january 21, 2010amp xi.m36 in the protection mode of surfaces from corrosion (program element, scope...

Dominion Energy Kewaunee, Inc.5000 Dominion Boulevard, Glen Allen, VA 23060

January 21, 2010

United States Nuclear Regulatory CommissionAttention: Document Control DeskWashington, DC 20555-0001

Serial No.: 09-777LR/MWH RODocket No.: 50-305License No.: DPR-43

DOMINION ENERGY KEWAUNEE, INC.KEWAUNEE POWER STATIONRESPONSE TO REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEWOF THE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATIONAGING MANAGEMENT REVIEW/AGING MANAGEMENT PROGRAM

By letter dated December 3, 2009 (reference 1), the NRC provided a request foradditional information regarding the aging management review results included in thelicense renewal application (LRA) for Kewaunee Power Station (KPS) (reference 2).The NRC staff indicated that responses to each request for additional information (RAls)are needed to complete the review of the KPS LRA. Attachment 1 to this letter providesthe Dominion Energy Kewaunee Inc. (DEK) responses to each of the RAls submitted bythe NRC staff in reference 1.

On October 22, 2009, a conference call was conducted between the NRC and DEK todiscuss DEK responses to RAls regarding neutron absorbing materials (Boral/BoronCarbide) in the KPS spent fuel pools. During the teleconference, the NRC staffindicated that additional information associated with the responses to RAls 3.3.2.2.6-1,3.3.2.2.6-2, and 3.3.2.2.6-3 (provided by DEK letter dated August 6, 2009 (reference 4))is required for the staff to complete their evaluation. NRC letter dated November 27,2009 (reference 5) documents the teleconference and the DEK commitment tosupplement the responses to these RAls. Attachment 2 to this letter contains therequested information related to neutron absorbing materials in the KPS spent fuelpools.

On December 14, 2009, a telephone conference call was conducted between the NRCand DEK (reference 6) to discuss information submitted by DEK related to the WorkControl Process program. The information was submitted in a letter dated September25, 2009 (reference 7). During the teleconference, the NRC staff indicated that certaintables provided in the letter included inconsistent footnote reference information.Attachment 3 to this letter contains replacement tables that correct the footnotereferences.

In reference 6, the NRC provided a correction to the numbering for one RAI transmittedin reference 1. The corrected numbering is reflected in attachment 1.

Serial No. 09-777Docket No. 50-305

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Should you have any questions regarding this submittal, please contact Mr. Paul C.Aitken at (804) 273-2818.

Very truly yours,

~¥Vice President - Nuclear Support Services

COMMONWEALTH OF VIRGINIA

COUNTY OF HENRICO

Attachments:

1. Response to Request for Additional Information Regarding the Kewaunee PowerStation License Renewal Application.

2. Supplemental Responses to RAls 3.3.2.2.6-1, 3.3.2.2.6-2, and 3.3.2.2.6-3.

3. Amendment to Dominion Energy Kewaunee, Inc. Letter 09-597 for Work ControlProcess Aging Management Program Supplement Table Corrections.

References:

1. Letter from Samuel Hernandez (NRC) to David A. Heacock (DEK), "Request forAdditional Information for the Review of the Kewaunee Power Station LicenseRenewal Application - Aging Management Review/Aging Management Program(TAC No.MD9408)," dated December 3, 2009. [ADAMS Accession No.ML0932400950]

2. Letter from D. A. Christian (DEK) to NRC, "Kewaunee Power Station Applicationfor Renewed Operating License," dated August 12, 2008. [ADAMS Accession No.ML082341 020]


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3. Letter from Stephen E. Scace (DEK) to NRC, "Response to Request for AdditionalInformation for the Review of the Kewaunee Power Station License RenewalApplication - Aging Management Programs," dated August 17, 2009. [ADAMSAccession No. ML092320093]

4. Letter from Leslie N. Hartz (DEK) to NRC, "Response to Request for AdditionalInformation for the Review of the Kewaunee Power Station License RenewalApplication - Leak Before Break I Boral," dated August 6, 2009. [ADAMSAccession No. ML092230618]

5. Notes of Teleconference from Samuel Hernandez (NRC) to Dominion EnergyKewaunee, Inc., "Summary of Telephone Conference Call Between DominionEnergy Kewaunee, Inc. and U.S. Nuclear Regulatory Commission to Discuss theSurveillance and Aging Management of Its Neutron Absorbing Material (TAC No.MD9408)," dated November 27,2009. [ADAMS Accession No. ML093230257]

6. Notes of Teleconference from Samuel Hernandez (NRC) to Dominion EnergyKewaunee, Inc., "Summary of Telephone Conference Call on December 14,2009,Between Dominion Energy Kewaunee, Inc. and U.S. Nuclear RegulatoryCommission to Discuss Tables Referenced in the Work Control ProcessAmendment Letter (TAC No. MD9408)," dated December 16, 2009. [ADAMSAccession No. ML093431339]

7. Letter from Leslie N. Hartz (DEK) to NRC, "Supplemental Information for theReview of the Kewaunee Power Station License Renewal Application - Changesto the Work Control Process Aging Management Program," dated September 25,2009. [ADAMS Accession No. ML09271 0045]. .

Commitments made in this letter:

1. License Renewal Commitment 37 will be added to LRA Table A6.0-1 consistentwith the response to RAI 3.2.2.2.2. The new commitment is proposed to supportapproval of the renewed operating license, and may change during the NRCreview period.

2. License Renewal Commitment 38 will be added to LRA Table A6.0-1 consistentwith the supplemental response to RAI 3.3.2.2.6-1. The new commitment isproposed to support approval of the renewed operating license, and may changeduring the NRC review period.

3. License Renewal Commitment 39 will be added to LRA Table A6.0-1 consistentwith the supplemental response to RAI 3.3.2.2.6-2. The new commitment isproposed to support approval of the renewed operating license, and may changeduring the NRC review period.

cc: u.s. Nuclear Regulatory CommissionRegional Administrator, Region III2443 Warrenville RoadSuite 210Lisle, IL 60532-4532

Mr. P. S. Tam, Senior Project ManagerU.S. Nuclear Regulatory CommissionOne White Flint, Mail Stop 08-H4A11555 Rockville PikeRockville, MD 20852-2738

Ms. V. PerinEnvironmental Project ManagerU.S. Nuclear Regulatory CommissionMail Stop 0-11 F1Washington, DC 20555-0001

Mr. John DailyLicense Renewal Project ManagerU.S. Nuclear Regulatory CommissionMail Stop 0-11 F1Washington, DC 20555-0001

NRC Senior Resident InspectorKewaunee Power StationN490 Highway 42Kewaunee, WI 54216

Public Service Commission of WisconsinElectric DivisionP.O. Box 7854Madison, WI 53707

David HardtkeChairman - Town of CarltonE2334 Lakeshore RoadKewaunee, WI 54216


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ATTACHMENT 1

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDINGTHE KEWAUNEE POWER STATION LICENSE RENEWAL APPLICATION

KEWAUNEE POWER STATIONDOMINION ENERGY KEWAUNEE, INC.


Attachment 1/Page 1 of 23

RAI 82.1.8-4

Background

Exception 1 in license renewal application (LRA) Section B2. 1.8 states that corrosioninhibitors are not used in the Control Room Air Conditioning System because thissystem interconnects with the Service Water System, which provides an alternatesafety-related cooling mode. The applicant stated that periodic testing of this modewould release any inhibitors to the environment. The applicant also stated that, in lieu ofthe use of corrosion inhibitors, the system is periodically sampled to verify systemintegrity. The applicant further stated that periodic visual inspections of systemcomponents are petformed under the plant-specific Work Control Process (WCP)Program.

Issue

Electric Power Research Institute (EPRI) TR-1007820 allows for the operation of closedcooling water systems without the addition of inhibitors, provided proper water chemistryis maintained. Specifically, EPRI TR-1007820 states that control of dissolved oxygen isparticularly important for systems containing copper or copper alloys. The reportrecommends that dissolved oxygen either be maintained at <100 ppb to stabilize thecuprous oxide film on component sutfaces or that it be maintained at >2000 ppb tostabilize the cupric oxide film. Operation at dissolved oxygen levels between these twolimits is specifically warned against, since it results in alternate formation andbreakdown of the two oxides and resulting loss of the protective film. The staff notesthat the applicant does not state the limits on dissolved oxygen level in the ControlRoom Air Conditioning System or in which of the two EPRI-recommended dissolvedoxygen level regimes this system operates.

Request

Please clarify the limits on dissolved oxygen level in the Control Room Air ConditioningSystem and specify in which of the two EPRI-recommended dissolved oxygen levelregimes this system operates. If the limits on dissolved oxygen in the Control Room AirConditioning System are not maintained within the levels that are recommended byEPRI TR-1007820, provide further details on how inspection procedures under theapplicant's WCP are used to verify that corrosion of copper alloy components is notoccurring. Include information on water sampling for the presence of dissolved and/orsuspended copper indicative of copper alloy corrosion.

DEK Response

The dissolved oxygen level in the Control Room Air Conditioning System is notmonitored. The water chemistry parameters monitored for the system, in accordancewith the Closed-Cycle Cooling Water System program, include adenosine triphosphate(ATP), conductivity, copper, iron, pH, and suspended solids. The acceptance criteria forthese parameters are consistent with EPRI TR-1007820, "Closed Cooling Water



Chemistry Guideline." If significant corrosion of copper alloy components were to occur,it would be indicated by elevated copper levels.

