inaccessible cables and connections. In the LRA, the applicant stated that its AMPs are

consistent with the GALL Report and referred to a corrective action element in LRA

Section B.1.3, common to all AMPs. The staff determined that the corrective actions described

in LRA Section B.1.3 may not contain certain recommendations described in the GALL

AMP XI.E3.

In RAI Q3, dated July 3, 2008, the staff requested that the applicant explain in detail how the

generic corrective actions in LRA Section B.1.3 are consistent with GALL AMP XI.E3.

3-85
In its response to RAI Q3, dated August 5, 2008, the applicant stated that for the Non-EQ

Inaccessible Medium-Voltage Cables Program, an engineering evaluation is performed in order

to ensure that the intended function of the electrical cables can be maintained consistent with

the CLB, when the test acceptance criteria are not met. The evaluation will consider the

significance of the test results, the operability of the component, the reportability of the event,

the extent of the concern, the potential root causes, the corrective actions required, and the

likelihood of recurrence. When an unacceptable condition or situation is identified, a

determination will be made as to whether the same condition or situation is applicable to other

in-scope medium-voltage cables.

Based on its review, the staff finds the applicant's response to RAI Q3 acceptable because the

applicant has adequately explained how the corrective actions are consistent with those in

GALL AMP XI.E3. Therefore, the staff's concern described in RAI Q3 is resolved.

Based on the review of the information contained in the LRA and the applicant's responses to

RAIs B.2.43-1, B.2.43-3, B.2.43-4, and Q3, the staff finds the Non-EQ Inaccessible

Medium-Voltage Cables Program consistent with the program elements of GALL AMP XI.E3,

and therefore is acceptable.

Operating Experience. The staff reviewed the applicant's OE and noted that inaccessible

medium-voltage cables in certain manholes at SSES have experienced significant moisture

(i.e., cable in standing water for more than few days). In addition, during a walk down, the staff

found several feet of water in Manhole Numbers 2 and 16.

The staff identified water in manholes as a generic, current operating plant issue in IN 2002-12,

"Submerged Safety-Related Electrical Cables," dated March 21, 2002, and GL 2007-01,

"Inaccessible or Underground Power Cable Failures That Disable Accident Mitigation Systems

Or Cause Plant Transients," dated February 7, 2007. The staff will address water in manholes,

during the current period of operation, through the reactor oversight process, in accordance

with the requirements of 10 CFR Part 50.

During its review of the LRA, the staff determined that the Non-EQ Inaccessible

Medium-Voltage Cable Program, if implemented as described, would ensure that the aging

affects on inaccessible medium-voltage cables, due to exposure to significant moisture and

significant voltage, will be adequately managed during the period of extended operation, and

pursuant to the guidance contained in GALL AMP XI.E3. The Non-EQ Inaccessible

Medium-Voltage Cable Program is a new AMP which will require the applicant to test the cables

and to evaluate plant-specific OE to determine whether the inspection frequency of the

manholes should be increased to ensure that the cables will be maintained in a dry

environment, during the period of extended period of operation.

In the LRA, the applicant stated that the Non-EQ Inaccessible Medium-Voltage Cable Program

is a new program for which there is no plant-specific OE.

In RAI Q1, dated July 3, 2008, the staff requested that the applicant describe plant-specific OE

associated with cables and connections in this AMP and explain how the new program will

manage non-EQ medium voltage cables.

In the response to RAI Q1, dated August 5, 2008, the applicant stated that the Non-EQ

Inaccessible Medium-Voltage Cable Program is license renewal AMP and has not yet been

implemented. However, the following example of OE demonstrates that the aging effects of

3-86
interest in this AMP (i.e., degradation of the conductor insulation for medium-voltage cables

exposed to significant moisture and voltage) can be, and has been, successfully detected at

SSES. The applicant further stated that it detected a negative trend in power factor test results

of 15 kV underground cables supplying power to the plant's river water intake. The test results

are indicative of expected aging of the cable insulation system. The applicant also stated that

these cables continue to be monitored under the plant corrective action program.

Based on its review, the staff finds the applicant's response to RAI Q1 acceptable because the

applicant has adequately explained how the aging effects due to significant moisture and

voltage will be detected and the corrective actions it will take. The staff determines that the

applicant's response supports the conclusion that this AMP will provide assurance that the

aging effects will be managed consistent with CLB, during the period of extended operation.

