ML061220306

Response to NRC Request for Additional Information, Dated March 30, 2006, Related to Plant License Renewal Application

ML061220306
Person / Time
Site:	Oyster Creek
Issue date:	04/28/2006
From:	Gallagher M AmerGen Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
%dam200606, 2130-06-20299, TAC MC7624
Download: ML061220306 (25)

Text

AmerGenSM Michael P. Gallagher, PE Vice President License Renewal Projects Telephohe 610.765.5958 www.exeloncorp.com michaelp.gallagher@exeloncorp.com An Exelon Company AmerGnen 200 Exelcn Way KSA/2-E Kennett Square, PA 19348 10 CFR 50 10 CFR 51 10 CFR 54 2130-06-20299 April 28, 2006 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Oyster Creek Generating Station Facility Operating License No. DPR-1 6 NRC Docket No. 50-219

Reference:

Response to NRC Request for Additional Information, dated March 30, 2006, Related to Oyster Creek Generating Station License Renewal Application (TAC No. MC7624)

"Request for Additional Information for the Review of the Oyster Creek Nuclear Generating Station, License Renewal Application (TAC No. MC7624)," dated March 30, 2006 In the referenced letter, the NRC requested additional information related to Sections 3.2, 3.4, 4.7, and B.2 of the Oyster Creek Generating Station License Renewal Application (LRA). contains the response to this request for additional information.

Several of our responses refer to planned one-time inspection of carbon steel feedwater system piping and carbon steel main steam system piping located inside containment. The formal commitments to perform these inspections are identified in Enclosure 2.

If you have any questions, please contact Fred Polaski, Manager License Renewal, at 610-765-5935.

I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Executed on 0q z 2)9-? 006 Michael P. Gall her Vice President, License Renewal AmerGen Energy Company, LLC

Enclosures:

1. Response to 03/30/06 Request for Additional Information

2. Summary of Commitments

,0II

April 28, 2006 Page 2 of 2 cc:

Regional Administrator, USNRC Region 1, w/o Enclosure U:SNRC Project Manager, NRR - License Renewal, Safety, w/Enclosure USNRC Project Manager, NRR - License Renewal, Environmental, w/o Enclosure USNRC Project Manager, NRR - OCGS, w/o Enclosure U.SNRC Senior Resident Inspector, OCGS, w/o Enclosure Bureau of Nuclear Engineering, NJDEP, w/Enclosure File No. 05040 Response to 3/30/06 Request for Additional Information Oyster Creek Generating Station License Renewal Application (TAC No. MC7624)

RAI 3.2-1 RAI 3.2-2 RAI 3.2-3 RAI 3.4-1 RAI 3.4-2 RAI 3.4-3 RAI 3.4-4 RAI 3.4-5 RAI 3.4-6 RAI 3.4-7 RAI 3.4-8 RAI 4.7.1-1 RAI 4.7.1-2 RAI B.2.1-1 RAI B.2.1-2 RAI B.2.4-1 RAI B.2.4-2 1 of 22

RAI 3.2-1 In LRA Table 3.2.2.1.3 the applicant states that for stainless steel closure bolting in indoor air (external) environment there are no aging effects requiring management (AERMs). The staff requests the applicant to provide the following information:

a.

Justification for excluding loss of preload and loss of closure integrity as aging mechanisms.

b.

Specific industry guidance for ventilation closure bolting relating to AERMs (e.g., EPRI documents, published reports, operating experience etc.).

c.

Sizes and locations of the bolting.

Response

a. Ventilation system duct bolting is similar to structural bolting in that it provides structural support for ventilation system assemblies, which is functionally different from piping system pressure retaining closure bolting. Typical ventilation system operating pressures and temperatures do not result in significant loads on the closure bolting such that ventilation system joint integrity would be compromised. Ventilation bolting applications at Oyster Creek do not require specific predetermined bolting preload to assure the associated intended functions are maintained. Loss of preload or loss of closure integrity for stainless steel ventilation system bolting in an indoor air environment is not a significant aging effect requiring management.

b. NUREG-1 801 does not specifically address ventilation closure bolting. NUREG-1 801 Item TP-5 identifies stainless steel bolted connections in an indoor air environment, with no aging effects or aging management program required. No other industry reports were identified specifically relating to ventilation closure bolting AERMs. Oyster Creek has not experienced age related degradation failures of stainless steel ventilation closure bolting in an indoor air environment.

c. Ventilation bolting is used at fan and damper connections, filter unit connections, valve connections, flexible connections, access ports, duct support locations, and connections between duct sections. Most bolting is less than one-half inch nominal diameter. Larger bolting is used when ducting is connected to large butterfly valves, because the design of the butterfly valve flange is based on pipe flange applications and not ducting connections.

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RAI 3.2-2 In LRA Table 3.2.2.1.3 the applicant states that loss of material in a number of components is managed by the Periodic Inspection of Ventilation Systems (B.2.4) aging management program. The staff requests the applicant to provide the specific tests and inspections including frequency and methods of inspections, preventive actions, parameters monitored and inspected, detection of aging effects, acceptance criteria arid operating experience in the applicant's aging management program (B.2.4) that relate Ito each of the following line items in the standby gas treatment system:

a.

Loss of material in aluminum duct work in an external soil environment.

b.

Loss of material in brass piping and fitting in an outdoor air (external) environment. In addition, identify the specific brass composition.

c.

Loss of material in copper piping and fittings in an outdoor air (external) environment. In addition, identify the specific copper composition.