In addition, to verify that degradation of the copper alloy components is not occurring,the Control Room Air Conditioning System will be subject to inspection under the OneTime Inspections portion of the Work Control Process program as confirmation of theeffectiveness of the Closed-Cycle Cooling Water System program. The One-TimeInspections program will use non-destructive examination techniques (visual and/orvolumetric examinations) to monitor the aging effects of the copper alloys in the system.

The combination of routine monitoring for copper content in the Control Room AirConditioning System cooling water and one-time inspection of the subject copper alloycomponents ensures that the system is not experiencing significant corrosion of copperalloy components.



RAI 3.3.2.1-1

Background

Steel tanks when in contact with soil and or concrete environments, at the inaccessibleinterface (between soil or concrete), can undergo corrosion and or loss of material. TheGeneric Aging Lessons Learned (GALL) Report for these aboveground steel tanksrecommends such aging effects to be managed through aging management program(AMP) XI.M29, ''Above Ground Steel Tanks." This AMP discusses how to manage lossof material, general corrosion of the tanks' external viewable surfaces, as well as thosethat are in inaccessible areas, e.g., at the Interface between soil or concrete at thebottom of the tank. The GALL Report, in order to prevent moisture and water toaccumulate under the steel tanks, emphasizes the installation and maintenance ofpristine seals around the tanks' bottoms, assuring, thus, the existence and adequacy ofa moisture barrier.

Issue

In the LRA, Kewaunee Power Station (KPS) indicates aging effects for the DieselGenerator Expansion Tanks will be managed with the GALL Report AMP XI.M36,"External Surfaces Monitoring." This AMP manages loss of material for steel andrelated corrosion aging effects. The GALL Report, however, recommends foraboveground steel tanks aging effects to be managed with AMP XI.M29. There aresignificant differences between the two AMPs. The AMP XI.M36 is a conditionmonitoring program, while AMP XI.M29 is a preventive measures program. XI.M36 isbased on visual inspections, periodic walkdowns, with sampling allowed. AMP XI.M29consists of the same approach for walkdowns and visual inspections. It differs fromAMP XI.M36 in the protection mode of surfaces from corrosion (program element,scope of program). AMP XI.M29 recommends paint to be applied at exposed tanksurfaces and caulking or sealant at the interface of the tank when supported by a slabor foundation (program element, preventive actions). AMP XI.M36 ascribes toqualification of personnel performing the Inspections. Caulking, sealant, and paint areinspected by AMP XI.M29 vs paint as designated In the AMP XI.M36 (program element,parameters monitored/inspected). In addition to these visually observed quantities,AMP XI.M29 also recommends inspecting personnel to track via ultrasonic testing (UT)the thickness of tank bottoms, when in contact with the ground to assure significantdegradation is not occurring (program element, detection of aging effects).

Request

• Are the elevated expansion tanks detached or attached to the ground (concreteslab/foundation)? State their location, elevation, and accessibility for performance offull visual inspections.

• State the frequency of inspections.



DEK Response

The component type "Expansion Tanks" identified in LRA Table 3.3.2-19 includes thejacket water expansion tanks for the emergency diesel generators and the jacket waterexpansion tank for the Technical Support Center (TSC) diesel generator.

The emergency diesel generator jacket water expansion tank is mounted on theassociated emergency diesel generator skid located in the basement (586 ft. elevation)of the Administration Building. The tank is located approximately 8 ft. above the skid.The emergency diesel generators are operated on a monthly basis to satisfy TechnicalSpecification surveillance requirements, which provides the opportunity to visuallyinspect the condition of the tank external surfaces as described in LRA Section B2.1.1 0,External Surfaces Monitoring.

The jacket water expansion tank for the TSC diesel generator is located on the roof ofthe TSC Building, at the 606 ft. elevation, approximately 7 ft. above the roof. The 14gallon tank is supported by the steel frame of the TSC diesel generator radiator. TheTSC diesel generator is operated on a monthly basis to satisfy Technical RequirementsManual surveillance requirements, which provides the opportunity to visually inspect thecondition of the tank external surfaces as described in LRA Section B2.1.10, ExternalSurfaces Monitoring.

These expansion tanks are not in contact with soil or concrete. The expansion tanksare accessible for full visual inspection.



RAI 3.3.2.2.3.3-1 Diesel Exhaust Piping

Background

Section 3.3.2.2.3.3, "Cracking due to Stress Corrosion Cracking" and Section3.3.2.2.7.3, "Loss of Material due to General, Pitting, and Crevice Corrosion" of theStandard Review Plan for License Renewal Applications of Nuclear Power Plants (SRPLR) identify cracking due to stress corrosion cracking (SCC) and loss of material asaging effects requiring management for steel and stainless steel diesel exhaust piping,piping components, and piping elements exposed to diesel exhaust. The applicant hascredited the plant-specific AMP B2.1.32 WCP Program with managing this aging effectfor the diesel engine exhaust piping, piping components, and piping elements.

Issue

Section A. 1.2.3.4 Detection of Aging Effects of the SRP-LR describes the attributes ofan acceptable plant-specific AMP which should be used to manage this aging effect.The SRP-LR states that aspects such as method or technique, frequency, sample size,etc should be appropriate in order to ensure timely detection of aging effects. LRASections 3.3.2.2.3.3 and 3.3.2.2.7.3 describe the inspection frequency to be on anongoing basis, dependent upon the preventive and corrective maintenance activitiesrequired for the components. The staff notes that preventive maintenance activities aretypically done based on a schedule set in advance of the maintenance activity beingperformed. However, the LRA is not clear in defining the preventive maintenanceactivity schedule for diesel exhaust gas components. The lack of a schedule wouldbring into question the adequacy ofpreventive maintenance, as well as the frequency ofthe accompanying visual examinations to manage the loss of material and crackingaging effects.

Request

Please clarify whether or not preventive maintenance will be done and whether or notactual inspections of the diesel exhaust gas components will be done during thescheduled preventive maintenance to manage the loss of material and cracking agingeffects.

DEK Response

As described in the response to RAJ 82.1.32-2, surveillance and maintenance activitieswill be identified that perform Internal Surfaces Monitoring inspections for each materialenvironment combination managed by the program. This will include the diesel exhaustgas components.



Though the applicable scheduled surveillance and maintenance activities have not yetbeen identified, as stated in the Work Control Process program description, Exception1, Element 4: Detection of Aging Effects (DEK Letter No. 09-597 dated September 25,2009 [ADAMS ML09271 0045]), an enhanced VT-1 NDE examination of the stainlesssteel diesel exhaust flexible connection will be performed to identify signs of cracking.The remaining steel and stainless steel portions of the diesel exhaust will also bevisually inspected to identify loss of material in conjunction with the enhanced VT-1NDE examination of the diesel exhaust flexible connection.



RAI 3.4.2.3-1 - Secondary Water Chemistry AMP

8ackground

LRA Tables 3.4.2-5, 3.4.2-6, 3.4.2-7, 3.4.2-8, 3.4.2-9, 3.4.2-10, 3.4.2-12, and 3.4.2-14address the SCC of copper-alloy valves, auxiliary feedwater components, and heatingsteam components exposed to treated secondary water and/or steam. The applicantproposes to manage this aging effect through the use of its AMPs "Secondary WaterChemistry" and "Work Control Process" (LRA 82.1.28 and 82.1.32). The applicant alsostates that for the component, material and environment combination listed, the agingeffect being considered is not included in the GALL Report (Generic Note H)

Issue

In its review of LRA Tables 3.4.2-5, 3.4.2-6, 3.4.2-7, 3.4.2-8, 3.4.2-9, 3.4.2-10, 3.4.2-12,and 3.4.2-14, the staff confirmed that the GALL Report does not address this agingprocess for the specific components identified by the applicant. The staff also notedthat aging management of SCC of specific copper-alloy components in contact withtreated secondary water and/or steam is not addressed anywhere as a line item in theGALL Report tables. The staff further noted that the GALL Report states in Table IX.Cthat "copper-zinc alloys >15% zinc are susceptible to stress corrosion cracking,selective leaching (except for inhibited brass), and pitting and crevice corrosion.Additional copper alloys may be susceptible, such as aluminum bronze >8% aluminum. "

Request

State whether the copper alloy components discussed in this section of the LRA are ormay be susceptible to SCC. If susceptible components are present or are believed tobe present, identify the limits on those chemical impurity species controlled by theapplicant's Secondary Water Chemistry AMP that might promote SCC in thesecomponents.

DEK Response

Industry operating experience has identified copper alloys containing greater than 15%zinc or 8% aluminum as being susceptible to stress corrosion cracking (SCC) in anaqueous environment with dissolved oxygen concentrations greater than 100 ppb.Equipment specifications identify copper alloys, including brass and bronze, as beingacceptable for use in secondary systems at Kewaunee. Specific limits on zinc and/oraluminum content are not always specified. Therefore, SCC was conservativelyassumed as an aging effect for copper alloys identified only as brass or bronze in theequipment specifications, since the zinc and/or aluminum content was not specificallyspecified.

Impurities in the Treated Water and/or Steam - Secondary environment are maintainedwithin industry standard limits as described in LRA Section 82.1.28, Secondary Water



Chemistry. Action Level limits are established as part of this program to limit dissolvedoxygen concentration in this environment to less than 100 ppb during plant operation.



RAI3.1.2.2.7-1 - Vessel Flange Leakage Monitor Lines

Background

In LRA Table 3.1.2-1, the applicant proposes to manage cracking/SCC in the stainlesssteel vessel flange leakage monitor lines exposed to primary reactor coolant waterthrough the use of its AMPs, "Primary Water Chemistry" and "Work Control Process(WCP)" (LRA B2.1.24 and B2.1.32). The vessel flange leak monitor lines requiremanagement so leakage from them, if it occurred, has no adverse impact on othercomponents inside containment. SRP-LR Section 3.1.2.2.7 requires that a plantspecific AMP be evaluated to ensure this aging effect is adequately managed, sinceexisting programs may not be capable of mitigating or detecting crack initiation andgrowth due to SCC in the vessel flange leak monitor line.

