ML051150161
| ML051150161 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/25/2005 |
| From: | Mitra S NRC/NRR/DRIP/RLEP |
| To: | Gannon C Carolina Power & Light Co |
| Mitra, SK, NRR/DRIP/RLEP, 415-2783 | |
| References | |
| TAC MC4639, TAC MC4640 | |
| Download: ML051150161 (13) | |
Text
April 25, 2005 Mr. Cornelius J. Gannon Vice President Carolina Power & Light Company P.O. Box 10429 Southport, NC 28461-0429
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MC4639 AND MC4640)
Dear Mr. Gannon:
By letter dated October 18, 2004, Carolina Power & Light Company, (CP&L or the applicant) submitted an application pursuant to 10 CFR Part 54, to renew the operating licenses for Brunswick Steam Electric Plant (BSEP), Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified, in the enclosure, areas where additional information is needed to complete the review.
These RAIs were discussed with your staff, Mike Heath, and a mutually agreeable date for this response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-2783 or e-mail SKM1@nrc.gov.
Sincerely,
/RA/
Sikhindra K. Mitra, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-325 and 50-324
Enclosure:
As stated cc w/encls: See next page
April 25, 2005 Mr. Cornelius J. Gannon Vice President Carolina Power & Light Company P.O. Box 10429 Southport, NC 28461-0429
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. MC4639 AND MC4640)
Dear Mr. Gannon:
By letter dated October 18, 2004, Carolina Power & Light Company, (CP&L or the applicant) submitted an application pursuant to 10 CFR Part 54, to renew the operating licenses for Brunswick Steam Electric Plant (BSEP), Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC). The NRC staff is reviewing the information contained in the license renewal application (LRA) and has identified, in the enclosure, areas where additional information is needed to complete the review.
These RAIs were discussed with your staff, Mike Heath, and a mutually agreeable date for this response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-2783 or e-mail SKM1@nrc.gov.
Sincerely,
/RA/
Sikhindra K. Mitra, Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos.: 50-325 and 50-324
Enclosure:
As stated cc w/encls: See next page DISTRIBUTION: See next page Adams accession no.: ML051150161 Document Name: E:\\Filenet\\ML051150161.wpd OFFICE PM:RLEP LA:RLEP SC:RLEP NAME SMitra YEdmonds SLee DATE 04/22/05 04/21/05 04/22/05 OFFICIAL RECORD COPY
Brunswick Steam Electric Plant, Units 1 and 2 cc:
Mr. Steven R. Carr Associate General Counsel - Legal Department Progress Energy Service Company, LLC Post Office Box 1551 Raleigh, North Carolina 27602-1551 Mr. David R. Sandifer, Chairperson Brunswick County Board of Commissioners Post Office Box 249 Bolivia, North Carolina 28422 Resident Inspector U. S. Nuclear Regulatory Commission 8470 River Road Southport, North Carolina 28461 Mr. John H. ONeill, Jr.
Shaw, Pittman, Potts & Trowbridge 2300 N Street NW Washington, DC 20037-1128 Ms. Beverly Hall, Section Chief Radiation Protection Section, Division of Natural Resources N.C. Department of Environment and Natural Resources 3825 Barrett Dr.
Raleigh, North Carolina 27609-7721 Mr. David H. Hinds Plant General Manager Brunswick Steam Electric Plant Carolina Power & Light Company Post Office Box 10429 Southport, North Carolina 28461-0429 Public Service Commission State of South Carolina Post Office Drawer 11649 Columbia, South Carolina 29211 Ms. Margaret A. Force Assistant Attorney General State of North Carolina Post Office Box 629 Raleigh, North Carolina 27602 Mr. Robert P. Gruber Executive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, North Carolina 27699-4326 Mr. T. P. Cleary Director - Site Operations Brunswick Steam Electric Plant Progress Energy Carolinas, Inc.
