This safety evaluation report (SER) documents the technical review of the Calvert Cliffs Nuclear Power Plant, Units 1 and 2 license renewal application by the U.S. Nuclear Regulatory Commission (NRC) staff. The Baltimore Gas and Electric Company requested renewal of the Class 104b operating licenses for the Calvert Cliffs units (license numbers DPR-53 and DPR-69) for a period of 20 years beyond the current expiration of midnight, July 31, 2014, for Unit 1 and midnight, August 13, 2016, for Unit 2. By letter dated April 8, 1998, the Baltimore Gas and Electric Company submitted the license renewal application for Calvert Cliffs in accordance with Part 54 of Title 10 of the Code of Federal Regulations.

The Calvert Cliffs nuclear station is located on the west shore of the Chesapeake Bay in Calvert County, Maryland, approximately 45 miles southeast of Washington, D.C., and 60 miles south of Baltimore, Maryland. Operation of the twin Combustion Engineering pressurized-water reactors results in an approximate net electrical output of 845 megawatts for each reactor.

This SER presents the results of the staff's review of information submitted in conjunction with the renewal application. In an earlier version of this safety evaluation report (SER) issued on March 21, 1999, the staff identified a number of open and confirmatory items. All of those items have been resolved, as discussed in this SER. On the basis of its evaluation of the application the staff concludes that: (1) actions have been identified and have been or will be taken with respect to managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require an aging management review under 10 CFR 54.21(a)(1), and (2) actions have been identified and have been or will be taken with respect to time-limited aging analyses that have been identified to require review under 10 CFR 54.21(c). Accordingly, the staff finds that there is reasonable assurance that the activities authorized by a renewed license will continue to be conducted in accordance with the current licensing basis for the Calvert Cliffs Nuclear Power Plant, Units 1 and 2.

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Summary

This report describes the results of a review by the Nuclear Regulatory Commission (NRC) staff of an application to renew the licenses for the two units of the Calvert Cliffs nuclear power plant. Under the Atomic Energy Act, the NRC issues licenses for commercial power reactors to operate for up to 40 years. The Act also permits the licenses to be renewed. The NRC established license renewal requirements in the regulations. When those requirements are satisfied, a license can be renewed for up to 20 additional years.

Plant owners are interested in license renewal because they need to know what requirements must be satisfied to permit long-term plant operation. This knowledge helps them to predict the cost of plant operation for long-term energy planning.

The requirements for license renewal are presented in Part 54 of Title 10 to the Code of Federal Regulations (10 CFR Part 54). When those requirements were developed, the NRC concluded that the existing licensing basis and the regulatory process are adequate to maintain safe plant operation, except for the possible effects of aging on passive systems, structures and components. Therefore, the requirements in Part 54 focus on managing the effects of aging for passive structures and components, like buildings, tanks and pipes.

The NRC also established requirements for a license renewal environmental report in Part 51. Those requirements establish the scope of a review of environmental impacts, which is part of the NRC's responsibilities under the National Environmental Policy Act (NEPA). The results of that review are described in a separate NRC report.

In a letter dated April 8, 1998, the Baltimore Gas and Electric Company (BGE) filed an application to renew the licenses for their two-unit Calvert Cliffs plant. BGE requested a 20-year extension in the license term for both units. The existing licenses expire on midnight July 31, 2014 and August 13, 2016, respectively. If granted, the renewed licenses would extend to July 31, 2034 and August 13, 2036, respectively.

The Calvert Cliffs plant is located on the west shore of the Chesapeake Bay in Calvert County, Maryland. It is approximately 45 miles southeast of Washington, D.C., and 60 miles south of Baltimore, Maryland. Each unit is a Combustion Engineering pressurized water reactor that produces a net electric output of about 845 megawatts.

In accordance with Part 54, BGE submitted information in their renewal application that identifies all plant systems, structures, and components: (1) that are safety-related; (2) whose failure could affect safety-related functions; and (3) that are relied on to demonstrate compliance with the NRC's regulations for fire protection, environmental qualification, pressurized thermal shock, anticipated transients without scram, and station blackout. BGE's application also describes how the effects of aging will be managed in such a way that the intended functions of those structures and components will be maintained for the 20-year period of extended operation. These structures and components include, but are not limited to, the containment building, other safety-related structures, the reactor vessel, the reactor cooling system pressure boundary, steam generators, the pressurizer, piping, pump casings, and valve bodies. The surveillance and maintenance programs for active equipment (for example, motors, diesel generators, air compressors, control rod drives, instruments, cooling fans, and batteries), as well as other aspects of the plant design and licensing basis, are required to be maintained throughout the period of extended operation.

For some passive structures and components within the scope of the renewal evaluation, no additional action was required where BGE demonstrated that the existing programs provide adequate aging management. In other cases, BGE described changes to existing programs and new programs to ensure that applicable aging effects would be adequately managed. These activities include, for example, adding new monitoring programs, increasing inspections, or revising inspection criteria.

Another requirement for license renewal is the identification and updating of time-limited aging analyses. During the design phase for a plant, certain assumptions about the length of time the plant will be operated are made and incorporated into design calculations for several of the plant's systems, structures, and components. These calculations must be shown to be valid for the period of extended operation or be projected to the end of the period of extended operation, or the applicant must demonstrate that the effect of aging on these structures, systems, and components will be adequately managed for the period of extended operation.

This report describes the results of the NRC staff's review of the BGE programs to manage aging effects. In this report, we conclude that BGE has demonstrated that aging effects applicable to the required scope of systems, structures and components will be adequately managed for the 20-year period of extended operation. Our evaluation describes the features of the maintenance and inspection programs that we relied on to develop this conclusion. Our evaluation also describes how BGE has resolved our questions about specific aging management concerns. In some cases, our conclusion is based on changes in procedures or actions that will be taken in the future. These procedure changes and future actions are summarized in a list included as Appendix E to this report. BGE will update their final safety analysis report, associated with the existing license, to include the changes to the licensing basis reflected in the Appendix E list, which we relied on to grant a renewed license.

During meetings to gather public comments about the environmental impacts of extending the Calvert Cliffs licenses, we heard several concerns related to plant safety because of aging effects. Interested individuals and groups expressed specific concerns regarding embrittlement of the reactor vessel and other aging effects on plant safety systems and fuel storage facilities. In applicable sections of this report, we describe the particular programs, maintenance activities, and inspection procedures that we have relied on to conclude that those concerns have been adequately addressed.

The conclusions in this report have been verified by inspections conducted by the NRC. The scope of the inspections consisted of selected information in the renewal application and information in this report. The inspection results form the basis for a separate recommendation by the Administrator of the regional office responsible for the plant.

The basis for the conclusions in this report are also reviewed by the NRC's Advisory Committee on Reactor Safeguards. They independently review the application, and submit their recommendation directly to the Commission. Their recommendation is included in the published version of this report.

In our recommendation for granting a renewed license for Calvert Cliffs, we have described the programs, maintenance activities, and inspection procedures that we rely on to conclude that there is reasonable assurance that actions have been or will be taken to manage effects of aging for a 20-year period of extended operation, such that the plant can continue to operate safely.

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1 Introduction and General Discussion

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1.1 Introduction

This document is a safety evaluation report (SER) on the application for license renewal for the Calvert Cliffs Nuclear Power Plant, Units 1 and 2, as filed by the applicant Baltimore Gas and Electric Company (BGE or Applicant). By a letter dated April 8, 1998, BGE submitted its application to the United States Nuclear Regulatory Commission (NRC) for renewal of the Calvert Cliffs operating licenses for an additional 20 years. This report was prepared by the NRC staff and summarizes the results of the staff's safety review of the renewal application for compliance with the requirements of 10 CFR Part 54 "Requirements for Renewal of Operating Licenses for Nuclear Power Plants." The NRC License Renewal Project Manager for Calvert Cliffs is David L. Solorio. Mr. Solorio may be contacted by calling 301-415-1973, or by writing to the License Renewal and Standardization Branch, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001.

In its April 8, 1998, submittal, BGE requested renewal of the Class 104b operating licenses for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (license numbers DPR-53 and DPR-69, respectively) for a period of 20 years beyond the current license expirations of midnight, July 31, 2014, and midnight, August 13, 2016, respectively. The nuclear station is located on the west shore of the Chesapeake Bay in Calvert County, Maryland, approximately 45 miles southeast of Washington, DC, and 60 miles south of Baltimore, Maryland. Operation of the twin Combustion Engineering pressurized-water reactors results in an approximate net electrical output of 845 megawatts for each reactor. Details concerning the plant and the site are contained in the Updated Final Safety Analysis Report (UFSAR) for Calvert Cliffs Nuclear Power Plant, Units 1 and 2.

The license renewal process proceeds along two tracks: a technical review of safety issues and an environmental review. The requirements for these reviews are stated in NRC regulations 10 CFR Parts 54 and 51, respectively. The safety review for the Calvert Cliffs license renewal is based on BGE's application for license renewal and on the licensee's answers to requests for additional information (RAIs) from the NRC staff. In meetings and docketed correspondence, BGE has also supplemented the answers that it has given to the RAIs. The license renewal application and all pertinent information and materials, including the UFSAR mentioned above, are available to the public for review at the NRC Public Document Room, 2120 L Street, NW., Washington, D.C. 20555-0001. In addition, the application and significant information and materials related to the renewal review are available on the NRC Web page at www.nrc.gov.

This SER summarizes the results of the staff's safety review of the Calvert Cliffs license renewal application and delineates the scope of the technical details considered in evaluating the safety aspects of its proposed operation for an additional 20 years beyond the term of the current operating license. The license renewal application was reviewed in accordance with the NRC regulations and the guidance provided in the NRC draft Standard Review Plan (SRP) for the Review of License Renewal Applications for Nuclear Power Plants, dated September 1997.

Chapters 2 through 4 of the SER address the staff's review and evaluation of license renewal issues that have been considered during the review of the application. Chapter 5 contains the report by the Advisory Committee on Reactor Safeguards (ACRS). The conclusions of this report are given in Chapter 6.

Appendix A is a chronology of NRC's principal correspondence related to the review of the application. Appendix B is a bibliography of the references used during the course of the review. Appendix C is a list of abbreviations used throughout the report. The NRC staff principal reviewers and its contractors for this project are listed in Appendix D.

Appendix E presents a summary listing of the programs, maintenance activities and inspection procedures that formed a significant basis for the staff's conclusion. As such, this list represents those commitments that warrant regulatory control. BGE will incorporate appropriate changes to the next update of the final safety analysis report (FSAR), following the issuance of the renewed license. The FSAR will be updated for each item in Appendix E in accordance with the guidance for 10 CFR Section 50.71(e). Since future changes to the FSAR will be made in accordance with 10 CFR Section 50.59, these programs, maintenance activities and inspection procedures will be adequately controlled. Until the FSAR update is complete, a license condition requires that any changes to the items on the list be made in accordance with Section 50.59.

The listing in Appendix E also identifies future actions. Throughout this safety evaluation report, the staff has described various schedules for future actions. The staff has determined that none of the future actions are required prior to the end of the current license term in order to effectively manage aging. Therefore, as long as they are completed by the end of the current license term, licensee can make changes to such schedules without prior NRC approval. However, all of the future actions must be completed before the plant enters the period of extended operation, except for the volumetric inspections of the control element drive mechanisms in Unit 1 which will be completed by 2029 as described in Section 3.2.3.2.1.C (6) of the SER. Accordingly, the renewed license also includes a condition that all of the future actions must be completed by the end of the existing license term.

In accordance with 10 CFR Part 51, the staff prepared draft and final plant-specific supplements to the generic environmental impact statement (GEIS) that discuss the considerations related to renewing the license for the Calvert Cliffs Nuclear Power Plant, Units 1 and 2. The draft and final plant-specific supplements to the GEIS were issued separate from this report.

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1.2 License Renewal Background

Pursuant to the Atomic Energy Act of 1954, as amended, and NRC regulations, licenses for commercial power reactors to operate are issued for 40 years. These licenses can be renewed for up to 20 additional years. The original 40-year license term was selected on the basis of economic and antitrust considerations--not by technical limitations. However, some individual plant and equipment designs may have been engineered on the basis of an expected 40-year service life.

In 1982, the NRC held a workshop on nuclear power plant aging, in anticipation of the interest in license renewal. That led the NRC to establish a comprehensive program plan for nuclear plant aging research (NPAR). Based on the results of that research, a technical review group concluded that many aging phenomena are readily manageable and do not pose technical issues that would preclude life extension for nuclear power plants. In 1986, the NRC published a request for comment on a policy statement that would address major policy, technical, and procedural issues related to life extension for nuclear power plants.

In 1991, the NRC published the license renewal rule in 10 CFR Part 54. The NRC participated in, and industry sponsored, demonstration programs to apply the rule to pilot plants and develop experience to establish implementation guidance. To establish a scope of review for license renewal, the rule defined age-related degradation unique to license renewal. However, during the demonstration program, the NRC found that many aging mechanisms occur and are managed during the period of the initial license. In addition, the NRC found that the scope of the review did not allow sufficient credit for existing programs, particularly the implementation of the maintenance rule, which also manages plant aging phenomena.

As a result, in 1995 the NRC amended the license renewal rule. The amended Part 54 established a regulatory process that is simpler, more stable, and more predictable than the previous license renewal rule. In particular, Part 54 was clarified to focus on managing the adverse effects of aging rather than on identification of all aging mechanisms. The rule changes were intended to ensure that important systems, structures, and components will continue to perform their intended function in the period of extended operation. In addition, the integrated plant assessment (IPA) process was clarified and simplified to be consistent with the revised focus on passive, long-lived structures and components.

In parallel with these efforts, the NRC pursued a separate rulemaking to similarly focus the scope of the review of environmental impacts of license renewal, under 10 CFR Part 51, which is part of the NRC's responsibilities under the National Environmental Policy Act of 1969 (NEPA).

1.2.1 Safety Reviews

License renewal requirements for power reactors are based on two key principles:

(1)

The regulatory process is adequate to ensure that the licensing bases of all currently operating plants provide and maintain an acceptable level of safety, with the possible exception of the detrimental effects of aging on the functionality of certain plant systems, structures, and components in the period of extended operation and possibly a few other issues related to safety only during the period of extended operation.

(2)

The plant-specific licensing basis must be maintained during the renewal term in the same manner and to the same extent as during the original licensing term.

In implementing these two principles, the rule in 10 CFR 54.4, defines the scope of license renewal as those plant systems, structures, and components (a) that are safety-related; (b) whose failure could affect safety-related functions; and (c) that are relied on to demonstrate compliance with the NRC's regulations for fire protection, environmental qualification, pressurized thermal shock, anticipated transients without scram, and station blackout.

Pursuant to 10 CFR 54.21(a) the applicant must review all systems, structures, and components within the scope of the rule to identify structures and components subject to an aging management review (AMR). Structures and components subject to an AMR are those that perform an intended function without a change in configuration or properties and are not subject to replacement based on qualified life or specified time period. As required by 10 CFR 54.21(a), it must be demonstrated that the effects of aging will be managed in such a way that the intended function or functions of those structures and components will be maintained for the period of extended operation. Active equipment, however, is considered to be adequately monitored and maintained by existing programs. In other words, the detrimental aging effects that may occur for active equipment are more readily detectable and will be identified and corrected by routine surveillance, performance indicators, and maintenance. The surveillance and maintenance programs for active equipment, as well as other aspects of maintaining the plant design and licensing basis, are required throughout the period of extended operation. Section 54.21(d) requires that a supplement to the FSAR contain a summary description of the programs and activities for managing the effects of aging.

Another requirement for license renewal is the identification and updating of time-limited aging analyses. During the design phase for a plant, certain assumptions about the length of time the plant will be operated are made and incorporated into design calculations for several of the plant's systems, structures, and components. Under 10 CFR 54.21(c)(1), these calculations must be shown to be valid for the period of extended operation or be projected to the end of the period of extended operation, or the applicant must demonstrate that the effect of aging on these structures, systems, and components will be adequately managed for the period of extended operation.

In 1996, the NRC developed and issued draft regulatory guide DG-1047, "Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses." This guide proposes to endorse an implementation guideline prepared by the Nuclear Energy Institute (NEI) as an acceptable method of implementing the license renewal rule. The NEI guideline is NEI 95-10, "Industry Guideline for Implementing the Requirements of 10 CFR Part 54--The License Renewal Rule," which was issued in March 1996. The NRC prepared a draft standard review plan for the safety review, which was made available in the Public Document Room in September 1997. The draft regulatory guide will be used, along with the draft standard review plan, to review applications and to assess technical issue reports involved in license renewal as submitted by industry groups. As experience is gained, NRC will improve the standard review plan and clarify regulatory guidance.

1.2.2 Environmental Reviews

The environmental protection regulations, 10 CFR Part 51, were revised in December 1996 to facilitate the environmental review for license renewal. The staff prepared a Generic Environmental Impact Statement (GEIS) for License Renewal of Nuclear Plants, NUREG-1437, in which the staff examined the possible environmental impacts associated with renewing licenses of nuclear power plants. For certain types of environmental impacts, the GEIS establishes generic findings that are applicable to all nuclear power plants. These generic findings are identified as Category 1 issues in 10 CFR Part 51, Subpart A, Appendix B. Pursuant to 10 CFR51.53(c)(3)(i), an applicant for license renewal may incorporate these generic findings in an environmental report and address only those environmental impacts that are required to be evaluated on a plant-by-plant basis.

The NRC performs plant-specific reviews of the remaining environmental impacts of license renewal (those identified as Category 2 issues in 10 CFR Part 51, Subpart A, Appendix B) as well as any new and significant information, in accordance with NEPA and the requirements of 10 CFR Part 51. A public meeting was held on July 9, 1998, near Calvert Cliffs nuclear power plant as part of the scoping process to identify environmental issues specific to the plant. The result of the environmental review is an NRC preliminary recommendation with respect to the license renewal action. This is known as a draft plant-specific supplement to the GEIS, which is published for comment and discussed at a separate public meeting. After consideration of comments on the draft, NRC prepares and publishes a final plant-specific supplement to the GEIS.

Two public scoping meetings were held on July 9, 1998 to identify environmental issues specific to the plant. On February 24, 1999, the staff issued the Draft Supplement 1 to the GEIS, regarding the results of the staff's environmental review of Calvert Cliffs. During the 75-day comment period that followed, two public meetings were held on April 6, 1999, in which the staff described the results of the NRC environmental review and answered questions related to it in order to provide members of the public with information to assist them in formulating any comments they might have regarding the review. On October 5, 1999, the staff issued the Final Supplement 1 to the GEIS on Calvert Cliffs, in which it presents its final environmental analysis that considers and weighs the environmental effects of the license renewal, the environmental impacts of alternatives to license renewal, and alternatives available for avoiding adverse environmental effects. The staff considered and addressed the comments that were received during the comment period.

Based on (1) the analysis and findings in the Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants, NUREG-1437; (2) the Environmental Report submitted by BGE; (3) consultation with other Federal, State, and local agencies; (4) its own independent review; and (5) its consideration of public comments, the staff recommended, in Supplement 1 to NUREG-1437 that the Commission determine that the adverse environmental impacts of license renewal for Calvert Cliffs Nuclear Power Plant Units 1 and Unit 2 are not so great that preserving the option of license renewal for energy planning decisionmakers would be unreasonable.

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1.3 Summary of Principal Review Matters

The requirements for the renewal of operating licenses for nuclear power plants are described in 10 CFR Part 54. The staff performed its technical review of the Calvert Cliffs application for license renewal in accordance with Commission guidance and the requirements of 10 CFR Sections 54.19, 54.21, 54.22, 54.23, and 54.25. The standards for issuance of a renewed license are contained in 10 CFR 54.29. This SER describes the results of the staff's technical review.

In 10 CFR 54.19(a), the Commission requires a license renewal applicant to provide general information. Baltimore Gas and Electric provided this general information in Attachment 1 to its April 8, 1998, submittal letter regarding the application for renewed operating licenses for the Calvert Cliffs Nuclear Power Plant, Units 1 and 2. The staff finds that Calvert Cliffs has provided the information required by 10 CFR 54.19(a) in Attachment 1 of the April 8, 1998, submittal letter.

In 10 CFR 54.19(b), the Commission requires that license renewal applications include "conforming changes to the standard indemnity agreement, 10 CFR 140.92, Appendix B, to account for the expiration term of the proposed renewed license." BGE states the following in its renewal application regarding this issue:

The current indemnity agreement (B-70) for licenses DPR-53 and DPR-69 does not contain a specific expiration term. Expiration is expressed in terms of the time of the expiration of the licenses specified. Therefore, conforming changes to account for the expiration term of the proposed renewed licenses are unnecessary.

The staff notes that the current indemnity agreement for Calvert Cliffs states in Article VII that the agreement shall terminate at the time of expiration of that license specified in Item 3 of the attachment to the agreement. Item 3 of the attachment to the indemnity agreement lists two license numbers. By maintaining the license numbers on issuance of the renewed license, there is no need to make conforming changes to the indemnity agreement. Therefore, the requirements of 10 CFR54.19(b) have been met.

In 10 CFR 54.21, the Commission requires that each application for a renewed license for a nuclear facility shall include an integrated plant assessment (IPA), current licensing basis (CLB) changes during NRC review of the application, an evaluation of time-limited aging analyses (TLAAs) and a final safety analysis report (FSAR) supplement. In 10 CFR 54. 22, the Commission states requirements regarding technical specifications. The staff evaluated the technical information required by 10 CFR 54.21 and 10 CFR 54.22 in accordance with the NRC's regulations and the guidance provided by the draft standard review plan entitled "Review of License Renewal Applications for Nuclear Power Plants," which was published in September 1997. The staff's evaluation of the license renewal application in accordance with 10 CFR 54.21 and 54.22 are contained in Chapters 2, 3, and 4 of this report.

The staff's evaluation of the environmental information required by 10 CFR 54.23 can be found in the draft and final plant-specific supplements to the GEIS, NUREG-1437, Supplement 1, that state the considerations related to renewing the license for the Calvert Cliffs Nuclear Power Plant, Units 1 and 2.

The report by the Advisory Committee on Reactor Safeguards required by 10 CFR 54.25 is included in Chapter 5 of this SER. The finding required by 10 CFR 54.29 is contained in Chapter 6 of this report.

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1.4 Summary of Open and Confirmatory Items

As a result of its initial review of the license renewal application for Calvert Cliffs, including the additional information provided to the NRC, the staff identified a number of open issues and confirmatory items when this report was issued in March 1999. This report has been revised to include a description, in each applicable section, of the manner by which those matters have been resolved.

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2 Structures and Components Subject to an Aging Management Review

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2.1 Methodology for Identifying Structures and Components Subject to an Aging Management Review

Applicants for license renewal are required by the license renewal rule to perform, among other things, an integrated plant assessment (IPA). The first two steps of the IPA, 10 CFR 54.21(a)(1) and 10 CFR 54.21(a)(2), require the applicant to identify and list, from those systems, structures, and components (SSCs) within the scope of the license renewal rule, those structures and components that are subject to an aging management review and to describe and justify the methods used to determine those structures and components subject to review. SSCs within the scope of the license renewal rule are those meeting the criteria in 10 CFR 54.4. Structures and components subject to an aging management review are those that meet the criteria of 10 CFR 54.21(a)(1)(i) and (ii).

In a letter dated August 18, 1995, BGE (the applicant) submitted its "Integrated Plant Assessment Methodology," which was subsequently amended to incorporate changes required by the staff. The amendment to the IPA was submitted in a BGE letter dated January 11, 1996. The staff reviewed this methodology and found it acceptable as documented in a Final Safety Evaluation (FSE) dated April 4, 1996. The BGE license renewal application (LRA) dated April 8, 1998, contains the IPA methodology, technically unchanged from that previously submitted in Attachment 1, Appendix A, Section 2. The staff concluded in its FSE that:

The BGE methodology sufficiently describes and justifies an acceptable process for identifying structures and components at Calvert Cliffs, Units 1 and 2, that are subject to an aging management review for license renewal and therefore would meet the requirement of 54.21(a)(2). In addition, this process, if implemented, provides reasonable assurance that all structures and components subject to an aging management review pursuant to 10 CFR 54.21(a)(1) will be identified.

The staff's evaluation of the implementation of the process for identifying SSCs that are subject to an aging management review pursuant to 10 CFR 54.21(a)(1) is contained in Section 2.2 of this safety evaluation report (SER).

2.2 Identification of Structures and Components Subject to an Aging Management Review

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2.2.1 Introduction

In Sections 3 through 6 of Appendix A, "Technical Information," to the LRA, BGE (the applicant) described the structures and components that are subject to an aging management review (AMR) for license renewal. The staff reviewed these sections of the application to determine if there is reasonable assurance that the applicant has identified and listed those structures and components subject to an AMR to meet the requirements stated in 10 CFR 54.21(a)(1).

2.2.2 Staff's Approach to the Evaluation

The staff reviewed Sections 3 through 6 of Appendix A to the LRA to determine if there is reasonable assurance that the applicant has appropriately identified and listed those structures and components subject to an AMR to meet the requirements stated in 10 CFR 54.21(a)(1). The statements of consideration (SOC) for the license renewal rule (60 FR 22478) indicate that an applicant has the flexibility to determine the set of structures and components for which an AMR is performed, provided that this set encompasses the structures and components for which the Commission has determined an AMR is required. Accordingly, the staff focused its review on verifying that the implementation of the applicant's methodology discussed in Section 2.1 of this staff SER did not result in the omission of structures and components subject to an AMR in accordance with 10 CFR 54.21(a)(1). The staff performed the following two-step evaluation:

(1)

The first step was to determine whether the applicant has properly identified the systems, structures, and components (SSCs) within the scope of license renewal, pursuant to 10 CFR 54.4. As described in more detail below, the staff reviewed selected structures and components that the applicant did not identify as within the scope of license renewal to verify that they do not have any intended functions.