Resoorise

a. The buried ductwork at Oyster Creek is contained in the Standby Gas Treatment System (SGTS). It is comprised of two aluminum duct exhaust lines that pass through approximately six feet of structural backfill above the roof of the Exhaust Tunnel. Above ground, the ducts connect to the Ventilation Stack. Oyster Creek has experienced age related material degradation failure of aluminum duct in this application. Corrosion of one of the original buried aluminum ducts near the roof of the Exhaust Tunnel required modification and repair after 25 years of service. The duct was internally sleeved with type B209 aluminum sheet with a wall thickness greater than the original duct and the surrounding backfill stabilized. The redundant buried duct was also modified such that all aluminum ducts with an external soil environment are now sleeved.

UT thickness measurements will be performed to detect the aging effect of loss of material of the buried aluminum duct. The acceptance criteria is measured loss of material of the sleeve caused by corrosion. Measured loss of material of the sleeve will be entered into the corrective action program and trended as required. The inspection frequency is every five years. There are no preventive actions associated with these components.

b. There is no brass pipe in the SGTS system. Brass fittings are used with copper tubes for the flow instrumentation downstream of the SGTS outdoor fans. Brass fittings are included under the listed component type piping and fittings since they are part of the copper tubing assembly. The brass fittings are visually inspected. The acceptance criteria is no evidence of penetrating corrosion. Identification of penetrating corrosion will be entered into the corrective action program. The inspection frequency is yearly.

Identification of aging effects does not require determination of the specific material composition in this application. Therefore, the specific brass composition was not 3 of 22

researched. Oyster Creek has not experienced aged related material degradation failures of tubing fittings in this application. There are no preventive actions associated With these components.

c. Copper tubing as listed under piping and fittings is used for the flow instrumentation downstream of the SGTS outdoor fans. The tubing is visually inspected. The acceptance criteria is no evidence of penetrating corrosion. Identification of penetrating corrosion will be entered into the corrective action program. The inspection frequency is yearly.

Identification of aging effects does not require determination of the specific material composition in this application. Therefore, the specific copper composition was not researched. Oyster Creek has not experienced aged related material degradation

'failures of tubing in this application. There are no preventive actions associated with these components.

The function of the SGTS is routinely demonstrated by the monthly surveillance tests.

RAI 3.2-3 In LRA Table 3.2.2.1.3 the applicant identified no AERMs for plexiglass duct work in an internal and external indoor air environment. The staff requests the applicant to discuss its current maintenance practices for plexiglass in this environment as well as vendor recommendations in this regard. In addition, the staff requests the applicant to identifyl the specific composition of this plexiglass material and its operating experience at Oyster Creek.

Response

Plexiglass duct panels are installed on the absolute filter inlet and exhaust boxes of each SGTS train. As no maintenance or cleaning is performed, the industry cleaning and care recommendations to preclude scratching or crazing when cleaning are not implemented.

Although not identified, the specific material composition of the plexiglass is not required as there are no aging effects for acrylics (thermoplastics) in an indoor air environment.

Acceptability for the use of thermoplastics is a design driven criteria. Once the appropriate material is chosen, there are no aging effects. Thermoplastics are susceptible to aging effects due to such stressors as high temperature, chemicals, radiation and UV rays. None of these are present in this application. Oyster Creek has not experienced aged related material degradation failures of plexiglass in the SGTS system.

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RAI 3.4-1 In LRA Table 3.4.2.1.2 the applicant states that loss of material of buried aluminum piping and fittings in an external soil environment will be managed by the Buried Piping Inspection Program (B.1.26). The staff requests the applicant to provide the following information regarding the management of the aging effects:

a.

Identify the type of loss of material which is expected to occur (pitting, cracking, general corrosion etc.).

b.

Operating experience with this material in this environment.

c.

Type of external coatings and wrappings which will be used and the preventive measures to keep them in place.

ResDorise

a. Buried aluminum piping at Oyster Creek is coated to preclude loss of material.

Deterioration of the protective coating of aluminum piping at Oyster Creek resulted in loss of material due to pitting and galvanic corrosion.

b. Operating experience for the buried Condensate Transfer aluminum piping adjacent to the Condensate Transfer pump house has shown previous loss of material subsequent to protective coatings failure. The loss of material was attributed to galvanic corrosion and resulted in leakage of the piping. The galvanic mechanism was primarily due to interaction between aluminum pipe and a large copper grounding grid at the same location. A significant portion of the underground piping is no longer in contact with soil.

Piping was relocated aboveground or routed in precast concrete trenches. The remaining run of buried pipe was replaced and coated with the Polykin coating system.

Also, a short run of aluminum pipe between the turbine building and reactor building is buried. This piping is located at a different location on site not near the grounding grid.

Operating experience and soil samples at this piping location did not identify any leakage.

c. Replaced piping is coated with Polykin 1029 pipeline primer then 3 layers of Polykin 910 Oil Field utility tape with 50% overlap are applied. Preventive measures to keep them in place include tape termination points sealed with a double wrap of tape around the pipe.

The short run of pipe between the turbine building and reactor building is protected by a coal tar enamel. It has a felt wrap and waterproof exterior finish system.

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RAI 3.4-2 In LRA Table 3.4.2.1.2 the applicant states that loss of material of aluminum tanks in an air (internal and external) and external soil environments will be managed by the Aboveground Outdoor Tanks Program (B.1.21). The staff requests the applicant to provide the following information relative to the tanks:

a.

Specific alloy composition of the tank material.

b.

Description of the tank supports.

c.

Aging management of the sealant or coatings on the tank bottom, if any.

d.

Operating experience with the tanks.

e.

Purpose of the tanks (including a description of the services performed) and any other material in contact with its internal and external surfaces, such as expansion joints, piping connections etc.

f.