Issue

The applicant states that the service environment for this austenitic stainless steelcomponent is primary water. However, the staff noted in its review that the normalinternal environment for the flange leakage monitor line is air, and the line would seereactor coolant only when there is a leak at the inner reactor vessel closure flange Dring. The staff determined that the applicant's Primary Water Chemistry program is oflittle value in mitigating SCC in a line that is intermittently exposed to stagnant reactorcoolant, particularly when that coolant is subject to the absorption of oxygen andpossible concentration of other impurities from the environment in the line. The staffalso noted that control of the water chemistry in the stagnant coolant intermittentlypresent in the line is extremely difficult under any water chemistry program. The stafftherefore concluded that effective management of degradation due to SCC for thiscomponent must be accomplished primarily through periodic inspection rather thanthrough water chemistry control. The staff questions the efficacy the applicant's WCPProgram, which it proposes to be an alternative to XI. M32, to detect crack initiation inthe components under consideration.

Request

LRA Section 3.1.2.2.7.1 utilizes the Primary Water Chemistry and the WCP AMPs.Hence, leakage occurring after a one-time inspection will not be discovered and itsimpact on other components will not be assessed. Provide additional justification todemonstrate that the applicant's WCP AMP is effective on an ongoing basis in detectingcracks in the vessel flange leakage monitor lines exposed to treated primary coolantwater. The justification should include a summary of industry experience with flawedvessel flange leak detection lines to demonstrate that failure of these lines is unlikely tooccur.



DEK Response

For the reactor vessel flange leakage monitor lines, the One-Time Inspection programwithin the Work Control Process program, as described in DEK letter 09-597 datedSeptember 25, 2009 [ADAMS ML092720184], will provide verification of theeffectiveness of the Primary Water Chemistry program for management of cracking dueto stress corrosion cracking. The One-Time Inspection program within the Work ControlProcess program, which is consistent with NUREG-1801, Generic Aging LessonsLearned (GALL) Report, Section XI.M32, "One-Time Inspection," uses NDE techniquesthat have been determined to be effective for the identification of stress corrosioncracking in stainless steel. The inspections will be conducted to verify thatunacceptable degradation is not occurring for material and environment combinationsthat include stainless steel in primary treated water. Indications of degradation wouldresult in an engineering review of the condition through the Corrective Action Programand could result in further corrective actions, such as an expansion of the inspectionscope, and a periodic inspection plan.

During normal operation, these lines are typically dry, and are only internally exposed toprimary water should the vessel flange leak due to O-ring failure. In that case, potentialRCS leakage would be limited by the 3/16 inch diameter orifice in the reactor pressurevessel flange. During refueling, the lines are filled with water when the reactor cavity isflooded and drained prior to plant heat-up.

A review of industry operating experience identified two instances of cracking due toSCC in these lines. Calvert Cliffs (1994) and Davis-Besse (2002) identifiedtransgranular stress corrosion cracking (TGSCC) in these lines. The TGSCC wasattributed to high concentrations of chlorides coupled with stagnant water at hightemperatures in the reactor vessel flange leakage monitor lines. As a correctivemeasure, both stations revised procedures to ensure that the lines are drained prior toplant heat-up to mitigate the conditions that contributed to the SCC. Kewauneeprocedures already require draining the lines prior to plant heat-up, which prevents theconditions and environment for SCC as identified in the industry OE. A review ofKewaunee plant-specific operating experience identified no instances of cracking due toSCC for reactor vessel flange leakage monitor lines.

Therefore, the One-Time Inspection program within the Work Control Process, whichprovides for verification of the effectiveness of Primary Water Chemistry program,provides an inspection that either verifies that unacceptable degradation is not occurringor results in additional actions that assure the intended function of affected componentswill be maintained during the period of extended operation.



RAI 3.2.2.2.2 - Loss of Material Due to Cladding Breach

Background

SRP-LR Section 3.2.2.2.2 notes that loss of material due to cladding breach could occurfor pressurized-water reactor steel pump casings with stainless steel cladding exposedto treated borated water, and recommends further evaluation of a plant-specific AMP to ~

ensure that the aging effect is adequately managed. The corresponding section of theKPS LRA notes that the failures in the referenced U. S. Nuclear Regulatory CommissionInformation Notice pertained to manufacturing at the Pacific Pump Division of DresserIndustries and were not related to aging. The KPS LRA continued by stating that thesafety injection pumps at the KPS were manufactured by Sulzer Bingham, and sincethere was no operating experience related to loss of material due to cladding breach inSulzer Bingham pumps, this item was not applicable.

Issue

According to the KPS USAR Table 6.2-6, the safety injection pumps are carbon steelforgings with stainless steel cladding. The lack of operating experience related to lossof material due to cladding breach in Sulzer Bingham pumps is an insufficient basis toensure that this aging effect is being managed.

Although the information notice in question may have specifically cited the Pacific PumpDivision of Dresser Industries, information notices are used to inform the nuclearindustry of recently-identified, significant operating experience that may have genericapplicability. In doing so, specific examples of the phenomenon in question areincluded; however, these examples should not be viewed as a limitation on applicability.The conditions which resulted in the corrosion of the listed pumps could exist for othercarbon steel pumps with stainless steel cladding, and therefore, they could similarlycorrode unless an aging management program is implemented. The GALL Reportrecommends further evaluation of a plant-specific Aging Management Program, whichmeets the acceptance criteria described in Branch Technical Position RLSB-1.

Request

Provide a plant-specific AMP, which meets the acceptance criteria described in BranchTechnical Position RLSB-1, to ensure that this aging effect, the loss of material due tocladding breach, for the pumps in question, is adequately managed.

DEK Response

The response to RAJ 3.3.2.2.14-1 (DEK letter 09-680 dated November 13, 2009[ML093170751]) stated that the industry issue related to charging pump cladding breach(Reference NRC Information Notices (IN) 80-38, Cracking in Charging Pump CasingCladding, and 94-63, Boric Acid Corrosion of Charging Pump Casing Caused by



Cladding Cracks) is not applicable to Kewaunee's Sulzer-Bingham safety injectionpumps because the cladding breach that occurred in the industry was the result of themanufacturing process used for these Dresser Industries - Pacific Pump Divisioncharging pumps.

However, to address NRC staff concerns, a visual (VT-1) examination of one safetyinjection pump will be performed as a leading indicator prior to the period of extendedoperation to ensure there are no signs of stainless steel cladding cracking or corrosion.As described in IN 94-63, visible rust-like stains may be indicative of a cladding breachand corrosion of the underlying carbon steel casing material. If degradation is identified,the condition will be entered into the Corrective Action Program and an engineeringevaluation will be performed to determine necessary actions.

The following commitment will be added to LRA Appendix A, USAR Supplement, TableA6.0-1 :

Item Commitment Source Schedule37 Perform a VT-1 visual examination of the Letter 09-777 Prior to the

stainless steel cladding of a safety Response to Period ofinjection pump for indications of cracking RAI 3.2.2.2.2. Extendedor corrosion due to cladding breach. Operation



RAI 82.1.32-1

Background

In Dominion Energy Kewaunee, Inc. (DEK) Letter No. 09-597, dated September 25,2009, the applicant amended its LRA to change the WCP from a plant-specific AMP toan AMP that is consistent with GALL Report AMP XI.M32, "One-Time Inspection" (withan enhancement). For those AMR line items in the LRA in which the Primary WaterChemistry Program (LRA AMP B2.1.24), Secondary Water Chemistry Program (LRAAMP B2.1.28), Closed-Cycle Cooling Water Program (LRA AMP B2.1.8), Fuel OilChemistry Program (LRA AMP B2. 1.14), or Lubricating Oil Analysis Program (LRA AMPB2. 1. 17) the applicant identifies that the WCP will be used to verify these program'seffectiveness and that the sample size of the one-time inspections will be based on anassessment of material, environment, plausible aging effects and operating experience.

Issue

Although the applicant's sampling basis is consistent with the sampling basis statementin GALL Report AMP XI.M32, the staff notes that it does not clearly establish what theapplicant's sampling basis would be because (1) the AMP that is credited in the AMRline items manage multiple materia/-environment-aging effect combinations and (2) theapplicant did not clearly establish whether the representative sample will be chosenfrom each "unique" materia/-environment-aging effect combination or will therepresentative sample be chosen from the collection of all materia/-environment-agingeffect combination. In addition, the staff felt that additional explanations were neededon the type of factors that would be used to select component or structure locations forthe one-time examinations. In addition, KLR-1336 indicates that methodology in EPRIReport No. 107514 may be used to select the sample of components that are inspectedon a periodic basis under the WCP.

Request

For those AMR line items in the LRA that credit the Primary Water Chemistry Program,Secondary Water Chemistry Program, Closed-Cycle Cooling Water Program, Fuel OilChemistry Program, or Lubricating Oil Analysis Program, clarify whether the WCP willinspect a representative sample of the component or structure populations for each"unique" materia/-environment-aging effect combination that is managed or whethersome other type of sampling basis will be used. If another sampling basis is used,please justify its use.

Clarify which type of engineering, design, operational or operating experienceconsiderations (e.g. stagnant areas for evidence of corrosion, high velocity flow areasfor evidence of erosion or wear, etc.) will be used to select the representative sample ofcomponents for the one-time Inspections.



Explain why these considerations are considered sufficient to justify the sample ofcomponents that are selected, particularly if a given sample is used to represent morethan one materia/-environment-aging effect combination in the AMR tables of the LRA.