(2)

The second step was to determine whether the applicant has properly identified the structures and components (S&Cs) subject to an AMR from among those identified in the first step. As described in more detail below, the staff reviewed selected S&Cs that the applicant identified as within the scope of license renewal to verify that the applicant has identified these S&Cs as subject to an AMR if they perform intended functions without moving parts or without a change in configuration or properties and are not subject to replacement on the basis of a qualified life or specified time period. To determine whether the applicant identified the S&Cs subject to an AMR, the staff did not review S&Cs that the applicant had identified as subject to an AMR because it is an applicant's option to include more S&Cs than those required by 10 CFR 54.21(a)(1).

The staff used the Calvert Cliffs Updated Final Safety Analysis Report (UFSAR) in performing its review. Pursuant to 10 CFR 50.34(b), the FSAR contains "[a] description and analysis of the structures, systems, and components of the facility, with emphasis upon performance requirements, the bases, with technical justification therefor, upon which such requirements have been established, and the evaluations required to show that safety functions will be accomplished." The FSAR is required to be updated periodically pursuant to 10 CFR 50.71(e). Thus, the UFSAR contains updated plant-specific licensing-basis information regarding the systems, SSCs, and their functions.

2.2.3 Systems, Structures, and Components

The applicant presented its methodology (i.e., the integrated plant assessment (IPA)) to identify the systems, structures, and components (SSCs) within the scope of license renewal in Section 2.0 of Appendix A to the LRA. This IPA methodology consists of a review of all plant systems and structures to determine those that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4. The staff reviewed the IPA methodology, and in a letter to the applicant dated April 4, 1996, the staff concluded that the methodology was acceptable for meeting the requirements of 10 CFR 54.21(a)(2) and, if implemented, offered reasonable assurance that all structures and components subject to an aging management review (AMR), as required by 10 CFR 54.21(a)(1), would be identified. Additionally, the letter stated that the staff concluded that the methodology provides processes for demonstrating that the effects of aging would be adequately managed pursuant to 10 CFR 54.21(a)(3) and for evaluating time-limited aging analyses pursuant to 10 CFR 54.21(c) that are conceptually sound and consistent with the intent of the license renewal rule.

To ensure that the IPA methodology described in Section 2.0 of Appendix A to the LRA properly implemented and identified the systems and structures within the scope of license renewal, the staff performed the following additional review. The staff compared the list of systems and structures at the Calvert Cliffs Nuclear Power Plant (CCNPP) listed in Table 3-1 in Section 2.0 of Appendix A to the LRA, to a list of the 66 systems and structures identified by the applicant as conforming to the scoping requirements of 10 CFR 54.4. The staff identified those systems and structures not included within the scope of license renewal and reviewed the information contained in the UFSAR for a sample of these systems and structures to determine whether they performed any intended function defined by 10 CFR 54.4, and thus would be required to be included within the scope of license renewal. The staff found no omissions. However, to ensure the applicant did not omit any system or structures with intended functions, by letter dated August 27, 1998, the staff requested additional information about eight systems and structures outside the scope of license renewal. In response to the staff's request for additional information, on November 2, 1998, the applicant submitted additional information about the five systems and three structures. For each system and structure, the applicant submitted a general description, listed the specific intended functions (active and passive), and identified the portion of the LRA in which the system's components were reviewed (if the system or structure performed an intended function). For example, the staff requested additional information about the reactor protective system. In its response, the applicant identified the three passive intended functions performed by this system and added that the components within the scope of license renewal that performed this intended function were evaluated in either Section 6.2, "Electrical Commodities"; Section 5.9, "Feedwater System"; or Section 6.1, "Cable Commodities."

The staff reviewed the information submitted by the applicant in the LRA and additional information submitted in response to the NRC's August 27, 1998, memorandum, and did not find any systems or structures with intended functions that were not already evaluated in the LRA. Therefore, the staff has reasonable assurance that the applicant had appropriately identified the systems and structures within the scope of license renewal in accordance with 10 CFR 54.4.

2.2.3.1 Component Supports Commodity Group

In Section 3.1, "Component Supports," of Appendix A to the LRA, the applicant described the systems with component supports at CCNPP that are within the scope for license renewal, and identified which of those structures and components are subject to an AMR.

2.2.3.1.1 Summary of Technical Information in the Application

As described in the LRA, component supports are associated with almost every plant system. A component support is the connection between a system, or a component within a system, and a plant structural member. Because component supports perform the same basic function regardless of the system, the applicant reviewed these components as a commodity group.

The applicant prepared a generic list of component supports by reviewing industry and plant-specific information, including the Seismic Qualification Utility Group guidance, American Society of Mechanical Engineers, Section XI, component support inspection documentation, and the CCNPP system level scoping results for license renewal. The applicant identified all component support types that provide support to plant components that are within the scope of license renewal and listed them as being within the scope of license renewal. The applicant identified 48 systems within the scope of license renewal that contained supports within this commodity group evaluation.

The applicant grouped the total population of component supports into four categories. The categories include supports for both the distributive portions of systems (e.g., piping and cable raceways) and for system equipment. The categories are defined by the components they support: piping; cable raceways; heating, ventilating, and air conditioning ducting; and equipment. These four categories are further separated into 19 sub-categories based on similarities of physical characteristics, loading conditions, and environment.

The applicant identified the following intended functions for the component supports within the scope of license renewal:

Provide structural support for systems and components required to remain functional during and following design-basis events.
Provide structural support for systems and components whose failure could prevent satisfactory accomplishment of safety functions for items identified in the preceding category.
Provide structural support for systems and components that are required for fire protection, environmental qualification, pressurized thermal shock, anticipated transient without scram, and station blackout.

The applicant identified the following component supports within the scope of license renewal that are evaluated elsewhere in Appendix A to the LRA:

Supports for the steam generators (other than the snubbers) and the reactor vessel, evaluated in Sections 4.1 and 4.2 of Appendix A to the LRA
Spent fuel pool cooling demineralizer and filter vessel supports, evaluated in Section 5.18 of Appendix A to the LRA.
Jet impingement barriers and whip restraint supports for high energy line break analysis, evaluated in Section 3.3 of Appendix A to the LRA with the structure that houses the individual component
Tubing supports, evaluated in Section 6.4 of Appendix A to the LRA

The applicant noted that all of the intended functions listed above are passive because they accomplish their function without moving parts or a change in configuration or property. The applicant therefore concluded that all component supports within the scope of license renewal are also subject to an AMR.

On the basis of the intended functions listed above, the applicant identified the following 19 component support types from the component support groups within the scope of license renewal as being subject to an AMR:

COMMODITY SUPPORT GROUPS AND TYPES
Piping Supports	Spring hangers, constant load, snubber supports--OC
Piping Supports	Spring hangers, constant load, snubber supports--IC
Piping frames and stanchions--OC
Piping frames and stanchions--IC
Cable Raceway Supports	Trapeze, cantilever, other supporting styles--OC
Piping frames and stanchions--IC
HVAC Ducting Supports	HVAC ducting supports--OC
HVAC ducting supports--IC
Equipment Supports	Elastomer vibration isolators--OC
Electrical cabinet anchorage--OC
Electrical cabinet anchorage--IC
Equipment frames and stanchions--OC
Equipment frames and stanchions--IC
Frames and saddles--OC
Frames and saddles--IC
Metal spring isolators and fixed bases--OC
Metal spring isolators and fixed bases--IC
Loss-of-coolant accident restraints--IC
Ring foundations for flat-bottomed vertical tanks--OC

OC - Outside Containment, IC - Inside Containment

2.2.3.1.2 Staff Evaluation

The staff reviewed Section 3.1 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the component supports within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, by letter dated September 7, 1998, the staff issued a request for additional information (RAI) regarding component supports, and by letter dated November 19, 1998, the applicant responded to the RAI.

2.2.3.1.2.1 Component Supports Within the Scope of License Renewal

In the first step of its evaluation, the staff reviewed the information submitted by the applicant in the LRA to identify if there were systems or portions of systems with component supports that the applicant failed to identify as within the scope of license renewal that should have been so identified. The applicant stated in the LRA that all component support types that provide support to plant components that are within the scope of license renewal are identified and these component support types are listed as being within the scope of license renewal. The staff compared Table 3.1-1, which is found in Section 3.1 of Appendix A to the LRA, with Table 3-1, which is found in Section 2.0 of Appendix A to the LRA, to determine if the applicant omitted any component supports when compiling its list of such systems within the scope of license renewal. The staff also sampled selected systems not listed in Table 3.1-1 to verify that they do not have any intended functions as defined in Section 3.1 of Appendix A to the LRA.

To help ensure that all systems with component supports within the scope of license renewal were listed in Table 3.1-1, the staff requested more detailed information from the applicant. In NRC Question Nos. 3.1.1 and 3.1.8, the staff noted seven systems in Table 3-1 of Section 2.0 of Appendix A to the LRA that were within the scope of license renewal but that did not appear in Table 3.1-1 of Section 3.1. The applicant responded that two of the systems were within the scope of license renewal, but contained no component supports; one was a portion of a system already listed in Table 3.1-1 (SG blowdown system is part of the MS system); three systems were evaluated in other commodity or system reports (e.g., the containment isolation group's individual containment penetrations are evaluated in each individual system's section); and one system was determined to be outside the scope of license renewal and, therefore, its component supports were outside the scope. One system, diesel generator building HVAC system, was inadvertently omitted from Table 3.1-1. The applicant corrected this error in its November 19, 1998, response to the staff's RAI, by adding the diesel generator building HVAC component supports to Table 3.1-1.

In NRC Question No. 3.1.4, the staff requested clarification on whether steel structural frames used for the support of piping systems were treated as component supports or as structural components. In its response, the applicant stated that the piping support frames were considered component supports and were discussed in Section 3.1 of Appendix A to the LRA. Information regarding the boundary of commodity supports was requested in NRC Question No. 3.1.6, specifically, were fasteners included, and if fasteners have welded connections, are they included within the scope of the components commodity report. The applicant clarified in its response that fasteners and attachments associated with the component side of the component support are evaluated in the component supports commodity group. Fasteners on the structure side of the component support are evaluated in both the component support commodity evaluation and in the evaluation for the specific structure. Welds and fasteners were not identified specifically, rather, they were considered part of the support.

As described above, the staff has reviewed the information in Section 3.1 of Appendix A to the LRA and the additional information submitted by the applicant in response to the staff's RAIs. On the basis of that review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the component supports within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.1.2.2 Component Supports Subject to an Aging Management Review

In Table 3.1-1 of Appendix A to the LRA, the applicant identified systems and their associated component supports within the scope of license renewal. In Section 3.1.1.1 of Appendix A to the LRA, the applicant stated that because these component supports performed their intended function without moving parts or without a change in configuration or properties, they have passive intended functions. Therefore, all component supports (except for snubbers, which were excluded as "active" equipment by 10 CFR 54.21(a)(1)(i)), are within the scope of license renewal. The applicant further clarified that the snubber subcomponents that mount the snubber to the pipe or component and to the structural component are referred to as snubber supports, and are included within the scope of license renewal and are subject to an AMR. Table 3.1-2 of Appendix A to the LRA summarizes all the component support types requiring an AMR. The staff agrees with the applicant's inclusion of all the component support types listed in Table 3.1-2 as requiring an AMR.

The staff reviewed the information in Section 3.1 of Appendix A to the LRA and has determined that there is reasonable assurance that the applicant has appropriately identified the component supports subject to an AMR to meet the requirements stated in 10 CFR 54.21(a)(1).

2.2.3.2 Piping Segments That Provide Structural Support

In Section 3.1A, "Piping Segments That Provide Structural Support," of Appendix A to the LRA, the applicant described the piping segments that provide structural support and that are within the scope for license renewal and identified which of those piping segments are subject to an AMR.

2.2.3.2.1 Summary of Technical Information in the Application

Systems that have safety-related/non-safety-related (SR/NSR) boundaries or changes in piping classification have a boundary valve at the functional transition point. The structural integrity of the boundary valve, which functions as the system pressure boundary, must not be compromised. To ensure proper seismic structural support if the valve itself is not anchored, the system's structural boundary must be extended beyond the boundary valve to the first seismic anchor (or equivalent) and must include the pipe segment connecting the boundary valve to the pipe support. These components together act as a single support system, ensuring the integrity of the SR/NSR functional boundary under all design-basis conditions.

Providing structural support under all current licensing-basis design loading conditions for safety-related components (within the scope of license renewal) is the only intended function identified by the applicant for these piping segments. Because the intended function is performed without moving parts or a change in configuration or properties, it is a passive intended function and, therefore, piping segments that provide such support are subject to an AMR.

All fluid systems containing safety-related piping are within the scope of license renewal. These systems have the potential for having SR/NSR functional boundaries where piping segments beyond the functional boundary would be credited for structural support of the boundary. The applicant reviewed all of the fluid systems at CCNPP and identified those systems with safety-related piping in Table 3.1A-1 of Appendix A to the LRA. A total of 25 systems were identified as having the potential for SR/NSR functional boundaries with seismic boundaries extending beyond them for structural support.

2.2.3.2.2 Staff Evaluation

The staff reviewed Section 3.1A of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the piping segments providing structural support within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.2.3.2.2.1 Piping Segments That Provide Structural Support Within the Scope of License Renewal

To determine which piping segments are credited with providing structural support for boundary valves and isolation points at SR/NSR boundaries, the staff performed the following reviews. The staff compared Table 3.1A-1 in Section 3.1 of Appendix A to the LRA and Table 3-1 in Section 2.0 of Appendix A to the LRA to determine if the applicant omitted any safety-related fluid systems when compiling its list of systems to evaluate for functional boundaries. The applicant considers all piping segments beyond the SR/NSR functional boundary that perform the intended function of providing structural support to the safety-related piping and boundary isolation valve or isolation point as being within the scope of license renewal. The staff also reviewed the UFSAR to determine if there were CCNPP fluid systems that might perform safety-related functions or other intended functions as described in 10 CFR 54.4 that were not identified in Table 3.1A-1. The staff sampled CCNPP fluid systems not included in Table 3.1A-1 to determine if the applicant had omitted any systems having the potential for safety-related or non-safety-related functional boundaries. No omissions were identified.

Safety-related systems have the potential for SR/NSR functional boundaries where non-safety-related piping segments may provide structural support beyond the functional boundary. The LRA identified the safety-related fluid systems that have the potential for SR/NSR functional boundaries with structural boundaries extending beyond the functional boundaries within the scope of license renewal. As described above, the staff reviewed the information in Section 3.1A of Appendix A to the LRA and concluded that there is reasonable assurance that the applicant has appropriately identified the piping segments providing structural support to safety-related piping and boundary valves within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.2.2.2 Piping Segments That Provide Structural Supports Subject to an Aging Management Review

In Table 3.1-1 of Appendix A to the LRA, the applicant identified systems within the scope of license renewal with the potential for containing piping segments beyond SR/NSR boundaries that provide structural support to the safety-related piping and boundary isolation valve or isolation point. In Section 3.1.A.1.1 of Appendix A to the LRA, the applicant stated that because these portions of piping segments performed their intended function without moving parts or without a change in configuration or properties, they have passive intended functions. Therefore, all of these piping segments are included within the scope of license renewal and are subject to an AMR. The staff agrees with the applicant's inclusion of all these piping segments as requiring an AMR.

The staff has reviewed the information in Section 3.1A of Appendix A to the LRA. On the basis of the staff's review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the piping segments that provide structural supports subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.2.3.3 Fuel Handling Equipment and Other Heavy Load Handling Cranes

In Section 3.2, "Fuel Handling Equipment (FHE) and Other Heavy Load Handling Cranes (HLHCs)," of Appendix A to the LRA, the applicant described structures and components of the FHE and HLHCs that are within the scope of license renewal (10 CFR 54.4). The applicant also identified which of those within-scope structures and components are subject to an AMR in accordance with 10 CFR 54.21(a)(1)(i) and (ii). By a letter to the NRC dated February 4, 1999, the applicant supplemented the scope of Section 3.2 by identifying additional structures and components that are within the scope of license renewal and subject to an AMR. In addition, the staff issued RAIs by letter dated August 26, 1998, regarding the FHE and HLHC commodity report. By letter dated November 4, 1998, the applicant responded to the staff's RAIs.

The staff reviewed Section 3.2, of Appendix A to the LRA, against the requirements of 10 CFR 54.4 (a)(1), (2), and (3) and 10 CFR 54.21(a)(1)(i) and (ii). More specifically, the staff focused its review on determining whether there is reasonable assurance that the applicant identified and listed (1) FHE and HLHC structures and components that are within the scope of license renewal and (2) FHE and HLHC structures and components that are subject to an AMR in accordance with the requirements stated in 10 CFR 54.21(a)(1).

2.2.3.3.1 Summary of Technical Information in the Application

The applicant stated that the structures and components of the FHE and HLHCs are common to many systems. Therefore, the applicant's evaluation is presented in Section 3.2 of Appendix A to the LRA as a separate commodity report on all the FHE and HLHC structures and components within the plant. Some of the FHE and HLHC structural type components, as discussed later in this section of the SER, are identified in Section 3.2 but are evaluated in the individual system sections or buildings in which they are housed.

The FHE and HLHC commodity report addresses (1) all structures and components involved in fuel handling and transfer and (2) cranes that routinely lift heavy loads over safety-related equipment. The applicant identified seven systems with structures and components that define the FHE and HLHC that are within scope for license renewal: (1) spent fuel storage (spent fuel pool), (2) refueling pool, (3) new fuel storage and elevator, (4) spent fuel cask washing pit, (5) fuel transfer tube, (6) fuel handling system, and (7) cranes. These major systems are described as follows:

(1)	Spent Fuel Storage System: The CCNPP Units 1 and 2 spent fuel storage system (SFSS), or spent fuel pool (SFP), is located in the auxiliary building and consists of the SFP, the spent fuel shipping cask pit (within the SFP), the spent fuel shipping cask support platform, the SFP work platform, and SFP storage racks.
	The SFP is located outside the containment in the auxiliary building and provides underwater storage for 1830 spent fuel assemblies and one spent fuel shipping cask. It is designed in two halves, north and south for Units 1 and 2, respectively, and is constructed of reinforced concrete lined with stainless steel (SS).
	The spent fuel shipping cask pit is an integral part of the SFP and is located on the Unit 1 side of the SFP. It is used to house the cask during loading with spent fuel bundles.
	The spent fuel shipping cask support platform is a SS energy-absorbing cask support platform upon which the cask is set before being loaded with spent fuel bundles. It is located on the floor of the spent fuel shipping cask pit. The cask support platform is made of a SS shell that encloses an aluminum honeycomb material.
	The SFP platform is a portable work platform 16 feet long x 4 feet wide. It is used to perform various maintenance, testing, and inspection activities in the SFP. For example, the platform is used during repair of spent fuel assembly guide tubes, and the performance of eddy current tests. It is constructed of aluminum decking with SS structural members and can be located along designated walls of the SFP.
	The SFP storage racks are fabricated of SS and boron carbide sheets and are in 10x10, 8x10, and 7x10 arrays in the Unit 1 pool and 10x10 arrays in the Unit 2 pool. The racks meet the requirements of seismic Category I.
(2)	Refueling Pool: CCNPP's refueling pool is constructed of reinforced concrete and lined with SS. It is located around the upper portion of the reactor vessel and filled with water from the refueling water storage tank by the SFP cooling pumps. The refueling pool is connected to the SFP by the fuel transfer tube, the safety injection system, and the spent fuel pool cooling system.
(3)	New Fuel Storage System and Elevator: The new fuel storage system consists of the new fuel dry storage racks and the new fuel inspection machine (new fuel storage inspection platform). It does not include the new fuel elevator which is part of the fuel handling system discussed under item 6 below. New fuel is removed from its shipping cask using the spent fuel cask handling crane and transferred to the storage racks. Each rack provides storage for 144 fuel assemblies (two-thirds of a core). New fuel is stored in the SFP as space allows. The new fuel inspection machine is located near the new fuel storage area. The new fuel inspection machine is designed to automatically check the straightness and sectional size of a fuel bundle through its full length.
(4)	Spent Fuel Cask Washing Pit: The spent fuel cask washing pit is constructed of reinforced concrete lined with SS and provides for storage and decontamination of spent fuel transfer/shipping casks. (This component is evaluated in Section 3.3E of Appendix A to the LRA.)
(5)	Fuel Transfer Tube: The fuel transfer tube connects the refueling pool with the SFP and accommodates the transfer of fuel between the two areas. (This component is evaluated in Section 3.3A of Appendix A to the LRA.)
(6)	Fuel Handling System: The fuel handling system contains those components used to move fuel from the time new fuel is received until the spent fuel is stored in the SFP. The system includes (a) the new fuel elevator, (b) the spent fuel handling machine, (c) fuel upending machines, (d) the transfer carriage, (e) the reactor refueling machine, and (f) the spent fuel inspection elevator. These components are described as follows:
	The New Fuel Elevator--The new fuel elevator is used to lower new fuel assemblies into the SFP where the spent fuel handling machine (SFHM) is able to grapple and transfer the fuel to the desired pool location. The new fuel elevator is located in the Unit 1 end of the SFP.
	Spent Fuel Handling Machine--The SFHM, also referred to as the fuel pool service platform, is a bridge and trolley arrangement that rides on rails set in concrete on each side of the SFP. The SFHM functions to transfer fuel between the storage locations in the SFP, the new fuel elevator, the spent fuel inspection elevator, the SFP upending machine, or a spent fuel shipping cask, as necessary.
	Fuel Upending Machines--There are two fuel upending machines for each unit, one in the containment structure refueling pool and the other in the SFP. Each consists of a structural steel support base from which an upending straddle frame is pivoted. The straddle frame engages the fuel carrier. When the carriage with its fuel carrier is in position within the upending frame, the pivots for the fuel carrier and the upending frame are coincident. Hydraulic cylinders attached to both the upending frame and the support base rotate the fuel carrier between a vertical and a horizontal position, as required.
	Transfer Carriage--The transfer carriage transports one or two fuel assemblies through the transfer tube between the refueling pool and the SFP. The carriage is driven by SS cables connected to the carriage and through sheaves to its driving winches mounted below the operating floor level. The fuel carrier is mounted on the carriage and is pivoted for tilting by the upending machines.
	Reactor Refueling Machine--The reactor refueling machine (RRM) is a traveling bridge and trolley that spans the refueling pool and moves on rails. The bridge and trolley movement allow one to coordinate the location for the fuel handling mast and hoist assembly over the fuel in the core. The RRM mast and hoist assembly is used for transporting and positioning fuel assemblies in the core and over the upending machine in the refueling pool. The RRM auxiliary hoist is used in conjunction with the control element assembly handling tool to exchange control element assemblies within the reactor core during refueling.
	Spent Fuel Inspection Elevator--The spent fuel inspection elevator is similar to the new fuel elevator, but is equipped with a fixed underwater periscope. Fuel assemblies are raised and lowered in front of the periscope to permit fuel inspection. The spent fuel inspection elevator has additional design features to prevent the hoist from raising fuel above the point at which adequate water for shielding is available. The spent fuel inspection elevator is located in the Unit 2 end of the SFP.
(7)	Cranes: The crane system is described as all cranes, monorails, and hoisting and jib equipment at CCNPP. The applicant stated that there are approximately 85 cranes in the plant and grouped them into three types: overhead gantry cranes, monorail systems and underhung cranes, and overhead hoists. The applicant further grouped the components of the cranes into mechanical components and electrical components. The mechanical components include overhead monorail systems, cranes, monorail tracks, carriers or trolleys, motor-driven electric hoist carriers, gears, hoists, hooks, bridges, and lift-drop sections. Electrical components include motors, connectors, contacts, electric lift and drop sections, motor starters, and control panels. The applicant also identified the specially designed structural load handling devices such as the lifting rig for the reactor vessel cooling shroud and the reactor vessel head (reactor vessel internals system) as structural components in the crane system.

As noted above, two of the systems identified as within scope for license renewal are addressed in other sections of Appendix A to the LRA.

In the LRA, the applicant identified the following intended functions for the above noted structures and components in the FHE and HLHC based on the requirements of 10 CFR 54.4(a)(1) and (2):

Provide structural and/or functional support to safety-related equipment;
Provide structural and/or functional support to non-safety-related equipment whose failure could directly prevent satisfactory accomplishment of any of the required safety-related functions; and
Provide structural and/or functional support for lifting heavy loads over the SFP.

The applicant also determined that there are no intended functions of the FHE and HLHC based on the requirements of 10 CFR 54.4(a)(3).

On the basis of its evaluation of the structures and components that provide the intended functions noted above, the applicant identified a total of 57 structural components/ subcomponents that are within the 5 systems and/or structures and components that constitute the FHE and HLHC and are within scope for license renewal and subject to an AMR.