Specific tests, wall thickness measurements and inspections which assure that the leak tightness of the tanks is maintained in the internal and external outdoor air and soil environments.

Response

The one aluminum tank included in the Aboveground Outdoor Tanks program, B.1.21 is the Condensate Storage Tank (CST).

a. The tank shell plates are made from type 5086-H34 aluminum. The bottom plates are constructed from type 5086-Hi 16 aluminum. The materials are identified in the tank specification and drawings.

b. The tank is supported by a concrete ring and soil foundation. The tank is connected to

-the pad by 12 anchor brackets as specified in the tank specification and drawings.

c. Caulking is applied to tank/concrete seam on the exterior of the tank base to prevent water intrusion underneath the tank. Caulking will be inspected with external surfaces of

,Lank.

d. The tank bottom was inspected in 1980 and localized patch plate repairs were made.

Water seepage was discovered during the refueling outage in March 1991. Subsequent inspection found through wall corrosion and thinning of the bottom plates. The tank bottom was then replaced. A layer of clean, washed "low iron" silica sand was installed under the bottom of the new tank plates to inhibit corrosion as detailed in the tank repair

specification.

e. The in scope aluminum tank is the site Condensate Storage Tank. The purpose of the 6 of 22

Condensate Storage Tank as discussed in LRA section 2.3.4.2 is to provide for bulk storage of condensate, surge volume capability for the Condensate system and condensate supply for the Condensate Transfer system. Aluminum supply and return piping connect to the aluminum tank. Additionally, overflow and instrument lines and a vent, containing component materials other than aluminum, are connected to the tank. As specified in the Oyster Creek Line List and Specifications, aluminum piping systems are insulated and electrically isolated from ferrous materials.

f. Aging management of external tank surfaces exposed to air will be performed by visual inspections every five years. The internal surfaces exposed to outdoor air are subcomponents of the tank vent and will be inspected along with the external tank inspection.

The external tank surface in contact with soil is inspected by UT measurements of the bottom plates prior to the period of extended operation. A corrosion rate of the bottom plates is determined from thickness measurements and original plate thickness. The results of these inspections are monitored and trended and the tank bottom inspection frequency set such that component intended function is ensured.

Note, the internal surfaces of the tank are managed by the Water Chemistry and One-Time Inspection aging management programs.

RAI 3.4-3 In LRA Table 3.4.2.1.2 the applicant states that loss of material in stainless steel tanks in internal and external outdoor air environments is managed by the Aboveground Outdoor Tanks [Program (B.1.21). The staff requests the applicant to provide the following information:

a.

Description of the tanks including supports and other connecting piping.

b.

Specific tests and inspections (including wall thickness measurements) in the Aboveground Outdoor Tanks Program (B.1.21), which are performed relative to these tanks to assure structural integrity.

c.

Operating history of these tanks.

ResDoise There are no stainless steel tanks in the Aboveground Outdoor Tanks program, B.1.21. The stainless steel listed in LRA Table 3.4.2.1.2, is a screen frame sub-component of the aluminum Condensate Storage Tank (CST) roof vent. Visual inspections of this stainless steel sub-component are included as part of the recurring task inspection of the CST tank in this program.

Operating history of the CST is included in the response to RAI 3.4-2.

Therefore, a separate discussion of items a, b & c are not applicable.

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RAI 3.4-4 In LRA Table 3.4.2.1.3 the applicant states that carbon and low alloy steel piping and fittings in containment atmosphere (external) have no aging effects. According to the applicant the aging effect in the GALL Report for this component, material and environment combination is not applicable (Note I). The applicant cites a previous staf f evalual ion in which the staff had concluded that loss of material is not an aging effect for carbon steel components in a containment nitrogen environment, because of negligible amounts of free oxygen (less than 4 percent by volume) during normal operation.

The staff believes that due to leakage of moisture and presence of oxygen during plant shutdown, the potential for degradation of carbon steel components cannot be ruled out over an extended period of time. Therefore, there is a need for a one-time inspection prior to the period of extended operation, unless the applicant can provide additional assurance in support of its position (e.g., monitored data from the Oyster Creek containment nitrogen environment to indicate that the free oxygen levels have been continuously maintained below threshold levels and would continue to be maintained during the period of extended operation). The staff requests the applicant to justify its position or alternately, commit to a one-time inspection of these components prior to the period of extended operation.

Responise AmerGen will perform a one-time inspection of carbon steel feedwater system piping located inside containment. The one-time inspection will be a visual inspection of the carbon steel piping external surface for loss of material due to corrosion. This inspection will be performed prior to entering the period of extended operation. This one-time inspection is intended to confirm that there is no significant age related degradation occurring on the external carbon steel surfaces of the feedwater system located inside containment. If aging degradation is identified, the condition will be documented on an Issue Report and evaluated for corrective actions including additional feedwater system piping and component inspection locations.

RAI 3.4-5 In LRA Table 3.4.2.1.3 the applicant states that for carbon and low alloy steel valve bodies, in external containment air and treated water environments, there are no AERMs.

The staff requests the applicant to address the concerns described in RAI 3.4-4, as they are also applicable to carbon and low alloy steel valve bodies. The staff requests the applicant to justify and provide basis for its response.

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Response

As stated in the response to RAI 3.4-4, AmerGen will perform a one-time inspection of carbon steel feedwater system piping located inside containment. The one-time inspection will be a visual inspection of the carbon steel piping external surface for loss of material due to corrosion.