In addition, justify how the methodology in EPRI Report No. 107514 can be applied tothe selection of components at Kewaunee Station, when the methodology in the reportis only limited to component inspections in a limited number of systems of the CalvertCliffs nuclear power station and when the report may only be relevant to PWR facilitiesthat are part of the Combustion Engineering Owners Group.

DEK Response

The One-Time Inspection program within the Work Control Process program will beimplemented to perform inspections of a representative sample of plant SSCs in orderto confirm the effectiveness of the Primary Water Chemistry, Secondary WaterChemistry, Closed-Cycle Cooling Water, Fuel Oil Chemistry, and Lubricating OilAnalysis programs. Management of aging effects by chemistry control programs hashistorically been effective, and degradation is not expected. The One-Time Inspectionprogram will use a representative sampling approach to provide verification thatdegradation is not occurring. Sample size and location will be based on an assessmentof the materials of fabrication, operating environments, plausible aging effects andoperating experience associated with SSCs within the scope of the One-TimeInspection program.

The representative sample size and inspection locations will be determined based onthe materials of fabrication for component groups for which chemistry programeffectiveness verification is required. A sample size will be established for eachmaterial, based on the total population, consistent with the methodology discussed inSection 4, "Sampling Program Description" of EPRI TR-107514, Age.;.RelatedDegradation Inspection Method and Demonstration In Behalf of Calvert Cliffs NuclearPower Plant License Renewal Application. For each material-based sample set,representative inspections will be performed for each operating environment in which inscope equipment is exposed. All applicable aging effects will be evaluated during eachinspection such that, in total, each unique combination of material, environment, andaging effect will be evaluated by the One-Time Inspection program inspections.

The specific inspection locations will be identified considering the bounding or leadingcomponents most susceptible to aging based on time in service, severity of operatingconditions, and lowest design margins. In determining the leading components, factorssuch as the potential for aging due to component geometry (Le., pipe versus valvebody) and environmental factors (e.g., stagnant or low flow areas) will be considered.

The One-Time Inspections sample size and inspection locations will be developed toensure that a representative sample of material-environment combinations is selected



with a focus on inspecting leading indicator components. This approach providesassurance that the aging of the components are being adequately managed.

As noted above, the methodology discussed in EPRI TR-107514 will be used only todetermine the required sample size for the One-Time Inspections. Although the reportis limited to component inspections in a limited number of systems at the Calvert Cliffsplant, the methodology provided in Section 4 of the report for determining the requiredsample size to obtain a desired confidence level as a function of population size isindependent of reactor design and can be appropriately applied for determining therequired sample size for Kewaunee.



RAI 82.1.32-2

Background

In DEK Letter No. 09-597, dated September 25, 2009, the applicant amended its LRA tochange the WCP from a plant-specific AMP to an AMP that is consistent with GALLReport AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping andDucting Components" (with noted exceptions and an enhancement).

Issue

The "detection of aging effects" element in GALL Report AMP XI.M38 states thatlocations for inspection should be chosen to include conditions likely to exhibit the agingeffects and that the inspection intervals should be established such that they provide fortimely detection of degradation. The staff has noted that the Dominion Technical ReportKLR-1336 does not specifically establish or justify what the sample populations, samplesizes, and inspection frequencies would be for the periodic examinations that areperformed in accordance with the WCP because the program is defined as a new,GALL-based program for the LRA.

Request

Clarify why the visual examinations of those components that are actually scheduled forperiodic maintenance are considered to be representative of those components thatmay not be inspected during the period of extended operation. Clarify how the resultsof the inspections will be applied to the population of components that may not beinspected under the program if aging is detected in the inspected components and howpotential aging in the non-inspected will be addressed.

DEK Response

Consistent with the NUREG-1801, Generic Aging Lessons Learned (GALL) Report,Section XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping and DuctingComponents," the Internals Surfaces Monitoring program inspections will be performedduring scheduled surveillance and maintenance activities, as part of the Work ControlProcess program described in DEK letter 09-597 dated September 25, 2009 [ADAMSML09271 0045].

For each material-environment combination, sufficient internal surfaces inspections willbe performed during scheduled surveillance and maintenance activities to provide anoverall assessment of any aging degradation that may be occurring. A review of thescheduled surveillance and maintenance actiVities will be performed to select activitiesthat will provide a set of inspections that will be representative of the components in theprogram. The review will consider component materials; operating environments;industry and plant-specific operating experience; engineering evaluations of equipment



performance; and susceptibility to aging due to time in service, severity of operatingconditions, and lowest design margins.

The selected scheduled surveillance and maintenance activities will be performed on arepetitive basis. The use of recurring surveillance and maintenance activities providesthe ability to detect aging of the material-environment combination prior to loss offunction.

Aging detected during the Internal Surfaces Monitoring program inspections will bedocumented and evaluated for applicability to similar components (Le., same materialenvironment combinations) within the total component population in accordance withthe Corrective Action Program. An engineering review will be performed to evaluate thecondition, the extent of the condition, and the need for corrective actions. The extent ofthe condition may require the inspection of additional plant equipment.

Implementation of the Internal Surfaces Monitoring program at Kewaunee will requireEngineering personnel to: (1) review the program inspection results to identify any newaging effects not previously considered, (2) monitor and/or perform walkdown activitiesto verify adequate identification and documentation of aging effects and initiation ofcorrective actions, (3) perform trending of inspection results, and (4) review siteoperating experience through the plant corrective action program to ensure that agingeffects are addressed.

The combination of the Corrective Action Program evaluations and the engineeringreviews discussed above provides reasonable assurance that the impact of identifiedaging will be considered for non-inspected components.



RAJ 82.1.32-3

Background

In DEK Letter No. 09-597, dated September 25, 2009, the applicant amended its LRA tochange the WCP from a plant-specific AMP to an AMP that is consistent with GALLReport AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping andDucting Components" (with noted exceptions and an enhancement).

Issue

The staff noted that the "detection of aging effects" element in GALL Report AMPXI. M38 states that the applicant should identify and justify the inspection technique usedfor detecting the aging effects of concern. The staff has noted that, although theapplicant's basis document appropriately identifies that enhanced VT-1 techniques willbe used to monitor for cracking by SCC, the applicant does not identify which type ofspecific visual inspection techniques would be used to monitor for loss of material or forreduction ofheat transfer capability by fouling.

Request

Clarify whether the visual inspection techniques that have been specified to detect forloss of material (corrosion, wear, erosion, etc.) and for reduction of heat transfercapability (fouling) during implementation of the one-time inspections of the program(i.e., the inspections that will be performed in accordance with GALL Report AMPXI. M32) also apply to the monitoring of these aging effects/mechanisms for the periodicinspections of the program (i.e., the inspections that will be performed in accordancewith GALL Report AMP XI.M38). In addition, confirm that visual inspection techniqueswould be coupled with ,physical manipulation methods on applicable elastomericcomponents to monitor for cracking, crazing, discoloration, swelling, tackiness, or otheraging effect parameters.

DEK Response

Visual inspections that have been specified by the One Time Inspection program todetect loss of material (corrosion, wear, erosion, etc.) and reduction of heat transfercapability (fouling) are VT-1 and VT-3 examinations governed by the requirements ofthe Kewaunee non-destructive examination program. These examinations areperformed by qualified NDE inspectors consistent with NUREG-1801, Generic AgingLessons Learned (GALL) Report, Section XI.M32, "One-Time Inspection." The visualinspections to detect loss of material (corrosion, wear, erosion, etc.) and reduction ofheat transfer capability (fouling) for the Internal Surfaces Monitoring program areperformed by Maintenance Department personnel during routine maintenance andsurveillance activities consistent with NUREG-1801, Section XI.M38, "Inspection ofInternal Surfaces in Miscellaneous Piping and DUCting Components." These InternalSurfaces Monitoring inspections are not VT-1 or VT-3 visual examinations.



As discussed in DEK letter 09-597 dated September 25, 2009 [ADAMS ML09271 0045],Work Control Process Program Description, Exception 1, Element 4: Detection of AgingEffects, the visual inspection techniques that will be used by personnel implementingthe Internal Surfaces Monitoring program are capable of detecting loss of material dueto corrosion and reduction of heat transfer due to fouling by observing localizeddiscoloration and surface irregularities such as rust, scale, deposits, surface pitting,surface discontinuities, and coating degradation. Maintenance personnel at Kewauneeare subject to a training and qualification program. As part of this program, personnelwill receive specific training to provide the knowledge necessary to identify anddocument the effects of aging. Only personnel appropriately qualified through theMaintenance training program will perform Internal Surfaces Monitoring programinspections.

Physical manipulation of elastomeric components through the Internal SurfacesMonitoring program also includes visual inspections to monitor for cracking, crazing,discoloration, swelling, tackiness, or other aging effect parameters.



RAI 82.1.32-4

Background

In DEK Letter No. 09-597, dated September 25,2009, the applicant amended its LRA tochange the WCP from a plant-specific AMP to an AMP that is consistent with GALLReport AMP XI.M38, "Inspection of Internal Surfaces in Miscellaneous Piping andDucting Components" (with noted exceptions and an enhancement).

Issue

The "acceptance criteria" element in GALL Report AMP XI. M38 states that acceptancecriteria are established in the maintenance and surveillance procedures or otherestablished plant procedures, and that, if the results are not acceptable, the correctiveaction program is implemented to assess the material condition and determine whetherthe component intended function is affected. The applicant states that the acceptancecriterion is "no unacceptable wear, corrosion, cracking, change in material properties(for materials and non-metallics) or significant fouling. "

Request

Clarify the intent (meaning) of the phrase "no unacceptable wear, corrosion, cracking,change in material properties (for materials and non-metallics) or significant fouling."Specifically clarify whether the intent is to establish acceptance criterion in which noevidence of wear, corrosion, cracking, change in material properties, or significantfouling is acceptable, or whether the intent is to establish an acceptance criterion inwhich a certain amount of wear, corrosion, cracking, change in material properties, orsignificant fouling may be permitted as long as it is within the bounds that areestablished in implementing procedures.