Therefore, the staff's concern described in RAI Q1 is resolved.

On this basis, the staff determines that the "operating experience" program element satisfies

the criterion defined in the GALL Report and the guidance found in SRP-LR Section A.1.2.3.10.

Therefore, the staff finds this program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement summary for the Non-EQ

Inaccessible Medium-Voltage Cables Program in LRA Section A.1.2.36 and Commitment No.

38 in Table A-I. The staff notes that SRP-LR Table 3.6-2 identifies when an inspection will be

implemented and how often the inspection will be performed. The UFSAR supplement for the

Non-EQ Inaccessible Medium-Voltage Cables Program does not provide the frequency of

inspection.

In RAI Q2, dated July 3, 2008, the staff requested that the applicant provide the frequency of

inspection in the UFSAR supplement.

In the response to RAI Q2, dated August 5, 2008, the applicant provided the inspection

frequency for its UFSAR supplement.

Based on the review, the staff finds the applicant's response to RAI Q2 acceptable because the

applicant has provided the frequency of inspection in the UFSAR supplement.

The staff finds that UFSAR Supplement summary description in LRA Section A. 1.2.36 provides

an adequate summary description of the applicant's Non-EQ Inaccessible Medium-Voltage

Cables Program, as required by 10 CFR 54.21(d). The staff notes that the applicant has

committed (Commitment No. 38) to implement this AMP prior to the period of extended

operation.

Conclusion. On the basis of the review of the applicant's Non-EQ Inaccessible Medium-Voltage

Cables Program and the applicant's responses to RAI B.2.43-1, B.2.43-3, B.2.43-4, Q1, Q2,

and Q3, the staff finds all program elements consistent with the GALL Report. The staff

concludes that the applicant has demonstrated that effects of aging will be adequately

managed so that the intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21(d). The staff also reviewed the

UFSAR supplement for this AMP and concludes that it provides an adequate summary

description of the program, as required by 10 CFR 54.21(d) and therefore is acceptable.

3-87
3.0.3.1.26 Metal-Enclosed Bus Inspection Program

Summary of Technical Information in the Application. In LRA Section B.2.44, the applicant

described the new Metal-Enclosed Bus Inspection Program as consistent with the GALL

AMP XI.E4, "Metal-Enclosed Bus." The applicant also stated that this AMP will provide the

periodic inspection of the applicable metal-enclosed bus, in order to determine whether agerelated degradation is occurring. The applicant further stated that the program provides for the

periodic inspection of the applicable metal-enclosed bus, in order to determine if age-related

degradation is occurring.

Staff Evaluation. During the audit, the staff reviewed the applicant's claim of consistency with

the GALL Report. The staff reviewed and compared the "scope of program," "preventative

actions," "parameters monitored/detected," "detection of aging effects," "monitoring and

trending," "acceptance criteria," and "operating experience" program elements of the AMP to

the corresponding program element criteria in the GALL AMP XI.E4.

The staff compared the programs elements in the applicant's program to those in the

GALL AMP XI.E4. The staff noted the program elements in the applicant's AMP claim of

consistency with GALL were consistent with the GALL AMP XI.E4. The staff determined that

additional information was required to complete its review.

In addition to the requirements of 10 CFR Part 50, Appendix B, the "corrective actions" program

element in the electrical GALL AMP XI.E4 recommends certain actions, such as making a

determination of whether the same condition or situation is applicable to other accessible or

inaccessible metal-enclosed busses. In the LRA, the applicant stated that its AMP is consistent

with the GALL Report and referred to a corrective action element in the LRA, Section B.1.3,

common to all AMPs. The staff determined that the corrective actions described in LRA

Section B.1.3 do not contain certain recommendations described in the GALL AMP XI.E4.

In RAI Q3, dated July 3, 2008, the staff requested that the applicant explain, in detail, how the

generic corrective actions in LRA Section B.1.3 are consistent with GALL AMP XI.E4.

In its response to RAI Q3, dated August 5, 2008, the applicant stated that for the new

Metal-Enclosed Bus Inspection Program, further investigation and evaluation are performed

when the acceptance criteria are not met. Corrective actions may include, but are not limited to

cleaning, drying, an increased inspection frequency, replacement, or repair of the affected

metal-enclosed bus components. If an unacceptable condition or situation is identified, the

applicant further stated that it determines whether the same condition or situation is applicable

to other metal-enclosed busses.

