q UoSoPRC

United States Nuclear Regulatory Commission

Protecting People and the Environment

NUREG-1920, Vol. 1

Safety EwaýUBUUeo Repoul

Related to the LUcense RenewaD of

Vogtfe EBectrdc Generating Rant,

Units 1 and 2

Docket Nos. 50-424 and 50-425

SouOhern Hiecr Olf•N•ucl Company, Inc.

Office of Nuclear Reactor Regulation
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*US.NRC

United States Nuclear Regulatory Commission

Protecting People and the Environment

NUREG-1920, Vol. 1

Safety Evaluation Report

Related to the License Renewal of

Vogtle Electric Generating Plant,

Units 1 and 2

Docket Nos. 50-424 and 50-425

Southern Nuclear Operating Company, Inc.

Manuscript Completed: April 2009

Date Published: April 2009

Office of Nuclear Reactor Regulation
Jj
ABSTRACT

This safety evaluation report (SER) documents the technical review of the Vogtle Electric

Generating Plant (VEGP), Units 1 and 2, license renewal application (LRA) by the United States

(US) Nuclear Regulatory Commission (NRC) staff (the staff). By letter dated June 29, 2007,

Southern Nuclear Operating Company, Inc. (SNC 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." SNC requests renewal of the Units 1

and 2 operating licenses (Facility Operating License Numbers NPF-68 and NPF-81,

respectively) for a period of 20 years beyond the current expiration date of January 16, 2027, for

Unit 1, and February 9, 2029, for Unit 2.

VEGP is located approximately 26 miles southeast of Augusta, GA. The NRC issued the

construction permits for Unit 1 on June 28, 1974, and on June 28, 1974, for Unit 2. The NRC

issued the operating licenses for Unit 1 on March 16, 1987, and on March 31, 1989, for Unit 2.

Units 1 and 2 are of a dry ambient containment pressurized water reactor design. Westinghouse

Electric supplied the nuclear steam supply system and Georgia Power Company originally

designed and constructed the balance of the plant with the assistance of its agent, Southern

Services and Bechtel. The licensed power output of each unit is 3625.6 megawatt thermal with

a gross electrical output of approximately 1250 megawatt electric.

This SER presents the status of the staff's review of information submitted through February 16,

2009, the cutoff date for consideration in the SER. The staff identified no open or confirmatory

items that would require a formal response from the applicant. SER Section 6 provides the

staff's final conclusion of its LRA review.

iii

TABLE OF CONTENTS

ABSTRACT .............................................................................................................. iii

ABBREVIATIONS .................................................................................................. xv

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

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

1.2 Regulatory Evaluation ................................................................................. 1-2

1.2.1 Background .................................................................................. 1-2

1.2.2 Safety Review ............................................................................... 1-3

1.2.3 Environmental Review ...... I ....................... 1-4

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

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

1.5 Summary of Open Items .................................................. .......................... 1-7

1.6 Summary of Confirmatory Items ................. ................................................. 1-7

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

2 STRUCTURES AND COMPONENTS SUBJECT TO AGING

MANAGEMENT REVIEW ..................................................................................... 2-1

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

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

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

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

2.1.3.1 Implementation Procedures and Documentation

Sources Used for Scoping and Screening ................ 2-3

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

2.1.3.3 Training ..................................................................... 2-6

2.1.3.4 Scoping and Screening Program Review

Conclusion ................................................................ 2-6

2.1.4 Plant Systems, Structures, and Components

Scoping Methodology ................................................................... 2-6

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) ................................................... 2-14

2.1.4.4 Plant-Level Scoping of Systems and Structures ...... 2-17

2.1.4.5 Mechanical Component Scoping .............................. 2-19

2.1.4.6 Structural Scoping .................................................... 2-21

v
2.1.4.7 Electrical Component Scoping........................ 2-22

2.1.4.8 Scoping Methodology Conclusion.................... 2-22

2.1.5 Screening Methodology ............................................. 2-23

2.1.5.1 General Screening Methodology...................... 2-23

2.1.5.2 Mechanical Component Screening................... 2-24

2.1.5.3 Structural Component Screening ..................... 2-25

2.1.5.4 Electrical Component Screening...................... 2-27

2.1.5.5 Screening Methodology Conclusion .................. 2-28

2.1.6 Summary of Evaluation Findings.................................... 2-28

2.1.7 References ........................................................... 2-28

2.2 Plant-Level Scoping Results.................................................. 2-29

2.2.1 Technical Information in the Application........................... 2-29

2.2.2 Staff Evaluation ..................................................... 2-29

2.2.3 Conclusion ........................................................... 2-30

2.3 Scoping and Screening Results: Mechanical Systems ..................... 2-31

2.3.1 Reactor Vessel, Reactor Vessel Internals, and

Reactor Coolant System ........................................... 2-32

2.3.1.1 Reactor Vessel ........................................ 2-33

2.3.1.2 Reactor Vessel Internals.............................. 2-34

2.3.1.3 Reactor Coolant System and Connected Lines .... 2-35

2.3.1.4 Pressurizer............................................. 2-36

2.3.1.5 Steam Generators..................................... 2-37

2.3.2 Engineered Safety Features........................................ 2-38

2.3.2.1 Containment Spray System........................... 2-39

2.3.2.2 Emergency Core Cooling Systems .................. 2-40

2.3.2.3 Containment Isolation System........................ 2-42

2.3.3 Auxiliary Systems ................................................... 2-43

2.3.3.1 Fuel Storage Racks - New and Spent Fuel......... 2-45

2.3.3.2 Spent Fuel Cooling and Purification System ........ 2-47

2.3.3.3 Overhead Heavy and Refueling

Load Handling System................................ 2-48

2.3.3.4 Nuclear Service Cooling Water Systems (NSCW).. 2-49

2.3.3.5 Component Cooling Water System .................. 2-52

2.3.3.6 Auxiliary Component Cooling Water System........ 2-54

2.3.3.7 Turbine Plant Cooling Water System ................ 2-55

2.3.3.8 River Intake Structure System........................ 2-56

2.3.3.9 Compressed Air System .............................. 2-57

2.3.3.10 Chemical and Volume Control and

Boron Recycle Systems ............................. 2-58

2.3.3.11 Ventilation Systems - Control Building............. 2-61

2.3.3.12 Ventilation Systems - Auxiliary Building ........... 2-63

2.3.3.13 Ventilation Systems - Containment Building......2-66

2.3.3.14 Ventilation Systems - Fuel Handling Building.....2-69

2.3.3.15 Ventilation Systems - Diesel Generator

Building ............... ............................... 2-72

2.3.3.16 Ventilation Systems - Auxiliary Feedwater

Pump House ......................................... 2-74

2.3.3.17 Ventilation Systems - Miscellaneous............... 2-76

vi
2.3.3.18 Ventilation Systems - Radwaste Buildings

H V A C .................................................................... 2-80

2.3.3.19 Fire Protection System .......................................... 2-81

2.3.3.20 Emergency Diesel Generator System ................... 2-95

2.3.3.21 Demineralized Water System .............................. 2-101

2.3.3.22 Hydrogen Recombiner and Monitoring

S ystem ................................................................ 2-102

2.3.3.23 Drain Systems ..................................................... 2-103

2.3.3.24 Potable and Utility Water Systems ...................... 2-107

2.3.3.25 Radiation Monitoring System (1609) ................... 2-108

2.3.3.26 Reactor Makeup Water Storage System ............. 2-110

2.3.3.27 Sampling Systems ............................................... 2-112

2.3.3.28 Auxiliary Gas Systems ........................................ 2-115

2.3.3.29 Chilled Water Systems ........................................ 2-117

2.3.3.30 Waste Management Systems ............................. 2-120

2.3.3.31 Thermal Insulation ............................................... 2-126

2.3.3.32 Miscellaneous Leak Detection System ................ 2-127

2.3.4 Steam and Power Conversion Systems................................... 2-128

2.3.4.1 Main Steam System .............................................. 2-129

2.3.4.2 Feedwater System ..................... 2-130

2.3.4.3 Steam Generator Blowdown System .................... 2-132

2.3.4.4 Auxiliary Feedwater System .................................. 2-133

2.3.4.5 Auxiliary Steam System ........................................ 2-136

2.3.4.6 Electrohydraulic Control System ........................... 2-137

2.4 Scoping and Screening Results - Structures .......................................... 2-138

2.4.1 Containment Structures ............................................................ 2-139

2.4.1.1 Summary of Technical Information in

the A pplication ...................................................... 2-139

2.4.1.2 Staff Evaluation ..................................................... 2-140

2.4.1.3 C onclusion ............................................................ 2-144

2.4.2 Auxiliary, Control, Fuel Handling, and Equipment Buildings .... 2-144

2.4.2.1 Summary of Technical Information in

the A pplication ...................................................... 2-144

2.4.2.2 Staff Evaluation ..................................................... 2-145

2.4.2.3 C onclusion ............................................................ 2-146

2.4.3 Emergency Diesel Generator Structures .................................. 2-146

2.4.3.1 Summary of Technical Information in

the A pplication ...................................................... 2-146

2.4.3.2 Staff Evaluation ..................................................... 2-147

2.4.3.3 C onclusion ............................................................ 2-147

2.4.4 Turbine Building ....................................................................... 2-147

2.4.4.1 Summary of Technical Information in

the A pplication ...................................................... 2-147

2.4.4.2 Staff Evaluation ..................................................... 2-148

2.4.4.3 C onclusion ............................................................ 2-149

2.4.5 Tunnels and Duct Banks .......................................................... 2-149

2.4.5.1 Summary of Technical Information in

the A pplication ...................................................... 2-149

2.4.5.2 Staff Evaluation ..................................................... 2-150

2.4.5.3 C onclusion ............................................................ 2-150

vii
2.4.6 Nuclear Service Cooling Water Structures ...................... 2-150

2.4.6.1 Summary of Technical Information in

the Application ....................................... 2-150

2.4.6.2 Staff Evaluation ...................................... 2-151

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

2.4.7 Concrete Tank And

Valve House Structures........................................... 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 Switchyard Structures............................................. 2-152

2.4.8.1 Summary of Technical Information

in the Application..................................... 2-152

2.4.8.2 Staff Evaluation ...................................... 2-153

2.4.8.3 Conclusion ........................................... 2-153

2.4.9 Fire Protection Structures ......................................... 2-153

2.4.9.1 Summary of Technical Information in

the Application ....................................... 2-153

2.4.9.2 Staff Evaluation ...................................... 2-154

2.4.9.3 Conclusion ........................................... 2-155

2.4.10 Radwaste Structures............................................. 2-155

2.4.10.1 Summary of Technical Information in

the Application ....................................... 2-155

2.4.10.2 Staff Evaluation..................................... 2-156

2.4.10.3 Conclusion .......................................... 2-156

2.4.11 Auxiliary Feedwater Pumphouse Structures ................... 2-156

2.4.11.1 Summary of Technical Information in

the Application ....................................... 2-156

2.4.11.2 Staff Evaluation..................................... 2-157

2.4.11.3 Conclusion .......................................... 2-157

2.4.12 Component Supports and Bulk Commodities .................. 2-157

2.4.12.1 Summary of Technical Information in

the Application ....................................... 2-157

2.4.12.2 Staff Evaluation..................................... 2-159

2.4.12.3 Conclusion .......................................... 2-160

2.5 Scoping and Screening Results'- Electrical and

Instrumentation and Controls Systems .................................... 2-160

2.5.1 Summary of Technical Information in the Application .......... 2-161

2.5.2 Staff Evaluation .................................................... 2-162

2.5.3 Conclusion.......................................................... 2-163

2.6 Conclusion for Scoping and Screening..................................... 2-163

3 AGING MANAGEMENT REVIEW RESULTS..................................... 3-1

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

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

3.0. 1.1 Overview of Table i s................................... 3-2

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

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

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

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

3.0.2.3 UFSAR Supplement .................................................. 3-6

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 .................................................... 3-36

3.0.3.3 AMPs Not Consistent with or Not Addressed in

the GALL Report ................................................... 3-125

3.0.4 Quality Assurance Program Attributes Integral to Aging

Management Programs ............................................................ 3-214

3.0.4.1 Summary of Technical Information in Application. 3-214

3.0.4.2 Staff Evaluation ..................................................... 3-214

3.0.4.3 C onclusion ............................................................ 3-215

3.1 Aging Management of Reactor Vessel, Reactor Vessel Internals,

and Reactor Coolant System .................................................................. 3-215

3.1.1 Summary of Technical Information in the Application .............. 3-215

3.1.2 Staff Evaluation ........................................................................ 3-216

3.1.2.1 AMR Results Consistent with the GALL Report .... 3-235

3.1.2.2 AMR Results Consistent with the GALL Report for

Which Further Evaluation is Recommended ......... 3-251

3.1.2.3 AMR Results Not Consistent with or

Not Addressed in the GALL Report ...................... 3-273

3.1.3 C onclusion ................................................................................ 3-283

3.2 Aging Management of Engineered Safety Features System .................. 3-284

3.2.1 Summary of Technical Information in the Application .............. 3-284

3.2.2 Staff Evaluation ........................................................................ 3-284

3.2.2.1 AMR Results Consistent with the GALL Report .... 3-294

3.2.2.2 AMR Results Consistent with the GALL Report for

Which Further Evaluation is Recommended ......... 3-299

3.2.2.3 AMR Results Not Consistent with or Not

Addressed in the GALL Report .............................. 3-307

3.2.3 C onclusion ................................................................................ 3-312

3.3 Aging Management of Auxiliary Systems ................................................ 3-312

3.3.1 Summary of Technical Information in the Application .............. 3-313

3.3.2 Staff Evaluation ........................................................................ 3-313

3.3.2.1 AMR Results Consistent with the GALL Report .... 3-330

3.3.2.3 AMR Results Not Consistent with or Not

Addressed in the GALL Report ............................. 3-373

3.3 .3 C onclusion ................................................................................ 3-4 27

3.4 Aging Management of Steam and Power Conversion Systems .............. 3-427

3.4.1 Summary of Technical Information in the Application .............. 3-427

3.4.2 Staff Evaluation ................................ 3-427

3.4.2.1 AMR Results Consistent with the GALL Report .... 3-435

ix
3.4.2.2 AMR Results Consistent with the GALL Report

for Which Further Evaluation is Recommended .... 3-443

3.4.2.3 AMR Results Not Consistent with or

Not Addressed in the GALL Report ...................... 3-465

3.4 .3 C onclusion ................................................................................ 3-486

3.5 Aging Management of Containments, Structures, and

Component Supports .............................................................................. 3-486

3.5.1 Summary of Technical Information in the Application .............. 3-487

3.5.2 Staff Evaluation ........................................................................ 3-487

3.5.2.1 AMR Results Consistent with the GALL Report .... 3-499

3.5.2.2 AMR Results Consistent with the GALL Report for

Which Further Evaluation is Recommended ......... 3-501

3.5.2.3 AMR Results Not Consistent with or Not

Addressed in the GALL Report ............................. 3-521

3.5.3 C onclusion ................................................................................ 3-528

3.6 Aging Management of Electrical and Instrumentation and

Controls System ................................................................. 3-528

3.6.1 Summary of Technical Information in the Application .............. 3-528

3.6.2 Staff Evaluation ........................................................................ 3-528

3.6.2.1 AMR Results Consistent with the GALL Report .... 3-532

3.6.2.2 AMR Results Consistent with the GALL Report

for Which Further Evaluation is Recommended .... 3-534

3.6.2.3 AMR Results Not Consistent with or Not

Addressed in the GALL Report ............................. 3-541

3.6.3 C onclusion ................................................................................ 3-543

3.7 Conclusion for Aging Management Review Results ............................... 3-543

4 TIME-LIMITED AGING ANALYSES .................................................................. 4-1

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

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

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

4 .1.3 C onclusion .................................................................................... 4-3

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

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

4.2.1.1 Summary of Technical Information in the Application4-4

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

4.2.1.3 UFSAR Supplement .................................................. 4-5

4.2.1.4 C onclusion ................................................................ 4-5

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

4.2.2.1 Summary of Technical Information in the Application4-6

4.2.2.2 Staff Evaluation ......................................................... 4-7

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

4 .2.2.4 C onclusion ................................................................ 4-8

4.2.3 Pressurized Thermal Shock ......................................................... 4-8

4.2.3.1 Summary of Technical Information in the Application4-8

4.2.3.2 Staff Evaluation ......................................................... 4-9

4.2.3.3 UFSAR Supplement ................................................ 4-10

x
4.2.3.4 Conclusion .............................................................. 4-10

4.2.4 Adjusted Reference Temperature .............................................. 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 .............................................................. 4-11

4.2.5 Pressure Temperature Limits ....................... 4-11

4.2.5.1 Summary of Technical Information in the

Application .............................................................. 4-11

4.2.5.2 Staff Evaluation ....................................................... 4-12

4.2.5.3 UFSAR Supplement ................................................ 4-12

4.2.5.4 Conclusion .............................................................. 4-12

4.3 Metal Fatigue ............................................................................................ 4-13

4.3.1 Fatigue of ASME Class 1 Components ...................................... 4-13

4.3.1.1 Class 1 Piping and Component Design Transient

Cycles ..................................................................... 4-13

4.3.1.2 CUF Monitoring - SG Main and Auxiliary Feedwater

Nozzles ................................................................... 4-15

4.3.1.3 CUF Monitoring- Charging Nozzles ....................... 4-16

4.3.1.4 Thermal Stratification of the Surge Line and Lower

Pressurizer Head .................................................... 4-17

4.3.1.5 Effects of Reactor Coolant System Environment on

Fatigue Life of Piping and Components .................. 4-19

4.3.1.6 Full Structural Weld Overlays on Pressurizer Spray

Nozzles, Safety and Relief Nozzles, and Surge

Nozzles ................................................................... 4-22

4.3.1.7 High-Energy Line-Break Postulated Locations

Based on Fatigue Cumulative Usage Factor .......... 4-23

4.3.2 Fatigue of ASME Non-Class 1 Components .............................. 4-25

4.3.2.1 Summary of Technical Information in the

Application .............................................................. 4-25

4.3.2.2 Staff Evaluation ....................................................... 4-26

4.3.2.3 UFSAR Supplement ................................................ 4-28

4.3.2.4 Conclusion .............................................................. 4-28

4.3.3 Fatigue of the Reactor Coolant Pump Flywheel ......................... 4-28

4.3.3.1 Summary of Technical Information in the

Application .............................................................. 4-28

4.3.3.2 Staff Evaluation ....................................................... 4-28

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

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

4.3.4 Fatigue of Reactor Vessel Supports ........................................... 4-29

4.3.4.1 Summary of Technical Information in the

Application .............................................................. 4-29

4.3.4.2 Staff Evaluation ............. * ......................................... 4-29

4.3.4.3 UFSAR Supplement ................................................ 4-30

4.3.4.4 Conclusion .............................................................. 4-30

4.3.5 Fatigue of Steam Generator Secondary Manway and

Handhole Bolts ........................................................................... 4-30

xi
4.3.5.1 Summary of Technical Information in the

Application .............................................................. 4-30

4.3.5.2 Staff Evaluation ....................................................... 4-30

4.3.5.3 UFSAR Supplement ................................................ 4-31

4.3.5.4 Conclusion .............................................................. 4-31

4.3.6 Fatigue of Reactor Vessel Internals ........................................... 4-31

4.3.6.1 Summary of Technical Information in the

Application .............................................................. 4-31

4.3.6.2 Staff Evaluation ....................................................... 4-32

4.3.6.3 UFSAR Supplement ................................................ 4-32

4.3.6.4 Conclusion .............................................................. 4-32

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

4.4.1 Summary of Technical Information in the Application ................ 4-33

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

4.4.3 UFSAR Supplement ................................................................... 4-34

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 .......................................................................... 4-35

4.5.3 UFSAR Supplement ................................................................... 4-36

4.5.4 Conclusion .................................................................................. 4-36

4.6 Penetration Load Cycles ........................................................................... 4-36'

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

4.6.2 Staff Evaluation .......................................................................... 4-37

4.6.3 UFSAR Supplement ............................................................. * ...... 4-38

4.6.4 Conclusion .................................................................................. 4-38

4.7 Other Plant Specific Analysis .................................................................... 4-38

4.7.1 Leak-Before-Break Analysis ....................................................... 4-38

4.7.1.1 Summary of Technical Information in the

Application .............................................................. 4-38

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

4.7.1.3 UFSAR Supplement ................................................ 4-40

4.7.1.4 Conclusion .............................................................. 4-40

4.7.2 Fuel Oil Storage Tank Corrosion Allowance .............................. 4-41

4.7.2.1 Summary of Technical Information in the

Application .............................................................. 4-4 1

4.7.2.2 Staff Evaluation ....................................................... 4-4 1

4.7.2.3 UFSAR Supplement ................................................ 4-45

4.7.2.4 Conclusion ......................................................... 4-4 5

4.7.3 Steam Generator Tube, Loss of M aterial ................................... 4-46

4.7.3.1 Summary of Technical Information in the

Application .............................................................. 4-4 6

4.7.3.2 Staff Evaluation ....................................................... 4-4 6

4.7.3.3 UFSAR Supplement ................................................ 4-47

4.7.3.4 Conclusion .............................................................. 4-4 7

4.7.4 Cold Overpressure Protection System ....................................... 4-4 7

xii
4.7.4.1 Summary of Technical Information in the

A pplication ............................................................... 4-47

4.7.4.2 Staff Evaluation ....................................................... 4-48

4.7.4.3 UFSAR Supplement ................................................ 4-49

4.7.4.4 C onclusion .............................................................. 4-4 9

4.7.5 Underclad Cracking of the Reactor Pressure Vessel ................. 4-49

4.7.2.1 Summary of Technical Information in the

A pplication .............................................................. 4-4 9

4.7.5.2 Staff Evaluation ....................................................... 4-50

4.7.5.3 UFSAR Supplement ................................................ 4-51

4.7.5.4 C onclusion .............................................................. 4-52

4.8 Conclusion for TLAAs ............................................................................... 4-52

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

C O N C LU S IO N ................................................................................................ 6-1

VEGP UNITS 1 AND 2 LICENSE RENEWAL COMMITMENTS ...................... A-1

CHRONOLOGY .............................................................................................. B-1

PRINCIPAL CONTRIBUTORS ........................................................................ C-1

R E FE R E N C ES ................................................................................................. D -1

Tables

Table 1.4-1 Current Interim Staff Guidance ......................................................... 1-7

Table 3.0.3-1 VEGP Aging Management Programs ............................................ 3-7

Table 3.1-1 Staff Evaluation for Reactor Vessel, Reactor Vessel Internals,

and Reactor Coolant System Components in the GALL Report ....................... 3-216

Table 3.2-1 Staff Evaluation for Engineered Safety Features System

Components in the GALL Report ...................................................................... 3-285

Table 3.3-1 Staff Evaluation for Auxiliary System Components

in the G A LL R eport ........................................................................................... 3-314

Table 3.4-1 Staff Evaluation for Steam and Power Conversion Systems

Components in the GALL Report ...................................................................... 3-428

Table 3.5-1 Staff Evaluation for Containments, Structures, and

Component Supports in the GALL Report ........................................................ 3-488

xiii
Table 3.6-1 Staff Evaluation for Electrical and Instrumentation

and Controls in the GALL Report ...................................................................... 3-529

Table 4.7.2-1: Summary of the Corrosion Allowance Analysis for

the Diesel Fuel Oil Storage Tanks and Associated

Fuel O il D elivery P iping ....................................................................................... 4-43

xiv
ABBREVIATIONS

AB auxiliary building

ACI American Concrete Institute

ACRS Advisory Committee on Reactor Safeguards

ADAMS Agencywide Document Access and Management System

AERM aging effect requiring management

AFW auxiliary feedwater

AISC American Institute of Steel Construction

AMP aging management program

AMR aging management review

AMSAC ATWS mitigation system actuation circuitry

ANSI American National Standards Institute

ART adjusted reference temperature

ASME American Society of Mechanical Engineers

ASTM American Society for Testing and Materials

ATWS anticipated transient without scram

AWWA American Water Works Association

BAC boric acid corrosion

BWR boiling water reactor

B&PV boiler and pressure vessel

CASS cast austenitic stainless steel

CCW component cooling water

CET core exit thermocouple

CF chemistry factor

CFR Code of Federal Regulations

Cl confirmatory item

CLB current licensing basis

COPS cold overpressure protection system

CRDM control rod drive mechanism

CR condition report

CRGT control rod guide tube

CS containment spray

CST condensate storage tank

CTMT containment

CTB containment building

CUF cumulative usage factor

CVCS chemical and volume control system

DAW dry active waste

DBA design basis accident

DBE design basis event

DC direct current

DW demineralized water

ECCS emergency core cooling system

EDG emergency diesel generator

EFPY effective full-power year

xv
EHC electrohydraulic control

EOL end of life

EPRI Electric Power Research Institute

EQ environmental qualification

ESF engineered safety feature

FAC flow-accelerated corrosion

Fen environmental fatigue life correction factor

FP fire protection

FPP fire protection plan

FR Federal.Register

FRRADS flood-retaining rooms, alarms, and drain system

FW feedwater

GALL Generic Aging Lessons Learned Report

GDC general design criteria or general design criterion

GElS Generic Environmental Impact Statement

GL generic letter

GPC Georgia Power Company

GSI generic safety issue

HAZ heat-affected zone

HELB high-energy line break

HE/ME high energy/moderate energy

HJTC heated junction thermocouple

HVAC heating, ventilation, and air conditioning

HX heat exchanger

I&C instrumentation and controls

IASCC irradiation assisted stress corrosion cracking

IEEE Institute of Electrical and Electronics Engineers

IGA intergranular attack

IN information notice

INPO Institute of Nuclear Power Operations

IPA integrated plant assessment

ISG interim staff guidance

ISO International Organization for Standardization

ISI inservice inspection

LBB leak-before-break

LOCA loss of coolant accident

LOSP loss of offsite power

LR license renewal

LRA license renewal application

MPL master parts list

MSLB main steam line break

MWe megawatts electric

MWt megawatts thermal

NDE nondestructive examination

xvi
NEI Nuclear Energy Institute

NPS nominal pipe size (in inches)

NRC U.S. Nuclear Regulatory Commission

NSCW nuclear service cooling water

NSR nonsafety-related

NSSS nuclear steam supply system

OBE operating basis earthquake

ODSCC outside-diameter stress corrosion cracking

01 open item

P&ID piping and instrumentation diagram

PRF penetration room filtration

PSRF nonsafety-related that can prevent a safety-related function

PTLR pressure-temperature limits report

PTS pressurized thermal shock

PVC polyvinyl chloride

PW pipe whip

PWR pressurized water reactor

PWSCC primary water stress corrosion cracking

RAI request for additional information

RCP reactor coolant pump

RCPB reactor coolant pressure boundary

RCS reactor coolant system

RG regulatory guide

RHR residual heat removal

RI-ISI risk-informed inservice inspection

RMWST reactor makeup water storage tank

RPV reactor pressure vessel

RTNDT reference temperature for nil ductility transition

RTpTs reference temperature for pressurized thermal shock

RTS reactor trip system

RVCH reactor vessel closure head

RVLIS reactor vessel level indicating system

RWST refueling water storage tank

RV reactor vessel

SBO station blackout

SCs structures and components

SCC stress-corrosion cracking

SER safety evaluation report

SFP spent fuel pool

SG steam generator

SGBD steam generator blowdown

SI safety injection

SMP structural monitoring program

SNC Southern Nuclear Operating Company, Inc.

SOC statement of consideration

SR safety-related

SRP Standard Review Plan

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

Power Plants

SSCs systems, structures, and components

SSE safe-shutdown earthquake

SW service water

TLAA time-limited aging analysis

TS technical specifications

TSP trisodium phosphate

UFSAR updated final safety analysis report

USE upper-shelf energy

UT ultrasonic testing

UV ultraviolet

VEGP Vogtle Electric Generating Plant

WCAP Westinghouse Commercial Atomic Power

WOG Westinghouse Owner's Group

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

Vogtle Electric Generating Plant (VEGP), Units 1 and 2, as filed by the Southern Nuclear

Operating Company, Inc. (SNC or the applicant). By letter dated June 29, 2007, SNC submitted

its application to the U.S. Nuclear Regulatory Commission (NRC) for renewal of the VEGP

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 Donnie Ashley. Mr. Ashley may be contacted by telephone at 301-415-3191 or by electronic

mail at Donnie.Ashley@nrc.gov. Alternatively, written correspondence may be sent to the

following address:

Division of License Renewal

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

Attention: Donnie Ashley, Mail Stop 011-F1

In its June 27, 2007, submission letter, the applicant requested renewal of the operating

licenses issued under Section 103 (Operating License Nos. NPF-68 and NPF-81) of the Atomic

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

expiration date of January 16, 2027, for Unit 1, and February 9, 2029, for Unit 2.

Although the Unit 2 license only has 18 years experience, the applicant requested and was

granted an exemption on January 9, 2007, (ML062770492) to that requirement prior to the

submittal of the application for both units. VEGP is located approximately 26 miles southeast of

Augusta, Georgia. The NRC issued the construction permits for Unit 1 on June 28, 1974, and on

June 28, 1974, for Unit 2. The NRC issued the operating licenses for Unit 1 on March 16, 1987,

and on March 31, 1989, for Unit 2. Units 1 and 2 are a dry ambient containment pressurized

water reactor design. Westinghouse Electric supplied the nuclear steam supply system and

Georgia Power Company originally designed and constructed the balance of the plant with the

assistance of its agent, Southern Services and Bechtel. The licensed power output of each unit

is 3565 megawatt thermal with a gross electrical output of approximately 1208 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 VEGP license renewal is based on the applicant's LRA and on its responses to the

staffs requests for additional information (RAIs). The applicant supplemented the LRA and

provided clarifications through its responses to the staff s RAIs in audits, meetings, and

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

information submitted through February 16, 2009. The public may view the LRA and all

1-1
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), and at the Burk County Library, 130 Highway 24 South,

Waynesboro, Georgia 30830. 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.

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-1800, 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 staffs 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 staffs 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 34, "Generic

Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 34,

Regarding Vogtle Electric Generating Plant, Units 1 and 2, Draft Report for Comment," on

April 22, 2008.

1.2 Regulatory Evaluation

1.2.1 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.

1-2
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 finds 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, particularly

the implementation of 10 CFR 50.65, "Requirements for Monitoring the Effectiveness of

Maintenance at Nuclear Power Plants," which regulates management of plant-aging

phenomena. As a result of this finding, the Commission 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 rule

changes were initiated 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 NRC 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.

1.2.2 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 (EQ), pressurized thermal shock

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

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

1-3
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.

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.

1.2.3 Environmental Review

Part 51 of 10 CFR contains regulations on 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 "Draft Generic Supplemental

Environmental Impact Statement, Vogtle Electric Generating Plant Site, Supplement 34,

NUREG-1437", (ML081900016) (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 (i.e., Category 2 issues).

1-4
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 September 27, 2007, in Waynesboro, Georgia, to identify

plant-specific environmental issues. The draft, plant-specific GElS Supplement 34 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 June 3, 2008, in Waynesboro,

Georgia, to discuss draft, plant-specific GElS Supplement 34. After considering comments on

the draft, the staff published the final, plant-specific GElS Supplement 34, on December 11,

2008.

1.3 Principal Review Matters

10 CFR Part 54 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 of 10 CFR, "Standards for Issuance of a Renewed

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

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 original Indemnity Agreement for VEGP, which was effective as of August

21, 1986, provides that such agreement "shall terminate at the time of expiration

of that license specified in Item 3 of the Attachment, which is the last to expire."

The license originally listed in Item 3 of the Attachment was SNM-1 967. Since

August 21, 1986, however, the Indemnity Agreement has been amended in order

to add license numbers NPF-61, NPF-68, SNM-1981, NPF-79 and NPF-81 to

Item 3 of the Attachment. As a consequence of these amendments, the existing

Indemnity Agreement is presently due to terminate at midnight, February 9, 2029,

as the last of these licenses expires. SNC requests that conforming changes be

made to Item 3 of the Attachment to the Indemnity Agreement (and any other

applicable provisions of the Indemnity Agreement and/or the Attachment) in order

to make clear that the Indemnity Agreement is extended until the last expiration

date of the renewed VEGP operating licenses issued by the Commission in

response to this application.

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

1-5
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 staffs 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 letter dated June 26, 2008, the applicant

submitted an LRA update which summarize the CLB changes that have occurred during the

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

under staff review.

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 VEGP operating licenses. This statement adequately addresses the

10 CFR 54.22 requirement.

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

(ACRS)," 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.

1-6
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 3.0.3.3.5

reactor coolant pressure boundary in the reactor pressure boundary.

(LR-ISG-1 9B)

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 to VEGP

containments corrosion of drywell shell in Mark I

(LR-ISG-2006-01) containments.

1.5 Summary of Open Items

As a result of its review of the LRA, including additional information submitted through February

16, 2009, the staff concludes that no open items exist which would require a formal response

from the applicant.

1.6 Summary of Confirmatory Items

As a result of its review of the LRA, including additional information submitted through February

16,2009, the staff concludes that no confirmatory items exist which would require a formal

response from the applicant.

1.7 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 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 second 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.

The third license condition requires the applicant to complete the commitments in the UFSAR

supplement, and notify the NRC in writing when implementation of those activities required prior

to the period of extended operations are complete and can be verified by NRC inspection.

1-7

SECTION 2

STRUCTURES AND COMPONENTS SUBJECT TO AGING

MANAGEMENT REVIEW

2.1 Scoping and Screeninq Methodologv

2.1.1 Introduction

Title 10, Section 54.21 of the Code of Federal Regulations (10 CFR 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) from all of the

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

accordance with 10 CFR 54.4.

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

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

Vogtle Electric Generating Plant (VEGP), Units 1 and 2, that are within the scope of license

renewal and the SCs that are subject to an AMR. The staff reviewed the Southern Nuclear

Operating Company, Inc., (SNC or 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 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) and other applicants, and NEI.

2.1.2 Summary of Technical Information in the Application

LRA Sections 2.0 and 3.0 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 under 10 CFR 54.4(a), and the process used to identify the SCs

that are subject to an AMR, as required by 10 CFR 54.21(a)(1). Additionally, Section 2.2, "PlantLevel Scoping Results," Section 2.3,"Scoping and Screening Results - Mechanical Systems;"

Section 2.4, "Scoping and Screening Results - Structural Systems;" and Section 2.5, "Scoping

and Screening Results - Electrical and Instrumentation and Control (I&C) Systems;" of the LRA,

provided the results of the process used to identify the SCs that are subject to an AMR. Section

3.0, "Aging Management Review Results," of the LRA, contained the following information:

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

Section 3.2, "Aging Management of Engineered Safety Features Systems;" Section 3.3, "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

2-1
Component Supports;" and Section 3.6, "Aging Management of Electrical and Instrumentation

and Controls (I&C) Components." Section 4.0 of the LRA, "Time-Limited Aging Analyses

(TLAA)," contained the applicant's identification and evaluation of TLAA.

2.1.3 Scoping and Screening Program Review

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

guidance contained in Section 2.1, "Scoping and Screening Methodology," of NUREG-1800,

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

Revision 1 (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 the identification of plant SSCs within the scope of the

Rule.

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

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 the 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 described a process for identifying SSCs that

are within the scope of license renewal, in accordance with the requirements of

10 CFR 54.4(a).

* Section 2.2 to ensure that the applicant described a process for determining the SCs

that are subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1)

and (a)(2).

In addition, the staff conducted a scoping and screening methodology audit at the applicant's

corporate facility, located near Birmingham, Alabama, during the week of September 17-21,

2007. 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. In addition, the staff conducted detailed discussions with

the applicant on the implementation and control of the license renewal program and reviewed

administrative control documentation and selected design documentation used by the applicant

during the scoping and screening process. The staff reviewed training for personnel that

developed the LRA, and quality practices used by the applicant to develop the LRA.

Additionally, the staff evaluated the quality attributes of the applicant's aging management

program activities described in Appendix A, "Final Safety Analysis Report Supplement," and

Appendix B, "Aging Management Programs and Activities," of the LRA. The staff reviewed

scoping and screening results reports for the main steam system (MSS), emergency core

cooling system (ECCS), and the nuclear service cooling water tower (NSCW) to ensure that the

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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 Used for Scoping and

Screening

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

documented in the Scoping and Screening Methodology audit report, dated March 17, 2008

(ML080640502), to verify that the process used to identify SCs subject to an AMR was

consistent with 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 had adequately implemented the

procedural guidance during the scoping and screening process.

2.1.3.1.1 Technical Information in the Application

LRA Section 2.1, "Scoping and Screening Methodology," states that the applicant reviewed the

following information sources during the license renewal scoping and screening process:

" Design Criteria Documents

* Update Final Safety Analysis Report (UFSAR)

" Plant drawings

* Maintenance Rule Scoping Documents

* Technical Specifications and Bases

* Safety Evaluation Reports

* Equipment Databases

" Master List of Environmental Qualification (EQ) Equipment

" Station Blackout (SBO) Analysis Report

" Licensing correspondence

" Vendor documents

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 54.4

(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

Scopincq and Screening Implementation Procedures The staff reviewed the applicant's scoping

and screening methodology implementation procedures, including license renewal guidelines,

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 the NEI 95-10. The

staff finds the overall process used to implement the 10 CFR 54 requirements described in the

implementing documents and AMRs was consistent with the Rule and industry guidance.

Guidance for determining plant SSCs within the scope of the Rule, and for determining which

component types of the SCs, within the scope of license renewal, were subject to an AMR, were

contained in the applicant's 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 NRC

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staff guidance documented in SRP-LR, and the information in request for addition information

(RAI) responses dated February 27, 2008.

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

screening methodology instructions were consistent with Section 2.1 of the LRA. 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 NRC requirements applicable to a specific plant

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

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

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

Technical Specifications, design-basis information documented in the most recent UFSAR, and

applicant's commitments remaining in effect that were made in docketed licensing

correspondence such as applicant responses to NRC bulletins, generic letters, and enforcement

actions, as well as applicant 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 criteria

documents, Technical Specifications and bases, safety evaluation reports, equipment

databases, the EQ master list, SBO analysis report, licensing correspondence, piping and

instrumentation drawings (P&IDs), plant layout drawings, and vendor documents. The staff

verified that the applicant's detailed license renewal program guidelines required use of the CLB

source information in developing scoping evaluations.

The VEGP Design Criteria DC-1 000-G and the Maintenance Rule list of systems were the

applicant's primary repository for system identification and classification information. During the

audit, the staff reviewed the applicant's administrative controls for the VEGP design criteria,

maintenance rule information and other information sources used to verify system information.

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 system

identification and classification information contained in the applicable VEGP documentation,

the NRC staff concluded that the applicant had established adequate measures to control the

integrity and reliability of VEGP system identification and classification data, and therefore, the

staff concludes that the information sources used by VEGP during the scoping and screening

process provided a sufficiently controlled source of system and component data to support

scoping and screening evaluations.

During the staff's review of the applicant's CLB evaluation process, the applicant provided the

staff with a discussion regarding 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

concludes that Section 2.1 of the LRA 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 the implementing procedures and results reports

used to support identification of SSCs relied upon to demonstrate compliance with the

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safety-related criteria, nonsafety-related criteria and the regulated events criteria referenced in

10 CFR 54.4(a). The applicant's license renewal program guidelines provided a comprehensive

listing of documents used to support scoping and screening evaluations. The staff finds these

design documentation sources to be 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 a review of information provided in Section 2.1 of the LRA, a review of the

applicant's detailed scoping and screening implementation 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 SRP-LR and 10 CFR 54 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 quality controls used by the applicant to ensure that scoping and

screening methodologies used in the LRA were adequately implemented. Although the

applicant did not develop the LRA under a 10 CFR 50, Appendix B, QA program, the applicant

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

The applicant developed written procedures to govern the implementation of the

scoping and screening methodology.

The applicant incorporated lessons learned from prior license renewal

applications. Previous NRC requests for additional information were also

reviewed to ensure that applicable issues were addressed.

The applicant used a review system to verify and validate the controlling

documents.

The LRA was reviewed by the applicant's on-site and corporate personnel and

industry peers, prior to submittal to the NRC.

The applicant's QA organization performed an internal audit as an independent

review of the LRA. The purpose of the audit was to ensure that the license

renewal documents, procedures and technical information were developed in

accordance with the requirements of 10 CFR 54.4.

2.1.3.2.2 Conclusion

The staff reviewed reports, LRA development guidance, and discussed the quality controls

applied to the LRA development with the applicant's license renewal staff. The staff concludes

that the quality assurance activities met current regulatory requirements and provided additional

assurance that LRA development activities were performed consistently with the applicant's

LRA program requirements.

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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 would be performed in a consistent and appropriate

manner. The license renewal scoping and screening activities and LRA development were

accomplished by the applicant's corporate staff and VEGP site staff.

The applicant's training process provided both instruction and written guidance documents to

the personnel involved with LRA development in order to ensure that the personnel had an

understanding of the license renewal procedures, industry guidance and regulations applicable

to the scoping and screening activities and LRA development. The applicant developed a

checklist used as a tracking system as a basis for the personnel training record which listed the

completed training sessions and the documents reviewed. Both corporate and site license

renewal personnel were also qualified in plant support which focused on core plant training and

how to support the plant in license renewal. In addition, the applicant provided training on

design modification, plant support, components and systems in the mechanical, electrical and

civil disciplines. The applicant developed technical training in scoping and screening

methodology to establish the necessary knowledge and understanding of the license renewal

process and the terminology used to support the license renewal review. The applicant's

management and staff also participated in industry groups and task forces.

2.1.3.3.2 Conclusion

The staff reviewed completed qualification and training records and completed checklists of

several of the applicant's license renewal personnel and concluded that the records adequately

documented the training for the applicant's staff. Additionally, based on discussions with the

applicant's license renewal personnel, the staff concludes that personnel were knowledgeable

regarding the license renewal process requirements and the specific technical issues within

their areas of responsibility.

2.1.3.4 Scoping and Screening Program Review Conclusion

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

applicant's detailed scoping and screening implementation 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 was consistent with the

SRP-LR and 10 CFR 54 and is therefore acceptable.

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 using design criteria and maintenance rule

system information. Additional information on mechanical system functions was obtained from

the UFSAR, plant layout drawings and P&IDs. Structural functions were identified using UFSAR,

the maintenance rule basis documents for structures, the plant seismic categorization

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information, and structural drawings. All electrical and I&C systems, and electrical and I&C

components in mechanical systems, were included within in the scope of license renewal.

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

2.1.4.1.1 Technical Information in the Application

LRA Section 2.1.2.1, "10 CFR 54.4(a)(1) - Safety-Related," describes the scoping methodology

as it relates to the safety-related criterion in accordance with 10 CFR 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 VEGP project classification designators (VEGP

UFSAR Section 3.2.2.1) which are used in the plant documentation, the safety design bases

discussions in the design criteria documents, the safety evaluation discussions in the UFSAR,

and the safety-related determination results for the Maintenance Rule scoping. Systems and

structures whose intended functions met one or more of the criteria in 10 CFR 54.4(a)(1 ) were

included within the scope of license renewal. The applicant confirmed that all plant conditions,

including conditions of normal operation, design basis accidents, external events, and natural

phenomena for which the plant must be designed, were considered for license renewal scoping

under 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: (i) the integrity of the reactor coolant pressure boundary; (ii) the capability to shut

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

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

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

the Code of Federal Regulations.

With regard to identification of DBEs, Section 2.1.3, "Review Procedures," of the SRP-LR

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 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, design basis accidents, external events and natural

phenomena) that were applicable to VEGP. The applicant identified the documents that

described the events, which are contained in the UFSAR and system design criteria which

discussed events such as internal and external flooding tornados, and missiles. The applicant

also reviewed licensing correspondence and design criteria.

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The staff concludes that the applicant's evaluation of DBEs was consistent with the SRP-LR.

The applicant performed scoping of SSCs for the 54.4(a)(1) criterion in accordance with the

license renewal implementing documents which provided 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 the implementing 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.

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

10 CFR 54.4(a)(1) and concluded that the VEGP CLB definition of safety-related did not contain

references to 10 CFR 50.34 or 10 CFR 50.67(b)(2) as specified in the Rule. The applicant's

definition of safety-related and exceptions to the definition in the Rule are documented in LRA

Section 2.1.2.1. Based on this review, the staff verified that 10 CFR 50.34(a)(1) is not applicable

to VEGP, Units 1 or 2, as it concerns applicants for a construction permit. The staff concludes

that 10 CFR 50.67(b)(2), which concerns the use of an alternate source term in the dose

analysis, is not applicable to VEGP, Units 1 or 2, which has not applied for the use of an

alternate source term.

The staff reviewed a sample of the license renewal scoping results for the MSS, ECCS, and the

NSCW tower to provide additional assurance that the applicant adequately implemented their

scoping methodology with respect to 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 in scope in accordance with the 10 CFR 54.4(a)(1) criteria.

The staff concludes that additional information would be required to complete the review of the

applicant's scoping methodology. RAI 2.1-1, dated January 28, 2008, stated that during the

NRC audit, the staff noted that source documents used to identify the SSCs which met the

scoping criteria of 10 CFR 54.4(a)(1), including the VEGP updated safety analysis report

Section 3.2, and procedures AP 05-007, Section 6.1.4, and AP 23M-001, Section 4.17.1, had

differing definitions of safety-related and also cited superseded regulatory text in establishing

the scoping criteria to be used in identifying VEGP SSCs in accordance with 10 CFR 54.4(a)(1)

requirements. Therefore, 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.