As discussed in the LRA and the UFSAR, the FHE and HLHC structural components are designated as safety-related and are designed to meet seismic Category I criteria because they must remain functional before, during, and after a safe-shutdown earthquake. Therefore, most of FHE and HLHC structural components perform the first and second intended functions noted above. For example, the SFP is designed to maintain structural integrity during a seismic event in order to support spent fuel in the SFP. Also, the SFP storage racks are designed to withstand all anticipated loadings and are separated in such a manner as to preclude a reduction in separation space under either operating-basis or safe-shutdown earthquake.

In addition, the applicant cited five major cranes in the crane system that handle heavy loads that are functionally not safety-related, but are considered safety-related because they are used to handle heavy loads in the vicinity of the reactor vessel, near spent fuel in the SFP, or in areas in which, if a load is dropped, could damage safe-shutdown or decay-heat-removal equipment. These cranes are the polar crane, the intake structure semi-gantry crane, the transfer jib machine crane, the containment purge exhaust monorail hoist, and the spent fuel cask handling crane (SFCHC).

These cranes are categorized as seismic Category I/II and satisfy the intended functions as noted above. The SFCHC crane (auxiliary building crane) is also designed in accordance with the single-failure-proof criteria in NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants," and NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants."

In Table 3.2-1 of Appendix A to the LRA, the applicant listed 48 of the 57 components and subcomponents that are identified for an AMR. The remaining 9 structures and components are structural-type components that are addressed in Section 3.3 of Appendix A to the LRA where they are treated for their intended functions as part of the buildings in which they are housed. Those 9 components are (1) polar crane girders, (2) spent fuel cask handling crane rail/support girders, (3) refueling pool reinforced concrete, (4) refueling pool SS liner, (5) fuel transfer tube SS liner, (6) spent fuel pool reinforced concrete, (7) spent fuel pool SS liner, (8) spent fuel pool storage racks, and (9) new fuel storage racks.

2.2.3.3.2 Staff Evaluation

The staff reviewed Section 3.2 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the FHE and HLHC components and supporting structures that are within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.2.3.3.2.1 Fuel Handling Equipment and Other Heavy Load Handling Cranes Within the Scope of License Renewal

The staff reviewed Section 9.7, "Fuel and Reactor Component Handling Equipment," of the UFSAR to determine if there were any additional portions of the structure and other components that the applicant should have identified as within the scope of license renewal. The staff also reviewed Section 9.7 of the UFSAR for any safety-related functions that were not identified as intended functions in the LRA to verify that no structure or component having an intended function was omitted from the scope of the rule.

The staff has reviewed the information presented in Section 3.2 of Appendix A to the LRA and Section 9.7 of the UFSAR. Table 3.2-1 of Appendix A to the LRA shows that all of the FHE and HLHC structures and components that comprise the 48 structural component types within the scope of license renewal require an AMR. Upon completing the initial review, the staff issued RAIs by letter dated August 26, 1998, regarding the FHE and HLHC commodity report. By letter dated November 4, 1998, the applicant responded to the staff's RAIs. As documented by a letter from BGE to NRC, dated February 4, 1999, an additional component type, the containment purge exhaust monorail, was added to the list of components that are within the scope of license renewal and subject to an AMR. In addition, the HLHC carbon steel chain hoist for the containment purge exhaust monorail is identified as a subcomponent that is within the scope of license renewal and subject to an AMR. The staff agrees that this non-safety-related component does perform the intended functions as defined in 10 CFR 54.4(a)(1), (2), and (3), and is within the scope of license renewal. On the bases discussed above, the staff finds that there is reasonable assurance that the applicant has appropriately identified the portions of the FHE and HLHC and the associated structures and components thereof that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.3.2.2 Fuel Handling Equipment and Other Heavy Load Handling Cranes Subject to an Aging Management Review

In accordance with the license renewal rule, the following structures and components are subject to an AMR: (1) those that perform an intended function without moving parts or without change in configuration or properties, and (2) those that are not subject to periodic replacement based on a qualified life or specified time period.

The applicant's process determined that some structural devices, such as drums, hydraulic cylinders, and wheels, perform their intended function(s) while in motion. Such devices were considered to be active subcomponents and were eliminated from an AMR. It was assumed that no structural components or subcomponents in the fuel handling equipment (FHE) and heavy load handling cranes (HLHCs) were replaced on the basis of time or qualified life.

On the basis of the results of the process described above, the portion of the FHE and HLHCs that is within the scope of license renewal and subject to an AMR includes 57 structural components and their supports.

The following FHE and HLHC components are addressed for their structural intended function(s) as parts of the building in which they are housed in Section 3.3 of Appendix A to the LRA, and are, therefore, not reviewed in this section:

PC girders
SFCHC rail/support girders
refueling pool reinforced concrete
refueling pool SS liner
fuel transfer tube SS liner
spent fuel pool reinforced concrete
spent fuel pool SS liner
spent fuel pool storage racks, and
new fuel storage racks

The remaining 48 components, listed in Table 3.2-1 in Appendix A to the LRA are subject to an AMR and are evaluated within this section. The staff reviewed the information submitted by the applicant and verified that the grouping was correct. Therefore, the staff finds that there is reasonable assurance that the applicant has appropriately identified the structures and components subject to an AMR for the FHE and HLHC's in accordance with the requirements of 10 CFR 54.21(a)(1).

2.2.3.4 Primary Containment Structure

In Section 3.3A, "Primary Containment Structure," of Appendix A to the LRA, the applicant describes portions of the primary containment and the components therein that are within the scope of license renewal, and identified which of those within-scope components are subject to an AMR.

2.2.3.4.1 Summary of Technical Information in the Application

As described in Appendix A to the LRA, the primary containment is designed to withstand an internal pressure of 50 psig with a coincident concrete surface temperature of 276^�F, and to limit leakage to no more than 0.20 percent by weight per day at the design temperature and pressure. The containment structure is designated a seismic Category I structure and is designed for all loading combinations described in Section 5A.3 of the UFSAR. The primary containment consists of two categories of components -- the containment structure and the containment system. The containment structure embraces the majority of structural components, such as beams, columns, walls, and liners. The containment system covers penetrations, hatches, air locks, and associated instrumentation.

In Appendix A to the LRA, the applicant identified the following intended functions for the primary containment in accordance with 10 CFR 54.4(a)(1) and 54.4(a)(2):

Serve as a pressure boundary or a fission-product retention barrier to protect public health and safety during a design-basis event;
Provide shelter/protection to safety-related equipment;
Provide structural and functional support or both to safety-related equipment;
Serve as a missile barrier (internal or external);
Provide structural and functional support or both to non-safety-related equipment whose failure could directly prevent satisfactory accomplishment of any of the required safety-related functions; and
Provide flood protection barrier (internal flood event).

The applicant also determined that the following were intended functions of the primary containment according to the requirements of 10 CFR 54.4(a)(3):

For station blackout -- Provide closure of containment airlock and access/egress hatches;
For equipment qualification -- Provide boundaries of harsh environment applicable to the functionality of electrical components as addressed by the equipment qualification program; and
For fire protection -- Provide rated fire barriers to confine or retard a fire from spreading to or from adjacent areas of the plant.

On the basis of the intended functions stated above, the applicant identified a total of 37 structural component types as being within the scope of license renewal. These structural component types were further combined into the following 4 structural component categories on the basis of their design and materials: (1) concrete, (2) structural steel, (3) architectural, and (4) unique (e.g., post-tensioning system, basemat and containment liner, permanent cavity seal ring, trisodium phosphate baskets, and emergency sump cover and screen). The applicant identified all 37 structural component types as subject to an AMR. The applicant identified the following 3 component types for the containment system: (1) air locks and equipment hatch, (2) containment penetrations, and (3) limit switches. Of these 3 component types, the applicant identified 2 as subject to an AMR.

The applicant also indicated that some components in the containment system that are common to many systems have been included in the separate commodity reports that address those components for the entire plant. Therefore, the following components were not included in the individual system sections:

Structural supports for piping, cables, and components, which are evaluated for the effects of aging in Section 3.1 of the application;
Supports for the steam generators and pressurizer, which are evaluated for the effects of aging in Section 4.1 of the application;
Supports for the reactor vessel, which are evaluated for the effects of aging in Section 4.2 of the application; and
Electrical control and power cabling, which is evaluated for the effects of aging in Section 6.1 of the application.

2.2.3.4.2 Staff Evaluation

The staff reviewed Section 3.3A of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the primary containment components and supporting structures within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.2.3.4.2.1 Systems, Structures, and Components Within the Scope of License Renewal

The staff reviewed Section 5.1, "Containment Structure," of the UFSAR and compared the description of the structures and components in the UFSAR to the description in the application to determine if there were any portions of the structure, and other components, that the applicant should have identified as within the scope of license renewal. The staff also reviewed Section 5.1 to determine if there are any safety-related functions that were not identified as intended functions in the LRA to determine if there are any structures or components with intended functions that might have been omitted from the scope of license renewal. On the basis of its review, the staff found that the applicant did not omit anything.

Table 3.3A-1 of Appendix A to the LRA shows that all of the containment structure components that comprise the 37 structural component types within the scope of license renewal also require an AMR. As mentioned in Section 2.2.3.17.2.1 of this SER, the containment sump, trisodium phosphate baskets, and the emergency sump cover and screens were adequately identified in Table 3.3A-1 as requiring an AMR. Only one of the three component types within the scope of license renewal for the containment system did not require an AMR. The component type, limit switches, was found to only support the active function of providing closure of the containment air lock and access/egress hatches during a station blackout. In performing their functions, limit switches change configuration; therefore, the limit switches do not require an AMR. The remaining component types requiring an AMR are shown in Table 3.3A-2 of Appendix A to the LRA. On the basis of the components identified in the tables referenced above and the supporting information in Section 5.1 of the USAR, the staff concludes that those portions of the primary containment structure that are not identified as within the scope of license renewal do not perform any intended functions.

As noted above, the staff has reviewed the information in Section 3.3A of Appendix A to the LRA and Section 5.1 of the USAR. On the basis of that review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the portions of the primary containment and the associated structures and components thereof that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.4.2.2 Primary Containment Structures Subject to an Aging Management Review

Of 45 component types within the scope of the license renewal rule, 37 are structural component types and are identified in Table 3.3A-1. The remaining 8 are system component types, 7 of which are identified in Table 3.3A-2, and the eighth is a limit switch. The staff reviewed the component types that are electrical/instrumentation components to verify that the applicant did not miss any electrical/instrumentation components that should be subject to an AMR. The applicant classified the limit switch as having only an active function and, therefore, not requiring an AMR. Electrical control/power cabling is evaluated in Section 2.2.3.32, "Cables," of this SER. One electrical/instrumentation component, electrical penetrations, evaluated in this section was classified as subject to an AMR. The staff agrees with this BGE determination covering electrical/instrumentation components, which is consistent with 10 CFR 54.21(a)(1).

Some components in the containment system are common to many other plant systems (e.g., structural supports for piping, cables, electrical control, and power cabling) and have been discussed by the applicant in separate sections of the LRA that address those components as commodities for the entire plant.

On the basis of the applicant's integrated plant assessment (IPA) methodology provided in Appendix A to the LRA and provisions of 10 CFR 54.21(a)(1), the applicant identified 44 component types for the containment structure and component system as components subject to an AMR, and listed these component types in Tables 3.3A-1 (37 structural type components) and 3.3A-2 (7 system type components) of Appendix A to the LRA.

The staff focused its evaluation of the applicant's approach for defining the applicability of an AMR for the containment structure and containment system on the issue of whether the requirements and intent of 10 CFR 54.4 and 54.21(a)(1) are fully complied with. The staff reviewed each of the 44 component types noted above for the containment structure and containment system to verify that these items are part of the containment structure and the containment system. The staff further verified that the applicant had not omitted any items from an AMR that are part of the containment structure and containment system, and that perform an intended function without moving parts or without a change in configuration or properties and are not subject to replacement based on a qualified life or specified time period. The staff also reviewed the manner in which the applicant handled some components in the containment system that are common to many other plant systems and have been reviewed by the applicant in separate sections of the LRA, that address those components as commodities for the entire plant. On the basis of the review described above, the staff concludes that the applicant has implemented an adequate procedure for defining structural and system component types for the CCNPP containment structure and the containment system that are subject to an AMR, because the applicant's approach included 100 percent of the structural and system component types that constitute the CCNPP containment structure and the containment system.

Table 3.3A-1, "Containment Structure Component Types Requiring an AMR," in Appendix A to the LRA designates the containment structural components subject to an AMR. The containment tendon gallery protects the bottom anchorages of the vertical tendons, and gives access to the tendon anchorages for inservice inspection activities. The tendon gallery is categorized as a non-safety-related element of the containment structures. BGE indicated that the tendon gallery is not relied upon for containment integrity in the seismic analyses or design-basis events. Documentation of this basis for excluding the tendon gallery from the scope of the structural elements subject to an AMR was identified as Confirmatory Item 2.2.3.4.2.2-1 in the previous SER.

In its July 2, 1999, response to this issue, the applicant committed to perform the aging management of tendon anchorages through procedures STP-M-663-1and -2, (Containment Tendon Surveillance Tests) and MN-1-319 (Structures and Systems Walkdown). The staff concludes that these procedures provide adequate monitoring of the condition of the tendon anchorages and allow detection of anchorage degradation in sufficient time to correct the degradation before the intended function is compromised. On this basis, the staff concludes that the applicant has provided an acceptable basis to exclude the tendon galleries from an AMR and considers Confirmatory Item 2.2.3.4.2.2-1 closed. The staff notes that managing the condition and environment in the tendon galleries (e.g., moisture and humidity) may be a prudent way to manage the degradation (i.e., corrosion) of bearing plates and other vertical tendon anchorage components in the tendon galleries.

The staff finds that there is reasonable assurance that the applicant has appropriately identified the structural and system component types for the primary containment structure that are subject to an AMR pursuant to 10 CFR 54.21(a)(1).

2.2.3.5 Turbine Building Structure

In Section 3.3B, "Turbine Building Structure," of Appendix A to the LRA, the applicant described the turbine building and noted the components that are within the scope of license renewal, and identified which of those components are subject to an AMR.

2.2.3.5.1 Summary of Technical Information in the Application

As described in the LRA, the turbine building is within the scope of license renewal because its structural components perform one or more of the following generic functions:

Provide structural and/or functional support to safety-related equipment;
Provide shelter/protection to safety-related equipment;
Serve as a missile barrier (internal or external);
Provide structural and/or functional support to non-safety-related equipment whose failure could directly prevent satisfactory accomplishment of any of the required safety-related functions;
Provide flood protection barrier (internal flooding event); and
Provide a rated fire barrier to confine or retard a fire from spreading to or from adjacent areas of the plant.

In Section 3.3B.1 of Appendix A to the LRA, the applicant described the turbine building, including the conceptual boundaries, and listed the intended functions performed by its structural components. The applicant then identified the structural component types within the scope of license renewal. Finally, the components subject to an AMR were identified and dispositioned in accordance with the integrated plant assessment methodology described in Section 2.0 of Appendix A to the LRA.

The turbine building for the CCNPP is common to both units and is oriented parallel to the Chesapeake Bay shoreline between the North Service Building and the auxiliary building. It is a steel structure with metal siding supported on reinforced-concrete foundations. The turbine building is a seismic Category II structure. The conceptual boundary of the turbine building includes the AFW pump rooms and portions of the electrical ductbanks that are seismic Category I structures. Since the seismic Category I structures are enclosed within the turbine building that serves such intended functions as providing support and shelter to safety-related equipment, the turbine building and its enclosures are within the scope of license renewal.

The electrical ductbanks that run under the turbine building are connected between the AFW pump rooms and the intake structure. These ductbanks are seismic Category I reinforced-concrete structures that encase the safety-related electrical conduits. The siding on the turbine building wall is not safety-related, but the siding clips that hold the siding in place are safety- related. The siding clips are designed to fail when a differential pressure across the siding reaches a pre-determined pressure, which allows the siding to blow off for venting blowdown pressure following an accident and protects vital equipment and structures within the turbine building. The wall at the end of the main steam pipe tunnel that separates the turbine building and the auxiliary building is designed to fail at 0.5 psi to release pressure if a main steam line breaks near the main steam pipe tunnel. The wall is also designed to fail at a hydraulic pressure of 3 feet of water from a main feedwater line rupture in the main steam piping area.

The applicant identified that the turbine building and the AFW pump rooms are within the scope of license renewal according to 10 CFR 54.4(a). Six of the seven generic structural functions (except for the pressure boundary for fission products) listed in Table 3.3B-1 of Appendix A to the LRA are the intended functions for the turbine building and the AFW pump rooms. As described in the IPA, the applicant developed a generic list of component types for use during the structural component scope task. On the basis of this generic list, the applicant determined 24 structural component types for the turbine building (as listed in Table 3.3B-2 of Appendix A to the LRA) that identify such structural components as walls, slabs, and equipment pads, which do not have unique equipment identifiers in the site equipment database. These structural component types were combined into the following four structural categories on the basis of their design and material:

concrete components
structural steel components
architectural components
unique components

The structural component types identified for the turbine building contribute at least one of the structural intended functions discussed in the LRA. For example, the electrical ductbanks that run under the turbine building have been identified as structural components under the category of concrete components and are included in the turbine building conceptual boundary because they are seismic Category I. The turbine building siding clips and retainer clips are identified as structural components under the category of architectural components because they are safety related. These structural components that fall within the scope of license renewal are functionally passive and are not subject to periodic replacement. All the structural components listed in Table 3.3B-2 of Appendix A to the LRA are subject to an AMR and are evaluated in this section.

Component supports that are connected to structural components in the turbine building are evaluated in Section 3.1 of Appendix A to the LRA under the component support commodity evaluation. A component support is defined as the connection between a system (or component within a system) and a plant structural member. Component supports interface with the component they support in the applicable systems and interface with the structural component to which they are attached. For example, a fixed base that supports a pump is considered a component support since it connects the concrete equipment pad to the pump. The pump itself would be included and evaluated within the associated system in Appendix A to the LRA. The fixed base would be included within the component support commodity evaluation, and the concrete equipment pad would be included within the evaluation for the associated structure. If anchor bolts are used at the interface with the structural member, there is overlap between the component support commodity evaluation and the evaluation for the structural component. Evaluations for structural components considered the effects of aging caused by the surrounding environment; the component support commodity evaluation considered the effects of aging caused by the supported equipment (thermal expansion, rotating equipment, etc.) as well as by the surrounding environment. Supports for structural components such as platform hangers are not "component supports" in this sense because any support for a structural component is itself a structural component (i.e., is included in the scope of the associated structure). All the component supports in the turbine building are evaluated in Section 3.1 of Appendix A to the LRA.

2.2.3.5.2 Staff Evaluation

The staff reviewed Section 3.3B of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the turbine building structural components that are within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.2.3.5.2.1 Systems, Structures, and Components Within the Scope of License Renewal

As part of the first-step evaluation (i.e., to determine whether the applicant has properly identified the systems, structures, and components within the scope of license renewal), the staff reviewed portions of the UFSAR, including the layout drawings for the turbine building, the AFW pump rooms, and the ductbanks, and compared them with the structural components listed in Table 3.3B-2 and shown in Figure 3.3B-1 in Appendix A to the LRA to determine if there were any portions of the structures and associated components that the applicant did not identify as within the scope of license renewal. The staff also reviewed the UFSAR to determine if there were any safety-related system functions that were not identified as intended functions in the LRA to determine if there were any structural components having intended functions that might have been omitted from consideration within the scope of license renewal. Although the staff found no omissions, the staff questioned why the turbine building roof trusses were described in the Structural Description portion of Section 3.3B, but not included in Table 3.3B-2, "Structural Component Types Requiring AMR for the Turbine Building."

During a site visit to the CCNPP on February 18, 1999 (summarized in an NRC letter dated March 19, 1999), the staff asked the applicant why the roof trusses were not subject to an AMR. The applicant stated that the roof trusses are not within the scope of license renewal. The applicant explained that the roof trusses are seismic Category II structures, but their failure during an abnormal (e.g. seismic) event could not affect the operability of any safety-related equipment in the turbine building. Therefore, the roof trusses do not meet the scoping criteria of 10 CFR 54.4. The staff reviewed the information and agreed that the roof trusses are not within scope.

On the basis of this review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the structural components of the turbine building and the AFW pump rooms that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.5.2.2 Turbine Building Structure Subject to an Aging Management Review

The staff determined whether the applicant has properly identified the structural component types of the turbine building subject to an AMR from among all of the structural component types in the turbine building. The applicant identified 24 structural component types under 4 structural component categories for the turbine building in Table 3.3B-2 in Section 3.3B of Appendix A to the LRA. In the "concrete" category, the structural components are walls, ground floor slabs and equipment pads, elevated floor slabs, cast-in-place anchors/embedments, ductbanks, grout, fluid-retaining walls and slabs, and post-installed anchors. In the "structural steel" category, the structural components are beams, baseplates, floor framing, platform hangers, decking, jet impingement barriers, floor grating, and stairs and ladders. In the "architectural components" category, the structural components are building siding clips, retainer clips, fire doors, jambs, hardware, and caulking and sealants. In the "unique components" category, the structural components are watertight doors, pipe whip restraints, and pipe encapsulations. The staff reviewed the list of 24 structural component types within the scope of license renewal and determined that they perform their intended functions without moving parts or changes in configuration, and are not replaced on a periodic basis.

Based on this review, the staff finds that since all 24 structural component types within the scope of license renewal are subject to an AMR, there is reasonable assurance that the applicant has identified the structural components subject to an AMR in accordance with 10 CFR 54.21(a)(1).

2.2.3.6 Intake Structure

In Section 3.3C, "Intake Structure," of Appendix A to the LRA, the applicant described the technical information related to the intake structure at the plant site. The staff reviewed this section of the application to determine if there is reasonable assurance that the applicant has identified and listed those structures and components of the intake structure that are subject to an AMR to meet the requirements stated in 10 CFR 54.21(a)(1).

2.2.3.6.1 Summary of Technical Information in the Application

As described in the LRA, the intake structure is situated to the east of the main plant between the North Service Building and the Chesapeake Bay shoreline. The structure houses 12 circulating water pumps that supply water from the Chesapeake Bay to the condensers, and 6 saltwater pumps that provide cooling water to various plant equipment. Trash racks and traveling screens protect the condensers from foreign bodies present in the bay water. A gantry crane, having a lifting capacity of 35 tons, spans the full width of the structure, and is capable of traversing the entire length of the intake structure.

The intake structure is approximately 90 feet x 385 feet, and is constructed primarily of reinforced concrete. The foundation slab varies in elevation from 26 feet 0 inches to 14 feet 3 inches. The total effective load due to the structure is approximately 42,000 tons. As a result, net soil pressures due to the structure are approximately 2500 pounds per square foot (psf). For all major structures below finish grades, a heavy waterproofing membrane of 40-mil thickness is provided at the exposed face of the exterior walls and below the base slab. Rubber waterstops are also provided at all construction joints up to grade elevation. Subsurface drains are provided to lower the elevation of groundwater around the plant. Since the intake structure houses the saltwater pumps that are essential for the safe shutdown of CCNPP, the structure was designed as a Category I structure for seismic, tornado, and hurricane conditions. The intake structure is also designed to protect the saltwater pump motors from external flooding from the maximum hypothetical hurricane tide and storm surges, including wave action. The intake structure design loads and conditions are shown in CCNPP UFSAR Section 5A.5. The structure is designed in accordance with American Concrete Institute (ACI) standards and the structural steel components are designed with American Institute of Steel Construction standards. The total length of the structure is divided into three sections above the base slab by two expansion joints. The high level roof at elevation 28 feet 6 inch is made of a reinforced-concrete slab supported on a structural steel frame.

The conceptual boundaries of this evaluation are the intake structure and all of its structural components, such as foundations, walls, slabs, and steel beams. Component supports that are connected to the structural components are evaluated for the effects of aging in the component supports commodity evaluation in Section 3.1 of Appendix A to the LRA. Component supports are defined as the connection between a system, or a component within a system, and a plant structural member. An example of a component support is the fixed base that supports a pump. The pump is scoped with its respective system evaluation. The component support is the fixed base that connects the concrete equipment pad to the pump. The fixed base is scoped with the component supports commodity evaluation and the concrete equipment pad is scoped with the evaluation for the structure. If anchor bolts are used, there is overlap between the component supports commodity evaluation and the evaluation for the structural component. Evaluations for structural components considered the effects of aging caused by the surrounding environment; the component supports commodity evaluation considered the effects of aging caused by the supported equipment (thermal expansion, rotating equipment, etc.), as well as the surrounding environment. Supports for structural components such as platform hangers are not "component supports" in this sense because any support for a structural component is itself a structural component and is included in the scope of its respective structure. Cranes and fuel handling equipment that are connected to structures are evaluated for the effects of aging in the cranes and fuel handling commodity evaluation in Section 3.2 of Appendix A to the LRA. The intake structure gantry crane rails, girders, and other structural support members were evaluated in the cranes and fuel handling commodity evaluation and are not evaluated in this section.

Electrical ductbanks run under the turbine building, and are connected between the auxiliary feedwater pump rooms and the intake structure. The ductbanks are seismic Category I and are constructed of reinforced concrete. These ductbanks contain electrical conduits used for routing the cables that power the saltwater pumps. The conduits in the ductbank connect to electrical pull boxes that are mounted on the west wall of the intake structure. These boxes served as a convenient pull point during construction for the saltwater pump motor cables. The pull boxes are not within the scope of license renewal since they do not perform any intended functions as described in 10 CFR 54.4(a). The ductbanks are sloped downward toward the intake structure, and the pull boxes have weep holes to facilitate drainage of the conduits. The ductbanks are evaluated for the effects of aging in the turbine building structure evaluation in Section 3.3B of Appendix A to the LRA. The cables are evaluated for the effects of aging in the cables commodity evaluation in Section 6.1 of Appendix A to the LRA.