Based on the review, the staff finds the applicant's response to RAI Q3 acceptable because the

applicant has adequately explained how its generic corrective actions in the new

Metal-Enclosed Bus Inspection Program are consistent with the GALL AMP XI.E4. The staff

determines that the applicant's corrective actions are consistent with those in the GALL

AMP XI.E4. Therefore, the staff's concern described in RAI Q3 is resolved.

Based on the review, the staff finds the Metal-Enclosed Bus Inspection Program consistent with

the program elements of GALL AMP XI.E4 and therefore is acceptable.

Operatinq Experience. The staff reviewed the applicant's OE described in LRA Section B.2.44.

The staff also reviewed industry experience relevant to this AMP and noted that industry

3-88
experience has shown that failures have occurred on metal-enclosed busses caused by

cracked insulation and moisture or debris buildup internal to the metal enclosed busses.

Experience also has shown that bus connections in metal-enclosed busses exposed to

appreciable ohmic heating, during operation, may experience loosening due to repeated cycling

of connected loads. However, under the "operating experience" program element in the LRA,

the applicant states that the Metal-Enclosed Bus Inspection Program is a new program for

which there is no plant-specific OE.

In RAI Q1, dated July 3, 2008, the staff requested that the applicant describe plant-specific OE

associated with cables and connections in this AMP and explain how the new program will

manage the aging effects of metal-enclosed buses.

In the response to RAI Q1, dated August 5, 2008, the applicant stated that visual inspections

were performed of bus 0A206 in 2006 and 0A107 in 1996. No significant age-related

degradation was detected during these inspections. The applicant also stated that bus

enclosures were found to be clean, with no evidence of overheating of bus connections. The

applicant concluded that these activities demonstrate that the bus is generally accessible for

visual inspection and in good condition, such that if any aging effects of interest for this

AMP occur, they should be detected during future inspections.

Based on the review, the staff finds the applicant's response to RAI Q1 acceptable because the

applicant has adequately explained how the Metal-Enclosed Bus Inspection Program will

manage the aging effects of metal-enclosed buses. The staff determines that the aging effects

of metal-enclosed busses will be detected and this AMP will provide assurance that the aging

effects will be managed consistent with CLB, during the period of extended operation.

Therefore, the staff's concern described in RAI Q1 is resolved.

On this basis, the staff confirms that the "operating experience" program element satisfies the

criterion defined in the GALL Report and the guidance found in SRP-LR Section A.1.2.3.10.

Therefore, the staff finds this program element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement summary for the

Metal-Enclosed Bus Inspection Program in LRA Section A.1.2.32 and Commitment No. 39 in

Table A-1. The staff notes that SRP-LR Table 3.6-2 identifies when an inspection will be

implemented and how often the inspection will be performed. The staff determined that the

UFSAR supplement for the Metal-Enclosed Bus Inspection Program does not provide the

frequency of inspection.

In RAI Q2, dated July 3, 2008, the staff requested that the applicant provide the frequency of

inspection in the UFSAR supplement.

In the response to RAI Q2, dated August 5, 2008, the applicant provided the inspection

frequency for the UFSAR supplement.

Based on the review, the staff finds the applicant's response to RAI Q2 acceptable because the

applicant has provided the inspection frequency for the UFSAR supplement. Therefore, the

staff's concern described in RAI Q2 is resolved.

The staff finds that UFSAR supplement in LRA Section A.1.2.32 provides an adequate

summary description of the applicant's Metal-Enclosed Bus Inspection Program, as required by

3-89
10 CFR 54.21(d). The staff notes that the applicant has committed (Commitment No. 39) to

implement this AMP, prior to the period of extended operation.

Conclusion. On the basis of the review of the applicant's Metal-Enclosed Bus Inspection

Program and the applicant's responses to RAls Q1, Q2, and Q3, the staff finds all program

elements consistent with the GALL Report. The staff concludes that the applicant has

demonstrated that effects of aging will be adequately managed so that the intended function(s)

will be maintained consistent with the CLB for the period of extended operation, as required by

10 CFR 54.21(a)(3). The staff also reviewed the UFSAR supplement for this AMP and

concludes that it provides an adequate summary description of the program, as required by

10 CFR 54.21(d) and therefore is acceptable.

3.0.3.1.27 Non-EQ Electrical Cable Connections Program

Summary of Technical Information in the Application. In LRA Section B.2.45, the applicant

described the new Non-EQ Electrical Cable Connections Program as consistent with the GALL

AMP XI.E6, "Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental

Qualification Requirements." The applicant stated that this AMP will manage the aging effects

for the metallic parts of non-EQ electrical cable connections within the scope of license renewal.