Post Office Box 10429 Southport, North Carolina 28461-0429 Mr. Norman R. Holden, Mayor City of Southport 201 East Moore Street Southport, North Carolina 28461 Mr. Warren Lee Emergency Management Director New Hanover County Department of Emergency Management Post Office Box 1525 Wilmington, North Carolina 28402-1525 Mr. Chris L. Burton, Manager Performance Evaluation and Regulatory Affairs PEB 7 Progress Energy Post Office Box 1551 Raleigh, North Carolina 27602-1551 Mr. Edward T. ONeill Manager - Support Services Brunswick Steam Electric Plant Carolina Power & Light Company Post Office Box 10429 Southport, North Carolina 28461
Brunswick Steam Electric Plant, Units 1 and 2 cc:
Allen K. Brittain Superintendent, Security Brunswick Steam Electric Plant Progress Energy Carolinas, Inc.
P.O. Box 10429 Southport, North Carolina 28461-0429 Mr. Michael Heath Brunswick Steam Electric Plant P.O. Box 10429 Southport, North Carolina 28461-0429 Talmage B. Clements Manager - License Renewal Progress Energy P. O. Box 1551 Raleigh, North Carolina 27602 Mr. Fred Emerson Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Ms. Ilene Brown NCUW William Randall Library 601 S. College Rd.
Wilmington, North Carolina 28403-5616 Mr. Cornelius J. Gannon, Vice President Brunswick Steam Electric Plant Carolina Power & Light Company Post Office Box 10429 Southport, North Carolina 28461-0429
DISTRIBUTION: Letter to C. Gannon, Re: RAI for review of the Brunswick Steam Electric Plant, Dated: April 25, 2005 ADAMS Accession No.: ML051150161 HARD COPY RLEP RF E-MAIL:
RidsNrrDrip RidsNrrDe G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins P. Shemanski J. Fair RidsNrrDssa RidsNrrDipm D. Thatcher R. Pettis G. Galletti C. Li K. Winsberg (RidsOgcMailCenter)
R. Weisman M. Mayfield A. Murphy S. Smith (srs3)
S. Duraiswamy Y. L. (Renee) Li RLEP Staff B. Mozafari C. Julian, RII P. Y. Chen R. McNally T. Cheng H. Ashar
BRUNSWICK STEAM ELECTRIC PLANT (BSEP), UNITS 1 AND 2 LICENSE RENEWAL APPLICATION (LRA)
REQUESTS FOR ADDITIONAL INFORMATION (RAIs)
RAI 2.4-1 BSEP primary containment encloses the reactor vessel and a number of other structures, such as the concrete pedestal and seismic bracing for the drywell. Table 2.4.1-1 does not include these structures in the scope of license renewal. They perform safety-related functions per 10 CFR 50.54(a)(1). If they are not included as an oversight, please provide a description of their scope and aging management review. If they are covered somewhere else in the LRA, please indicate the location. If they are excluded from the scope of license renewal, please provide the basis for excluding these items from the scope of license renewal.
RAI 2.4-2 Based on information provided in LRA Section 2.4.1, it is not clear if all drywell and torus supports are within the scope of license renewal. If they are not included as an oversight, please provide a description of their scope and aging management review. If they are covered somewhere else in the LRA, please indicate the location. If they are excluded from the scope of license renewal, please provide the basis for excluding these items from the scope of license renewal.
RAI 2.4-3 It is not clear from Table 2.4.2-7 if the BWR reactor building with steel superstructure (enclosure building) including the metal structure, metal panels, is within the scope of LR.
Please clarify the extent to which the enclosure building is within the scope of license renewal, and indicate the location(s) where all its components are included in the LRA.
RAI 2.4-4 LRA Section 2.4, Scoping and Screening Results - Structures, identifies structures that are in the scope of license renewal. As indicated in LRA Figure 2.2-1, some structures are not considered in the scope of license renewal and are not listed in LRA Section 2.4. These structures include Circulating Water Intake Structure, Chlorination Building, Auxiliary Boiler House, Auxiliary Surge Tank, Diesel Generator Fuel Oil Tank Vault, Radioactive Material Container Storage, and Service Building. It is not obvious to the staff that all these structures serve no intended function as defined in 10 CFR 54.4(a)(1). The staff cannot evaluate whether these structures are correctly excluded from the license renewal scope. Additional descriptive information is needed for these structures before a determination can be made. Therefore, the applicant is requested to submit a more detailed description of these structures, define their function, and describe the technical bases for their exclusion from the license renewal scope.