The intended functions for the intake structure were determined on the basis of the requirements of 10 CFR 54.4(a)(1), (2), and (3), in accordance with Section 4.2.2 of the CCNPP IPA methodology in Section 2.0 of Appendix A to the LRA. In Table 3.3C-1, the applicant indicates that six out of seven of the generic structural functions listed above are applicable to the intake structure.

To identify the structures and structural components, the applicant combined the structural components in four structural categories according to their design and materials as (1) concrete components; (2) structural steel components; (3) architectural components; and (4) unique components.

During the scoping process, the structural component types actually contained in the intake structure were identified within the four structural component categories. Twenty-seven structural component types (e.g., concrete beams and slabs, steel beams, base slabs) were determined to contribute to at least one of the intake structure intended functions. Table 3.3C-2 of Appendix A to the LRA lists these component types and their associated intended functions. Structural component types that are part of the intake structure, but that do not contribute to any of the intended functions of the structure, are not listed in the table.

As discussed in Section 5.4 of the CCNPP IPA methodology in Section 2 of Appendix A to the LRA all seven of the generic structural functions are considered to be passive. In addition, plant structural components are not normally subject to periodic replacement programs. Therefore, structural components are considered to be long-lived, unless specific justification is provided to the contrary. On this basis, all of the structural component types listed in Table 3.3C-2 are subject to an AMR for the intake structure.

Furthermore, the applicant stated that it may elect to replace components for which an AMR identifies that further analysis or examination is needed. In accordance with the license renewal rule, components subject to replacement based on qualified life or specified time period would not be subject to an AMR.

2.2.3.6.2 Staff Evaluation

The staff reviewed Section 3.3C of Appendix A to the LRA to determine if there is reasonable assurance that the applicant has appropriately identified the structures and components in the intake structure within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements in 10 CFR 54.21(a)(1).

The staff used the UFSAR, and the content of Section 3.3C of Appendix A to the LRA in performing its review.

2.2.3.6.2.1 Intake Structure Within the Scope of License Renewal

The basic intake structure is a reinforced-concrete structure whose walls and slabs are 2 feet thick or more. Its basic function is to shelter the safety-related saltwater pumps from severe and extreme natural phenomena, such as earthquakes, winds, and tornados (hurricanes). Its internal components (e.g., slabs, beams) provide supports for the safety-related (SR), and non-safety-related (NSR) components, whose failure could directly prevent the SR components from functioning satisfactorily. It also serves as a flood protection barrier (internal flooding event) and as a rated fire barrier. The applicant has systematically identified seven intended functions for structures and components to comply with the requirements of 10 CFR 54.4(b). Because the intake structure does not serve as a pressure boundary or a fission-product retention barrier, the applicant excluded this from its intended functions. The staff agrees with the applicant's identification of intended functions of the intake structure.

The applicant then established the conceptual boundaries of the intake structure, and discussed the scope of the structures and components to be evaluated under Section 3.3C. The electrical ductbanks that are located between the turbine building and intake structure are evaluated in Section 3.3B of Appendix A to the LRA. Other structures and components that are within the boundary of the intake structure, but not included in the evaluation of the intake structure are:

The associated pumps are evaluated under the respective systems.
The fixed bases (normally steel) that support the pumps and connect them to concrete pads are evaluated under the component support commodity evaluation
The environmental aging effects on the associated anchor bolts are evaluated as the intake structure components; however, the aging caused by the supported equipment is evaluated under the component support commodity evaluation.
The intake structure's gantry crane rails, girders, and other structural support members are evaluated in Section 3.2 of Appendix A to the LRA.

The intake structure is protected by baffle walls to prevent pleasure craft from entering the intake area. The baffle walls overhang from the embankment and are partially submerged in the intake channel. This facilitates in drawing in a large volume of water from the bottom stratum of the bay with minimal ecological effects. The staff queried the applicant for not including the baffle walls and intake channel in the scope of license renewal. During the staff's site visit on February 17, 1999, (NRC meeting summary dated March 19, 1999), this item was discussed. The applicant emphasized that the functional requirements of these components do not meet any of the scoping criteria, and decided to exclude them from the scope of license renewal. The staff found the applicant's reasoning acceptable, and resolved the issue; therefore, this item is not considered to be an omission on the part of the applicant.

On the basis of this review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the intake structure within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.6.2.2 Intake Structure Subject to an Aging Management Review

During the scoping process, the structural component types in the intake structure were identified within four structural component categories: (1) concrete components, (2) structural steel components, (3) architectural components, and (4) unique components. Twenty-seven structural component types (e.g., concrete beams and slabs, steel beams, base slabs) were determined to contribute to at least one of the intake structure's intended functions.

The applicant has identified the long-lived and passive structures and component types within the intake structure, and the staff 's review did not find any omissions of structures and components that are required to be subject to an AMR in accordance with 10 CFR 54.21(a)(1).

The staff has reviewed the information submitted in Section 3.3C of Appendix A to the LRA and additional information submitted by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the structure and components subject to an AMR for the intake structure to meet the requirements of 10 CFR 54.21(a)(1).

2.2.3.7 Miscellaneous Tank and Valve Enclosures

In Section 3.3D, "Miscellaneous Tank and Valve Enclosures," of Appendix A to the LRA, the applicant described the enclosures for tanks and valves at the plant site within the scope for license renewal, and identified which enclosures are subject to an AMR.

2.2.3.7.1 Summary of Miscellaneous Tank and Valve Enclosures Technical Information in the Application

The applicant identified three miscellaneous tank and valve enclosures as being within the scope of license renewal: the No. 12 condensate storage tank (CST) enclosure, the No. 21 fuel oil storage tank (FOST) enclosure, and the auxiliary feedwater (AFW) valve enclosure.

As described in the LRA, the No. 12 CST enclosure houses and protects the No. 12 CST, which provides demineralized water for decay heat removal and cooldown of CCNPP Units 1 and 2. The No. 21 FOST enclosure houses and protects the No. 21 FOST, which provides a fuel supply for the three emergency diesel generators installed in the auxiliary building. The AFW valve enclosure houses and protects the AFW pump suction valves and associated manifold piping, which provide a pressure boundary function for the AFW system. These three enclosures are reinforced-concrete structures of sufficient thickness to protect their associated tanks, valves, or piping from design-basis loadings such as weight, thermal, seismic, and wind.

For each of these miscellaneous tank and valve structures identified by the applicant as being within the scope of license renewal, the applicant identified the following three structural component categories as subject to an AMR: (1) concrete components, (2) structural steel components, and (3) unique components. Within the three applicable structural component categories, 17 structural component types were determined to be subject to an AMR. These 17 structural component types requiring an AMR for the miscellaneous tank and valve enclosures are listed in Table 3.3D-2 of Appendix A to the LRA. The 17 structural component types either (1) provide structural and/or functional support to SR equipment, (2) provide shelter/protection to SR equipment, (3) serve as a missile barrier (internal or external), or (4) provide structural and/or functional support to NSR equipment whose failure could directly prevent satisfactory accomplishment of any of the required SR functions.

2.2.3.7.2 Staff Evaluation

The staff reviewed Section 3.3D of Appendix A to the LRA to determine if there is reasonable assurance that the applicant has identified the miscellaneous tank and valve enclosures within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.2.3.7.2.1 Miscellaneous Tank and Valve Enclosures Within the Scope of License Renewal

In an attempt to determine whether the applicant has properly identified all of the enclosures at the CCNPP site that are within the scope of license renewal, the staff reviewed Chapters 1 and 5 of the UFSAR for comparison with Figure 3.3D-1 of Appendix A to the LRA, which is a simplified diagram of the CCNPP site structures. On Figure 3.3D-1, the CCNPP site structures within the scope of license renewal are identified as (1) the intake structure, (2) Unit 1 and Unit 2 containment, (3) the auxiliary building, (4) the below-grade electrical ductbank for diesel generator 1A, (5) the safety-related diesel generator building, (6) the No. 12 CST enclosure, (7) the No. 21 FOST enclosure, and (8) the AFW valve enclosure.

The CCNPP site plan, UFSAR Figure 1-2, shows each of the yard structures and tanks in addition to the buildings. The only small enclosures shown on UFSAR Figure 1-2 are the No. 12 CST enclosure and the No. 21 FOST enclosure. The AFW valve enclosure is not shown on UFSAR Figure 1-2; however, this enclosure is listed as one of the seismic Category I structures in Appendix 5a to Chapter 5 of the UFSAR. Other enclosures listed as seismic Category I structures in the UFSAR are the enclosures for the critical service water and saltwater pumps. The staff examined the list of seismic Category I structures since the primary function of tank and valve enclosures is to provide shelter/protection to SR equipment and the seismic Category I classification is required for structures that house SR equipment that must remain functional before, during, or after a safe-shutdown earthquake. The critical service water and saltwater pumps are not covered in Section 3.3D of Appendix A to the LRA since they are considered part of the intake structure, which is covered in Section 3.3C of Appendix A to the LRA.

On the basis of this review, the staff finds that there is reasonable assurance that each of the miscellaneous tank and valve enclosures that house SR equipment at the CCNPP site have been appropriately identified by the applicant as being within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.7.2.2 Miscellaneous Tank and Valve Enclosure Structural Component Types Subject to Aging Management Review

In the second step of its evaluation, the staff determined whether the applicant properly identified the structural component types of the No. 12 CST enclosure, the No. 21 FOST enclosure, and the AFW valve enclosure subject to an AMR from among all of the structural component types that constitute these three enclosures. For these three enclosures the applicable structural component categories are (1) concrete, (2) structural steel, and (3) unique components. Examples of components within these three structural component categories are (1) walls, foundations, and roof slab for the concrete category; (2) beams, baseplates, roof framing, and bracing for the structural steel category; and (3) anchor brackets and manhole framing and cover for the unique component category. On the basis of a staff review of the 17 structural component types listed in Table 3.3D-2 of Section 3.3D of Appendix A to the LRA, the staff concludes that the applicant has identified all of the structural component types of the No. 12 CST enclosure, the No. 21 FOST enclosure, and the AFW valve enclosure that perform an intended function without moving parts or without a change in configuration or properties and are not subject to replacement based on a qualified life or specified time period.

Therefore, the staff finds that there is reasonable assurance that the applicant has appropriately identified the structural component types for the No. 12 CST enclosure, the No. 21 FOST enclosure, and the AFW valve enclosure that are subject to an AMR to meet the requirements stated in 10 CFR 54.21(a)(1).

2.2.3.8 Auxiliary Building and Safety-Related Diesel Generator Building Structures

In Section 3.3E, "Auxiliary Building and Safety-Related Diesel Generator Building Structures," of Appendix A to the LRA, the applicant described the auxiliary building, the adjacent emergency diesel generator (EDG) rooms, the refueling water tank (RWT) pump rooms, the safety-related diesel generator building, and the duct bank for EDG 1A, and the components that are within the scope for license renewal, and identified which of those components are subject to an AMR.

2.2.3.8.1 Summary of Technical Information in the Application

As described in Appendix A to the LRA, all of the auxiliary building and safety-related EDG building structures identified above are within the scope of license renewal. The applicant determined that these structures were within the scope of license renewal because they perform one or more of the following intended functions:

(1)	Provide structural or functional support or both to safety-related equipment.
(2)	Provide shelter/protection to safety-related equipment. (NOTE: This function includes protection from (a) radiation effects for equipment addressed by the Equipment Qualification (EQ) Program and (b) high-energy line-break effects.)
(3)	Serve as a pressure boundary or a fission product retention barrier in the event of a design-basis event.
(4)	Serve as a missile barrier (internal or external).
(5)	Provide structural or functional support or both to non-safety-related equipment whose failure could directly prevent satisfactory accomplishment of any of the required safety-related functions (e.g., seismic Category II over I [II/I] design considerations).
(6)	Provide flood protection barrier (internal flooding event).
(7)	Provide rated fire barriers to confine or retard a fire from spreading to or from adjacent areas of the plant.

In Section 3.3E of Appendix A to the LRA, the applicant described the auxiliary building and safety-related diesel generator building structures and listed the intended functions performed by each structure. The applicant then used the intended functions to identify the structural component types within the scope of license renewal. Finally, the applicant identified the components subject to an aging management review (AMR) and dispositioned them in accordance with the integrated plant assessment methodology described in Section 2.0 of Appendix A to the LRA.

The auxiliary building is located between the Unit 1 and Unit 2 containment structures, on the west side of, and adjacent to, the turbine building. The auxiliary building is common to both units. Major structural features related to the nuclear steam supply system (NSSS) and located inside the auxiliary building are the control room, nuclear waste treatment facilities, and facilities for new and spent fuel handling, storage, and shipment. Three EDG rooms and each unit's RWT pump room are adjacent to the auxiliary building structure, and are supported on reinforced-concrete foundations that are separate from the auxiliary building foundation mat. The auxiliary building and adjacent rooms, and their structural components, provide support and shelter to safety-related and non-safety-related equipment. All structural components enclosed within these structures that serve intended functions such as support and shelter are within the scope of license renewal. The applicant noted that those areas inside the auxiliary building that are specifically excluded from seismic Category I requirements in the plant's Quality List (e.g., maintenance shops, stairways, kitchen, toilets, offices) are not within the scope of license renewal. The conceptual boundary of the auxiliary building includes the areas that house safety-related systems, equipment, or components that must remain functional before, during, and after a safe-shutdown earthquake. Additionally, the conceptual boundary includes functional or structural supports for non-safety-related components whose failure during an abnormal (e.g., seismic) event could affect the operability of safety-related components; the associated structural components in the auxiliary building provide support for safety-related mounting of such components. The auxiliary building and adjacent rooms are primarily reinforced-concrete structures, and their foundations support structural steel and reinforced-concrete frames that consist mainly of reinforced-concrete walls and floors.

The safety-related diesel generator building is located northwest of the auxiliary building and is common to both units. It houses EDG 1A, which is one of four EDGs designed to provide a dependable onsite power source under all conditions. The other three EDGs are housed in the rooms adjacent to the auxiliary building described above. The safety-related diesel generator building also houses the fuel oil storage tank (FOST) for EDG 1A and other auxiliary equipment. The safety-related diesel generator building is primarily a reinforced-concrete structure supported on a mat foundation at grade level with a partial basement in the area of the EDG pedestal. In addition, a one-story structure is provided on the east side of the building as missile protection for the main building entry and EDG area exhaust louver. The conceptual boundary of the safety-related diesel generator building includes all structural components, such as concrete foundations, walls, and slabs, as well as a buried duct bank that runs between the safety-related diesel generator building and the auxiliary building for the electrical distribution for EDG 1A. Portions of the buried duct bank are also common to the SBO diesel generator.

The applicant performed a one-time procedure to evaluate aging management for structural component types within the conceptual boundary of the safety-related diesel generator building. The evaluation produced a listing of structural component types subject to an AMR grouped by materials and environment, and related them to similar groupings in the auxiliary building. Since completion of construction in 1996, evidence of age-related degradation of the safety-related diesel generator building has not been observed. Because the function and structure of the diesel generator building are so similar to the function and structure of the auxiliary building, which was built before the Unit 1 operating license was issued in 1974, operating experience related to aging mechanisms and their management for the auxiliary building is expected to give early warning to the applicant of any aging of the safety-related diesel generator building that will need to be managed.

Components that are connected to structural components in the auxiliary and safety-related diesel generator building structures are evaluated in Section 3.1, "Component Supports," of Appendix A to the LRA. A "component support" is the connection between a system, or a component within a system, and a plant structural member. Component supports interface with the component they support in the applicable systems, and they interface with the structural component to which they are attached. For example, a fixed base supporting a pump is considered a component support since it connects the concrete equipment pad to the pump. The pump itself would be included within the associated system LRA evaluation. The fixed base would be included within the component supports commodity evaluation, and the concrete equipment pad would be included within the evaluation for the associated structure. If anchor bolts are used at the interface with the structural member, there is overlap between the component supports commodity evaluation and the evaluation for the structural component. Evaluations for structural components considered the effects of aging caused by the surrounding environment; the component commodity report evaluation considered the effects of aging caused by the supported equipment (thermal expansion, rotating equipment, etc.), as well as the surrounding environment. Supports for structural components (e.g., platform hangers) are not "component supports" in this sense because any support for a structural component is itself a structural component (i.e., included in the scope of the associated structure).

The applicant identified that the auxiliary building and safety-related diesel generator building structures are within the scope of license renewal based on 10 CFR 54.4(a). All seven generic structural functions listed above are intended functions for the auxiliary building and adjacent rooms. Six of the seven listed functions (No. 3 is excepted) are intended functions for the safety-related diesel generator building. For the EDG 1A duct bank, only three of the seven functions are intended functions (Nos. I, 2, and 4). These three intended functions are related to structural or functional support or both, shelter/protection, and missile barrier functions. In Appendix A to the LRA, the applicant identified the first four listed intended functions for these structures on the basis of 10 CFR 54.4(a)(1), the fifth and sixth intended functions on the basis of 10 CFR 54.4(a)(2), and the last on the basis of 10 CFR 54.4(a)(3).

As described in the Integrated Plant Assessment (IPA) (see Section 2.4.2.3, "Structural Component Type Listing for the Structure," of Appendix A to the LRA), the applicant developed a generic list of component types for use during the structural component scoping task. The generic list started with component types associated with safety-related functions contained in technical reports prepared by industry addressing containment and seismic Category I structures. Other structural component types related to fire and flooding events were added to the list to ensure completeness. These structural components were combined into the following four structural categories according to their design and materials:

concrete components
structural steel components
architectural components
unique components

From within the four structural categories listed above, the applicant determined that 47 structural component types contributed to at least one of the structural intended functions listed above. Of the 47 structural component types within the scope of license renewal for the auxiliary building and safety-related diesel generator building structures, one unique component type, pipe encapsulation, was evaluated in the main steam AMR evaluation as described in Section 5.12, "Main Steam, Generator Blowdown, Extraction Steam, & Nitrogen & Hydrogen Systems," of Appendix A to the LRA. The remaining 46 component types, listed in Table 3.3E-2 of Appendix A to the LRA, are subject to an AMR and are evaluated in this section.

2.2.3.8.2 Staff Evaluation

The staff reviewed Section 3.3E of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the auxiliary building and safety-related diesel generator building structural components that are within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding the subject structures (NRC letter to BGE dated September 7, 1998), and by letter dated November 19, 1998, the applicant responded to those RAIs.

2.2.3.8.2.1 Auxiliary Building and Safety-Related Diesel Generator Building Structures Within the Scope of License Renewal

As part of the first step of its evaluation, the staff reviewed portions of the UFSAR, including the layout drawings for these structures, to determine if there were any portions of the structures and associated components that the applicant did not identify as within the scope of license renewal. The staff also reviewed the UFSAR for any safety-related system functions that were not identified as intended functions in the LRA to verify that structural components having intended functions were not omitted from consideration within the scope of the rule.

As a check to determine if the applicant omitted a component from its list of components that are within the scope of license renewal, the staff asked the applicant to clarify several issues. In NRC Question No. 3.3.43, the staff noted to the applicant that Section 3.3E, "Auxiliary Building and Safety-Related Diesel Generator Building Structures," of Appendix A to the LRA addresses the safety-related diesel buildings but does not address the SBO diesel generator. In its response, the applicant referred to Subsection 4.2.2, "Function Identification," of Section 2.0 of Appendix A to the LRA (i.e., the IPA) and stated that the structure that encloses the SBO diesel generator does not perform any of the seven listed functions and, therefore, is not within the scope of license renewal. However, Section 8.4.5.1.e of the UFSAR states that certain structural components of the SBO diesel generator building are designed to preclude seismic failure and subsequent impact of the structure on the adjacent safety-related EDG building. In addition, as stated in the same UFSAR section, certain equipment located "outdoors or on the building roof" could exceed the parameters for a Spectrum II tornado and has been anchored to resist these wind loads. Function No. 5 in Section 4.2.2 of Section 2.0 of Appendix A to the LRA addresses non-safety-related equipment whose failure may affect the function of safety-related equipment. Therefore, the staff believes that the SBO diesel generator building structures and the mounting components securing the aforementioned equipment associated with the SBO diesel generator building against tornado wind loads, structures and components whose failure could directly prevent satisfactory accomplishment of the EDG building's intended safety function, should be included within the scope of license renewal. This issue was identified as Open Item 2.2.3.8-1.

In a letter to the staff dated September 28, 1999, the applicant reviewed its position on the SBO diesel building and mounting components described above, and has decided to include these SSCs within the scope of license renewal. On the basis of the applicant's decision to include these structures and components within the scope of license renewal, Open Item 2.2.3.8-1 is closed.

In NRC Question No. 3.3.45, the staff asked the applicant to state if any portions of the equipment and floor drainage system (EFDS) associated with the auxiliary building and EDG structures are relied upon for protection against internal or external flooding. The applicant responded that no portions of the EFDS are relied upon to protect against flooding and, therefore, no drains are within the scope of license renewal because of postulated internal or external flooding. The applicant also noted in its response that the plant drain system and liquid waste system are within the scope of license renewal for fire protection purposes and are addressed in Section 5.10 of Appendix A to the LRA. On the basis of the applicant's response, the staff agrees that there are no license renewal aspects of the EFDS that should be identified in Section 3.3E of Appendix A to the LRA.

As described above, the staff has reviewed the information presented in Section 3.3E of Appendix A to the LRA and the additional information submitted by the applicant in response to the staff's RAIs. On the basis of that review, the staff concluded that there is reasonable assurance that the applicant has appropriately identified the structural components of the auxiliary building and safety-related diesel generator building structures that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.8.2.2 Auxiliary Building and Safety-Related Diesel Generator Building Structures Subject to an Aging Management Review

The 47 structural component types within the scope of license renewal were determined by the applicant to contribute to at least one of the seven structural intended functions discussed above. One unique component type, pipe encapsulations, was evaluated in an AMR for the main steam system. The applicant identified the remaining component types for the auxiliary building and SR diesel generator building as structural components subject to an AMR, and listed these component types in Table 3.3E-2 of Appendix A to the LRA.

The staff verified that each of the remaining 46 structural component types determined by the applicant to require an aging management review are part of the auxiliary building and SR diesel generator building structures. The staff further verified that there were no additional auxiliary building and SR diesel generator building structural components that perform an intended function without moving parts or without a change in configuration or properties and that are not subject to replacement based on a qualified life or specified time period. The staff also reviewed the manner in which the applicant handled some components in the auxiliary building and SR diesel generator building structures that are common to many other plant systems and have been included by the applicant in separate sections of the LRA, which address those components as commodities for the entire plant.

Table 3.3E-2 contains the list of structural component types requiring an aging management review. This table contains 37 line items. Some of these 37 line items contained multiple component types, potentially 53 in all. The discussion in the LRA refers to 46 component types. The staff considered that the applicant should clarify how the component types are grouped so that the discussion in the text of the application and the component list in Table 3.3E-2 are consistent. During a site meeting on February 17, 1999, the applicant clarified that the discussion was in error and the components listed in Table 3.3.E-2 were the components requiring an AMR. The staff reviewed the entire list of structural component types and verified that the applicant included all the structural and system component types that constitute the auxiliary building and SR diesel generator building structures that are subject to an AMR.

The staff has reviewed the information in Section 3.3E of Appendix A to the LRA, and has determined that there is reasonable assurance that the applicant has appropriately identified the portions of the auxiliary building and SR diesel generator building structures and structural components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.2.3.9 Reactor Coolant System

In Section 4.1, "Reactor Coolant System (RCS)," of Appendix A to the LRA, the applicant described the systems with component supports at the plant site that are within the scope of license renewal, and identified which of those structures and components are subject to an AMR.

2.2.3.9.1 Summary of Technical Information in the Application

As described in Appendix A to the LRA, the function of the RCS is to remove heat from the reactor core and reactor internal components and transfer it to the secondary (steam generating) system. The RCS of each unit, which is located entirely within the containment building, consists of two heat transfer loops connected in parallel across the reactor pressure vessel (RPV). Each loop contains one steam generator (SG), two reactor coolant pumps (RCPs), connecting piping, and flow and temperature instrumentation. Other major RCS components are the pressurizer and quench tank. Coolant system pressure is maintained by the pressurizer, which is connected to one of the RCS loop hot legs. Because the RPV is a significant component of the RCS and because several aging mechanisms are unique to it, the RPV was separately evaluated for aging management in Section 4.2 of Appendix A to the LRA, which is evaluated in Section 3.2 of this SER.

The basic RCS functional requirements are:

To remove heat from the reactor core and reactor internal components and transfer it to the secondary (steam) system;
To contain fission products released by fuel element defects and prevent the release of these fission products to the environment;
To provide remote monitoring capability for the RCS parameters;
To permit remote control of RCS parameters; and
To provide required information to the reactor protective system, the reactor regulating system, and the engineered safety features actuation system for the purpose of protecting the reactor core and RCS components.

The primary function of the RCPs is to force coolant flow through the core. There are four RCPs in the RCS of each unit, which are located in the SG (return lines) cold legs.