It will address cable connections that are used to connect cable conductors to other cables or

electrical devices.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff reviewed and compared the "scope of program," "preventative actions," "parameters monitored/detected," "detection of aging effects," "monitoring and trending," "acceptance criteria," and "operating experience" program elements of the AMP to the

corresponding program element criteria in GALL AMP XI.E6.

The staff compared the programs elements in the applicant's program to those in

GALL AMP XI.E6. The staff noted that the program elements in the applicant's AMP claim of

consistency with the GALL Report were consistent with the GALL AMP XI.E6. The staff

determined that additional information was required to complete its review.

In addition to the requirements of 10 CFR Part 50, Appendix B, the "corrective actions" program

element in the electrical GALL AMPs recommends certain actions, such as making a

determination of whether the same condition or situation is applicable to other accessible or

inaccessible cables and connections. In the LRA, the applicant stated that the AMPs are

consistent with the GALL Report and referred to a corrective action element in LRA

Section B.1.3, common to all AMPs. The staff determined that the corrective actions described

in LRA Section B.1.3 do not contain certain recommendations described in the GALL

AMP XI.E6.

In RAI Q3, dated July 3, 2008, the staff requested that the applicant explain, in detail, how the

generic corrective actions in LRA Section B.1.3 are consistent with the GALL AMP XI.E6.

In the response to RAI Q3, dated August 5, 2008, the applicant stated that for the GALL

AMP XI.E6, (the Non-EQ Electrical Cable Connections Program), it performs an engineering

evaluation, when the test acceptance criteria are not met, to ensure that the intended functions

of the cable connections can be maintained, consistent with the CLB. The evaluation will

consider the significance of the test results, the operability of the component, the reportability of

the event, the extent of the concern, the potential root causes, the corrective actions required,

3-90
and the likelihood of recurrence. The applicant further stated that when an unacceptable

condition or situation is identified, a determination is made as to whether the same condition or

situation is applicable to other in-scope cable connections that were not tested.

Based on its review, the staff finds the applicant's response to RAI Q3 acceptable because the

applicant has adequately explained how the generic corrective actions in LRA Section B.1.3 are

consistent with the GALL AMP XI.E6. The staff confirms that the corrective actions identified by

the applicant are consistent with those recommended in the GALL report AMP XI.E6.

Therefore, the staff's concern described in RAI Q3 is resolved.

Based on the review, the staff finds the Non-EQ Electrical Cable Connections Program

consistent with the program elements of the GALL AMP XI.E6 and therefore is acceptable.

Operating Experience. The staff reviewed the applicant's OE described in LRA Section B.2.45.

The staff also reviewed industry guidance with relevance to this AMP. The staff noted that

under the OE program element in the LRA, the applicant stated that the Non-EQ Electrical

Cable Connections Program is a new program for which there is no plant-specific OE.

In RAI Q1, dated July 3, 2008, the staff requested that the applicant describe plant-specific OE

associated with cables and connections in this AMP and explain how the new program will

manage the aging effects of cable and connection insulations.

In the response to RAI Q1, dated August 5, 2008, the applicant stated that this license renewal

AMP has not yet implemented, but, the following are examples of OE that demonstrate that the

aging effects of interest in this AMP (i.e., loosening of cable connections), can be, and have

been successfully detected. The applicant further stated that during routine maintenance

activities in 2007, it found a cable crimp connection in a switchgear cubicle, operating at a

higher temperature than other connections in the same circuit. The applicant determined that

the temperature differential was only minor and; thus, not an operability concern. Nonetheless,

the applicant replaced the cable lug. The applicant concluded that this demonstrates that a

loose connection can be detected via thermography, before loss of intended functions. The

applicant further stated that in 1997, using thermography while performing preventive

maintenance activities on a battery charger, it detected a hot spot on the DC output cable lugs.

The applicant replaced the cable lugs and returned the battery charger to service, without loss

of intended function.