This inspection will be performed prior to entering the period of extended operation. This one-time inspection is intended to confirm that there is no significant age related degradation occurring on the external carbon steel surfaces of the feedwater system located inside containment. Since the piping and valves are carbon steel, and the environment is the same, results of the one-time inspection of the piping surface will also be applicable to the carbon sieel valve external surfaces. If aging degradation is identified, the condition will be documented on an Issue Report and evaluated for corrective actions including additional feedwater system piping and component inspection locations.

RAI 3.4-6 In LRA Table 3.4.2.1.4 the applicant states that there are no AERMs for the following main condenser subcomponents:

a.

Carbon and low alloy steel main condenser shell in indoor air (external) and steam (internal) environments,

b.

Titanium main condenser tubes in a raw salt water (internal) and steam (external) environment, and

c.

Aluminum/bronze tubesheet in a raw salt water (internal) and steam (external) environment.

The applicant further states that aging management of the main condenser is not based on analysis of materials, environments and aging effects. Condenser integrity required to perform the post accident intended function (holdup and plate out of MSIV leakage) is continuously confirmed by normal plant operation. Therefore, the applicant states that no traditional aging management review or aging management is required. The staff requests the applicant to provide the following information relating to the main condenser at Oyster Creek or provide justification that this information does not apply:

a.

Operational and maintenance history of the main condenser, summarizing the significant abnormal conditions or events which may have occurred In the past. This summary should include a brief discussion of the root cause determination and evaluation of these events, if available. The staff is particularly interested in events related to fouling, insulation failure, tube ruptures or major leaks, expansion joint failures, condenser air in-leakage 9 of 22

and condenser tube microbiologically induced corrosion.

b.

Discuss any concerns related to condenser capacity under power uprate conditions.

Resporse

a. The main condenser is a critical balance-of-plant component for power generation. The main condenser is required to continuously maintain vacuum pressure integrity to support normal power operation of the station. Condenser tubes can become fouled c r corroded as a result of normal plant operation, and these issues are addressed by tube

-leaning or tube plugging during refueling and maintenance outages. Tube corrosion, tube fouling or insulation failure does not immediately prevent continued plant operation, and does not prevent the main condenser from performing its intended function of post-accident holdup and plateout of main steam isolation valve (MSIV) bypass leakage.

Significant condenser air in-leakage would prevent the main condenser from maintaining normal vacuum and would require immediate corrective action or plant shutdown for repair. Air in-leakage does not prevent the main condenser from performing its intended Function of post-accident holdup and plateout of MSIV bypass leakage. Under post-accident conditions, condenser vacuum is lost and the condenser is at atmospheric pressure.

Major leaks including tube leaks and expansion joint failure would result in immediate shutdown for repair. Such failures would not be expected when the condenser is performing its post-accident intended function because the condenser is not under vacuum conditions and is at atmospheric pressure.

The intended function of the main condenser is to provide a post-accident holdup and plateout volume for MSIV bypass leakage. This intended function is not a pressure boundary function. The approach for aging management of the Main Condenser is to demonstrate adequate post-accident structural integrity of the Main Condenser, based on the fact that the condenser is operating prior to the accident and that the conditions, for the condenser are more severe during power operations than they are post-accident, when the MSIVs will be closed and vacuum will be lost. The structural integrity of the main condenser components during power operation will not immediately change post-accident, and no aging effects will cause a loss of intended function in the short time that

-the main condenser is credited following the accident. Since no aging effects can cause a loss of intended function, no aging management is required. Assurance that the main condenser will be available to perform its post-accident intended function is continuously demonstrated by its ability to support normal plant operation. This demonstration is not dependent on the operational and maintenance history of the main condenser. Although the Oyster Creek main condenser has performed well, as demonstrated by reliable plant operation, it is not necessary to consider the detailed operation and maintenance history to support the license renewal conclusion that an aging management program is not required.

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b. AmerGen has no plans to implement power uprate at Oyster Creek. Therefore, the main condenser will not be subject to power uprate conditions.

RAI 3.4-7 In LRA Table 3.4.2.1.6 the applicant states that for carbon and low alloy steel expansion joints, illow element and thermowells, in an internal and external containment atmosphere environment, there are no AERMs. As discussed in RAI 3.4-4 above, the staff considers a one-time inspection prior to the period of extended operation to be appropriate for these components. The staff requests the applicant to respond to these concerns as they relate to the main steam system and justify its position.

ResDonse As stated in the response to RAI 3.4-8, AmerGen will perform a one-time inspection of carbon steel main steam system piping located inside containment. The one-time inspection will be a visual inspection of the carbon steel piping external surface for loss of material due to corrosion.

This inspection will be performed prior to entering the period of extended operation. This one-time inspection is intended to confirm that there is no significant age related degradation occurring on the external carbon steel surfaces of the main steam system located inside containment. Since the piping, valves, expansion joints, flow elements and thermowells are carbon steel, and the environment is the same, results of the one-time inspection of the piping surface will also be applicable to these other carbon steel component external surfaces. If aging degradation is identified, the condition will be documented on an Issue Report and evaluated for corrective actions including additional main steam system piping and component inspection locations.

RAI 3.4-8 In LRA Table 3.4.2.1.6 the applicant states that for carbon and low alloy steel piping and fittings and valve bodies in internal and external containment air and internal treated water environments, the applicant has identified no AERMs. As discussed in RAI 3.4-4 above, the staff considers a one-time inspection prior to the period of extended operation to be appropriate for these components. The staff requests the applicant to respond to the above concerns as they relate to the main steam system and justify its position.