During operation, the four RCPs in each unit circulate water through the RPV where the water serves as both coolant and neutron moderator for the core. The heated water enters the two SGs in each unit, transferring heat to the secondary (steam) system, and then returns to the RCPs to repeat the cycle.

The RCS pressure is maintained by regulating the water temperature in the pressurizer where steam and water are held in thermal equilibrium. Steam is either formed by the pressurizer heaters or condensed by the pressurizer spray to limit the pressure variations caused by contraction or expansion of the reactor coolant. The pressurizer is located with its base at a higher elevation than the RCS loop piping. A number of pressurizer heaters are operated continuously to offset the heat losses and the continuous minimum spray, thereby maintaining the steam and water in thermal equilibrium at the saturation temperature corresponding to the desired system pressure.

Overpressure protection is provided by two power-operated relief valves (PORVs) and two spring-loaded safety valves connected to the top of the pressurizer. Steam discharged from the valves is cooled and condensed by water in the quench tank. The RCS vent lines from the RPV and the pressurizer also discharge to the quench tank. In the unlikely event that the discharge exceeds the capacity of the quench tank, the tank is relieved to the containment via the quench tank rupture disc. The quench tank is located at a level lower than the pressurizer. This ensures that any PORV or pressurizer safety valve leakage from the pressurizer, or any discharge from these valves, drains to the quench tank.

The nuclear steam supply system (NSSS) utilizes two SGs to transfer the heat generated in the RCS to the secondary (steam) system. The SG shell is constructed of carbon steel. Manways and handholes are provided for easy access to the SG internals.

The SG is a vertical U-tube heat exchanger. It operates with the reactor coolant in the tube side and the secondary fluid in the shell side. Reactor coolant enters the SG through the inlet nozzle, flows through 3/4-inch (outside diameter) U-tubes, and leaves through two outlet nozzles. Vertical partition plates in the lower head separate the inlet and outlet plenums. The plenums have SS cladding, and the primary side of the tubesheet has nickel-chromium-iron (Ni-Cr-Fe) cladding. The vertical U-tubes are made of Ni-Cr-Fe alloy. The tube-to-tubesheet joint is welded on the primary side. Tubes that have degraded may be repaired using tube sleeves or may be removed from service by either a welded or a mechanical-type tube plug.

Feedwater enters the SG through the feedwater nozzle where it is distributed via a feedwater distribution ring. Water exits the ring through apertures in the top fitted with J-tubes, then flows into the downcomer. The downcomer is an annular passage formed by the inner surface of the SG shell and the cylindrical shell wrapper that encloses the vertical U-tubes. At the bottom of the downcomer, the secondary water is directed upward past the vertical U-tubes where heat transfer from the primary side produces a water-steam mixture.

Constant RCS makeup and letdown are handled by the chemical and volume control system (CVCS). An inlet nozzle on each of the four RPV inlet pipes allows injection of borated water into the RPV from the CVCS and from the safety injection system in the event that emergency core cooling is needed. During a normal plant shutdown, these nozzles are also used to supply shutdown cooling flow from the low-pressure safety injection pumps. An outlet nozzle on one RPV outlet pipe is used to remove shutdown cooling flow.

Drains from the RCS piping to the radioactive waste processing system are provided for draining the RCS for maintenance operations. A connection is also provided on the quench tank for draining it to the radioactive waste processing system following a relief valve or safety valve discharge.

The RCS piping consists of two loops that connect the SGs to the reactor vessel. Each loop consists of 42-inch (inside diameter) hot leg piping connecting the reactor vessel outlets to the SG inlets, and 30-inch (inside diameter) piping connecting the SG outlets to the RCPs and the coolant pumps to the reactor vessel inlet nozzles. A surge line connects one loop hot leg to the pressurizer.

Vents were added to the RPV head and to the pressurizer head in response to the Three Mile Island "lessons learned" report ("Clarification of TMI Action Plan Requirements," NUREG-0737, Item II.B.1). These vents are intended to provide a means of releasing non-condensable gases from the RCS during natural circulation. The pressurizer vent line valves are used as a backup to main and auxiliary spray to depressurize the RCS during a SG tube rupture. The original design of CCNPP allowed venting of the RCS only during cold shutdown. The vent modifications provide electrically operated solenoid valves, powered from emergency electrical buses, that are operated from the control room. The RPV and the pressurizer each has two of these valves in series, which fail closed (power-to-open). The reactor vessel vent line valves are installed in previously existing lines; the pressurizer vent line valves are installed in a line that was added as another branch off the pressurizer vapor sample line. The two vent lines join to a common line that leads to the quench tank. The common line contains a temperature element and an alarm that are used for valve seat leak detection and flow indication.

The components evaluated here are the RCPs and their motors, RCS piping, pressurizer, pressurizer heaters, PORVs and safety valves, SGs, quench tank, and associated instruments and controls. The SG boundaries are set at the ends of the nozzles' safe-ends connecting the SG to other components or systems. The nozzles include main feedwater, auxiliary feedwater, main steam, RCS inlet and outlet, instrumentation, and any integral attachments.

The boundary between the RPV and RCS main coolant piping excludes the RPV nozzles, which are evaluated along with the RPV and control element drive mechanisms (CEDMs)/electrical system in Section 4.2 of Appendix A to the LRA.

In addition, the applicant stated that the following piping, supports, instrumentation and controls, and valves are covered in or excluded from Section 4.1 of Appendix A of the LRA.

The following piping is evaluated in or excluded from this evaluation:

Small tubing and piping that are field run (i.e., instrumentation tubing) and that have no component designators are not evaluated in Section 4.1 of Appendix A of the LRA;
PORV and safety valve discharge piping is included up to but not including the connecting nozzles on the quench tank;
Vents, drains, and other similar attached lines are included out to the second valve from the RCS; and
Safety injection and similar lines from the interconnecting systems are included out to the first valve from the RCS.

Supports and hangers for piping and components that are not discussed in Section 4.1 of Appendix A of the LRA are evaluated in Section 3.1, and the staff's evaluation of Section 3.1 is given in Section 2.2.3.1 of this SER.

The following instrumentation and controls are covered in Section 4.1 of Appendix A of the LRA:

All remote and local instrumentation associated with the RCS loops, the pressurizer, and the RCPs. Steam generator secondary-side instrumentation is not covered in Section 4.1 of Appendix A of the LRA;
Incore neutron detectors and incore (core exit) temperature monitors;
Instrumentation scope includes transmitters, signal processing equipment, control room displays, and other applicable readouts, but does not include cabling. Cabling is evaluated in the cables commodity evaluation in Section 6.1 of Appendix A to the LRA;
Automatic and manual controls for pressurizer heaters, pressurizer spray, RCPs, and the PORV and its isolation valves are evaluated in Section 4.1 of Appendix A of the LRA; and
Power supply components for the RCPs and heaters are included up to the power supply breaker.

The following valves are evaluated in Section 4.1 of Appendix A of the LRA:

Valves associated with the pressurizer spray (including instrument air system supply valves to the pressurizer spray control valves);
Pressurizer code safety valves;
PORV and associated motor-operated block valves;
All normally closed RCS pressure boundary valves in vent and drain lines (this extends to the second valve from the RCS in each line); and
Instrument valves for the RCS instrumentation (e.g., pressurizer level transmitter instrument root valves).

In addition, a few valves in associated systems are included in Section 4.1 of Appendix A of the LRA; these are

Two manual valves in the CVCS letdown line;
Check valves in the CVCS RCP seal bleedoff lines;
Two check valves in the relief piping from the RCS drain tank heat exchanger;
The air system valves noted above; and
RCP lube oil reservoir level transmitter root valves.

The RCP and motors and their oil lift system are evaluated in Section 4.1 of Appendix A of the LRA. The RCP and motor cooling subcomponents are included in Section 4.1 of Appendix A of the LRA out to the connection with the Component Cooling (CC) System. Included in Section 4.1 of Appendix A of the LRA, are the SG and pressurizer supports. Component supports, cables, instrument lines, and instruments not identified as RCS components in Section 4.1 of Appendix A of the LRA are generally included in the component supports commodity, cables commodity, instrument lines commodity, and fire protection AMRs.

In Appendix A to the LRA, the applicant identified the following intended functions for the RCS and system components on the basis of the requirements of 10 CFR 54.4(a)(1) and (2):

To provide manual control of RCS pressure and pressurizer level via charging pumps during design-basis events;
To control RCS pressure by regulating water temperature in the pressurizer;

To provide indication of degrees of subcooling during design-basis events;
To provide wide-range loop temperature signals via resistance temperature detector circuits;
To provide thermal margin/low-pressure signals to the reactor protection system for thermal margin/low pressure trip;
To provide coastdown flow on interruption of power to the RCPs;
To vent the RCS when natural circulation flow has been disrupted or blocked by the accumulation of non-condensable gases;
To provide differential pressure signals to the reactor protection system for low-flow trip;
To provide valve operation logic signals to support safety injection system functions;
To maintain electrical continuity and/or provide protection of the electrical system;
To maintain the pressure boundary of the system (liquid and/or gas for five process fluids, RCS primary side, feedwater/main steam secondary side, CC system, and RCP lube oil);
To provide containment isolation of the RCS during a loss-of-coolant accident;
To provide reactor core decay heat removal via natural circulation [this function also applies to station blackout (10 CFR 50.63) based on 10 CFR 54.4(a)(3)];
To provide indication of natural circulation flow via core exit thermocouples [this function also applies to station blackout (10 CFR 50.63) based on 10 CFR 54.4(a)(3)];
To provide reactor vessel coolant inventory level indication [this function also applies to station blackout (10 CFR 50.63) based on 10 CFR 54.4(a)(3)]; and
To provide protection from overpressure in the RCS [this function also applies to station blackout (10 CFR 50.63) based on 10 CFR 54.4(a)(3)];

The following RCS intended functions were determined on the basis of the requirements of 10 CFR 54.4(a)(3):

For station blackout --To detect leakage from the primary system following loss of AC power;
For station blackout and fire protection --To provide RCS isolation to maintain inventory following loss of AC power;
For post-accident monitoring --To provide information used to assess the environs and plant conditions during and following an accident;
For environmental qualification --To maintain functionality of electrical components as addressed by the environmental qualification program;
For fire protection --To provide lube oil collection for RCP motors sized to accommodate the largest potential oil leak;
For fire protection --To provide monitoring of essential parameters for ensuring safe shutdown in the event of a postulated severe fire;
For fire protection --To provide RCS heat removal by realignment and operation of the shutdown cooling flowpath; and
For fire protection --To control RCS pressure by regulating pressurizer water temperature during shutdown in the event of a postulated severe fire.

On the basis of the intended functions stated above, the applicant has identified the following structures and components of the RCS as within the scope of license renewal: piping, components (e.g., heat exchangers, pressure vessels, pumps, valves, and tanks), and instrumentation that are relied on for mitigation of design-basis events, station blackout, post-accident monitoring, environmental qualification, and fire protection. The applicant identified a total of 63 device types from within these structures and components as being within the scope of license renewal. Of these 63 device types, the applicant identified the following 16 that are subject to an AMR: piping sections CC, GC, HB, and HC; check valve (CKV); control valve (CV); electronically operated relief valve (ERV); hand valve (HV); heat exchanger (HX); level gauge (LG); motor-operated valve (MOV); pump; pressure vessel (only the pressurizer) (PZV); relief valve (RLV); solenoid valve (SV); and tank (TK).

The applicant also indicated that some components in the RCS that are common to many systems have been included in the separate commodity reports that address those components for the entire plant. Therefore, the following components were not included in the individual system sections:

Those structural supports for piping, cables, and components in the RCS that are subjected to an AMR are evaluated for the effects of aging in Section 3.1 of Appendix A to the LRA under the component supports commodity evaluation except for the SG supports and pressurizer support skirts that are evaluated as part of HX and PZV, respectively.
Electrical cabling for components in the RCS that are subject to an AMR are evaluated for the effects of aging in Section 6.1 of Appendix A to the LRA under the electrical cables commodity evaluation.
Instrument tubing and piping, and the associated supports, instrument valves, and fittings for components in the RCS that are subject to an AMR, and the pressure boundaries of the instrument themselves, are all evaluated for the effects of aging in Section 6.4 of Appendix A to the LRA under the instrument lines commodity evaluation.

2.2.3.9.2 Staff Evaluation

The staff reviewed Section 4.1 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the RCS components and supporting structures within scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). This was done in two steps, as described in the following two sections.

2.2.3.9.2.1 Systems, Structures, and Components Within the Scope of License Renewal

As part of the first step of its evaluation, the staff determined whether the applicant has properly identified the systems, structures, and components within the scope of license renewal, pursuant to 10 CFR 54.4. The staff reviewed portions of the UFSAR for the RCS, and compared the information in the UFSAR with the information in Appendix A to the LRA to determine if there were any additional portions of the system piping and other components that the applicant should have identified as within the scope of license renewal. The staff then reviewed structures and components outside the portion identified by the applicant and, as described below, asked the applicant to submit additional information and/or clarifications for a selected number of structures and components to verify that they do not have any intended functions as delineated in 10 CFR 54.4(a). The staff also reviewed the UFSAR for any safety-related system functions that were not identified as intended functions in Appendix A to the LRA to verify that no structure or component having an intended function was omitted from consideration within the scope of the rule.

After completing the initial review, (NRC letter dated September 2, 1998) the staff issued requests for additional information (RAI) regarding the RCS, and by letter dated November 2, 1998, the applicant responded to those RAIs. NRC Question No. 4.1.1 asked the applicant to explain why the component known as "spray head," which sprays colder water inside the pressurizer, was not included within the scope of license renewal.

In response, the applicant stated that the spray head inside the pressurizer does not provide a passive intended function (e.g., pressure boundary) and therefore, was not within the scope of license renewal. The staff found that the applicant's response needed further clarification as follows: On page 4.1-11 of Appendix A to the LRA, the applicant stated that for the RCS components "a detailed list of system intended functions was determined based on the requirements of 10 CFR 54.4(a)(1) and (2)," and one of those intended functions listed in Appendix A to the LRA was "to control RCS pressure by regulating water temperature in the pressurizer." Then, on page 4.1-2 of Appendix A to the LRA, the applicant described how this particular intended function is carried out: "The RCS pressure is maintained by regulating the water temperature in the pressurizer where steam and water are held in thermal equilibrium. Steam is either formed by the pressurizer heaters or condensed by the pressurizer spray to limit the pressure variations caused by contraction or expansion of the reactor coolant. A number of pressurizer heaters are operated continuously to offset the heat losses and the continuous minimum spray, thereby maintaining the steam and water in thermal equilibrium at the saturation temperature corresponding to the desired system pressure."

On the basis of this discussion in Appendix A to the LRA, it is apparent that both of the components of the pressurizer, namely, the heater and the spray head, are relied upon to perform the intended function of RCS pressure control. The heater was included within the scope of license renewal and listed in Table 4.1-1 of Appendix A to the LRA; however, the spray head was not. The heater was dispositioned as a component not subject to an AMR because it is classified as an active component. The staff believes that the spray head is a passive component, and it is not subject to replacement based on a qualified life or specified time period. In light of this discussion, the staff requested additional clarification from the applicant concerning why the spray head should not be within the scope of license renewal, and not subject to an AMR.

In response, the applicant provided clarification during onsite meetings with the staff held on February 16-18, 1999, as documented in an NRC meeting summary dated March 19, 1999, that it has reviewed the staff's concern and verified that the pressurizer spray head has no safety-related function. The applicant further stated that the spray head and its spray function is not credited for the mitigation of any accidents addressed in the UFSAR Chapter 14 accident analyses and therefore does not meet the scoping requirements of 10 CFR 54.4(a)(1). The function of the pressurizer spray is to reduce RCS pressure under normal operating conditions. Also, its failure would not prevent satisfactory accomplishment of any of the functions identified in 10 CFR 54.4(a)(1). On the basis of this clarification, the staff agrees with the applicant's conclusion that the spray head need not be within the scope of license renewal.

In NRC Question No. 4.1.2, the staff asked the applicant to clarify its understanding that in Table 4.1-2 of Appendix A to the LRA, "Tank (TK)" was listed as a device type requiring an AMR; but that Figure 4.1-1 of Appendix A to the LRA shows that the quench tank No.11 is not within the scope of license renewal. In response, the applicant indicated that the device type "Tank (TK)" in Section 4.1 referred to the RCP lube oil reservoir tanks. These RCP lube oil reservoir tanks have a license renewal intended function to act as a pressure boundary for fire protection purposes. The quench tanks for CCNPP Units 1 and 2 were not in the scope of license renewal because these non-safety-related components did not serve a license renewal intended function. The staff reviewed the information and agrees with the applicant's conclusion.

Finally, in NRC Question No. 4.1.4, the staff requested the following clarification: In Table 4.2-2 in Section 4.2 of Appendix A to the LRA, footnotes were used to indicate that "not all components of a device-type were affected by the ARDM." This has been interpreted to mean that some components within the device type category are not subject to the effects of the listed plausible ARDM. Referring to Table 4.1-3 in Section 4.1.2 of Appendix A to the LRA, the applicant was asked to clarify whether any subcomponents of the components listed in the table are similarly not subject to the plausible ARDMs shown. The applicant responded that there were some components within the device-type categories listed in Table 4.1-3 of Appendix A to the LRA that were not affected by the listed ARDMs. Because of the large number of components in the RCS report, the applicant elected not to individually list those components that were not affected by the ARDMs listed in Table 4.1-3. Section 4.1 in Appendix A to the LRA for the RCS contains all of the components for each device type subject to an AMR.

As described above, the staff has reviewed the information in Section 4.1 of Appendix A to the LRA and the additional information submitted by the applicant in response to the staff's RAIs. On the basis of that review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the portions of the RCS and the associated structures and components that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.9.2.2 Reactor Coolant System Subject to Aging Management Review

In Section 4.1.1.2 of Appendix A to the LRA, the applicant identified which structures and components of the reactor coolant system (RCS) were within the scope of the license renewal. The applicant divided those structures and components into device types not subject to an aging management review (AMR) and device types subject to an AMR [listed in Table 4.1-2 in Appendix A to the LRA]. The staff reviewed the information to verify that the applicant's grouping was correct. As described in detail below, the staff did not find any omissions or mistakes in classification by the applicant.

Of 66 device types within the scope of license renewal rule, 52 device types are electrical/ instrumentation components. The staff reviewed the device types that are electrical/ instrumentation components to verify that the applicant did not omit any electrical/instrumentation components that should be subject to an AMR. Of the 52 components, the applicant classified the following 38 as having only active functions and, therefore, not requiring an AMR:

analyzer element
electric coil
hand switch
power lamp indicator
level indicating controller
125/250-V dc motor
pressure alarm
pressure recorder
temperature indicator
temperature relay
vibration indicator
power supply
miscellaneous
relay
analyzer indicator
voltage/current device
current/current device
level controller
level relay
13-kV motor
pressure controller
pressure relay
temperature recorder
heater
vibration-indicating alarm
position-indicating lamp
circuit breaker
fuse
ammeter
level indicator
microprocessor
480-V local control station
pressure indicator controller
radiation indicator
temperature transmitter
vibration element
vibration transmitter
position switch

One device type, temperature element (pressure wells), is considered to be part of the pipe and is evaluated with the piping.

One device type, temperature test point (TP), is evaluated in Section 4.2 of Appendix A to the LRA, "Reactor Pressure Vessel and CEDMs/Electrical Systems."

The following eight device types are evaluated in Sections 2.2.3.32, 2.2.3.33, and 2.2.3.35, of this SER:

level transmitter
differential pressure transmitter
pressure indicator
pressure-indicator alarm
pressure transmitter
panel
control/power cabling
instrument tubing/valve

Four electrical/instrumentation components--control valve, electronically operated relief valve, MOV, and solenoid valve--evaluated in this section were classified as subject to an AMR (only pressure boundary/body). The staff agrees with the applicant's determination, which is consistent with 10 CFR 54.21(a)(1) except for the category of miscellaneous.

In NRC Question No. 4.1.3, the staff asked the applicant to describe the types of components that make up the device type "Miscellaneous (XL)" listed in Table 4.1-1 of Appendix A to the LRA. This device type has been classified as only associated with active functions and, therefore, was excluded from the AMR. The applicant responded that an XL device type is a status-indicating lamp. Indication is an active function for license renewal and, therefore, XL device type components are not within scope and are not subject to an AMR. The staff finds this acceptable.

The remaining device types listed in Table 4.1-2 in Section 4.1.1.3, "Components Subject to Aging Management Review," of Appendix A to the LRA are piping and mechanical components that perform passive functions. The staff agrees with the applicant's inclusion of these devices as requiring an AMR.

The staff has reviewed the information included in Section 4.1.1.3, "Components Subject to Aging Management Review," of Appendix A to the LRA. On the basis of its review, the staff finds that there is reasonable assurance that the applicant has appropriately identified those structures and components subject to an AMR for the RCS to meet the requirements stated in 10 CFR 54.21(a)(1).

2.2.3.10 Reactor Pressure Vessels and Control Element Drive Mechanisms/Electrical System

In Section 4.2, "Reactor Pressure Vessels and Control Elements Drive Mechanisms/Electrical System," of Appendix A to the LRA, the applicant described the structures and components of the reactor pressure vessel (RPV) and control element drive mechanisms (CEDMs), including the reactor vessel level monitoring system (RVLMS) within the scope for license renewal, and identified those systems and components that are subject to an AMR.

2.2.3.10.1 Summary of Technical Information in the LRA Concerning the RPV and CEDMs

As described in the LRA, the CCNPP Unit 1 and Unit 2 RPVs are major parts of each reactor coolant system (RCS). Each RCS has one RPV, one pressurizer, two steam generators, two reactor coolant loops, and four reactor coolant pumps. The RPV is composed of a removable head with multiple penetrations; four primary coolant inlet nozzles; two primary coolant outlet nozzles; upper, intermediate, and lower shell courses; a bottom head; and vessel supports. Each vessel is approximately 503 3/4 inches high, with an inside diameter of 172 inches, and is of an all-welded, manganese molybdenum steel plate and forging construction. The RPV is supported vertically and horizontally by three pads welded to the underside of the RPV primary nozzles. Each RPV support consists of a support foot welded to the primary nozzle; a socket bolted to the support foot (with a cap screw); and a sliding bearing, the spherical crown of which fits into the socket, and flat side sliding surface of which rests on a base plate.

Each RPV contains the reactor vessel internals (RVIs) and associated reactor core, as discussed in Section 4.3, "Reactor Vessel Internals System," of Appendix A to the LRA. The rate of the nuclear reaction in the core is controlled by a combination of a chemical shim (dissolved boric acid) and control element assemblies (CEAs), which are made of a solid boron carbide neutron absorber. The CEAs (that is, four tubes in a square matrix plus a central tube) are connected together at their tops by a yoke that is connected, in turn, to the CEDM extension shaft (some CEDMs have two yokes attached). The CEDMs are designed to permit rapid insertion of the CEAs into the reactor core by gravity.

The CEDMs are magnetic jack-type drives capable of withdrawing, inserting, holding, or tripping a CEA from any point within their 137-inch stroke. Originally, 65 CEDMs were mounted on flanged nozzles on top of the reactor closure head. Eight of those CEDMs were connected to partial-length CEAs, which were subsequently removed. Two of these eight CEDMs have been modified to house RVLMS probes. The remaining six were not used. The CEDM housings comprise the motor assembly, the motor housing assembly, the coil stack assembly, the upper pressure housing assembly, the shroud and conduit assembly, the reed switch assembly, and the drive shaft. The CEDM pressure housings are part of the reactor coolant pressure boundary attached to the reactor vessel and are designed to meet the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), Section III, "Nuclear Vessels."

The RVLMS housings consist of a motor housing assembly, an upper pressure housing assembly (modified from the CEDM design), a shroud, a flange adapter assembly, and a heated junction thermocouple (HJTC) probe assembly. This system is capable of providing the plant operator with the information needed to assess void formation in the reactor vessel head region and the trend of liquid level in the reactor vessel plenum. The HJTC system is composed of two redundant channels, each powered from separate, reliable Class 1E sources.

In Appendix A to the LRA, the applicant identified the following intended functions for the RPV, the RVLMS, and system components based on the requirements of 10 CFR 54.4(a)(1) and (2):

To vent the RCS when natural circulation flow has been disrupted or blocked by an accumulation of non-condensable gases
To provide reactor vessel coolant inventory level indication
To maintain the pressure boundary of the system (liquid and/or gas)
To provide structural support for the fuel assemblies, CEAs, and in-core instrumentation so that they maintain the configuration and flow distribution characteristics assumed in the CCNPP UFSAR Chapter 14 analyses

The following intended functions for the CEDMs and electrical system components were identified based on the requirements of 10 CFR 54.4(a)(1) and (2):

To provide a pressure-retaining boundary for the RCS
To provide rapid shutdown of the reactor

The following CEDM intended functions were determined based on the requirements of 10 CFR 54.4(a)(3):

For fire protection--Interrupt CEDM motor generator set output power to ensure safe shutdown in the event of a severe fire.
For anticipated transient without scram (ATWS)--Initiate reactor trip by interrupting power to the CEDMs upon a diversified scram system signal.
For station blackout--Trip reactor to provide for rapid shutdown of the reactor.