DEK Response

The intent of the phrase "no unacceptable wear, corrosion, cracking, change in materialproperties for elastomers, or fouling" included in DEK letter 09-597 dated September 25,2009 [ADAMS ML09271 0045], under the Work Control Process program description,Exception 1, Element 6: Acceptance Criteria is that a certain amount of wear, corrosion,cracking, change in material properties, or fouling may be permitted as long as it iswithin the bounds that are established in implementing procedures.


Attachment 1/Page 21 of ~3

RAI83.2-4a

Background/Issue

The applicant responded to RAI B3.2-4 in a letter dated August 17, 2009. The lastparagraph of the response to RAI B3.2-4 states, "The differential temperature (L\ T)between the pressurizer and the reactor coolant loop is determined through a calculatedplant computer data point that subtracts the greater of reactor coolant loop A or loop Bwide range temperature from the pressurizer water temperature. "

However, in subtraction, the larger the deduction, the smaller the net will be. It followsthat the L\T (i.e., the net) calculated in accordance with the formula stated above issmaller than what you would get if you were subtracting the smaller of TA or TB from thepressurizer water temperature. Therefore, the L\ T values you obtained are nonconservative, considering that, L\T represents potential of stress due to stratification andinsurge/outsurge.

Request

• Demonstrate that the formula as described for the L\T calculation is conservative.• The need of correction of the L\T data was identified in August 2006 but

Westinghouse Commercial Atomic Power (WCAP)-12841 and WCAP-12842 thathelped to close the Bulletin 88-11 request concerning the issue on the surge linestratification and insurge/outsurge for KPS were prepared in 1991. Justify that theWCAP analyses remain valid since the L\T data, which the WCAP analyses basedupon, are changed due to the corrections demanded by the 2006 incident.

DEK Response

The pressurizer-to-reactor coolant loop differential temperature (11T) is used to indicatethe relative severity of plant heatup and cooldown transients for thermal cycle trackingpurposes. The 11T value is not used directly as an input to pipe or component stressdeterminations. The 11T is normally measured between the pressurizer and reactorcoolant loop '8' hot leg since that is where the surge line connects the pressurizer to thereactor coolant system. However, in the event that the reactor coolant loop '8' hot legtemperature data point is out of service (as indicated by an abnormally low or zeroreading), an acceptable approximation can be obtained by substituting the reactorcoolant loop 'A' hot leg temperature data point.

The evaluations performed and documented in WCAP-12841 (and WCAP-12842, whichis the non-proprietary version), Structural Evaluation of the Kewaunee PressurizerSurge Line, Considering the Effects of Thermal Stratification, did not use the subjectpressurizer-to-reactor coolant loop 11T data as an input. Therefore, the erroneously high



l:1T indications had no effect on the results of these evaluations or the resolution of NRCBulletin 88-11, Pressurizer Surge Line Thermal Stratification.



RAI4.3-2a

Background/Issue

The applicant responded to RAI 4.3-2 in a letter dated August 17, 2009. The responseto RAI 4.3-2 does not provide the historical dissolved oxygen data for the first 10 yearsof the plant history (1974 - 1984), although it covered the most recent 25 years.

Request

• Provide justification that, for the first 10 years of the plant operation (1974through 1984), the KPS dissolved oxygen concentration in the reactor coolantsystem coolant was maintained at or below 0.05 ppm level.

DEK Response

As discussed in the response to RAI 4.3-2 (DEK letter 09-469 dated August 17, 2009[ADAMS ML092320093]), Kewaunee maintains an elevated hydrogen concentration inthe reactor coolant during normal operation to ensure a low concentration of dissolvedoxygen (DO). Reactor coolant chemistry data recorded since 1984 were reviewed andshowed that DO is typically less than 0.005 ppm. The plant has operated with elevatedhydrogen concentration since initial operations in 1973. Therefore, the DOconcentrations during normal plant operation for the 1973 to 1984 operating period areexpected to be consistent with the DO data recorded since 1984.


ATTACHMENT 2

SUPPLEMENTAL RESPONSES TO RAls 3.3.2.2.6-1, 3.3.2.2.6-2, and 3.3.2.2.6-3



Attachment 2/Page 1of 5

NRC Request

On October 22, 2009, the U. S. Nuclear Regulatory Commission (NRC or the staff)conducted a conference call (teleconference) with representatives from DominionEnergy Kewaunee, Inc. (DEK). The purpose of the teleconference was to discuss DEKresponses to the staff's requests for additional information (RAls) regarding theKewaunee Power Station (KPS) Neutron Absorbing Material (Boral/Boron Carbide).

In a letter dated July 7, 2009 (Agencywide Documents and Access ManagementSystem [ADAMS] Accession Number ML091190389), the staff submitted its RAlsrelated to KPS neutron absorbing material. In the RAI letter, the staff had threerequests that were related to the Boral and Boron Carbide (RAls 3.3.2.2.6-1, 3.3.2.2.62, and 3.3.2.2.6-3). DEK responded to the staff's RAls on a letter dated August 6, 2009(ADAMS Accession Number ML092230618). During the teleconference, the staffindicated that the responses to RAls 3.3.2.2.6-1, 3.3.2.2.6-2, and 3.3.2.2.6-3 did notprovide enough information for the staff to make its evaluation. The main issuediscussed during the teleconference is summarized below.

Need of a Program to assess the material condition of the neutron absorbing material

• The applicant does not have a program to assess the material condition of theBoral in the KPS spent fuel pool and transfer canal. The staff indicated that tohave reasonable assurance that the aging of the material would be adequatelymanaged during the period of extended operation, a program describing thefrequency and attributes that would be monitored needs to be submitted forreview. The staff believes that operating experience indicating that nodegradation of the neutron absorbing material at KPS is not sufficient basis toconclude that degradation would not occur in the future.

As a result of the discussions, DEK indicated that they will supplement their responsesto RAls 3.3.2.2.6-1, 3.3.2.2.6-2, and 3.3.2.2.6-3 to provide additional information to thestaff regarding the use and implementation of a program to monitor and assess thecondition of the neutron absorbing materials for Kewaunee.

RAI 3.3.2.2.6-1 Supplemental Response

The existing boron carbide surveillance program, which includes neutron attenuationtesting as described in the response to RAI 3.3.2.2.6-1 (DEK letter 09-451 dated August6, 2009 [ADAMS ML092230618]), will continue to be performed during the period ofextended operation. The testing will be performed every 3 years.




Item Commitment Source Schedule38 The boron carbide surveillance Letter 09-777 During the

program, which includes neutron Supplemental Period ofattenuation testing, will continue to be Response to Extendedperformed during the period of RAI 3.3.2.2.6-1. Operationextended operation every 3 years.


Attachment Z/Page 3 of 5


As described in LRA Section 2.3.3.2, Boral is utilized as a neutron absorber in theKewaunee fuel transfer canal pool storage racks. These racks consist of 215 cells andwere placed in service September 2001. As discussed in the response to RAI 3.3.2.2.62 (DEK letter 09-451, dated August 6, 2009 [ADAMS ML092230618]), a review of plantspecific and industry operating experience did not identify any reason to conclude thatdegradation of the capability of the Boral spent fuel storage rack neutron absorber toperform its intended function would be expected with continued service. However,absent an additional basis to support that degradation will not occur in the future,Kewaunee will establish a surveillance program to monitor the performance of the Boralneutron absorber during the period of extended operation or, alternatively, will reperform the Spent Fuel Pool Criticality Analysis such that no credit is taken for Boral inthe spent fuel storage racks.

The surveillance program for these racks will consist of a periodic determination of theareal density of the Boral neutron absorber using an in-situ inspection technique (suchas the currently available BADGER system). The initial test of Boral areal density willbe performed prior to 2017 on at least five storage cells. This surveillance program planis justified based on the following:

• There is no industry operating experience indicating a failure of Boral to attenuateneutrons in non-flux trap design storage racks.

• The Boral storage racks at Kewaunee have been in service for less than ten years,which is insufficient time for the occurrence of significant corrosion or otherdegradation of the Boral sheets.

• The racks contain relatively cool spent fuel assemblies, limited to those dischargedfrom the reactor during or prior to the 1984 refueling outage, resulting in a lessaggressive low temperature water environment near the racks.

• The gamma/neutron fluence to which the Boral is exposed from these assemblies issignificantly less than from recently discharged fuel assemblies such that any effectof the neutron or gamma fluence from stored fuel assemblies on the Boral sheets isexpected to be minor and evenly distributed.

Selection of the cells to be tested will consider those cells that are known to haveroutinely. been occupied with spent fuel. This will ensure that the test results will eitherbound or be fully representative of the untested rack cells.

The surveillance program will be perfQrmed every 10 years following the initial testing.

Kewaunee will continue to monitor industry operating experience related to Boral, andany necessary actionswill be initiated through the Corrective Action Program.




Item Commitment Source Schedule39 A surveillance program will be Letter 09-777 Prior to 2017.

implemented to perform verification that Supplemental Surveillancethe Boral spent fuel storage rack Response to program willneutron absorber B-1 0 areal density is RAI 3.3.2.2.6-2. be performedmaintained within the bounds of the every 10spent fuel pool criticality analysis. yearsAlternatively, the criticality analysis for thereafter.the spent fuel pool will be revised toeliminate credit for the Boral neutronabsorber material.