Response

AmerGon will perform a one-time inspection of carbon steel main steam system piping located inside containment. The one-time inspection will be a visual inspection of the carbon steel piping external surface for loss of material due to corrosion. This inspection will be performed prior to entering the period of extended operation. This one-time inspection is intended to 11 of 22

confirm that there is no significant age related degradation occurring on the external carbon steel surfaces of the main steam system located inside containment. Since the piping and valves are carbon steel, and the environment is the same, results of the one-time inspection of the piping surface will also be applicable to the carbon steel valve external surfaces. If aging degradation is identified, the condition will be documented on an Issue Report and evaluated for corrective actions including additional main steam system piping and component inspection locations.

RAI 4.7.1-1 The staff requests the applicant to discuss any major repairs, modifications or replacements done in the past which affected the original design basis of the reactor building, turbine and heater bay cranes at Oyster Creek. Also identify any lifts at or in excess of the capacity of these cranes which have occurred in the past.

Responise Operating experience review indicates that there were no major repairs of passive components made to the reactor building, turbine building, and heater bay cranes. However modifications were made to both the reactor building and the turbine building crane. The only major modification is the replacement of the original reactor building crane trolley with a new upgraded single failure-proof trolley that satisfies the guidelines of NUREG 0612, Section 5.1.6 "Single Failure Proof Handling Systems" As described in the UFSAR Section 9.1.4.2.3, the new trollEy main hoist is rated for 105 tons and the auxiliary hoist is rated for 10 tons. The design is in accordance with NUREG 0612, NUREG 0554 and specification CMAA-70. Other modifications and replacements done in the three cranes, in the past, consist of replacement of active components with state-of-art components to improve operational performance and instrument reliabili'y. For example a modification was initiated in 1995 to retrofit the entire existing reactor building crane control system.

The cranes are predominantly used for lifts that are significantly less than their rated capacity.

On occasion, the cranes are used for lifts near their capacity. Only the turbine building crane is used every 5 outages (10 years) for lifts that exceed its rated capacity of 150 Tons. The lifts consist of removing the main generator for inspection and repairs and reinstalling it.

Engineering evaluation was conducted to determine if the crane is capable of handling the lift, which is approximately 165 Tons. The evaluation concluded that the crane bridge, trolley, and supporting structure are capable of supporting the lift. However the capacity of a reduction g Bar and reduction pinion are exceeded. As a result Oyster Creek initiated a modification to upgrade the crane from 150 Ton rated capacity to 165 Tons. The modification consists of replacing existing motors and other active components, and replacing existing bolts and studs with SA-325 high strength material.

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RAI 4.7.1-2 The staff requests the applicant to discuss the operational history of the three cranes within the scope of license renewal.

Responise A review of the site operating and maintenance experience found no history of age-related degradation that adversely impacts the structural support intended function of the reactor building crane, turbine building crane, and the heater bay crane. Minor degradations that are not aged related, such as a bent support angle for the main walkway handrail of the reactor building crane, and overstressed bolts on the same walkway, were identified during the recent crane inspection. The support angle and the bolts were replaced. NDE examinations identified weld indications that were subsequently determined to be acceptable as-is. Other identified crane problems were due to degradation of active components that do not impact the license renewal intended function.

RAI B..2.1-1 The staff requests the applicant to discuss any aging mechanisms for the piping support materials in the containment air environment. In addition provide the bases for identifying these aging mechanisms or identifying no aging mechanism for the environment and material combination.

Responise The ASME Section Xl Subsection IWF program B.1.28 addresses aging management for piping supports for the ASME Class 2 containment spray piping in the containment air environment, as shown in LRA Table 3.5.2.1.18. For carbon and low alloy steel support materials in an air -

indoor uncontrolled environment, which is how the containment air environment is conservatively treated for piping supports, the aging effect of loss of material is due to the mechanisms of general and pitting corrosion, in accordance with GALL line item lll.B13.2-8 (T-24). No aging effect or program is credited for cumulative fatigue damage of these piping supports under GALL item 1ll.B13.2-7 (T-26), as cumulative fatigue is not a TLAA in the Oyster Creek CLB. The aging effect of loss of mechanical function of carbon and low alloy steel supports is due to the aging mechanisms of corrosion, distortion, dirt, overload, and fatigue due to vibratory and cyclic thermal loads, in accordance with GALL line item lll.B13.3-2 (T-28).

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RAI B.2.1-2 As stal:ed in the LRA, the applicant conducts flow tests with air rather than water. The staff believes that since the reaction forces on the supports and the spray nozzles are substantially less with air flow versus water flow, the periodic flow tests simply assure that there is no clogging of the spray nozzles but do not test the structural integrity of the spray system under actual operating conditions. The staff's concern is that the piping supports and nozzles may not be able to withstand the forces exerted during accident conditions when water is turned on and potentially result in a failure of the spray system.

Therefore, the staff requests the applicant to provide justification to assure that the structural integrity of the system under accident conditions will be maintained during the period of extended operation.

Respoise Pre-operational testing of the containment spray piping was performed with water at design flow to assure the structural integrity of the system under accident conditions. During those water flow tests, the piping supports and nozzles were shown to be able to withstand the forces exerted during actual operating conditions. The airflow tests were subsequently implemented to demonstrate that the nozzles were clear without wetting the spray piping and containment equipment. The ASME Section Xl Subsection IWF program B.1.28 addresses aging management and the continued structural integrity of the ASME Class 2 containment spray piping supports during the period of extended operation, as shown in LRA Table 3.5.2.1.18.

RAI B.'2.4-1 In LRA Section B.2.4 the applicant states that existing ventilation system periodic preventive maintenance activities will be enhanced as follows:

"Instrument piping and valves, restricting orifices and flow elements, thermowells and Standby Gas Treatment System ducts exposed to soil will be added to the scope of the plant implementation documents."