On the basis of the intended functions identified above, the portions of the RPV and the CEDMs/ electrical system that are identified by the applicant as being within the scope of license renewal include the following structures and components: RPVs, CEDMs, CEAs, motors, electrical panels, and associated components. The applicant identified a total of eight device types from within these structures and components as being within the scope of license renewal. Of these eight device types, the applicant identified the following three that are subject to an AMR: the RPV, CEDMs, and RVLMS test points.

The applicant also indicated that some components in the RPVs and the CEDMs/electrical system that are common to many systems have been included in the separate commodity reports that address those components for the entire plant. Therefore, the following components were not included in the individual system sections:

Electrical panels in the CEDMs/electrical system are evaluated for the effects of aging in the Electrical Panels Commodity Evaluation in Section 6.2, "Electrical Commodities" of Appendix A to the LRA.
Electrical components and cables associated with components in the system are evaluated for the effects of aging in the Environmental Qualification Commodity Evaluation in Section 6.3, "Environmental Qualification" of the LRA.

2.2.3.10.2 Staff Evaluation

The staff reviewed this section of the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the RPVs and the CEDMs/electrical system components and supporting structures within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). This evaluation was done in two steps, as described in the following two sections.

2.2.3.10.2.1 Systems, Structures, and Components Within the Scope of License Renewal

As part of the first step in its evaluation, the staff determined whether the applicant had properly identified the systems, structures, and components within the scope of license renewal, pursuant to 10 CFR 54.4. The staff reviewed portions of the UFSAR for the RPV and the CEDMs/electrical system and compared the information in the UFSAR with the information in the LRA to identify any structures or components that the applicant did not identify as being within the scope of license renewal. The staff, using the UFSAR, then reviewed structures and components outside the scope of components identified by the applicant and, as described below, requested that the applicant provide additional information and/or clarifications for a selected number of structures and components to verify that they did not have any intended functions delineated in 10 CFR 54.4(a). The staff also reviewed the UFSAR to determine if there were any safety-related system functions that were not identified as intended functions in the LRA as another method of verifying whether any structures or components relied upon to perform the intended functions were omitted from the scope of license renewal.

After completing the initial review of components not included within the scope of license renewal, the staff issued RAIs regarding the RPVs and the CEDMs/electrical system (NRC letter dated August 26, 1998), and by letter dated November 19, 1998, the applicant responded to the RAIs. Specifically, the staff noted in NRC Question No. 4.2.1 that Figure 4-2 (Revision 18) in Chapter 4 of the CCNPP UFSAR for Units 1 and 2 showed a component attached to the closure head of the RPV, which was called a "lifting lug," and asked the applicant to indicate whether the lifting lugs were within the scope of license renewal. In response, the applicant stated that the lifting lugs were considered to be an integral part of the RPV closure head plates, were included within the scope of the license renewal review, and were evaluated for aging management as described in Section 4.2.2 of Appendix A to the LRA. In NRC Question No. 4.2.2, the staff noted that Figure 4-2 (Revision 18) in Chapter 4 of the CCNPP UFSAR showed that the closure head insulation is attached to the closure head of the RPV and requested that the applicant describe the functions of the closure head insulation and explain whether it is required to support one of the functions listed in 10 CFR 54.4(a). The applicant responded that this insulation performs none of the intended functions listed in Section 4.2.1.1 on page 4.2-5 of Appendix A to the LRA and, therefore, was not within the scope of license renewal. The staff concurred with the assessment. NRC Question No. 4.2.3 asked the applicant to clarify whether the component identified in comment (d) of Table 4.2-2 of Section 4.2.1 of Appendix A to the LRA as a "core stop lug" was the same component labeled as the "core support lug" in Figure 4-2 (Revision 18), in Chapter 4 of the CCNPP UFSAR. If these components are not the same, the staff requested that the applicant describe the functions of the core support lug and explain whether it is required to support one of the functions listed in 10 CFR 54.4(a). In its response, the applicant indicated that these components are the same (they just have a different nomenclature) and, therefore, they are within the scope of license renewal. On the basis of the staff's review of supporting information in the CCNPP UFSAR and the applicant's response to the RAI, the staff has found no omissions by the applicant and, therefore, concludes that there is reasonable assurance that the applicant has appropriately identified those portions of the RPV and the CEDMs/electrical system and their associated (supporting) structures and components that are within the scope of license renewal in accordance with 10 CFR 54.4.

2.2.3.10.2.2 Reactor Pressure Vessels and Control Element Drive Mechanisms/Electrical System Subject to an Aging Management Review

In Section 4.2.1.2 of Appendix A to the LRA, the applicant identified which structures and components of the electrical system were within the scope of the license renewal. The applicant divided those structures and components into device types not subject to an AMR and device types subject to an AMR (listed in Table 4.2-1 of Appendix A to the LRA). The staff reviewed the information submitted by the applicant to verify that the grouping was correct. As described in detail below, the staff finds no omissions or mistakes in classification by the applicant. Therefore, the staff finds that there is reasonable assurance that the applicant has identified the structures and components subject to an AMR for the RPVs and CEDMs/electrical system.

Of eight device types within the scope of the license renewal rule, six device types are electrical/ instrumentation components. The staff reviewed the device types that are electrical/ instrumentation components to verify that the applicant did not omit any electrical/ instrumentation components that should be subject to an AMR. Of the six components, the applicant classified the following four as having only active functions and, therefore, not requiring an AMR:

480-V AC motors
control element assemblies
125/250-V dc motors
load contactors

Two device types, control/power cabling and electrical panels, are evaluated in Section 2.2.3.32, "Cables," and Section 2.2.3.33, "Electrical Commodities," of this SER. No other electrical/instrumentation components were determined to be subject to an AMR. The staff agrees with the applicant's determination, which is consistent with 10 CFR 54.21(a)(1).

Table 4.2-1 indicates that the RPV, the CEDM, and the reactor vessel level monitoring system (RVLMS) test point (TP) were determined to be device types that require an AMR. The applicant indicated that the passive intended function of the RPV and CEDMs is to maintain the pressure boundary of the system. In addition, the applicant indicated that another passive function of the RPV is to provide structural support for the fuel assemblies, control element assemblies (CEAs), and incore instrumentation (ICI). The applicant further divided the RPV into subcomponent parts to identify additional passive intended functions. These additional passive intended functions are listed in the LRA. The staff agrees with the applicant's inclusion of the devices listed in Table 4.2-1 as requiring an AMR.

The staff has reviewed the information in Section 4.2.1.3, "Components Subject to Aging Management Review," of Appendix A to the LRA. On the basis of its review, the staff finds that there is reasonable assurance that the applicant has appropriately identified those structures and components subject to an AMR for the RPVs and CEDMs to meet the requirements of 10 CFR 54.21(a)(1).

2.2.3.11 Reactor Vessel Internals System

In Section 4.3, "Reactor Vessel Internals System," of Appendix A to the LRA, the applicant described the structures and components of the reactor vessel internals (RVI) system at the plant site that are within the scope for license renewal, and identified which of those structures and components are subject to an AMR.

2.2.3.11.1 Summary of Technical Information in Application

As described in Appendix A to the LRA, the RVI includes the reactor core and the RVI structures, which together provide the heat source and direct the flow of coolant through the reactor vessel. The system also contains reactor component handling equipment.

The major components of the reactor core are 217 fuel assemblies and 77 control element assemblies (CEAs, also called the control rods). The major components of the RVI structures are the core support barrel (CSB), the lower core support structure (including the core shroud), and the upper guide structure (UGS) (including the 65 CEA shrouds and incore instrumentation [ICI] guide tubes). The reactor component handling equipment includes the reactor vessel head lifting rig, the RVI lifting rigs, and the surveillance capsule retrieval tool.

The RVIs are designed to (1) support and orient the fuel assemblies and CEAs, (2) absorb the CEA dynamic loads and transmit these and other loads to the reactor vessel flange, (3) direct reactor coolant flow through the reactor core, and (4) support and orient ICI.

In Section 3.3.3 of the UFSAR, the applicant describes the RVI structures. Figures 3.3-1, 3.3-6, 3.3-11, 3.3-13, and 3.3-14 of the UFSAR depict components of the RVI. Table 4-10 of the UFSAR identifies that the RVIs are constructed of Type 304 SS and nickel-chromium-iron (Ni-Cr-Fe) alloy steels. These materials were chosen during the design phase because they had shown satisfactory performance in operating reactor plants.

The major support member of the RVI is the core support assembly, which consists of the CSB, the lower core support structure, and the core shroud. The core support assembly is supported by the upper flange of the CSB, which rests on a ledge in the reactor vessel flange. The lower flange of the CSB supports and positions the lower core support structure, which consists of a core support plate (CSP), vertical columns, horizontal beams, and an annular skirt. The weight of the core is supported by the CSP, which transmits the load through the columns to the beams to the skirt to the lower flange of the CSB. The CSP provides support and orientation for the fuel assemblies. The Core shroud, which provides lateral support for the peripheral fuel assemblies, is also supported by the CSP. The lower end of the CSB is restrained radially by six CSB snubbers. The core support assembly normally remains in the reactor vessel during refueling.

The UGS assembly consists of the upper support plate, 65 CEA shrouds, a fuel assembly alignment plate, and a hold-down ring (HDR). The UGS assembly aligns and laterally supports the upper end of the fuel assemblies, maintains the CEA spacing, prevents fuel assemblies from being lifted out of position during a severe-accident condition, and protects the CEAs from the effect of coolant cross-flow in the upper plenum. The UGS is handled as a unit and is removed during refueling to gain access to the fuel assemblies in the reactor core.

In the reactor core, the fuel assemblies have functions during design-basis events that place the assemblies within the scope of license renewal. However, the assemblies are replaced at regular intervals dependent on the fuel cycle of the plant. Since the assemblies are short-lived components, their aging is not discussed in Appendix A to the LRA. The CEAs in the core are discussed with the control element drive mechanisms and electrical system in Section 4.2 of Appendix A to the LRA.

The reactor vessel head lifting rig is discussed with the fuel handling equipment and other heavy load handling cranes in Section 3.2 of Appendix A to the LRA. The RVI lifting rigs and the surveillance capsule retrieval tool are not installed components and are not within the scope of license renewal.

In Appendix A to the LRA, the applicant identified the following intended function for the RVI and system components according to the requirements in 10 CFR 54.4(a)(1):

Provide structural support for the fuel assemblies, CEAs, and ICI so that they maintain the configuration and flow distribution characteristics assumed in the UFSAR Chapter 14 analyses.

On the basis of the intended function noted above, the portions of the RVI that are identified by the applicant as within the scope of license renewal and as subject to an AMR include the following 17 device types: CEA shroud and bolts (CEASB), CEA shroud extension shaft guides (ESGs), Core shroud, core shroud tie rod (CSTR) and bolts, CSB, core support barrel alignment (CSBA) key, core support barrel snubber and snubber bolts, core support columns (CSCs), CSP, flow baffle, fuel alignment pins, fuel alignment plate/guide lug insert, HDR, ICI thimble support plate (ITSP), ICI thimbles, lower support structure beam assembly (LSSBA), and upper guide structure support plate (UGSP).

Not all device types of the RVIs shown above are evaluated in Section 4.3 of Appendix A to the LRA. These device types are excluded from Section 4.3 for the following reasons:

The CSB snubber bolts are physically bolted to the CSB, but work with the core-stabilizing lugs that are welded to the vessel wall. Together these components limit flow-induced vibrations in the CSB. The design of the CSB snubber assembly is shown in UFSAR Figure 3.3-12. Because of this mating-part relationship, the snubber and the snubber bolts are evaluated along with the lugs in Section 4.2 rather than in Section 4.3 of Appendix A to the LRA.
The flow baffle is a structure inside the reactor pressure vessel, but it is welded to supports that are welded to the inside of the vessel wall. The flow baffle is shown as the flow skirt in UFSAR Figure 3.1-1. Since it is welded to the vessel wall, the baffle is evaluated along with other vessel components in the reactor vessel/control element drive mechanism system in Section 4.2 of Appendix A to the LRA.
For the ICI thimbles device type, the only component that is within the scope of license renewal is the ICI flange, which provides a pressure-retaining boundary for the RCS. Because of this function, the ICI flange is evaluated in Section 4.2 of Appendix A to the LRA along with reactor pressure vessel components that have the same function.

2.2.3.11.2 Staff Evaluation

The staff reviewed Section 4.3 of Appendix A to the LRA to determine whether there is reasonable assurance that the RVI components and supporting structures subject to an AMR have been identified in accordance with the requirements of 10 CFR 54.21(a)(1). This was accomplished in two steps, as described in the following two subsections.

2.2.3.11.2.1 Systems, Structures, and Components Within the Scope of License Renewal

As part of the first step of its evaluation, the staff reviewed portions of the UFSAR for the RVIs, and compared the information in the UFSAR with the information in Appendix A to the LRA to determine if there were any additional portions of the RVI and other components that the applicant should have identified as within the scope of license renewal. The staff then reviewed structures and components outside the applicant-identified portion, and as described below, asked the applicant to submit additional information and/or clarifications for a selected number of structures and components to verify that they do not have any intended functions as delineated in 10 CFR 54.4(a). The staff also reviewed the UFSAR for any safety-related system functions that were not identified as intended functions in Appendix A to the LRA to verify that no structure or component having an intended function was omitted from consideration within the scope of the rule.

After completing the initial review, by letter dated September 3, 1998, the staff issued requests for additional information (RAIs) regarding the RVIs, and by letter dated November 19, 1998, the applicant responded. Figure 3.3-6 (Revision 21) of the CCNPP UFSAR shows the fuel assembly hold-down (FAHD) structure. One of the intended functions of the FAHD structure is to prevent fuel assemblies from being lifted out of position under accident loading conditions. NRC Question No. 4.3.1 asked the applicant to clarify whether the FAHD structure (particularly the spring) was within scope and subject to an AMR; the spring may lose its required force at an extended age. In response, the applicant stated that Figure 3.3-6, "Fuel Assembly Hold Down," illustrates the relationship between the fuel alignment plate (which is part of the RVIs) and an individual fuel assembly. Except for the fuel alignment plate, all the components shown on Figure 3.3-6, including the upper end fitting, spring, spider, and upper end fitting posts, are part of the fuel assembly. Since the upper end fitting components of a fuel assembly are discarded with that assembly and since fuel assemblies are replaced based on a fixed number of fuel cycles fuel assemblies (including the upper end fitting components) are considered short-lived and are not subject to an AMR.

Figure 3.3-14 (Revision 21) of the CCNPP UFSAR shows the upper guide structure (UGS) assembly. NRC Question No. 4.3.2 asked the applicant to describe the functions of the component identified in the UFSAR as the expansion compensating ring, and to indicate if its intended functions would meet the definition of intended function given in 10 CFR 54.4(a). The applicant responded by noting that the expansion compensating ring, called the hold-down ring (HDR) in Appendix A to the LRA, states the following intended function: "provide structural support for the fuel assemblies, CEAs, and ICI so that they maintain the configuration and flow distribution characteristics assumed in UFSAR Chapter 14 analyses." This intended function conforms to the definition of "intended function" in 10 CFR 54.4(a). All RVI components that perform this function were subject to an AMR.

In Section 4.1.3.6 (Revision 18) of the CCNPP UFSAR, the applicant indicated that vents were added to the reactor vessel and to the pressurizer head in response to the Three Mile Island "Lessons Learned Report" (NUREG-0737, Item II.B.1). One of the intended functions of the vents is to ensure core cooling during a loss-of-coolant accident. NRC Question No. 4.3.3 asked the applicant to clarify if this vent system was subject to an AMR, and if it was, the question also asked for a cross-reference to where this system is addressed in Appendix A to the LRA. The applicant stated in its response that the reactor vessel vent system was within scope and subject to an AMR. The nozzles were evaluated as part of the reactor vessel heads in Section 4.2 of Appendix A to the LRA. The vent system includes valves, piping, and tubing. The piping and associated valves were evaluated along with the reactor coolant system (RCS) in Section 4.1 of Appendix A to the LRA. Tubing and associated valves were evaluated in the instrument lines commodity evaluation in Section 6.4 of Appendix A to the LRA. The pressurizer vent system was also subject to an AMR. As noted in Section 4.1.3.6 of the CCNPP UFSAR, the pressurizer vent line valves are installed in a line that was added as another branch off the pressurizer vapor sample line. Part of this vent system was evaluated along with the nuclear steam supply sampling system in Section 5.13 of Appendix A to the LRA. The other part was evaluated with the RCS in Section 4.1 of Appendix A to the LRA.

As described above, the staff has reviewed the information in Section 4.3 of Appendix A to the LRA and the additional information submitted by the applicant in response to the staff's RAIs. On the basis of that review, the staff concludes that the applicant has appropriately identified those portions of the RVIs and the associated (supporting) structures and components that fall within the scope of license renewal, in accordance with the requirements of 10 CFR 54.4.

2.2.3.11.2.2 Reactor Vessel Internals System Subject to an Aging Management Review

According to their function, the RVI structures are determined to perform their functions without moving parts or without a change in configuration or properties. Section 4.3 of Appendix A to the LRA only evaluates the RVI structures component device types that are subject to age-related degradation mechanisms (ARDMs) that require their inclusion in the AMR program. In the reactor core, the fuel assemblies have functions during design-basis events that make the assemblies fall within the scope of license renewal. However, the assemblies are replaced at regular intervals based on the fuel cycle of the plant and, therefore, the fuel assemblies are not subject to an AMR in accordance with 10 CFR 54.21(a)(1)(ii).

The staff has reviewed the information in Section 4.3 of Appendix A to the LRA and additional information submitted by the applicant in response to the staff RAIs. On the basis of a review of selected RVI structures and components, the staff finds that there is reasonable assurance that the applicant has appropriately identified the RVI structures and components subject to an AMR in accordance with the requirements in 10 CFR 54.21(a)(1).

2.2.3.12 Auxiliary Feedwater System

In Section 5.1, "Auxiliary Feedwater System," of Appendix A to the LRA, the applicant described the structures and components of the AFW system at the plant site that are within the scope for license renewal, and identified which of those structures and components are subject to an AMR.

2.2.3.12.1 Summary of AFW Technical Information in the Application

As described in the LRA, the AFW system is designed to provide emergency water from the No. 12 condensate storage tank (CST) to the steam generators for the removal of sensible and decay heat, and to cool the primary system to 300 �F if the main condensate pumps or the main feedwater pumps are inoperative. The AFW system has three pumps per unit-- two turbine-driven pumps and one motor-driven pump. The turbine-driven pumps can be used to perform plant cooldown to 300 �F; the motor-driven pump is reserved for emergency use only.

Upon automatic initiation, one turbine-driven AFW pump and the motor-driven AFW pump automatically start. The pumps take suction from the 300,000 gallon CST, which provides sufficient water for decay heat removal and cooldown for both units. The system also contains the following major components: piping, turbine isolation and governor valves, flow control valves, check valves, flow elements, and instrumentation and controls sufficient to safely operate the system. Part of the instrumentation and controls for the AFW system is the auxiliary feedwater actuation system (AFAS). The AFAS starts the AFW pumps upon detection of a very low level of steam in either steam generator and blocks AFW flow to a ruptured steam generator.

In the LRA, the applicant identified the following intended functions for the AFW system based on 10 CFR 54.4(a)(1) and (2):

Provide AFW to the steam generators (SGs) for decay heat removal.
Maintain the pressure boundary of the system.
Isolate the AFW to the SG.
Maintain electrical continuity and/or provide protection of the electrical system.
Provide circuit protection for the SG pressure signal being sent from the feedwater system to the engineered safety features actuation system and the reactor protective system.
Provide seismic integrity and/or protection of safety-related components.
Restrict flow to ensure adequate recirculation flow for pump cooling, and to limit recirculation flow so that adequate AFW flow is provided to the SGs.

The applicant also determined that the following were intended functions of the AFW system based on the requirements of 10 CFR 54.4(a)(3):

For environmental qualification (EQ)--Maintain functionality of electrical components as addressed by the EQ program, and provide information used to assess the condition of the plant and its environs during and following an accident.
For anticipated transient without scram (ATWS)--Provide AFAS start signal on low steam generator water level condition.
For station blackout (SBO)--Provide AFW to steam generators for decay heat removal and provide condensate inventory.
For fire protection--Monitor essential AFW parameters to ensure safe shutdown in the event of a postulated fire. Provide alternate control of the AFW system via local hand valves, flow transmitters, and current/pneumatic components at the auxiliary shutdown panel to ensure safe shutdown in the event of a fire.

On the basis of the intended functions listed above, the portions of the AFW system that are identified by the applicant as within the scope of license renewal are the following equipment types: piping; components (i.e., pumps, valves, and tanks); supports; instrumentation; and cables that are required for mitigation of design basis-events, for EQ, for SBO, for ATWS, and for safe shutdown following a fire. The applicant identified a total of 47 device types from within these AFW equipment types as being within the scope of license renewal because they have at least one intended function. Of these 47 device types, the applicant identified the following 19 that are subject to an AMR: 7 piping types, 6 valves types (check, flow control, pressure control, governor, solenoid, and hand valve), flow element, flow orifice, current/pneumatic device, pump, turbine, and tank. The applicant further indicated that maintenance of the pressure boundary for the liquid in the AFW system, restricting flow for pump cooling, and ensuring adequate flow to the SGs are the only passive intended functions associated with the AFW system that are not addressed in one of the commodity evaluations of the LRA.

The applicant also indicated that some components in the AFW system that are common to many systems have been evaluated in the separate commodity reports that address those components for the entire plant. Therefore, they were not evaluated in the individual system sections. These components include the following:

Structural supports for piping, cables, and components that are evaluated for the effects of aging in Section 3.1 of Appendix A to the LRA;
Electrical control and power cabling, which is evaluated in Section 6.1 of Appendix A to the LRA;
Instrument tubing and piping and their associated supports, instrument valves and fittings, and the pressure boundaries of the instrument themselves, which are all evaluated in Section 6.4 of Appendix A to the LRA.

2.2.3.12.2 Staff Evaluation

The staff reviewed Section 5.1 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the AFW system components and supporting structures within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued requests for additional information (RAIs) regarding the AFW system (NRC letter dated August 21, 1998), and the applicant responded to those RAIs by letter dated November 2, 1998.

2.2.3.12.2.1 Auxiliary Feedwater System Structures and Components Within the Scope of License Renewal

As part of the first step of its evaluation, the staff reviewed the information submitted by the applicant in the LRA and portions of the UFSAR, including flow diagrams for Unit 1 and Unit 2 AFW systems, to look for portions of the system piping and other components that the applicant should have identified as within the scope of license renewal. Essentially all portions of the AFW system were determined to perform at least one intended function and, therefore, essentially all portions and components of the AFW system are within the scope of license renewal and are identified as such by the applicant either in Section 5.1 or in other sections of Appendix A to the LRA. The staff reviewed the few remaining components of the AFW system to verify that they have no intended functions. The staff also reviewed portions of the UFSAR for any safety-related system functions that were not identified as intended functions in Appendix A to the LRA to verify that no structures or components having an intended function were omitted from within the scope of the rule.

In the LRA, the applicant submitted a simplified diagram (Figure 5.1-1) of the AFW system and a list of device types to identify the portion of the AFW system that is within the scope of license renewal and to identify the system interfaces. Figure 5.1-1 was representative of the system, but did not contain many of the details necessary to determine the system interfaces or the components within the scope of license renewal. The staff used the flow diagram in the UFSAR to identify components that did not appear on the simplified diagram, such as the local temperature indicators on the AFW turbines, steam piping drains, steam stop and control valves, and AFW turbine exhaust piping. To help ensure that all components within the scope of license renewal appeared on the list of device types, that those portions of the AFW system identified as not within the scope of license renewal did not have any intended functions that may require an AMR, and to ensure that all interfacing systems and components within the scope of license renewal were identified, the staff asked the applicant for more detailed information.

In response to NRC Question Nos. 5.1.1 and 5.1.3 regarding components within the scope of license renewal, the applicant submitted information justifying the omission of the local turbine temperature indicators from the list of device types within the scope of license renewal, because these indicators provide local indication of turbine oil reservoir temperature but do not perform an intended function as defined in 10 CFR 54.4(a)(1), (2), or (3). For the steam drain piping, the applicant clarified that this piping was within the scope of license renewal and was evaluated in another section of the LRA. The applicant provided a cross-reference to where the information could be found. The applicant also clarified that the steam stop and control valves were within the scope of license renewal and evaluated in Section 5.1.

Exhaust piping from the AFW turbines to the roof exhausts was also omitted from the list of components within the scope of license renewal. The applicant explained in its response to NRC Question No. 5.1.1 that this piping is non-safety-related with no intended functions for license renewal. The staff reviewed the applicant's response and concluded that the applicant had not submitted sufficient information to determine whether the piping was outside the scope of license renewal. On February 18, 1999, the staff met with the applicant to discuss the AFW turbine exhaust piping. The applicant presented an evaluation of the failure of the exhaust piping and its effects on the safety-related equipment in the room. The staff reviewed this evaluation and accepted that the failure of the exhaust piping would not cause the failure of any safety-related equipment to perform its intended function. As a result of this evaluation, the staff concludes that the piping is not required to be within the scope of license renewal based on 10 CFR 54.4. The staff documented the results of this meeting in a meeting summary dated March 19, 1999.

In response to NRC Question No. 5.1.2 regarding system interfacing components for the main steam and auxiliary steam systems, the applicant clarified the interfacing boundaries for the AFW system so that the staff was able to conclude that any interfacing components in the main steam and auxiliary steam system were included in the list of components within the scope of license renewal for the AFW system, or were included in the list of components within the scope of license renewal for the interfacing system.