In the response to RAI 2.1-1 dated February 27, 2008, the applicant stated,

"The VEGP definition of safety related for current design activities is defined in procedure

ENG-016 which reads:

Any structure, system, component, or part used in a nuclear power plant that is relied

upon during or following design basis events to assure

* The integrity of the reactor coolant pressure boundary,

0 The capability to shut down the reactor and maintain it in safe shutdown condition, or

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* The capability to prevent or mitigate the consequences of accidents that could result

in potential offsite exposures comparable to the guideline exposures of

10 CFR 100.11."

As noted in the question, wording in historic procedures has not always been section specific,

but the intent and application was consistent. The CLB classification of VEGP SSCs was based

on design criteria documents. The applicant's governing procedure for creation of these

documents (PS-VS-001) was the primary source of the wording discrepancy in that it defined

safety related as:

Equipment, components, or structures perform a safety-related function if that function is

required to:

* Maintain the integrity of the reactor coolant pressure boundary.

* Shut down the plant and maintain the plant in a safe shutdown condition.

* Prevent accidents or mitigate their consequences.

This definition could not be used without further clarification because it did not define which

accidents or consequences had been considered. However, the staff understood that this

paragraph referred to accidents defined by limits in 10 CFR 100. This inference was

demonstrated in the applicant's procedure (DC-1010), which was the section of the design

manual that defined the safety classification of the VEGP SSCs. This section defined safety

related as:

Systems, structures, and components important to safety are defined as those items

necessary to ensure:

" The integrity of the reactor coolant pressure boundary.

* The capability to shut down the reactor and maintain it in a safe shutdown condition.

* The capability to prevent or mitigate the consequences of accidents that could result

in potential offsite exposures comparable to the guideline exposures of 10 CFR 100.

While this reference does not include the specific section (10 CFR 100.11), the section of the

10 CFR 100 that defined "potential off site exposures" during initial classification of VEGP SSCs

was Section 11. Therefore, the CLB definition of safety related SSCs for VEGP has been

consistently applied and meets the criteria of 10 CFR 54.4(a)(1). (As noted in the VEGP LRA,

10 CFR 50.34(1)(1) and 10 CFR 50.67(b)(2) do not apply to VEGP).

The staff reviewed the applicant's response to RAI 2.1-1 and determined that the applicant had

provided a description of an adequate process used to ensure that SSCs had been

appropriately included within the scope of license renewal, in accordance with

10 CFR 54.4(a)(1) and that the definitions for safety-related used to classify SSCs, as described

in the response to RAI 2.1-1, was consistent with 10 CFR 54.4(a)(1).

2.1.4.1.3 Conclusion

On the basis of a review of systems sampled, discussions with the applicant, review of the

applicant's scoping process, and the applicant's response to RAI 2.1-1, the staff concludes that

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the applicant's methodology for identifying systems and structures is consistent with the SRPLR and 10 CFR 54.4(a)(1), and is therefore acceptable.

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

2.1.4.2.1 Technical Information in the Application

LRA Section 2.1.2.2, "10 CFR 54.4(a)(2) - Nonsafety-Related SSCs Affecting Safety-Related

SSCs," 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 10 CFR 54.4(a)(2) scoping

methodology was based on guidance provided in Appendix F of NEI 95-10, Rev. 6. The

applicant evaluated the impacts of nonsafety-related SSCs that met 10 CFR 54.4(a)(2) criteria

by considering functional failures and physical failures.

Functional Failure of Nonsafety-Related SSCs LRA 2.1.2.2.1, "Nonsafety-Related SSCs That

Perform A Required Function In Support Of Safety-Related Functions," stated that SSCs

required to perform a function in support of safety-related components are generally classified

as safety-related and are included within the scope of license renewal in accordance with

10 CFR 54.4(a)(1).

For the few exceptions where nonsafety-related components are required to remain functional

to support a safety function, this system intended function was identified and the components

were included within the scope of license renewal in accordance with the requirements of

10 CFR 54.4(a)(2).

Nonsafety-Related SSCs directly connected to Safety-Related SSCs LRA 2.1.2.2.2, "NonsafetyRelated SSCs Directly Connected To Safety-Related SSCs and Relied Upon For Structural

Support Of Safety-Related SSCs," stated that nonsafety-related piping and supports are

included within the scope of license renewal up to and including the seismic anchor as identified

in the stress analysis, or to an equivalent anchor, or one of the other methods provided for in

NEI 95-10, Appendix F. The LRA defined equivalent anchor as a combination of restraints or

supports such that the nonsafety-related piping and associated SCs attached to safety-related

piping is included in scope up to a boundary point that encompasses two (2) supports

(restraints) in each of the three (3) orthogonal directions. The other methods used to define a

scoping boundary included bounding conditions discussed in NEI 95-10, including ending at a

base mounted component, flexible connection, or to include the entire piping run.

Nonsafety-Related SSCs With the Potential for Spatial Interaction With Safety-Related SSCs

LRA 2.1.2.2.3, "Nonsafety-Related SSCs Whose Failure Could Result In a Potential Spatial

Interaction with Safety-Related SSCs That Could Prevent Accomplishment of a Safety

Function," stated that nonsafety-related systems and nonsafety-related portions of safetyrelated 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 were defined as failures of

nonsafety-related SSCs that are located in the vicinity of safety-related SSCs creating the

potential for interaction between the SSCs due to physical impact, pipe whip, jet impingement, a

harsh environment resulting from a piping rupture, or damage due to leakage or spray that could

impede or prevent the accomplishment of the safety-related functions of a safety-related SSC.

Also included were nonsafety-related SSCs which provide protection from temperature

extremes, or detect flooding and leaks. Mitigative features, such as missile barriers, flood

barriers, and spray shields, were included within the scope of license renewal in accordance

with 10 CFR 54.4(a)(2). In addition, the preventive option described in Appendix F of NEI 95-10

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was used to determine the scope of license renewal with respect to the protection of safetyrelated 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 if fluid-filled

system components are located in the same space as safety-related equipment. A "space" was

defined as barriers composed of walls, floors and ceilings which prevented interaction between

safety-related and nonsafety-related SSCs.

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: (i) the integrity of the

reactor coolant pressure boundary; (ii) the capability to shut down the reactor and maintain it in

a safe shutdown condition; or (iii) the capability to prevent or mitigate the consequences of

accidents that could result in potential offsite exposures comparable to those referred to in

10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), or 10 CFR 100.11.

NRC Regulatory Guide 1.188, "Standard Format and Content for Applications to Renew Nuclear

Power Plant Operating Licenses," Revision 1, (Reg. Guide 1.188) provided NRC endorsement

of the use of NEI 95-10, Revision 6, which discusses in Appendix F, the NRC staff position on

54.4(a)(2) scoping criteria, nonsafety-related SSCs typically identified in the CLB, consideration

of missiles, cranes, flooding, high energy line breaks, nonsafety-related SSCs connected to

safety-related SSCs, nonsafety-related 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 NRC staff position (as discussed NEI 95-10, Rev. 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. NEI 95-10 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 2.1.2.2, where the applicant described the scoping methodology as it related to the

application of the 10 CFR 54.4(a)(2) nonsafety-related criteria. In addition, the staff reviewed the

applicant's results report which documented the guidance and corresponding results of the

applicant's 10 CFR 5.4.4(a)(2) scoping review which had been performed in accordance with

the guidance contained in NEI 95-10, Revision 6, Appendix F.

Nonsafety-Related SSCs Required to Perform a Function that Supports a Safety-Related SSC

The staff concludes that 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)(1) with several exceptions, which were

included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2). This

evaluating criteria was discussed in the applicant's 10 CFR 54.4(a)(2) report. The staff finds that

the applicant 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 The staff concludes that

in order to identify the nonsafety-related SSCs connected to safety-related SSCs and required

to be structurally sound to maintain the integrity of the safety-related SSCs, the applicant used a

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combination of the information contained in the VEGP structural analysis (to identify the

structural boundary), equivalent anchors and the bounding approach as described in NEI 95-10,

Appendix F. The applicant reviewed the safety-related to nonsafety-related interfaces for each

mechanical system in order to identify the nonsafety-related components located between the

interface and the structural boundary. The staff concludes that the applicant had included all

nonsafety-related SSCs within the structural boundary within the scope of license renewal in

accordance with 10 CFR 54.4(a)(2).

If a seismic support could not be located using the structural boundary, the applicant identified

the portion of the nonsafety-related piping up to, and including, an equivalent anchor or a

bounding condition such as a base-mounted component, flexible connection, or the end of the

piping run, in accordance with the guidance of NEI 95-10, Appendix F, which was included

within the scope of license renewal. The LRA and the applicant's implementing procedures

defined an equivalent anchor as two supports in each of the three orthogonal directions.

Nonsafety-Related SSCs with the Potential for Spatial Interaction with Safety-Related SSCs The

applicant considered physical impact (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" to

identify the portions of nonsafety-related systems with the potential for spatial interaction with

safety-related SSCs. The spaces approach focused on the interaction between nonsafetyrelated and safety-related SSCs that are located in the same space, which was defined as a

room or cubicle that is separated from other spaces by substantial objects (such as wall, floors,

and ceilings).

Physical Impact or Floodinq the applicant had considered situations where nonsafetyrelated supports for non-seismic piping systems with potential for spatial interaction with

safety-related SSCs for inclusion within the scope of license renewal in accordance with

10 CFR 54.4(a)(2). The applicant had identified the nonsafety-related SSCs by performing

a review of the UFSAR, CLB documents, industry guidance, equipment layout drawings,

composite drawings, isometric drawings and by performing walkdowns. Piping and

equipments supports and components were 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

as considered in the high energy line break (HELB) analysis for high energy systems) and

the piping sections are not required to be included within the scope of license renewal in

accordance with 10 CFR 54.4(a)(2) due to a physical impact hazard. The applicant

evaluated the missiles that could be generated from internal or external events such as

failure of rotating equipment. The nonsafety-related design features which protect safetyrelated SSCs from such missiles were included within the scope of license renewal. All

nonsafety-related cranes, monorails and hoists (overhead-handling systems) were included

within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) as structural

commodities due to the potential for interaction with safety-related SSCs.

Pipe Whip, Jet Impinqement. and Harsh Environment The applicant had evaluated

nonsafety-related portions of high energy lines against thelO CFR 54.4(a)(2) criteria. The

applicant's evaluation was based on a review of documents such as the UFSAR, design

criteria documents and relevant site documentation. The applicant's high energy systems

were evaluated to ensure identification of components that are part of nonsafety-related

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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 (piping, equipment and supports) was included

within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) and subject to an

AMR in order to provide assurance that those assumptions remain valid through the period

of extended operation. Also, as discussed in the VEGP 10 54.4(a)(2) report, the applicant

reviewed the reference documents, primarily the UFSAR and the VEGP Technical

Requirements Manual, that contained HELB analysis for inside and outside containment

and which identified high energy lines. Many of the identified systems were safety-related

or required for a regulated event 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 the potential for interaction with safety-related SSCs, were

included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2).

Spray and Leakage The applicant evaluated moderate and low energy systems which have

the potential for spatial interactions due to spray or 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 in the LRA, a space was defined as barriers

composed of walls, floors and ceilings which prevented interaction between safety-related

and nonsafety-related SSCs. 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 plant and industry operating experience, the applicant excluded

the nonsafety-related SSCs containing air or gas from the scope of license renewal with the

exception of lines containing hydrogen gas whose failure were determined to have a

potential impact on safety-related SSCs. The applicant then determined whether the

system had any components located within a space containing safety-related SSCs. Those

nonsafety-related SSCs determined to contain fluid or hydrogen gas, and located within a

space containing safety-related SSCs, were included within the scope of license renewal in

accordance with 10 CFR 54.4(a)(2).

The staff concludes that additional information would be required to complete the review of the

applicant's scoping methodology. During the on-site audit the staff reviewed the applicant's

technical evaluation for nonsafety-related affecting safety-related SSCs which discussed the

consideration of components located in the turbine building and identified as safety-related in

the UFSAR. The applicant concluded in the technical evaluation that, although the turbine

building contains components identified as safety-related in the UFSAR, these components are

not vulnerable to the effects of a failure of nonsafety-related SSCs in the non-seismic areas

within the limits of the CLB. Therefore, no additional SSCs located in the turbine building were

included within the scope of license renewal based on the requirements of 10 CFR 54.4(a)(2).

In RAI 2.1-2, dated January 28, 2008, the staff requested that the applicant provide the rationale

and basis for not including nonsafety-related SSCs in the vicinity of safety-related SSCs in the

turbine building within the scope of license renewal.

In the response to RAI 2.1-2 dated February 2.7, 2008, the applicant stated the following:

The following components in the turbine building are classified as safety related:

0 Turbine impulse pressure transmitters

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" Turbine steam bypass valve (steam dump valve) air supply solenoid valves

" High pressure turbine steam stop valve limit switches

" High pressure turbine steam control valve [electrohydraulic control] oil pressure

transmitters and manual isolation valves

The applicant stated that although these components are conservatively classified as safetyrelated they (1) perform no safety function, (2) are not credited in the accident analysis, and (3)

meet the VEGP CLB for preventing interactions from propagating back into the reactor

protection system and they can not prevent satisfactory accomplishment of any of the safety

related functions discussed in 10 CFR 54.4, paragraphs (a)(1) (i), (ii), or (iii). Based on the

review of the functions of the components classified as safety related in the turbine building, the

applicant determined that there were no nonsafety-related components located in the turbine

building whose failure could prevent the performance of a safety-related function.

Therefore, no components located within the turbine building were included within the scope of

license renewal in accordance with 10 CFR 54.4(a)(2).

The staff reviewed the applicant's response to RAI 2.1-2 and determined that the applicant had

provided a description of an adequate process to review the functions of the components

classified as safety-related and located in the turbine building. The staff concludes that the

applicant had adequately performed and documented a review to determine that certain

components located in the turbine building had been conservatively classified as safety-related

although they did not perform a safety-function as defined in the CLB and, therefore, there were

no nonsafety-related components located in the turbine building whose failure could prevent the

performance of safety-related function.

Protective Features The applicant evaluated protective features such as whip restraints, spray

shields, supports, 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 in accordance with 10 CFR 54.4(a)(2).

2.1.4.2.3 Conclusion

On the basis of a review of the applicant's scoping process and sample systems, discussions

with the applicant, and review of the information provided in the response to RAI 2.1-2, the staff

concludes that the applicant's methodology for identifying and including nonsafety-related

SSCs, which could affect the performance of a safety-related SSCs, within the scope of license

renewal, is consistent with the scoping criteria of 10 CFR 54.4(a)(2), and is therefore

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

LRA Section 2.1.2.3 , "10 CFR 54.4(a)(3) - Regulated Events," describes the methodology for

identifying those systems and structures within the scope of license renewal in accordance with

the Commission's criteria for five regulated events: (1) 10 CFR 50.48, "Fire Protection;" (2)

10 CFR 50.49, "Environmental Qualification of Electric Equipment Important to Safety for

Nuclear Power Plants;" (3) 10 CFR 50.61, "Fracture Toughness Requirements for Protection

Against Pressurized Thermal Shock Events;" (4) 10 CFR 50.62, "Requirements for Reduction of

Risk from Anticipated Transients Without Scram (ATWS) Events for Light-Water-Cooled Nuclear

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Power Plants;" and (5) 10 CFR 50.63, "Loss of All Alternating Current Power."

Fire Protection LRA Section 2.1.2.3.1, "10 CFR 50.48 - Fire Protection," described scoping of

systems and structures relied on in safety analyses or plant evaluations to perform a function

that demonstrates compliance with the fire protection criterion. The LRA stated the SSCs relied

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

with 10 CFR 50.48, "Fire Protection," were included in the scope of license renewal under the

10 CFR 54.4(a)(3) criterion.

The VEGP CLB documents applicable to the VEGP Fire Protection Program, such as the

UFSAR Section 9.5.1 and Appendices 9A and 9B, were reviewed to determine the SSCs relied

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

with 10 CFR 50.48. Based on the CLB, the applicant included the SSCs credited with fire

prevention, detection, and mitigation for areas containing equipment important to safety and for

certain radioactive waste areas (as required by the CLB), within the scope of license renewal.

The applicant also included in the scope of license renewal those SSCs relied upon in the CLB

to maintain the ability to perform reactor plant safe-shutdown functions in the event of a fire.

Environmental Qualification LRA Section 2.1.2.3.2, "10 CFR 50.49 - Environmental Qualification

(EQ)," describes the scoping of systems and structures relied on in safety analyses or plant

evaluations to perform a function in compliance with the EQ criterion. The LRA stated that the

master list of safety-related equipment located in a harsh environment (EQ master list) defines

the electrical equipment subject to the requirements of 10 CFR 50.49. The electrical

components on the EQ master list have been included in the scope of license renewal in

accordance with 10 CFR 54.4(a)(3).

Pressurized Thermal Shock LRA Section 2.1.2.3.3, "10 CFR 50.61 - Pressurized Thermal

Shock (PTS)," describes the scoping of systems and structures relied on in safety analyses or

plant evaluations to perform a function that demonstrates compliance with the PTS criterion.

The LRA stated that SSCs relied on in safety analyses or plant evaluations to perform a function

that demonstrates compliance with 10 CFR 50.61, "Fracture Toughness Requirements for

Protection Against Pressurized Thermal Shock Events," are within the scope of license renewal.

Based upon a review of design basis documentation, only the reactor vessels and the reactor

vessel internals credited to reduce fast neutron fluence are relied upon for protection against

PTS. The reactor vessels and the reactor vessel internals structures credited to reduce fast

neutron fluence have been included within the scope of license renewal for PTS in accordance

with 10 CFR 54.4(a)(3).

Anticipated Transient Without Scram LRA Section 2.1.1.3.4, "Commission's Regulations for

Anticipated Transients without Scram (10 CFR 50.62)," describes the scoping of systems and

structures relied on in safety analyses or plant evaluations to perform a function that

demonstrates compliance with the ATWS criterion. The LRA stated that the ATWS mitigation

system actuation circuitry (AMSAC) was required to meet the 10 CFR 50.62 requirements. The

AMSAC is described in UFSAR Section 7.7.1.11. The AMSAC and other SSCs relied on in

analyses or plant evaluations to sense, initiate, and perform these required functions have been

included within the scope of license renewal for ATWS in accordance with 10 CFR 54.4(a)(3).

Station Blackout LRA Section 2.1.1.3.5, "Commission's Regulations for Station Blackout

(10 CFR 50.63)," describes the scoping of systems and structures relied on in safety analyses

or plant evaluations to perform a function that demonstrates compliance with the SBO criterion.

The LRA stated that the functions relied upon during the SBO coping phase were described in

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UFSAR Section 8.4. The SSCs relied on in the analyses and plant evaluations for coping with

an SBO event, and the systems containing these components, have been included within the

scope of license renewal in accordance with 10 CFR 54.4(a)(3). In addition the SSCs required

to recover from a SBO event were also included within the scope of license renewal in

accordance with 10 CFR 50.63.

2.1.4.3.2 Staff Evaluation

The staff reviewed the applicant's approach to identifying mechanical systems and structures

relied upon to perform functions meeting the requirements of the fire protection, EQ, PTS,

ATWS, and SBO regulations. As part of this review the staff discussed the methodology with the

applicant, reviewed the documentation developed to support the approach, and evaluated a

sample of the mechanical systems and structures indicated as within the scope of license

renewal under the 10 CFR 54.4(a)(3) criteria.

The applicant's implementing procedures describe the process for indentifying systems and

structures within the scope of license renewal. The procedures state that all mechanical

systems and structures that perform functions addressed in 10 CFR 54.4(a)(3) are to be

included within the scope of license renewal and that the results are to be documented in

scoping results reports.

The results reports reference the information sources used for determining the systems and

structures credited for compliance with the regulated events.

Fire Protection The applicant's scoping results reports indicate that it considered CLB

documents to identify in-scope systems and structures. These documents include the UFSAR,

design criteria and fire protection P&IDs. The staff reviewed the scoping results reports in

conjunction with the LRA and the CLB information to validate the methodology for including the

appropriate SSCs within the scope of license renewal. The staff finds that the scoping results

reports indicated which of the mechanical systems and structures are included within the scope

of license renewal because they perform intended functions meeting 10 CFR 50.48

requirements. The staff concludes that the applicant's scoping methodology was adequate for

including SSCs credited in performing fire protection functions.

Environmental Qualification The applicant had used the EQ master list to identify SSCs meeting

the requirements of 10 CFR 50.49. The EQ master list included system information, component

identification numbers and descriptions. The staff reviewed the LRA, implementing procedures,

scoping results reports, and the EQ master list to verify that the applicant had identified SSCs

within the scope of license renewal. The staff concludes that the applicant's scoping

methodology was adequate for identifying EQ SSCs within the scope of license renewal.

Pressurized Thermal Shock The applicant addressed PTS requirements for these components

in a TLAA report. The staff reviewed the TLAA report and scoping report and determined that

the methodology is appropriate for identifying SSCs with functions credited for complying with

the PTS regulation and within the scope of license renewal. For this requirement the applicant

identified the reactor vessel and certain vessel internal components within the scope of license

renewal.

Anticipated Transient Without Scram The applicant's scoping results report indicated the

mechanical systems were included within the scope of license renewal because they perform

intended functions meeting 10 CFR 50.62 requirements. The applicant determined the intended

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functions based on CLB information and identified most in-scope components as electrical

equipment. For scoping electrical equipment, the applicant's bounding methodology included

within the scope of license renewal all electrical and I&C systems in mechanical systems by

default. The applicant also included mechanical systems with ATWS intended functions based

on CLB information. The staff concludes that this scoping methodology was adequate for

identifying SSCs with functions credited for complying with the ATWS regulation.

Station Blackout The scoping results reports indicate the mechanical systems and structures

credited with performing intended functions to comply with the SBO requirement. During the

scoping process the applicant considered CLB information, including the UFSAR, design criteria,

plant drawings and the SBO analysis report. The applicant included within the scope of license

renewal electrical equipment, mechanical systems, and structures with intended functions

meeting SBO requirements. For scoping electrical equipment, the applicant's bounding

methodology included within the scope of license renewal all electrical and I&C systems by

default. The mechanical systems and structures within the scope of license renewal are those

relied on in the CLB for the SBO coping duration phase and for the SBO recovery phase. The

staff concludes that this scoping methodology was adequate for identifying SSCs with functions

credited for complying with the SBO regulation. The staff review and conclusion of the results of

the implementation of the SBO scoping methodology is contained in Section 2.5.

2.1.4.3.3 Conclusion

The staff concludes that the applicant's methodology for identifying systems and structures

meets the scoping criteria of 10 CFR 54.4(a)(3) and is therefore acceptable. This conclusion is

based on sample reviews, discussions with the applicant, and review of the applicant's scoping

process as discussed above.

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 performing

the scoping of SSCs in accordance with 10 CFR 54.4(a) in the LRA, guidance documents and

scoping and screening reports. The applicant's approach to system and structure scoping

provided in the site guidance and implementing documents was consistent with the

methodology described in Section 2.1 of the LRA. Specifically, the guidance documents

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 included the UFSAR, design criteria,

maintenance rule information, plant drawings, equipment databases 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). If any part of a system or structure met any of the license renewal scoping

criteria, the system or structure was included in the scope of license renewal. The system and

structure scoping results included an overall system/structure description, an evaluation of each

of the 10 CFR 54.4 scoping criteria and the basis for the conclusion reached. The applicant

developed evaluation boundaries to document the system and structure level scoping

determinations and to define the in-scope SSCs to support the subsequent screening and AMR

processes. The boundaries for the in-scope systems and structures were defined and

documented in a manner for each discipline that assured the in-scope SSCs were included in

the screening process.

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Component Level Scopinc After the applicant identified the intended functions of systems or

structures within the scope of license renewal, a review was performed to determine which

components and structures support the system's license renewal intended functions. The

components that support intended functions were considered within the scope of license

renewal and screened to determine if an AMR was required. The applicant considered three

groups of SCs during this stage of the scoping methodology: (1) mechanical, (2) structural, and

(3) electrical.

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 2.1.2.2.3 stated that insulation was included with the mechanical

scoping. Piping insulation in containment penetrations was identified as being required to keep

the local concrete temperatures below 2000F. Also, for certain HVAC systems, thermal

insulation is credited in the calculations that assure that the HVAC systems will perform their

safety-related functions. Insulation was included within the scope of license renewal in

accordance with 10 CFR 54.4(a)(2).

Consumables LRA Section 2.1.2.3, "Screening," discusses consumables. The information in

Table 2.1-3 of the SRP-LR was used to categorize and evaluate consumables. Consumables

were divided into the following four categories for the purpose of license renewal: (a) packing,

gaskets, component seals, and O-rings; (b) structural sealants; (c) oil, grease, and component

filters; and (d) system filters, fire extinguishers, fire hoses, and air packs.

Group (a) Packing, gaskets, component mechanical seals, and O-rings are typically used to

provide a leak proof seal when components are mechanically joined together. These items are

commonly found in components such as valves, pumps, heat exchangers, ventilation units or

ducts, and piping segments. Based on ANSI B31.1 and the ASME B&PV Code Section III, the

subcomponents of these pressure retaining components are not pressure-retaining parts.

Therefore, these subcomponents are not relied on to perform a pressure boundary intended

function and were not subject to an AMR.

Group (b) Elastomers and other materials used as structural sealants are subject to an AMR if

they are not periodically replaced and they perform an intended function, typically supporting a

pressure boundary, flood barrier, or rated fire barrier. Compressible joints and seals, seismic

joint filler, and roof membranes were included in the AMR of bulk commodities. Sealants with a

pressure boundary function were included in the AMR of the containment buildings.

Group (c) Oil, grease, and component filters have been treated as consumables because either

(1) they are periodically replaced or (2) they are monitored and replaced based on condition and

were not subject to an AMR.

Group (d) Components such as system filters, fire hoses, fire extinguishers, self-contained

breathing apparatus (SCBA), and SCBA cylinders are considered consumables and are

routinely tested, inspected, and replaced when necessary. Periodic inspection procedures

specify the replacement criterion of these components that are routinely checked by tests or

inspections. Therefore, while these consumables are in the scope of license renewal, they are

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

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components to ensure it was consistent with 10 CFR 54.4(a). The methodology used to

determine the systems and components within the scope of license renewal was documented in

implementing procedures and scoping results reports for mechanical systems. The scoping

process defined the plant in terms of systems and structures. Specifically, the implementing

procedures identified the systems and structures that are subject to 10 CFR 54.4 review,

described the processes for capturing the results of the review, and were used to determine if

the system or structure performed an intended function consistent with the criteria 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 documented the results of the plant-level scoping process in accordance with the

guidance documents. The results were provided in the systems and structures documents and

reports which 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 the documents and reports and concluded that the applicant's scoping results

contained an appropriate level of detail to document the scoping process.

2.1.4.4.3 Conclusion

Based on its review of the LRA, scoping and screening implementation procedures, and a

sampling of system scoping results during the audit, the staff concludes that the applicant's

methodology identifies SSC types, and commodity groups within the scope of license renewal

and their intended functions in accordance with the requirements of

10 CFR 54.4.

2.1.4.5 Mechanical Component Scoping

2.1.4.5.1 Summary of Technical Information in the Application

In addition to the information previously discussed in Section 2.1.4.4.1, LRA Section 2.1.2

stated that for the mechanical scoping effort, summary-level boundary descriptions were

developed, along with a set of license renewal mechanical boundary drawings. The mechanical

boundary drawings were developed from the VEGP piping and instrumentation diagrams and

show the mechanical components within the scope of license renewal, including those

components that are only within the scope of license renewal in accordance with

10 CFR 54.4(a)(2), using color-coding. End points for the portions within the scope of license

renewal were clearly delineated. Notes were added to the drawings as necessary to clarify the

endpoints when they do not occur at a component or feature already depicted on the drawing.

2.1.4.5.2 Staff Evaluation

The staff evaluated LRA Section 2.1.2 and the guidance in the implementing project documents

and reports to perform the review of mechanical scoping process. The project documents and

reports provided instructions for identifying the evaluation boundaries. Determination of the

mechanical system evaluation boundary required an understanding of system operations in

support of intended functions.

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This process was based on the review of design criteria documents, UFSAR, plant drawings.,

maintenance rule scoping documents, technical specifications and bases,.safety evaluation

reports, .equipment databases., master list of EQ equipment., SBO analysis report, licensing

correspondencp., and vendor documents. The evaluation boundaries for mechanical systems

were documented on license renewal boundary drawings that were created by 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 were established based on

whether a particular function of a component was necessary to support the system functions

that meet the scoping criteria.

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 implementation

procedures and whether the scoping results were consistent with CLB requirements. The staff

concludes that the applicant's proceduralized methodology was consistent with the description

provided in the LRA Section 2.1 and the guidance contained in the SRP-LR, Section 2.1, and

was adequately implemented.

The staff reviewed the applicant's methodology for identifying MSS and ECCS 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 had identified and used pertinent

engineering and licensing information in order to determine the MSS and ECCS 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 MSS and ECCS,

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 had identified and highlighted

system P&IDs to develop the license renewal 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 implementation procedures. Additionally, the staff

verified that the applicant had independently verified the results 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 implementation procedures, the systems sampled, and

discussions with the applicant, the staff concludes that the applicant's methodology for

identifying mechanical systems within the scope of license renewal is in accordance with the

requirements of 10 CFR 54.4.

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2.1.4.6 Structural Scoping

2.1.4.6.1 Technical Information in the Application

In addition to the information previously discussed in Section 2.1.4.4.1, LRA Section 2.1.2

stated that the structural scoping effort, summary-level boundary descriptions were developed.

Generally, the VEGP scoping process used a "spaces" approach in establishing the evaluation

boundaries. With few exceptions, the scoping for a building or structure was the entire building.

Individual license renewal drawings were not created for structures and were not necessary

since the spaces approach was being used. A single boundary drawing based on the site plot

plan drawing was created, however. This license renewal structural boundary drawing showed

the in scope structures using color-coding, and displays the spatial relationship of the plant

structures to one another.

2.1.4.6.2 Staff Evaluation

The staff reviewed the applicant's approach for identifying structures relied upon to perform the

functions described in 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 within the scope of

license renewal.

The applicant had identified and developed a list of plant structures and the structures intended

functions through a review of design criteria documents, UFSAR, plant drawings, maintenance

rule scoping documents, technical specifications and bases, safety evaluation reports,

equipment databases, licensing correspondence, and vendor documents. Each structure was

evaluated against the criteria of 10 CFR 54.4 (a)(1), (a)(2) and (a)(3).

The staff reviewed selected portions of the UFSAR, maintenance rule documents, design

criteria, and structural drawings, implementing procedures and selected AMR reports to verify

the adequacy of the methodology. In addition, staff reviewed the scoping results, including

information contained in the source documentation, for the NSCW cooling tower building to

verify that application of the methodology would provide the results as documented in the LRA.

The staff reviewed the applicant's methodology for identifying structures 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 had identified and used pertinent engineering and licensing information in order to

determine the NSCW tower structure and components required to be within the scope of license

renewal. As part of the review process, the staff evaluated the intended functions identified for

the NSCW tower and components, the basis for inclusion of the intended function, and the

process used to identify each of the component types. Additionally, the staff verified that the

applicant had independently verified the results in accordance with the governing procedures.

2.1.4.6.3 Conclusion

Based on the staffs review of information in the LRA, scoping implementation 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 is in

accordance with the requirements of 10 CFR 54.4.

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2.1.4.7 Electrical Component Scoping

2.1.4.7.1 Technical Information in the Application

LRA Section 2.1.2, states that for the electrical scoping effort, boundary drawings were not

needed since the screening was performed using a "Plant-Wide Spaces Approach." LRA

Section 2.5.1, "Plant-Wide Electrical," states that plant-wide electrical was the designation used

by VEGP in the LRA for the sole purpose of grouping electrical components into one system

grouping for scoping, screening, and an AMR. Identification of in-scope electrical and I&C

components was performed on a generic component type basis. The electrical and I&C

component types associated with the in-scope electrical and I&C systems and in-scope

mechanical systems and civil structures, were also identified generically.

2.1.4.7.2 Staff Evaluation

The staff evaluated LRA Sections 2.1.2 and 2.5.1 and the applicants implementing procedures

and AMR reports that governed the electrical scoping methodology. The applicant had 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. During the

scoping process, the applicant used the design criteria documents, UFSAR., plant drawings,

maintenance rule scoping documents, technical specifications and bases, safety evaluation

reports,.equipment databases., master list of EQ equipment, SBO analysis report, licensing

correspondence., and vendor documents.

All electrical and I&C components contained in plant systems and electrical systems contained

in mechanical or structural systems were included within the scope of license renewal. The

applicant reviewed fuse-holders using the plant fuse documentation and drawings and did not

identify any fuse holders to be included within the scope of license renewal. The applicant

reviewed the application of tie-wraps to determine if credit had been taken in the CLB for tiewrap use or if nonsafety-related tie-wraps could affect a safety-related function, but did not

identify any tie-wraps to be included within the scope of license renewal. The staff reviewed

selected portions of the data sources and selected several examples of components for which

the applicant demonstrated the process used to determine electrical components were within

the scope of license renewal. The results of the staff's review of the implementation of the SBO

scoping methodology is discussed in Section 2.5.

2.1.4.7.3 Conclusion

On the basis of the review of information contained in the LRA, scoping implementation

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 is in accordance with the requirements of 10 CFR 54.4.

2.1.4.8 Scoping Methodology Conclusion

On the basis of a review of the LRA and the scoping implementation procedures, the staff

concludes that the applicant's scoping methodology is consistent with the guidance contained in

the SRP-LR and identifies those SSCs (1) that are safety-related, (2) whose failure could affect

safety-related functions, and (3) that are necessary to demonstrate compliance with the NRC's

regulations for Fire Protection, Environmental Qualification, Pressurized Thermal Shock,

Anticipated Transient Without Scram and Station Blackout. The staff concludes that the

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applicant's methodology is consistent with the requirements of 10 CFR 54.4(a), and is therefore,

acceptable.

2.1.5 Screening Methodology

2.1.5.1 General Screening Methodology

2.1.5.1.1 Technical Information in the Application

In LRA Section 2.1.3, "Screening Methodology," the applicant discussed the process for

determining which components and structural elements require an AMR. Screening identifies

SCs within the scope of license renewal that perform an intended function as described in

10 CFR 54.4, without moving parts or without a change in configuration or properties and that

are not subject to replacement based on a qualified life or specified time period. The screening

process determines the SCs subject to an AMR by:

* Listing the in-scope SCs by component type using the scoping results for a particular

system or structure;

" "Screening" the component types for the passive and long-lived criteria; and

* Identifying the intended function(s) performed by the passive and long-lived SCs by

component type for the in-scope system or structure.

The result was a tabulation of the in-scope passive long-lived SCs that perform intended

functions and therefore require an AMR. The screening process grouped SCs into component

groups (component types) based on similarity of design and purpose. Use of component groups

enables evaluation of entire groups of SCs in a single screening evaluation. The screening

process followed the recommendations of NEI 95-10. "Active" and "short-lived" determinations

were made consistent with NEI 95-10. Components or structural elements that were either

active or subject to replacement based on a qualified life were "screened out" as not subject to

an AMR.

2.1.5.1.2 Staff Evaluation

Pursuant to 10 CFR 54.21, each LRA must contain an Integrated Plant Assessment (IPA) that

identifies SCs within the scope of license renewal that are 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 SCs 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 if mechanical and

structural components 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).

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In LRA Section 2.1.3, the applicant discussed these screening activities as they related to the

component types and commodity groups within the scope of license renewal.

The screening process evaluated the component types and commodity groups, included within

the scope of license renewal, to determine which ones were long-lived and passive and

therefore subject to an AMR. The staff reviewed Section 2.3, Section 2.4, and Section 2.5 of the

LRA that provided the results of the process used to identify component types and commodity

groups subject to an AMR. The staff also reviewed the screening results reports for the MSS

and ECCS and the NSCW tower.

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 a review of the LRA, the screening implementation procedures and a sampling

of screening results, the staff concludes that the applicant's screening methodology was

consistent with the guidance contained in the SRP-LR and was capable of identifying passive,

long-lived components in-scope of license renewal that are subject to an AMR. The staff

concludes that the applicant's process for determining which component types and commodity

groups subject to an AMR is consistent with the requirements of 10 CFR 54.21.

2.1.5.2 Mechanical Component Screening

2.1.5.2.1 Summary of Technical Information in the Application

LRA Section 2.1.3.1, "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. For mechanical

systems, a systematic process was used to identify the components that require an AMR. The

mechanical component screening included the following steps: (1) identifying the in-scope SCs

and associated component types using the license renewal mechanical boundary information

and drawings created during the scoping process; (2) evaluating the component types against

the active/passive and long-lived/short-lived criteria of 10 CFR 54.21(a)(1)(i) and (ii); and (3)

identifying the component intended functions for the passive and long-lived component types.

For each system, the applicable component types for the components and component groups

were identified and listed. The criteria of 10 CFR 54.21 (a)(1)(i) and (ii) were applied to identify

the passive long-lived component types. Component intended functions were also identified.

The components that contribute to the performance of a system intended function, and perform

their function without moving parts and without a change in configuration or properties, and are

not subject to replacement based on a qualified life or specified time period were subject to an

AMR.

2.1.5.2.2 Staff Evaluation

The staff evaluated the mechanical screening methodology discussed and documented in LRA

Section 2.1.3.1, the implementing guidance documents, the AMR reports, and the license

renewal drawings. The mechanical system screening process began with the results from the

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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 were subject to

an AMR. The results of the review are documented in the AMR reports. The AMR reports

contain information such as-the information sources reviewed and the system intended

functions.

The staff reviewed the results of the boundary evaluations and discussed the process with the

applicant. The staff verified that mechanical system evaluation boundaries were established for

each system within the scope of license renewal and that the boundaries were determined by

mapping the system intended function boundary onto P&IDs. The applicant reviewed the

components within the system intended function boundary to determine if the component

supported the system intended function. Those components that supported the system intended

function were reviewed to determine if the component was passive and long lived and therefore

subject an AMR.

The staff reviewed selected portions of design criteria documents, UFSAR,.plant drawings,

maintenance rule scoping documents, and selected AMR reports. The staff conducted detailed

discussions with the applicant's license renewal team and reviewed documentation pertinent to

the screening process. The staff assessed if the mechanical screening methodology outlined in

the LRA and procedures was appropriately implemented and if the scoping results were

consistent with CLB requirements. The staff also reviewed the mechanical screening results for

the MSS and ECCS 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.

2.1.5.2.3 Conclusion

Based on its review of the LRA, the screening implementation procedures, and a sample of the

MSS and ECCS screening results, the staff concludes that the applicant's mechanical

component screening methodology is consistent with SRP-LR guidance. The staff concludes

that the applicant's methodology for identification of passive, long lived mechanical components

within the scope of license renewal and subject to an AMR is in accordance with the

requirements of 10 CFR 54.21 (a)(1).

2.1.5.3 Structural Component Screening

2.1.5.3.1 Technical Information in the Application

LRA Section 2.1.3.2, "Screening of Structures," states that the screening process was applied

to in-scope buildings and civil structures to identify the structural elements to be evaluated in the

AMRs.. Screening evaluation boundaries were established based on the scoping boundary

results. A "Component Supports and Bulk Commodities" screening evaluation boundary was

also established to address common components within the in-scope structures. The scoping

and screening process used a "spaces" approach in establishing the evaluation boundaries and

with few exceptions, the scoping and screening boundary for a building or structure was the

entire building. The listing of structural elements was facilitated by grouping components into

component groups since structural components and commodities often do not have unique

identifiers such as those given to mechanical components. Structural components and

commodities were identified based on materials of construction and functional applications to

categorize them for AMRs. A list of structural components and component groups was

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developed for each structural evaluation boundary. Since structures are inherently passive, and

with few exceptions long-lived, the screening of structural components and commodities was

based primarily on whether or not they perform an intended function.

Structural components that perform an intended function without moving parts and without a

change in configuration or properties, and that are not subject to replacement based on a

qualified life or specified time period were 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 within the

scope of license renewal.

The staff reviewed the applicant's methodology used for structural screening described in LRA

Section 2.1.3.2 and in the applicant's implementing guidance and AMR reports. The applicant

had performed the screening review in accordance with the implementation guidance and

captured pertinent structure design information, component, materials, environments, and aging

effects. The staff verified that the applicant had determined that structures are inherently

passive and long-lived, such that the screening of structural components and commodities was

based primarily on whether they perform an intended function. Structural components were

grouped as commodities based on materials of construction. The primary task performed by the

applicant during the screening process was to evaluate structural components to identify

intended functions as they relate to license renewal. 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 reviewed selected portions of the design criteria documents, UFSAR, .plant drawings,

maintenance rule scoping documents, structural drawings, implementing procedures and

selected AMR reports. The staff conducted detailed discussions with the applicant's LR team

and reviewed documentation pertinent to the screening process. The staff assessed if the

screening methodology outlined in the LRA and procedures was appropriately implemented and

if the scoping results were consistent with CLB requirements. The staff also reviewed structural

screening results for the NSCW tower 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 the staff's review of information contained in the LRA, the applicant's detailed

screening implementation procedures, and a sampling review of structural screening results, the

staff concludes that the applicant's methodology for identification of structural components

within the scope of license renewal and subject to an AMR is in accordance with the

requirements of 10 CFR 54.21(a)(1).

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2.1.5.4 Electrical Component Screening

2.1.5.4.1 Technical Information in the Application

LRA Section 2.1.3.3 stated that VEGP used a "plant-wide spaces" approach for electrical and

I&C screening. Electrical component types were screened on a plant-wide basis without regard

to plant system. The spaces approach used was consistent with the approach described in NEI

95-10, Revision 6. A screening evaluation boundary was created which included all of the inscope electrical and I&C systems, and the electrical

and I&C portions of the in-scope mechanical systems. This plant-wide electrical boundary

permitted the screening evaluation to be consolidated under one system boundary.

The electrical and I&C component types in use at VEGP were identified and listed. The listing

provided by NEI 95-10 Appendix B, as well as plant-specific document reviews were the basis

for this list. Electrical component types were organized into component groups. The electrical

and I&C component groups were identified from a review of plant documents, drawings,

equipment databases, and interface with the parallel mechanical and civil/structural screening

efforts. Following the identification of the electrical and I&C component commodity groups, the

"passive" screening criterion of 10 CFR 54.21 (a)(1 )(i) was applied to identify component groups

that perform their intended function(s) without moving parts or without a change in configuration

or properties. These passive components were identified utilizing the guidance of NEI 95-10

and the Electric Power Research Institute (EPRI) License Renewal Electrical Handbook.

The "short-lived" screening criterion of 10 CFR 54.21 (a)(1)(ii) was then applied to those specific

component groups that were not previously eliminated. The "short-lived" screening criterion

found in 10 CFR 54.21 (a)(1 )(ii) excludes those components or commodity groups that are

subject to replacement based on a qualified life or specific time period fRom the requirements of

an AMR. Electrical components included in the plant EQ program are replaced on a specified

interval based on a qualified life. Therefore, components in the EQ program do not meet the

"long-lived" criteria of 10 CFR 54.21(a)(1)(ii) and are "short-lived" per the regulatory definition.

The passive component types that are not subject to replacement based on a qualified life or

specified time period and were subject to an AMR were determined to include cables,

connectors, fuse holders, and various switchyard components.

2.1.5.4.2 Staff Evaluation

The staff reviewed the applicant's methodology used for electrical screening in LRA Sections

2.1.3.3 of the LRA and the applicant's implementation procedures and AMR reports. The

applicant used the screening process described in these documents to identify the electrical

commodity groups subject to an AMR. The applicant used the information contained in NEI 95-

10, plant documents and drawings, the EQ master list, and the EPRI License Renewal Electrical

Handbook as data sources to identify the electrical and I&C components.

The applicant identified two commodity groups which were determined to meet the passive

criteria in accordance with NEI 95-10. The applicant evaluated the identified, passive

commodities to identify 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 screening of selected components

to verify the correct implementation of the methodology.

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2.1.5.4.3 Conclusion

The staff reviewed the LRA, procedures, electrical drawings, and a sample of the results of the

screening methodology. The staff concludes that the applicant's methodology was consistent

with the description provided in LRA and the applicant's implementing procedures. On the basis

of a review of information contained in the LRA, the applicant's screening implementation

procedures, and a sampling review of electrical screening results, the staff concludes that the

applicant's methodology for identification of electrical commodity groups within the scope of

license renewal and subject to an AMR is in accordance with the requirements of

10 CFR 54.21(a)(1).

2.1.5.5 Screening Methodology Conclusion

On the basis of a review of the LRA, the screening implementation procedures, discussions with

the applicant's staff, and a sample review of screening results, the staff concludes that the

applicant's screening methodology was consistent with the guidance contained the SRP-LR and

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 is therefore 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 implementation procedures and reports, the information presented

during the scoping and screening methodology audit, and the applicant's responses to the

staff's RAIs dated February 27, 2008, formed the basis of the staff's determination. The staff

verified that the applicant's scoping and screening methodology was 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 is therefore acceptable.