Also verify that none of these structures serves a seismic II/I intended function as defined in 10 CFR 54.4(a)(2).
RAI 2.4-5 LRA Section 2.4.1.1 discusses the scoping and screening results for the Primary Containment Structure. It is the staffs understanding that this LRA section addresses not only the primary containment (drywell, pressure suppression chamber, and the vent system connecting the two structures), but also all the structures inside the primary containment, all attachments to the containment, and the containment supports. LRA Table 2.4.1-1 identifies the primary containment component types requiring aging management review and the associated component intended function(s). Since LRA Table 2.4.1-1 combines many components under a single component type, the staff requests that the applicant identify, as appropriate, which component type is intended to cover the specific components listed in (a) through (f) below, or identify the location in the LRA where these specific components are addressed. If these specific components are not considered to be within the scope of license renewal, the staff requests the applicant to provide the technical bases for their exclusion:
(a)
Reactor Vessel to Biological Shield Stabilizers (b)
Biological Shield to Containment Stabilizer (c)
Biological Shield Wall Anchor Bolts (d)
Reactor Vessel Anchor Bolts (e)
Reactor Vessel Support Ring Girder including Anchor Bolts and Reactor Vessel Support Pedestal (f)
The drywell head closure bolts and double gasket, tongue-and-groove seal arrangement RAI 2.4-6 As described in UFSAR Section 10.4.5.2, an expanded metal fence, and eight traveling screens (four for each unit) are installed in the intake canal to prevent marine lives and debris from entering the system. From its review of LRA Section 2.4.2.1, the staff found that these items are not subject to aging management. The applicant is requested to submit a more detailed description of these items, define their functions, and describe the technical bases for their exclusion from the license renewal scope.
RAI 2.4-7 LRA Table 2.4.2-7, Component Commodity Groups requiring Aging Management Review and Their Intended Functions: Reactor Building, presents a list of component groups. However, for certain components, the staff needs further information and explanation to complete its evaluation. The staff requests the applicant to provide a description of the Neutron-Absorbing Sheets used for Brunswick spent fuel storage racks and confirm that they are part of the spent fuel storage racks.
RAI 2.4-8 LRA Tables 2.4.2-1 through 2.4.2-14 lists component commodity groups requiring aging management review. Some of these tables indicate that structural steel includes platforms, stairways, mezzanines, and hardware. The applicant is requested to respond to the following questions: (1) what is covered under the word hardware? (2) which structural steel components are considered as hardware, (3) are the major structural steel components (e.g.,
beams, columns, roof frames, other steel frames, etc.) considered as hardware? and (4) if not, in which table (or tables) are these structural components listed for the aging management.
RAI 2.4-9 Clarify whether the Brunswicks Reactor Building pipe penetrations include some type of silicone rubber seals that allow for pipe movement while providing a seal between the pipe and the Reactor Buildings to maintain the differential pressure. As applicable, confirm whether these penetration seals are designated within the scope of AMR and are included in Table 2.4.2.7 of the LRA.
RAI 2.4-10 As described in LRA Section 2.4, masonry walls located in the Service Water Intake Structure, Reactor Building, Augmented Off-Gas Building, Diesel Generator Building, Control Building, and Turbine Building are within the scope of license renewal. The applicant is requested to identify whether there are masonry walls located in other building structures within the LR scope, such as the Radwaste Building, Water Treatment Building, HPCI CO2 Bottle Storage Building, etc. If yes, the applicant is requested to include these masonry walls in the component commodity groups requiring aging management review or provide justification for their exclusion from the scope.
RAI 2.4-11 Regarding the scope and screening of crane/rail systems, the applicant is requested to clarify the treatment of cranes and hoists in the scoping and screening, and in the aging management review. Please submit the following information:
(d)
A list of all cranes/hoists/rails and associated components in the scope of license renewal.
(e)
A list of all cranes/hoists/rails and associated components requiring aging management review (i.e., passive, long-lived).
(f)
A list of all cranes/hoists/rails and associated components requiring aging management and/or time-limited aging analysis (TLAA).