As described above, the staff has reviewed the information in Section 5.1 of Appendix A to the LRA and the additional information submitted by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds that there is reasonable assurance that the applicant has appropriately identified those AFW structures and components within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.12.2.2 Auxiliary Feedwater System Subject to an Aging Management Review

In Section 5.1.1.2 of Appendix A to the LRA, the applicant identified which structures and components of the AFW are within the scope of license renewal. The applicant divided those structures and components into device types not subject to an AMR and device types subject to an AMR (listed in Table 5.1-1 of Appendix A to the LRA). The staff reviewed the information submitted by the applicant to verify that the grouping was correct. The staff finds that there is reasonable assurance that the applicant has appropriately identified the structures and components for the AFW system subject to an AMR in accordance with 10 CFR 54.21(a)(1).

Of the 50 device types within the scope of the license renewal rule, 35 device types are electrical/instrumentation components. The staff reviewed the device types that are electrical/ instrumentation components to verify that the applicant did not omit electrical/instrumentation components that should be subject to an AMR. Of the 35 components, the applicant classified the following 21 as having only active functions and therefore not requiring an AMR:

2/4 logic component
flow indicator
flow component (relay)
current/current component
power lamp indicator
125/250-V dc motor
power supply
voltage/current component
flow indicator controller
hand controller
current/voltage component
level indicator alarm
vacuum breaker valve
position indicating lamp
coil
fuse
hand switch
ammeter
4-kV motor
relay
position switch

The staff agreed that these 21 device types were active and therefore not subject to an AMR. The applicant has used the following AFW system functions to determine whether or not components perform their functions with moving parts or a change in configuration or properties:

Maintain the pressure boundary of the system;
Maintain electrical continuity and/or provide protection of the electrical system;
Provide seismic integrity and/or protection of safety-related components; and
Provide flow restriction to ensure adequate recirculation flow for pump cooling, and to limit recirculation flow so that adequate AFW flow is provided to the steam generators.

The staff finds that application of these criteria will not result in components that should be subject to an AMR being excluded from an AMR.

Instrument line manual drain, equalization, and isolation valves in the AFW system that are subject to an AMR are evaluated for the effects of aging in Section 2.2.3.35, "Instrument Line," or Section 2.2.3.33, "Electrical Commodities," of this SER.

Hand valves and piping, which are relied upon for safe shutdown in the event of a fire and are classified as non-safety-related, are discussed for the effects of aging in the fire protection evaluation in Section 5.10 of Appendix A to the LRA. All safety-related valves and piping are subject to an AMR. A total of 24 current/pneumatic devices are within the scope of license renewal. Only 8 of these devices are subject to an AMR. The other 16 are not subject to an AMR because they are either included in a replacement program or they have only active intended functions.

One device type, flow transmitter, consists of 16 flow transmitters that are within the scope of license renewal. Four of the transmitters are subject to replacement based on a qualified life and do not require an AMR. Twelve transmitters are evaluated in Section 2.2.3.35, "Instrument Line," of this SER.

The following eight device types are evaluated in Sections 2.2.3.32, "Cables," 2.2.3.33, "Electrical Commodities," or 2.2.3.35, "Instrument Line," of this SER:

level indicator
pressure switch
control/power cabling
level transmitter
pressure transmitter
instrument tubing/valve
pressure indicator
panel

The following five electrical/instrumentation components evaluated in this section were classified as subject to an AMR (only pressure boundary/body):

control valve
control valve operator
flow element
pressure control valve
current pneumatic device
solenoid valve

The remaining device types listed in Table 5.1-1, including the piping, check valve, hand valve, pump/drive assembly, relief valve, and tank, were reviewed and verified that the applicant did not omit components that should be subject to an AMR.

The staff has reviewed the information in Section 5.1 of Appendix A to the LRA and additional information submitted by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds reasonable assurance that the applicant has appropriately identified the structures and components subject to an AMR in accordance with the requirements in 10 CFR 54.21(a)(1).

2.2.3.13 Chemical and Volume Control System

In Section 5.2, "Chemical and Volume Control System (CVCS)," of Appendix A to the LRA, the applicant described the systems with component supports at the plant site that are within the scope for license renewal, and identified which of those structures and components are subject to an AMR.

2.2.3.13.1 Summary of Technical Information in the Application

As described in Appendix A to the LRA, the purpose of the CVCS is to perform the following functions:

Maintain reactor coolant activity at the desired level by removing corrosion and fission products;
Inject chemicals into the reactor coolant system (RCS) to control coolant chemistry and minimize corrosion;
Control the reactor coolant volume by compensating for coolant contraction or expansion from changes in reactor coolant temperature and other coolant losses or additions;
Provide means for transferring fluids to the radioactive waste processing system;
Inject concentrated boric acid into the RCS upon a safety injection actuation signal;
Control the reactor coolant boric acid concentration;
Provide auxiliary pressurizer spray for operator control of RCS pressure during startup and shutdown;
Provide continuous on-line trending of reactor coolant boron concentration, and fission product activity; and
Provide a means for degasifying the RCS before maintenance outages and during normal operations.

The CVCS automatically adjusts the volume of water in the RCS using a signal from level instrumentation located on the pressurizer. The system reduces the amount of fluid that must be transferred between the RCS and the CVCS during power changes by employing a programmed pressurizer level setpoint that varies with reactor power level. The CVCS also purifies and conditions the coolant by means of ion exchangers, filters, degasification, and chemical additives.

The CVCS is composed of two subsystems: letdown and charging, and makeup. The letdown and charging subsystem's major components are letdown stop valves, regenerative heat exchanger, excess flow check valves, letdown flow control valves, letdown heat exchangers, letdown backpressure control valves, purification filters, ion exchangers, volume control tank, charging pumps, boronmeter, process radiation monitor, and reactor coolant pump bleedoff containment isolation valves (to the volume control tank). The makeup subsystem's major components are boric acid batching tank, boric acid storage tanks, boric acid pumps, reactor coolant makeup pumps, chemical addition tank, chemical addition metering tank, and chemical addition metering pump.

In Appendix A to the LRA, the applicant identified the following intended functions for the CVCS and its components based on the requirements of 10 CFR 54.4(a)(1) and 54.4(a)(2):

To provide containment isolation of the CVCS during a loss-of-coolant accident (LOCA) (a function also applicable to station blackout (10 CFR 50.63), based on 10 CFR 54.4(a)(3));
To inject concentrated boric acid into the RCS for reactivity control and RCS pressure and level control during design-basis events (a function also applicable to pressurized thermal shock (10 CFR 50.61) and fire protection (10 CFR 50.48), based on 10 CFR 54.4(a)(3));
To provide radiological release control by isolating the RCS letdown line during a LOCA;
To provide the pressure boundary of the CVCS (liquid and/or gas);
To provide long-term core flush via pressurizer auxiliary spray (also applicable to pressurized thermal shock (10 CFR 50.61), based on 10 CFR 54.4(a)(3));
To maintain electrical continuity and/or protect the electrical system;
To maintain mechanical operability and/or protect the mechanical system;
To restrict flow to a specified value in support of a design-basis event response; and,
To maintain safety-related components seismic integrity and/or protect them.

The following CVCS intended functions were determined based on the requirements of 10 CFR 54.4(a)(3):

For post-accident monitoring--to provide information used to assess the environs and plant condition during and following an accident;
For fire protection (10 CFR 50.48)--to provide RCS pressure and inventory control to ensure safe shutdown in the event of a severe fire;
For environmental qualification (10 CFR 50.49)--to maintain functionality of electrical components as prescribed by the environmental qualification program; and
For station blackout (10 CFR 50.63)--to provide RCS isolation to maintain RCS inventory during a station blackout.

On the basis of the intended functions listed above, the portions of the CVCS that are within the scope of license renewal include all components (electrical, mechanical, and instrument) and their supports along the following system flowpaths:

From the volume control tank outlet stop valve through the charging pumps and regenerative heat exchanger to the auxiliary spray and charging line check valves;
From the reactor coolant pump bleedoff isolation valves inside containment through the containment penetration to the isolation valve outside containment;
From the boric acid storage tanks through the boric acid pumps to the charging pump header and to the makeup stop valve;
From the boric acid storage tanks through the gravity feed valves to the charging pump header; and
From the RCS interface at the letdown stop valves through the regenerative heat exchangers to the letdown flow control valves. The letdown heat exchanger is also within the scope of license renewal due to its safety-related pressure boundary for the component cooling (CC) system, although the piping between the letdown flow control valves and the letdown heat exchanger is not within the scope of license renewal.

All piping within the scope of license renewal for the CVCS is identified as being within the safety-related pressure boundary, and each piece of equipment within this boundary is considered a safety-related pressure boundary component.

On the basis of the intended functions identified above, 53 device types (not including the two device types evaluated in commodity reports, described below) were listed from the portions of the CVCS that are noted by the applicant as within the scope of license renewal. Of these 53 device types, the applicant identified 25 that are subject to an AMR. Of these 25 device types, 17 are addressed in Section 5.2 of Appendix A to the LRA: piping sections CC and HC, accumulator (ACC), basket strainer (BS), check valve (CKV), control valve (CV), flow element (FE), flow orifice (FO), hand valve (HV), heat exchanger (HX), motor-operated valve (MOV), pressure control valve (PCV), pump/driver assembly (PUMP), relief valve (RLV), solenoid valve (SV), temperature element (TE), and tank (TK). The remaining 8 device types are flow transmitter (FT), level indicator alarm (LIA), level switch (LS), pressure differential indicator (PDI), pressure indicator (PI), pressure switch (PS), and pressure transmitter (PT) are evaluated in the Instrument Lines Commodity Evaluation in Section 6.4 of Appendix A to the LRA, and panel (PNL) is evaluated in the Electrical Panels Commodity Evaluation in Section 6.2 of Appendix A to the LRA.

The applicant also indicated that some components in the CVCS that are common to many systems have been included in the separate commodity reports addressing those components for the entire plant. Therefore, these components are not included among the 53 CVCS device types discussed above. They are evaluated as follows:

Structural supports for piping, cables and components in the CVCS that are within scope and are subject to an AMR are evaluated for the effects of aging in the Component Supports Commodity Evaluation in Section 3.1 of Appendix A to the LRA.
Electrical cabling for components in the CVCS that are subject to an AMR are evaluated for the effects of aging in the Electrical Cables Commodity Evaluation in Section 6.1 of Appendix A to the LRA.
Instrument lines (i.e., tubing and small bore piping), tubing supports, instrument valves (e.g., equalization, vent, drain, isolation), and fittings for components in the CVCS that are subject to an AMR are evaluated for the effects of aging in the Instrument Lines Commodity Evaluation in Section 6.4 of Appendix A to the LRA.

2.2.3.13.2 Staff Evaluation

The staff reviewed Section 5.2 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the CVCS components and supporting structures within the scope of license renewal in accordance with 10 CFR 54.4.and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). This was accomplished in two steps, as described in the following two subsections.

2.2.3.13.2.1 Chemical and Volume Control System Within the Scope of License Renewal

As part of the first step of its evaluation, the staff determined whether the applicant has properly identified the systems, structures, and components within the scope of license renewal, pursuant to 10 CFR 54.4. The staff reviewed portions of the UFSAR for the CVCS, and compared the information in the UFSAR with the information in Appendix A to the LRA to determine if there were any additional portions of the system piping and other components that the applicant should have identified as within the scope of license renewal. The staff then reviewed structures and components outside the portion identified by the applicant, as described below, asked the applicant to provide additional information or clarifications for selected structures and components to verify that they do not have any of the intended functions listed in 10 CFR 54.4(a). The staff also reviewed the UFSAR for any safety-related system functions that were not identified as intended functions in Appendix A to the LRA to verify that no structure or component having an intended function was omitted from consideration within the scope of the rule.

After completing the initial review, by letter dated September 3, 1998, the staff issued requests for additional information regarding the CVCS, and by letter dated November 4, 1998, the applicant provided responses to NRC questions. Page 9.1-31 (Rev. 21) of the CCNPP UFSAR indicates that boric acid solution is stored in heated and insulated tanks and is piped in heat-traced and insulated lines to preclude precipitation of the boric acid. NRC question No. 5.2.8 requested that the applicant specify whether the storage tank and pipe insulation material within the CVCS was within the scope of license renewal and subject to an AMR, and if not, to justify excluding these components from the renewal scope. In response, the applicant stated that the insulation performs none of the intended functions listed in Appendix A to the LRA and, as such is not within the scope of license renewal. The staff concludes that, even if the CVCS relied on the insulation to perform any accident mitigation functions, there are no plausible aging effects for the insulation that would warrant an aging management program.

As described above, the staff has reviewed the information in Section 5.2 of Appendix A to the LRA and the additional information submitted by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the portion of the CVCS and associated structures and components within the scope of license renewal, in accordance with the requirements of 10 CFR 54.4.

2.2.3.13.2.2 Chemical and Volume Control System Subject to an Aging Management Review

In Section 5.2.1.2 of Appendix A to the LRA, the applicant identified which structures and components of the chemical and volume control system (CVCS) are within the scope of the rule. The applicant divided those structures and components into device types not subject to an AMR and device types subject to an AMR (listed in Table 5.2-2 of Appendix A to the LRA). The staff reviewed the information submitted by the applicant to verify that the applicant's grouping was correct.

Of the 55 device types within the scope of the license renewal rule, 42 are electrical/instrumentation components. The staff reviewed the device types that are electrical/instrumentation components to verify that the applicant did not omit electrical/instrumentation components that should be subject to an AMR. Of the 42 components, The applicant classified the following 27 as having only active functions and, therefore, not requiring an AMR:

coil
disconnect switch/link
flow device (relay)
current/pneumatic device
level controller
480-V motor
pressure controller
temperature indicating controller
control switch
flow indicator alarm
hand indicator controller
ammeter
level indicating transmitter
125/250-V dc motor
heat tracing controller
temperature switch
control valve operator
fuse
hand switch
power lamp indicator
level device (relay)
MOV operator
relay
electric heater
miscellaneous indicating lamps
position indicating lamp
position switch

The following 10 device types are evaluated under Section 2.2.3.32, "Cables"; Section 2.2.3.33, "Electrical Commodities"; or Section 2.2.3.35, "Instrumentation Lines," of this SER:

flow transmitter
pressure differential indicator
pressure switch
instrument tubing/valves
level indicator alarm
pressure indicator
pressure transmitter
level switch
panel
control/power cabling

The following five electrical/instrumentation components evaluated in this section were classified as subject to an AMR (only pressure boundary/body). The staff considers the applicant's classification consistent with 10 CFR 54.21(a)(1):

control valve
solenoid valve
flow element
temperature element
MOV

Thirteen device types within the scope of license renewal are mechanical components or structural supports. The structural supports for piping, cables and components are evaluated in Section 2.2.3.1, "Component Supports," of this SER.

The remaining 12 device types listed in Table 5.2-2 are piping and mechanical components that perform passive functions. The staff agrees with the applicant's inclusion of these devices as requiring an AMR.

The staff reviewed the information in Section 5.2.1.3, "Components Subject to Aging Management Review," of Appendix A to the LRA. On the basis of its review, the staff finds that there is reasonable assurance that the applicant has appropriately identified those structures and components subject to an AMR for the CVCS to meet the requirements stated in 10 CFR 54.21(a)(1).

2.2.3.14 Component Cooling System

In Section 5.3, "Component Cooling (CC) System," of Appendix A to the LRA, the applicant described the CC system and the CC components that are within the scope for license renewal, and identified which of those components are subject to an AMR.

2.2.3.14.1 Summary of Technical Information in the Application

As described in the LRA, the CC system is designed to remove heat from various safety-related and non-safety-related plant systems. The saltwater (SW) system (Section 5.16, "Safety Injection System," of Appendix A to the LRA) supplies the cooling medium for the CC heat exchangers and discharges the heated water to the ultimate heat sink. The CC system is required to operate during normal operation, plant shutdown, and post-accident conditions. The CC system for each unit consists of three motor-driven pumps, two heat exchangers, a head tank, a chemical additive tank, and associated valves, piping, instrumentation, and controls.

In Appendix A to the LRA, the applicant identified the following intended functions for the CC system based on 10 CFR 54.4(a)(1) and 54.4(a)(2):

Provide containment integrity during a design-basis event.
Provide support as a vital auxiliary for containment spray process fluid cooling (via shutdown cooling heat exchanger) plus high- and low-pressure safety-injection pump cooling.
Provide seismic integrity and protect safety-related components.
Maintain electrical continuity and protect the electrical system.
Maintain the pressure boundary of the system.

The applicant also determined that the following were intended functions of the CC system based on the requirements of 10 CFR 54.4(a)(3):

For post-accident monitoring-- Provide information used to assess the condition of the plant and its environs during and following an accident.
For equipment qualification--Maintain functionality of electrical components as required by 10 CFR 50.49.
For fire protection-- Provide a heat sink for essential shutdown cooling loads to ensure safe shutdown in the event of a fire.
For fire protection-- Provide alternate heat sink via the unaffected unit for essential shutdown cooling loads in the event of a fire in the CC room.

On the basis of the intended functions listed above, the portions of the CC system that are identified by the applicant as within the scope of license renewal include the following equipment types: piping; components (i.e., heat exchangers, pumps, valves, and tanks); supports; instrumentation; and cables that are required for mitigation of design-basis events, for EQ, and for safe shutdown following a fire. The applicant identified a total of 36 device types from within these CC equipment types as being within the scope of license renewal. Of these 36 device types, the applicant noted the following 13 that are subject to an AMR: piping; six valve types (automatic vent, check, control, relief, solenoid, and hand valve); pump/driver assembly; radiation element; temperature element; temperature indicator; temperature indicating controller, and tank. The applicant further indicated that maintenance of the pressure boundary for the liquid in the CC system is the only passive intended function associated with the CC system that is not addressed in one of the commodity evaluations of the LRA. Additionally, the CC heat exchanger is evaluated in the salt water system section (Section 5.16) of Appendix A to the LRA and Section 2.2.3.29 of this SER.

The applicant also indicated that some components in the CC system that are common to many systems have been included in the separate commodity reports, which address those components for the entire plant. Therefore, the following components were not included in the individual system sections:

Structural supports for piping, cables, and components, which are evaluated for the effects of aging in Section 3.1, "Component Supports," of Appendix A to the LRA;
Electrical control and power cabling that is evaluated in Section 6.1, "Cables," of Appendix A to the LRA; and
Instrument tubing and piping and their associated supports, instrument valves and fittings, and the pressure boundaries of the instrument themselves, which are all evaluated in Section 6.4, "Instrument Lines," of Appendix A to the LRA.

2.2.3.14.2 Staff Evaluation

The staff reviewed Section 5.3 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the CC system components and supporting structures within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding the CC system (NRC letter to BGE dated August 11, 1998), and by letters dated November 2 and 12, 1998, the applicant responded to those RAIs.

2.2.3.14.2.1 Component Cooling System Within the Scope of License Renewal

As part of the first step of its evaluation, the staff reviewed portions of the UFSAR, including the system flow diagrams for the CC system, to determine if there were any portions of the system piping and other components that the applicant did not identify as within the scope of license renewal. In the LRA, the applicant identified a number of license renewal interface boundaries within the CC system. On one side of the interface boundary, the system piping and other components are within the scope of license renewal; on the other side of the interface boundary, the piping and other components are outside the scope of license renewal. A license renewal interface boundary usually exists within the system at a point at which non-safety-related portions of the system piping interface with safety-related portions because the non-safety-related portions do not perform any intended functions and the safety-related portions perform at least one intended function. Appropriate isolation capability, which is part of the existing licensing and design basis for the system, is provided at each of the license renewal interfaces. Isolation capability was not reevaluated for license renewal because each of the interfaces is part of the current licensing basis and was previously found acceptable by the staff. However, the staff did verify that the components providing this isolation capability were within the scope of license renewal. Interface boundaries also exist where the CC system interfaces with other systems through various components such as heat exchangers, equipment cooling coils, or head tank fill piping. The staff reviewed all the identified license renewal interface boundaries within the CC system in addition to all the identified interface boundaries with other systems, structures, and components. The staff also reviewed the system flow diagrams to verify that there were no significant interface boundaries that were not identified by the applicant in the LRA. If the portions of the CC system beyond the license renewal interface boundary (i.e., portions of the system that are not within the scope of license renewal) were verified by the staff to have no intended functions, then the components within those portions of the system were also deemed to have no intended function and were eliminated from further consideration. The staff also reviewed the UFSAR to determine if there were any safety-related system functions that were not identified as intended functions in Appendix A to the LRA to verify that no structures and components having intended functions might have been omitted from consideration within the scope of license renewal.

Because of its function as a cooling water supply, the CC system interfaces with 20 other systems, 13 of which are within the scope of license renewal. In Appendix A to the LRA, the applicant indicated that the CC system at the interfaces may or may not be within the scope of license renewal. To help ensure that those portions of the CC system identified as outside the scope of license renewal at these interfaces did not perform any intended functions and, therefore, did not have any components subject to an AMR, the staff requested additional information from the applicant based on the information in the UFSAR and the LRA. In response to NRC Question No. 5.3.1, regarding the system interfaces, the applicant described the interfaces for the seven interfacing systems that were not within the scope of license renewal. Of the seven interfaces, five were adequately separated by normally closed or automatically closing valves (or check valves at some component outlets) that were accepted as adequate separation between safety-related and non-safety-related portions of the system as part of the licensing and design basis. As approved in the current licensing basis, these valves provide acceptable separation between portions of the CC system that are within the scope of license renewal and those portions that are not. Of the other two interfaces, one is the demineralized water makeup line to the head tank, whose failure cannot affect any intended function, and the other is at the gas analyzer sample cooler where the CC system is within the scope of license renewal because the cooler is continuously supplied with CC flow from either Unit 1 or Unit 2. On the basis of the applicant's response and the supporting information in the UFSAR, the staff concludes that those portions of the CC system that are identified as outside the scope of license renewal do not perform any intended functions that would have designated these portions of the system to be within the scope of license renewal.

As described above, the staff reviewed the information presented in Section 5.3 of Appendix A to the LRA and the additional information submitted by the applicant in response to the staff's RAIs. On the basis of that review, the staff finds reasonable assurance that the applicant has appropriately identified the portions of the CC system and the associated structures and components thereof that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.14.2.2 Component Cooling System Subject to an Aging Management Review

In Section 5.3.1.2 of Appendix A to the LRA, the applicant identified which structures and components of the component cooling (CC) system were within the scope of license renewal. The applicant divided those structures and components into device types not subject to an AMR and device types subject to an AMR (listed in Table 5.3-2 in Appendix A to the LRA). The staff reviewed the information submitted by the applicant to verify that the grouping was correct.

Of the 37 device types within the scope of the license renewal rule, 29 device types are electrical/instrumentation components. The staff reviewed the device types that are electrical/instrumentation components to verify that the applicant did not omit electrical/instrumentation components that should be subject to an AMR. Of the 29 components, the applicant classified the following 15 as having only active functions and, therefore, not requiring an AMR:

coil
fuse
power light indicator
pressure indicator
power supply
disconnect link switch
hand switch
480-V ac motor
relay
position indicating lamp
voltage current device
ammeter
125/250-V dc motor
temperature indicating alarm
position switch

One device type, pressure transmitter, is subject to replacement on the basis of a qualified life or specified time period and does not require an AMR.

The following seven device types are evaluated under Sections 2.2.3.32, "Cables"; 2.2.3.33, "Electrical Components"; or 2.2.3.35, "Instrument Lines," of this SER:

level switch
pressure switch
panel
level transmitter
control/power cabling
differential pressure Indicating switch
instrument tubing/valve

The following six electrical/instrumentation components were classified as subject to an AMR (only pressure boundary/body):

control valve
temperature element
radiation element
temperature indicator
solenoid valve
temperature indicating controller

The remaining device types listed in Table 5.3-1 of Appendix A to the LRA, including the piping, check valve, hand valve, pump/drive assembly, relief valve, and tank, were reviewed to verify that the applicant did not omit any components that should be subject to an AMR. The staff found no omissions or mistakes in classification of these components.

The staff agrees with the applicant's determination, which is consistent with10 CFR 54.21(a)(1).

The staff reviewed the information in Section 5.3 of Appendix A to the LRA and additional information submitted by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds reasonable assurance that the applicant has appropriately identified the structures and components subject to an AMR for the CC system to meet the requirements of 10 CFR 54.21(a)(1).

2.2.3.15 Compressed Air System

In Section 5.4, "Compressed Air System," of Appendix A to the LRA, the applicant described the system and the components that are within the scope for license renewal, and identified which of those components are subject to an AMR.

2.2.3.15.1 Summary of Technical Information in Application

As described in the LRA, the compressed air system consists of the instrument air (IA), plant air (PA), and saltwater air (SWA) subsystems for each unit. The IA subsystem is designed to produce a reliable supply of dry and oil-free air for pneumatic instruments and controls and for pneumatically operated containment isolation valves. The PA subsystem is designed to meet necessary service air requirements for plant maintenance and operation. The SWA subsystem provides a backup supply of compressed air to most safety-related air-operated components.