2.1.7 References

1. LRA, Vogtle Electric Generating Plant, Units 1 and 2, dated June 29, 2007.

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

Nuclear Power Plants," Revision 1, dated September 2005.

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

License Renewal Rule," Revision 6, dated September 2005.

4. Scoping and Screening Methodology audit Trip Report Regarding the Southern Nuclear

Operating Company, Inc., License Renewal Application for the Vogtle Electric Generating

Plant, Units 1 and 2, dated June 29, 2007.

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2.2 Plant-Level Scoping Results

2.2.1. Technical Information in the Application

In LRA Table 2.2-1 the applicant listed plant mechanical systems, structural systems, and

electrical and instrumentation and controls systems within the scope of license renewal. Based

on the DBEs considered in the plant's CLB, other CLB information relating to nonsafety-related

systems and structures, and certain regulated events, the applicant identified plant-level

systems and structures within the scope of license renewal as defined by 10 CFR 54.

2.2.2 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 reviewed the

scoping and screening methodology and provides its evaluation in SER Section 2.1. To verify

that the applicant properly implemented its methodology, the staff's review focused on the

implementation results shown in LRA Tables 2.2-1, and 2.2-2 to confirm that there were no

omissions of plant-level systems and structures within the scope of license renewal.

The staff concludes whether the applicant properly identified the systems and structures within

the scope of license renewal in accordance with Title 10 of the Code of Federal Regulations

(10 CFR) Part 54.4. The staff reviewed selected systems and structures that the applicant

identified as not 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, "Plant-Level Scoping Results."

The staff's review of LRA Section 2.2 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results.

The applicant responded to the staff's RAIs as discussed below.

In RAI 2.2-1, dated January 28, 2008, the staff noted that the LRA Table 2.2-2 defines the

circulating water (CW) system, System No. 1401, as not within the scope of license renewal.

Similar plant designs have identified their CW systems as being within scope based on

10 CFR 54.4(a)(2). The applicant was asked to provide additional information to justify exclusion

of the CW system with respect to the applicable requirements of 10 CFR 54.4(a).

In its response, dated February 27, 2008, the applicant stated:

The CW system components are located entirely within the Turbine Building,

or in outside areas remote from any safety related systems, structures, or

components (SCs). The CW system is not attached to any safety related

SCs. Refer to the answer to RAI 2.1-2 for discussion regarding non-safety

related components in the Turbine Building. The Circulating Water System

components in the outside areas are physically located such that there is no

potential for interaction with a safety related

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SC. Therefore, the CW system is not in scope for the 10 CFR 54.4(a)(2)

scoping criteria.

Based on its review, the staff finds the applicant's response to RAI 2.2-1 acceptable, because

the applicant provided clarification as to why the CW system is not in scope with respect to the

applicable requirement of 10 CFR 54.4(a); therefore, the staffs concern described in RAI 2.2-1

is resolved.

In RAI 2.2-2, dated January 28, 2008, the staff noted that LRA Table 2.2-2 defines the turbine

plant closed cooling water system, System No. 1404, as not within the scope of license renewal.

However, the turbine plant cooling water system (System No. 1405), LRA section 2.3.3.7, is

identified as being within the scope of license renewal based on 10 CFR 54.4(a)(2). It appears

these two systems are very similar. The applicant was asked to provide additional information to

justify exclusion of the turbine plant closed cooling water system with respect to the applicable

requirements of 10 CFR 54.4(a).

In its response, dated February 27, 2008, the applicant stated:

The Turbine Plant Cooling Water System, System No. 1405, is in scope

based on 10 CFR 54.4(a)(2) because it supplies cooling water to the CVCS

Chiller, the Steam Generator Blowdown Trim Heat Exchangers, and

corrosion product monitors which are located in the Auxiliary Building. With

certain exceptions based on location, those portions of the Turbine Plant

Cooling Water System which are located in the Auxiliary Building are in scope

for potential spatial interaction ... the Turbine Plant Cooling Water System

components which are locatedin Room 124, the CVCS Chiller Pumps Room,

are not in scope.. .There are no safety related components in Room 124,

therefore, there is no potential for spatial interaction, so the components

located in this room are not within the scope of license renewal for

10 CFR 54.4(a)(2).

The Turbine Plant Closed Cooling Water System, System No. 1404, is not in

scope based on 10 CFR 54.4(a)(2) because its components are located

entirely within the Turbine Building. Refer to the answer to RAI 2.1-2 for

discussion regarding non-safety related components in the Turbine Building.

Based on its review, the staff finds the applicant's response to RAI 2.2-2 acceptable, because

the applicant provided clarification as to why the Turbine Plant Closed Cooling Water System is

not in scope with respect to the applicable requirement of 10 CFR 54.4(a). Therefore, the staffs

concern described in RAI 2.2-2 is resolved.

2.2.3 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. The staff finds no such omissions. On the basis of its review, the staff

concludes the applicant has adequately identified, in accordance with 10 CFR 54.4, the systems

and structures within the scope of license renewal.

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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, reactor vessel internals, and reactor coolant system

* engineered safety features

* auxiliary systems

* steam and power conversion systems

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 staffs review focused on the

implementation results. This focus allowed the staff to confirm that there were no omissions of

mechanical system components that meet the scoping criteria and are subject to an AMR.

The staff's evaluation of the information in the LRA was the same for all mechanical systems.

The objective was to determine whether the applicant has identified, in accordance with

10 CFR 54.4, components and supporting structures for mechanical 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 are 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 mechanical

system to determine whether the applicant has omitted from the scope of license renewal

components with intended functions delineated under 10 CFR 54.4(a). The staff also reviewed

the licensing basis documents to determine whether the LRA specified all intended functions

delineated under 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 delineated under 10 CFR 54.4(a), the staff sought to

determine whether (1) the functions are performed with moving parts or a change in

configuration or properties or (2) 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 are 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.

Two-Tier Scoping Review Process for Balance of Plant (BOP) Branch Systems

There are 98 mechanical systems identified as within scope in the LRA, of which 51 systems

are BOP systems. These 51 systems include most of the auxiliary systems and all the steam

and power conversion systems. The staff performed a two-tier scoping review for the BOP

systems.

A Tier 1 review is a less detailed review where the staff reviews the LRA and UFSAR to

.determine if the applicant failed to identify any component type that is typically found within the

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scope of license renewal. During this review the staff evaluated the system's function(s)

described in the LRA and UFSAR to verify the applicant has not omitted from the scope of

license renewal any component types with the intended functions delineated under 10 CFR

54.4(a).

A Tier 2 review is a detailed review of the LRA, UFSAR, and license renewal boundary drawings

to determine if the applicant failed to identify any components within the scope of license

renewal and any components subject to an AMR. During this review the staff evaluated the

system's function(s) described in the LRA and UFSAR to verify the applicant did not omit from

the scope of license renewal any components with intended functions delineated under

10 CFR 54.4(a). The staff then reviews those components that the applicant has identified as

within the scope of license renewal to verify that the applicant has not omitted any passive,

long-lived components subject to an AMR in accordance with 10 CFR 54.21.

In determining the level of review (i.e., Tier 1 vs. Tier 2), the staff reviewed the LRA and the

UFSAR description for each BOP system, focusing on the system's intended function(s). Tier 2

reviews were performed on systems that have:

" safety significance or risk significance

o high safety significant systems

o common cause failure of redundant trains

" operating experience indicating likely passive failure

• previous LRA experience

Examples of safety important or risk significant systems are the diesel generator (DG) and

support systems and the emergency service water (ESW) system. An example of a system

whose failure could result in common cause failure of redundant trains is a drain system

providing flooding protection. Examples of systems with operating experience indicating likely

passive failures include the main steam system (MSS), feedwater system, and service water

system. Examples of systems with identified omissions in previous LRA reviews include spent

fuel cooling system and makeup water sources to safety systems.

2.3.1 Reactor Vessel, Reactor Vessel Internals, and Reactor Coolant System

LRA Section 2.3.1 identifies the reactor vessel, reactor vessel internals, and reactor coolant

system (RCS) SCs subject to an AMR for license renewal. The applicant described the

supporting SOs of the reactor vessel, internals, and RCS in the following LRA sections:

2.3.1.1 Reactor vessel

2.3.1.2 Reactor vessel internals

2.3.1.3 RCS and connected lines

2.3.1.4 Pressurizer

2.3.1.5 Steam generators

The reactor vessel, reactor vessel internals, and RCS contain safety-related components relied

upon to remain functional during and following DBEs. The failure of nonsafety-related SCs in the

RCS potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the RCS performs functions that support fire protection, PTS, SBO, and EQ.

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2.3.1.1 Reactor Vessel

2.3.1.1.1 Summary of Technical Information in the Application

LRA Section 2.3.1.1 describes the reactor vessel:

The reactor vessel system boundary includes the reactor vessel and system

portions, including the control rod drive mechanism pressure boundary

components and pressure boundary components for both incore flux and core

cooling monitoring instrumentation, effectively constituting a part of the reactor

coolant pressure boundary. The cylindrical reactor vessel has a welded

hemispherical bottom head and a hemispherical upper closure head and

contains the core, core supporting structures, control rods, and other core parts

addressed in the next section. The upper closure head has penetrations for

control rod drive mechanisms (CRDMs), thermocouples, reactor vessel level

instrumentation system instruments, and a head vent. The vessel shell has inlet

and outlet nozzles in a horizontal plane just below the reactor vessel flange but

above the top of the core. The bottom head has penetrations for connection and

entry of nuclear incore instrumentation. Conduits extend from the nuclear incore

instrumentation penetrations down through the concrete shield area and up to a

thimble seal table. The conduits and seal table mechanical seals provide the

pressure barrier between the reactor coolant and the containment atmosphere.

LRA Table 2.3.1.1 identifies reactor vessel component types within the scope of license renewal

and subject to an AMR. The intended functions of the reactor vessel component types within the

scope of license renewal include:

" pressure-retaining boundary

* structural/functional support for safety-related/nonsafety-related components

with maintenance of physical integrity and flow path considerations

2.3.1.1.2 Staff Evaluation

The staff reviewed LRA Section 2.3.1.1 and UFSAR Sections 5.3, 7.7.2.7, and 7.7.2.8 using the

evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3,

"Scoping and Screening Results: Mechanical Systems."

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 delineated under 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- 2.3.1-1 dated January 28, 2008, the staff requested the applicant to verify that the "holddown spring", listed in LRA Table 2.3.1.2 is the same spring described in UFSAR 3.9.5.1.2,

Upper Core Support Assembly, which restrains axial movements of the upper and lower core

support assemblies. In its response dated February 27, 2008, the applicant verified the spring

was the same. The staff finds this response acceptable because the components are included

in-scope for license renewal.

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2.3.1.1.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

applicant failed to identify any SCs within the scope of license renewal. The staff finds no such

omissions. In addition, the staffs 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 reactor vessel 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).

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 reactor vessel internals consisting of the lower core support,

the upper core support, and the incore instrumentation support structures and including the fuel

and control rod drive assemblies. The reactor vessel internals support the core, maintain fuel

alignment, limit fuel assembly movement, maintain alignment between fuel assemblies and

CRDMs, direct coolant flow past the fuel elements and to the pressure vessel ý head, provide

gamma and neutron shielding and provide guides for the incore instrumentation.

The lower core support structure consists of the core barrel, the core baffle, the

lower core plate and support columns, the neutron shield pads, and the core

support, which is welded to the core barrel. The lower core support structure is

supported at its upper flange from a ledge in the reactor vessel and restrained at

its lower end by a radial support system attached to the vessel wall. The upper

core support structure consists of the upper support, the upper core plate, the

support columns, and the guide tube assemblies. The incore instrumentation

support structures consist of an upper system to convey and support

thermocouples penetrating the vessel through the head and a lower system to

convey and support flux thimble tubes penetrating the vessel through the bottom.

LRA Table 2.3.1.2 identifies reactor vessel internals component types within the scope of

license renewal and subject to an AMR. The intended functions of the reactor vessel internals

component types within the scope of license renewal include:

* reactor core support and orientation

" control rod assembly support, orientation, guidance, and protection

" passageway for the distribution of reactor coolant to the reactor core

* passageway for incore instrumentation support, guidance, and protection

* secondary core support to limit core support structure downward displacement

" reactor vessel gamma and neutron shielding

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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.

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 delineated under 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).

2.3.1.2.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 reactor vessel internals 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).

2.3.1.3 Reactor Coolant System and Connected Lines

2.3.1.3.1 Summary of Technical Information in the Application

LRA Section 2.3.1.3 describes the RCS and connected lines:

The RCS consists of four similar heat transfer loops connected in parallel to the

reactor pressure vessel. Each loop has a reactor coolant pump (RCP), steam

generator, piping, and valves. In addition, the system includes a pressurizer,

pressurizer relief and safety valves, the reactor vessel head vent system,

interconnecting piping, reactor vessel level instrumentation system instruments,

and instrumentation for operational control. The pressurizer and steam

generators are addressed separately in following sections. All these components

are located in the containment building. During operation, the RCS transfers the

heat generated in the core to the steam generators that drive the turbinegenerator. Borated demineralized water circulating in the RCS at a flow rate and

temperature for reactor core thermal-hydraulic performance acts as a neutron

moderator and reflector and as a solvent for the neutron absorber for chemical

shim control. The design of the RCS pressure boundary-that provides a barrier

against the release of radioactivity generated within the reactor is for high

integrity throughout the life of the plant.

The pressurizer controls RCS pressure by electrical heaters and water sprays that maintain

water and steam at saturation conditions. Steam can be formed (by the heaters) or condensed

(by the pressurizer spray) to minimize pressure variations due to contraction and expansion of

the reactor coolant. Spring-loaded safety and power-operated relief valves of the pressurizer

discharge from the RCS steam then piped to the pressurizer relief tank (pressurizer relief

discharge system), mixed with quench water, condensed, and cooled.

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LRA Table 2.3.1.3 identifies RCS and connected lines component types within the scope of

license renewal and subject to an AMR. The intended functions of the reactor coolant system

and connected lines component types within the scope of license renewal include:

" prevention of flame propagation from ignition of vent pipe vapors back to the

source

" restriction of process flow

" pressure-retaining boundary

2.3.1.3.2 Staff Evaluation

The staff reviewed LRA Section 2.3.1.3 and UFSAR Section 7.7.2.8 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 delineated under 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).

2.3.1.3.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs within the scope of license renewal. The staff finds no such omissions. In

addition, the staffs 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 reactor coolant system and

connected lines 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).

2.3.1.4 Pressurizer

2.3.1.4.1 Summary of Technical Information in the Application

LRA Section 2.3.1.4 describes the pressurizer, which controls RCS pressure by maintaining

water and steam in equilibrium by electrical heaters and coolant sprays. Steam can be formed

or condensed to minimize pressure variations caused by contraction or expansion of the reactor

coolant. The pressurizer upper head has spring-loaded safety and power-operated relief valves.

The pressurizer is a vertical, cylindrical vessel with hemispherical top and bottom heads. Spray

line nozzles and relief and safety valve connections are located in the top head. The pressurizer

surge line connects the pressurizer bottom nozzle to a reactor coolant hot leg.

Removable electric heaters are installed in the bottom head.

LRA Table 2.3.1.4 identifies pressurizer component types within the scope of license renewal

and subject to an AMR. The intended functions of the pressurizer component types within the

scope of license renewal include:

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pressure-retaining boundary

structural/functional support for safety-related/nonsafety-related components with

maintenance of physical integrity and flow path considerations

2.3.1.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.1.4 and UFSAR Section 5.4.10 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 delineated under 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).

2.3.1.4.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs within the scope of license renewal. The staff finds no such omissions. In

addition, the staffs 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 pressurizer 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).

2.3.1.5 Steam Generators

2.3.1.5.1 Summary of Technical Information in the Application

LRA Section 2.3.1.5 describes the steam generators, four installed in each unit, one in each

reactor coolant loop. All steam generators are Westinghouse Model F, vertical U-tube steam

generators with moisture-separating equipment. On the primary side, reactor coolant flows

through the inverted U-tubes, entering and exiting through the nozzles in the hemispherical

steam generator bottom head divided into inlet and outlet chambers by a vertical partition plate

extending from the head to the tube sheet.

On the secondary side, feedwater flows directly into the annulus formed by the outer shell and

tube bundle wrapper before entering the boiler section of the steam generator. The water and

steam mixture then flows upward through the tube bundle and into the steam drum section.

Centrifugal moisture separators, located above the tube bundle, remove most of the moisture

entrained in the steam. Steam dryers further improve the steam quality.

LRA Table 2.3.1.5 identifies steam generators component types within the scope of license

renewal and subject to an AMR. The intended functions of the steam generators component

types within the scope of license renewal include:

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heat exchange between fluid media

spray shield or curbs for flow direction

Flow pattern or distribution provision

restriction of process flow

physical integrity maintenance to prevent generation of debris or loose parts

which could interfere with a safety-related function

pressure-retaining boundary

structural/functional support for safety-related/nonsafety-related components with

maintenance of physical integrity and flow path considerations"

2.3.1.5.2 Staff Evaluation

The staff reviewed LRA Section 2.3.1.5 and UFSAR Section 5.4.2 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 delineated under 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).

2.3.1.5.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 steam generators 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).

2.3.2 Engineered Safety Features

LRA Section 2.3.2 identifies the engineered safety features SCs subject to an AMR for license

renewal.

The applicant described the supporting SCs of the engineered safety features in the following

LRA sections:

* Containment Spray System

" Emergency Core Cooling Systems

" Containment Isolation Systems

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2.3.2.1 Containment Spray System

2.3.2.1.1 Summary of Technical Information in the Application

LRA Section 2.3.2.1 describes the containment spray system, which provides borated water for

removing decay heat and iodine from the containment atmosphere in post-accident conditions.

The system consists of two trains, each with a pump, spray ring header and spray nozzles,

valves, and connecting piping. Baskets with trisodium phosphate located on the containment

floor control post-accident sump pH by mixing with the recirculating borated water. Containment

emergency sumps located in containment collect borated water to provide suction to the

containment spray pumps for recirculation after initial injection.

Water from the refueling water storage tank (RWST) provides suction to the containment spray

pumps for initial injection. At the latter stages of the injection phase, operators initiate a manual

switch-over to recirculation in which the containment spray pumps take suction from the

containment emergency sumps. Each sump has a suction strainer to prevent debris from

entering the containment spray system, which is designed to operate over an extended period

of time in environmental conditions following a reactor coolant system failure.

The containment spray system contains safety-related components relied upon to remain

functional during and following DBEs. The failure of nonsafety-related SCs in the containment

spray system potentially could prevent the satisfactory accomplishment of a safety-related

function. In addition, the containment spray system performs functions that support EQ.

LRA Table 2.3.2.1 identifies containment spray system component types within the scope of

license renewal and subject to an AMR:

* capillary tubing (sealed) for Containment (CTMT) pressure sensors

* closure bolting

* eductors - CTMT spray

* encapsulation vessels

* flow orifice/elements

* motor coolers - CTMT spray pumps (channel heads)

* motor coolers - CTMT spray pumps (shells)

* motor coolers - CTMT spray pumps (tubes)

* motor coolers - CTMT spray pumps (tubesheets)

* piping components

* piping components - pipe spools for startup strainers

* pump casings - CTMT spray pumps

* spray nozzles

* tank - spray additive tank (Unit 2 only)

* valve bodies

The intended functions of the containment spray system component types within the scope of

license renewal include:

heat exchange between fluid media

flow pattern or distribution provision

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pressure-retaining boundary

structural/functional support for safety-related/nonsafety-related components with

maintenance of physical integrity and flow path considerations,

2.3.2.1.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.1 and UFSAR Section 6.2.2.2 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 delineated under 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).

2.3.2.1.3 Conclusion

The staff reviewed the LRA, UFSAR and drawings to determine whether the applicant failed to

identify any SCs 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 containment spray system

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).

2.3.2.2 Emergency Core Cooling Systems

2.3.2.2.1 Summary of Technical Information in the Application

LRA Section 2.3.2.2 describes the ECCS, which include the safety injection system, safety

injection portion of the chemical volume and control system (CVCS), and residual heat removal

(RHR) system. The primary ECCS function following an accident is removal of the stored and

fission product decay heat from the reactor core. The ECCS consists of passive injection by the

safety injection accumulators, high-head active injection by the centrifugal charging and safety

injection pumps, and low-head active injection by the RHR pumps. Long-term recirculation and

cooling of ECCS is by RHR pumps and heat exchangers.

The RWST supplies emergency borated cooling water to the high-head safety injection, lowhead safety injection, and containment spray during the injection mode. The RWST is designed

to hold enough dilute boric acid solution to fill the refueling canal prior to refueling operations

and to provide injection water to support the safety injection system. The RWST also can fill the

refueling cavity via the refueling water purification pump.

The safety-injection system consists of two safety-injection pumps, four accumulators, piping,

and valves. The system provides post-accident, high-head and portions of low-head safety

injection for emergency core cooling to limit core damage and fission product release for

adequate shutdown margin and includes passive injection of coolant via the safety injection

accumulators.

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The RHR system consists of two trains of one pump, one heat exchanger, piping, and valves.

The system transfers heat from the RCS to the NSCW via the component cooling water system

to reduce reactor coolant temperature to the cold shutdown level at a controlled rate during the

second part of normal plant cooldown and maintains this temperature until the plant starts up

again. During RCS low-temperature operation, RHR system relief valves in the RHR pump

suction lines mitigate RCS overpressure transients. RHR system portions also serve as ECCS

parts for accident mitigation. Following a loss-of-coolant accident (LOCA) the RHR system is

aligned initially to take suction from the RWST and inject into the RCS if RCS pressure is low

enough for low-head safety injection. When the ECCS switches from the injection to the

recirculation phase, the RHR pumps take suction from the containment emergency sumps and

recirculate sump borated water to the RCS at low pressure or provide suction to the safetyinjection and charging pumps for high-head recirculation. Each containment emergency sump

has a strainer to prevent debris from entering the ECCS.

The ECCS contains safety-related components relied upon to remain functional during and

following DBEs. The failure of nonsafety-related SCs in the ECCS potentially could prevent the

satisfactory accomplishment of a safety-related function. In addition, the ECCS performs

functions that support fire protection and EQ.

LRA Table 2.3.2.2 identifies ECCS component types within the scope of license renewal and

subject to an AMR. The intended functions of the ECCS component types within the scope of

license renewal include:

0 heat exchange between fluid media

* restriction of process flow

* pressure-retaining boundary

* structural/functional support for safety-related/nonsafety-related components with

maintenance of physical integrity and flow path considerations

2.3.2.2.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.2 and UFSAR Sections 5.2.2.10, 5.4.7, 6.2.2, and 6.3

using the evaluation methodology described in Safety Evaluation Report (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 delineated under 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 2.3.2.2-1, dated January 28, 2008, the staff requested additional information on the ECCS

sump screens, which were designed in LRA Drawings 1X4LD122 and 131 as not in-scope

components. The applicant responded that the ECCS sump screens are in scope components.

They are categorized as structural components. Refer to LRA section 2.4.1, Table 2.4.1, and

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Table 3.5.2-1, Item 12. The staff finds this response acceptable because the components are

included in-scope for license renewal.

The staff also requested that the applicant verify the LRA status of the boron injection surge

tank because the tank is listed as an ECCS component in UFSAR Table 6.3.2-4. In its response

dated February 27, 2008, the applicant responded that the boron injection surge tank on Unit 1

has been retired in place. Since it has no functions and is empty it is not in scope (refer to

boundary drawing 1X4LD1 19). A boron injection surge tank was never installed on Unit 2 (refer

to boundary drawing 2X4LD1 19).

The staff also requested that the applicant verify the status of the boric acid batching tank. In

LRA Drawing 1X4LD1 18, the tank is highlighted but not listed in Table 2.3.2.2 or discussed in

text. The applicant responded that the boric acid batching tanks are in scope components.

These tanks are listed in LRA Table 3.3.2-10, Items 38a & 38b. The staff finds this response

acceptable because the components are included in-scope for license renewal.

The staff also requested that the applicant verify the status of portions of the RWST liner. In

LRA Table 2.3.2.2, the RWST tank liner is listed. In UFSAR 6.3.2.2.9; the tank is described as

reinforced concrete tank with a stainless steel liner.

The applicant responded that the RWST tank liner is categorized as a mechanical component

and is listed in LRA Table 2.3.2.2, Item 32.

As discussed in LRA section 2.3.2.2, the concrete shell, roof, and base slab which provide

structural support for the tank liner are evaluated in the Structural scoping for the Concrete Tank

and Valve House Structures, Section 2.4.7. The staff finds this response acceptable because

the components are included in-scope for license renewal.

2.3.2.2.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

applicant failed to identify any SCs within the scope of license renewal. The staff finds no such

omissions. In addition, the staffs 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 ECCS 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).

2.3.2.3 Containment Isolation System

2.3.2.3.1 Summary of Technical Information in the Application

LRA Section 2.3.2.3 describes the containment isolation system, an engineered safety feature

that allows appropriate process fluids to pass through the containment boundary during normal

and accident conditions while isolating containment barrier penetrations as required to preserve

containment barrier integrity during accident conditions to prevent uncontrolled or unmonitored

leakage of radioactive materials to the environment. The containment isolation system is not

completely independent. Each piping system which penetrates the containment has

containment isolation features which minimize the release of fission products following a designbasis accident. These features are scoped and evaluated in their respective mechanical

process systems rather than in the containment isolation system.

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2.3.2.3.2 Staff Evaluation

The staff reviewed LRA Section 2.3.2.3 and UFSAR Sections 6.2.4, and 15.6.5.4 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 delineated under 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).

2.3.2.3.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs within the scope of license renewal. The staff finds no such omissions. In

addition, the staffs 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 containment isolation system

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).

2.3.3 Auxiliary Systems

LRA Section 2.3.3 identifies 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: (NOTE: Systems marked with "*" are Balance of Plant systems)

LRA Section System

2.3.3.1* new fuel storage

2.3.3.1* spent fuel storage

2.3.3.2* spent fuel cooling and purification system

2.3.3.3* containment building polar bridge crane

2.3.3.3* fuel handling & RV servicing equipment

2.3.3.3* spent fuel cask bridge crane

2.3.3.4* nuclear service cooling water

2.3.3.4* nuclear service cooling water chemical injection

2.3.3.5* component cooling water

2.3.3.6* auxiliary component cooling water

2.3.3.7* turbine plant cooling water

2.3.3.8* river intake structure

2.3.3.9* instrument air

2.3.3.9* instrument, service, and breathing air

2.3.3.10* boron recycle

2.3.3.10* CVCS (non-ECCS portions)

2.3.3.10 CVCS (non-ECCS portions)

2.3.3.11 CB control room area HVAC

2.3.3.11 CB safety feature electrical equipment room HVAC

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2.3.3.11 CB wing area, levels A, B, 1 and 2 normal HVAC

2.3.3.11 CB lab hood and laboratory area ventilation

2.3.3.11 CB locker and toilet exhaust

2.3.3.11 CB cable spreading rooms HVAC

2.3.3.11 electrical penetration filter exhaust

2.3.3.11 TSC HVAC

2.3.3.12 AB outside air supply and normal HVAC

2.3.3.12 AB radwaste area filter exhaust and continuous exhaust

2.3.3.12 AB engineered safety features room coolers

2.3.3.12 piping penetration filter exhaust

2.3.3.13 containment building air cooling

2.3.3.13 CTB lower level air circulation

2.3.3.13 CTB preaccess filter

2.3.3.13 CTB minipurge supply and normal preaccess purge supply

2.3.3.13 CTB minipurge exhaust and normal access purge exhaust

2.3.3.13 CTB post LOCA purge exhaust

2.3.3.13 CTB cavity cooling

2.3.3.13 CTB reactor support cooling

2.3.3.13 CTB auxiliary air cooling

2.3.3.13 CTB post-LOCA cavity purge

2.3.3.14 FHB normal HVAC

2.3.3.14 FHB post-accident exhaust

2.3.3.15 ventilation system - diesel generator building

2.3.3.16 ventilation system - auxiliary feedwater pump house

2.3.3.17 electrical tunnel ventilation

2.3.3.17 piping penetration ventilation

2.3.3.17 fire protection facilities HVAC

2.3.3.18 ventilation systems - radwaste buildings

2.3.3.19 fire protection water

2.3.3.19 fire protection seismic category I water

2.3.3.19 fire protection halon

2.3.3.20* emergency diesel generator system

2.3.3.21* demineralized water system

2.3.3.22 hydrogen recombiner and monitoring

2.3.3.23* auxiliary building drain system - nonradioactive

2.3.3.23* auxiliary building flood-retaining rooms, alarms, and drains

2.3.3.23* containment and auxiliary building drain system - radioactive

2.3.3.23* control building drains

2.3.3.23* fuel handling building drains

2.3.3.23* sanitary waste and vent

2.3.3.23* turbine building drain

2.3.3.24* potable water

2.3.3.24* utility water

2.3.3.25* radiation monitoring system

2.3.3.26* reactor makeup water storage tank and degasifier

2.3.3.27* nuclear sampling system - gaseous

2.3.3.27* nuclear sampling system - liquids

2.3.3.27* post-accident sampling

2.3.3.27* turbine plant sampling

2.3.3.28* auxiliary gas system - H2

2.3.3.28* auxiliary gas system - N2

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2.3.3.29* essential chilled water

2.3.3.29* normal chilled water

2.3.3.29* special chilled water

2.3.3.30* backflushable filter

2.3.3.30* condensate cleanup

2.3.3.30* waste processing system, gas

2.3.3.30* waste processing system, liquid

2.3.3.31 thermal insulation

2.3.3.32* miscellaneous leak detection

In accordance with Section 2.3, "Scoping and Screening Results - Mechanical Systems," the

staff identified the following BOP systems for Tier 1 reviews:

LRA Section System

2.3.3.23 sanitary waste and vent

2.3.3.23 turbine building drain system

2.3.3.24 potable water

2.3.3.24 utility water

2.3.3.28 auxiliary gas system - H2

2.3.3.30 backflushable filter system

2.3.3.30 condensate cleanup system

As part of the staffs review, the following RAIs identified instances of drawing errors where the

continuation notation for piping on one drawing to another drawing was incorrect:

* RAI 2.3.3.4-4

* RAI 2.3.3.4-5

* RAI 2.3.3.6-1

* RAI 2.3.3.6-2

* RAI 2.3.3.23-1

* RAI 2.3.3.26-1

In its response, dated February 27, 2008, the applicant identified the correct locations.

Based on its review, the staff finds the applicant's responses to these RAIs acceptable because

the applicant provided the correct drawing continuation references. Therefore, the staffs

concerns described in the RAIs are resolved.

The staff's findings for the auxiliary systems are discussed below.

2.3.3.1 Fuel Storage Racks - New and Spent Fuel

2.3.3.1.1 Summary of Technical Information in the Application

LRA Section 2.3.3.1 describes the fuel storage racks for new and spent fuel. The fuel handling

building houses the new fuel storage area and the spent fuel pool. The new fuel storage area

houses new fuel storage racks for temporary dry storage of new fuel assemblies. Each rack is

composed of individual vertical cells that can be fastened together in any number to form a

module that can be bolted firmly to anchors in the floor of the new fuel storage area. The new

fuel storage rack design includes storage for 162 fuel assemblies at a center-to-center spacing

of 21 inches for minimal separation between adjacent fuel assemblies of 12 inches, sufficient to

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maintain a subcritical array even when the building is flooded with unborated water or during

any DBE.

Spent fuel is stored in high-density racks. Each rack in the Unit 1 spent fuel pool consists of

several cells welded together to form the rack top grid and at the bottom to a supporting grid

structure. The Unit 2 spent fuel pool consists of an assemblage of cells interconnected along

their contiguous corners in a honeycomb cellular structure. None of these free-standing

modules are anchored to the floor or braced to the wall. The design of the racks with the soluble

boron in the fuel storage pool is relied upon to keep the stored fuel subcritical!'for all analyzed

events as described in the UFSAR. There are storage locations for 1476 assemblies in the Unit

1 pool and 2098 in the Unit 2 pool.

The fuel storage racks - new and spent fuel contain safety-related components relied upon to

remain functional during and following DBEs.

LRA Table 2.3.3.1 identifies fuel storage racks - new and spent fuel component types within the

scope of license renewal and subject to an AMR:

* failed fuel rod storage basket

* new fuel storage rack assembly

" spent fuel storage racks

The intended functions of the fuel storage racks - new and spent fuel component types within

the scope of license renewal include:

reactivity control

structural/functional support for safety-related/nonsafety-related components with

maintenance of physical integrity and flow path considerations

2.3.3.1.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.1 and UFSAR Sections 4.3.2.6.1 and 9.1 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 delineated under 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).

2.3.3.1.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 fuel storage racks - new and spent

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fuel 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).

2.3.3.2 Spent Fuel Cooling and Purification System

2.3.3.2.1 Summary of Technical Information in the Application

LRA Section 2.3.3.2 describes the spent fuel cooling and purification system, which removes

decay heat generated by spent fuel assemblies stored in the spent fuel pool and which can

maintain water clarity and purity in the spent fuel pool, the fuel transfer canal, the refueling

cavity, and the RWST.

The spent fuel cooling and purification system consists of two cooling trains, each with one heat

exchanger and pump, piping, and valves. One purification loop, with demineralizer, filter, piping,

valving, and instrumentation, services both cooling loops. There is also a surface skimmer loop.

Each cooling train is designed to maintain spent fuel pool temperatures and heat loads as

described in the UFSAR.

The spent fuel cooling and purification system contains safety-related components relied upon

to remain functional during and following DBEs. The failure of nonsafety-related SCs in the

spent fuel cooling and purification system potentially could prevent the satisfactory

accomplishment of a safety-related function. In addition, the spent fuel cooling and purification

system performs functions that support EQ.

LRA Table 2.3.3.2 identifies spent fuel cooling and purification system component types within

the scope of license renewal and subject to an AMR:

* closure bolting

* demineralizer vessels

* flow orifice/elements

" heat exchangers - SFP HXs (channel heads)

" heat exchangers - SFP HXs (shells)

* heat exchangers - SFP HXs (tubes)

* heat exchangers - SFP HXs (tubesheets)

* piping components

" piping components - piping spools for startup strainers

" pump casings - refuel water purification pumps

* pump casings - SFP pumps

" pump casings - SFP skimmer pumps

* strainer elements

* strainer housings

* valve bodies

The intended functions of the spent fuel cooling and purification system component types within

the scope of license renewal include:

" protection from debris

0 heat exchange between fluid media

* pressure-retaining boundary

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2.3.3.2.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.2 and UFSAR Section 9.1.3 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 delineated under 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).

2.3.3.2.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 spent fuel cooling and purification

system 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).

2.3.3.3 Overhead Heavy and Refueling Load Handling System

2.3.3.3.1 Summary of Technical Information in the Application

LRA Section 2.3.3.3 describes the overhead heavy and refueling load handling system, which

includes the containment building (reactor) polar bridge crane, spent fuel cask bridge crane, and

fuel handling and reactor vessel servicing equipment.

The containment building (reactor) polar bridge crane is a steel double-box girder, electric,

overhead, top-running, motorized bridge crane with a 134-foot span mounted on a circular

runway rail supported by the containment building superstructure. The bridge consists of two

asymmetrical, welded plate box girders with full-depth diaphragms held together by structural

end tie girders. The primary function of the polar crane is hoisting as required for the reactor

head and internals during refueling and servicing operations.

The crane's rated operational load capacity is based on the integrated reactor head, the

heaviest refueling lift requirement.

The primary function of the spent fuel cask bridge crane is to transport spent fuel casks

between the railcar loading and unloading area and the spent fuel storage area. The crane may

be in use during normal plant operation or when the plant is shut down for refueling or

maintenance. The crane is also for unpacking and transporting new fuel to the new fuel pit and

for construction and maintenance lifts as required in the fuel handling and auxiliary buildings.

The fuel handling and reactor vessel servicing equipment for core alterations (fuel shuffle and

fuel movement, core unload and reload), the refueling machine in the containment building and

the fuel handling machine bridge crane in the fuel handling building are designed to protect

against fuel.damage during handling and transfer operations.

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The overhead heavy and refueling load handling system contains safety-related components

relied upon to remain functional during and following DBEs. The failure of nonsafety-related SCs

in the overhead heavy and refueling load handling system potentially could prevent the

satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3.3 identifies overhead heavy and refueling load handling system component

types within the scope of license renewal and subject to an AMR:

* base plates and anchors for attachment to structures, and retaining clips

* crane (including bridge & trolley) structural girders

* crane rails

2.3.3.3.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.3 and UFSAR Sections 9.1.4 and 9.1.5 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 delineated under 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).

2.3.3.3.3 Conclusion

The staff reviewed the LRA, and UFSAR to determine whether the applicant failed to identify

any SCs 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 overhead heavy and refueling load handling system

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).

2.3.3.4 Nuclear Service Cooling Water Systems (NSCW)

2.3.3.4.1 Summary of Technical Information in the Application

LRA Section 2.3.3.4 describes the NSCW systems, which include the NSCW and the NSCW

chemical injection systems. The NSCW system, composed of two redundant, completely

independent, full-capacity flow trains, provides essential cooling to safety-related equipment and

to some nonsafety-related auxiliary components. Each train has three 50-percent capacity

vertical centrifugal pumps, one forced-draft cooling tower, piping, and valves. The system

supplies cooling water for the containment coolers, control building essential chiller condensers,

various engineered safety feature (ESF) pump coolers, standby diesel generator jacket water

coolers, and the component cooling water (CCW) and auxiliary component cooling water

(ACCW) heat exchangers.

The NSCW cooling towers, the ultimate heat sink for the plant, are required for safe shutdown.

They remove heat from the NSCW system during normal operation, safe shutdown or cooldown

of the reactor, or accident conditions. Each cooling tower consists of a basin which contains the

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ultimate heat sink water and of an upper structure which transfers the NSCW heat loads to the

atmosphere. The upper structure is a vertical, circular, concrete mechanical draft tower with

motor-driven fans for heat transfer to the atmosphere by direct contact of water droplets from

spray manifolds with forced air flow.

The combined storage capacity of the two tower basins per unit meets short-term (30 days)

storage requirements for the ultimate heat sink without makeup. The mechanical portion of the

NSCW cooling towers includes the piping, valves, and mechanical draft fans.

The NSCW chemical injection system, which injects biocide, dispersant, and corrosion inhibitor

solutions to the NSCW system to inhibit biological growth, prevent deposition of suspended

solids, and reduce copper tube corrosion, is comprised of chemical injection pumps, chemical

mixing and storage tanks, drums, or both, and piping components for transferring chemical

solutions to the injection points downstream of the NSCW pumps at the NSCW cooling tower

basins. The chemical injection equipment is located in the NSCW chemical control building.

The NSCW systems contain safety-related components relied upon to remain functional during

and following DBEs. The failure of nonsafety-related SCs in the NSCW systems potentially

could prevent the satisfactory accomplishment of a safety-related function. In addition, the

NSCW systems perform functions that support fire protection and EQ.

LRA Table 2.3.3.4 identifies NSCW systems component types within the scope of license

renewal and subject to an AMR:

* closure bolting

* flow orifice/elements

* oil coolers - NSCW pumps thrust bearings (coils)

* piping components

* pump casings - NSCW system pumps

* pump casings - NSCW transfer pumps

* spray nozzles

* valve bodies

The intended functions of the NSCW systems component types within the scope of license

renewal include:

* heat exchange between fluid media

* flow pattern or distribution provision

* restriction of process flow

* pressure-retaining boundary

2.3.3.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.4 and UFSAR 9.2.1 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 delineated under 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

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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).

The staff's review of LRA Section 2.3.3.4 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. In addition to

the RAIs 2.3.3.4-4 and 2.3.3.4-5 related to drawing continuation errors described in Section

2.3.3, the applicant responded to the staffs RAIs as discussed below.

In RAI 2.3.3.4-1, dated January 28, 2008, the staff noted that drawings 1 X4LD1 33-1,

1X4LD133-2, 2X4LD133-1, and 2X4LD133-2, locations G-6, G-7, and G-8 show NSCW cooling

tower fans as within the scope of license renewal based on criterion 10 CFR 54.4(a)(1 ).

However, the fan casings/housings are not included in LRA Table 2.3.3.4 as a component type

subject to an AMR. The applicant was requested to provide additional information to explain

why the NSCW tower fan casings/housings are not included in LRA Table 2.3.3.4 as component

types subject to an AMR.

In its response, dated February 27, 2008, the applicant stated:

The NSCW fan, composed of the motor driver, gearbox, shaft, hub assembly

and blades, is an active assembly, not subject to an AMR. The stack that

forms the fan's housing for flow direction control is constructed of concrete

and is an integral part of the NSCW cooling tower structure. The housing is in

scope and is included in Table 2.4.6 as NSCW cooling tower stack.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.4-1 acceptable

because the applicant provided clarification that the fan housing in question is within the scope

of license renewal and is included in Table 2.4.6 as part of the "NSCW cooling tower stack."

Therefore, the staffs concern described in RAI 2.3.3.4-1 is resolved.

In RAI 2.3.3.4-2, dated January 28, 2008, the staff noted that drawings 1X4LD133-1 and

2X4LD133-1 (D-4) show pipe sections 131-1" and 130-1" and drawings 1X4LD133-2 and

2X4LD133-2 (D-4) show pipe sections 132-1" and 369-1" that are within the scope of license

renewal based on criterion 10 CFR 54.4(a)(2). None of these pipelines show in-scope anchoring

that assures these pipelines are adequately anchored for spatial interaction.

The applicant was requested to provide additional information explaining how the pipelines

listed above are adequately anchored to prevent spatial interaction.

In its response, dated February 27, 2008, the applicant stated:

The above pipe lines are in scope for attached or connected piping

(10 CFR 54.4(a)(2)). In this case, attached piping bounds spatial interaction -

the entire lines out to their termination points are in the scope of license

renewal and are age managed. These lines terminate at either a blind flange

or welded pipe cap and thus the (a)(2) concerns associated with them do not

propagate into other systems or to other nonsafety-related segments of the

NSCW system. As part of the plant's CLB, these lines are seismically

analyzed and seismically supported, with the pipe supports being in the

scope of license renewal and age managed. These segments of nonsafetyrelated piping cannot fail in a way that would compromise safety-related

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equipment, either by failure of attached piping or a pressure boundary breech

resulting in a spatial interaction.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.4-2 acceptable

because the applicant stated that the subject pipe sections, as part of the plant's CLB, are

seismically analyzed and supported. Therefore, the staffs concern described in RAI 2.3.3.4-2 is

resolved.

In RAI 2.3.3.4-3, dated January 28, 2008, the staff noted that drawings 1X4LD133-1,

2X4LD133-1, 1X4LD133-2, and 2X4LD133-2 (D-4) show pipe sections 505-2", 057-2", 007-2",

and 007-2", respectively, that are within the scope of license renewal based on criterion

10 CFR 54.4(a)(2). None of these pipe sections show in-scope anchoring that assures these

pipe sections are adequately anchored for spatial interaction. The applicant was requested to

provide additional information explaining how these pipelines are adequately anchored to

prevent spatial interaction.

In its response, dated February 27, 2008, the applicant stated:

The above pipe lines are in scope for attached or connected piping

(10 CFR 54.4(a)(2)). In this case, attached piping bounds spatial interaction - the

entire lines out to their termination points are in the scope of license renewal and

are age managed. These lines terminate at a blind flange and thus the (a)(2)

concerns associated with them do not propagate into other systems or to other

nonsafety-related segments of the NSCW system. As part of the plant's CLB,

these lines are seismically analyzed and seismically supported, with the pipe

supports being in the scope of license renewal and age managed.

These segments of nonsafety-related piping cannot fail in a way that would

compromise safety-related equipment, either by failure of attached piping or a

pressure boundary breech resulting in a spatial interaction.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.4-3 acceptable

because the applicant stated that the subject pipe sections, as part of the plant's CLB,

are seismically analyzed and supported. Therefore, the staffs concern described in RAI

2.3.3.4-3 is resolved.

2.3.3.4.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

applicant failed to identify any components 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 the applicant has adequately identified the nuclear service cooling

water system 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).

2.3.3.5 Component Cooling Water System

2.3.3.5.1 Summary of Technical Information in the Application

LRA Section 2.3.3.5 describes the closed-loop CCW system as an intermediate heat transfer

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system between potentially radioactive heat sources and the NSCW system to reduce the

probability of radioactive releases to the environment from a leaking component. The CCW

system cools the spent fuel pool heat exchangers, the RHR heat exchangers, and the RHR

pump seal coolers.

The CCW system, consisting of two redundant trains, each with one heat exchanger, three 50-

percent centrifugal pumps, one surge tank, piping, and valves, is designed to operate at lower

pressure than is the NSCW system to prevent potentially contaminated CCW water from

entering the NSCW system, which is open to atmosphere through the NSCW cooling towers.

The CCW system contains safety-related components relied upon to remain functional during

and following DBEs. The failure of nonsafety-related SCs in the CCW system potentially could

prevent the satisfactory accomplishment of a safety-related function. In addition, the CCW

system performs functions that support fire protection.