RAI 2.4-12 Provide additional information regarding the following Class I Group 6 Structures:
(a)
With respect to the Intake Pumping Station, identify items such as hatches and plugs; structural steel embedments; carbon steel boltings; reinforced concrete foundation footings; grouted concrete; and water proofing membrane materials that require an AMR.
(b)
Regarding the Condensate Water Storage Tanks Foundation and Trenches, confirm that the equipment supports and foundations as well as the trenches consist of reinforced concrete components. As appropriate, identify items such as structural steel embedments; carbon steel boltings; grouted concrete; and water proofing membrane materials that require an AMR.
RAI 2.4-13 Based on information provided in LRA Section 2.4, the staff cannot identify the insulation and insulation jacketing included in the license renewal scope nor the specific subsets of insulation and insulation jacketing that are included in Section 2.4 tables. It is also unclear whether insulation and jacketing on the reactor coolant system has been included.
In order to complete the screening review for insulation and insulation jacketing, the staff requests the applicant to provide the following information:
(c)
Specifically identify the structures and structural components, designated within the license renewal scope, that have insulation and/or insulation jacketing, and identify their location in the plant.
(d)
List all insulation and insulation jacketing materials associated with item (a) above that require an aging management review and results of the aging management review for each. Also, identify the aging management program(s) credited to manage aging.
(e)
List insulation and insulation jacketing materials associated with item (a) above that do not require aging management, and include your justification for their exclusion in relation to plant-specific operating experience.
RAI 2.4-14 For some of the in-scope building structures, the applicant identified the Fire Barrier Assembly as one of the commodity groups requiring aging management review. The applicant is requested to provide a list of in-scope Brunswick buildings with fire proofing material applied to some of their structural steel members or components as part of fire barriers. Discuss how and where these fire proofing materials are included in the AMR as part of the fire barrier review.
Section 3.3 Auxiliary Systems General RAIs RAI 3.3-1 In LRA Table 3.3.2-5 for the screen wash water system and in Table 3.3.2-6 for the service water system, cracking is identified as an aging effect for plastics/polymer piping exposed to a raw water (internal) environment. Table 3.3.2-5 credits the one-time inspection and Table 3.3.2-6 credits the open-cycle cooling water system program to manage cracking caused by exposure to raw water. LRA Table 3.0-1 describes raw water as water that enters the plant from a river, lake, pond, ocean, or bay that has not been demineralized and has been rough filtered to remove large particles. Small particles in raw water may cause erosion in materials susceptible to erosion. For example, LRA Table 3.3.2-6 identifies copper alloy materials exposed to raw water as being susceptible to loss of material due to erosion and the open-cycle cooling water system program is credited with managing this aging effect. The applicant is requested to clarify why loss of material from erosion is not identified for plastics/polymer piping in a raw water environment, and why one-time inspections rather than periodic inspections are proposed to manage aging effects for plastics/polymer piping in the screen wash water system.
Industry and plant operating experience should be considered in determining appropriate aging effects and programs to manage this material.
RAI 3.3-2 The auxiliary systems 3.3.2 AMR tables do not include bolting and the bolting integrity AMP is not credited in the 3.3.2 AMR tables. In LRA Table 3.3.1, Item 3.3.1-24 indicates that the bolting integrity program is not applicable to Non-Class 1 closure bolting and bolting materials are not itemized as a separate component. This table further states that the AMP, Systems Monitoring Program, credited for visual identification of external general corrosion will also address bolting materials. The applicant is requested to explain (1) why crack initiation and growth due to cyclic loading, and loss of preload are not identified as aging effects for auxiliary systems bolting; (2) explain the conditions under which certain sizes of cracks can be identified visually in the closure bolting for auxiliary system components; and (3) clarify why the bolting integrity AMP, currently designated for Class 1 closure bolting only, is not credited for managing cracking, loss of preload, and other aging effects for closure bolting in auxiliary system components.