The staff requests the applicant to provide a listing of the line items in the LRA AMR Tables which would be within the scope of this AMP and would be credited.

ResDonse Seven systems credit the Periodic Inspection of Ventilation Systems program. They include the 480V Switchgear Room Ventilation, Battery and MG Set Room Ventilation, C Battery Room Heating & Ventilation, Control Room HVAC, Radwaste Area Heating and Ventilation System, Reactor Building Ventilation System and the Standby Gas Treatment System (SGTS). The line items in the program are included in the License Renewal Application AMR Tables 3.3.2.1.03, 3.3.2.1.04, 3.3.2.1.01, 3.3.2.1.10, 3.3.2.1.28, 3,3,2,1,31 and 3.2.2.1.3 respectively. The list of 14 of 22

the items crediting the Periodic Inspection of Ventilation Systems program is attached as Tatle 1 to this enclosure.

RAI B.2.4-2 In LRA Section B.2.4, the applicant states that existing ventilation system periodic preventive maintenance activities will be enhanced as follows:

"Specific guidance for identification of applicable aging effects will be added to preventive maintenance documents."

The information in the LRA suggests that the identification of the aging effects is currently based on qualitative acceptance criteria. The staff requests the applicant to discuss in detail the enhancements to indicate whether or not any aging effects would be identified on the basis of quantitative acceptance criteria such as durometer reading limits for identification of aging effects in elastomers.

Respoise The general inspection acceptance criteria for components in the Periodic Inspection of Ventilation Systems program is qualitative. When aging effects are identified as not meeting acceptance criteria, such as penetrating corrosion for metals and loss of material, hardening or tears in elastomers, or fouling of heat transfer surfaces, the issue will be entered into the corrective action program and will be evaluated. The corrective action program will ensure that conditions adverse to quality are addressed.

An exception to this is the quantitative inspection incorporated into ventilation program inspection criteria to determine loss of material of buried Standby Gas Treatment System ducts as modified with internal aluminum sleeves. Refer to RAI 3.2-2 item a) response for the discussion of this inspection process.

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Table I Periodic Inspection of Ventilation Systems program - Aging Management Review Results SSC Name Structure and/or Material Environment Aging Effect Component 480V Switchgear Room Door Seal Elastomer Indoor Air Change in Ventilation (External)

Material Properties 480V Switchgear Room I Door Seal Elastomer Indoor Air Loss of Material Ventilation I

(External) 480V Switchgear Room l Door Seal Elastomer Indoor Air Loss of Material Ventilation (Internal) 480V Switchgear Room Door Seal 1 Elastomer Indoor Air Change in Ventilation (Internal)

Material l

j Properties X

i P o e t e 480'1 Switchgear Room Door Seal Elastomer I Outdoor Air Loss of Material Ventilation l _

(External) 480'1 Switchgear Room 'Door Seal I Elastomer Outdoor Air Change in Venmilation l

(External)

Material Properties 480'1 Switchgear Room Fan Housing

'Carbon and low Outdoor Air

'Loss of Material Ven:ilation alloy steel (External) 480'1 Switchgear Room Fan Housing I Carbon and low Indoor Air Loss of Material Ven:ilation alloy steel (Internal) 480'1 Switchgear Room Filter Housing Galvanized Steel Outdoor Air Loss of Material Venmilation l

E (External) 480'1 Switchgear Room Flexible Connection Elastomer Indoor Air Change in Ventilation (Internal)

Material llProperties

,-O Change 480V Switchgear Room Flexible Connection Elastomer Outdoor Air lChange in Ventilation (External)

Material j

I

!Properties i-_ _ __ _ _ _ __ _ _ _ -

a-- -- __ _ _ _ _ _ _

I-P o e t e 480V Switchgear Room Piping and fittings Brass Outdoor Air Loss of Material Ventilation I

(External) 480V Switchgear Room Piping and fittings Copper Outdoor Air

'Loss of Material Ventilation (External) 480'1 Switchgear Room Sensor Element M Stainless Steel Outdoor Air Loss of Material Ventilation (External) 16 of 22

SSC Name Structure and/or l

Material Environment Aging Effe S

Component E

480V Switchgear Room Valve Body Brass i Outdoor Air j Loss of Material Ventilation (External)

Battery and MG Set Door Seal Elastomer Indoor Air Loss of Material Room Ventilation (Internal) i Battery and MG Set Door Seal Elastomer Indoor Air Change in Room Ventilation (Internal)

Material Properties I

Battery and MG Set Door Seal Elastomer Outdoor Air Loss of Material l

Room Ventilation (External)

Battery and MG Set Door Seal Elastomer Outdoor Air Change in Room Ventilation (External)

Material

_Properties Battery and MG Set Fan Housing Carbon and low Outdoor Air Loss of Material Room Ventilation l _

alloy steel (External)

Battery and MG Set

[ Fan Housing Carbon and low Indoor Air Loss of Material Room Ventilation alloy steel (Internal)

Battery and MG Set Filter Housing Galvanized Steel

' Outdoor Air Loss of Material Room Ventilation I

(External)

Battery and MG Set Flexible Connection l Elastomer Outdoor Air I Change in Room Ventilation (External)

Material l

Properties Battery and MG Set Flexible Connection Elastomer Indoor Air Change in Roo-m Ventilation I

(Internal)

Material

.Properties Battery and MG Set I Piping and fittings Brass Outdoor Air Loss of Material Room Ventilation E

E (External)

Battery and MG Set Piping and fittings Copper Outdoor Air I Loss of Material Roo:m Ventilation i __

l (External)