LRA Table 2.3.3.5 identifies CCW system component types within the scope of license renewal

and subject to an AMR:

* closure bolting

* flow orifice/elements

* heat exchangers - CCW HXs (channel heads)

• heat exchangers - CCW HXs (shells)

* heat exchangers - CCW HXs (tubes)

* heat exchangers - CCW HXs (tubesheets)

* motor coolers - CCW pumps (channel heads)

* motor coolers - CCW pumps (shells)

* motor coolers - CCW pumps (tubes)

* motor coolers - CCW pumps (tubesheets)

* piping components

* piping components - pipe spools for startup strainers

* pump casings - CCW pumps

* tanks - CCW chemical addition feeder tanks

* tanks - CCW surge tanks

* valve bodies

The intended functions of the CCW system component types within the scope of license

renewal include:

* heat exchange between fluid media

* restriction of process flow

* pressure-retaining boundary

2.3.3.5.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.5 and UFSAR Section 9.2.2 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 delineated under 10 CFR 54.4(a). The staff then reviewed those components

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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).

2.3.3.5.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs within the scope of license renewal. The staff finds no such omissions. In

addition, the staffs 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 CCW system 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)(11).

2.3.3.6 Auxiliary Component Cooling Water System (1217)

2.3.3.6.1 Summary of Technical Information in the Application

LRA Section 2.3.3.6 describes the ACCW system, which removes heat from the heat

exchangers and components that handle radioactive fluids necessary for normal plant startup,

normal power operation, normal shutdown and cooldown, and refueling. Not essential for safe

plant shutdown under accident conditions, the ACCW system is composed of two 100-percent

capacity ACCW heat exchangers, two 100-percent capacity ACCW pumps, one ACCW surge

tank, piping, and valves. The ACCW system accomplishes cooling through an intermediate

closed-loop design cooled in turn by water directly from the NSCW system.

Because it may be contaminated by radioactive materials, the ACCW system is designed for

lower pressures than those for the NSCW system, which is open to the atmosphere through the

ultimate heat sink cooling towers, so the cooling systems do not release radioactive materials to

the environment. The system cools the normal charging pump motor coolers, seal water heat

exchanger, catalytic hydrogen recombiners, waste gas compressors, pressurizer sample

coolers, reactor coolant sample cooler, reactor coolant drain tank heat exchanger, reactor

coolant pump (RCP) motor coolers, thermal barriers, bearing lube oil coolers, 'letdown heat

exchanger, excess letdown heat exchanger, and ACCW pump and motor coolers.

The ACCW system contains safety-related components relied upon to remain functional during

and following DBEs. The failure of nonsafety-related SCs in the ACCW system potentially could

prevent the satisfactory accomplishment of a safety-related function. In addition, the ACCW

system performs functions that support fire protection and EQ.

LRA Table 2.3.3.6 identifies ACCW system component types within the scope of license

renewal and subject to an AMR:

* closure bolting

* flow orifice/elements

* heat exchangers - ACCW HXs (channel heads)

* heat exchangers - ACCW HXs (shells)

• heat exchangers - ACCW HXs (tubes)

* heat exchangers - ACCW HXs (tubesheets)

* motor coolers - ACCW pumps (channel heads)

* motor coolers - ACCW pumps (shells)

2-54
* motor coolers - ACCW pumps (tubes)

* motor coolers - ACCW pumps (tubesheets)

* piping components

* piping components - pipe spools for startup strainers

* pump casings - ACCW pumps

* tanks - ACCW chemical addition feeder tanks

* tanks - ACCW surge tanks

* valve bodies

The intended functions of the ACCW system component types within the scope of license

renewal include:

* restriction of process flow

* pressure-retaining boundary

2.3.3.6.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.6 and UFSAR Section 9.2.8 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 delineated under 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).

The staff's review of LRA Section 2.3.3.6 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The staff

identified RAIs 2.3.3.6-1 and 2.3.3.6-2 involving instances of drawing errors where continuation

notation for the piping from one drawing to another drawing was incorrect. These are described

in Section 2.3.3.

2.3.3.6.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

applicant failed to identify any components within the scope of license renewal. The staff finds

no such omissions. In addition, the staffs 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 the applicant has adequately identified the ACCW auxiliary

component cooling water system 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).

2.3.3.7 Turbine Plant Cooling Water System

2.3.3.7.1 Summary of Technical Information in the Application

LRA Section 2.3.3.7 describes the turbine plant cooling water (TPCW) system, which supplies

cooling water to remove heat from nonsafety-related heat exchangers: turbine plant closed-loop

cooling water heat exchangers, main turbine lube oil coolers, normal cooling water system

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chillers, steam generator blowdown trim heat exchangers, CVCS chillers, generator hydrogen

coolers, isophase bus coolers, vacuum pump seal water coolers, and generator stator coolers.

The failure of nonsafety-related SCs in the TPCW system could potentially prevent the

satisfactory accomplishment of a safety-related function. LRA Table 2.3.3.7 identifies TPCW

system component types within the scope of license renewal and subject to an AMR:

* closure bolting

* flow orifice/elements

* piping components

* strainer housings

* valve bodies

The intended function of the TPCW system component types within the scope of license

renewal is to provide a pressure-retaining boundary.

2.3.3.7.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.7 and UFSAR Section 9.2.11 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 delineated under 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).

2.3.3.7.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 TPCW system 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).

2.3.3.8 River Intake Structure System

2.3.3.8.1 Summary of Technical Information in the Application

LRA Section 2.3.3.8 describes the river intake structure system, which provides makeup water

to the circulating water system hyperbolic cooling towers and an alternate source of makeup to

the NSCW cooling towers and dilutes the discharge of plant effluent as required to meet

10 CFR Part 20 limits.

The failure of nonsafety-related SCs in the river intake structure system could potentially

prevent the satisfactory accomplishment of a safety-related function.

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LRA Table 2.3.3.8 identifies river intake structure system component types within the scope of

license renewal and subject to an AMR:

* closure bolting

* piping components

* valve bodies

The intended function of the river intake structure system component types within the scope of

license renewal is to provide a pressure-retaining boundary.

2.3.3.8.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.8 and UFSAR Sections 10.4.5.2.2C and 10.4.5.2.3 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 delineated under 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).

2.3.3.8.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 river intake structure system

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).

2.3.3.9 Compressed Air System

2.3.3.9.1 Summary of Technical Information in the Application

LRA Section 2.3.3.9 describes the compressed air system, which continuously supplies filtered,

dry, oil-free compressed air for pneumatic instrument operation and control of pneumatic

actuators. The system also supplies compressed, normally filtered, dry, and oil-free service air

to outlets throughout the plant for operation of pneumatic tools and for other service air

requirements. There are one reciprocating compressor and two rotary compressor trains located

in each unit. The outlets from the air receivers of these three trains for each unit connect to a

common compressed air supply line. Piping for the third reciprocating compressor train located

in Unit 1 can be aligned to either the Unit 1 or Unit 2 compressed air supply line.

The compressed air supply line in each unit branches to supply both the service air system and

the instrument air system. The service air system consists of a prefilter, a dryer, and an afterfilter from which the air flows to the various service air loops. The instrument air system consists

of two dryers in parallel, each with a pre-filter and after-filter. The air from the system flows to

the various instrument air loops in the unit.

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The compressed air system contains safety-related components relied upon to remain

functional during and following DBEs. The failure of nonsafety-related SCs in the compressed

air system potentially could prevent the satisfactory accomplishment of a safety-related function.

In addition, the compressed air system performs functions that support EQ.

LRA Table 2.3.3.9 identifies compressed air system component types within the scope of

license renewal and subject to an AMR:

0 closure bolting

* flow orifice/elements

* piping components

* valve bodies

The intended functions of the compressed air system component types within the scope of

license renewal include:

* restriction of process flow

* pressure-retaining boundary

2.3.3.9.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.9 and UFSAR Section 9.3.1 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 delineated under 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).

2.3.3.9.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 compressed air system 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).

2.3.3.10 Chemical and Volume Control and Boron Recycle Systems

2.3.3.10.1 Summary of Technical Information in the Application

LRA Section 2.3.3.10 describes the CVCS and the boron recycle system. The CVCS maintains

the required RCS inventory by regulating the programmed pressurizer water level through

continuous charging and letdown of reactor coolant water for the control of water chemistry

conditions, activity level, and soluble chemical neutron absorber concentration.

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The CVCS also injects seal water into the RCPs. Portions of the system contain borated water

at a concentration higher than that of the RCS to maintain reactor shutdown margin.

The CVCS consists of one normal charging and two standby centrifugal charging pumps. The

centrifugal charging pumps provide safety injection flow as described in LRA Section 2.3.2.2. In

addition, the system has a letdown heat exchanger, an excess letdown heat exchanger, a

regenerative heat exchanger, a volume control tank, piping, valves, and filters. The CVCS has

demineralizer vessels and chemical tanks to control RCS water chemistry and the system

recycles reactor grade water. Portions of the CVCS functioning as parts of the ECCS inject flow

to the RCS during post-accident injection and recirculation. LRA Section 2.3.2.2 describes

ECCS functions.

The CVCS boron recycle system portion processes reactor coolant effluent fit for reuse as

makeup and decontaminates the effluent by demineralization. The CVCS thermal regeneration

system portion is usable during reactor coolant boration and dilution operations, when RCS

letdown flow may be directed to the thermal regeneration demineralizers to adjust reactor

coolant boric acid concentration.

The CVCS and boron recycle systems contain safety-related components relied upon to remain

functional during and following DBEs. The failure of nonsafety-related SCs in the CVCS and

boron recycle systems potentially could prevent the satisfactory accomplishment of a safetyrelated function. In addition, the CVCS and boron recycle systems perform functions that

support fire protection, SBO, and EQ.

LRA Table 2.3.3.10 identifies CVCS and boron recycle systems component types within the

scope of license renewal and subject to an AMR:

* closure bolting

* demineralizer vessels

* filter housings

* flow orifice/elements

* heat exchangers - excess letdown HXs (channel heads)

* heat exchangers - excess letdown HXs (shells)

* heat exchangers - excess letdown HXs (tubes and tubesheets)

* heat exchangers - letdown chillers (channel heads)

* heat exchangers - letdown chillers (shells)

• heat exchangers - letdown chillers (tubes)

* heat exchangers - letdown HXs (channel heads)

* heat exchangers - letdown HXs (shells)

* heat exchangers - letdown HXs (tubes and tubesheets)

* heat exchangers - letdown reheat HXs (channel heads)

* heat exchangers - letdown reheat HXs (shells)

* heat exchangers - letdown reheat HXs (tubes and tubesheets)

* heat exchangers - moderating HXs (channel heads)

* heat exchangers - moderating HXs (shells)

* heat exchangers - moderating HXs (tubes and tubesheets)

* heat exchangers - regenerative HXs (channel heads)

* heat exchangers - regenerative HXs (shells)

• heat exchangers - regenerative HXs (tubes and tubesheets)

* letdown orifices

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* motor coolers - normal charging pumps (channel heads)

* motor coolers - normal charging pumps (shells)

• motor coolers - normal charging pumps (tubes)

* motor coolers - normal charging pumps (tubesheets

* piping components

* piping components - pipe spools for startup

• strainers

* pump casings - boric acid transfer pumps

* pump casings - CVCS recycle feed pumps

* pump casings - normal charging pumps

• pump casings - zinc addition injection pumps

• tank diaphragms - boric acid storage tanks

* tanks - boric acid batching tanks

* tanks - boric acid storage tanks

* tanks - boron meter tanks

* tanks - chemical mixing tanks

• tanks - recycle holdup tanks

• tanks - volume control tanks

* valve bodies

The intended functions of the CVCS and boron recycle systems component types within the

scope of license renewal include:

restriction of process flow

* physical integrity maintenance to prevent generation of debris or loose

parts which could interfere with a safety-related function

pressure-retaining boundary

2.3.3.10.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.10 and UFSAR Sections 9.3.4.1 and 9.3.4.2 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 delineated under 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).

2.3.3.10.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 CVCS and boron recycle system

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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).

2.3.3.11 Ventilation Systems - Control Building

2.3.3.11.1 Summary of Technical Information in the Application

LRA Section 2.3.3.11 describes the control building ventilation systems, which include the

following:

* control room area HVAC system

* control building safety feature electrical equipment room HVAC system

* control building wing area, levels A, B, 1, and 2 normal HVAC system

• control building lab hood and laboratory area ventilation system

* control building locker and toilet exhaust system

* control building cable spreading rooms HVAC system

* electrical penetration filter exhaust system

* onsite technical support center HVAC system

The control room area HVAC system operates in either normal or emergency mode. In the

normal mode the system supplies conditioned air to the control room area during normal plant

operating conditions for personnel comfort and a suitable operating environment for equipment.

If gaseous fission product levels exceed limits in the outside air intake, the control room HVAC

system would be re-aligned from normal to emergency mode where a small amount of outside

air filtered by high-efficiency filtration units maintains control room envelope pressurization. The

system also switches to the emergency mode upon a safety injection signal or manual

actuation. The four safety-related filtration units have train-related cooling coils which take

cooling water from the essential chilled water system. Both Units 1 and 2 share the control room

emergency HVAC system, the air ducts serving the control room forming a common system

connected to the safety-related air handling units.

The control building safety feature electrical equipment room HVAC system provides a proper

environment and temperature for electrical equipment and maintenance personnel during

normal and postulated accident conditions. During normal operations, cooling is by coils

containing cooling water from the normal chilled water system. Under design-basis accident

conditions, two cooling trains are by cooling coils with cooling water from the essential chilled

water system. Power for each train of the system is from a separate and independent Class 1 E

power system. Continuous exhaust minimizes the accumulation of hydrogen gas within the

battery rooms.

The control building wing area levels A, B, 1, and 2 normal HVAC systems provide ventilation,

cooling, heating, and smoke removal for operating personnel during normal conditions. Cooling

coils contain cooling water from the normal chilled water system.

The control building laboratory hood and laboratory area ventilation system provides exhaust

and auxiliary makeup airflow necessary for the proper operation of the laboratory hoods. The

system also purges the laboratory area of airborne radioactive contamination. Air in the hoods

and laboratory area pass through carbon filters before discharging to the atmosphere. Safetyrelated system components are limited to the tornado dampers and their ductwork.

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The control building locker and toilet exhaust system purges the locker, shower, storage, toilet,

and control building level 2 battery areas by exhausting to the atmosphere the air supplied to

these areas during normal operating conditions.

The control building cable spreading rooms HVAC system cools, heats, and ventilates the cable

spreading, auxiliary relay, normal air-conditioning, electric equipment, and computer rooms

during normal conditions.

The system provision of emergency cooling to the auxiliary relay, normal air-conditioning, and

electric equipment rooms is a safety-related function. These emergency cooling coils contain

cooling water from the essential chilled water system. The other safety-related portions of this

system are the tornado dampers and their ductwork.

The electrical penetration filter exhaust system fans and filtration units for Unit I were

abandoned in place and never installed on Unit 2. Ductwork and dampers for this system are in

use for normal ventilation.

The onsite technical support center HVAC system provides environmental control for

habitability, supports computer operational requirements, and filters potentially radioactive

particulates and iodine gas during normal and emergency plant operations. This system is not

safety-related but has certain fire dampers within the scope of license renewal.

The control building ventilation systems contain safety-related components relied upon to

remain functional during and following DBEs. The failure of nonsafety-related SCs in the control

building ventilation systems potentially could prevent the satisfactory accomplishment of a

safety-related function. In addition, the control building ventilation systems perform functions

that support fire protection and SBO.

LRA Table 2.3.3.11 identifies control building ventilation systems component types within the

scope of license renewal and subject to an AMR:

* AC units (ESF) housings

• closure bolting

* control room filter and fan unit housings

* control room filter and fan unit moisture eliminators

* cooling coils (essential chilled water)

* cooling coils (normal chilled water)

* damper housings

* duct silencer housings

* ductwork and fittings

* fan housings

* flexible connectors

* heater housings

* piping components

* sealants

The intended functions of the control building ventilation systems component types within the

scope of license renewal include:

* heat exchange between fluid media

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* missile barrier

* moisture elimination or reduction

* pressure-retaining boundary

2.3.3.11.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.11 and UFSAR Sections 6.4, and 9.4.1 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 delineated under 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).

2.3.3.11.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs within the scope of license renewal. The staff finds no such omissions. In

addition, the staffs 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 control building ventilation system

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).

2.3.3.12 Ventilation Systems - Auxiliary Building

2.3.3.12.1 Summary of Technical Information in the Application

LRA Section 2.3.3.12 describes the auxiliary building ventilation systems, which include the

following:

* auxiliary building outside air supply and normal HVAC

* auxiliary building radwaste area filter exhaust and continuous exhaust system

* auxiliary building ESF room coolers

* piping penetration filter exhaust system

The auxiliary building outside air supply and normal HVAC system provides the outside air

required to maintain acceptable auxiliary building activity. The system also heats and cools the

building to maintain acceptable temperatures during normal operation. This system works in

conjunction with the auxiliary building radwaste area filter exhaust system, which filters and

exhausts the air supply to maintain negative pressurization in the auxiliary building for

radioactivity control. A containment isolation signal isolates the auxiliary building outside air

supply and normal HVAC system from the building's penetration filter exhaust system.

The auxiliary building radwaste area filter exhaust and continuous exhaust system maintains

negative pressure in the auxiliary building by exhausting from the building more air than is

supplied so no unfiltered potentially contaminated air leaks to the environment. This system also

exhausts air from the radwaste transfer building and radwaste transfer tunnel, filtering all

exhaust air to collect any fission products before discharging it through the equipment building

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stack. A containment isolation signal isolates the auxiliary building radwaste area filter exhaust

and continuous exhaust system from the auxiliary building penetration filter exhaust system.

The auxiliary building ESF room coolers provide cooling to safety-related switchgear, motor

control centers, and pump rooms during normal, post-accident, and loss-of-offsite-power

conditions. Individual fan-coil units use train-related essential chilled water during such

emergency conditions.

The safety-related piping penetration filter exhaust system minimizes the release to the outside

atmosphere of airborne radioactivity from containment leakage into the piping penetration areas

during accident conditions by exhausting air to maintain negative pressure in those areas and

filtering the exhaust air to remove fission products before releasing it through the vent stack. A

portion of the exhaust air passes through cooling coils and recirculates back to the piping

penetration areas. A containment ventilation isolation signal isolates the piping penetration filter

exhaust system from the normal auxiliary building supply and exhaust systems, energizing the

piping penetration exhaust fan and filter. Cooling coils contain cooling water from the NSCW

system.

The auxiliary building ventilation systems contain safety-related components relied upon to

remain functional during and following DBEs. The failure of nonsafety-related SCs in the

auxiliary building ventilation systems potentially could prevent the satisfactory accomplishment

of a safety-related function. In addition, the auxiliary building ventilation systems perform

functions that support fire protection and EQ.

LRA Table 2.3.3.12 identifies auxiliary building ventilation systems component types within the

scope of license renewal and subject to an AMR:

* closure bolting

* cooling coils (essential chilled water)

• cooling coils (normal chilled water)

* cooling coils (NSCW)

* damper housings

* ductwork and fittings

* fan housings

* flexible connectors

* piping components

* piping penetration area cooler housings

* piping penetration filter and fan unit housings

* piping penetration filter and fan unit moisture eliminators

* room cooler housings

The intended functions of the auxiliary building ventilation systems component types within the

scope of license renewal include:

* heat exchange between fluid media

* missile barrier

• moisture elimination or reduction

* pressure-retaining boundary

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2.3.3.12.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.12 and UFSAR Section 9.4.3 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 delineated under 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 reviewing LRA Section 2.3.3.12, the staff identified areas in which additional information was

necessary to complete the review of the results of the applicant's scoping and screening.

Therefore, by letter dated January 28, 2008, the staff issued a request for additional information

concerning the specific issues to determine whether the applicant has properly applied the

scoping criteria of 10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21(a)(1). The

following paragraphs describe the staff's RAI and the applicant's related response.

In RAI 2.3.3.12-1, dated January 28, 2008, the staff identified several non-safety-related fans,

not identified on the drawings as in-scope, but identified as being subject to an AMR. The

Scope Determination Summary states that non-safety-related fan housings in this system are

relied upon as missile barriers (for the fan element). Therefore, the staff requested the applicant

to clarify whether these components are subject to aging management review.

Applicant's Response and Staff's Evaluation

In a letter dated February 27, 2008, the applicant stated:

The fans are an airfoil design. The fan manufacturer asserts that the airfoil fan

blade design used for these fans does not fail catastrophically in such a manner

that a missile could be ejected. Therefore, the associated fan housings are not

considered in scope under 10 CFR Part 54.4(a)(2) criterion as missile barriers.

The applicant also stated that the Scoping Determination Summary (Page 2.3-70) in the LRA

will be revised to clarify that only certain fan housings perform a missile barrier function. Based

on its review, the staff finds the applicant's response to RAI 2.3.3.12-1 acceptable.

2.3.3.12.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI response, and drawings to determine whether the

applicant failed to identify any SCs within the scope of license renewal. The staff finds no such

omissions. In addition, the staffs 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 auxiliary building ventilation

system 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).

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2.3.3.13 Ventilation Systems - Containment Building

2.3.3.13.1 Summary of Technical Information in the Application

LRA Section 2.3.3.13 describes the containment building (CTB) ventilation systems, which

include the following:

* containment building air cooling system

0 containment building lower level air circulating system

* containment building preaccess filter system

* containment building minipurge supply and normal preaccess purge supply

systems

* containment building minipurge exhaust and normal preaccess purge exhaust

systems

* containment building post-LOCA purge exhaust system

containment building cavity cooling system

containment building reactor support cooling system

containment building auxiliary air cooling system

containment building post-LOCA cavity purge system

The safety-related containment building air cooling system reduces the containment

temperature and pressure following a LOCA or main streamline break accident inside

containment by removing thermal energy. The system consists of eight air coolers per unit and

their ductwork and dampers. The containment coolers are divided into two trains with four fan

coolers each. Every cooler receives a start signal automatically upon a safety'! injection signal.

The containment building air cooling system also detects reactor coolant leakage during normal

operation. If air cooler condensate collected and measured in a standpipe rises above a preset

level in the standpipe, a high condensate flow alarm annunciates in the control room.

The containment building lower level air circulating system mixes containment lower level air to

prevent local hot spots. The system fans provide horizontal circulation in the area below the

operating deck during normal operations.

The containment building preaccess filter system, with the normal purge system, controls

airborne radioactivity inside containment.

This system circulates and filters containment air without makeup to reduce radioactivity in the

containment atmosphere below the level required for personnel access for inspection,

maintenance, and refueling operations.

The containment building minipurge supply and normal preaccess purge supply systems filter

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outside air to the containment atmosphere for adequate ventilation and personnel comfort while

the plant is shut down and for reduction of airborne contaminants and control of pressure

buildup inside containment during normal operations.

The containment building minipurge exhaust and normal preaccess purge exhaust systems

support the containment building minipurge supply and normal preaccess purge supply systems

with the necessary containment ventilation air exhaust and filtration. Air exhaust is through the

plant vent.

The containment building post-LOCA purge exhaust system allows containment purging as a

backup to the hydrogen recombiner system to maintain post-accident hydrogen concentration

below the combustible level. Use of the system post-LOCA may be in conjunction with a

portable air compressor through the seismic Category I portion of the service air piping to

provide the purge motive force. The air removed through ducting in the containment dome area

passes through the seismic Category I containment penetrations and the filter units where it

exhausts through the vent stack.

The containment building cavity cooling system cools the reactor cavity. The containment

building cavity cooling units operate with NSCW system cooling water in conjunction with the

containment building air cooling system to cool the primary shield concrete and nuclear

instrumentation. The system operates during normal and Ioss-of-offsite-power conditions. Upon

loss of offsite power loading of the cooling fans is automatic on a bus energized by the diesel

generator but the fans must be loaded manually following a LOCA. Safety-related portions of

the system include the cooling coils and cavity pressure relief dampers. This system is also

within the scope of license renewal under 10 CFR 54.4(a)(2) due to the missile barrier function

of its fan housings.

The containment building reactor support cooling system operates in conjunction with the

reactor cavity cooling system to cool the reactor supports. The containment building reactor

support cooling fans exhaust air from the reactor vessel supports to keep the concrete within its

operating temperature limit during normal and loss-of-offsite-power conditions.

The containment building auxiliary air cooling system removes excess thermal energy from the

containment atmosphere due to heat losses from operating equipment during normal power

generation and refueling outages. The system augments the containment cooling system

cooling capacity by an amount equivalent to the heat lost from the CRDM unit fans.

The system detects reactor coolant leakage during normal operation by collecting and

measuring air cooler condensate in a standpipe.

The containment building post-LOCA cavity purge system prevents hydrogen pocketing in the

reactor cavity after a LOCA by supplying air to the reactor cavity to maintain hydrogen

concentration below the combustible level, a safety-related function. The system has a Class 1 E

power supply, each redundant train connected to separate safety buses.

The system meets seismic Category I criteria and starts automatically upon a safety injection

signal.

The containment building ventilation systems contain safety-related components relied upon to

remain functional during and following DBEs. The failure of nonsafety-related SCs in the

containment building ventilation systems potentially could prevent the satisfactory

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accomplishment of a safety-related function. In addition, the containment building ventilation

systems perform functions that support EQ.

LRA Table 2.3.3.13 identifies containment building ventilation systems component types within

the scope of license renewal and subject to an AMR:

* closure bolting

* cooling coils (NSCW)

* CTB aux cooling unit housings

* CTB cooling unit housings

* damper housings

* ductwork and fittings

* fan housings

* flexible connectors

* flow orifice/elements

* piping components

* valve bodies

The intended functions of the CTB ventilation systems component types within the scope of

license renewal include:

* heat exchange between fluid media

* restriction of process flow

* missile barrier

* pressure-retaining boundary

2.3.3.13.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.13 and UFSAR Sections 6.2.1, 6.2.2, 6.5.1, and 9.4.6

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 delineated under 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 reviewing LRA Section 2.3.3.13, the staff identified areas in which additional information was

necessary to complete the review of the results of the applicant's scoping and screening.

Therefore, by letter dated January 28, 2008, the staff issued a request for additional information

concerning the specific issues to determine whether the applicant has properly applied the

scoping criteria of 10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21(a)(1).

The following paragraphs describe the staff's RAI and the applicant's related response.

In RAI 2.3.3.13-1, dated January 28, 2008, the staff identified that the CRDM unit fans were not

identified on the drawings as in-scope and being subject to an AMR when the applicant had

indicated in other areas that the housings for some fans in the containment building are

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considered in scope under 10 CFR Part 54.4(a)(2) criterion as missile barriers. Therefore,

the staff requested the applicant to clarify whether these components are subject to AMR, or

justify their exclusion.

Applicant's Response and Staff's Evaluation

In a letter dated February 27, 2008, the applicant stated:

The housings for the CRDM unit fans, 1(2)1509B7001 000 through 1(2)

1509B7004000, perform a missile barrier function in accordance with 10 CFR

54.4(a)(2) and should have been shown as in scope on boundary drawings

1X4LD214-1 and 2X4LD214-1. Therefore, Containment Building CRDM Cooling

System will be removed from LRA Table 2.2-2, "Systems and Structures Not

Within the Scope of License Renewal," and added to Table 2.2-1. A description

of the system will also be added to the Auxiliary System Description in LRA

Section 2.3.3.13. This system description will describe the basis for the

Containment Building CRDM Cooling System meeting 10 CFR 54.4(a)(2)

criterion.

The commodity type fan housings (ID No. 7d and 7e) in LRA Table 3.3.2-13 provide the AMR

for these fan housings.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.13-1 acceptable,

because it is the staffs understanding, based on the applicant's response to the staff's RAI, that

the CRDM unit fan housings are within the scope of license renewal in accordance with 10 CFR

54.4(a), and are subject to an AMR in accordance with 10 CFR 54.21(a) (1).

2.3.3.13.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI response, and drawings to determine whether the

applicant failed to identify any SCs 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 containment building

ventilation system 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).

2.3.3.14 Ventilation Systems - Fuel Handling Building

2.3.3.14.1 Summary of Technical Information in the Application

LRA Section 2.3.3.14 describes the fuel-handling building ventilation systems, which include the

fuel-handling building normal HVAC and fuel-handling building post-accident exhaust systems.

The fuel-handling building normal HVAC system heats, cools, ventilates, and filters fuelhandling building (shared by Units 1 and 2) air to maintain an atmosphere suitable for personnel

and equipment during normal operation. Redundant radiation monitors in the fuel-handling

building normal exhaust ductwork detect high radiation levels. If radiation levels exceed

setpoints, a signal isolates the fuel-handling building normal exhaust system and initiates the

fuel-handling building post-accident exhaust system.

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The fuel-handling building post-accident exhaust system prevents ex-filtration of contaminated

air from the fuel-handling building by filtering and exhausting air from the area after its isolation

from the normal fuel-handling building ventilation subsystem. The fuel-handling building postaccident exhaust system maintains a negative pressure within the area following a fuel-handling

accident. The system consists of two 100-percent capacity exhaust filtration units, piping,

ductwork, and dampers and shares the exhaust ductwork from the isolation dampers to the

post-accident exhaust filtration units with the fuel-handling building normal HVAC system. If a

fuel-handling accident releases radioactivity, radiation monitors in the normal fuel-handling

building exhaust duct sense high radioactivity and transmit a high-radiation signal to the balance

of plant safety actuation system, which in turn generates a fuel-handling building isolation signal

which causes the isolation dampers to close, isolating the fuel-handling building from the normal

supply and exhaust. The exhaust filtration units start automatically upon the isolation signal and

duct the exhaust from the filtration units to the plant vent. The fuel-handling building postaccident exhaust system also can be actuated manually from the control room.

The fuel-handling building ventilation systems contain safety-related components relied upon to

remain functional during and following DBEs. The failure of nonsafety-related SCs in the fuelhandling building ventilation systems potentially could prevent the satisfactory accomplishment

of a safety-related function. In addition, the fuel-handling building ventilation systems perform

functions that support fire protection and EQ.

LRA Table 2.3.3.14 identifies fuel-handling building ventilation systems component types within

the scope of license renewal and subject to an AMR:

* closure bolting

* cooling coils (normal chilled water)

* damper housings

* ductwork and fittings

* fan housings

* fuel-handling building post-accident filter and fan unit housings:

• fuel-handling building post-accident filter and fan unit moisture eliminators

* flexible connectors

* piping components

* valve bodies

The intended functions of the fuel handling-building ventilation systems component types within

the scope of license renewal include:

* missile barrier

* moisture elimination or reduction

* pressure-retaining boundary

2.3.3.14.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.14 and UFSAR Section 9.4.2 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 delineated under 10 CFR 54.4(a). The staff then reviewed those components

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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 reviewing LRA Section 2.3.3.13, the staff identified areas in which additional information was

necessary to complete the review of the results of the applicant's scoping and screening.

Therefore, by letter dated January 28, 2008, the staff issued a request for additional information

concerning the specific issues to determine whether the applicant has properly applied the

scoping criteria of 10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21 (a)(1). The

following paragraphs describe the staff's RAIs and the applicant's related responses.

In RAI 2.3.3.14-1, dated January 28, 2008, the staff identified that the fuel handling building

normal AC unit fans and fuel pool area recirculating air handling unit fans were not identified on

the drawings as in-scope, but were identified as being subject to an AMR. The Scope

Determination Summary states that non-safety-related fan housings associated with this system

are relied upon as missile barriers (for the fan element). Therefore, the staff requested the

applicant to clarify whether these components are subject to AMR.

Applicant's Response and Staff's Evaluation

In a letter dated February 27, 2008, the applicant stated:

The fans are an airfoil design. The fan manufacturer asserts that the airfoil fan

blade design used for these fans does not fail catastrophically in such a manner

that a missile could be ejected. Therefore, the associated fan housings are not

considered in scope under 10 CFR Part 54.4(a)(2) criterion as missile barriers.

The applicant also stated that the Scoping Determination Summary (Page 2.3-70) in the LRA

will be revised to qualify that only certain fan housings perform a missile barrier function.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-1 acceptable.

In RAI 2.3.3.14-2, dated January 28, 2008, the staff concludes fuel pool area recirculating air

handling system ductwork was not identified on the drawings as in-scope or being subject to an

AMR. The Scope Determination Summary states that certain ductwork and dampers associated

with the Fuel Handling Building Normal HVAC System interface with the Fuel Handling Building

Post-Accident Exhaust System and must maintain integrity in order to maintain negative

pressure in the Fuel Handling Building post-accident.

Therefore, the staff requested the applicant to clarify whether these components are in scope

and subject to AMR.

Applicant's Response and Staff's Evaluation

In a letter dated February 27, 2008, the applicant stated:

The ductwork from PASS 1-2702-P5-SAP does not perform an in-scope function.

NE195-10 Appendix F section 5.2.2.1 provides the basis for air and gas systems

not being a hazard to other plant equipment. The failure of the non-safety related

portion of ductwork is not a credible event which could impact the portion of duct

that is in-scope for 10 CFR Part 54.4(a)(1). Therefore, the ductwork from PASS

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1-2702-P5-SAP is not considered in scope under 10 CFR Part 54.4(a)(2)

criterion.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-2: acceptable,

because it is the staff's understanding, based on the applicant's response to the staff's RAI, that

the ductwork does not perform an in scope function and therefore is not within the scope of

license renewal in accordance with 10 CFR 54.4(a).

In RAI 2.3.3.14-3, dated January 28, 2008, the staff identified fuel pool area recirculating air

handling system ductwork and booster that were not identified on the drawings as in-scope or

being subject to an AMR. The Scope Determination Summary states that certain ductwork and

dampers associated with the Fuel Handling Building Normal HVAC System interface with the

Fuel Handling Building Post-Accident Exhaust System and must maintain integrity in order to

maintain negative pressure in the Fuel Handling Building post-accident. Therefore, the staff

requested the applicant to clarify whether these components are in scope and are subject to

AMR.

Applicant's Response and Staff's Evaluation

In a letter dated February 27, 2008, the applicant stated:

The ductwork from PASS 2-2702-P5-SAP and Booster Fan 2-1541-B7-001-

000 does not perform an in-scope function. NEI 95-10 Appendix F section

5.2.2.1 states that industry operating experience has shown no failures due to

aging that have adversely impacted the accomplishment of a safety function.

Failure of these non-safety related portions of ductwork is not a credible event

which could impact the portion of duct that is in-scope for 10 CFR Part

54.4(a)(1). Therefore, the ductwork from PASS 2-2702-P5-SAP and Booster

Fan 2-1541-B7-001-000 is not considered in scope under 10 CFR Part

54.4(a)(2) criterion.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.14-3' acceptable,

because it is the staffs understanding, based on the applicant's response to the staff's RAI, that

the ductwork and booster fan do not perform an in scope function and therefore are not within

the scope of license renewal in accordance with 10 CFR 54.4(a).

2.3.3.14.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

applicant failed to identify any SCs 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 fuel handling building

ventilation system 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).

2.3.3.15 Ventilation Systems - Diesel Generator Building

2.3.3.15.1 Summary of Technical Information in the Application

LRA Section 2.3.3.15 describes the diesel generator building ventilation system, which

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ventilates and removes heat from the building during diesel generator operation and supplies

sufficient heat for easy starting of the diesel generators and for personnel occupancy. The

system is divided into two subsystems, ESF and non-ESF. During normal plant operation, the

non-ESF heating system maintains a minimum temperature when the diesel generators are not

running. Non-ESF building ventilation is also utilized as required for maintenance and personnel

access.

The ESF ventilation system maintains the maximum temperature of the building below analyzed

limits with the diesel generator operating. Building ventilation is by 100-percent outside air at

summer design temperatures and by recirculation and outside air as the temperature drops in

winter. Power for the ESF ventilation equipment is by the Class 1 E bus of the same train as the

diesel generator set ventilated.

The diesel generator building ventilation system contains safety-related components relied upon

to remain functional during and following DBEs. In addition, the diesel generator building

ventilation system performs functions that support fire protection.

LRA Table 2.3.3.15 identifies diesel generator building ventilation system component types

within the scope of license renewal and subject to an AMR:

* closure bolting

* damper housings

* ductwork and fittings

* fan housings

* filter housings - EDG control panel supply ventilation

* flexible connectors

The intended function of the diesel generator building ventilation system component types

within the scope of license renewal is to provide a pressure-retaining boundary.

2.3.3.15.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.15 and UFSAR Section 9.4.7 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 delineated under 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 reviewing LRA Section 2.3.3.15, the staff identified areas in which additional information was

necessary to complete the review of the results of the applicant's scoping and screening.

Therefore, by letter dated January 28, 2008, the staff issued an RAI concerning the specific

issues to determine whether the applicant has properly applied the scoping criteria of

10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21 (a)(1). The following paragraphs

describe the staff's RAI and the applicant's related response.

In RAI 2.3.3.15-1, dated January 28, 2008, the staff identified that the diesel generator building

ventilation system unit heater fans were not identified on the drawings as in-scope or being

subject to an AMR. The Scope Determination Summary states that non-safety-related fan

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housings associated with this system are relied upon as missile barriers (for the fan element).

Therefore, the staff requested the applicant to clarify whether these components are in scope

and subject to an AMR.

In a letter dated February 27, 2008, the applicant stated:

The Non-ESF Exhaust fan housings, perform a missile barrier function per 10

CFR 54.4(a)(2), and should have been shown as in scope on boundary drawings

1X4LD217 and 2X4LD217. Unit heaters, 1(2)-1566-U7001-000 through 1(2)-

1566-U7-020-000, also perform a missile barrier function per 10 CFR 54.4(a)(2).

The applicant will add commodity type Fan Housings (ID No.4) in LRA Table 3.3.2.15. They will

also provide the AMR for the Fan Housings, and a new commodity type Heater Housings to

Tables 2.3.3-15 and 3.3.2-15, the latter of which will provide the AMR for the Heater Housings.

The scoping determination (LRA Page 2.3-89) is also revised to reflect the addition in

accordance with 10 CFR 54.4(a)(2).

Based on its review, the staff finds the applicant's response to RAI 2.3.3.15-1 acceptable,

because it is the staff's understanding, based on the applicant's response to the staffs RAI, that

the fan housings are within the scope of license renewal in accordance with 10 CFR 54.4(a),

and are subject to an AMR in accordance with 10 CFR 54.21(a) (1).

2.3.3.15.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI response, and drawings to determine whether the

applicant failed to identify any SCs within the scope of license renewal. The staff finds no such

omissions. In addition, the staffs 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 diesel generator building

ventilation system 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).

2.3.3.16 Ventilation Systems - Auxiliary Feedwater Pump House

2.3.3.16.1 Summary of Technical Information in the Application

LRA Section 2.3.3.16 describes the auxiliary feedwater pumphouse ventilation system, which

provides heating, cooling and ventilation for an environment suitable for equipment and

maintenance personnel. The system operates whenever the pumps operate during normal,

accident, or loss-of-offsite-power conditions. This system utilizes both ESF and non-ESF

outside air supply units. The ESF fans maintain the temperature in the pump rooms within

analyzed limits. Pneumatically-operated dampers open automatically for natural ventilation of

the turbine-driven auxiliary feedwater pump room during SBO.

The auxiliary feedwater pumphouse ventilation system contains safety-related components

relied upon to remain functional during and following DBEs. In addition, the auxiliary feedwater

pumphouse ventilation system performs functions that support fire protection and SBO.

LRA Table 2.3.3.16 identifies auxiliary feedwater pumphouse ventilation system component

types within the scope of license renewal and subject to an AMR:

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* closure bolting

* damper housings

* ductwork and fittings

* fan housings

The intended function of the auxiliary feedwater pumphouse ventilation system component

types within the scope of license renewal is to provide a pressure-retaining boundary.

2.3.3.16.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.16 and UFSAR Section 9.4.8 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 delineated under 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 reviewing LRA Section 2.3.3.16, the staff identified areas in which additional information was

necessary to complete the review of the results of the applicant's scoping and screening.

Therefore, by letter dated January 28, 2008, the staff issued an RAI concerning the specific

issues to determine whether the applicant has properly applied the scoping criteria of

10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21 (a)(1). The following paragraphs

describe the staff's RAI and the applicant's related response.

In RAI 2.3.3.16-1, dated January 28, 2008, the staff identified that the auxiliary feedwater pump

house ventilation system unit heater fans were not identified on the drawings as in-scope or

being subject to an AMR. The Scope Determination Summary states that non-safety-related fan

housings associated with the system are relied upon as missile barriers (for the fan element).

Therefore, the staff requested the applicant to clarify whether these components are in scope

and subject to an AMR.

In a letter dated February 27, 2008, the applicant stated:

The Housings for unit heaters, 1(2)-1593-U7-001-000 through 1(2)-1593-U7-

007-000, perform a missile barrier function per 10 CFR 54.4(a)(2), and should

have been shown as in scope on boundary drawings 1X4LD227 and

2X4LD227.

As a result, the applicant LRA Tables 2.3.3.16 (Item 4) and 3.3.2.16 (Items 4a and 4b), will

be revised to include the missile barrier function. The scoping determination (LRA Page 2.3-91)

is also revised to reflect the addition in accordance with 10 CFR54.4(a)(2).

Based on its review, the staff finds the applicant's response to RAI 2.3.3.16-1 acceptable,

because it is the staffs understanding, based on the applicant's response to the staff's RAI, that

the fan housings are within the scope of license renewal in accordance with 10 CFR 54.4(a),

and are subject to an AMR in accordance with 10 CFR 54.21(a) (1).

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2.3.3.16.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI response, and drawings to determine whether the

applicant failed to identify any SCs 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 auxiliary feedwater pump

house ventilation system 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).

2.3.3.17 Ventilation Systems - Miscellaneous

LRA Section 2.3.3.17 describes the miscellaneous ventilation systems, which include the

following:

* electrical tunnel ventilation system

* piping penetration ventilation system

* fire protection facilities ventilation system

The electric tunnel ventilation system ventilates the tunnels carrying safety-related train-oriented

cables, normal cables, or both to prevent excessive heat during normal operation, shutdown,

refueling, and accident conditions. Essential system components ventilate the two diesel power

cable tunnels (train A and train B), the two NSCW tower cable tunnels (train A and train B), and

the turbine building and auxiliary building train A tunnel. Normal system components ventilate

the turbine building chase to control building tunnel. Each tunnel has its own subsystem.

The piping penetration ventilation system provides cooling air to the main steam and feedwater

pipe restraints in the main steam area and steam tunnel to keep concrete temperatures below

limits. The system functions during normal plant operation, startup, cold shutdown, cooldown

and hot standby, and refueling operations and remains functional during loss of offsite power.

Power is from the non-Class 1E standby power system.

The fire protection facilities ventilation system uses fans and louvers to ventilate the fire

protection pumphouses and fire protection valve houses and maintain the air temperature within

these structures at or below design temperature during fire pump operation. Two diesel-driven

fire pumps are located in one of the pumphouses and an electric motor-driven fire pump in the

other. The pump room ventilation components are within the scope of licensei renewal for fire

protection.

The miscellaneous ventilation systems contain safety-related components relied upon to remain

functional during and following DBEs. The failure of nonsafety-related SCs in the miscellaneous

ventilation systems potentially could prevent the satisfactory accomplishment of a safety-related

function. In addition, the miscellaneous ventilation systems perform functions that support fire

protection and EQ.

LRA Table 2.3.3.17 identifies miscellaneous ventilation systems component types within the

scope of license renewal and subject to an AMR:

* closure bolting

* damper housings

* ductwork and fittings

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* fan housings

* filter housings - tunnel supply air

* flexible connectors

The intended functions of the miscellaneous ventilation systems component types within the

scope of license renewal include:

* missile barrier

* pressure-retaining boundary

2.3.3.17A Ventilation Systems - Electric Tunnel Ventilation

2.3.3.17A.1 Summary of Technical Information in the Application

The electric tunnel ventilation system ventilates the tunnels carrying safety-related train-oriented

cables, normal cables, or both to prevent excessive heat during normal operation, shutdown,

refueling, and accident conditions. Essential system components ventilate the two diesel power

cable tunnels (train A and train B), the two NSCW tower cable tunnels (train A and train B), and

the turbine building and auxiliary building train A tunnel. Normal system components ventilate

the turbine building chase to control building tunnel. Each tunnel has its own subsystem.

2.3.3.17A.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.17 and UFSAR Section 9.4.9.2 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 delineated under 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 reviewing LRA Section 2.3.3.17, the staff identified areas in which additional information was

necessary to complete the review of the results of the applicant's scoping and screening.

Therefore, by letter dated January 28, 2008, the staff issued an RAI concerning the specific

issues to determine whether the applicant has properly applied the scoping criteria of

10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21(a)(1). The following paragraphs

describe the staff's RAI and the applicant's related response.

In RAI 2.3.3.17A-1, dated January 28, 2008, the staff identified that electrical tunnel ventilation

system drawing shows that the exhaust duct and fan are in scope, but the makeup air duct for

this space were not identified on the drawings as in-scope or being subject to an AMR. The

Scope Determination Summary states that non-safety-related fan housings associated with the

system are relied upon as missile barriers (for the fan element). Therefore, the staff requested

the applicant to clarify whether these components are in scope and subject to an AMR.