See the supplemental response to RAI 3.3.2.2.6-2 above.




ATTACHMENT 3

AMENDMENT TO DOMINION ENERGY KEWAUNEE, INC. LETTER 09-597 FORWORK CONTROL PROCESS AGING MANAGEMENT PROGRAM SUPPLEMENT

TABLE CORRECTIONS




NRC Request

On December 14, 2009, the U.S. Nuclear Regulatory Commission (NRC or the staff)conducted a telephone conference call (teleconference) with representatives fromDominion Energy Kewaunee, Inc (DEK). The purpose of the teleconference was todiscuss the information presented by DEK on several tables of their Work ControlProcess Amendment letter dated September 25, 2009.

During the teleconference, the staff stated that information is missing from tables 3.3.26, 3.3.2-8, 3.3.2-14, 3.3.2-15, 3.3.2-19, 3.3.2-20, 3.3.2-22, 3.3.2-26, 3.3.2-27, 3.3.2-28,3.4.2-1, 3.4.2-9, 3.4.2-10, 3.4.2-12, and 3.5.2-4. Specifically, the above mentionedtables make reference to footnotes that are not defined in the license renewalapplication (LRA) or the amendment letter.

As a result of the discussions, DEK indicated that they will amend the affected tablesand that the information to be referenced in the amended tables would be available onthe LRA.

DEK Supplemental Response

DEK letter 09-597, dated September 25, 2009 [ADAMS ML09271 0045], submittedsupplemental information for changes to the Work Control Process aging managementprogram. Changes to LRA Table 2s were provided in Attachment 2 Part B: "LRASection 3 Changes" in the table titled "Changes to LRA Table 3.x.2-y (Table 2)."Some of the numeric footnotes in the "Notes" column of the table were incorrect andnot consistent with the LRA "Notes." The numeric Notes should have been identical tothose in the LRA, since there were no changes to the numeric Notes as part of theLetter 09-597 submittal.

To correct the erroneous numeric Notes provided in Letter 09-597, the attached tablereplaces the Letter 09-597, Attachment 2, Part B table "Changes to LRA Table 3.x.2-y(Table 2)" in its entirety. There are no other changes to this table other than to correctthe numeric Notes.

Chan{les to LRA Table 3.x.2-y (Table 21



Component Material Environment Aging Effect I Mechanism Aging NUREG-1801 Table 1 Item Notes LRA PageType Management Vol. 2 Number

Program ReferenceTable 3.2.2-2: Engineering Safety Features - Safety Injection - Aging Management EvaluationPipe Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~;2 3-192

Steel microbiologically influenced Processcorrosion

Table 3.3.2-3: Auxiliary Systems - Spent Fuel Pool Cooling - Aging Management EvaluationSpent Fuel Pool Steel Raw water Loss of material/general, pitting, Work Control A-004 ~ H~ 3-324Heat Exchanger crevice, galvanic, and ProcessShell microbiologically influenced

corrosion, and foulinaSpent Fuel Pool Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-324Heat Exchanger Steel microbiologically influenced ProcessTubes corrosion, and foulinaSpent Fuel Pool Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-325Heat Exchanger Steel microbiologically influenced ProcessTubesheet corrosion, and foulinqTable 3.3.2-6: Auxiliary Systems - Service Water - Aging Management EvaluationFilter Housings Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ H~ 3-331SWto Steel corrosion, and fouling ProcesschlorinationpumpsFlexible Hoses Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ H~ 3-332

Steel corrosion, and foulina ProcessFlow Switches Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C109 ~ H~;1 3-333

Alloys microbiologically influenced Processcorrosion, and foulina

Orifices Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ H ~;1 3-333Steel corrosion, and fouling Process

Pipe Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C109 ~ H~;1 3-334Alloys microbiologically influenced Process

corrosion, and foulinaSight Flow Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C1 09 ~ H ~;1 3-337Indicators Alloys microbiologically influenced Process

corrosion, and foulingStandpipes Steel Raw water Loss of material/general, pitting, Work Control VII.C1 19 ~ H~;1;2 3-338

crevice, and microbiologically Processinfluenced corrosion, fouling, andlining-coating degradation

Changes to LRA Table 3.x.2-yJTable 2)



Component Material Environment Aging Effect / Mechanism . Aging NUREG-1801 Table 1 Item Notes LRA PageType Management Vol. 2 Number

Program ReferenceStrainer Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C1 09 ~ He;1 3-339Housings Alloys microbiologically influenced Process

corrosion, and foulinqStrainer Steel Raw water Loss of material/general, pitting, Work Control VII.C1 19 ~ He;1;2 3-339Housings crevice, and microbiologically Process

influenced corrosion, fOUling, andlininq-coating deqradation

Tubing Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C109 ~ H e;1 3-340Alloys microbiologically influenced Process

corrosion, and foulinqTubing Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ He;1 3-340

Steel corrosion, and fouling ProcessTubing Steel Raw water Loss of material/general, pitting, Work Control VII.C1 19 ~ He;1;2 3-341

crevice, and microbiologically Processinfluenced corrosion, fouling, andIinina-coatina dearadation

Valves Copper Raw water Loss of material/pitting, crevice, and Work Control VII.C1 09 ~ H e;1 3-341Alloys microbiologically influenced Process

corrosion, and foulinaValves Stainless Raw water Loss of material/pitting and crevice Work Control VII.C1 15 ~ He;1 3-342

Steel corrosion, and foulina ProcessValves Steel Raw water Loss of material/general, pitting, Work Control VII.C1 19 ~ He;1;2 3-342

crevice, and microbiologically Processinfluenced corrosion, fOUling, andlining-coating degradation

Table 3.3.2-8: Auxiliary Systems - Station and Instrument Air - Aging Management EvaluationAftercoolers Steel Raw water Loss of material/general, pitting, Work Control A-004 ~ He 3-356Shell crevice, galvanic, and Process

microbiologically influencedcorrosion, and fouling

Aftercoolers Copper Raw water Loss of material/pitting, crevice, Work Control A-OOa ~ He 3-357Tubes Alloys galvanic, and microbiologically Process

influenced corrosion, and foulinaAftercoolers Copper Raw water Reduction of heat transfer/fouling Work Control A-fJ+2 ~ He 3-357Tubes Allovs ProcessAftercoolers Steel Raw water Loss of material/general, pitting, Work Control A-004 ~ He 3-357Tubesheets crevice, galvanic, and Process

microbiologically influencedcorrosion, and fouling

Chanaes to LRA Table 3.x.2-v (Table 2)



Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRA PageType Management Vol. 2 Number

Program ReferenceCompressors Steel Raw water Loss of material/general, pitting, Work Control ~ ~ H e;1 3-358Housing crevice, and microbiologically Process

influenced corrosion, fouling, andlininQ-coatinQ deQradation

Traps Steel Air-moist Loss of material/general and pitting Work Control ¥J.h.Q.-@ ~ He 3-366corrosion Process

Traps Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He;1 3-366crevice, and microbiologically Processinfluenced corrosion, fouling, andlining-coatinQ deQradation

Table 3.3.2-9: Auxiliary Systems - Chemical and Volume Control - Aging Management EvaluationBoric Acid Steel Raw water Loss of material/general, pitting, Work Control A-004 ~ He 3-371Evaporator crevice, galvanic, and ProcessDistillate microbiologically influencedSample Cooler corrosion, and foulingShellBoric Acid Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-372Evaporator Steel microbiologically influenced ProcessDistillate corrosion, and foulingSample CoolerTubingTable 3.3.2-13: Auxiliary Systems - Auxiliary Building Ventilation - Aging Management EvaluationFan Coil Units Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-429Drip Pans crevice, and microbiologically Process

influenced corrosion, and foulingTable 3.3.2-14: Auxiliary Systems - Reactor Building Ventilation - Aging Management EvaluationContainment Stainless Raw water Loss of material/pitting and crevice Work Control ~ ~ He 3-435Fan Coil Units Steel corrosion ProcessDrip PanDrip Pans Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-435Shroud Cooling crevice, and microbiologically ProcessCoils influenced corrosion, and foulingPipe Stainless Raw water Loss of material/pitting and crevice Work Control ~ ~ He 3-438

Steel corrosion ProcessTable 3.3.2-15: Auxiliary Systems - Turbine Building and Screenhouse Ventilation - Aging Management EvaluationFan Coil Units Copper Raw water Loss of material/pitting, crevice, Work Control A-Gea ~ H e;1 3-443Cooling Alloys galvanic, and microbiologically ProcessCoils/Fins influenced corrosion, and foulingFan Coil Units Copper Raw water Reduction of heat transfer/fouling Work Control ~ ~ H e;1 3-443Cooling Alloys ProcessCoils/Fins

Chanaes to LRA Table 3.x.2-y (Table 2)




Program ReferenceFan Coil Units Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-444Drip Pans crevice, and microbiologically Process

influenced corrosion, and foulinaTable 3.3.2-17: Auxiliary Systems - Technical Support Center Ventilation - Aging Management EvaluationAir Conditioning Steel Air-indoor Loss of material/general corrosion Work Control 'I.llh+-Q8 ~ He 3-451Units uncontrolled ProcessCompressorAir Conditioning Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-451Units crevice, and microbiologically ProcessCondenser Drip influenced corrosion, and foulingPanAir Handling Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-452Units Battery crevice, and microbiologically ProcessRoom Coil Drip influenced corrosion, and foulingPanTable 3.3.2-18: Auxiliary Systems - Fire Protection - Aging Management EvaluationFlexible Hoses Stainless Air-moist Loss of material/pitting and crevice Work Control AP-OO:I- ~ He 3-460