RAI 3.3-3 In LRA Tables 3.3.2-6 and 3.3.2-8, the applicant did not identify aging effects for certain carbon steel and copper alloy components in a lube oil environment. Carbon steel and copper alloy materials may experience loss of material in an oil environment if exposed to contaminants and/or moisture. For example, Table 3.3.2-8 identified certain carbon steel materials in a fuel oil environment are susceptible to loss of material. GALL Item VII G.7.2 identifies loss of material for copper alloy materials in a lube oil environment with contaminants and/or moisture.
In LRA Table 3.0-1, the description of a lubricating oil environment includes the statement that water contamination of lubricating oil is not assumed unless indicated by operating experience or design review. The applicant is requested to clarify if leakage of raw water or the absence of a chemistry control AMP for the lubricating oil may result in contamination of the lube oil environment such that aging effects could occur. If such aging effects could occur, the applicant is requested to identify an appropriate AMP to manage the aging effect. Industry and plant specific operating experience should be addressed for this aging effect.
RAI 3.3-4 For various component commodities in the following LRA tables, the applicant did not identify aging effects for various materials exposed to dry air/gas (internal) environment:
Table 3.3.2-10, Instrument Air System (p. 74, 75)
Table 3.3.2-11, Pneumatic Nitrogen System (p. 76)
Table 3.3.2-12, Fire Protection System (p. 83)
Table 3.3.2-14, Radioactive Floor Drains System (p. 91)
Table 3.3.2-15, Radioactive Equipment Drains System (p. 95)
Table 3.3.2-19, Liquid Waste Processing System (p. 104)
Table 3.3.2-21, HVAC Diesel Generator Building (p. 108)
Table 3.3.2-22, HVAC Reactor Building (p. 113)
However, it should be noted that in the dry air/gas system, components that are located upstream of the air dryers are generally exposed to wet air/gas environment and therefore, may be subject to aging effect of loss of material due to general and pitting corrosion. In addition, it is reasonable to assume that components downstream of the dryers are exposed to dry air/gas environment. However, this may not be supported by the operating experience. For an example, NRC IN 87-28, Air Systems Problems at U.S. Light Water Reactors, provides the following: A loss of decay heat removal and significant primary system heat up at Palisades in 1978 and 1981 were caused by water in the air system. This experience implies that the air/gas system downstream of the dryer may not be dry. The applicant is requested to provide technical basis for not identifying loss of material as an aging effect for these components including a discussion of the plant specific operating experience related to components that are exposed to air environment to support its conclusion.
System Specific RAIs RAI 3.3.2-1-1 In LRA Table 3.3.2-1 for Reactor Water Cleanup (RWCU) System, piping and fittings (small bore piping less than NPS 4), are identified but the location or class of the piping is not identified. The applicant is requested to clarify if this piping includes small bore piping beyond the second containment isolation valve that are addressed in GALL Section VII E3 or is this piping limited to the Class 1 piping within the RCPB that is addressed in GALL Section IV under the RCS?
RAI 3.3.2-1-2 In LRA Table 3.3.2-1 for Reactor Water Cleanup (RWCU) System, a treated water environment with steam is identified for various stainless steel components in the RWCU system beyond the second isolation valve. For these components, cracking due to SCC is identified as one aging effect and the water chemistry combined with the one-time inspection are credited with managing this aging effect. In LRA Table 3.3.1, Item 3.3.1-26 states that different programs apply and the water chemistry program combined with the ASME Section XI program are credited with managing SCC and IGSCC. The applicant is requested to further explain why the BWR reactor water cleanup system AMP identified in GALL is not applied. For example, clarify if the combination of the two credited programs are consistent with the BWR reactor water cleanup system AMP or are there specific exceptions the applicant is taking to GALL. The applicant should also clarify which program (one-time inspections identified in Table 3.3.2-1 or Section XI inspections identified in Table 3.3.1) is used to verify chemistry control. Also clarify if the stainless steel piping beyond the second containment isolation valve has been replaced with material not susceptible to IGSCC.
RAI 3.3.2-1-3 In LRA Table 3.3.2-1 for Reactor Water Cleanup (RWCU) System, a treated water environment with steam is identified for various carbon steel components in the RWCU system beyond the second isolation valve. For these components, loss of material due to crevice corrosion, general corrosion and pitting corrosion is identified as the aging effect and the water chemistry combined with the one-time inspection are credited with managing this aging effect. For this two phase environment, the applicant is requested to explain why loss of material due to FAC managed by the flow-accelerated corrosion AMP is not identified as an aging effect for carbon steel components beyond the second isolation valve.