In a letter dated February 27, 2008, the applicant stated that the makeup air passageway and

associated components perform a pressure boundary function for makeup air to the tunnels and

should have been shown as in scope for 10 CFR 54.4(a)(2) on boundary drawings 1X4LD238

and 2X4LD238. The pressure boundary intended function will be added to the concrete

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components (Component Type IDs 1-4) in License Renewal Application tables 2.4.5 and 3.5.2-5

to account for the concrete portion of the passageways which serves a pressure boundary

function for the makeup air.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.17A-1 acceptable,

because it is the staff s understanding, based on the applicant's response to the staff's RAI, that

the makeup air passageway and associated components are within the scope of license

renewal in accordance with 10 CFR 54.4(a), and are subject to an AMR in accordance with 10

CFR 54.21 (a) (1).

In RAI 2.3.3.17A-2, dated January 28, 2008, the staff identified that the electric tunnel

ventilation system fan for the North-South Turbine Building Chase to Control Building tunnel

ventilation and associated ductwork were not identified on the drawings as in-scope as being

subject to an AMR therefore, the staff requested the applicant to clarify whether these

components are in scope and subject to an AMR.

In a letter dated February 27, 2008, the applicant stated:

the North-South Turbine Building Chase to Control Building Tunnel Ventilation

Fan 1(2)-1540-B7-007-000 and associated ductwork are not credited in the

design calculations for exhausting the Turbine Building and Auxiliary Building

Train A Tunnel. The purpose of these fans is to recirculate and, thereby,

prevent a stagnant air condition in the adjoining Turbine Building Chase to

Control Building Tunnel during normal plant conditions. Therefore, the NorthSouth Turbine Building Chase to Control Building Tunnel Ventilation Fan 1(2)-

1540-B7-007-000 and associated ductwork are not in scope for license

renewal.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.17A-2 acceptable,

because it is the staffs understanding, based on the applicant's response to the staff's RAI, that

the North-South Turbine Building Chase to Control Building. Tunnel Ventilation Fan (1(2)-1540-

B7-007-000) and associated duct are not in scope of license renewal in accordance with 10

CFR 54.4(a), and are not subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.3.3.17A.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

applicant failed to identify any SCs within the scope of license renewal. The staff finds no such

omissions. In addition, the staffs 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 electric tunnel ventilation

system 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).

2.3.3.17B Ventilation Systems - Piping Penetration Ventilation

2.3.3.17B.1 Summary of Technical Information in the Application

The piping penetration ventilation system provides cooling air to the main steam and feedwater

pipe restraints in the main steam area and steam tunnel to keep concrete temperatures below

limits. The system functions during normal plant operation, startup, cold shutdown, cooldown

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and hot standby, and refueling operations and remains functional during loss of offsite power.

Power is from the non-Class 1 E standby power system.

2.3.3.17B.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.17 and UFSAR Section 9.4.9.3 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 delineated under 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).

2.3.3.17B.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 piping penetration ventilation system

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).

2.3.3.17C Ventilation Systems - Fire Protection Facilities HVAC

2.3.3.17C.1 Summary of Technical Information in the Application

The fire protection facilities ventilation system uses fans and louvers to ventilate the fire

protection pumphouses and fire protection valve houses and maintain the air temperature within

these structures at or below design temperature during fire pump operation. Two diesel-driven

fire pumps are located in one of the pumphouses and an electric motor-driven fire pump in the

other. The pump room ventilation components are within the scope of license renewal for fire

protection.

2.3.3.17C.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.17 and UFSAR Section 9.5.1 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 delineated under 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).

2.3.3.17C.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

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identify any SCs 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 fire protection facilities HVAC system

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).

2.3.3.18 Ventilation Systems - Radwaste Buildings HVAC

2.3.3.18.1 Summary of Technical Information in the Application

LRA Section 2.3.3.18 describes the radwaste building ventilation systems, which include the

ventilation systems for the radwaste transfer building, radwaste transfer tunnel, and dry active

waste (DAW) Facilities.

The functions of the radwaste transfer building, radwaste transfer tunnel, and DAW facilities

HVAC systems are to:

heat, cool, and ventilate the DAW facility for proper operation of equipment and

personal comfort of maintenance or operations personnel

distribute and exhaust air suitably to reduce possible concentrations of

radioactive and chemical impurities in the process areas

draw effluent exhaust air from the radwaste transfer building through the auxiliary

building filtration system

ventilate the tunnel as required for periodic inspection

The radwaste transfer building and radwaste transfer tunnel HVAC systems are abandoned

except for the auxiliary building filtration system exhaust ductwork from the auxiliary building

radwaste area filter exhaust and continuous exhaust system; however, a fire damper in the west

fire-rated wall to prevent smoke and fire from translating to the auxiliary building via the

radwaste transfer tunnel is in the fire protection program, which is credited for 10 CFR 50.48

compliance and is within the scope of license renewal for fire protection. The radwaste building

ventilation systems perform functions that support fire protection.

LRA Table 2.3.3.18 identifies radwaste building ventilation systems component types within the

scope of license renewal and subject to an AMR:

* damper housings

* ductwork and fittings

The intended function of the radwaste building ventilation systems component types within the

scope of license renewal is to provide a pressure-retaining boundary.

2.3.3.18.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.18 and UFSAR Section 9.4.3.3 using the evaluation

methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

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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 delineated under 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).

2.3.3.18.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 radwaste building HVAC system

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).

2.3.3.19 Fire Protection Systems

2.3.3.19.1 Summary of Technical Information in the Application

LRA Section 2.3.3.19 describes the fire protection systems, which include the following:

* fire protection water system

* fire protection seismic Category 1 water system

* fire protection halon systems

The fire protection water system minimizes both the probability and the consequences of

postulated fires by adequate means for prompt fire detection, suppression, and control. The

primary goals of the fire protection water system are to ensure performance of design functions

required for safe plant shutdown and to minimize the probability of radioactive releases to the

environment in a fire. To prevent or limit fire damage to safety-related SCs so at least one

redundant train of equipment is available for safe shutdown, the system relies on fire prevention,

fire suppression, fire detection and annunciation, suppression system automatic supervision,

fire separation and confinement, fire extinguishment, fire brigade implements, and plant design

features to minimize fires and their consequences. Fire water suppression systems include fire

tanks and pumps, automatic and manual spray and sprinkler systems, hose stations, fire

hydrants and hose houses, and fire mains or yard loop headers to supply water to extinguish

fires. Consumables and short-lived components (e.g., fire extinguishers, self-contained

breathing apparatus air bottles, fire brigade accouterments like boots, gloves, and helmets, and

fire hoses) are included in this system.

Screening of the fire detection and actuation portion of this system is as part of the electrical

and instrumentation and controls systems (see LRA Section 2.5), of fire dampers as parts of the

assigned HVAC system, of other passive fire barriers as parts of the structural systems (see

LRA Section 2.4), and of the RCP oil collection system as part of the RCS and connected lines

(LRA Section 2.3.1.3).

The fire protection - seismic Category 1 water system supplies fire-extinguishing water for

manual hose stations in areas with equipment required for safe shutdown after a safe shutdown

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earthquake that might disable the normal fire protection system. This system fights fires

following a safe shutdown earthquake if no other source of fire-fighting water is available. The

system is completely manual with hose stations and stand pipes in the containment, diesel

generator, auxiliary, and control buildings. The NSCW system supplies water by manual valves

normally locked closed.

The fire protection halon system, which protects by halon fire-extinguishing gas electrical

equipment which supports safe plant shutdown, is composed of halon cylinders, discharge

piping, local halon control panels, and instruments. Shutdown panels in the control building

shutdown panel rooms and ventilation equipment in the control building records storage room

supporting safe plant shutdown are protected from fire by packaged halon flooding systems.

Other plant spaces and electrical equipment not supporting safe plant shutdown but fireprotected by packaged halon systems include the plant operating computer; the service building

communications room; the service building plant documentation storage rooms; and the

technical support center communication, computer, cathode ray tube (CRT) display, and

electrical equipment rooms.

The fire protection systems contain safety-related components relied upon to remain functional

during and following DBEs. In addition, the fire protection system performs functions that

support fire protection and EQ.

LRA Table 2.3.3.19 identifies fire protection systems component types within the scope of

license renewal and subject to an AMR:

* closure bolting

* fire hydrants

* flame arrester elements

* flame arrester housings

* flexible connectors

* flow orifice/elements

* fusible links and sprinkler head bulbs

• hose station nozzles and hose connections

* hose stations

• piping components

* pump casings - fire pumps (diesel-driver, motor-driven, and jockey pumps)

* sight glasses

* silencers

* spray shields

* sprinkler heads and spray nozzles

* strainer elements

* strainer housings

* tanks - fuel oil storage tanks (fire pump diesel)

* tanks - fire protection water storage tanks

* valve bodies

The intended functions of the fire protection systems component types within the scope of

license renewal include:

* protection from debris

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* prevention of flame propagation from ignition of vent pipe vapors back to the

source

* spray shield or curbs for flow direction

0 flow pattern or distribution provision

* restriction of process flow

* pressure-retaining boundary

2.3.3.19.2 Staff Evaluation

The staff reviewed the VEGP LRA, Section 2.3.3.19, (UFSAR), Section 9.5.1; NUREG-1 137,

"Safety Evaluation Report Related to the Operation of Vogtle Electric Generating Plant, Units 1

and 2," through Supplement 5; and NUREG-1 137, "Safety Evaluation Report Related to the

Operation of Vogtle Electric Generating Plant, Units 1 and 2," through Supplement 9; approving

the VEGP Fire Protection Program listed in the VEGP Units 1 and 2 Operating License

Condition 2.G, 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 delineated under 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).

The staff also reviewed VEGP Units 1 and 2 commitments to Title 10 CFR 50.48, "Fire

protection" (i.e., approved fire protection program), using their commitment documents to the

Branch Technical Position (BTP) Chemical and Mechanical Engineering Branch (CMEB) 9.5-1,

"Guidelines for Fire Protection for Nuclear Power Plants," Revision 2, July 1981, documented in

the fire protection CLB.

The staffs review of LRA, Section 2.3.3.19, identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAIs as discussed below.

In RAI 2.3.3.19-1, dated January 28, 2008, the staff stated that the following LRA drawings

show fire protection system components as out of scope (i.e., not colored in red):

LRA drawing CX4LD173-2:

* Fire Hydrants

* Fire Protection Piping to Turbine Building, Steam Tunnel, and Radwaste

Solidification Building

Intake Structure

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LRA drawing CX4LD173-4, in the following locations:

* Dry Active Waste Processing Facility

* Dry Active Waste Storage Building

LRA drawing 1X4LD174-1, Halon 1301 fire protection system in the following locations:

* Computer Room Level A

* Computer CRT Display and Communication Rooms Level 1

* Radwaste Solidification Building Contamination Oil Room Level 1

* Radwaste Solidification Building Elevation 192'-0"

LRA drawing 2X4LD174-1, Halon 1301 fire protection system's in the following location:

* Computer Room Level A

The staff requested that the applicant verify whether the above systems and components 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).

If these components are excluded from the scope of license renewal and not subject to an AMR,

the staff requests that the applicant provide justification for the exclusion. By letter dated

February 27, 2008, the applicant stated that:

The fire protection SCs that are relied upon in the event of a fire to maintain

the ability to perform reactor plant safe shutdown functions at VEGP (including

plant SCs that are relied upon to perform safe shutdown in the event of a fire),

or to minimize radioactive releases to the environment in the event of a fire,

are in-scope for license renewal - see VEGP-LR-TE-007, "Technical

Evaluation VEGP Fire Protection Scoping." For the fire protection system,

certain SCs are in scope for license renewal and certain SCs are not in scope,

depending on whether they are relied upon for 10 CFR 50.48 and Branch

Technical Position (BTP) CMEB 9.5-1 compliance or not (hereafter referred to

as "regulatory compliance"). The following is a breakdown of fire protection

SCs and a discussion of in-scope applicability:

Drawing CX4LD173-2: The fire hydrants listed in UFSAR Table 9.5.1-10D are

required for regulatory compliance and are in scope and highlighted as such

on the drawing. Those fire hydrants not in UFSAR Table 9.5.1-10D are not

required for regulatory compliance and are not in scope and thus not

highlighted on the drawing. The fire protection piping to the Turbine Building

(including steam tunnels) is not in scope because the fire protection system in

the Turbine Building is not relied upon for regulatory compliance (FSAR

Appendix 9B, paragraph C.7.h). Refer to the answer to RAI 2.1-2 for

discussion regarding non-safety related components in the Turbine Building.

The fire protection system in the Radwaste Solidification Building is not in

scope because the building has been abandoned in place and there is no

radioactive material stored there (UFSAR Section 11.4.2.4).

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Since the Intake Structure is not in the scope of license renewal, the fire protection system in

this structure is not in scope. See License Renewal Civil Boundary Drawing AX1 D45L01. In

evaluating this response, the staff finds that it was incomplete and that review of LRA, Section

2.3.3.19, could not be completed. Several yard fire hydrants are excluded from the scope of

license renewal and from subject to an AMR.

During a conference call, the staff questioned, in RAI 2.3.3.19-1, the applicant's methodology,

which excluded certain fire hydrants from the scope of the license renewal and subject to an

AMR. In its response dated June 23, 2008, the applicant stated that:

Fire protection SCs that are relied upon in the event of a fire to maintain the

ability to perform reactor plant safe-shutdown functions at VEGP (including

plant SCs that are relied upon to perform safe-shutdown in the event of a

fire), or to minimize radioactive releases to the environment in the event of a

fire are in-scope for license renewal. For the fire protection system, certain

SCs are in scope for license renewal and certain SCs are not in scope,

depending on whether they are relied upon for 10 CFR 50.48 and BTP CMEB

9.5-1 compliance or not (hereafter referred to as "regulatory compliance").

The CLB for VEGP's fire protection system is as follows:

The fire protection systems described in the VEGP UFSAR conform to General Design Criterion

3 as stated in UFSAR Section 3.0 (10 CFR 50, Appendix A, "General Design Criteria for Nuclear

Power Plants," Criterion 3, "Fire Protection"). The scoping criteria in 10 CFR 54.4(a)(3) states

that plant SCs within the scope of this part are "...relied on in safety analyses or plant

evaluations to perform a function that demonstrates compliance with the NRCs regulation for

fire protection (10 CFR 50.48)..." In addition to compliance with General Design Criterion 3 and

10 CFR 50.48, VEGP also utilizes the detailed guidance of BTP CMEB 9.5.1, "Guidelines for

Fire Protection for Nuclear Power Plants."

10 CFR 50.48 dictates that each applicant must have a fire protection plan that satisfies

Criterion 3 of Appendix A to 10 CFR 50. Criterion 3, "Fire Protection," stipulates:

"Structures, systems, and components important to safety shall be designed and located to

minimize, consistent with other safety requirements, the probability and effect of fires and

explosions. Noncombustible and heat resistant materials shall be used wherever practical

throughout the unit, particularly in locations such as the containment and control room. 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. Firefighting systems shall be designed to assure that their rupture or

inadvertent operation does not significantly impair the safety capability of these structures,

systems, and components." 10 CFR 50.48 requires that the plan describe specific features

necessary to implement the program such as automatic and manually operated fire detection

and suppression systems, and the means to limit fire damage to SCs important to safety so that

the capability to shut down the plant safely is ensured.

The VEGP fire protection program is described in detail in the UFSAR and was approved as

described in the UFSAR and other licensing documents by the NRC in the operating license:

Southern Nuclear shall implement and maintain in effect all provisions of the

approved fire protection program as described in the Final Safety Analysis

Report for the facility, and submittals dated July 2, August 4 and 13, October

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10 and 24, November 5, and December 19, 1986, and January 2, 1987, as

approved in the SER (NUREG-1 137) through Supplement 5 subject to the

following provision:

Southern Nuclear may make changes to the approved fire protection program

without prior approval of the Commission, only if those changes would not

adversely affect the ability to achieve and maintain safe-shutdown in the event

of a fire.

The SER (NUREG-1 137) was reviewed through Supplement 9 to help make scoping

determinations.

NUREG-1800 section 2.1.3.1.3, "Regulated Events," is a source of additional guidance on

applying the scoping criteria of 10 CFR 54.4(a)(3). It states that "...all SCs that are relied upon in

the plant's CLB (as defined in 10 CFR 54.3), plant-specific experience, industry-wide experience

(as appropriate), and safety analyses or plant evaluations to perform a function that

demonstrates compliance with NRC regulations identified under 10 CFR 54.4(a)(3), are required

to be included within the scope of the rule." In addition, it limits the extent of the review with the

statement that "an applicant need not consider hypothetical failures or second-, third-, or fourthlevel support systems in determining the SCs within the scope of the rule for 10 CFR

54.4(a)(3)." This guidance is not intended to exclude any support system.. .that is specifically

relied upon for compliance with the applicable NRC regulation. The guidance also recognizes

that "mere mention of an SC in the analysis or evaluation does not necessarily constitute

support of an intended function as required by the regulation." Thus, the mention of a system,

structure, or component in an analysis or evaluation (e.g., UFSAR, etc.) does not in and of itself

constitute reliance on the SC for regulatory compliance. Fire protection components also exist

solely to satisfy insurance requirements and are likewise not relied upon for regulatory

compliance and are not in the CLB.

In general, every fire protection system, structure, and component was reviewed against the

current licensing basis and scoping determinations were made based on whether the SC is part

of the CLB or not.

For the fire protection water system, portions of the system that are in scope for 10 CFR

54.4 a(3) are separated from portions of the system that are not in scope by manual isolation

valves that are normally open. These valves remain normally open so that in the event of a fire

in a not-in-scope portion of the system, water may be immediately available for fire suppression

following automatic initiation of the detection/suppression system(s) in the not-in-scope portion.

This also applies to not-in-scope yard fire hydrants that may be used to manually suppress fires.

Should an age related pressure boundary failure occur in the not-in-scope portion of the system

such that a significant system pressure drop results, an alarm would notify plant personnel and

the fire water pump(s) would start automatically. Following the alarm and pump start, plant

personnel would investigate the cause and manually close the isolation valve(s) separating the

failed not-in-scope portion of the system from the in-scope portion, as warranted, considering

the need to preserve fire water inventory for 10 CFR 50.48 compliance. The design of the

system provides multiple pumps and a large volume of stored water which can be used to

maintain system pressure while the location of a leak is identified and isolated. Ample time is

available to isolate a leak in a not-in-scope location before operability of the 50.48 protection

features can be affected. Therefore, terminating the license renewal boundary at an open

manual isolation valve is acceptable.

2-86
Based on its review, the staff finds the applicant's response to the first portion of RAI 2.3.3.19-1

acceptable. The fire hydrants included in scope of license renewal encompass the fire hydrants

included in Table 9.5.1-10D, UFSAR Amendment 28, November 14, 1985, and reviewed and

approved by the staff in Supplement 4 to NUREG-1 137, December 1985, as a part of the

original CLB of VEGP. This report is referenced directly in the VEGP fire protection CLB and

summarizes the fire protection program and commitments to 10 CFR 50.48 using BTP CMEB

9.5-1. Supplement 4 to NUREG-1 137 reviewed the VEGP UFSAR Amendments 24, 25, and 28,

in which the applicant made substantial changes to its fire hazards analysis for compliance with

the guidelines set forth in BTP CMEB 9.5-1. Originally VEGP UFSAR Amendment 28, Table

9.5.1-10D, consisted of four hydrants for Unit 1. After Unit 2 commercial operation, seven

hydrants were added in Table 9.5.1-10D based on the Unit 2 fire hazard analysis.

The staff finds the hydrants in question are not credited to meet the requirements of Appendix R

for achieving safe-shutdown in the event of a fire and were correctly excluded from the scope of

license renewal and not subject to an AMR. Therefore, the staff's concern described in the first

portion of RAI 2.3.3.19-1 is resolved.

In its response, by letter dated February 27, 2008, the applicant stated that, in Drawing

CX4LD 173-4:

The fire protection systems in the Dry Active Waste Processing Facility and Dry

Active Waste Storage Building are in the scope of license renewal. Although

these buildings are in the scope of license renewal, they are categorized as

structures and are not highlighted on mechanical boundary drawing CX4LD173-4

because this drawing is strictly a mechanical boundary drawing as stated in the

drawing title block. Structures are sometimes shown on mechanical boundary

drawings for clarity in describing the mechanical system, but the structure itself is

not highlighted on the mechanical boundary

drawings. For the highlighted in-scope structures, see License Renewal Civil

Boundary Drawing AX1D45L01.

Based on its review, the staff finds the applicant's response to the second portion of RAI

2.3.3.19-1 acceptable because the applicant explained that the fire suppression systems and

components in the Dry Active Waste Processing Facility and Dry Active Waste Storage Building

are in scope of license renewal and subject to an AMR. The applicant identified that, although

the Dry Active Waste Processing Facility and Dry Active Waste Storage Building are in scope of

license renewal and categorized as structures, they are not highlighted on mechanical boundary

drawing CX4LD173-4. However, these structures are highlighted on the civil boundary drawing

AXl D45L01. Therefore, the staff is adequately assured that the above fire suppression systems

and components for fire suppression in the Dry Active Waste Processing Facility and Dry Active

Waste Storage Building will be considered appropriately during the aging management

activities. Therefore, the staffs concern described in the second portion of RAI 2.3.3.19-1 is

resolved.

In its response, by letter dated February 27, 2008, the applicant stated that in, Drawing

1X4LD174-1:

The Halon systems in the Computer Room Level A, Computer CRT Display and

Communication Rooms Level 1, Radwaste Solidification Building Contamination

Oil Room Level 1, and the Radwaste Solidification Building Elevation 192'-0" are

shown not highlighted on drawing 1X4LD174-1. UFSAR Table 9.5.1-10,

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paragraph 4.1, lists the fixed Halon systems required for regulatory compliance

and these systems are highlighted on drawing 1X4LD174-1. The above listed

Halon systems are not in this table because they are not required for regulatory

compliance and are thus not in the scope of license renewal. The fire protection

system in the Radwaste Solidification Building is not in scope because it has

been abandoned in place and there is no radioactive material stored there (FSAR

Section 11.4.2.4).

In its response, by letter dated February 27, 2008, the applicant stated that in, Drawing

2X4LD174-1:

The Halon system in the Computer Room Level A is shown not highlighted on

drawing 2X4LD174-1. UFSAR Table 9.5.1-10, paragraph 4.1, lists the fixed

Halon systems required for regulatory compliance and these systemsare

highlighted on drawing 2X4LD174-1. The above listed Halon system is not in this

table because it is not required for regulatory compliance and is thus not in the

scope of license renewal.

The staff finds that the applicant's two responses shown above, acceptable. The total flooding

Halon 1301 systems in Computer Room Level A, Computer CRT Display and! Communication

Rooms Level 1, Radwaste Solidification Building Contamination Oil Room Level 1, and the

Radwaste Solidification Building Elevation 192'-0, do not mitigate fires in areas containing

equipment important to safe operation of the plant, nor are they credited with achieving safeshutdown in the event of a fire. Although the total flooding Halon 1301 fire suppression system

for the above areas are addressed in the NUREG-1 137, these systems in question are not

credited to meet the requirements of Appendix R for achieving safe-shutdown in the event of a

fire. The staff has confirmed that the applicant correctly excluded the above total flooding Halon

1301 fire suppression systems from scope of license renewal and subject to an AMR.

Therefore, the staffs concerns described in the third and fourth portions of RAI 2.3.3.19-1 are

resolved.

In RAI 2.3.3.19-2, dated January 28, 2008, the staff stated that LRA, Section 2.3.3.19,

discusses 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 to be passive, long-lived components. Both trash racks and traveling

screens are located in a fresh or raw water/air environment and are typically constructed of

carbon steel. Carbon steel in a fresh or raw water environment or water/air environment is

subject to loss of material, pitting, crevice formation, and microbiologically influenced corrosion,

and fouling. The staff requested that the applicant explain the apparent exclusion of the trash

racks and traveling screens that are 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).

By letter dated February 27, 2008, the applicant provided the following response:

VEGP's fire pumps take suction from fire water storage tanks and as such, do

not have trash racks and traveling screens. See LRA drawing CX4LD173-1.

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Based on its review, the staff finds the applicant's response to RAI 2.3.3.19-2 acceptable

because it adequately described that the intended function supporting the fire pump suction

supply is accomplished from the water storage tanks for Units 1 and 2. The fire pumps at VEGP

do not take suction from a natural source or bay; therefore, trash racks and traveling screens

are not required. Additionally, water tanks are in license renewal scope and are subject to an

AMR. Therefore, the staff's concern described in RAI 2.3.3.19-2 is resolved.

In RAI 2.3.3.19-3, dated January 28, 2008, the staff stated that LRA, Table 2.3.3-19, excludes

several types of fire protection components that appear in NUREG-1 137 and its supplements

and/or the UFSAR, and which also appear in the LRA drawings colored in red. These

components are listed below:

* Hose racks

* Yard hose houses

* Interior fire hose stations

* Pipe fittings

* Pipe supports and hangers

* Couplings

* Threaded connections

* Restricting orifices

* Interface flanges

* Dikes for oil spill confinement

* Floor drains and curbs for fire-fighting water

* Filter housing

* Heater housing

* Chamber housing

* Actuator housing

• Halon storage tanks/bottles

* Buried outside diesel fuel storage tanks

* Buried fire protection piping and underground fire main loop

* Heat exchanger (bonnet)

* Heat exchanger (shell)

* Heat exchanger (tube)

* Post-indicator sectional control valves

* Turbocharger

* Tank heater

* Thermowells

* Expansion joints

* Gear box housing

* Lubricating oil collecting system components (reactor coolant pump)

* Engine intake and exhaust silencers/muffler (diesel driven fire pump)

* Backflow prevention devices

* Flame retardant coating for cables

Fire retardant coating for structural steel supporting walls and ceilings

* Fire barrier penetration seals

• Fire barrier walls, ceilings, floor, and slabs

• Fire doors

• Fire rated enclosures

2-89
The staff requested that the applicant verify whether the components listed above should be

included in LRA, Table 2.3.3.19. If they are excluded from the scope of license renewal and not

subject to an AMR, the staff requests that the applicant provide justification for the exclusion.

By letter dated February 27, 2008, the applicant stated that:

For the most part, the above listed fire protection components are in the scope of

license renewal. In some cases, the item is not specifically listed in Table

2.3.3.19 but is included as one of the component types listed in the table. For

example, "pipe fittings" and several other components listed above are included

as "piping components" in Table 2.3.3.19. This is consistent with the guidance

provided in NEI 95-10, Revision 6, and Appendix B. The following is a breakdown

of how each component is treated in license renewal:

1) Hose racks are in scope and form part of a hose station, and as such, are

included as "hose stations" in Table 2.3.3.19.

2) Yard hose houses are not in the scope of license renewal because they are not

required for regulatory compliance and are a second level support system for

yard fire hydrants and fire hydrant fire hoses. These structures are small sheds

associated with yard fire hydrants and serve as a convenient location for

storing tools and the accompanying fire hydrant fire hoses. These structures

also afford limited protection from the weather for the fire hydrants and fire

hoses. However, convenience of fire hydrant accessory storage and limited

protection from the weather for the fire hydrants and fire hoses are not credited

in license renewal and not required for regulatory compliance. Hypothetical

failure of a hose house, which is a second level support system, need not be

considered in determining the SCs within the scope of the rule under 10 CFR

54.4(a)(3) -see NUREG-1800, Revision 1, Section 2.1.3.1.3. The cast iron fire

hydrants are in scope and age managed in the outdoor environment (fire

hydrants in Table 2.3.3.19) and the fire hoses are in scope but are short-lived,

being subject to periodic replacement and as such, do not require an AMR.

3) Interior fire hose stations are in scope and included in hose station nozzles and

hose connections and hose stations in Table 2.3.3.19.

4) Pipe fittings are in scope and included in "piping components" in Table

2.3.3.19.

5) Pipe supports and hangers are in scope and considered structural components

and covered in Table 2.4.12.

6) Couplings are in scope and included in "piping components" in Table 2.3.3.19.

7) Threaded connections are in scope and included in "piping components" in

Table 2.3.3.19.

8) Restricting orifices are in scope and included in "flow orifice/element" in Table

2.3.3.19.

9) Interface flanges are in scope and included in "piping components" in Table

2.3.3.19.

10) Dikes for oil spill confinement are considered to be part of the in-scope

structure in which they are located and are included in structural concrete

commodities in LRA section 2.4.

11 a) Curbs for containment of spilled water, including fire fighting water, are

considered to be part of the in-scope structure in which they are located and

are also included in structural concrete commodities in LRA Section 2.4.

11 b) Floor drains for processing spilled water, including fire fighting water, are

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included in the "Drains Systems" and are found in Table 2.3.3.23. The

structures for which the drain systems are in scope include the containment

building, the auxiliary building, and the control building, and the fuel handling

building. The NSCW structure has a leak detection system with associated

level switches and alarms. The drain or leak detection features for these

structures are in scope primarily for mitigation of flooding due to a line break.

However, release of fire protection system water in these structures would also

be processed by these in-scope drains. The drain systems for the other

structures that contain in-scope fire protection systems are not credited in the

CLB for mitigation of flooding and are therefore not in the scope of license

renewal. Flooding analyses have determined that flooding in these structures

will not impact any safety-related equipment. References: VEGP-LR-TE-010,

"Scoping Methodology for Nonsafety Related Equipment that Could Affect

Safety Related Equipment," Section 5.3.2; UFSAR Sections 3F.2.4, 3.4.1, and

9.3.3.

12) Filter housings are in scope and included as "strainer housings" in Table

2.3.3.19.

13) Heater housings are associated with the fire water pump diesel engines' onskid heat exchangers. The fire pump diesel engines and the on-skid equipment

are in scope but are complex active assemblies, not subject to an AMR.

14) Chamber housings include retard chambers in fire suppression systems.

Chambers are in scope and included as "piping components" in Table 2.3.3.19.

15) Actuator housings include dry pilot actuator housings in fire suppression

systems. Actuator housings are in scope and included as "valve bodies" in

Table 2.3.3.19.

16) Halon storage bottles are in scope and are short-lived, being subject to periodic

replacement and as such, do not require an AMR.

17) The fire pump diesel fuel oil storage tanks are in scope but are not buried,

being located outside, above ground level. They are included in Table 2.3.3.19

as "tanks -F. 0. storage tanks (fire pump diesel)."

18) The buried fire protection piping and underground fire main loop are in scope

and included in Table 2.3.3.19 as follows: piping components; fire hydrants;

valve bodies; closure bolting.

19) Heat exchanger bonnets are associated with the fire water pump diesel

engines' on-skid heat exchangers. The fire pump diesel engines and the onskid equipment are in scope but are complex active assemblies, not subject to

an AMR.

20) Heat exchanger shells are associated with the fire water pump diesel engines'

on-skid heat exchangers. The fire pump diesel engines and the on-skid

equipment are in scope but are complex active assemblies, not subject to an

AMR.

21) Heat exchanger tubes are associated with the fire water pump diesel engines'

on-skid heat exchangers. The fire pump diesel engines and the on-skid

equipment are in scope but are complex active assemblies, not subject to an

AMR.

22) The post-indicator sectional control valves are in scope and included as "valve

bodies" in Table 2.3.3.19.

23) The turbochargers are associated with the fire water pump diesel engines and

are mounted on the engines. The fire pump diesel engines, their

appurtenances, and the on-skid equipment are in scope but are complex active

assemblies, not subject to an AMR.

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24) There are no tank heaters associated with the fire protection system tanks -fire

water storage tanks or fire pump diesel fuel oil storage tanks.

25) Thermowells are in scope and included as "piping components" in Table

2.3.3.19.

26) Expansion joints are in scope and included as "flexible connectors" in Table

2.3.3.19.

27) Gear box housings for such components as electric motor driven equipment

are in scope but are part of the complex active assembly and not subject to an

AMR.

28) The lubricating oil collecting system components (reactor coolant pump) are in

scope and included in the RCS in Table 2.3.1.3 as follows: RCP lube oil drain

tank; RCP lube oil drain tank flame arrestor element; RCP lube oil drain tank

flame arrestor housing; RCP lube oil drip pans and enclosure; piping

components.

29) The engine intake and exhaust silencers/mufflers (diesel driven fire pump) are

in scope. The mufflers are mounted on the fire pump house roof and are

included in Table 2.3.3.19 as "silencers." The intake silencers are mounted on

the engine skids and are part of the complex active engine assembly and as

such, do not require an AMR.

30) The backflow prevention devices include check valves and are included in

Table 2.3.3.19 as "valve bodies".

31) Flame retardant coatings are not used at VEGP for cables.

32) Fire retardant coatings for structural steel supporting walls and ceilings are in

scope and included in LRA Section 2.4.12 and Table 2.4.12, Item 13.

33) Fire barrier penetration seals are in scope and included in LRA Section 2.4.12

and Table 2.4.12, Item 18.

34) Fire barrier walls, ceilings, floors, and slabs are in scope and included in LRA

Section 2.4.12 and Table 2.4.12, Items 14 and 15.

35) Fire doors are in scope and included in LRA Section 2.4.12 and Table 2.4.12,

Item16.

36) Fire rated enclosures are in scope and included in LRA Section 2.4.12 and

Table 2.4.12, Items 12 and 17.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.19-3' acceptable.

Although the applicant states that they consider some components to be included in other line

items, the descriptions of the line items in the LRA do not actually list all these components

specifically. Further the applicant has committed to interpret some components, for example,

dikes for oil spill confinement and curbs for fire-fighting, as being included in structural concrete

commodities in LRA, Section 2.4. Floor drains for processing spilled water, including fire-fighting

water are included in "Auxiliary System Drains Systems" in LRA Table 2.3.3.23. The applicant

has included the following items in the scope of license renewal and subject to an AMR

because of their intended functions as part of the pressure boundary: (1) hose racks are

included in hose stations commodity; (2) interior fire hose stations are included in hose station

nozzles and hose connection commodity; (3) pipe fittings, couplings, threaded connections,

interface flanges, chamber housing, and thermowells are included in piping components

commodity; (4) pipe supports, fire retardant coatings for structural steel, fire barrier penetration

seals, fire barrier wall, ceiling, floor, and slabs, fire doors, and fire rated enclosures are included

in Section 2.4.12 and Table 2.4.12; (5) buried fire protection piping and underground fire main

loop are included in Table 2.3.3.19 as piping components, fire hydrants, valve bodies and

closure bolting; (6) restricting orifices are included in flow orifice/element commodity (7) actuator

housings, backflow prevention devices, and post-indicator sectional control valves are included

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in valve bodies commodity;(8) expansion joints are included in flexible connectors commodity;

(9) lubricating oil collection system components are included in Table 2.3.1.3.

The applicant considered the Halon 1301 storage bottles to be in the scope of license renewal

but excluded from the AMR. The applicant stated that Halon storage bottles are replaced

periodically and, therefore, not subject to an AMR. The applicant excluded Halon storage bottles

from an AMR under 10 CFR 54.21 (a)(1)(ii) on a plant-specific basis. The applicant routinely

monitors Halon storage bottles based on performance or condition criteria ensuring that storage

bottles will maintain their intended function. Because the applicant has interpreted the Halon

storage bottles as part of an active component (condition monitoring to determine whether the

Halon storage bottles 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.

For each of the following components, the staff finds that they were not included in the line item

descriptions in the LRA for an AMR: heat exchanger bonnets, shells, and tubes; fire pump

turbocharger; gear box housings; diesel driven fire pump intake silencers; and heater housings.

The staff recognizes that the applicant's interpretation of these components as active will result

in more vigorous oversight of their condition and performance.

Because the applicant has interpreted heat exchanger bonnets, shells, and tubes; fire pump

turbocharger; gear box housings; diesel driven fire pump intake silencers; and heater housings

as active, the staff concludes their exclusion from scope of license renewal is correct and that

they are not subject to an AMR.

The staff finds that the yard hoses were not included in the line item descriptions in the LRA

table. The applicant stated that yard fire hydrants are housed in small sheds; fire hoses are in

scope but are short-lived, being subject to periodic replacement. Therefore, they do not require

an AMR. The staff recognizes the applicant's interpretation of these components as passive

(short-lived component), which will result in more vigorous oversight of the condition and

performance of the components. The staff concludes that the above components were excluded

correctly from the scope of license renewal and are not subject to an AMR. Therefore, the staff's

concern described in RAI 2.3.3.19-3 is resolved.

In RAI 2.3.3.19-4, dated January 28, 2008, the staff informed the applicant that NUREG-1 137

and its supplements listed various types of fire suppression systems provided in the plant areas

for fire suppression activities. The fire suppression systems in various areas are:

0 Total flooding Halon 1301 systems for two shutdown panel rooms,

computer room, and five non-safety-related areas in the control

building.

0 Dry standpipe for the control building, containment building, and auxiliary building

0 Deluge systems for charcoal filter assemblies

* Dry pre-action sprinkler systems below the reactor coolant pumps and in areas of

high cable tray concentrations

* Cable spreading room automatic pre-action sprinkler system

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9 Wet standpipe and hose system throughout the plant

The staff requested that the applicant verify whether the above fire suppression systems

installed in various areas of the plant 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). If they are

excluded from the scope of license renewal and not subject to an AMR, the staff requested that

the applicant provide justification for the exclusion.

By letter dated February 27, 2008, the applicant stated that:

The above listed fire protection systems are in the scope of license renewal as follows:

1) The total flooding Halon 1301 systems required for regulatory

compliance are in scope. See response to 2.3.3.19-1 for details.

2) The dry standpipe systems for the control building, containment

building, and auxiliary building are in scope. See License Renewal

Boundary Drawings 1X4LD174-6 and 2X4LD174-6.

3) The deluge systems for charcoal filter assemblies are in scope. See

License Renewal Boundary Drawings 1X4LD205-1, 1X4LD208-1,

1X4LD209, lX4LD213-1, lX4LD213-2, AX4LD204-1, AX4LD206-1,

AX4LD206-3, AX4LD215, AX4LD235, 2X4LD205-1, 2X4LD208-1,

2X4LD213-1, and 2X4LD213-2. It is noted that two charcoal filters (1-

1562-N7-001 & 002) on boundary drawing 1X4LD209 in the control

building on Unit 1 have been abandoned in place and the charcoal

removed from the filter units. The manual fire protection spray systems

for these two filters are not required and are not in-scope. The fire

protection in-scope boundary terminates at the first isolation valve in

each filter unit's fire water supply header. The high temperature fire

alarm that was in each filter's charcoal bed has been disabled.

4) The dry pre-action sprinkler systems below the reactor coolant pumps

and in areas of high cable tray concentrations in the containment

building were never installed. See NUREG-1 137, Supplement No.2,

Section 9.5.1.6.

5) The cable spreading room automatic pre-action sprinkler systems are

in scope. See License Renewal Boundary Drawings 1X4LD174-3,

rooms R-A44 and R-225 at coordinates D-2 and G-3 respectively;

2X4LD174-3, rooms R-A23 and R-224 at coordinates D-2 and G-3,

respectively. :1

6) The wet standpipe and hose system throughout the plant is in scope.

See License Renewal Boundary Drawings 1X4LD174-2, 1X4LD174-3,

lX4LD174-4, 2X4LD174-2, 2X4LD174-3, and 2X4LD174-4.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.19-4 acceptable.

The applicant stated that all above mentioned fire suppression systems in various area of the

plant are in scope; except for the Unit 1 control building charcoal filter deluge system because

the two charcoal filters for this system have been abandoned in place. Further, the applicant

informed the staff that the dry-action sprinkler systems, which were to be located below the

reactor coolant pumps and in areas of high cable tray concentrations in the containment

building, were never installed.

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The total flooding Halon 1301 systems in Computer Room Level A, Computer CRT Display, and

Communication Rooms Level 1, do not mitigate fires in areas containing equipment important to

safe operation of the plant, nor are they credited with achieving safe-shutdown in the event of a

fire. Although the total flooding Halon 1301 fire suppression system for the above areas are

addressed in the NUREG-1 137, these systems in question are not credited to meet the

requirements of Appendix R for achieving safe-shutdown in the event of a fire. The staff has

confirmed that the applicant correctly excluded the above total flooding Halon 1301 fire

suppression systems from scope of license renewal and subject to an AMR. Therefore, the

staff's concern described in RAI 2.3.3.19-4 is resolved.

2.3.3.19.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

applicant failed to identify any SCs within the scope of license renewal. The staff finds no such

omissions. On the basis of its review, the staff concludes that the applicant has adequately

identified the fire protection system components that are 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).

2.3.3.20 Emergency Diesel Generator System

2.3.3.20.1 Summary of Technical Information in the Application

LRA Section 2.3.3.20 describes the emergency diesel generator (EDG) system, which consists

of one diesel generator per safety-related load group complete with its accessories and fuel

storage and transfer systems and which generates onsite electric power to feed the standby

power system. The standby power system provides alternating current power for safe shutdown

of the plant in loss of offsite power. There are two EDGs per unit, each connected exclusively to

a single 4.16kV safety feature bus of a load group. Each unit has two 4.16kV Class 1E trains,

and the safety-related equipment on both trains is similar. The trains are redundant and for each

unit one train is adequate to satisfy minimum ESF demand caused by a LOCA and a

simultaneous loss of preferred power supply. The fuel oil storage for each unit is sized for seven

days of operation to meet the ESF load plus an additional amount for periodic testing of the

diesel generator. The EDG support systems provide stored energy to start the EDGs along with

cooling, lubrication, and combustion air intake and exhaust to allow the EDGs to perform their

function. The NSCW system supplies cooling water to the EDG jacket water coolers.

The EDG system contains safety-related components relied upon to remain functional during

and following DBEs. The failure of nonsafety-related SCs in the EDG system potentially could

prevent the satisfactory accomplishment of a safety-related function. In addition, the EDG

system performs functions that support fire protection and SBO.

LRA Table 2.3.3.20 identifies EDG system component types within the scope of license renewal

and subject to an AMR:

* air receivers

* closure bolting

* collection troughs (EDG lube oil leakage)

* eductors - EDG fuel oil ejector assembly

* electric heater housings

* filter housings

* flame arrester elements

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* flame arrester housings

* flexible connectors

* flow orifice/elements

* heat exchangers - EDG jacket water HXs (channel heads)

* heat exchangers - EDG jacket water HXs (shells)

• heat exchangers - EDG jacket water HXs (tubes)

* heat exchangers - EDG jacket water HXs (tubesheets)

* heat exchangers - EDG lube oil HXs (channel heads)

* heat exchangers - EDG lube oil HXs (shells)

* heat exchangers - EDG lube oil HXs (tubes)

* heat exchangers - EDG lube oil HXs (tubesheets)

* oil reservoirs - EDG lube oil sumps

* piping components

* pump casings - EDG fuel oil engine-driven pumps

* pump casings - EDG fuel oil storage tank pumps

* pump casings - EDG jacket water chemical addition pumps

* pump casings - EDG jacket water keep-warm pumps

* pump casings - EDG jacket water pumps

* pump casings - EDG lube oil keep-warm pumps

* pump casings - EDG lube oil pumps

* silencers

* strainer elements

* strainer housings

* tanks - EDG fuel oil day tanks

* tanks - EDG fuel oil line leakage tanks

* tanks - EDG fuel oil storage tanks

* tanks - EDG jacket water chemical addition tanks

* valve bodies

* vent screens - tank vents

The intended functions of the EDG system component types within the scope of license renewal

include:

* protection from debris

* heat exchange between fluid media

* prevention of flame propagation from ignition of vent pipe vapors back to the

source

* restriction of process flow

* pressure-retaining boundary

2.3.3.20.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.20 and UFSAR Sections 8.3.1.1.3, 9.5.4 through

9.5.8 using the evaluation methodology described in SER Section 2.3 and the guidance in SRPLR Section 2.3.

During its review, the staff evaluated the system functions described in the LRA and UFSAR to

verify that tlie applicant has not omitted from the scope of license renewal any components with

intended functions delineated under 10 CFR 54.4(a). The staff then reviewed those components

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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).

The staff's review of LRA Section 2.3.3.20 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 2.3.3.20-1, dated January 28, 2008, the staff noted that drawings 1X4LD170-1,

lX4LD170-2, 2X4LD170-1, and 2X4LD170-2 (G-7) indicate jacket water standpipes that are

within the scope of license renewal based on criterion 10 CFR 54.4(a)(1). The applicant was

requested to provide additional information explaining why the standpipes are not listed in LRA

Table 2.3.3.20 as a component type subject to an AMR.

In its response, dated February 27, 2008, the applicant stated:

The Emergency Diesel Generator System jacket water system standpipe is not

listed in LRA Table 2.3.3.20 as a separate component type subject to an AMR.

However, the standpipes are included in the component type, "Piping

Components" as shown in Table 2.3.3.20 Item No. 20 and Table 3.3.2-20 Items

20c, 20d and 20k. The standpipes are vertical, cylindrical piping components

constructed of carbon steel; therefore, they have been classified in the LRA as

piping components.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.20-1 acceptable

because the applicant provided clarification that the standpipes are included as Item No. 20

"Piping Components" in the AMR tables. Therefore, the staff's concern described in RAI

2.3.3.20-1 is resolved.