Based on the review, the staff finds the applicant's response to RAI Q1 acceptable because the

applicant has demonstrated that the aging effects of cable connections will be detected using

thermography. The staff determines that this AMP will provide assurance that the aging effects

will be managed consistent with the CLB. Therefore, the staff's concern described in RAI Q1 is

resolved.

On this basis, including the applicant's response to the RAI, the staff confirms that the

"operating experience" program element satisfies the criterion defined in the GALL Report and

the guidance found in SRP-LR Section A.1.2.3.10. Therefore, the staff finds this program

element acceptable.

UFSAR Supplement. The applicant provided the UFSAR supplement summary for the Non-EQ

Electrical Cable Connections Program in LRA Section A.1.2.37 and Commitment No. 50 in

Table A-I. The staff notes that SRP-LR Table 3.6-2 identifies when an inspection will be

implemented and how often the inspection will be performed. The UFSAR supplement for the

3-91
Non-EQ Electrical Cable & Connections Visual Inspection Program does not provide the

frequency of inspection.

In RAI Q2, dated July 3, 2008, the staff requested that the applicant provide the frequency of

inspection in the UFSAR supplement.

In the response to RAI Q2, dated August 5, 2008, the applicant provided the inspection

frequency for its UFSAR supplement, Commitment No. 50.

Based on the review, the staff finds the applicant's response to RAI Q2 acceptable because the

applicant has provided the frequency of inspection for the UFSAR summary. Therefore, the

staff's concern described in RAI Q2 is resolved.

The staff finds that UFSAR Supplement summary description in LRA Section A. 1.2.37, provides

an adequate summary description of the applicant's Non-EQ Electrical Cable Connections

Program, as required by 10 CFR 54.21(d). The staff notes that the applicant has committed to

implement this AMP prior to the period of extended operation.

Conclusion. On the basis of the review of the applicant's Non-EQ Electrical Cable Connections

Program, the staff finds all program elements consistent with the GALL Report. The staff

concludes that the applicant has demonstrated that effects of aging will be adequately

managed so that the intended function(s) will be maintained consistent with the CLB, for the

period of extended operation, as required by 10 CFR 54.21(a)(3). The staff also reviewed the

UFSAR supplement for this AMP and concludes that it provides an adequate summary

description of the program, as required by 10 CFR 54.21(d) and therefore is acceptable.

3.0.3.1.28 Environmental Qualification (EQ) Program

Summary of Technical Information in the Application. In LRA Section B.3.2, the applicant

described the existing Environmental Qualification (EQ) Program as consistent with the GALL

AMP X.E1, "Environmental Qualification (EQ) of Electric components." The applicant stated that

this EQ program manages component thermal, radiation, and cyclic aging through the use of

aging evaluation in accordance with 10 CFR 50.49(f) qualification methods.

As required by 10 CFR 50.49, EQ components not qualified for the current license term are to

be refurbished, replaced or have their qualification extended, prior to reaching the aging limits

established in the evaluation.

Staff Evaluation. During its audit, the staff reviewed the applicant's claim of consistency with the

GALL Report. The staff reviewed and compared the "scope of program," "preventive actions,"

parameters monitored/detected," "detection of aging effects," "monitoring and trending,"

"acceptance criteria," and "operating experience" program elements of the AMP to the

corresponding program element criteria in the GALL AMP X.E1.

The staff's review of the "corrective actions," "administrative controls," and "confirmatory

controls" program elements for the Environmental Qualification (EQ) Program was performed

as part of the staff's review of the QA attributes of the AMPs and is discussed in SER

Section 3.0.4.

3-92
In comparing the programs elements in the applicant's program to those in the GALL

AMP X.E1, the staff noted the program elements in the applicant's AMP claim of consistency

with the GALL Report, were consistent with GALL AMP X.E1.

Based on the review, the staff finds the Environmental Qualification (EQ) Program consistent

with the program elements of the GALL AMP X.El and therefore is acceptable.

Operating Experience. The staff reviewed the applicant's OE described in LRA Section B.3.2.