M Battery and MG Set Sensor Element Copper Outdoor Air Loss of Matet Roo Ventilation L

(Temperature)

(External)

Battery and MG Set Valve Body Brass Outdoor Air Loss of Material Roo:mn Ventilation i

, (External)

C Battery Room Heating Door Seal Elastomer i Indoor Air Loss of Material

& Ventilation l I

, (External)

C Battery Room Heating Door Seal I Elastomer Indoor Air Change in

& Ventilation I

i (External)

Material l_

I_

i Properties 17 of 22

SSC Name Structure and/or l

Material Environment l

Aging Effect Component l

C Bittery Room Heating Door Seal Elastomer

! Indoor Air j Change in

& Ventilation (Internal)

Material l_

_ P r o p e r t i e s C Battery Room Heating !Door Seal I Elastomer

'Indoor Air Loss of Material

& Ventilation D

S E

(Internal)

C Battery Room Heating l Fan Housing l Carbon and low I Indoor Air Loss of Matef ial

& Ventilation alloy steel (Internal)

Cabo an lo Inoo Air C Battery Room Heating Fan Housing Carbon and low Indoor Air Loss of Material

& Ventilation alloy steel (External)

C Battery Room Heating Flexible Connection Elastomer Indoor Air Change in

& Ventilation (Internal)

Material Properties C Battery Room Heating Flexible Connection Elastomer Indoor Air Change in

&Ventilation

.(External)

'Material

__i__!__X_

Properties Control Room HVAC Damper housing Carbon and low Indoor Air Loss of Matefial alloy steel (Internal)

Control Room HVAC Door Seal Elastomer Indoor Air Loss of Material i

l_

_(External)

Control Room HVAC Door Seal Elastomer Outdoor Air Change in (External)

Material ii __,___I____Properties Control Room HVAC Door Seal Elastomer Outdoor Air Loss of Material (External)

Con Tol Room HVAC Door Seal Elastomer I Indoor Air Change in (External)

Material I

Properties Con rol Room HVAC Door Seal Elastomer Indoor Air l Loss of Material l_

I_

((Internal)

I Control Room HVAC Door Seal Elastomer l Indoor Air Changein (Internal)

Material i ii i_ Properties i----

a-______

Con iol Room HVAC Fan Housing

'Carbon and low l Indoor Air Loss of Material alloy steel (Internal)

Con-iol Room HVAC Fan Housing Carbon and low Indoor Air Loss of Material alloy steel (External) 18 of 22

SSC Name Structure and/or l

Material Environment Aging Effect Component Control Room HVAC Fan Housing l Galvanized Steel Outdoor Air Loss of Material l_ _ _(External) l Control Room HVAC Filter Housing Carbon and low Indoor Air Loss of Material i

alloy steel j (Internal)

Control Room HVAC Filter Housing Carbon and low Indoor Air Loss of Material alloy steel l (External)

Control Room HVAC l Filter Housing I Galvanized Steel I Outdoor Air l Loss of Material i_

l (External)

Control Room HVAC Flexible Connection

,Elastomer Indoor Air Change in (Internal)

Material IIProperties Control Room HVAC

'Flexible Connection Elastomer Indoor Air Change in E (External)

Material Properties Control Room HVAC Heat Exchangers i Copper (fins)

Outdoor Air Reduction of (Condensing Coil) l (External)

Heat Transfer Control Room HVAC Heat Exchangers Copper (coils) l Outdoor Air Reduction of (Condensing Coil)

(External)

Heat Transfer Control Room HVAC Heat Exchangers Copper (coils)

Outdoor Air Loss of Material (Condensing Coil) i (External) i (C onde sing.C oi )

(E xte n l Control Room HVAC Heat Exchangers Copper (coils)

Indoor Air Reduction of i (Evaporator Coil)

(External)

Heat Transfer Control Room HVAC Heat Exchangers Copper (coils)

Indoor Air Loss of Mate ial i

(Evaporator Coil)

I (External)

Control Room HVAC Heat Exchangers Aluminum (fins)

Indoor Air Reduction of I_

(Evaporator Coil)

(External)

Heat Transfer Control Room HVAC I Heater Housing i Galvanized Steel Outdoor Air Loss of Material Roo ilExternal)

Control Room HVAC E Piping and fittings Stainless Steel Outdoor Air Loss of Material

_(E xternal) i'_

Control Room HVAC Piping and fittings Polyvinyl Chloride Outdoor Air Change in (PVC, CPVC)

(External)

Material l

Properties Control Room HVAC Piping and fittings Brass Outdoor Air Loss of Material i __

l_

_ i i(External)

_i Control Room HVAC

'Piping and fittings Copper Outdoor Air Loss of Material (External) i 19 of 22

SSC Name Structure and/or l

Material Environment Aging Effect Component I

Radwaste Area Heating Door Seal l Elastomer Indoor Air Change in and Ventilation System (Internal)

Material Properties Radwaste Area Heating Door Seal iElastomer Outdoor Air

! Loss of Material and Ventilation System

.__l (External)

-l--___

Radwaste Area Heating Door Seal Elastomer Indoor Air Loss of Mateiial and Ventilation System (Internal)

Rad waste Area Heating Door Seal i Elastomer

! Outdoor Air l Change in and Ventilation System l

(External)

Material

_l_

i Properties Radwaste Area Heating Fan Housing Carbon and low Outdoor Air Loss of Material l

and Ventilation System alloy steel (External)

__i Rad waste Area Heating Fan Housing Carbon and low Indoor Air Loss of Mater ial and Ventilation System l

alloy steel (Internal)