In RAI 2.3.3.20-2, dated January 28, 2008, the staff noted that drawings 1X4LD170-1,

IX4LD170-2, 2X4LD170-1, and 2X4LD170-2 (E-6) and as described in the UFSAR Section

9.5.8.2.3 indicate that the housings for the turbocharger and aftercooler form a pressure

boundary for intake air going to the engine intake manifolds and should be in scope for license

renewal based on criterion 10 CFR 54.4(a)(1). The applicant was requested to provide

additional information explaining why the turbocharger/aftercooler housings with their pressure

boundary and heat exchange functions are not listed in LRA Table 2.3.3.20 for components

subject to an AMR.

In its response, dated February 27, 2008, the applicant stated:

The turbocharger and after-cooler are skid mounted equipment of the Emergency

Diesel Generators assembly and thus considered part of this complex assembly -

emergency diesel generator engine. Therefore, no AMR of the housing for these

components is required due to the complex active assembly classification of this

assembly, i.e., this component/assembly does not meet the AMR criteria for an

integrated plant assessment per 10 CFR 54.21 (a)(1)(i). Consequently, the

turbocharger/aftercooler housings with their pressure boundary and heat

exchange functions are not listed in LRA Table 2.3.3.20 for components subject

to an AMR.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.20-2 acceptable

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because the applicant stated that the turbocharger/aftercooler housings are skid mounted

equipment of the complex assembly - emergency diesel generator, and do not meet the AMR

criteria for an integrated plant assessment per 10 CFR 54.21 (a)(1)(i). Therefore the staff's

concern described in RAI 2.3.3.20-2 is resolved.

In RAI 2.3.3.20-3, dated January 28, 2008, the staff noted that drawings 1X4LD170-1,

1X4LD170-2, 2X4LD170-1, and 2X4LD170-2 (E-3) and (B-3) indicate that manhole covers

which provide a pressure boundary for the diesel fuel oil day and storage tanks are within the

scope of license renewal based on criterion 10 CFR 54.4(a)(1). The applicant was requested to

provide additional information explaining why the manhole covers are not listed in LRA Table

2.3.3.20 for components subject to an AMR.

In its response, dated February 27, 2008, the applicant stated:

Tank manways were not identified as a separate component type for tanks in

mechanical systems. The manways for the diesel fuel oil day and fuel oil storage

tanks were included as part of the tank. In the LRA Table 2.3.3.20, the manway

covers for the diesel fuel oil day and storage tanks are covered under Item 31

and 33 respectively.

In the LRA Table 3.3.2-20, the AMR of the diesel fuel oil day tank manways are

covered by Items 31a and 31c.

The AMR of the diesel fuel oil storage tank manways and covers are covered by

Items 33a and 33c of this table as well.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.20-3 acceptable,

because the applicant provided clarification that the manway covers for the diesel fuel oil day

and storage tanks are considered an integral part of the tank components listed in the AMR

tables. Therefore, the staffs concern described in RAI 2.3.3.20-3 is resolved.

In RAI 2.3.3.20-4, dated January 28, 2008, the staff noted that drawings 1X4LD170-1,

1X4LD170-2, 2X4LD170-1, and 2X4LD170-2 locations (H-7), (C-8), (D-2), (C-2), and (E-3)

indicate tank vents that are within the scope of license renewal. LRA Table 2.3.3.20 lists tank

vent screens as components that provide debris protection for a vent, but none of the vents

show a debris screen. The applicant was requested to provide additional information explaining

which tank vents on the drawings do or do not have the tank vent screen component that is

listed as Item 36 in LRA Table 2.3.3.20.

In its response, dated February 27, 2008, the applicant stated:

Vent screens that cover tank vents for debris/ bird protection on the various

EDG System atmospheric vents to outdoors have been put in scope. Since

no equipment tag numbers apply and no material documentation could be

found, the vent screens are assumed to be carbon steel based on the piping

material. Piping and instrument diagrams used to develop the referenced

LRA boundaries did not show screens for tank vents; although, area physical

drawings do identify screen covers for the diesel fuel oil storage tank vents;

no screen covers were identified for the diesel fuel oil day tank vents. Since

the vents for both tanks provide the same function, it was assumed that

screen covers were installed on the diesel fuel day tank vents as well.

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By telecom dated April 17, 2008, the applicant was advised that the staff will proceed based on

having the screens in place. The applicant acknowledged staffs position and stated that they

are planning to inspect the plant in the near future to verify screen installation and screen

materials.

In a letter dated February 16, 2009, the applicant provided a revision to the LRA concerning

diesel generator day tank vent line inspections. The new commitment, number 42, provides for

an inspection to verify screen installation prior to the period of extended operation.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.20-4 acceptable,

because the applicant stated the screens are in scope and committed to verify screen materials

and vents with screens. Therefore, the staffs concern described in RAI 2.3.3.20-4 is resolved.

In RAI 2.3.3.20-5, dated January 28, 2008, the staff noted that drawings 1X4LD170-1,

1X4LD170-2, and 2X4LD170-1 (D-4) indicate that the concrete vault roof has a vent that is

within the scope of license renewal based on criterion 10 CFR 54.4(a)(1). Those drawings cover

the diesel generator trains A and B for plant Unit #1 and train A for plant Unit #2. However,

drawing 2X4LD170-2 for train B of plant Unit #2 does not show a vent for the concrete vault

roof. The applicant was requested to provide additional information explaining why the concrete

vault roof vent is missing on drawing 2X4LD170-2 for diesel generator plant Unit #2 Train B.

In its response, dated February 27, 2008, the applicant stated:

It has been determined from review of domestic supporting drawings that the

concrete vault roof vent missing on drawing 2X4LD170-2 is an error and the

vent should be shown as on 2X4LD170-1.

The diesel fuel oil storage tank pump house forming plans sections and

details show the roof vents for both trains of both units.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.20-5 acceptable,

because the applicant provided clarification that the concrete vault roof vent was missing from

drawing 2X4LD170-2 in error and should be shown and in scope for license renewal. Therefore,

the staffs concern described in RAI 2.3.3.20-5 is resolved.

In RAI 2.3.3.20-6, dated January 28, 2008, the staff noted that drawing 2X4LD170-2 (F/G-6)

indicates the 343-3/4" pipeline and associated drain are within the scope of license renewal

based on criterion 10 CFR 54.4(a)(1). However, drawings 1X4LD170-1, 1X4LD170-2, and

2X4LD170-1 for the same location indicates that the similar 343-3/4" and 339-3/4" pipelines are

within the scope of license renewal based on criterion 10 CFR 54.4(a)(2), rather than

10 CFR 54.4(a)(1), and the drain is not within the scope of license renewal. The applicant was

requested to provide additional information to define the correct criterion to use for all four of

these drawings for the 343-3/4" and 339-3/4" drain pipelines and their respective drains.

In its response, dated February 27, 2008, the applicant stated:

License renewal drawing 2X4LD170-2 (FIG-6) inadvertently shows the 343-

3/4" pipeline and associated drain within the scope of license renewal based

on criterion 10 CFR 54.4(a)(1). This pipeline 343-3/4" is within the scope of

license renewal based on criterion 10 CFR 54.4(a)(2), rather than

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10 CFR 54.4(a)(1) which is the same in scope bases as pipeline 339-3/4"

shown on 2X4LD170-2 (F/G-6). These lines function as drain piping from the

diesel generator spill collection trough and are classified as non-safety

related.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.20-6 acceptable

because the applicant provided clarification that the 343-3/4" pipeline on drawing 2X4LD170-2

(FIG-6) should have been shown in scope for criterion 10 CFR 54.4(a)(2), rather than criterion

10 CFR 54.4(a)(1). Therefore, the staff's concern described in RAI 2.3.3.20-6 is resolved.

In RAI 2.3.3.20-7, dated January 28, 2008, the staff noted that drawing 2X4LD170-1 (C/D-8),

indicates a lube oil press fill pipeline located outside the engine piping boundary and connected

to a three-inch pipeline within the engine piping boundary that is entirely within the scope of

license renewal based on criterion 10 CFR 54.4(a)(1). However, drawings 1X4LD170-1,

1X4LD170-2, and 2X4LD170-2, for the same general location and pipeline characteristics,

indicate the lube oil press fill piping is not within the scope of license renewal. The applicant was

requested to provide additional information to define the correct criterion to be applied to the

lube oil press fill pipeline outside the engine piping boundary on all four drawings referenced

above.

In its response, dated February 27, 2008, the applicant stated:

Per review of the License Renewal drawing 2X4LD170-1 at (C/D-8) regarding

scoping of the lube oil press fill pipeline, the boundary line for this pipeline

should have been shown as red not gray for drawings 1X4LD170 -1 & 2 and

2X4LD170-2. The lube oil press fill piping is within the scope of license

renewal based on criterion 10 CFR 54.4(a)(1).

Based on its review, the staff finds the applicant's response to RAI 2.3.3.20-7 acceptable

because the applicant provided clarification that the lube oil press fill pipelines on drawings

1X4LD170 -1 &2 and 2X4LD170-2 are in scope for criterion 10 CFR 54.4(a)(1). Therefore, the

staffs concern described in RAI 2.3.3.20-7 is resolved.

In RAI 2.3.3.20-8, dated January 28, 2008, the staff noted that drawing 2X4LD170-1 (E-8)

shows sections of 037-10" and 035-10" piping within the scope of license renewal based on

criterion 10 CFR 54.4(a)(2) with a continuation to drawing 2X4LD135-1 (G-6). The continuation

location G-6 on drawing 2X4LD135-1 indicates the 037-10" and 035-10" piping are within the

scope of license renewal based on criterion 10 CFR 54.4(a)(1). It appears that the sections of

037-10" and 035-10" piping shown on drawing 2X4LD170-1 between the engine piping

boundary and the continuation marker to drawing 2X4LD135-1 should also be in-scope based

on criterion 10 CFR 54.4(a)(1) as are the other emergency diesel generators shown in LR

drawings 2X4LD170-2, lX4LD170-1, and 1X4LD170-2. The applicant was requested to provide

additional information clarifying why the subject piping on drawing 2X4LD170-1 (E-8) meets the

requirements of criterion 10 CFR 54.4(a)(2), rather than 10 CFR 54.4(a)(1).

In its response, dated February 27, 2008, the applicant stated:

From a review of the drawings 2X4LD170-1 and 2X4LD135-1 and a re-visit

of the 10 CFR 54.4(a)(1) criterion against the function of the pipelines, 037-

10" and 035-10", it is concluded that the sections of piping shown on drawing

2X4LD170-1 between the engine piping boundary and the continuation

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marker to drawing 2X4LD1 35-1 are in-scope based on criterion

10 CFR 54.4(a)(1), and should have been indicated as the other pipelines are

for this function shown on LR drawings 2X4LD170-2, 1X4LD170-1, and

1X4LD170-2.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.20-8 acceptable

because the applicant provided clarification that on drawing 2X4LD170-1 the sections of 037-

10" and 035-10" pipelines between the engine piping boundary and the continuation marker to

drawing 2X4LD135-1 should have been in scope for criterion 10 CFR 54.4(a)(1). Therefore, the

staffs concern described in RAI 2.3.3.20-8 is resolved.

2.3.3.20.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

applicant failed to identify any components within the scope of license renewal. The staff finds

no such omissions. In addition, the staffs 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 the applicant has adequately identified the emergency diesel

generator system 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).

2.3.3.21 Demineralized Water System

2.3.3.21.1 Summary of Technical Information in the Application

LRA Section 2.3.3.21 describes the demineralized water (DW) system, which stores and

delivers deionized water to various plant systems. Demineralized water is not required for any

safety-related function.

The DW system contains safety-related components relied upon to remain functional during and

following DBEs. The failure of nonsafety-related SCs in the DW system potentially could prevent

the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3.21 identifies DW system component types within the scope of license renewal

and subject to an AMR:

* closure bolting

* flow orifice/elements

* piping components

* piping components - pipe spools for startup strainers

* pump casings - demineralized water transfer booster pumps

* valve bodies

The intended function of the DW system component types within the scope of license renewal is

to provide a pressure-retaining boundary.

2.3.3.21.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.21 and UFSAR Section 9.2.3 using the evaluation

methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

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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 delineated under 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).

The staff's review of LRA Section 2.3.3.21 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In RAI 2.3.3.21-1, dated January 28, 2008, the staff noted drawing AX4LD190-2 (E-3) shows

pipe section 172-1" in-scope for 10 CFR 54.4(a)(2). The continuation to AX4LD123-2 (A-6) is

not shown as in-scope for license renewal. The applicant was asked to provide additional

information detailing the license renewal boundary for pipe section 172-1" on drawing

AX4LD123-2 (A-6).

In its response, dated February 27, 2008, the applicant stated:

The segment of line A-1210-172-1" which appears on mechanical boundary

drawing AX4LD123-2 was inadvertently not shown as being in scope for

10 CFR 54.4(a)(2). This line segment is in scope for 10 CFR 54.4(a)(2).

Based on its review, the staff finds the applicant's response to RAI 2.3.3.21-1 acceptable

because the applicant explained that the piping in question is within the scope of license

renewal. Therefore, the staff's concern described in RAI 2.3.3.21-1 is resolved.

2.3.3.21.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

applicant failed to identify any components 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 the applicant has adequately identified the DW water system

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).

2.3.3.22 Hydrogen Recombiner and Monitoring System

2.3.3.22.1 Summary of Technical Information in the Application

LRA Section 2.3.3.22 describes the hydrogen recombiner and monitoring system, which was

installed to monitor and control post-accident containment hydrogen. The applicant intends to

downgrade the recombiners to nonsafety-related and to abandon them in place. The hydrogen

monitors also will be downgraded to nonsafety-related; however, piping for these monitors

penetrating containment has a containment integrity safety function. Until these CLB changes

are processed, these components are within the scope of license renewal as safety-related.

The hydrogen recombiner and monitoring system contains safety-related components relied

upon to remain functional during and following DBEs. In addition, the hydrogen recombiner and

monitoring system performs functions that support EQ.

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LRA Table 2.3.3.22 identifies hydrogen recombiner and monitoring system component types

within the scope of license renewal and subject to an AMR:

* closure bolting

* hydrogen recombiner (containment) housings

* piping components

* valve bodies

The intended functions of the hydrogen recombiner and monitoring system component

types within the scope of license renewal include:

* spray shield or curbs for flow direction

* pressure-retaining boundary

2.3.3.22.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.22 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.

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 delineated under 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).

2.3.3.22.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 hydrogen recombiner and monitoring

system 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).

2.3.3.23 Drain Systems

2.3.3.23.1 Summary of Technical Information in the Application

LRA Section 2.3.3.23 describes the drain systems, which consist of collection piping, valves,

equipment drains, floor drains, vents, seals, cleanouts, oil and sediment interceptors, acid

neutralization tanks, collection sumps, sump pumps, and collection tanks with discharge pumps,

piping, and valves.

The drains within the scope of license renewal include the following systems:

* containment and auxiliary building drain system - radioactive

* auxiliary building drain system - nonradioactive

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* auxiliary building flood-retaining rooms, alarms, and drains

• control building drain system

* fuel-handling building drains

* sanitary waste and vent

* turbine building drain system

The containment and auxiliary building drain system - radioactive is designed to drain water in

the containment building and tritiated water in the other buildings. Water drained into the system

enters the plant liquid waste processing system for recycling or disposal.

The auxiliary building drain system - nonradioactive drains normally nonradioactive equipment

and floor liquid waste from open areas of the auxiliary building to the floor drain tank via the

auxiliary building sump or the penetration room sump. This system also includes miscellaneous

drains that convey fluids to other sumps and empty or drain the sumps.

The auxiliary building flood-retaining rooms, alarms, and drain system prevents drain or flood

water from backing up into selected important auxiliary building rooms. The system retains postLOCA radioactive liquid leakage within the water-tight flood-retaining rooms up to the maximum

expected flood level by water-tight doors evaluated as parts of component supports and bulk

commodities (LRA Section 2.4.12).

The control building drain system collects water from fire protection sprinklers in the control

building, equipment building, technical support center, and connected electrical tunnels as well

as from incidental leaks. The system routes water to a sump below the control building. Sump

pumps transfer the water to the turbine building oil separator. The system also provides an

alternate route to the waste monitor tank in the auxiliary building for processing radioactive

liquid.

The fuel-handling building drainage system collects water in the fuel-handling building drain

sump from drains within the building. Fuel-handling building drain sump pumps transfer water

from the building's drain sump to the waste monitor tank for processing or disposal.

The sanitary waste and vent system provides plumbing drains and vents for toilets, locker

rooms, showers, and janitor rooms in the control and turbine buildings.

The turbine building drain system removes all liquid wastes from the turbine building for

disposal to the waste water effluent system. This system also monitors and, if necessary,

removes radioactive contaminants from these wastes if radioactive material appears in the

drains from a tube leak in one of the steam generators. Filters and demineralizers that remove

radioactive contaminants from wastes processed by this system are located in the auxiliary

building.

The drain systems contain safety-related components relied upon to remain functional during

and following DBEs. The failure of nonsafety-related SCs in the drain systems potentially could

prevent the satisfactory accomplishment of a safety-related function. In addition, the drain

systems perform functions that support EQ.

LRA Table 2.3.3.23 identifies drain systems component types within the scope of license

renewal and subject to an AMR:

• closure bolting

* drain bodies

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* floor drain plugs

* piping components

* pump casings - CCW drain tank pumps

* tanks - acid neutralizing sumps

* valve bodies

The intended function of the drain systems component types within the scope of license renewal

is to provide a pressure-retaining boundary.

2.3.3.23.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.23 and UFSAR Sections 9.3.3 and 11.2 using the

evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review of the sanitary waste and vent and the turbine building drain systems, 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 component types with intended functions

delineated under 10 CFR 54.4(a).

During its review of the remaining drain systems, 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 delineated under 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).

The staff's review of LRA Section 2.3.3.23 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. In addition to

the RAI 2.3.3.23-1 related to drawing continuation errors discussed in Section 2.3.3, the

applicant responded to the staff's RAIs as discussed below.

In RAI 2.3.3.23-2, dated January 28, 2008, the staff noted that drawings 1X4LD145-6 and

2X4LD145-6 (B-2) show pipe 256-4" as not within the scope of license renewal. Drawings

1X4LD145-5 and 2X4LD145-5 (D-4) show pipe 256-4" within the scope of license renewal

based on criterion 10 CFR 54.4(a)(2). The applicant was requested to provide additional

information clarifying why pipe 256-4" on drawings 1X4LD145-6 and 2X4LD145-6 (B-2) is not

within the scope of license renewal.

In its response, dated February 27, 2008, the applicant stated:

Line 1215-256-4" as shown on drawings 1X4LD145-6 and 2X4LD145-6 is in

scope for 10 CFR 54.4(a)(2). Drawings 1X4LD145-6 and 2X4LD145-6 should

have shown this line highlighted as in scope for 10 CFR 54.4(a)(2).

Based on its review, the staff finds the applicant's response to RAI 2.3.3.23-2 acceptable

because the applicant provided clarification that line 1215-256-4" on drawings 1X4LD145-6 and

2X4LD145-6 should have been shown highlighted as in scope for 10 CFR 54.4(a)(2). Therefore,

the staff's concern described in RAI 2.3.3.23-2 is resolved.

In RAI 2.3.3.23-3, dated January 28, 2008, the staff noted that drawings 1X4LD179-2 and

2X4LD179-2 (D-7) show pipeline 097-2" within the scope of license renewal based on criterion

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10 CFR 54.4(a)(2) continuing to drawings 1X4LD124-2 (F-4) and 2X4LD124-2 (G-4). Drawings

1X4LD124-2 and 2X4LD124-2 could not be located in the boundary drawing package. The

applicant was requested to provide additional information to verify that the continuation from

drawings 1X4LD179-2 and 2X4LD179-2 has been made to the correct drawings and locations

and provide the drawings.

In its response, dated February 27, 2008, the applicant stated:

Line 1407-097-2" on drawings 1X4LD179-2 and 2X4LD179-2 continues to

P&ID AX4DB124-2. P&ID AX4DB124-2 shows the point where this line exits

the Auxiliary Building into the Radwaste Transfer Tunnel. There are no safety

related components in the Radwaste Transfer Tunnel, so potential spatial

interactions are not a concern and the in-scope portion of the line ends at the

Auxiliary Building to Radwaste Transfer Tunnel boundary. However, P&ID

AX4DB124-2 was not redrawn into a license renewal mechanical boundary

drawing. To resolve this discrepancy, mechanical boundary drawings

1X4LD179-2 and 2X4LD179-2 should have been revised to include the

Auxiliary Building to Radwaste Transfer Tunnel boundary for clarity.

By telecom dated April 17, 2008, the applicant verified that there were no new component types

within the boundary for which the drawings were not provided.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.23-3 acceptable

because the applicant provided clarification that the license renewal boundary ends at the

Auxiliary Building to Radwaste Transfer Tunnel boundary and stated that there were no new

component types within the boundary for which drawings were not provided. Therefore, the

staff's concern described in RAI 2.3.3.23-3 is resolved.

2.3.3.23.3 Conclusion

For the sanitary waste and vent and the turbine building drain systems, the staff reviewed the

LRA and the UFSAR to determine whether the applicant failed to identify any component types

that are typically found within the scope of license renewal and finds no such omissions. On the

basis of its review, the staff concludes that the applicant has adequately identified the sanitary

waste and vent and the turbine building drain systems component types within the scope of

license renewal, as required by 10 CFR 54.4(a).

For the remaining drain systems, the staff reviewed the LRA, UFSAR, RAI responses, and

drawings to determine whether the applicant failed to identify any components within the scope

of license renewal. The staff finds no such omissions. In addition, the staffs 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 the applicant has adequately

identified the

* containment and auxiliary building drain system - radioactive,

* auxiliary building drain system - nonradioactive,

* auxiliary building flood-retaining rooms, alarms, and drains,

* control building drain system, and

* fuel-handling building drains

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as 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).

2.3.3.24 Potable and Utility Water Systems

2.3.3.24.1 Summary of Technical Information in the Application

LRA Section 2.3.3.24 describes the potable and utility water systems. The potable water system

chemically treats, stores, and distributes well water for drinking to the units. The utility water

system provides water for general washdown purposes at utility stations throughout the plant

(nonradioactive process areas). Utility water also serves for sump pump bearing lubrication and

miscellaneous cooling purposes (e.g., cooling of the steam generator blowdown samples). The

failure of nonsafety-related SCs in the potable and utility water systems could potentially prevent

the satisfactory accomplishment of a safety-related function.

LRA Table 2.3.3.24 identifies potable and utility water systems component types within the

scope of license renewal and subject to an AMR:

* arresters (water hammer)

• closure bolting

* piping components

* pump casings - hot water recirculation pumps

* strainer housings

* valve bodies

* water heater housings and jackets

The intended functions of the potable and utility water systems component types within the

scope of license renewal include:

* spray shield or curbs for flow direction

* pressure-retaining boundary

2.3.3.24.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.24 and UFSAR Section 9.2.4 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 component types

with intended functions delineated under 10 CFR 54.4(a).

2.3.3.24.3 Conclusion

The staff reviewed the LRA and the UFSAR to determine whether the applicant failed to identify

any component types that are typically found within the scope of license renewal and finds no

such omissions. On the basis of its review, the staff concludes that the applicant has adequately

identified the potable and utility water systems component types within the scope of license

renewal, as required by 10 CFR 54.4(a).

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2.3.3.25 Radiation Monitoring System (1609)

2.3.3.25.1 Summary of Technical Information in the Application

LRA Section 2.3.3.25 describes the radiation monitoring system, which monitors radiation levels

in the process flow streams of plant fluid systems, measures direct gamma radiation, and

provides corresponding indications, recordings, alarms, and controls. For normally radioactive

fluid systems with direct or diluted discharge paths to the surrounding environment, the radiation

monitoring system actuation functions limit further discharge if activity concentrations exceed

preset levels. The system also provides information for detecting and monitoring RCS leakage.

Radiation monitors fall into five functional classifications:

process monitors, which determine concentrations of radioactive material in plant

fluid systems. The primary-to-secondary leak detection monitors (N16 and noble

gas leak rate detectors) are included in this category.

effluent monitors, which measure radioactivity discharged to the environs

airborne monitors, which provide operator information on airborne concentrations

of radioactive gases and particulate radioactivity at various points in the

ventilation ducts

area monitors, which provide operator information on external gamma radiation

levels at fixed points throughout the plant

post-accident (or high-range) monitors designed to assess and follow potential

pathways for release of radioactive materials during accident conditions

The radiation monitors themselves are instrumentation components and therefore are

addressed in the scoping and screening for the electrical and instrumentation and controls

systems (LRA Section 2.5). Mechanical aspects (e.g.; process line components) are addressed

in the mechanical scoping and screening.

The radiation monitoring system contains safety-related components relied upon to remain

functional during and following DBEs. The failure of nonsafety-related SCs inthe radiation

monitoring system potentially could prevent the satisfactory accomplishment of a safety-related

function. In addition, the radiation monitoring system performs functions that support EQ.

LRA Table 2.3.3.25 identifies radiation monitoring system component types within the scope of

license renewal and subject to an AMR:

* closure bolting

* piping components

* valve bodies

The intended function of the radiation monitoring system component types within the scope of

license renewal is to provide a pressure-retaining boundary.

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2.3.3.25.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.25 and UFSAR Sections 11.5 and 12.3.4 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 delineated under 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).

The staff's review of LRA Section 2.3.3.25 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 2.3.3.25-1, dated January 28, 2008, the staff noted that drawings 1X4LD133-1,

1X4LD133-2, 2X4LD133-1, and 2X4LD133-2 (H-3), and drawings 1X4LD136 and 2X4LD136 (A3) and (E-3) show radiation monitors that are identified as in scope for license renewal based on

criterion 10 CFR 54.4(a)(2). Each radiation monitor is connected to 1 inch sensing lines

identified as within the scope of license renewal based on criterion 10 CFR 54.4(a)(1). Also, the

staff noted that for similar equipment on drawings 1X4LD213-2 and 2X4LD213-2 (D-1) radiation

monitors are within the scope of license renewal based on criterion 10 CFR 54.4(a)(2) but have

equivalent anchors on each end. The applicant was requested to provide additional information

explaining why the radiation monitors on drawings 1X4LD133-1, 1X4LD133-2, 1X4LD136,

2X4LD133-1, 2X4LD136, and 2X4LD133-2 are not within the scope of license renewal based on

criterion 10 CFR 54.4(a)(1) as are the connecting pipe sections.

In its response, dated February 27, 2008, the applicant stated:

The radiation monitors on mechanical boundary drawings 1X4LD133-1,

1X4LD133-2, 1X4LD136, 2X4LD133-1, 2X4LD136, 2X4LD133-2, 1X4LD213-

2 and 2X4LD213-2 are not in scope for 10 CFR 54.4(a)(1) scoping criteria

because they do not ensure the integrity of the reactor coolant pressure

boundary; ensure the capability to shut down the reactor and maintain it in a

safe shutdown condition; or ensure the capability to prevent or mitigate the

consequences of accidents that could result in potential offsite exposure

comparable to the guidelines in 10 CFR 50.34(a)(1), 10 CFR 50.67(b)(2), or

10 CFR 100.11, as applicable.

The safety classifications of both the radiation monitors and the connecting

pipe sections are established in the current licensing basis in accordance

with regulatory guidance. Refer to LRA section 2.1, Scoping and Screening

Methodology, for additional discussion.

Also note that the radiation monitors on mechanical boundary drawings

1X4LD213-2 and 2X4LD213-2 do not have equivalent anchors on each end.

Boundary endpoint clarification note #4 indicates that the radiation monitors

are the equivalent anchors. However, given that there are no piping

endpoints at the radiation monitors, it would be more appropriate to describe

these radiation monitor packages as non-safety related piping that is

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connected at both ends to safety related piping. Boundary endpoint

clarification note # 4 on mechanical boundary drawings 1X4LD213-2 and

2X4LD213-2 is unnecessary and should not have been included.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.25-1 acceptable

because the in scope classification of the radiation monitor and sensing lines are consistent with

the plant licensing bases. 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, RAI response, and drawings to determine whether the

applicant failed to identify any components within the scope of license renewal. The staff finds

no such omissions. In addition, the staffs 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 the applicant has adequately identified the radiation monitoring

system 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).

2.3.3.26 Reactor Makeup Water Storage System

2.3.3.26.1 Summary of Technical Information in the Application

LRA Section 2.3.3.26 describes the reactor makeup water storage system (RMW), which

supplies recycled and deaerated demineralized water to safety-related surge tanks. This system

also supplies water to the boric acid mixing tee for daily use as an RCS diluent and to various

gas strippers, pumps, tanks, and pipelines for cleaning and flushing operations. It is an assured

seismic Category I make-up source to the spent fuel pool and an assured backup seismic

Category I makeup source to the CCW and ACCW surge tanks. The reactor makeup water

storage tank degasifier recirculates and degasifies the demineralized water to reduce the

oxygen content to primary plant usage specifications.

The reactor makeup water storage tanks are constructed of concrete with a stainless steel liner.

The tank liner is evaluated in this section as a mechanical component. The concrete shell, roof,

and base slab are evaluated in the structural scoping for the concrete tank and valve house

structures (LRA Section 2.4.7). The reactor makeup water storage tanks have floating

diaphragms which minimize oxygen absorption.

The reactor makeup water storage system contains safety-related components relied upon to

remain functional during and following DBEs. The failure of nonsafety-related SCs in the reactor

makeup water storage system potentially could prevent the satisfactory accomplishment of a

safety-related function.

LRA Table 2.3.3.26 identifies reactor makeup water storage system component types within the

scope of license renewal and subject to an AMR. The intended functions of the reactor makeup

water storage system component types within the scope of license renewal include:

* restriction of process flow

" physical integrity maintenance to prevent generation of debris or loose parts

which could interfere with a safety-related function

" pressure-retaining boundary

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2.3.3.26.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.26 and UFSAR Section 9.2.7 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 delineated under 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).

The staff's review of LRA Section 2.3.3.26 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. In addition to

RAI 2.3.3.26-1 related to drawing continuation errors described in Section 2.3.3, the applicant

responded to the staffs RAIs as discussed below.

In RAI 2.3.3.26-2, dated January 28, 2008, the staff noted drawing 1X4LD184 (C-8) shows a

drawing continuation of 163-1" piping, within the scope of license renewal based on criterion

10 CFR 54.4(a)(2), to drawing 1X4LD129 (G-6). Part of the 163-1" piping on 1X4LD129 (G-6) to

In-Scope Boundary Endpoint Clarification Symbol Al 1 is shown as not in scope for license

renewal. The applicant was asked to provide additional information justifying the boundary

locations.

In its response, dated February 27, 2008, the applicant stated:

Mechanical boundary drawing 1X4LD129 shows that the in scope portion of line

1228-163-1" ends at an anchor, and refers to endpoint clarification Note #11.

Note #11 indicates that the pipe is in scope for attached pipe considerations up

to the identified anchor. Note #11 also states that the spatial interaction boundary

extends beyond the identified anchor. No endpoint should have been shown at

this location. Where spatial interaction concerns bound the attached anchor

endpoint, the line should have been shown as in scope all the way to the spatial

interaction endpoint.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.26-2 acceptable

because the applicant explained that the entire piping between the anchor Al 1 and the spatial

interaction endpoint is in scope for license renewal.

Therefore, the staffs concern described in RAI 2.3.3.26-2 is resolved.

In RAI 2.3.3.26-3, dated January 28, 2008, the staff noted drawing 1X4LD129 (H-2) shows pipe

section 172-1" splits and connects to a 172-3/4" line and a 172-1" line. The drawing also shows

that part of the 172-1" line before the split, as well as the 172-3/4" line, as nonsafety-related and

within the scope of license renewal for spatial effects. Yet no portion of the continuing 172-1"

line that is connected to the catalytic hydrogen re-combiner is within the scope of license

renewal. The applicant was asked to provide additional information to clarify why this line is not

included in the scope of license renewal as per requirements of 10 CFR 54.4(a)(2).

In its response, dated February 27, 2008, the applicant stated:

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On mechanical boundary drawing 1X4LD129 the Reactor Makeup Water

(RMW) System piping was put in scope up to the boundaries of that system.

After additional review of this drawing, the RMW System boundaries do not

clearly coincide with 10 CFR 54.4(a)(2) endpoints as defined in NEI 95-10,

Appendix F. The mechanical boundary drawings 1X4LD129 and 2X4LD129

should have shown the RMW System piping to the catalytic hydrogen

recombiners as in scope for 10 CFR 54.4(a)(2) up to the connections to the

recombiners. The catalytic hydrogen recombiners are already in scope for

10 CFR 54.4(a)(2) as equivalent anchors.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.26-3 acceptable

because the applicant explained that the mechanical boundary drawings 1X4LD129 and

2X4LD129 should have shown the RMW System piping to the catalytic hydrogen recombiners

as in scope for 10 CFR 54.4(a)(2) up to the connections to the recombiners. Therefore, the

staff's concern described in RAI 2.3.3.26-3 is resolved.

2.3.3.26.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

applicant failed to identify any components within the scope of license renewal. The staff finds

no such omissions. In addition, the staffs 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 the applicant has adequately identified the reactor makeup water

storage system components within the scope of license renewal, as required ýýby

10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21 (a)(1).

2.3.3.27 Sampling Systems

2.3.3.27.1 Summary of Technical Information in the LRA

LRA Section 2.3.3.27 describes the sampling systems, which consists of the following:

* nuclear sampling system - liquids

* nuclear sampling system - gaseous

* turbine plant sampling system

• post-accident sampling system

The nuclear sampling system - liquids supplies representative process liquidi samples to the for

laboratory analysis to guide operation of the RCS, the RHR system, safety injection system,

waste processing system, and CVCS. The nuclear sampling system - liquids is for manual

operation and has no emergency function; however, certain valves in the system have a

containment isolation function, and lines which penetrate containment are relied upon for

containment integrity.

The nuclear sampling system - gaseous supplies representative process stream gas samples

for laboratory analysis from the CVCS and gaseous waste and boron recycle! systems as

required to support plant operation. The nuclear sampling system - gaseous is for manual

operation only during periods of normal plant operation.

The turbine plant sampling system collects, cools, analyzes, controls, alarms, and records water

quality from various sampling points in the secondary plant systems. The system monitors water

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samples from the steam generator blowdown lines, the turbine cycle, and the circulating water

system to control water chemistry and permit appropriate corrective action.

The post-accident sampling system takes and returns post-accident containment atmosphere

samples via system piping and skid-mounted equipment. The original system design included

the capability, now eliminated, to obtain fluid samples from the RCS and the containment

sumps. Post-accident fluid samples from the RCS and the containment sumps can be obtained

by the nuclear sampling system - liquids. Certain system lines and valves are relied upon for

containment isolation and integrity.

The sampling systems contain safety-related components relied upon to remain functional

during and following DBEs. The failure of nonsafety-related SCs in the sampling systems

potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the sampling systems perform functions that support SBO and EQ.

LRA Table 2.3.3.27 identifies sampling systems component types within the scope of license

renewal and subject to an AMR:

* closure bolting

* corrosion product monitors (shells and heads)

* filter housings

0 flow orifice/elements

* piping components

* pump casings - SGBD sample pumps

0 rotameter housings

sample baths - steam generator blowdown bath (shells)

sample coolers - primary and secondary-side samples (shells and end plates)

strainer housings

valve bodies

The intended functions of the sampling systems component types within the scope of license

renewal include:

* restriction of process flow

* pressure-retaining boundary

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2.3.3.27.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.27 and UFSAR Section 9.3.2 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 delineated under 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).

The staff's review of LRA Section 2.3.3.27 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 2.3.3.27-1, dated January 28, 2008, the staff noted that drawing 2X4LD171-8 (E-5),

turbine plant sampling system, pipe section 139-1 1⁄2/2" downstream of valve 094 is shown as not

within the scope of license renewal for criterion 10 CFR 54.4(a)(2). While drawing IX4LD171-8

(E-5), Turbine Plant Sampling System, shows this piping within the scope of license renewal.

The applicant was asked to provide additional information to justify the omission of the

2X4LD171-8 pipe section 139-11⁄2" from the applicable requirements of 10 CFR 54.4(a)(2) and

provide the license renewal boundary for 139-11⁄2".

In its response, dated February 27, 2008, the applicant stated:

Line 1305-139-1 /" downstream of valve 094 on mechanical boundary drawing

2X4LD171-8 was inadvertently omitted from scope. This drawing should have

shown all of line 1305-139-11⁄2" in scope for 10 CFR 54.4(a)(2).

Based on its review, the staff finds the applicant's response to RAI 2.3.3.27-1 acceptable

because the applicant explained that the piping in question is within the scope of license

renewal. Therefore, the staffs concern described in RAI 2.3.3.27-1 is resolved.

In RAI 2.3.3.27-2, dated January 28, 2008, the staff noted that drawings 1X4LD171-8 and

2X4LD171-8 have 16 within the scope of license renewal to not within the scope of license

renewal transitions identified for 3/8" piping downstream of the steam generator main steam

sample coolers that meets the 10 CFR 54.4(a)(2) criterion. There is not enough information

provided to identify the transition location. The applicant was asked to provide additional

information to identify these LR boundaries and to justify the boundary locations with respect to

the applicable requirements of 10 CFR 54.4(a)(2) for the following locations on both drawings:

Location D-3, downstream of valve 008.

Location E-3, downstream of valve 007.

Location F-3, downstream of valve 006.

Location G-3, downstream of valve 005.

Location D-6, downstream of valve 010.

Location E-6, downstream of valve 011.

Location F-7, downstream of valve 012.

Location G-8, downstream of valve 009.

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In its response, dated February 27, 2008, the applicant stated:

The sample lines described above are shown as in scope for

10 CFR 54.4(a)(2) criteria up to the point where they exit from the Auxiliary

Building into Main Steam and Feedwater Tunnel 1T1 (2T1 on Unit 2). The

sample lines downstream of the sample coolers are only in scope for

potential spatial interaction effects. There are no safety related systems or

components in Tunnels 1T1 or 2T1, therefore the 10 CFR 54.4(a)(2) spatial

interaction criteria do not apply once the sample lines have exited the

Auxiliary Building. Refer to the answer to RAI 2.1-2 for non-safety related

components in the Turbine Building.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.27-2 acceptable

because the applicant explained why these sample lines are not in scope. Therefore, the staffs

concern described in RAI 2.3.3.27-2 is resolved.

In RAI 2.3.3.27-3, dated January 28, 2008, the staff noted that drawings 1X4LD110 and

2X4LD 110 (F-8), Post Accident Sampling System, show the piping associated with penetration

86C as not within the scope of license renewal based on criterion 10 CFR 54.4(a). The

applicant was asked to provide additional information to justify the omission of this piping from

the applicable requirements of 10 CFR 54.4(a).

In its response, dated February 27, 2008, the applicant stated:

Line 2702-008-1" which is associated with penetration 86C on mechanical

boundary drawings 1X4LD1 10 and 2X4LD1 10 is in scope. These drawings

should have shown line 2702-008-1" in scope for 10 CFR 54.4(a)(1).

Based on its review, the staff finds the applicant's response to RAI 2.3.3.27-3 acceptable

because the applicant explained that the piping in question is within the scope of license

renewal. Therefore, the staffs concern described in RAI 2.3.3.27-3 is resolved.

2.3.3.27.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

applicant failed to identify any components within the scope of license renewal. The staff finds

no such omissions. In addition, the staffs 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 the applicant has adequately identified the sampling system

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).

2.3.3.28 Auxiliary Gas Systems

2.3.3.28.1 Summary of Technical Information in the Application

LRA Section 2.3.3.28 describes the auxiliary gas systems, which include the auxiliary gas

system - nitrogen and the auxiliary gas system - hydrogen.

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The auxiliary gas system-nitrogen supplies nitrogen for pressurizing, blanketing, and purging of

various plant components.

The auxiliary gas system-hydrogen supplies hydrogen to the generator for cooling, to the CVCS

for oxygen scavenging, and to the waste gas decay tanks and the reactor coolant drain tanks.

The auxiliary gas systems contain safety-related components relied upon to remain functional

during and following DBEs. The failure of nonsafety-related SCs in the auxiliary gas systems

potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the auxiliary gas systems perform functions that support EQ.

LRA Table 2.3.3.28 identifies auxiliary gas systems component types within the scope of license

renewal and subject to an AMR:

* closure bolting

* piping components

* valve bodies

The intended function of the auxiliary gas systems component types within the scope of license

renewal is to provide a pressure-retaining boundary.

2.3.3.28.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.28 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.

During its review of the auxiliary gas system - nitrogen, 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 delineated under 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).

During its review of the auxiliary gas system - hydrogen, the staff evaluated the system

functions described in the LRA and the UFSAR to verify that the applicant has not omitted from

the scope of license renewal any component types with intended functions delineated under 10

CFR 54.4(a).

2.3.3.28.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any components within the scope of license renewal. The staff finds no such omissions.

In addition, the staffs 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 the applicant has adequately identified the auxiliary gas system - nitrogen

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 reviewed the LRA and UFSAR associated with the auxiliary gas system - hydrogen to

determine whether the applicant failed to identify component types that are typically found within

the scope of license renewal and finds no such omissions. On the basis of its review, the staff

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concludes that the applicant has adequately identified the auxiliary gas system - hydrogen

component types within the scope of license renewal, as required by 10 CFR 545.4(a).

2.3.3.29 Chilled Water Systems

2.3.3.29.1 Summary of Technical Information in the Application

LRA Section 2.3.3.29 describes the chilled water systems, which consist of the following:

* normal chilled water system

* essential chilled water system

* special chilled water system

The normal chilled water system supplies chilled water throughout the plant to all airconditioning and air cooling units required during normal plant operation. Each unit's system

also can be connected to supply chilled water for use in one containment building auxiliary air

cooling unit and one reactor cavity cooling unit during refueling outages.

The essential chilled water system supplies chilled water to the cooling coils of the various ESF

rooms or areas, including battery rooms, switchgear rooms, control rooms, ESF pump rooms,

penetration areas, and the spent fuel pool heat exchanger and pump rooms. Both trains of

essential chilled water actuate automatically upon either a safety injection signal or control room

isolation signal; however, in a loss of offsite power system actuation is manual. Power for each

essential chilled water train is by the emergency bus for the equipment it cools.

The special chilled water system supplies the necessary cooling water to air-cooling systems for

the onsite technical support center and the standby central alarm station.

The chilled water systems contain safety-related components relied upon to remain functional

during and following DBEs. The failure of nonsafety-related SCs in the chilled water systems

potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the chilled water systems perform functions that support fire protection.

LRA Table 2.3.3.29 identifies chilled water systems component types within the scope of license

renewal and subject to an AMR:

* air separator

* closure bolting

* electric heater housings

* essential chillers - condenser (channel heads)

* essential chillers - condenser (shells)

* essential chillers - condenser (tubes)

* essential chillers - condenser (tubesheets)

* essential chillers - evaporator (channel heads)

* essential chillers - evaporator (shells)

* essential chillers - evaporator (tubes)

* essential chillers - evaporator (tubesheets)

• flow orifice/elements

* oil reservoirs - chiller compressors

* piping components

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* piping components - pipe spools for startup strainers

* pump casings - chilled water pumps

* pump casings - chiller motor driven oil pumps

* sight glasses

* strainer elements

* strainer housings

* tanks - chilled water chemical feed pots

* tanks - chilled water expansion tanks

* tanks - chiller economizers

* valve bodies

The intended functions of the chilled water systems component types within the scope of

license renewal include:

* protection from debris

* heat exchange between fluid media

• restriction of process flow

* pressure-retaining boundary

2.3.3.29.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.29, and UFSAR Section 9.2.9, and UFSAR Table 3.2.2-1

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 delineated under 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).

The staffs review of LRA Section 2.3.3.29 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAIs as discussed below.

In RAI 2.3.3.29-1, dated January 28, 2008, the staff noted that drawings 1X4LD233, 2X4LD233,

1X4LD234, and 2X4LD234 show numerous essential chilled water cooling coils that are within

the scope of license renewal based on criterion 10 CFR 54.4(a)(1). Also, drawings AX4LD231

and AX4LD232 show numerous normal chilled water cooling coils that are within the scope of

license renewal based on criterion 10 CFR 54.4(a)(2). The applicant was requested to provide

additional information explaining why the cooling coil component type was omitted from LRA

Table 2.3.3.29 for components subject to an AMR.

In its response, dated February 27, 2008, the applicant stated:

The cooling coil component type(s) are included within the LRA ventilation

system which corresponds to their associated component tag number. For

instance, essential and normal chilled water cooling coil component types are

included in the control and auxiliary building ventilation component type tables,

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2.3.3.11 and 2.3.3.12, respectively. Therefore, the component types were not

duplicated in the chilled water system Table 2.3.3.29.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.29-1 acceptable

because the applicant explained that the essential and normal chilled water cooling coil

component types are included in the control and auxiliary building ventilation component tables,

2.3.3.11 and 2.3.3.12 respectively. Therefore, the staffs concern described in RAI 2.3.3.29-1 is

resolved.

In RAI 2.3.3.29-2, dated January 28, 2008, the staff noted that the license renewal AMR Table

2.3.3.29 did not include some of the typical components that are listed in AMR tables of other

plant LRAs, including the housings for the chiller compressor/motor, compressor oil cooler, oil

filter, oil pump, and the refrigerant dryer filter. The applicant was requested to provide additional

information to explain why these components are not included in LRA Table 2.3.3.29 as

components subject to an AMR.