The staff also reviewed the applicant's plant basis documents and discussed with the applicant

the OE with existing program. The OE included past corrective actions, which resulted in a

program's enhancement. The applicant stated in CR 191057, that while performing

investigation of equipment, it concluded that terminal voltages typically exceed the 120 VAC

rating of solenoid-operated valves in the EQ program. The study concluded an establishment of

the maximum end-device voltages for U1 Class 1E 120V panels, and on the average T10 and

T20 bus voltage over the last year. A review of effected Environmental Qualification

Assessment Report has determined that temperature rise due to self-heat, at voltages above

120 VAC, has not been factored into qualified life determinations. Corrective action was taken

to address the issue. The staff determines that this information will provide objective evidence

to support the conclusion that the effects of aging will be managed so that the intended

functions will be maintained consistent with CLB, during the period of extended operation.

The staff confirms that the "operating experience" program element satisfies the criterion

defined in the GALL Report and the guidance found in SRP-LR Section A.1.2.3.10. Therefore,

the staff finds this program element acceptable.

UFSAR Supplement The applicant provided the UFSAR supplement summary of the EQ of

electrical equipment in LRA Section A.1.3.4 and Commitment No. 44 in Table A-1. The

summary description is not consistent with SRP-LR Table 4.4.2, as it does not contain

reanalysis attributes. Reanalysis should address the attributes of analytical methods, data

collection and reduction methods, underlying assumptions, acceptance criteria, corrective

actions, if acceptance criteria are not met, and the period of time when the reanalysis will be

completed.

In RAI B.3.2-1, dated July 3, 2008, the staff requested that the applicant revise the UFSAR

supplement to include these reanalysis attributes.

In the response to RAI B.3.2-1, dated August 5, 2008, the applicant added the following in LRA

Section A. 1.3.4:

10 CFR 50.49 requires EQ components that are not qualified for the current

license term to be refurbished, replaced, or have their qualifications extended

prior to reaching the aging limits established in the aging evaluation. Reanalysis

of aging evaluation to extend the qualifications of components is performed on a

routine basis as part of the EQ Program. Important attributes for the reanalysis

of aging evaluations include analytical methods, data collection and reduction

methods, underlying assumptions, acceptance criteria, corrective actions (if

acceptance criteria are not met), and the time remaining to the end of qualified

life.

3-93
Based on the review, the staff finds the applicant's response to RAI 3.2-1 acceptable because

the applicant has revised the UFSAR supplement to be consistent with SRP-LR Table 4.4.2.

Therefore, the staff's concern described in RAI 3.2-1 is resolved.

The staff finds that the UFSAR supplement summary description in LRA Section A. 1.3.4,

provides an adequate summary description of the applicant's EQ Program, as required by

10 CFR 54.21(d). The staff notes that the applicant has committed (Commitment No. 44) to

implement this AMP prior to the period of extended operation.

Conclusion. On the basis of the review of the applicant's Environmental Qualification (EQ)

Program, the staff finds all program elements consistent with the GALL Report. The staff

concludes that the applicant has demonstrated that effects of aging will be adequately

managed so that the intended function(s) will be maintained consistent with the CLB for the

period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed the

UFSAR supplement for this AMP, including the applicant's response to RAI B.3.2-1, and

concludes that it provides an adequate summary description of the program, as required by

10 CFR 54,21(d) and therefore is acceptable.

3.0.3.2 AMPs Consistent with the GALL Report with Exceptions or Enhancements

In LRA Appendix B, the applicant stated that the following AMPs are, or will be, consistent with

the GALL Report, with exceptions or enhancements:

* Inservice Inspection (ISI) Program

• BWR CRD Return Line Nozzle Program

* BWR Penetrations Program

* BWR Vessel Internals Program

* Bolting Integrity Program

* Piping Corrosion Program

" Closed Cooling Water Chemistry Program

" Fire Protection Program

* Fire Water System Program

* Buried Piping and Surveillance Program

• Fuel Oil Chemistry Program

* Reactor Vessel Surveillance Program

* Buried Piping and Tanks Inspection Program

• System Walkdown Program

* Lubricating Oil Analysis Program

* Masonry Wall Program

• Structures Monitoring Program

• RG 1.127 Water-Control Structures Inspection

* Fatigue Monitoring Program

* Fuse Holders Program

For AMPs that the applicant claimed are consistent with the GALL Report, with exception(s),

enhancement(s), or both, the staff performed an audit and review to confirm that those

attributes or features of the program, for which the applicant claimed consistency with the GALL

Report, were indeed consistent. The staff also reviewed the exception(s) and/or

enhancement(s) to the GALL Report to determine whether they were acceptable and adequate.

The results of the staff's audits and reviews are documented in the following sections.

3-94