Steel corrosion ProcessTubing Stainless Air-moist Loss·of material/pitting and crevice Work Control AP-OO:I- ~ He 3-466

Steel corrosion ProcessValves Stainless Air-moist Loss of material/pitting and crevice Work Control AP-OO:I- ~ He 3-469

Steel corrosion ProcessTable 3.3.2-19: Auxiliary Systems - Diesel Generator - Aging Management EvaluationFlexible Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ He;1;3 3-479Connections Steel closed cycle corrosion Processincludes coolingbraided hosesPipe Steel Raw water Loss of material/general, pitting, Work Control VII.H222 ~ He;2;4 3-485

crevice, and microbiologically Processinfluenced corrosion, fouling, andlining-coating dearadation

Pumps Jacket Steel Treated water- Loss of material/general, pitting, Work Control VII.H2 2~ ~ H e;1;3 3-486water cooling closed cycle and crevice corrosion Process

coolingRadiator Tubes Copper Treated water- Loss of material/pitting, crevice, and Work Control VII.H208 ~ He;1;3 3-487

Alloys closed cycle galvanic corrosion Processcooling

Sight Glass Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ H e;1;3 3-488Steel closed cycle corrosion Process

coolingTable 3.3.2-20: Auxiliary Systems - Circulating Water - Aging Management Evaluation

Changes to LRA Table 3.x.2-y (Table 2)




Program ReferenceChlorine Steel Raw water Loss of material/general, pitting, Work Control VILC310 ~ He;3 3-499Monitoring crevice, and microbiologically ProcessWater Pump influenced corrosion, fouling, and

lining-coating degradationCirculating Steel Raw water Loss of material/general, pitting, Work Control VILCa 10 ~ He;3 3-499Water Pumps crevice, and microbiologically Process

influenced corrosion, fouling, andlining-coating degradation

Condensers Steel Raw water Loss of material/general, pitting, Work Control VILCa 10 ~ He;3 3-500Waterboxes crevice, and microbiologically Process

influenced corrosion, fouling, andIinina-coatina degradation

Flow Elements Stainless Raw water Loss of material/pitting and crevice Work Control '!ILCa 07 ~ He 3-500Steel corrosion Process

Flow Indicators Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-501Alloys microbiologically influenced Process

corrosion, and foulingFlow Indicators Stainless Raw water Loss of material/pitting and crevice Work Control VILCa 07 ~ He 3-501

Steel corrosion ProcessPipe Stainless Raw water Loss of material/pitting and crevice Work Control VILCa 07 ~ He 3-502

Steel corrosion ProcessPipe Steel Raw water Loss of material/general, pitting, Work Control '!ILCa 10 ~ He;2;3 3-503


Recirculating Steel Raw water Loss of material/general, pitting, Work Control VILCa 10 ~ He;3 3-503Water Pump crevice, and microbiologically Process

influenced corrosion, fouling, andlining-coating degradation

Tubing Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-504Alloys microbiologically influenced Process

corrosion, and foulingTubing Stainless Raw water Loss of material/pitting and crevice Work Control VILCa 07 ~ He 3-504

Steel corrosion ProcessTubing Steel Raw water Loss of material/general, pitting, Work Control VILCa 10 ~ He;3 3-504


Valves Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-504Alloys microbiologically influenced Process

corrosion, and fouling





Program ReferenceValves Stainless Raw water Loss of material/pitting and crevice Work Control VII.CJ 07 ~ He;2 3-505

Steel corrosion ProcessValves Steel Raw water Loss of material/general, pitting, Work Control VII.CJ 10 ~ He;3 3-505

crevice, and microbiologically Processinfluenced corrosion, fouling, andIinino-coatino deoradation

Table 3.3.2-21: Auxiliary Systems - Gaseous Waste Processing and Discharge - Aging Management EvaluationFilter Housings Stainless Air-moist Loss of material/pitting and crevice Work Control AP-W-1- ~ He 3-507

Steel corrosion ProcessHeat Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-508Exchangers crevice, and microbiologically ProcessShell influenced corrosion, and foulinoHeat Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-509Exchangers Alloys microbiologically influenced ProcessTubes corrosion, and foulingHeat Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-509Exchangers crevice, and microbiologically ProcessTubesheet influenced corrosion, and foulingMoisture Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-510Separators crevice, and microbiologically Process

influenced corrosion, and foulingOrifices Stainless Air-moist Loss of material/pitting and crevice Work Control AP-W-1- ~ He 3-510

Steel corrosion ProcessOrifices Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-510


Pipe Stainless Air-moist Loss of material/pitting and crevice Work Control AP-W-1- ~ He 3-511Steel corrosion Process

Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-511Steel microbiologically influenced Process

corrosionStrainer Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-512Housings Steel microbiologically influenced Process

corrosionTubing Stainless Air-moist Loss of material/pitting and crevice Work Control AP-W-1- ~ He 3-512

Steel corrosion ProcessValves Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-513

Alloys microbiologically influenced Processcorrosion, and fouling

Valves Stainless Air-moist Loss of material/pitting and crevice Work Control AP-W-1- ~ He 3-513Steel corrosion Process





Program ReferenceValves Stainless Raw water Loss of material/pitting, crevice, and Work Control AP--Oa5 ~ H~ 3-513


Waste Gas Steel Raw water Loss of material/general, pitting, Work Control ~ ~ H~ 3-514Compressors crevice, and microbiologically Process

influenced corrosion, and foulinqTable 3.3.2-22: Auxiliary Systems - Liquid Waste Processing and Discharge - Aaina Management EvaluationDeaerated Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-516Drains Tank Steel microbiologically influenced Process

corrosionDeaerated Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-516Drains Tank Steel microbiologically influenced ProcessPump corrosionDistillate Cooler Stainless Air-moist Loss of material/pitting and crevice Work Control ~ ~ H ~;1 3-517Shell Onlv Steel corrosion ProcessEvaporator Stainless Air-moist Loss of material/pitting and crevice Work Control AP-004- ~ H ~;1 3-517Condenser Steel corrosion ProcessShell OnlvFilter Housings Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-517


Flexible Hoses Elastomers Raw water Hardening and loss of Work Control AP-Q7§ ~ H~ 3-518strenqth/elastomer deqradation Process

Flexible Hoses Elastomers Raw water Loss of material/erosion Work Control AP-G+e ~ H~ 3-518Process

Flow Elements Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-518Steel microbiologically influenced Process

corrosionFlow Orifices Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Oaa ~ H~ 3-518


Flow Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ H~ 3-519Transmitters Steel microbiologically influenced Process

corrosionLaundry and Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Oaa ~ H~ 3-519Hot Shower Steel microbiologically influenced ProcessTanks corrosionLaundry Pump Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Oaa ~ H~ 3-520


Changes to LRA Table 3.x.2-v (Table 2)




Program ReferenceLevel Switches Stainless Air-moist Loss of material/pitting and crevice Work Control AP-QS.i ~ He 3-520

Steel corrosion ProcessLevel Switches Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-520


Pipe Stainless Air-moist Loss of material/pitting and crevice Work Control AP-QS.i ~ He 3-521Steel corrosion Process

Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-521Steel microbiologically influenced Process

corrosionPipe Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-521

crevice, and microbiologically Processinfluenced corrosion, and fouling

Sludge Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-523Interceptor Steel microbiologically influenced ProcessPump corrosionSludge Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Gaa ~ He 3-523Interceptor Steel microbiologically influenced ProcessTank corrosionStandpipes Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-523


Strainer Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-524Housings Steel microbiologically influenced Process

corrosionSump Tank Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-524Pumps Steel microbiologically influenced Process

corrosionSump Tanks Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-524


Tubing Stainless Air-moist Loss of material/pitting and crevice Work Control AP-QS.i ~ He 3-525Steel corrosion Process

TUbing Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-525Steel microbiologically influenced Process

corrosionValves Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Q5§ ~ He 3-526





Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRAPageType Management Vol. 2 Number

Program ReferenceValves Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-526

crevice, and microbiologically Processinfluenced corrosion, and foulinq

Waste Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-G&a ~ He 3-527Condensate Steel microbiologically influenced ProcessPumps corrosionWaste Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-G&a ~ He 3-527Condensate Steel microbiologically influenced ProcessTanks corrosionWaste Stainless Air-moist Loss of material/pitting and crevice Work Control ~ ~ He;1 3-527Evaporator Steel corrosion ProcessConcentratesSample CoolerShell OnlyWaste Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-G&a ~ He 3-528Evaporator Steel microbiologically influenced ProcessFeed Pump corrosionWaste Holdup Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Gaa ~ He 3-528Tank Steel microbiologically influenced Process

corrosionTable 3.3.2-23: Auxiliary Systems - Radiation Monitoring - Aging Management EvaluationRadiation Stainless Air-moist Loss of material/pitting and crevice Work Control ~ ~ He 3-530Detectors Steel corrosion ProcessRadiation Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-G&a ~ He 3-530Detectors Steel microbiologically influenced Process

corrosionTubing Stainless Air-moist Loss of material/pitting and crevice Work Control ~ ~ He 3-531

Steel corrosion ProcessValves Stainless Air-moist Loss of material/pitting and crevice Work Control ~ ~ He 3-531

Steel corrosion ProcessTable 3.3.2-25: Auxiliary Systems - Service Water Pretreatment - Aging Management EvaluationFilter Housings Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-537


Flow Elements Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-537Steel microbiologically influenced Process

corrosionMixers Static Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-537


Chanaes to LRA Table 3.x.2-y (Table 2)




Program ReferencePipe Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Gaa ~ He 3-538


Pipe Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-538crevice, and microbiologically Processinfluenced corrosion, and foulina

Tubing Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-539Alloys microbiologically influenced Process

corrosion, and foulingTubing Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Gaa ~ He 3-539