In its response, dated February 27, 2008, the applicant stated:

The chiller compressor oil is cooled as the lube oil piping passes through the

refrigerant filled motor, therefore the chiller compressor does not have a

separate sub-component which functions as an oil cooler.

The oil pump is listed in LRA Table 2.3.3.29, Item No. 17, as "Pump Casings

- Chiller Motor Driven Oil Pumps."

The chiller compressor housings, chiller compressor lube oil filters, and

refrigerant filter dryers were omitted from the application and will be added to

LRA Table 2.3.3.29. In addition, the chiller compressor purge tanks were

omitted from the application and will be added to LRA Table 2.3.3.29.

LRA Table 3.3.2-29 will be revised to include AMR results for the chiller

compressor housings, chiller compressor lube oil filters, refrigerant filter dryers,

and chiller compressor purge tanks. In addition, LRA Table 3.3.2-29 will be

revised to include AMR results for the following components in the chiller

compressor lube oil and refrigerant sub-systems that were not included in the

initial AMR results:

* Closure Bolting (copper alloy)

* Flow Orifice / Elements

• Piping Components

* Sight Glasses

* Strainer Elements

* Strainer Housings

* Valve Bodies

Based on its review, the staff finds the applicant's response to RAI 2.3.3.29-2 acceptable

because the applicant explained that LRA AMR Tables 2.3.3.29 and 3.3.2-29 would be updated

to include missing components that were not included in the initial AMR results. Therefore, the

staffs concern described in RAI 2.3.3.29-2 is resolved.

2.3.3.29.3 Conclusion

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

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applicant failed to identify any components within the scope of license renewal. The staff finds

no such omissions. In addition, the staffs 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 the applicant has adequately identified the chilled water system

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).

2.3.3.30 Waste Management Systems

2.3.3.30.1 Summary of Technical Information in the Application

LRA Section 2.3.3.30 describes the waste management systems, which include the following:

* backflushable filter system

* condensate cleanup system

* waste processing system, liquid

* waste processing system, gas

The backflushable filter system consists of two major subsystems which filter and transport

radioactive crud:

backflushable filters subsystem for filtering crud during normal operation in the

CVCS, boron recycle system, liquid waste processing system, spent fuel cooling

and purification system, and steam generator blowdown system

crud collection subsystem consisting of a backflushable filter crud tank (equipped

with a sprayball) and two crud tank pumps which collect and transport the crud

solution to the radwaste solidification system or alternate radwaste building for

disposal.

The backflushable filter system is nonsafety-related, intermittent during infrequent filter

backflushing operations, and isolated most of the time.

The condensate cleanup system maintains the required purity of feedwater fo0r the steam

generators by filtration to remove corrosion products, ion exchange to remove condenser

leakage impurities, or both filtration and ion exchange.

The condensate cleanup system consists of the condensate filter demineralizer, the backwash

recovery, the spent resin disposal, and the spent resin dewatering systems, all of which are

retired in place.

The condensate polishing system is included in the condensate cleanup system. The

condensate polishing system (full-flow condensate filter/demineralizers) filtersý suspended

corrosion products from the condensate and removes ionic contaminants to minimize localized

corrosion in the steam generator, turbine, and feedwater systems.

The waste processing system, liquid controls, collects, processes, handles, stores, and

disposes of liquid radioactive waste generated by normal operation, including anticipated

operational.occurrences. This system has three subsystems that perform the following activities:

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* the recycle subsystem processes reactor grade water entering the system via

equipment leaks and drains, valve leakoffs, pump seal leakoffs, tank overflows,

and other tritiated water sources and makes it available for reuse in the plant

the liquid waste subsystem collects and processes nonreactor-grade liquid

wastes, including wastes from floor drains, equipment drains for nonreactor

grade sources, laundry and hot shower drains, spent and excess radioactive

samples, and other nonreactor grade sources

the spent resin collection subsystem transports spent resin to the spent resin

storage tank

The waste processing system, gas, removes fission product gases from the RCS in the volume

control tank, the boron recycle system, the reactor coolant drain tank, and the liquid waste

processing system. The waste processing system, gas, has a long-term storage capacity for

fission product gases, eliminating any need for scheduled discharges of radioactive gases.

The waste processing system, gas, performs no function for safe shutdown of the plant;

however, the system distributes the stored activity inventory so that, in a waste gas decay tank

failure, the dose will be a fraction of the 10 CFR Part 100 permissible limit with the curie content

of each waste gas decay tank individually limited in accordance with the technical requirements

manual; hence, the waste gas decay tanks are safety-related. The tanks and the piping and

valves out to the first isolation valve are safety-related,

and the safety-related portion includes the common piping header for the discharge of the

pressure relief valves for the tanks.

A safety-related interface allows the CLB to consider a waste processing system, gas release

and a recycle hold-up tank gaseous release separately. Without the safety-related interface,

consideration of the two releases would have to be concurrent; therefore, the interface

components mitigate accident consequences and are within the scope of license renewal.

The waste management systems contain safety-related components relied upon to remain

functional during and following DBEs. The failure of nonsafety-related SCs in the waste

management systems potentially could prevent the satisfactory accomplishment of a safetyrelated function. In addition, the waste management systems perform functions that support EQ.

LRA Table 2.3.3.30 identifies waste management systems component types within the scope of

license renewal and subject to an AMR:

* accumulators

* closure bolting

* equipment frames - catalytic H 2 recombiner skid

* equipment frames - waste gas compressor skid

* filter housings

* flow orifice/elements

* gas traps

* piping components

* piping components - pipe spools for startup strainers

* pump casings - gas decay drain pumps

* tanks - backflushable filter crud tanks

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* tanks - waste gas decay shutdown tanks

* tanks - waste gas decay tanks

* valve bodies

The intended function of the waste management systems component types within the

scope of license renewal is to provide a pressure-retaining boundary.

2.3.3.30.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.30 and UFSAR Sections 11.4.2.3.2, 10.4.6, 11.2, and

11.3 using the evaluation methodology described in SER Section 2.3 and the guidance in SRPLR Section 2.3.

During its review of the backflushable filter system and the condensate cleanup system, the

staff evaluated the system functions described in the LRA and the UFSAR to verify that the

applicant has not omitted from the scope of license renewal any component types with intended

functions delineated under 10 CFR 54.4(a).

During its review of the waste processing system, liquid and waste processing system, gas, 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 delineated under 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).

The staff's review of LRA Section 2.3.3.30 identified areas in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAIs as discussed below.

In RAI 2.3.3.30-1, dated January 28, 2008, the staff noted drawing 1X4LD1 11 (H-7) shows pipe

section 314-2" as within the scope of license renewal based on criterion 10 CFR 54.4(a)(2) with

the license renewal boundary identified by note A2 and the continuation portion not within the

scope of license renewal. However, the continuation of pipe 314-2" on 1X4LD127 (A-8) is also

identified as within the scope of license renewal. The applicant was asked to provide additional

information detailing the license renewal boundary for pipe section 314-2" on drawings

lX4LD111 (H-8) and 1X4LD127 (A-8).

In its response, dated February 27, 2008, the applicant stated:

A detail review of the piping isometrics that identify the equivalent anchors for the

pipe section 314-2" shown on License Renewal drawing 1X4LD 111 (H-7) which

continues to drawing 1X4LD127 (A-8) confirms that this line should have been

shown in scope per criterion 10CFR 54.4(a)(2). This discrepancy represents a

duplication in identifying equivalent anchors for this section of pipe. It has been

determined that the in-scope pipe section (314-2") per criterion (a)(2) should

continue to drawing 1X4LD127 (A-8) and terminate at note 8 downstream.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.30-1 acceptable

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because the applicant explained that the in scope pipe section (314-2") should continue to

drawing 1X4LD127 (A-8) and terminate at note A8. Therefore, the staffs concern described in

RAI 2.3.3.30-1 is resolved.

In RAI 2.3.3.30-2, dated January 28, 2008, the staff noted drawings lX4LD1 11 (H-3) and

1X4LD127 (F-7) show pipe sections 376-1/2" not within the scope of license renewal. This line

connects to 255-3/4" inside the 10 CFR 54.4(a)(2) boundary identified on 1X4LD127.

Additionally, 376-1/2" connects to 048-3" valve 025 on drawing 1X4LD 111 which is identified

within the scope of license renewal based on criterion 10 CFR 54.4(a)(1). The applicant was

asked to provide additional information detailing the license renewal boundary for pipe sections

376-1/2" on drawings 1X4LD111 (H-3) and 1X4LD127 (F-7).

In its response, dated February 27, 2008, the applicant stated:

Mechanical boundary drawing 1X4LD127 should have taken credit for

existing pipe supports so that the end point of the in-scope portion of line

1901-199-3/8" terminated before the connection to line 1901-001-3." This

removes part of line 1901-199-3/8," all of line 1901-001-3," and all of line

1901-255-3/4" from scope. Refer to the answer to RAI 2.3.3.30-4 for

additional discussion of line 1901-376-1/2".

Based on its review, the staff finds the applicant's response to RAI 2.3.3.30-2 acceptable

because the applicant stated that:

Connecting line to 255-3/4" as well as 376-1/2" are not included in scope. These

lines are non-safety related and are not in scope for 10 CFR 54.4(a)(1). Also

these lines are not in scope for 10 CFR 54.4(a)(2) connected pipe criteria

because the CLB considers that the non-safety related small bore line can not

affect the large bore safety related line and spatial interaction criteria because all

safety related SCs inside containment are assumed to be qualified for spray

effects or submergence.

Therefore, the staffs concern described in RAI 2.3.3.30-2 is resolved.

In RAI 2.3.3.30-3, dated January 28, 2008, the staff noted drawing 1X4LD1 14 (G-3) shows pipe

section 369-1/2" within the scope of license renewal based on criterion for 10 CFR 54.4(a)(2).

However, the continuation of pipe section 369-1/2" on drawing 1X4LD127 (G-7) shows it is not

within the scope of license renewal. The applicant was asked to provide additional information

detailing the license renewal boundary for pipe sections 369-1/2" on drawings 1X4LD1 14 (G-3)

and 1X4LD127 (G-7).

In its response, dated February 27, 2008, the applicant stated:

Mechanical boundary drawing 1X4LD1 14 inadvertently showed lines 1901-

382-1/2" and 1901-369-1/2" as being in scope for 10 CFR 54.4(a)(2).

However, these lines are not in scope. Mechanical boundary drawing

1X4LD127 correctly shows line 1901-369-1/2" as not in scope. Refer to the

answer to RAI 2.3.3.30-4 for additional discussion.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.30-3 acceptable

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because the applicant explained that 1901-382-1/2" and 1901-369-1/2" are non-safety related

and are not in scope for 10 CFR 54.4(a)(1). Also, these lines are not in scope for

10 CFR 54.4(a)(2) connected pipe criteria because the CLB considers that the non-safety

related small bore line can not affect the large bore safety related line and spatial interaction

criteria because all safety related SCs inside containment are assumed to be qualified for spray

effects or submergence. Therefore, the staff's concern described in RAI 2.3.3.30-3 is resolved.

In RAI 2.3.3.30-4, dated January 28, 2008, the staff noted drawing 1X4LD1 14, (G-3) and (F-3),

shows pipe sections 369-1/2" within the scope of license renewal based on criterion

10 CFR 54.4(a)(2) and 428-1/2" within the scope of license renewal based on criterion

10 CFR 54.4(a)(1). The following pipe sections which also continue to the reactor coolant drain

tanks are not within the scope of license renewal:

1X4LD1 14 and 2X4LD1 14 (F-5) 364-1/2"

1X4LD1 14 and 2X4LD1 14 (G-5) 363-1/2"

1X4LD1 14 and 2X4LD1 14 (G-5) 365-1/2"

1X4LD114 and 2X4LD114 (F-5) 366-1/2"

1X4LD114 and 2X4LD114 (G-6) 362-1/2"

1X4LD1 14 and 2X4LD1 14 (G-7) 370-1/2"

1X4LD1 14 and 2X4LD1 14 (G-7) 375-1/2"

1X4LD1 14 (G-8) 370-1/2"

1X4LD114 and 2X4LD114 (E-3) 371-1/2"

2X4LD1 14 (F-4) 428-1/2", Note 428-1/2" is in scope for 10 CFR 54.4(a)(1) on 1X4LD1 14

(F-4).

2X4LD114 (G-3) 369-1/2", Note 369-1/2" is in scope for 10 CFR 54.4(a)(2) on

lX4LD114 (G-3).

2X4LD 114 (G-4) 382-1/2", Note 382-1/2" is in scope for 10 CFR 54.4(a)(2) on

1X4LD114 (G-4).

The applicant was asked to provide additional information detailing the license renewal

boundaries for the above pipe sections and explain the apparent difference in scoping

methodologies.

In its response, dated February 27, 2008, the applicant stated:

Mechanical boundary drawing 1X4LD114 inadvertently showed lines 1901-

382-1/2" and 1901-369-1/2" as being in scope for 10 CFR 54.4(a)(2). Refer to

the answer to RAI 2.3.3.30-3. These lines are not in scope. See below for

10 CFR 54.4(a)(2) criteria discussion.

Mechanical boundary drawing 1X4LD1 14 inadvertently showed line 1901-

428-1/2" as being in scope for 10 CFR 54.4(a)(1). Line 1901-428-1/2",, is

Project Classification 427, which is non-safety related and therefore not in

scope for 10 CFR 54.4(a)(1). See below for 10 CFR 54.4(a)(2) criteria

discussion.

Lines 1901-362-1/2," 1901-363-1/2," 1901-364-1/2," 1901-365-1/2," 1901-

366-1/2," 1901-369-1/2," 1901-370-1/2," 1901-371-1/2," 1901-375-1/2," 1901-

382-1/2," and 1901-428-1/2" on each unit are non-safety related valve

packing leakoff lines. Because they are non-safety related they are not in

scope for 10 CFR 54.4(a)(1).

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These lines are not in scope for 10 CFR 54.4(a)(2) connected pipe criteria

because the CLB considers that the non-safety related small bore line can

not affect the large bore safety related line. In general the stress calculations

consider the loads imposed on a large bore line by 1⁄2" or 3⁄4" tubing to be

insignificant and those loads are neglected. The small bore line is considered

to be decoupled. Therefore the 10 CFR 54.4(a)(2) connected pipe criteria

does not apply.

These lines are not in scope for 10 CFR 54.4(a)(2) spatial interaction criteria

because all safety related SCs inside containment are assumed to be

qualified for spray effects or submergence, where required, to address a high

energy line break or LOCA. Furthermore, the pipe supports for these lines are

in scope so seismic 2/1 is not a concern and the lines operate at low

pressure so pipe whip is not a concern.

Based on its review, the staff finds the applicant's response to RAI 2.3.3.30-4 acceptable

because the applicant explained that the subject lines are non-safety related and are not in

scope for 10 CFR 54.4(a)(1). Also these lines are not in scope for 10 CFR 54.4(a)(2) connected

pipe criteria because the CLB considers that the non-safety related small bore line can not

affect the large bore safety related line and spatial interaction criteria because all safety related

SCs inside containment are qualified for spray effects or submergence. Therefore, the staff's

concern described in RAI 2.3.3.30-4 is resolved.

In RAI 2.3.3.30-5, dated January 28, 2008, the staff noted drawing 2X4LD124 (A-5) shows the

license renewal boundary for pipe section 045-2" from the Boron Recycle System (BRS) recycle

evaporator as within the scope of license renewal based on criterion 10 CFR 54.4(a)(2). This inscope line is continued from drawing AX4LD123-1. However, the same section of pipe on Unit 1

is identified as not within the scope of license renewal in drawing 1X4LD124 (A-5). The

applicant was asked to provide additional information explaining the apparent difference in

scoping methodologies for pipe section 045-2" on drawings 1X4LD124 (A-5) and 2X4LD124 (A5).

In its response, dated February 27, 2008, the applicant stated:

The scoping methodologies for Unit 1 and Unit 2 piping line number 045-2" are

the same. A section of Unit 2 piping line number 2-1901-045-2" is located on

Level B of the auxiliary building in the vicinity of safety related components that

are within the scope of license renewal based on criterion 10 CFR 54.4(a)(1).

The corresponding section of Unit 1 piping (line number 1-1901-045-2") is

located in a separate area of the auxiliary building such that there is no potential

for spatial interaction with safety related components. Therefore, only the Unit 2

piping section is within the scope of license renewal based on criterion

10 CFR 54.4(a)(2).

Based on its review, the staff finds the applicant's response to RAI 2.3.3.30-5 acceptable

because the applicant explained that a section of Unit 2 piping line number 2-1901-045-2" is

located on Level B of the auxiliary building in the vicinity of safety related components that are

within the scope of license renewal based on criterion 10 CFR 54.4(a)(1). The corresponding

section of Unit 1 piping is located in a separate area of the auxiliary building such that there is

no potential for spatial interaction with safety related components. Therefore, the staffs concern

described in RAI 2.3.3.30-5 is resolved.

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2.3.3.30.3 Conclusion

The staff reviewed the LRA and UFSAR associated with the backflushable filter system and the

condensate cleanup system to determine whether the applicant failed to identify component

types that are typically found within the scope of license renewal and finds no such omissions.

On the basis of its review, the staff concludes that the applicant has adequately identified the

backflushable filter system and the condensate cleanup system component types within the

scope of license renewal, as required by 10 CFR 54.4(a).

The staff reviewed the LRA, UFSAR, RAI responses, and drawings to determine whether the

applicant failed to identify any components within the scope of license renewal for the waste

processing system, liquid, and the waste processing system, gas. 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 the applicant has adequately identified the waste processing system, liquid,

and the waste processing system, gas, 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).

2.3.3.31 Thermal Insulation

2.3.3.31.1 Summary of Technical Information in the Application

LRA Section 2.3.3.31 describes the thermal insulation, which minimizes heat loss from

components and protects personnel from high-temperature components. Insulation in areas with

safety-related equipment retains structural integrity during and after a seismic Category I event.

The insulation support structures for the reactor vessel and nozzles limit the amount of

insulation displaced by blowdown during a LOCA condition below the amount assumed for the

reactor cavity pressurization analysis. Inside the containment, the containment cooling system

design credits insulation on components with high operating temperatures.

Thermal insulation outside containment has no safety design basis; however, insulation in areas

with safety-related equipment is designed to retain structural integrity during and after seismic

events.

Insulation on piping at containment penetrations must keep local concrete temperatures below

200 OF. For certain HVAC systems, heat load calculations, that assure performance of safetyrelated functions credit insulation. The EDG building heat-up calculation credits EDG exhaust

pipe insulation (including the silencers).

Outside area insulation with heat tracing protects small-bore piping and instrument lines for inscope systems from freezing. Insulation supports heat tracing and shields certain lines in the

battery rooms from spray.

The failure of nonsafety-related SCs in the thermal insulation could prevent the satisfactory

accomplishment of a safety-related function. The thermal insulation also performs functions that

support SBO.

LRA Table 2.3.3.31 identifies thermal insulation component types within the scope of license

renewal and subject to an AMR:

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* insulation - jacketing and supports

* thermal insulation

The intended functions of the thermal insulation component types within the scope of license

renewal include:

* environmental control of plant areas within equipment limitations

* physical integrity maintenance to prevent generation of debris or loose parts

which could interfere with a safety-related function

* shelter/protection for safety-related/nonsafety-related components

* structural/functional support for safety-related/nonsafety-related components with

maintenance of physical integrity and flow path considerations

2.3.3.31.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.31 and UFSAR Sections 5.2.3.2.3 and 6.2.1.2.1.2 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 delineated under 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).

2.3.3.31.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 thermal insulation 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).

2.3.3.32 Miscellaneous Leak Detection System

2.3.3.32.1 Summary of Technical Information in the Application

LRA Section 2.3.3.32 describes the miscellaneous leak detection system, which detects leaks in

the containment bottom and side liners and in liners of the spent fuel pool, fuel transfer canal,

and fuel cask loading pit. This system also has containment penetrations necessary to perform

the periodically necessary containment integrated leak rate test.

The miscellaneous leak detection system contains safety-related components relied upon to

remain functional during and following DBEs. The failure of nonsafety-related SCs in the

miscellaneous leak detection system potentially could prevent the satisfactory accomplishment

of a safety-related function.

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LRA Table 2.3.3.32 identifies miscellaneous leak detection system component types within the

scope of license renewal and subject to an AMR:

* closure bolting

* piping components

* valve bodies

The intended function of the miscellaneous leak detection system component types within the

scope of license renewal is to provide a pressure-retaining boundary.

2.3.3.32.2 Staff Evaluation

The staff reviewed LRA Section 2.3.3.32 and the UFSAR 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 delineated under 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).

2.3.3.32.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the,ý applicant failed to

identify any SCs 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 miscellaneous leak detection system

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).

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 main steam system

2.3.4.2 condensate and feedwater

2.3.4.2 condensate chemical injection

2.3.4.2 feedwater heater and MSR drain

2.3.4.3 steam generator blowdown system

2.3.4.4 auxiliary feedwater systems

2.3.4.5 auxiliary steam system

2.3.4.6 electrohydraulic control system

All of these systems are Balance of Plant systems.

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The staff identified the following BOP systems for Tier 1 reviews:

LRA Section System

2.3.4.2 feedwater heater and moisture separator/reheater drain system

2.3.4.5 auxiliary steam system

2.3.4.1 Main Steam System

2.3.4.1.1 Summary of Technical Information in the Application

LRA Section 2.3.4.1 describes the main steam system (MSS), which is integral to the nuclear

steam supply system heat removal systems and steam generator overpressure protection

features. The main steam system conducts the steam generated in the four steam generators

through the containment to the turbine-generator, moisture separator reheaters, steam jet air

ejectors, turbine shaft gland seals, steam generator feedwater pump turbines, turbine-driven

auxiliary feedwater pump, and the turbine bypass system.

Safety-related portions of the main steam system include heat removal, overpressure

protection, and isolation features. Steam conducted from the steam generators to the

atmospheric relief and main steam safety valves, which protect the steam generator and the

main steam piping from over-pressurization, removes heat from the RCS. The outlet nozzle of

each steam generator has a flow restrictor designed to limit flow rate and thrust loads in a main

steam line rupture. The main steam system also supplies steam to the auxiliary feedwater pump

turbine supplying feedwater to the steam generators for reactor heat removal during accident or

transient conditions when normal feedwater is unavailable.

Each of the four main steam lines has two main steam isolation valves and two main steam

bypass valves to isolate the secondary side of the steam generators in the event of leakage or

malfunction to prevent uncontrolled blowdown of the steam generators and to isolate nonsafetyrelated portions of the system.

The main steam system contains safety-related components relied upon to remain functional

during and following DBEs. The failure of nonsafety-related SCs in the MSS potentially could

prevent the satisfactory accomplishment of a safety-related function. In addition, the main steam

system performs functions that support fire protection, ATWS, SBO, and EQ.

LRA Table 2.3.4.1 identifies main steam system component types within the scope of license

renewal and subject to an AMR:

* closure bolting

* filter housings - ARV local (manual) actuators

* flexible connectors

* flow orifice/elements

* flow restrictors - ARV discharge paths

* oil reservoirs - ARV local (manual) actuators

* oil reservoirs filler/breather caps - ARV local (manual) actuators

* piping components

* piping components - forged sections for 5-way pipe restraints

* pump casings - ARV manual hand pumps

* pump casings - wet layup recirculation pumps

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valve bodies

The intended functions of the main steam system component types within the scope of license

renewal include:

* protection from debris

* spray shield or curbs for flow direction

* restriction of process flow

* pressure-retaining boundary

2.3.4.1.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.1 and UFSAR Section 10.3 using the evaluation

methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3. I

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 delineated under 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).

2.3.4.1.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 main steam system 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).

2.3.4.2 Feedwater System

2.3.4.2.1 Summary of Technical Information in the Application

LRA Section 2.3.4.2 describes the feedwater system, which includes the following:

* condensate and feedwater system

* condensate chemical injection system

* feedwater heater and moisture separator/reheater drain system

The condensate and feedwater system condenses high-pressure and low-pressure turbine

extraction and exhaust steam and main feedwater pump turbine exhaust steam, collects the

condensate in the condenser hotwell, and maintains steam generator water levels by supplying

preheated feedwater through all power operation modes of the plant. The system also isolates

feedwater as required to limit mass and energy in the containment in any feedwater break and

prevents RCS over-cooling and steam generator overfilling with water in the steam lines.

Feedwater flow to each steam generator is via a 16-inch main feedwater line to the steam

generator r6iain feedwater nozzle or the 6-inch feedwater bypass line to the auxiliary feedwater

nozzle. The system shares the feedwater bypass line portion from upstream of the feedwater

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bypass isolation valves to the steam generator bypass feedwater/auxiliary feedwater nozzle with

the safety-related auxiliary feedwater (AFW) system.

The primary function of the condensate chemical injection system is to supply chemicals to the

condensate and feedwater system for corrosion control. The condensate chemical injection

system includes the piping and storage/transfer equipment conveying the chemicals and

extending to the piping for the condensate and feedwater system, AFW system, and steam

generators. System safety functions are containment isolation and integrity.

The feedwater heater and moisture separator/reheater drain system drains the liquid

(condensed steam) from the feedwater heaters and moisture separator/reheaters and routes it

to the condensate and feedwater system. This system performs no safety function but is within

the 10 CFR 54.4(a)(2) scope of license renewal.

The feedwater system contains safety-related components relied upon to remain functional

during and following DBEs. The failure of nonsafety-related SCs in the feedwater system

potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the feedwater system performs functions that support ATWS and EQ.

LRA Table 2.3.4.2 identifies feedwater system component types within the scope of license

renewal and subject to an AMR:

* closure bolting

* flow orifice/elements

* piping components

* piping components - forged sections for 5-way pipe restraints

* piping components - guard pipe

* valve bodies

The intended functions of the feedwater system component types within the scope of license

renewal include:

* restriction of process flow

* pressure-retaining boundary

2.3.4.2.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.2 and UFSAR Sections 10.3.5 and 10.4.7 using the

evaluation methodology described in SER Section 2.3 and the guidance in SRP-LR Section 2.3.

During its review of the condensate and feedwater system and the condensate chemical

injection system, 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 delineated under 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).

During its review of the feedwater heater and moisture separator/reheater drain system, the

staff evaluated the system functions described in the LRA and the UFSAR to verify that the

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applicant has not omitted from the scope of license renewal any component types with intended

functions delineated under 10 CFR 54.4(a).

2.3.4.2.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings associated with the condensate and

feedwater system and the condensate chemical injection system to determine whether the

applicant failed to identify any SCs within the scope of license renewal. The staff finds no such

omissions. In addition, the staffs 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 condensate and feedwater

system and the condensate chemical injection system 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 reviewed the LRA and UFSAR associated with the feedwater heater and moisture

separator/reheater drain system to determine whether the applicant failed to identify component

types that are typically found within the scope of license renewal and finds no such omissions.

On the basis of its review, the staff concludes that the applicant has adequately identified the

feedwater heater and moisture separator/reheater drain system component types within the

scope of license renewal, as required by 10 CFR 54.4(a).

2.3.4.3 Steam Generator Blowdown System

2.3.4.3.1 Summary of Technical Information in the Application

LRA Section 2.3.4.3 describes the steam generator blowdown system, which accepts

secondary water from each steam generator blowdown line, processes the water as required,

and delivers the processed water to either the condensate system or the waste water retention

basin. Process steps include cooling with heat recovery, pressure reduction, 'filtration, and ion

exchange. The purpose of the steam generator blowdown system is to maintain optimum

secondary side water chemistry during normal operation and during anticipated operational

occurrences by removing impurities from primary coolant or circulating water in-leakage

concentrated in the steam generator by evaporation.

Safety-related instrumentation in the steam generator blowdown system helps detect and

isolate high-energy lines in the auxiliary building. Interfaces between steam generator blowdown

system nonsafety-related portions and other plant systems can affect safety-related portions of

the plant adversely following a postulated pipe rupture in the nonsafety-related high-energy

portion of the system outside of containment.

The steam generator blowdown system contains safety-related components relied upon to

remain functional during and following DBEs. The failure of nonsafety-related SCs in the steam

generator blowdown system potentially could prevent the satisfactory accomplishment of a

safety-related function. In addition, the steam generator blowdown system performs functions

that support EQ.

LRA Table 2.3.4.3 identifies steam generator blowdown system component types within the

scope of license renewal and subject to an AMR:

e closure bolting

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* filter housings

* flow orifice/elements

* heat exchangers - SGBD HXs (channel heads)

* heat exchangers - SGBD HXs (shells)

* heat exchangers - SGBD trim HXs (channel heads)

* heat exchangers - SGBD trim HXs (shells)

* piping components

* piping components - pipe spools for startup strainers

* pump casings - steam generator drain pumps

* pump casings - steam generator blowdown spent resin sluice pumps

* strainer housings

* valve bodies

The intended functions of the steam generator blowdown system component types within the

scope of license renewal include:

* restriction of process flow

* pressure-retaining boundary

2.3.4.3.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.3 and UFSAR Section 10.4.8 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 delineated under 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).

2.3.4.3.3 Conclusion

The staff reviewed the LRA, UFSAR and drawings to determine whether the applicant failed to

identify any SCs 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 steam generator blowdown system

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).

2.3.4.4 Auxiliary Feedwater System (1302)

2.3.4.4.1 Summary of Technical Information in the Application

LRA Section 2.3.4.4 describes the AFW system, which supplies feedwater to the steam

generators during startup, cooldown, and emergency conditions resulting in a loss of main

feedwater. The two motor-driven and one turbine-driven AFW pumps are available to ensure the

required feedwater flow to the steam generators. During normal operations, the system is in a

standby mode with controls selected for automatic operation.

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System capacity is sufficient to remove decay heat and to supply adequate feedwater for RCS

cooldown within specified limits. The AFW system is relied upon for feedwater supply to the

steam generators to maintain a secondary heat sink for DBE mitigation; therefore, this system is

safety-related.

The AFW feedwater source for both normal conditions and DBE mitigation is the condensate

storage tank. Such tanks are constructed of concrete lined with stainless steel. This section

evaluated the tank liner as a mechanical component. LRA Section 2.4.7, "Concrete Tank and

Valve House Structures," evaluated the concrete shell, roof, and base slab. The condensate

storage tanks have floating diaphragms to minimize oxygen absorption.

The AFW system contains safety-related components relied upon to remain functional during

and following DBEs. The failure of nonsafety-related SCs in the AFW system potentially could

prevent the satisfactory accomplishment of a safety-related function. In addition, the AFW

system performs functions that support fire protection, ATWS, SBO, and EQ.

LRA Table 2.3.4.4 identifies AFW system component types within the scope of license renewal

and subject to an AMR:

* closure bolting

* filter housings

* flow orifice/elements

* oil coolers - TDAFWP turbine (channel heads)

* oil coolers - TDAFWP turbine (shells)

* oil coolers - TDAFWP turbine (tubes)

* oil coolers- TDAFWP turbine (tubesheets)

* oil reservoirs - TDAFWP turbine lube oil

* piping components

* piping components - pipe spools for startup strainers

* pump casings - AFW pumps

* pump casings - CST vacuum degasifier pumps

* pump casings - TDAFWP lube oil pumps

* spargers - TDAFWP steam exhaust condensate

* tank - CST degasifier tank

* tank diaphragms - CSTs

* tank liners (and internals) - CST liners

* turbine casings (AFW pump drive turbine)

* valve bodies

The intended functions of the AFW system component types within the scope of license renewal

include:

* heat exchange between fluid media

* flow pattern or distribution provision

* restriction of process flow

* physical integrity maintenance to prevent generation of debris or loose parts

which could interfere with a safety-related function

pressure-retaining boundary

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2.3.4.4.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.4 and UFSAR Section 10.4.9 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 delineated under 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).

The staff's review of LRA Section 2.3.4.4 identified an area in which additional information was

necessary to complete the review of the applicant's scoping and screening results. The

applicant responded to the staffs RAI as discussed below.

In RAI 2.3.4.4-1, dated January 28, 2008, the staff noted drawings 1X4LD161-1 and 2X4LD161-

1 (E-7) downstream of valve HV5089 is shown as within the scope of license renewal based on

criterion 10 CFR 54.4(a)(2), up to an equivalent anchor Al/A4, whereas, there is no annotation

if there is an equivalent anchor for the 153-10" line at HV5103. The applicant was asked to

provide additional information justifying the boundary locations with respect to the applicable

requirements of 10 CFR 54.4(a).

In its response, dated February 27, 2008, the applicant stated:

Downstream of HV5103 on 1X4LD161-1 and 2X4LD161-1 is a spool piece

identified as line 1302-104-10." This spool piece is shown as not in scope

(colored gray) and in phantom on these boundary drawings because it is a

removable spool piece that is only installed for hydrostatic testing of the main

condenser. The lines on either side of the spool piece (1302-153-10" and

1302-010-10"") terminate at the blind flanges. The end point of line 1302-153-

10" is therefore defined in accordance with the guidance provided in NEI 95-

10, Appendix F, as the free end of the non-safety related piping. An

equivalent anchor is not required.

By telecom dated April 17, 2008, the applicant corrected an error in line reference numbers from

1302-153-10" and 1302-010-10" to 1305-153-10" and 1305-010-10", respectively.

Based on its review, the staff finds the applicant's response to RAI 2.3.4.4-1 acceptable,

because the applicant explained that the lines on either side of the spool piece (1305-153-10"

and 1305-010-10") terminate at the blind flanges. The end point of line 1305-153-10" is

therefore defined in accordance with the guidance provided in NEI 95-10, Appendix F, as the

free end of the non-safety related piping. Therefore, the staffs 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 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

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AMR. The staff finds no such omissions. On the basis of its review, the staff concludes the

applicant has adequately identified the auxiliary feedwater system 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).

2.3.4.5 Auxiliary Steam System

2.3.4.5.1 Summary of Technical Information in the Application

LRA Section 2.3.4.5 describes the auxiliary steam system, which conveys auxiliary steam to the

balance-of-plant systems during startup, shutdown, and normal operation. The supply of steam

for this system is the main steam system. By a cross-connect an operating unit can supply

steam to a unit shut down. The auxiliary steam system performs the following functions:

* heating of the condensate during condensate and feedwater system

preoperational cleanup

0 assisting in attaining and holding the required vacuum in the main condensers

0 sealing the glands of the main turbine and feedwater pump drive turbines prior to

the availability of main steam

0 preoperational testing of the AFW pump turbine and steam generator feedwater

pump turbines

a heating the cleaning solutions for preoperational piping and equipment cleaning

* steam blanketing of moisture separator reheaters during plant shutdown

* assisting in deaeration of the main condensate during cold cleanup operations

* as an alternative, main steam line and main turbine shell preheating following

extended main steam isolation and prior to entry of steam from steam generators

I

The failure of nonsafety-related SCs in the auxiliary steam system could potentially prevent the

satisfactory accomplishment of a safety-related function.

LRA Table 2.3.4.5 identifies auxiliary steam system component types within the scope of license

renewal and subject to an AMR:

* closure bolting

* flow orifice/elements

* piping components

* steam/fluid trap bodies

* valve bodies

The intended functions of the auxiliary steam system component types within the scope of

license renewal include:

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* restriction of process flow

* pressure-retaining boundary

2.3.4.5.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.5 and UFSAR Section 9.5.9 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 component types

with intended functions delineated under 10 CFR 54.4(a).

2.3.4.5.3 Conclusion

The staff reviewed the LRA and UFSAR to determine whether the applicant failed to identify any

component types that are typically found within the scope of license renewal and finds no such

omissions. The staff finds no such omissions. On the basis of its review, the staff concludes that

the applicant has adequately identified the auxiliary steam system component types within the

scope of license renewal, as required by 10 CFR 54.4(a).

2.3.4.6 Electrohydraulic Control System

2.3.4.6.1 Summary of Technical Information in the Application

LRA Section 2.3.4.6 describes the electrohydraulic control system. The steam turbine converts

the thermal energy of the steam from the main steam system into mechanical energy to drive

the main generator and produce the plant electrical output. Integral to operation of the turbine is

the turbine control system, which includes the digital electrohydraulic control system.

The turbine control system positions the steam valves controlling steam flow to the highpressure and low-pressure turbines (i.e., high-pressure control valves and stop valves and lowpressure intermediate stop valves and intercept valves). The electrohydraulic control system

meets the fluid pressure demands for positioning of these steam valves. The turbine lube oil

system supplies pressurized oil to the auto-stop oil header and lubricates the turbine. Loss of

the auto-stop oil header pressure or the electrohydraulic control fluid pressure to the actuators

will close the steam valves (tripping the turbine).

Electrohydraulic control system nonsafety-related components required to trip the turbine in

response to ATWS are within the 10 CFR 54.4(a)(3) regulated event scoping criteria for license

renewal. The applicant conservatively includes nonsafety-related components which trip the

turbine in response to overspeed within the scope of license renewal under 10 CFR 54.4(a)(2).

The failure of nonsafety-related SCs in the electrohydraulic control system could potentially

prevent the satisfactory accomplishment of a safety-related function. The electrohydraulic

control system also performs functions that support ATWS.

There are no electrohydraulic control system mechanical components subject to an AMR. The

screening process concluded that active components accomplish system mechanical

component functions and that any component pressure boundary failure would not prevent

performance of system intended functions, a conclusion consistent with the SRP-LR Table 2.1-5

as to turbine controls for actuator and overspeed trip. The screening concluded that the

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electrohydraulic control system components perform no intended functions for license renewal;

therefore, none of the electrohydraulic control system components are subject to an AMR.

2.3.4.6.2 Staff Evaluation

The staff reviewed LRA Section 2.3.4.6 and UFSAR Sections 7.7.1.11, 10.1, 10.2, and

10.2.2.3.1.5 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 delineated under 10 CFR 54.4(a). The staff then reviewedý 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).

2.3.4.6.3 Conclusion

The staff reviewed the LRA, UFSAR, and drawings to determine whether the applicant failed to

identify any SCs 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 electrohydraulic control system

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).

2.4 ScoDinc 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:

* containment structures

• auxiliary, control, fuel handling, and equipment buildings

* EDG structures

* turbine building

* tunnels and duct banks

* nuclear service cooling water structures

* concrete tank and valve house structures

* switchyard structures

* fire protection structures

* radwaste structures

* auxiliary feedwater pumphouse structures

* component supports and bulk commodities

In accordance with the requirements of 10 CFR 54.21 (a)(1), the applicant must identify and 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 approach 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.

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The staff's evaluation of the information in the LRA was performed in the same manner 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 those 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, focusing on

components that have not been identified as within the scope of license renewal. The staff

reviewed the UFSAR, for each structure to determine whether the applicant has omitted from

the scope of license renewal components with intended functions delineated under

10 CFR 54.4(a). The staff also reviewed the UFSAR to determine whether the LRA specified all

intended functions delineated under 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 (1) the functions are

performed with moving parts or a change in configuration or properties or (2) 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). By letter dated, January

28, 2008, the staff requested additional information to resolve any omissions or discrepancies

identified.

2.4.1 Containment Structures

2.4.1.1 Summary of Technical Information in the Application

In LRA Section 2.4.1, the applicant described the containment structures, including containment

buildings and containment internal structures. The containment building is a seismic Category I

structure that completely encloses the reactor, the Reactor Coolant System (RCS), the steam

generators, and portions of the auxiliary and engineered safety features systems. The

containment building also houses components required for reactor refueling, including the polar

crane, refueling cavity, and portions of the fuel handling system. The containment structure

protects these features from external events (e.g., tornado, flooding, et cetera) and functions as

a fission product barrier following an accident. The containment structure also provides

biological shielding during normal operation and following a LOCA.

The major elements of the containment building structure are the main structure and foundation,

the steel containment liner, and the containment penetrations.

The containment internal structures are comprised of concrete and steel components. The

major concrete internal components are the reactor cavity and primary shield wall, secondary

shield wall, refueling cavity (and transfer canal), and floor slabs. Major steel internal

components are the refueling canal liner and structural steel framing. Miscellaneous items

unique to the containment internal structures include the emergency sump screens and the

trisodium phosphate baskets on the containment base slab. Common structural commodities

include supports for piping, cable trays, conduits, ventilation ducting, and other components,

whip restraints, cable trays and conduits, platforms, racks and frames, and grating.

The containment structures contain safety-related components relied upon to remain functional

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during and following DBEs. The failure of nonsafety-related SCs in the containment structure

potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the containment structures perform functions that support fire protection, ATWS, and

SBO.

LRA Table 2.4.1 identifies containment structures component types within the scope of license

renewal and subject to an AMR.

2.4.1.2 Staff Evaluation

The staff reviewed LRA Section 2.4.1 using the evaluation methodology described in SER

Section 2.4 and the guidance in SRP-LR Section 2.4, "Scoping and Screening Results:

Structures."

During its review of the LRA Section 2.4.1, the staff identified areas in which additional

information was necessary to complete the evaluation of the applicant's scoping and screening

results for containment structures. Therefore, the staff issued requests for additional information

(RAls) by letter dated January 28, 2008 to determine whether the applicant properly applied the

scoping criteria of 10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21(a)(1). The

following discussion describes the staffs RAls related to the LRA Section 2.4.1, the

corresponding applicant responses, and the staff evaluation.

In Section 2.4.1 of the LRA the applicant stated that a tendon access gallery is located beneath

the perimeter of the base slab for the installation and inspection of the U-shaped tendons. In

RAI 2.4.1-1, dated January 28, 2008, the staff asked whether the applicant considered the

tendon access gallery and its associated vertical access shafts in the scope of license renewal

and subject to an AMR.

By letter dated February 27, 2008, the applicant provided the response to RAI 2.4.1-1 and

confirmed that the tendon access gallery and its associated vertical access shafts are included

in the scope of license renewal for VEGP and subject to an AMR. Therefore, the staff finds the

applicant's scoping of the tendon access gallery acceptable.

From review of LRA Table 2.4.1, the staff could not determine if the following components of the

Containment Structures have been screened-in as components subject to an AMR.

(i) Control rod drive missile shield

(ii) Polar crane support brackets

(iii) Reactor cavity manipulator crane

In RAI 2.4.1-2, dated January 28, 2008, the staff asked the applicant to clarify the inclusion of

these components in the scope of license renewal.

By letter dated February 27, 2008, the applicant provided the following response to RAI 2.4.1-2.

(i) Control rod drive missile shield has been screened-in as a component subject to

an AMR. This item is included in Table 2.4.1 ID 13 'Steel Components:

Integrated Reactor Head Steel Assemblies.'

(ii) Polar crane support brackets have been screened-in as a component subject to

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an AMR. This item is included in Table 2.4.1 ID 11 'Steel Components: All

Structural Steel.'

(iii) Reactor cavity manipulator crane is part of 'Refueling Machine' at VEGP and it

has been screened-in as a component subject to an AMR. This item is included

in Section 2.3.3.3 under 'Fuel Handling and RV Servicing Equipment.'

In its response, the applicant provided clarification that the control rod drive missile shield, polar

crane support brackets and reactor cavity manipulator crane are included in the scope of

license renewal for VEGP and subject to an AMR. Therefore, the staff finds the applicant's

response to RAI 2.4.1-2 acceptable.

Under the title "Steel Containment Liner" in Section 2.4.1, the LRA states that "The floor liner

plate is installed on top of the foundation slab and is then covered with concrete." The staff

issued RAI 2.4.1-3 on January 28, 2008, to request the applicant to confirm that the

inaccessible floor liner plate of the base mat, including the leak chase system and the concrete

fill slab above this liner are included in the components listed in Table 2.4.1 and are subject to

an AMR.

By letter dated February 27, 2008, the applicant provided the response to RAI 2.4.1-3 and

confirmed that the inaccessible floor liner plate (including the leak chase system) on the top of

the base mat is included in Table 2.4.1 ID 14 'Steel Components: Liner (Containment); Liner

Anchors; Integral Attachments' and the concrete fill slab above this liner is included in

Table 2.4.1 ID 4 'Concrete: Internal Structures.' Considering that these items are included in the

scope of license renewal for VEGP and subject to an AMR, the staff finds the applicant's

response to RAI 2.4.1-3 acceptable.

By letter dated January 28, 2008, the staff issued RAI 2.4.1-4 to request the applicant to clarify

that the component identified as "Steel Components: All Structural Steel" in various tables in

Section 2.4 of the LRA includes the connection components (gusset plates, welds, bolts, etc.) of

structural steel.

By letter dated February 27, 2008, the applicant confirmed that the connection components

(gusset plates, welds, bolts, etc.) are included in the scope of license renewal for VEGP and

subject to an AMR. Therefore, the staff finds the applicant's response to RAI 2.4.1-4 acceptable.

By letter dated January 28, 2008, the staff issued RAI 2.4.1-5 to request clarification on the

intended function of containment internal structure relative to radiation shielding as described in

Section 3.8.3 of the VEGP UFSAR.

By letter dated February 27, 2008, the applicant confirmed that radiation shielding is an

intended function of concrete internal structures and was inadvertently omitted from Table 2.4.1.

By letter dated March 20, 2008, the applicant amended the LRA to add radiation shielding to

Table 2.4.1 and Table 3.5.2-1. Therefore, the staff finds the applicant's response related to the

intended function of the internal structures acceptable.