Rad waste Area Heating i Flexible Connection Elastomer Outdoor Air

'Change in and Ventilation System (External)

'Material Properties Rad waste Area Heating i Flexible Connection Elastomer Indoor Air Change in and Ventilation System I (Internal)

Material

'l_ __

_Properties X

Reactor Building l Door Seal Elastomer Indoor Air Loss of Material Ventilation System i

(External)

Reactor Building l Door Seal

! Elastomer Indoor Air Loss of Material V tilation System I

(Internal)

Reactor Building Door Seal

! Elastomer Indoor Air Change in Ventilation System i

(External)

Material i__

i_

_i _ _IiProperties Reactor Building Door Seal I Elastomer Indoor Air i Change in Ventilation System j

(Internal)

, Material l_

,1 Properties Reactor Building Piping and fittings Carbon and low Indoor Air I Loss of Material Ventilation System

, alloy steel (External)

Reactor Building Piping and fittings I Carbon and low Indoor Air Loss of Material Ventilation System l

,alloy steel

, (Internal)

Reactor Building lValve Body i Cast Iron Indoor Air Loss of Material Ventilation System I (Internal) 20 of 22

SSC Name Structure and/or Material Environment Aging Effect Component Reactor Building Valve Body Cast Iron Indoor Air Loss of Material Ventilation System (External)

Stardby Gas Treatment Damper Housing Carbon and low Indoor Air l Loss of Matelial System (SGTS)

[alloy steel (Internal)

Standby Gas Treatment Door Seal Elastomer Indoor Air Loss of Mater tat System (SGTS) l

, (External)

Stardby Gas Treatment Door Seal Elastomer Outdoor Air Change in System (SGTS) l (External)

Material I

_Properties Standby Gas Treatment Door Seal Elastomer Indoor Air Change in System (SGTS) l (External)

Material Properties Stardby Gas Treatment Door Seal j

Elastomer Indoor Air Loss of Material System (SGTS)

(Internal)

Standby Gas Treatment Door Seal Elastomer Indoor Air Change in System (SGTS)

(Internal)

Material Properties Standby Gas Treatment !

Door Seal

Elastomer Outdoor Air Loss of Material System (SGTS)

(External)

Stardby Gas Treatment

'Ductwork Aluminum

'Soil (External)

Loss of Material System (SGTS)

Standby Gas Treatment I Fan Housing Carbon and low Indoor Air Loss of Material System (SGTS) l

, alloy steel (Internal)

Standby Gas Treatment Fan Housing

'Carbon and low Outdoor Air Loss of Material System (SGTS) l

, alloy steel (External)

Standby Gas Treatment Flexible Connection Elastomer Indoor Air Change in System (SGTS)

(Internal)

Material

_!_IProperties Standby Gas Treatment Flexible Connection Elastomer Outdoor Air Change in System (SGTS)

(External)

Material Properties Standby Gas Treatment Flow Element Stainless Steel Outdoor Air Loss of Mateial System (SGTS) i (External)

Standby Gas Treatment Piping and fittings Brass Outdoor Air Loss of Material System (SGTS)

!(Exta(Exte l

Standby Gas Treatment Piping and fittings Carbon and low Indoor Air Loss of Material System (SGTS) alloy steel (External) 21 of 22

SSC Name Structure and/or Material Environment Aging Effe Component Standby Gas Treatment Piping and fittings Copper Outdoor Air Loss of Material Systenm (SGTS) i (External)

Standby Gas Treatment Piping and fittings Stainless Steel Outdoor Air I

Loss of Material System (SGTS)

St I

(xss o

i Standby Gas Treatment Piping and fittings Carbon and low Indoor Air Loss of Material System (SGTS) 1alloy steel (Internal)

Standby Gas Treatment I Restricting Orifice Carbon and low l Indoor Air I Loss of Material System (SGTS) l l alloy steel (Internal)

Standby Gas Treatment Restricting Orifice Carbon and low Indoor Air Loss of Material System (SGTS) l _alloy steel (External)

Standby Gas Treatment Restricting Orifice Carbon and low Indoor Air Loss of Material System (SGTS)

¢ alloy steel (External)

Standby Gas Treatment Restricting Orifice Carbon and low Indoor Air Loss of Material System (SGTS) alloy steel (Internal)

Standby Gas Treatment Thermowell Stainless Steel

'Outdoor Air E Loss of Material System (SGTS)

(External)

Standby Gas Treatment Valve Body

! Brass Outdoor Air Loss of Material System (SGTS) l (External)

Standby Gas Treatment Valve Body j Cast Iron Outdoor Air Loss of Material L

System (SGTS)

(External)

I Standby Gas Treatment Valve Body Cast Iron Indoor Air Loss of Material Systerm (SGTS)

(External)

I Standby Gas Treatment Valve Body Cast Iron Indoor Air Loss of Material System (SGTS)

(Internal) 22 of 22 Summary of Commitments The following table identifies commitments made in this document. Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.

Committed One-Time Commitment Date or Action Programmatic Outage (Yes/No)

(Yes/No)

1. AmerGen will perform a one-time Prior to the Yes No inspection of carbon steel period of feedwater system piping located extended inside containment. The one-operation time inspection will be a visual inspection of the carbon steel piping external surface for loss of material due to corrosion. This inspection will be performed prior to the period of extended operation.

2. AmerGen will perform a one-time Prior to the Yes No inspection of carbon steel main period of steam system piping located extended inside containment. The one-operation time inspection will be a visual inspection of the carbon steel piping external surface for loss of material due to corrosion. This inspection will be performed prior to the period of extended operation.