Tubing Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-539crevice, and microbiologically Processinfluenced corrosion, and fouling

Valves Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-540Alloys microbiologically influenced Process

corrosion, and foulingValves Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-540

crevice, and microbiologically Processinfluenced corrosion, and foulina

Table 3.3.2-26: Auxiliary Systems - Miscellaneous Drains and Sumps - Aging Management EvaluationAnnulus Sump Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-542Pumps crevice, and microbiologically Process

influenced corrosion, and foulingDeaerated Stainless Raw water Loss of material/pitting, crevice, and Work Control AP-Gaa ~ He 3-543Drains Tank Steel microbiologically influenced ProcessEmergency corrosionPumpsFlow Elements Elastomers Raw water Hardening and loss of Work Control AF!--Q7§ ~ He 3-543

strenath/elastomer dearadation ProcessFlow Elements Elastomers Raw water Loss of material/erosion Work Control AP-G7e ~ He 3-543

ProcessReactor Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-543Containment crevice, and microbiologically ProcessVessel Sump influenced corrosion, and foulingPumps Includes1A, 18, and RxCavity C



Attachment 3/Page 12 of16


Program ReferenceOrifices Stainless Raw water Loss of materiaVpitting, crevice, and Work Control ~ ~ He 3-544


Pipe Stainless Air-moist Loss of material/pitting and crevice Work Control AP--GS-1- ~ He 3-545Steel corrosion Process

Pipe Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-545Steel microbiologically influenced Process

corrosionPipe Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-545

crevice, and microbiologically Processinfluenced corrosion, and foulina

RHR Pump Pit Stainless Raw water Loss of material/pitting, crevice, and Work Control AP--Q§§ ~ He 3-546Sump Pumps Steel microbiologically influenced Process

corrosionSafeguards Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-546Alley Sump crevice, and microbiologically ProcessPumps influenced corrosion, and foulingScreen House Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-546Sump Pumps crevice, and microbiologically Process

influenced corrosion, and foulingValves Stainless Air-moist Loss of material/pitting and crevice Work Control AP--GS-1- ~ He 3-547

Steel corrosion ProcessValves Stainless Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-547


Valves Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-547crevice, and microbiologically Processinfluenced corrosion, and foulina

Table 3.3.2-27: Auxiliary Systems - Miscellaneous Gas - Aging Management EvaluationHoses Stainless Air-moist Loss of material/pitting and crevice Work Control AP--GS-1- ~ He 3-551

Steel corrosion ProcessTable 3.3.2-28: Auxiliary Systems - Potable Water - Aging Management EvaluationNozzles Steel Air-fndoor Loss of material/general corrosion Work Control ¥I-k-l-OO ~ He 3-557

uncontrolled ProcessPipe Copper Raw water Loss of material/pitting, crevice, and Work Control A-G44 ~ He 3-558

Alloys microbiologically influenced Processcorrosion, and fouling

Pipe Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-558crevice, and microbiologically Processinfluenced corrosion, and fouling





Program ReferenceValves Copper Raw water Loss of material/pitting, crevice, and Work Control A-Q44 ~ He 3-559

Alloys microbiologically influenced Processcorrosion, and foulinQ

Valves Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-559crevice, and microbiologically Processinfluenced corrosion, and foulina

Table 3.4.2-1: Steam and Power Conversion System - Turbine - Aging Management EvaluationElectro Steel Raw water Loss of material/general, pitting, Work Control s-Q24 ~ He 3-611Hydraulic crevice, galvanic, and ProcessControl System microbiologically influencedOil Coolers corrosion, and foulingBonnetsTurbine Oil Steel Raw water Loss of material/general, pitting, Work Control s-Q24 ~ He 3-615Coolers crevice, galvanic, and ProcessChannel heads microbiologically influenced

corrosion, and fouling

Table 3.4.2-4: Steam and Power Conversion Svstem - Feedwater - Aaina Manaaement EvaluationFeedwater Steel Raw water Loss of material/general, pitting, Work Control s-Q24 ~ He 3-633Pumps Oil crevice, galvanic, and ProcessCoolers microbiologically influencedChannel Heads corrosion, and foulinQTable 3.4.2-9: Steam and Power Conversion System - Heater and Moisture Separator Drains - Aging Management EvaluationHeater Drain Steel Raw water Loss of material/general, pitting, Work Control s-Q24 ~ He 3-675Pumps crevice, galvanic, and Process

microbiologically influencedcorrosion, and foulinQ

Table 3.4.2-10: Steam and Power Conversion System - Heating Steam - Aging Management EvaluationBoric Acid Steel Raw water Loss of material/general, pitting, Work Control s-Q24 ~ He 3-683Evaporator crevice, galvanic, and ProcessCond Return microbiologically influencedUnit Heat corrosion, and fOUlingExchangerBonnetControl Room Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-685NC HWPump crevice, and microbiologically Process

influenced corrosion, and foulinQ

Chan~es to LRA Table 3.x.2-v (Table 2)



Component Material Environment Aging Effect I Mechanism Aging NUREG-1801 Table 1 Item Notes LRAPageType Management Vol. 2 Number

Program ReferenceHeating Coils Copper Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-686

Alloys microbiologically influenced Processcorrosion

Table 3.4.2-11: Steam and Power Conversion System - Main Generator (Mechanical) and Auxiliaries - Aging Management EvaluationAir Side Seal Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-694Oil Cooler crevice, galvanic, and ProcessChannel Heads microbiologically influenced

corrosion, and foulingGenerator Copper Raw water Loss of material/pitting, crevice, and Work Control ~ ~ He 3-696Hydrogen Alloys microbiologically influenced ProcessCoolers Coils corrosionHydrogen Side Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-696Seal Oil Cooler crevice, galvanic, and ProcessChannel Heads microbiologically influenced

corrosion, and foulingTable 3.4.2-12: Steam and Power Conversion System - Secondary Sampling - Aging Management EvaluationCooler Units Steel Raw water Loss of material/general, pitting, Work Control ~ ~ He 3-702Channel head crevice, galvanic, and Processof first stage microbiologically influencedcooler units corrosion, and foulinoCooler Units Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-702Shell of first closed cycle crevice, and galvanic corrosion Processstage cooler coolingunitsCoolers Shell of Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ He 3-703sample coolers Steel closed cycle corrosion Process

coolinoCoolers Shell of Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-703sample coolers closed cycle crevice, and galvanic corrosion Process

coolingFW Sample Stainless Treated water- Loss of material/pitting and crevice Work Control SP--W9 ~ He 3-704Line Chiller Steel closed cycle corrosion ProcessEvaporator tank coolingFW Sample Stainless Treated water- Loss of material/pitting and crevice Work Control SP--W9 ~ He 3-704Line Chiller Steel closed cycle corrosion ProcessRecirculating coolingpumpPipe Stainless Treated water- Loss of material/pitting and crevice Work Control SP--W9 ~ He 3-705

Steel closed cycle corrosion Processcooling




Component Material Environment Aging Effect / Mechanism Aging NUREG-1801 Table 1 Item Notes LRAPageType Management Vol. 2 Number

Program ReferencePipe Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-706

closed cycle crevice, and galvanic corrosion ProcesscoolinQ

Recirculation Steel Treated water- Loss of materiaVgeneral, pitting, Work Control ~ ~ He 3-706Pumps closed cycle crevice, and galvanic corrosion Process

coolinqRefrigeration Steel Raw water Loss of material/general, pitting, Work Control s-424 ~ He 3-707Unit Chiller crevice, galvanic, and ProcessCondenser microbiologically influencedChannel head corrosion, and foulinqRefrigeration Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-707Unit Chiller closed cycle crevice, and galvanic corrosion ProcessCondenser coolingShellRefrigeration Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-707Unit Chiller closed cycle crevice, and galvanic corrosion ProcessEvaporator coolingShellStorage Tank Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-708

closed cycle crevice, and galvanic corrosion Processcooling

Tubing Copper Treated water- Loss of material/pitting, crevice, and Work Control SP-008 ~ He 3-709Alloys closed cycle galvanic corrosion Process

coolingTubing Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ He 3-709

Steel closed cycle corrosion Processcoolinq

Tubing Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-710closed cycle crevice, and galvanic corrosion Processcooling

Valves , Copper Treated water- Loss of material/pitting, crevice, and Work Control SP-008 ~ He 3-711Alloys closed cycle galvanic corrosion Process

coolingValves Stainless Treated water- Loss of material/pitting and crevice Work Control ~ ~ He 3-711

Steel closed cycle corrosion Processcooling

Valves Steel Treated water- Loss of material/general, pitting, Work Control ~ ~ He 3-712closed cycle crevice, and galvanic corrosion Processcooling

Table 3.5.2-1: Structures and Component Supports - Reactor Containment Vessel - Aging Management Evaluation





Program ReferenceReactor cavity Elastomers Air-indoor Loss of sealing/deterioration of Work Control +P-007 ~ H e;;4 3-793seal ring uncontrolled seals, gaskets, and moisture Process

barriers (caulking, flashing, andother sealants)

Table 3.5.2-4: Structures and Component Supports - Auxiliary Building - Aging Management EvaluationSpent fuel pool Elastomers Air-indoor Loss of sealing/deterioration of Work Control +P-007 ~ He; 3-819gate seal uncontrolled seals, gaskets, and moisture Process

barriers (caulking, flashing, andother sealants)

Table 3.5.2-14: Structures and Component Supports - Miscellaneous Structural Commodities - Aging Management EvaluationGaskets/seals Elastomers Air-outdoor Loss of sealing/deterioration of Work Control +P-007 ~ He; 3-872in junction, seals, gaskets, and moisture Processterminal, and barriers (caulking, flashing, andpull boxes other sealants)