LRA Table 2.4.1 lists the Equipment Hatch and Personnel Airlocks as Containment components

subject to an AMR. By letter dated January 28, 2008, the staff issued RAI 2.4.1-6 to request the

applicant to confirm that the hatch locks, hinges and closure mechanisms, that help prevent loss

of sealing/leak-tightness for these listed hatches, are included in the scope of license renewal

and subject to an AMR.

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By letter dated February 27, 2008, the applicant responded to RAI 2.4.1-6, stating that the

locks, hinges and closure mechanisms for the containment hatches and locks are active

components and are not subject to an AMR. In a subsequent telephone conference, as

summarized in a letter from D. J. Ashley (NRC) to Southern Nuclear Operating Company dated

March 26, 2008, the applicant agreed to update the LRA Table 3.5.1 to delete "active

component" discussion of Item 3.5.1-17. By letter dated March 20, 2008, the applicant amended

the LRA stating that the locks, hinges and closure mechanisms are subject to an AMR under

VEGP 10 CFR 50 Appendix J program along with the host components. Considering the above,

the staff finds the applicant's response to RAI 2.4.1-6 acceptable.

By letter dated January 28, 2008, the staff issued RAI 2.4.1-7 to request the applicant to confirm

that the channel/angle shrouds that have been used at the liner welded joints (including those at

penetrations) are considered in-scope components and subject to an AMR.

By letter dated February 27, 2008, the applicant confirmed that all items welded to the concrete

side of the liner or welded to the interior face of the liner are included in the scope of license

renewal for VEGP and subject to an AMR. Therefore, the staff finds the applicant's response to

RAI 2.4.1-7 acceptable.

Section 3.8.2.1.4 of the VEGP UFSAR discusses the isolation valve encapsulation vessel

assemblies. These vessels and their respective supports/anchorages were not specifically listed

in Table 2.4.1 as in-scope components and subject to an AMR. By letter dated January 28,

2008, the staff issued RAI 2.4.1-8 to request the applicant to confirm that the isolation valve

encapsulation vessel assemblies and their supports/anchorages are screened-in and subject to

an AMR.

By letter dated February 27, 2008, the applicant provided clarification and confirmed that the

isolation valve encapsulation vessel assemblies are in scope and are included in Table 2.3.2.1

and their supports/anchorages are also in scope and are included in Table 2.4.2. Considering

that the encapsulation vessel assemblies and their supports are considered in the scope of

license renewal for VEGP and subject to an AMR, the staff finds the applicant's response to RAI

2.4.1-8 acceptable.

The insulation and cooling system provided to limit the inside face temperature of primary shield

wall and reactor cavity to 150OF are described in Section 3.8.3.4.4 of the VEGP UFSAR. By

letter dated January 28, 2008, the staff issued RAI 2.4.1-9 to request the applicant to confirm

that the insulation and cooling system described in Section 3.8.3.4.4 of the VEGP UFSAR have

been considered in the scope of license renewal and subject to an AMR.

By letter dated February 27, 2008, the applicant provided clarification and confirmed that the

insulation installed on the reactor vessel, reactor coolant system piping, and other components

inside the containment building with high operating temperatures is credited for reducing the

thermal loading inside the containment building, including thermal loading of the primary shield

wall and reactor cavity. The applicant also stated that the cooling systems provided to limit the

inside face temperature of primary shield wall and reactor

cavity consist of the Containment Building Cavity Cooling System and the Containment Building

Reactor Support Cooling System.

By letter dated March 20, 2008, the applicant amended the LRA to update Sections 2.3.3.13

and 2.3.3.31 of the LRA to include clarification relative to the criterion 10 CFR 54.4(a)(2)

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in-scope function of insulation and cooling system provided to limit the inside face temperature

of the primary shield wall and reactor cavity to 1501F.

Considering the applicant's clarifications and the LRA updates, the staff finds the applicant's

response to RAI 2.4.1-9 acceptable.

By letter dated January 28, 2008, the staff issued RAI 2.4.1-10 to determine whether the

equipment hatch concrete external shield door is considered in the scope of license renewal

and subject to an AMR.

By letter dated February 27, 2008, the applicant provided the response to RAI 2.4.1-10 and

stated that the equipment hatch concrete external shield door is in-scope and subject to an

AMR. By letter dated March 20, 2008, the applicant amended the LRA to update Table 2.4.1

and Table 3.5.2-1 to add the equipment hatch concrete external shield door as a component

subject to an AMR. Therefore, the staff finds the applicant's response to RAI 2.4.1-10

acceptable.

According to VEGP UFSAR Section 2.4.12.1.3.1, ground water is the primary source of supply

for reactor cooling water makeup, normal makeup to the nuclear service cooling towers, and fire

protection. By letter dated January 28, 2008, the staff issued RAI 2.4.1-11 to request the

applicant to provide justification for the exclusion of makeup water wells from the scope of

license renewal.

By letter dated February 27, 2008, the applicant provided its response to RAI 2.4.1-11 and

stated that the Plant Makeup Well Water System is a non-safety related system that does not

perform any safety related functions, nor can failure of this system prevent any safety related

system from performing its functions. In addition, the applicant stated that the non-safety related

Plant Makeup Well Water System is not in scope for supporting the Fire Protection System

because the 10 CFR 54.4(a)(2) criteria do not apply to non-safety related systems or

components which support other non-safety related systems or components. Based on the

above, the applicant concluded that the Plant Makeup Well Water System does not perform any

functions that meet the criteria of 10 CFR 54.4(a)(1), 10 CFR 54.4(a)(2) or 10 CFR 54.4(a)(3)

and is not in the scope of license renewal.

In a'subsequent telephone conference, as summarized in a letter from D. J. Ashley (NRC) to

Southern Nuclear Operating Company, Inc., dated March 26, 2008, further discussion with the

applicant provided clarification that although the VEGP UFSAR Section 2.4.12.1.3.1 states that

the Plant Makeup Well Water System is the primary source of supply for fire protection, the fire

water storage tanks are credited as the sources of water for the fire protection system. As

discussed in NUREG 1800, Table 2.1-2, for 10 CFR 54.4(a)(3), a second level support system

(i.e., Plant Makeup Well Water System) need not be considered in the scope of license renewal.

Considering the above, the staff finds the applicant's response to RAI 2.4.1-11 acceptable.

Section 2.4.1 of the LRA discusses Jib cranes inside the containment structures. By letter dated

January 28, 2008, the staff issued RAI 2.4.1-12 to request the applicant to confirm

that the support anchorages and mechanical components of Jib cranes are in-scope and

subject to an AMR.

By letter dated February 27, 2008, the applicant responded to RAI 2.4. 1-12 and confirmed that

the Jib cranes and associated passive components are included in Table 2.4.12 ID 21

'Miscellaneous Cranes including Monorails' and support anchorages are included in Table

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2.4.12 ID 35 'Supports for EDGs, HVAC Components, and Misc. Mechanical Equipment:

Support Members, Welds, Bolted Connections, Support Anchorages to Building Structure.'

Considering that the Jib cranes, support anchorages and other passive components of Jib

cranes inside the containment structures are included in the scope of the LRA and subject to an

AMR, the staff finds the applicant's response to RAI 2.4.1-12 acceptable.

2.4.1.3 Conclusion

The staff reviewed the LRA, UFSAR, and RAI responses to determine whether the applicant

failed to identify any SCs 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 containment 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).

2.4.2 Auxiliary, Control, Fuel Handling, and Equipment Buildings

2.4.2.1 Summary of Technical Information in the Application

LRA Section 2.4.2 describes the auxiliary, control, fuel-handling, and equipment buildings,

which include the following structures:

* auxiliary building

* control building

* fuel-handling building

* equipment buildings

These adjacent structures form a common complex that adjoins the containment buildings.

The auxiliary building is a seven-story reinforced concrete seismic Category I structure common

to both plant units located south of the fuel-handling building and containment structures. Three

stories are above grade, four subterranean. There are two penetration areas, one, on the south

side of each containment. All auxiliary building columns, slabs, and structural walls are of

reinforced concrete. The roof is a reinforced concrete slab with a minimum thickness of two feet.

The auxiliary building structure is founded on a mat continuous over the plan of the building.

The auxiliary building houses major safety-related and nonsafety-related plant facilities (e.g.,

CVCS, ECCS, RHR system, HVAC facilities) and other equipment.

A number of access openings are sealed with removable concrete block wall units of short

height for radiation shielding and maintenance purposes held in place by structural elements

(e.g., steel angle or steel beams).

The control building is a six-story, deeply-embedded, reinforced concrete structure common to

both plant units situated north of and adjacent to the fuel-handling and the two containment

buildings. It is supported on a mat foundation 40 feet below grade. The boxlike center section

has three upper levels extending to 60 feet above grade. A partial fourth level extends an

additional 20 feet. Penetration areas east and west of the center section for access to the two

containment buildings are the primary areas for routing of electrical and control system cables

into the containment. Directly north of each containment building is a main steam isolation valve

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room which extends 40 feet above grade. The control room and technical support center

principally occupy the level at grade. The levels, immediately above and below grade, house the

cable spreading rooms. The lowest level houses the switchgear and HVAC equipment. The third

and fourth floors mainly contain HVAC equipment, while the fourth floor is primarily occupied by

nonsafety-related components.

The fuel-handling building is a five-story, boxlike, reinforced concrete structure, common to both

plant units, completely surrounded by other Category I buildings and located between the two

containment structures. The fuel storage facility part of the fuel-handling building consists of the

new fuel storage area, spent fuel pool (including the structure, liner, and fuel storage racks), fuel

transfer canal, cask storage area, cask washdown area, and rooms for supporting equipment.

Each nuclear unit has a separate but connected spent fuel pool approximately 41 feet deep,

constructed of reinforced concrete, and lined with a stainless steel plate. The spent fuel pool is

for underwater storage of spent fuel assemblies after their removal from the reactor. New fuel

may be moved from the new fuel racks to the spent fuel racks in preparation for a refueling

outage.

The fuel transfer canal is an intermediate handling area, connected to the refueling canal inside

containment by the fuel transfer tube, which is evaluated as part of the containment structures.

The fuel transfer canal may be drained for fuel handling equipment service or flooded for fuel

handling. The cask storage area is a location for shipping casks to be loaded. The isolated cask

wash area is for cleaning and decontamination of shipping casks. Adjacent rooms house the

spent fuel cooling and cleanup system equipment that cools and purifies the spent fuel pool

water. The fuel-handling building's overhead and refueling load handling cranes are evaluated

in Section 2.3.3.3.

The equipment building is not a distinct structure but composed of portions of the control and

fuel-handling buildings. The equipment building partially surrounding (approximately three

quadrants) the containment building is a seismic Category II structure, designed, however, to

seismic Category I requirements to preclude any safety impact on the safety-related equipment

in the control and fuel-handling buildings. The primary function of the equipment building is to

support nonsafety-related HVAC equipment.

The auxiliary, control, fuel-handling, and equipment buildings contain safety-related components

relied upon to remain functional during and following DBEs. The failure of nonsafety-related SCs

in the auxiliary, control, fuel-handling, and equipment buildings potentially could prevent the

satisfactory accomplishment of a safety-related function. In addition, the auxiliary, control, fuelhandling, and equipment buildings perform functions that support fire protection, ATWS, and

SBO.

LRA Table 2.4.2 identifies auxiliary, control, fuel-handling, and equipment buildings component

types within the scope of license renewal and subject to an AMR.

2.4.2.2 Staff Evaluation

The staff reviewed LRA Section 2.4.2 using the evaluation methodology described in SER

Section 2.4 and the guidance in SRP-LR Section 2.4.

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

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results for auxiliary, control, fuel-handling and equipment buildings. Therefore, the staff issued

an RAI by letter dated January 28, 2008, to determine whether the applicant properly applied

the scoping criteria of 10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21 (a)(1). The

following discussion describes the staff's RAI related to the LRA Section 2.4.2 and the

corresponding applicant response.

By letter dated January 28, 2008, the staff issued RAI 2.4.2-1 to confirm that the leak chase

system for the spent fuel pool liner is in-scope and subject to an AMR.

By letter dated February 27, 2008, the applicant provided its response to RAI 2.4.2-1 and

confirmed that the leak chase system for the spent fuel pool liner is in the scope of license

renewal for VEGP and subject to an AMR. Therefore, the staff finds the applicant's response to

RAI 2.4.2-1 acceptable.

2.4.2.3 Conclusion

The staff reviewed the LRA, UFSAR and RAI response to determine whether the applicant

failed to identify any SCs 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 auxiliary, control, fuel handling, and equipment

buildings 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).

2.4.3 Emergency Diesel Generator Structures

2.4.3.1 Summary of Technical Information in the Application

LRA Section 2.4.3 describes the EDG structures, which include the diesel generator buildings

and diesel fuel storage tank pump houses. Each diesel generator building and its proximate

diesel fuel storage tank pump houses support EDG operation.

The diesel generator buildings (one for each unit) are rectangular, reinforced! concrete, seismic

Category I structures designed to withstand various combinations of loads defined in the

UFSAR. Each bay houses a diesel generator and air-handling, exhaust, and silencing

equipment. The building's primary function is to house the diesel generators needed to supply

emergency onsite power in a loss of offsite power.

The diesel fuel storage tank pump houses (two for each unit) are seismic Category I structures

that shelter the pumps and valves for the buried diesel fuel oil storage tanks supplying the

EDGs and house the nozzles, gages, drains, and pump mount systems. The reinforced

concrete pump houses straddle the tanks and extend three feet above grade except for a

common entry between each pair of pump houses extending 14 feet above grade. Each pump

house foundation consists of wall strip footings. The pump houses are boxlike with work space

levels above the top of the tanks.

The EDG structures contain safety-related components relied upon to remain functional during

and following DBEs. The failure of nonsafety-related SCs in the EDG structures potentially could

prevent the satisfactory accomplishment of a safety-related function. In addition, the EDG

structures perform functions that support fire protection and SBO.

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LRA Table 2.4.3 identifies EDG structures component types within the scope of license renewal

and subject to an AMR.

2.4.3.2 Staff Evaluation

The staff reviewed LRA Section 2.4.3 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 delineated under 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 and UFSAR to determine whether the applicant failed to identify any

SCs within the scope of license renewal. The staff finds no such omissions. In addition, the

staffs 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 EDG 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).

2.4.4 Turbine Building

2.4.4.1 Summary of Technical Information in the Application

LRA Section 2.4.4 describes the turbine building, a nonsafety-related, seismic Category II

structure that houses all main turbine-generator equipment including the main condenser and

other power-generation and auxiliary equipment.

Steel-framed and enclosed with a reinforced concrete roof and metal siding, the turbine building

is a trussed rigid-frame structure above the turbine deck level; below, the frames are braced to

reduce side sway. The building has three floors of reinforced concrete or steel grating and a

basement. The building mat foundation also supports the turbine pedestal.

The turbine-generator pedestal supports the turbine-generator unit. The pedestal, designed to

withstand operating and emergency loading forces including seismic disturbances and machine

imbalance, consists of a reinforced concrete deck on columns attached to a basemat. Also part

of the turbine building is the elevated electrical bridge structure between the main structure and

the control building.

The turbine building and the electrical bridge structure are in close proximity to safety-related

structures. In addition, the failure of nonsafety-related SCs in the turbine building could

potentially prevent the satisfactory accomplishment of a safety-related function. The turbine

building also performs functions that support ATWS and SBO.

LRA Table 2.4.4 identifies the turbine building component types within the scope of license

renewal and subject to an AMR.

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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 of LRA Section 2.4.4, the staff identified areas in which additional information

was necessary to complete the evaluation of the applicant's scoping and screening results for

the turbine building. Therefore, the staff issued its RAIs by letter dated January 28, 2008, to

determine whether the applicant properly applied the scoping criteria of 10 CFR 54.4(a) and the

screening criteria of 10 CFR 54.21(a)(1). The following discussion describes the staff's RAIs

related to the LRA Section 2.4.4 and the corresponding applicant responses.

By letter dated January 28, 2008, the staff issued RAI 2.4.4-1 to request the applicant to provide

justification for excluding the turbine pedestal from the scope of license renewal. In addition,

considering the plant's current licensing basis, the applicant was requested to discuss the

ATWS and SBO systems/components identified in Section 2.4.4 and their spatial interaction

with the turbine pedestal.

By letter dated February 27, 2008, the applicant provided the following response to RAI 2.4.4-1.

An integral foundation system is provided for both turbine building and the turbine pedestal. The

turbine generator pedestal is isolated from the turbine building structure above the foundation.

The turbine building is in scope because of its proximity to Class I structures. Cascading effects

of the turbine pedestal on the main turbine building is not required to be considered. Therefore,

the turbine pedestal is not in the scope of license renewal. However, the turbine pedestal is in

scope under maintenance rule and inspected under the Structural Monitoring Program.

Some of the raceways and supports for the turbine impulse input signal to the AMSAC system

and the output signal to the turbine trip solenoids that are mounted to the turbine pedestal are

within the scope of license renewal. As per NUREG-1 800 for 10 CFR 54.4(a)(3), an applicant

need not consider second level support systems. This condition does not need the turbine

pedestal to be included in scope of license renewal because as per NUREG-1800 for

10 CFR 54.4(a)(3), an applicant need not consider second level support systems.

Considering that, under the current VEGP licensing basis, the interaction between the turbine

pedestal and turbine building is not required to be evaluated. The turbine pedestal is currently

inspected under the Structural Monitoring Program, and as discussed in NUREG-1800, Table

2.1-2, for 10 CFR 54.4(a)(3); a second level support system (i.e., turbine pedestal) need not be

considered in the scope of license renewal, and as such, the staff finds the applicant's response

to RAI 2.4.4-1 acceptable.

In RAI 2.4.4-2, dated January 28, 2008, the staff requested the applicant to provide justification

for excluding the turbine building bridge crane from the scope of license renewal.

By letter dated February 27, 2008, the applicant provided the response to RAI 2.4.4-2 and

stated that the turbine building bridge crane is in a seismic Category II structure and does not

have a license renewal intended function. The applicant also referred to the response to RAI

2.1-2. In RAI 2.1-2, the staff requested that the applicant provide the rational and basis for not

including nonsafety-related SCs in the vicinity of safety-related SCs in the turbine building within

the scope of license renewal. In response to RAI 2.1-2, the applicant provided! justification that

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while VEGP conservatively classified a number of components in the turbine building as safetyrelated, these components are either strictly anticipatory, perform no safety function, or are not

credited in the accident analysis. As such, the provisions of 10 CFR 54.4(a)(2) do not apply and

no other components in the turbine building are considered in the scope of license renewal.

Since the components in the turbine building are either anticipatory, perform no safety function

and are not credited in the accident analysis, the staff finds the exclusion of the turbine building

bridge crane from the scope of license renewal acceptable.

2.4.4.3 Conclusion

The staff reviewed the LRA, UFSAR, and RAI responses to determine whether the applicant

failed to identify any SCs within the scope of license renewal. The staff finds no such omissions.

In addition, the staffs 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 turbine 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 Tunnels and Duct Banks

2.4.5.1 Summary of Technical Information in the Application

LRA Section 2.4.5 describes the tunnels and duct banks, which include mechanical piping

tunnels, electrical cable tunnels, duct banks, and valve and pull boxes. The radwaste transfer

tunnel is not evaluated in this structures grouping but as part of the radwaste structures

grouping in Section 2.4.10 of the LRA.

The Category I tunnels within the scope of license renewal consist of main steam, NSCW,

diesel generator piping, diesel generator electric, AFW, turbine electric, and electric steam

boiler tunnels. The main steam and electric steam boiler tunnels are designed to seismic

Category I criteria and for pipe break loads due to their proximity to, and required interface with

other seismic Category I structures; however, the design did not have to consider the effects of

tornado missiles.

The Category I box-like, reinforced concrete tunnels are buried either completely or with roofs

exposed at or near grade level and house piping and electrical trays. The main steam tunnel

roof is mainly grating instead of concrete for venting in the event of postulated pipe breaks. The

auxiliary feedwater tunnels are covered with removable concrete slabs that are bolted down to

prevent them from becoming missiles in a postulated AFW line break. The underground

electrical duct banks for safety-related electrical cables to and from safety-related buildings and

equipment are rectangular reinforced concrete structures poured in place around PVC conduit.

Also included are nonsafety-related duct runs for SBO (e.g., for the high-voltage switchyard).

Rectangular reinforced concrete valve boxes and pull boxes with steel or aluminum covers for

safety-related boxes and aluminum covers for nonsafety-related boxes are located strategically

for above-ground access to isolation valves and to cables in buried piping and cable runs routed

through the pull boxes to appropriate duct banks.

The tunnels and duct banks contain safety-related components relied upon to remain functional

during and following DBEs. The failure of nonsafety-related SCs in the tunnels and duct banks

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potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the tunnels and duct banks perform functions that support fire protection, ATWS, and

SBO.

LRA Table 2.4.5 identifies tunnels and duct banks component types within the scope of license

renewal and subject to an AMR.

2.4.5.2 Staff Evaluation

The staff reviewed LRA Section 2.4.5 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

SOs with intended functions delineated under 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).

2.4.5.3 Conclusion

The staff reviewed the LRA and UFSAR to determine whether the applicant failed to identify any

SCs 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 tunnels and duct banks 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 Nuclear Service Cooling Water Structures

2.4.6.1 Summary of Technical Information in the Application

LRA Section 2.4.6 describes the NSCW structures, which include the NSCW cooling towers and

NSCW valve houses and consist of four NSCW cooling towers (two per reactor unit) and their

valve houses. The NSCW structures are seismic Category I safety-related structures designed

to withstand the load combinations defined in the UFSAR. The NSCW towers and valve houses

support and protect the appropriate NSCW system components during normal plant operation

and shutdown conditions as well as during earthquakes, extreme wind, tornadoes, and other

abnormal conditions of postulated accidents. The NSCW towers are relied upon as the ultimate

heat sink to support normal operation, safe shutdown, and post-accident heat loads.

Each NSCW cooling tower, comprised of a cooling tower superstructure and a below-grade

storage basin, is a reinforced concrete cylindrical shell with a concrete basemat, flat roof deck

and supported on a 9-foot thick circular mat foundation.

The NSCW valve house next to each NSCW tower is a transition structure which protects the

piping, valves, and electrical supply running from the NSCW tunnels into the tower. The valve

houses are irregularly-shaped reinforced concrete structures with roofs approximately 14 feet

above and basemat tops approximately 14 feet below grade to match the NSCW tunnels. The

NSCW valve house is supported on a 6-foot thick mat foundation.

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The NSCW structures contain safety-related components relied upon to remain functional

during and following DBEs. The failure of nonsafety-related SCs in the NSCW structures could

potentially prevent the satisfactory accomplishment of a safety-related function. In addition, the

NSCW structures perform functions that support fire protection.

LRA Table 2.4.6 identifies NSCW structures component types within the scope of license

renewal and subject to an AMR.

2.4.6.2 Staff Evaluation

The staff reviewed LRA Section 2.4.6 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 delineated under 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).

2.4.6.3 Conclusion

The staff reviewed the LRA and UFSAR to determine whether the applicant failed to identify any

SCs 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 NSCW 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).

2.4.7 Concrete Tank And Valve House Structures

2.4.7.1 Summary of Technical Information in the Application

LRA Section 2.4.7 describes the concrete tank and valve house structures, which include the

condensate storage tanks and valve houses, reactor makeup water storage tanks, and RWST.

Each unit has two dedicated condensate storage tanks, one reactor makeup water storage tank,

and one RWST.

The condensate storage tank is a seismic Category I, safety-related, 480,000-gallon capacity,

cylindrical, reinforced concrete shell. Each pair of condensate water storage tanks has a

common reinforced concrete valve house protecting piping and equipment from missiles and

supported by a combined foundation mat. Perimeter dikes for retention of spilled water are

constructed of reinforced concrete integral to the basemat. The condensate storage tank

supplies condensate water for the AFW system and for normal make-up and supply to the

condenser hot well.

The reactor make-up water storage tank is a seismic Category I, safety-related, 165,000-gallon

capacity, cylindrical, reinforced concrete shell supported by a basemat foundation at grade.

Tank perimeter dikes for retention of spilled water are constructed of reinforced concrete

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integral to the basemat. The reactor make-up water storage tank supplies the RCS makeup

water.

The RWST is a seismic Category I, safety-related, 715,500-gallon capacity, cylindrical,

reinforced concrete shell supported by a basemat foundation at grade. Perimeter dikes for the

retention of spilled water, constructed of reinforced concrete, are integral portions of the

basemat.

The RWST is designed to hold enough dilute boric acid solution to fill the refueling canal prior to

refueling operations and to provide injection water to support emergency core cooling and

containment spray functions.

The concrete tank and valve house structures contain safety-related components relied upon to

remain functional during and following DBEs. The failure of nonsafety-related SCs in the

concrete tank and valve house structures could potentially prevent the satisfactory

accomplishment of a safety-related function. In addition, the concrete tank and valve house

structures perform functions that support fire protection, ATWS, and SBO.

LRA Table 2.4.7 identifies concrete tanks and valve house structures component types within

the scope of license renewal and subject to an AMR.

2.4.7.2 Staff Evaluation

The staff reviewed LRA Section 2.4.7 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 delineated under 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).

2.4.7.3 Conclusion

The staff reviewed the LRA and UFSAR to determine whether the applicant failed to identify any

SCs 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 concrete tank and valve house 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).

2.4.8 Switchyard Structures

2.4.8.1 Summary of Technical Information in the Application

LRA Section 2.4.8 describes the switchyard structures, which include the high-voltage and the

low-voltage switchyards. The high-voltage switchyard is the connection point for the off-site

transmission and generator output lines and for the feeds to the unit startup transformers. The

high-voltage switchyard electrical installation connects two preferred power sources from the

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offsite transmission lines to the transformer yards as required per 10 CFR Part 50 Appendix A

General Design Criterion 17. The high-voltage switchyard structures include a switch house with

the primary functions of relieving space congestion in the main control room and locating the

switchyard relay panels close to their equipment. The switch house also stores other switchyard

equipment.

The low-voltage switchyard adjacent to the turbine building is where the main power, unit

startup, and unit auxiliary transformers are located. The low-voltage switchyard electrical

installation connects the high-voltage switchyard to the plant. The high- and low-voltage

switchyards are connected by both overhead and underground cables.

The switchyard structures perform functions that support SBO.

LRA Table 2.4.8 identifies switchyard structures component types within the scope of license

renewal and subject to an AMR.

2.4.8.2 Staff Evaluation

The staff reviewed LRA Section 2.4.8 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 delineated under 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).

2.4.8.3 Conclusion

The staff reviewed the LRA and UFSAR to determine whether the applicant failed to identify any

SCs 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 switchyard 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).

2.4.9 Fire Protection Structures

2.4.9.1 Summary of Technical Information in the Application

LRA Section 2.4.9 describes the fire protection structures, which include the fire water

pumphouse and the structural support feature of the fire water storage tanks.

The primary function of the fire pumphouse is to house conventional fire protection water pumps

for extinguishing fires. The fire water pumphouse provide structural support, fire barrier

separation, and environmental protection for the fire pumps and their auxiliary components.

Only the fire protection features, including fire-rated block walls, equipment pedestals, and the

concrete building foundation are within the scope of license renewal.

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There are two fire water pumphouses, No. 1 with one electric motor-driven fire pump and one

electric motor-driven jockey pump and No. 2 with two diesel-driven fire pumps and one electric

motor-driven jockey pump. The floor slab, perimeter footing, and equipment block pads consist

of a reinforced concrete mat slab. The one-story concrete masonry buildings have steel-framed

concrete roofs supported by steel decking.

The fire water storage tank foundations support two separate fire water storage tanks. The

boundary includes a reinforced concrete ring beam and a mat of oiled sand inside the ring beam

and underneath the bottom of the tanks. Two 300,000-gallon fire water storage tanks are

adjacent to the fire water pumphouses. The fire protection tanks are vertically cylindrical, flatbottom tanks made of steel plate.

The failure of nonsafety-related SCs in the fire protection structures could potentially prevent the

satisfactory accomplishment of a safety-related function. The fire protection structures also

perform functions that support fire protection.

LRA Table 2.4.9 identifies fire protection structures component types within the scope of license

renewal and subject to an AMR.

2.4.9.2 Staff Evaluation

The staff reviewed LRA Section 2.4.9 using the evaluation methodology described in SER

Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review of the LRA Section 2.4.9, the staff identified areas in which additional

information was necessary to complete the evaluation of the applicant's scoping and screening

results for the fire protection structures. Therefore, the staff issued its RAI by' letter dated

January 28, 2008 to determine whether the applicant properly applied the scoping criteria of

10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21(a)(1).

The following discussion describes the staff's RAI related to the LRA Section 2.4.9 and the

corresponding applicant response.

By letter dated January 28, 2008 the staff issued RAI 2.4.9-1 to request the applicant to provide

information relative to proximity (spatial interaction) of the demineralized water storage tank and

the electrical fire pump house No. I considering the current VEGP licensing basis.

By letter dated February 27, 2008, the applicant provided its response to RAI 2.4.9-1 and stated

that the Fire Protection System components contained in electrical fire pump house No. 1,

including the pump house structure, are non-safety related components that are in scope for

license renewal for 10 CFR 54.4(a)(3) criteria. The non-safety related Demineralized Water

Storage Tank is not in scope for 10 CFR 54.4(a)(2) spatial interaction criteria relative to

electrical fire pump house No. 1 because those criteria do not apply to non-safety related

systems or components which could affect other nonsafety-related systems or components.

In its response, the applicant provided clarification and confirmed that within the current VEGP

licensing basis the spatial interaction between nonsafety-related SCs which could affect other

nonsafety-related SCs need not be considered. Therefore, the staff finds the applicant's

response to RAI 2.4.9-1 acceptable.

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2.4.9.3 Conclusion

The staff reviewed the LRA, UFSAR, and RAI response to determine whether the applicant

failed to identify any SCs 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 fire protection 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 Radwaste Structures

2.4.10.1 Summary of Technical Information in the Application

LRA Section 2.4.10 describes the radwaste structures, which house equipment and provide

space for processing, packaging, and storage of radioactive wastes generated in normal plant

operation. The radwaste structures in the scope of license renewal include the following:

* radwaste transfer tunnel

* radwaste transfer building

* dry active waste warehouse

• dry active waste processing facility

* radwaste processing facility

* alternate radwaste building

The DAW buildings consist of processing and storage buildings located in the southwest portion

of the owner-controlled area. These metal-siding buildings, supported on base slabs, have

precast concrete panels and concrete masonry walls for shielding. The roofs are metal panels

supported by steel beams. The processing building houses equipment for processing dry waste

and the storage building stores it for offsite shipment. The grade elevation is above that required

for natural flood protection. Curbs and ramps in radioactive areas are provided to contain water

from fire sprinkler actuation.

The radwaste processing facility, located between the solidification and the field support

buildings, is a concrete building supported on a slab to house process equipment for handling

radioactive liquids, resins, and filters. The facility has a subterranean demineralizer vault,

subterranean high-integrity container storage vaults, a rollup door for a truck bay, and a 40-ton

bridge crane to service equipment. The slab and shield walls inside the building are designed to

retain radioactive liquids.

The alternate radwaste building and its systems and equipment were designed to process liquid

and solid waste without utilizing the solidification systems and evaporators of the original plant

design. This metal-siding building, which formerly housed the liquid radwaste systems, is

supported on a base slab. The building basemat has curbing to retain radioactive liquid. It

contains a demineralizer vault, high-integrity container system storage vault, laydown area, and

a truck-trailer loading bay. Allotted areas are for staging process shields and process skids.

The radwaste transfer building has two-stories with the basemat located at grade. This building

and the radwaste transfer tunnel are no longer in service and abandoned in place; however, the

radwaste transfer building has a fire damper on the fire-rated west wall credited with preventing

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smoke and fire from entering the auxiliary building through the radwaste transfer tunnel, and

other fire protection equipment with its supports is also in this building.

The reinforced-concrete radwaste transfer tunnel connects the auxiliary, radwaste transfer, and

radwaste solidification buildings and houses pipes for transferring liquid and slurry wastes to the

radwaste solidification building (which is abandoned in place), pipes for related services, and a

walkway for access. Though the radwaste transfer tunnel is abandoned in place, a portion of it

is within the scope of license renewal because of the fire protection and electrical components

for fire protection that pass through it. Conservatively, the tunnel from the auxiliary building to

the entrance of the radwaste transfer building (concrete structure and fire protection supports)

and south end of the tunnel (support for in-scope electrical commodities only) are within the

scope of license renewal.

The radwaste structures perform functions that support fire protection.

LRA Table 2.4.10 identifies radwaste structures component types within the scope of license

renewal and subject to an AMR.

2.4.10.2 Staff Evaluation

The staff reviewed LRA Section 2.4.10 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 delineated under 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).

2.4.10.3 Conclusion

The staff reviewed the LRA and UFSAR to determine whether the applicant failed to identify any

SCs 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 radwaste 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).

2.4.11 Auxiliary Feedwater Pumphouse Structures

2.4.11.1 Summary of Technical Information in the Application

LRA Section 2.4.11 describes the AFW pumphouse structures, including the AFW pumps and

auxiliary support systems. The AFW pumphouse is a seismic Category I, safety-related

structure.

The one-story, rectangular, reinforced concrete AFW pumphouses (one for each unit) extend 22

feet above grade and are supported on basemat foundations four feet below grade. Four interior

walls separate the steam- and electric-driven pumps. Roof hatches allow pump access.

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Separation walls between pumps and tanks guard against fire, flooding, and heat.

The AFW pumphouse structures contain safety-related components that are relied upon to

remain functional during and following DBEs. The failure of nonsafety-related SCs in the AFW

pumphouse structures could potentially prevent the satisfactory accomplishment of a

safety-related function. In addition, the AFW pumphouse structures perform functions that

support fire protection, ATWS, and SBO.

LRA Table 2.4.11 identifies AFW pumphouse structures component types within the scope of

license renewal and subject to an AMR.

2.4.11.2 Staff Evaluation

The staff reviewed LRA Section 2.4.11 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 delineated under 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).

2.4.11.3 Conclusion

The staff reviewed the LRA and UFSAR to determine whether the applicant failed to identify any

SCs 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 auxiliary feedwater pumphouse 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).

2.4.12 Component Supports and Bulk Commodities

2.4.12.1 Summary of Technical Information in the Application

LRA Section 2.4.12 describes the component supports and bulk commodities, which include the

following:

" electrical raceway supports

* HVAC duct supports

" pipe supports

* pipe whip restraints

" raceway system

* miscellaneous cranes and hoists

There are physical interfaces with the structure, system, or component supported and with the

building structural element anchoring the support. A primary function of a support is to provide

anchorage for DBEs so the supported element can perform its intended function. Items within

the scope of license renewal include support members, welds, bolted connections, anchorage

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(including base plate and grout) to the building structure, spring hangers, guides, and building

concrete at bolt/anchorage locations.

The major RCS component group includes the supports and support anchorage for ASME Code

class piping and components like pumps and heat exchangers. Components evaluated in this

group include support structural members (e.g., welds, bolting) that comprise the interface

between the structure and the mechanical component. The reactor pressure vessel is supported

by four seats under two hot leg and two cold leg nozzles spaced approximately 90 0 apart in the

primary shield wall. The support seats carry the vertical loads to the embedded steel welds

under each support, while the embedded steel welds in the primary shield wall carry the radial

and tangential loads.

Four steel columns vertically support the steam generator. Bearing blocks and a steel beam

spanning the inside of the walls supply a lower lateral component support. The upper lateral

component support consists of a bearing ring located near the steam generator center of

gravity.

Each reactor coolant pump support consists of three structural steel columns and lateral tie

rods. A steel ring bearing plate bolted to the flange of the pressurizer support skirt supports the

pressurizer. This ring rests in turn on a structural steel frame attached to steel embeds in the

pressurizer compartment walls. Four stops projecting from embeds within the pressurizer

compartment walls also support the pressurizer laterally at an upper level.

For supports and support anchorage for cable trays, conduits, HVAC ducts, tube track, and

instrument tubing components evaluated include cable trays, conduits, HVAC ducts, and their

structural support members, welds, bolting, etc., comprising the interface between the structure

and the mechanical, electrical, or instrument component.

For supports and support anchorage for enclosures of various types that contain and support

electrical equipment components evaluated include support structural members, welds, bolting,

etc., comprising the interface between the structure and the electrical or instrument component.

For supports and support anchorage for equipment not addressed in previous groups (e.g.,

diesel generators, HVAC fans), components evaluated include support structural members,

welds, bolting, etc., comprising the interface between the structure and the component.

For structure and anchorage for miscellaneous support structures (e.g., platforms, pipe whip

restraints, and high energy line break barriers) not included in the other support categories,

component types include support structural members, welds, bolting, etc., comprising the

support structure and its anchorage.

The component supports and bulk commodities contain safety-related components that are

relied upon to remain functional during and following DBEs. The failure of nonsafety-related SCs

in the component supports and bulk commodities could potentially prevent the satisfactory

accomplishment of a safety-related function. In addition, the component supports and bulk

commodities perform functions that support fire protection, SBO, and EQ.

LRA Table 2.4.12 identifies component supports and bulk commodities within the scope of

license renewal and subject to an AMR.

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2.4.12.2 Staff Evaluation

The staff reviewed LRA Section 2.4.12 using the evaluation methodology described in SER

Section 2.4 and the guidance in SRP-LR Section 2.4.

During its review of the Section 2.4.12, the staff identified areas in which additional information

was necessary to complete the evaluation of the applicant's scoping and screening results for

component supports and bulk commodities. Therefore, the staff issued its RAI by letter dated

January 28, 2008, to determine whether the applicant properly applied the scoping criteria of

10 CFR 54.4(a) and the screening criteria of 10 CFR 54.21 (a)(1). The following discussion

describes the staff's RAI related to LRA Section 2.4.12 and the corresponding applicant

response.

By letter dated January 28, 2008, RAI 2.4.12-1 was issued to request the applicant to confirm

whether the following items are considered in the scope of license renewal:

Grout pads for building structural column base plates

Vibration isolators

Floor and wall embedded plates/anchorages for RCS primary equipment

Fluid containment curbs/walls/dikes

Waterproofing membrane in general

Any other hoists or lifting devices (e.g. Reactor Vessel Head Lifting Device,

Reactor Internals Lifting Device)

Relevant subcomponents of crane (bridge, trolley, rails/hardware, girders)

All cranes within in-scope structures

By letter dated February 27, 2008, the applicant responded to RAI 2.4.12-1 and stated that

grout pads for building structural column base plates, floor and wall embedded

plates/anchorages for RCS primary equipment, fluid containment curbs/walls/dikes,

waterproofing membrane, relevant crane sub-components (including bridge and trolley, crane

rail, fasteners and rail hardware, girders, etc.), and all the cranes within in-scope structures,

unless otherwise stated as not in scope (e.g., Turbine Building Overhead crane) are included in

the scope of license renewal. The applicant also stated that lifting devices are considered as

tools and rigging components and are not in the scope of license renewal. Furthermore, the

applicant stated that vibration isolators are not applicable to VEGP and in a subsequent

telephone conference, as summarized in a letter from D. J. Ashley (NRC) to Southern Nuclear

Operating Company, Inc. dated March 26, 2008, the applicant agreed to update LRA Section

2.4.12 to remove "vibration isolators" and to clarify that VEGP does not utilize vibration isolators.

The applicant, in the same telephone conference, also agreed to update the LRA Table 2.4.12

and Table 3.5.2-12 to change "roof membrane" to "waterproofing membrane." By letter dated

March 20, 2008, the applicant amended the LRA to include the above changes.

Considering the above, the staff finds the applicant's response to RAI 2.4.12-1 acceptable.

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2.4.12.3 Conclusion

The staff reviewed the LRA, UFSAR, and RAI response to determine whether the applicant

failed to identify any SCs 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 component supports and 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 Scopincq and Screening Results - Electrical and Instrumentation and Controls

Systems

This section documents the staff's review of the applicant's scoping and screening results for

electrical and instrumentation and controls (I&C) systems. Specifically, this section discusses:

scoping - plant-wide electrical

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

electrical and I&C system 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 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 delineated under 10 CFR 54.4(a). The staff also reviewed

the licensing basis documents to determine whether the LRA specified all intended functions

delineated under 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 (1) the functions are

performed with moving parts or a change in configuration or properties or (2) 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 omissions or discrepancies identified.

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2.5.1 Summary of Technical Information in the Application

LRA Section 2.5 describes the scoping - plant-wide electrical, the LRA designation grouping

electrical components into one system for scoping, screening, and AMR. This designation is not

a VEGP system, not found in the UFSAR, and strictly for convenience in presenting the results

of electrical AMRs. LRA Section 2.1.3.3 describes the methodology for identifying electrical and

I&C components requiring an AMR. Identification of component types of electrical and I&C

systems, mechanical systems, and civil structures within the scope of license renewal was

generic. In limited cases (e.g., restoration of offsite power following SBO) component type

identification and evaluation was not generic but limited to only the system portion within the

scope of license renewal. LRA Section 2.1.2.3.5 describes the evaluation boundaries of the

offsite power system for SBO.

During the scoping phase, the applicant determined that the following component types do not

meet 10 CFR 54.4(a) criteria:

Metal Enclosed Bus: A metal enclosed bus evaluation determined that VEGP has no metal

enclosed bus that supports any license renewal intended function.

Uninsulated Ground Conductors: Nonsafety-related uninsulated ground conductors bond metal

raceways, building structural steel, and plant equipment to earth ground through an installed

grounding grid and protect personnel and equipment. In the event of a fault in an electrical

circuit or component, the ground conductors provide a direct path to ground for fault currents to

minimize equipment damage. They do not prevent faults and are not required for equipment

operation. Failure of a ground conductor cannot affect any safety functions; therefore,

uninsulated ground conductors perform no intended function that meets 10 CFR 54.4(a) criteria

and are not within the scope of license renewal.

The in-scope electrical and I&C component types associated with the in-scope electrical and

I&C systems contain safety-related components relied upon to remain functional during and

following DBEs. The failure of nonsafety-related SCs in the scoping - plant-wide electrical

potentially could prevent the satisfactory accomplishment of a safety-related function. In

addition, the electrical component types perform functions that support fire protection, ATWS,

SBO, and EQ.

LRA Table 2.5.1 identifies electrical component types within the scope of license renewal and

subject to an AMR:

* cable connections (metallic parts) not subject to 10 CFR 50.49 EQ requirements

* conductor insulation for electrical cables and connections not subject to

10 CFR 50.49 EQ requirements

* conductor insulation for inaccessible medium-voltage cables not subject to

10 CFR 50.49 EQ requirements

* connector contacts for electrical connectors exposed to borated water leakage

not subject to 10 CFR 50.49 EQ requirements

* fuse holders (not parts of any larger assembly): insulation not subject to

10 CFR 50.49 EQ requirements

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fuse holders (not parts of any larger assembly): metallic clamps

high-voltage insulators

switchyard bus and connections

transmission conductors and connections

The intended functions of the electrical component types within the scope of license renewal

include:

insulation resistance to preclude shorts/grounds and unacceptable current

leakage

electrical conductor insulation from ground and support from the mounting

structure

electrical connections for delivery of voltage, current, or signals to specific

electric circuit sections

2.5.2 Staff Evaluation

The staff reviewed LRA Section 2.5 using the evaluation methodology described in the guidance

in SRP-LR Section 2.5, "Scoping and Screening Results: Electrical and Instrumentation and

Controls Systems."

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 delineated under 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).

Interim Staff Guidance (ISG)-2, 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 SRP-LR 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 structures

and components 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."

Section 2.1.2.3.5 of the LRA indicates that the preferred path of offsite power when recovering

from a Station Blackout is through the Reserve Auxiliary Transformers (RATs) from the power

grid via the 230 kV switchyard, and the 230 kV power circuit breakers represent the scoping

boundary. Figure 2.1.2.3.5-1, "Plant Vogtle License Renewal Offsite Power for SBO," shows

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that 230 kV circuit breakers 161860 and 161960 for Offsite Power Source 1 and 230 kV circuit

breakers 161820 and 161920 for Offsite Power Source 2 represent the scoping boundary.

Hence, the scoping boundary is in accordance with SRP-LR Section 2.5.2.1.1, and the staff

finds this acceptable.

2.5.3 Conclusion

The staff reviewed the LRA and UFSAR to determine whether the applicant failed to identify any

SCs within the scope of license renewal. The staff finds no such omissions. In addition, the

staffs 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 component types 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).

2.6 Conclusion for Scopincq and Screening

The staff reviewed the information in LRA Section 2, "Structures and Components Subject to

AMR." The staff concludes that the applicant's scoping and screening methodology is consistent

with 10 CFR 54.21 (a)(1) requirements and the staffs position on the treatment of safety-related

and nonsafety-related SCs within the scope of license renewal and that the SCs requiring an

AMR is consistent with the requirements of 10 CFR 54.4 and 10 CFR 54.21(a)(1).

On the basis of its review, the staff concludes that the applicant has adequately identified

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 the activities authorized by the renewed license will continue to be

conducted in accordance with the CLB, and any changes made to the CLB, in order to comply

with 10 CFR 54.29(a), with the Atomic Energy Act of 1954, as amended, and with NRC

regulations.

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