RAI 3.3.2-3-1 In LRA Table 3.3.2-3 for Reactor Building Sampling System, stainless steel piping and fittings are identified as being managed by either the water chemistry and Section XI inservice inspection programs or the water chemistry and one-time inspection programs. LRA Section 2.3.3.3 states that portions of this system comprise part of the RCPB, but it is not clear in Table 3.3.2-3 which piping is part of the RCPB as addressed by GALL Section IV and which piping is not part of the RCPB as addressed in GALL Section VII. The applicant is requested to clarify which stainless steel piping and their aging management programs are part of the RCPB and which piping and their aging management programs are not part of the RCPB. The applicant is also requested to clarify if this piping is less than 4" NPS.
RAI 3.3.2-5-1 In LRA Table 3.3.2-5 for Screen Wash Water System, various components exposed to a raw water environment are identified as being managed by the one-time inspection. One-time inspection is appropriate where either an aging effect is not expected to occur but there is insufficient data to completely rule it out or the aging effect is occurring very slowly so as not to affect the component intended function. Periodic inspections are appropriate where degradation is expected such as in service water systems containing raw water that are managed by the open-cycle cooling water program. Industry and plant specific operating experience should be considered in determining if there is sufficient data and which type of inspection is appropriate for each material. The applicant is requested to explain why one-time inspections rather than periodic inspections are proposed to manage various components exposed to raw water in the screen wash water system.
RAI 3.3.2-6-1 In LRA Table 3.3.2-6 for Service Water System, copper alloy underground piping and fittings are identified with an environment of indoor air (external). Note 332 states that copper alloys in an indoor environment have no aging effects in the absence of sustained wetting. In LRA Table 3.0-2 a buried/below grade/submerged environment is described as exposed to soil/fill, ground water, or water from the intake Canal. In LRA Table 3.0-2, aggressive intake water is identified in the immediate vicinity of the service water intake. The applicant is requested to clarify whether the underground piping is in a tunnel or buried, and explain why this environment is considered an indoor environment with no sustained wetting.
RAI 3.3.2-8-1 In LRA Table 3.3.2-8 for Diesel Generator System, the materials for strainer (basket) and filter (media) are identified as filter media and strainer element, respectively. The applicant is requested to identify the specific materials (carbon steel, stainless, etc.) for the strainer (basket) and filter (media).
RAI 3.3.2-21-1 In LRA Table 3.3.2-21 for HVAC Diesel Generator Building, the applicant credited the Preventive Maintenance Program for managing the aging effect of cracking due to various degradation mechanisms for piping (piping and fittings) made of plastics/polymers exposed to indoor air (internal). However, in the same table, no aging effect was identified for the same material exposed to the same environment for duct (duct, fittings, fan housing, damper housing, access doors, and closure bolts). The applicant is requested to explain the difference between these two cases.
RAI 3.3.2-22-1 In LRA Table 3.3.2-21 for Diesel Generator Building HVAC, the applicant credited the System Monitoring Program for managing the aging effect of cracking due to various degradation mechanisms for non-carbon steel components made of plastics/polymers exposed to indoor air (external). However, in LRA Table 3.3.2-22 for Reactor Building HVAC, no aging effect was identified for the same component commodity where the same material is exposed to the same environment. The applicant is requested to explain the inconsistency between these two items.
RAI 3.3.2-24-1 In LRA Table 3.3.2-24 for Civil Structure Auxiliary System, no aging effects were identified for piping (piping and fittings) made of plastics/polymers exposed to indoor air (External) and raw water (Internal). However, different conclusions were reached for the same components of same material exposed to the same environments as described in Table 3.3.2-5 and Table 3.3.2-6. The applicant is requested to explain the apparent inconsistencies cited above. The applicant is also requested to clarify why loss of material from erosion is not identified for plastics/polymer piping and fittings exposed to raw water (internal), and what AMP will be used to manage this aging effect (Refer to RAI 3.3-1 above).