The IA subsystem incorporates two non-safety-related, full-capacity, oil-free compressors, each having a separate inlet filter, aftercooler, and moisture separator. The IA compressors discharge to a single header, which is connected to two air receivers. Both air receivers discharge to a compressed air outlet header, which supplies IA to the air dryers and filter assembly. The compressed air header then divides into branch lines supplying compressed air to the pretreatment and tank-storage area, the intake structure, the service building, the water- treatment area, the turbine building, the containment structure, and the auxiliary building. An emergency backup tie from the PA header automatically supplies air to the IA subsystem if the pressure at the IA filter and dryer assembly falls below a preset value. The PA service header isolation valves also automatically shut if the pressure falls below a set value so the PA compressors discharge only to the IA subsystem.

The PA system consists of one non-safety-related, full-capacity PA compressor with an inlet filter, aftercooler, and moisture separator that discharges to the PA air receiver. The receiver outlet header is connected to the prefilter assembly, which is followed by an outlet header. The outlet header branches into two separate air headers--one that supplies the IA dryers and filter assembly through a cross-connect that is normally isolated, and the other that supplies the PA subsystem loads via the PA service header. A system cross-tie between the Unit 1 and Unit 2 PA subsystems has been provided for the PA headers.

A continuous supply of IA is provided to hold various pneumatically operated valve actuators in the positions necessary for plant operating conditions. Under normal operating conditions, one IA compressor operates and the second IA compressor remains on automatic standby. The PA subsystem is normally cross-connected between units, with one PA compressor operating and supplying both units' loads, and the other PA compressor in standby. The power supply for the air compressors is the normal distribution system and it can be backed up by the EDGs. Accumulators are located at various locations throughout the plant and act as safety reservoirs and also reduce system pressure pulsations.

In the event that the IA and PA compressors become unavailable, such as following load shedding due to a safety injection actuation signal (SIAS), two safety-related SWA compressors will provide a backup supply of compressed air to most safety-related components. These compressors are automatically started upon receipt of a SIAS and can also be operated from a local panel. The SWA compressors supply the SWA header that distributes air to all saltwater (SW) isolation valves for the service water heat exchangers, component cooling heat exchangers, and the emergency core cooling system pump room air coolers. The SWA header also supplies compressed air to the auxiliary feedwater control valves, containment air-operated control valves, atmospheric dump valves, reactor coolant sample isolation valves, and service water containment air cooler valves.

The applicant indicated that the compressed air system has an interface with the service water system (Section 5.17 of Appendix A to the LRA), which supplies cooling water to the IA and PA compressors and aftercoolers. The compressed air system also has interfaces with the many systems that have components being supplied with compressed air. Any local air set or accumulator associated with a specific load is typically included (for license renewal purposes) within the boundaries of the system being supplied.

The compressed air system is within the scope of license renewal based on 10 CFR 54.4(a). In Appendix A to the LRA, the applicant identified the following intended functions for the compressed air system based on 10 CFR 54.4(a)(1) and 54.4(a)(2):

Provide a vital auxiliary air supply, via the saltwater air subsystem, for components used to mitigate design-basis events.
Provide a vital auxiliary air supply, via the auxiliary feedwater air subsystem, for components used to mitigate design-basis events.
Provide a vital auxiliary air supply, via the containment-air subsystem, for components used to mitigate design-basis events.
Provide a load shed indication.
Provide containment isolation during a design-basis event.
Maintain the pressure boundary for the system liquid or gas or both.
Maintain electrical continuity or provide protection or both of the electrical system.
Provide seismic integrity or protection or both of safety-related components.

The applicant also determined that the following were intended functions of the compressed air system based on the requirements of 10 CFR 54.4(a)(3):

For environmental qualification -- Maintain functionality of electrical components as addressed by the Equipment Qualification (EQ) Program.
For fire protection -- Supply compressed air to essential loads to ensure safe shutdown in the event of a fire.

The applicant also noted that all components of the compressed air system that are within the scope of license renewal under Section 54.4(a)(3) ( because they require environmental qualification) are also safety-related. Some of the components relied on to demonstrate compliance with fire protection requirements (10 CFR 50.48) are not safety-related, and are identified as within the scope of license renewal based only on the criteria of 10 CFR 54.4(a)(3). The applicant also noted that all components of the compressed air system that support the 10 intended functions identified above, with the exception of the fire protection function, are safety-related and seismic Category I.

On the basis of the 10 intended functions listed above, the portion of the compressed air system that is identified by the applicant as within the scope of license renewal includes all safety-related components in the system (electrical, mechanical, and instrument) and their supports. Safety-related portions of the compressed air system include those that support the 10 intended functions listed above for meeting the requirements of 10 CFR 54.4(a)(1) and 54.4(a)(2), and the EQ-intended function in accordance with the requirements of 10 CFR 54.4(a)(3).

Also identified by the applicant as within the scope of license renewal are certain non-safety-related portions of the compressed air system required for fire protection in 10 CFR 54.4(a)(3). Included are those portions of the system that supply air to components required to achieve safe shutdown in the event of a postulated fire, as required by 10 CFR Part 50, Appendix R. Each of the compressed air system compressors, that is, IA, PA, and SWA compressors, supports the fire protection intended function because they are relied on in postulated fire scenarios. Essential safe-shutdown loads, which may be supplied with compressed air from either the safety-related or non-safety-related portions of the system in the event of a fire include service water valves, main steam isolation valves, EDGs, saltwater valves, component cooling valves, safety injection valves, and containment spray valves. However, all of the non-safety-related portions of the compressed air system subject to an AMR are evaluated in the fire protection evaluation in Section 5.10 of the LRA.

In Appendix A to the LRA, the applicant identified a total of 29 device types within the safety-related portions of the compressed air system as being within the scope of license renewal. Of these 29 device types, the applicant identified 10 that are subject to an AMR. The 10 device types are piping; six valve types (check, control relief, pressure control, motor-operated and hand valve); air accumulator; filter; and pump (air amplifier). For the air-accumulator device type, the applicant identified that safety-related components that are integral to the skid-mounted SWA compressors are excluded. For the hand valve device type, the applicant noted that instrument line manual drain, equalization, and isolation valves in the compressed air system that are subject to an AMR are evaluated for the effects of aging in the Instrument Lines Commodity Evaluation in Section 6.4 of Appendix A to the LRA, and instrument line manual root valves are evaluated in Section 5.4 of Appendix A to the LRA. With regard to piping type, the applicant noted that all tubing and tubing supports are also evaluated in Section 6.4, "Instrument Lines," of Appendix A to the LRA. Lastly, the applicant noted that many pressure control valves, regulating valves, and reducing valves in the compressed air system do not have unique identifiers in the plant's Master Equipment List. These valves are also reviewed in the Instrument Lines Commodity Evaluation in Section 6.4 of Appendix A to the LRA. The applicant further indicated that maintenance of the pressure boundary of the compressed air system is the only passive intended function associated with the system that is not addressed in one of the commodity evaluations of the LRA.

As identified by the applicant, some components in the compressed air system are common to many systems and, therefore, have been included in the separate commodity report sections, which address those components for the entire plant. Hence, the following common components were not included in the individual system section for compressed air:

Structural supports for piping, cables, and components that are evaluated for the effects of aging in Section 3.1 of Appendix A to the LRA.
Electrical instrumentation, control, and power cabling, which is evaluated in Section 6.1, "Cables," of Appendix A to the LRA. This commodity evaluation completely addresses the passive intended function titled "maintain electrical continuity and/or provide protection of the electrical system" for the compressed air system.
Instrument tubing and piping and the associated supports, instrument valves and fittings (generally everything from the outlet of the final root valve up to and including the instrument), and the pressure boundaries of the instrument themselves, which are all evaluated in Section 6.4 of Appendix A to the LRA.
Also, as noted above, all tubing and many pressure control valves, regulating valves, and pressure-reducing valves without unique identifiers are evaluated in Section 6.4 of Appendix A to the LRA.

2.2.3.15.2 Staff Evaluation

The staff reviewed Section 5.4 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the compressed air system components and supporting structures are within the scope of license renewal in accordance with the requirements in 10 CFR 54.4, and subject to an AMR in accordance with the requirements in 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding the compressed air system (NRC letters to BGE dated August 21 and September 24, 1998), and by letter dated November 2, 1998, the applicant responded to those RAIs.

2.2.3.15.2.1 Compressed Air System Within the Scope of License Renewal

As part of the first step of its evaluation, the staff reviewed portions of the UFSAR, including the flow diagrams for the compressed air system, to determine if there were any portions of the system piping and other components that the applicant did not identify as within the scope of license renewal. In the LRA, the applicant identified that the compressed air system has an interface with the service water system, which provides cooling water to the IA and PA compressors and aftercoolers. The service water system is within the scope of license renewal and is addressed in Section 5.17, "Service Water System," of Appendix A to the LRA and Section 2.2.3.17 of this SER. The compressed air system also interfaces with many systems that have components being supplied with compressed air. Any local air set or accumulator associated with a specific load is typically included within the license renewal boundaries of the system being supplied with the compressed air. The staff reviewed all the identified license renewal interface boundaries within the compressed air system in addition to all the identified interface boundaries with other systems, structures, and components. The staff also reviewed the system flow diagrams to verify that there were no significant interface boundaries that were not identified by the applicant in the LRA. If the portions of the compressed air system beyond the license renewal interface boundary (i.e., portions of the system that are not within the scope of license renewal) were verified by the staff to have no intended functions, then the components within those portions of the system were also deemed to have no intended function and were eliminated from further consideration. The staff also reviewed the UFSAR to determine if there were any safety-related system functions that were not identified as intended functions in the LRA to determine if there were any structures and components having intended functions that may have been omitted from consideration within the scope of the rule.

Many of the components of the compressed air system that are within the scope of license renewal are addressed either in the commodity report sections of the LRA, or in the sections that evaluate the individual systems that are within the scope of license renewal and require the use of compressed air. As a test to determine if the applicant omitted a component from its list of components that are within the scope of license renewal, the staff requested (NRC Question No. 5.4.4) that the applicant clarify what equipment comprised the auxiliary feedwater (AFW) air subsystem and the containment air subsystem. In the LRA, it was not clear whether these two subsystems were separate air systems with their own air compressors or were part of the IA or PA system. The applicant's response clarified that the AFW air system is a grouping of safety-related components dedicated to supplying air to certain safety-related valves required for the operation of the AFW system, and that the containment air subsystem is a grouping of safety-related components dedicated to supplying air to certain safety-related valves inside the containment. The components and associated supporting structures for both these subsystems are within the scope of license renewal. In response to NRC Question No. 5.4.2, the applicant also stated that there are no pressure-retaining components in the compressed air system whose failure would result in loss of system pressure that are not within the scope of license renewal. Because the specific license renewal interface points were not depicted on a simplified drawing in the LRA as was done for the other LRA system sections, the staff asked the applicant to more clearly define the interface points to help assess what portions of the compressed air system were within the scope of license renewal. In its response to NRC Question No. 5.4.1, the applicant presented a simplified drawing of the compressed air system, which clearly defined that essentially all of the compressed air system was within the scope of license renewal and is included in an AMR either in Section 5.4 of Appendix A to the LRA or in one of the commodity report evaluation sections.

As described above, the staff reviewed the information presented in Section 5.4 of Appendix A to the LRA and the additional information provided by the applicant in response to the staff's RAIs. On the basis of that review and upon the applicant's response to the staffs' RAIs, the staff finds reasonable assurance that the applicant has appropriately identified the portions of the compressed air system, and the associated structures and components thereof, that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.15.2.2 Compressed Air System Subject to an Aging Management Review

In Section 5.4.1.2 of Appendix A to the LRA, the applicant identified which structures and components of the compressed air system are within the scope of the license renewal. The applicant divided those structures and components into device types not subject to an AMR and device types subject to an AMR (listed in Table 5.4-1 of Appendix A to the LRA). The staff reviewed the information to verify that the applicant's grouping was correct.

The staff reviewed the information in Table 5.4-1 Appendix A to the LRA and verified that the applicant identified all components that are subject to an AMR. Of 30 device types within the scope of the license renewal rule, 19 are electrical/instrumentation components. The staff reviewed these device types to verify that the applicant did not omit any electrical/instrumentation components that should be subject to an AMR. Of the 19 components, the applicant classified the following 9 as having only active functions and, therefore, not requiring an AMR:

coil
motor
power lamp indicator
fuse
position-indicating lamp
relay
hand switch
position switch
indicating lamp

The staff agrees with the applicant's determination that these 9 electrical/instrumentation components require moving parts or a change in configuration or properties to perform their intended functions.

One device type, solenoid valve, is subject to a replacement based on a qualified life or specified time period and does not require an AMR. The basis for excluding solenoid valves from an AMR is valid provided that the valve bodies are also replaced, rather than refurbished, because the valve body may have a pressure-retaining function, like that described for many of the other systems. Alternatively, the pressure boundary provided by the valve body may not be relied upon for the system intended functions, as is described for the safety injection system in Section 2.2.3.28.1 of this SER. Verification of the appropriate exclusion basis for solenoid valves in the compressed air system and the containment spray system was Confirmatory Item 2.2.3.17.2.2-1 in the previous SER.

In the July 2, 1999 letter, the applicant stated that the solenoid valves in the compressed air system are replaced based on a qualified life that is less than 40 years. Because the applicant now provides the appropriate exclusion basis from an AMR for solenoid valves in the compressed air system, Confirmatory Item 2.2.3.17.2.2-1 is closed.

Two device types, level switch and temperature switch, do not require an AMR because of specific exclusion by the license renewal rule under 10 CFR 54.21(a)(1)(i), that is, all components included with the air compressors.

The following five device types are evaluated in Section 2.2.3.32, "Cables,"; Section 2.2.3.33, "Electrical Commodities"; or Section 2.2.3.35, "Instrumentation Line," of this SER:

control/power cabling
pressure indicator
instrument tubing/valve
pressure switch
panel

The two electrical/instrumentation components remaining, control valve and MOV, were determined by the applicant to be subject to an AMR (only pressure boundary/body). The staff also agrees with the applicant's determination that control valves and MOVs perform only the pressure boundary intended function without moving parts or without a change in configuration or properties.

The staff also reviewed the non-electrical components in the compressed air system in order to verify that the applicant identified all the structures and components subject to an AMR. Of the 11 non-electrical components, the applicant correctly identified drain traps and air compressors as not requiring an AMR because of specific exclusion by the license renewal rule under 10 CFR 54.21(a)(1)(i). The applicant evaluated structural supports for piping, cabling, and other components in Section 3.1 of Appendix A to the LRA. The eight non-electrical component types remaining, air accumulators, compressed air system piping, check valves, filters, hand valves, PCVs, pumps and relief valves were determined by the applicant to be subject to an AMR. The staff found no additional structures and components requiring an aging management review. The staff also agrees with the applicant's determination that these components perform only the pressure boundary intended function without moving parts or without a change in configuration or properties.

On the basis of this evaluation, the staff finds reasonable assurance that the applicant has appropriately identified all the structures and components for the compressed air system that are subject to an AMR in accordance with the requirements in 10 CFR 54.21(a)(1).

2.2.3.16 Containment Isolation Group

In Section 5.5, "Containment Isolation Group," of Appendix A to the LRA, the applicant described portions of the containment isolation group and the components therein that are within the scope of license renewal, and identified which of those components are subject to an AMR.

2.2.3.16.1 Summary of Technical Information in the Application

As described in Appendix A to the LRA, numerous systems have a containment isolation function and, therefore, have containment isolation valves, containment penetrations, and associated piping and test connections. The components that perform the containment isolation function in systems that are evaluated in other sections of the LRA are included within those sections. Containment isolation valves are designed to ensure leak-tightness and reliability of operation.

In Appendix A to the LRA, the applicant identified the following intended functions for the containment isolation group based on 10 CFR 54.4(a)(1) and 54.4(a)(2):

Provide containment isolation;
Maintain electrical continuity and provide protection of the electrical system; and
Maintain the pressure boundary of the system (liquid or gas or both).

The applicant also determined the following intended function of the containment isolation group based on the requirements of 10 CFR 54.4(a)(3):

For equipment qualification

Maintain functionality of electrical components as addressed by the equipment qualification (EQ) program
Provide information used to assess the condition of the plant and its environs during and following an accident; and
Provide containment isolation valve position indication.

On the basis of the intended functions stated above, the portion of the containment isolation group that is identified by the applicant as within the scope of license renewal includes all safety-related components (electrical, mechanical, and instrument) and their supports making up the containment penetration pressure boundary. Also included are the safety-related components (electrical, mechanical, and instrument) and their supports associated with the waste gas decay tank pressure boundary. The applicant identified 10 device types as being within the scope of license renewal for the containment isolation group. The applicant identified all 10 device types as subject to an AMR. Eight of the device types are piping (Class HB and HC); five valve types (check, control, relief, motor operated, and hand valve), and tank. The applicant also indicated that the remaining two device types (level switch and pressure transmitter) were evaluated in the Instrument Line and Commodity Evaluation in Section 6.4 of Appendix A to the LRA.

2.2.3.16.2 Staff Evaluation

The staff reviewed Section 5.5 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the containment isolation components and supporting structures within the scope of license renewal in accordance

with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding the containment isolation group (NRC letter dated September 2, 1998), and by letter dated November 12, 1998, the applicant responded to the RAIs.

2.2.3.16.2.1 Containment Isolation Group Within the Scope of License Renewal

The staff reviewed Section 5.2, "Isolation System," of the UFSAR and compared the description of the structures, systems, and components in the UFSAR to the description in the application to determine if there were any additional portions of the system piping and other components that the applicant should have identified as within the scope of license renewal. The plant's containment isolation valves are listed in Table 5-3 of the UFSAR. Because some of the valves and their associated components that perform the containment isolation function are evaluated in other sections of Appendix A to the LRA, the staff asked the applicant (NRC Question 5.5.1) to clarify whether all the containment isolation valves listed in Table 5-3 of the UFSAR are subject to an AMR. In response to NRC Question No. 5.5.1, the applicant stated that all the containment isolation valves listed in Table 5-3 are subject to an AMR. In addition, the applicant provided a cross-reference, which showed where each penetration in Table 5-3 was evaluated in the LRA. The staff also reviewed Section 5.2 of the UFSAR to determine if there were any safety-related functions that were not identified as intended functions in Appendix A to the LRA to determine if there were any structures and components having intended functions that might have been omitted from consideration within the scope of license renewal. The staff found no omissions and therefore, concluded there is reasonable assurance that the applicant adequately identified those portions of the containment isolation system and its associated (supporting) structures and components that fall within the scope of license renewal in accordance with 10 CFR Part 54.

As described above, the staff has reviewed the information in Section 5.5 of Appendix A to the LRA and the additional information sent by the applicant in response to the staff's RAI. On the basis of that review, the staff finds reasonable assurance that the applicant has appropriately identified the portions of the containment isolation system and the associated structures and components thereof that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.16.2.2 Containment Isolation Group Subject to an Aging Management Review

The staff reviewed the 10 devices identified in Section 5.5 of Appendix A to the LRA and finds that the containment isolation group valves (except for the valve body), level switch, and pressure transmitter have active functions and are subject to existing testing or inspection programs, as well as to repair or replacement. Pursuant to 10 CFR 54.21(a)(1)(i), these components are not subject to an AMR; hence, they are not required to be reviewed in aging management programs.

Pursuant to 10 CFR 54.21(a)(1)(i), the containment isolation group piping, component supports, tank, certain electrical controls, and power cabling are subject to an AMR because they perform an intended safety function without moving parts, or without a change in configuration or properties.

As described above, the staff has reviewed the information concerning system level scoping and component level scoping in Section 5.5 of Appendix A to the LRA and additional information submitted by the applicant in response to the staff's RAI. On the basis of that review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the structures and components for the containment isolation group subject to an AMR in accordance with the requirements in 10 CFR 54.21(a)(1).

2.2.3.17 Containment Spray System

In Section 5.6, "Containment Spray (CS) System" of Appendix A to the LRA, the applicant described portions of the CS system and the components therein that are within the scope of license renewal, and identified which of those components are subject to an AMR.

2.2.3.17.1 Summary of Technical Information in the Application

As described in Appendix A to the LRA, the CS system is designed to limit the pressure and temperature of the containment atmosphere so the associated design limits are not exceeded following design-basis events (DBEs). This is accomplished by spraying borated water into the containment atmosphere. The CS system is also utilized to remove heat from the reactor coolant system (RCS) during plant cooldown and to maintain the RCS temperature during plant shutdown. The CS system for each unit consists of two electric-motor-driven pumps, two shutdown cooling heat exchangers, two CS headers, and associated valves, piping, instrumentation, and controls.

In Appendix A to the LRA, the applicant identified the following intended functions for the CS system based on 10 CFR 54.4(a)(1) and 54.4(a)(2):

Provide containment pressure control and cooling;
Provide containment isolation;
Maintain electrical continuity and provide protection or both of the electrical system;
Maintain the pressure boundary of the system; and
Restrict flow to a specified value in support of the DBE response.

The applicant also determined that the following were intended functions of the CS system based on the requirements of 10 CFR 54.4(a)(3):

For post-accident monitoring -- Provide information used to assess the conditions of the plant and its environs during and following an accident;
For equipment qualification -- Maintain functionality of electrical components as addressed by the EQ program; and
For fire protection -- Provide RCS heat removal to ensure safe shutdown.

On the basis of the intended functions stated above, the portion of the CS system that is identified by the applicant as within the scope of license renewal includes all components (electrical, mechanical, and instrument) and their supports along the shutdown cooling, minimum-flow recirculation, and injection flowpaths as shown on Figure 5.6-1 of Appendix A to the LRA. The applicant identified a total of 33 device types from within the CS system as being within the scope of license renewal. Of these 33 device types, the applicant identified 13 that are subject to an AMR. The 13 device types are Class "GC" and "HC" piping (including spray nozzles), five valve types (motor operated, check, control, relief, and hand valve), pump/driver assembly, flow element, temperature element, temperature indicator, and flow orifice.

The applicant also indicated that some components in the CS system that are common to many systems have been discussed in the separate commodity reports that address those components for the entire plant. Therefore, the following components were not discussed in the individual system sections:

Structural supports for piping, cables, and components that are evaluated for the effects of aging in Section 3.1 of Appendix A to the LRA, except for the shutdown cooling heat exchanger supports that are addressed in Section 5.6 of Appendix A to the LRA;
Electrical control and power cabling, which is evaluated in Section 6.1 of Appendix A to the LRA; and
Instrument tubing and piping and their associated supports, instrument valves and fittings, and the pressure boundaries of the instruments themselves, which are all evaluated in Section 6.4 of Appendix A to the LRA.

2.2.3.17.2 Staff Evaluation

The staff reviewed Section 5.6 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the CS system components and supporting structures within the scope of license renewal in 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding the CS system (NRC letter dated September 2, 1998), and by letter dated November 4, 1998, the applicant responded to those RAIs.

2.2.3.17.2.1 Containment Spray System Within the Scope of License Renewal

The staff reviewed portions of the UFSAR, including Section 6.4, "Containment Spray System," to determine if there were any portions of the system piping and other components that the applicant should have identified as within the scope of license renewal. In Appendix A to the LRA, the applicant identified a number of license renewal interface boundaries within the CS system. On one side of the interface boundary, the system piping and other components are within the scope of license renewal; on the other side of the interface boundary, the piping and other components are not within the scope of license renewal. A license renewal interface boundary usually exists within the system at a point where non-safety-related portions of the system piping interface with safety-related portions because the non-safety-related portions do not perform any intended functions and the safety-related portions perform at least one intended function. Appropriate isolation capability, which is part of the existing licensing and design basis for the system, is provided at each of the license renewal interfaces. Isolation capability was not reevaluated for license renewal because each of the interfaces is part of the current licensing basis and was previously found acceptable by the staff. Interface boundaries also exist where the CS system interfaces with other systems through various components such as heat exchangers, equipment cooling coils, or head tank fill piping. The staff reviewed all the identified license renewal interface boundaries within the CS system in addition to all the identified interface boundaries with other systems, structures, and components. The staff also reviewed the flow diagrams for the safety injection and containment spray systems (UFSAR Figures 6-1 and 6-10) to verify that there were no interface boundaries that were not identified by the applicant in the LRA. If the portions of the CS system beyond the license renewal interface boundary (i.e., portions of the system that are not within the scope of license renewal) were verified by the staff to have no applicable intended functions, then the components within those portions of the system were eliminated from further consideration.

The staff also reviewed the UFSAR to determine if there were any safety-related system functions that were not identified in Appendix A to the LRA to determine if there were any structures and components that might have been omitted from consideration within the scope of license renewal. The staff found that the applicant had not omitted any interface boundaries and intended functions (refer to detailed discussion in next paragraph), and therefore, concluded there is reasonable assurance that the applicant adequately identified those portions of the CS system and its associated (supporting) structures and components that fall within the scope of license renewal in accordance with 10 CFR Part 54.

To help ensure that those portions of the CS system identified as not within the scope of license renewal at these interfaces did not perform any intended functions and, therefore, did not have any components subject to an AMR, the staff requested additional information from the applicant based on the information in the UFSAR and the LRA. Section 6.4.2 of the UFSAR states that the containment spray is expected to be effective in removing fission products from the containment atmosphere. NRC Question No. 5.6.1 asked why this intended function was not included as part of the system description or the scoping results. In response, the applicant stated that this active function performed by the CS system was inadvertently omitted. The applicant further stated that this omission would not affect the AMR results since, as an active function, the CS components that accomplish the active function are not required to be evaluated as stated in 10 CFR 54.21(a)(1)(i). The staff believes that two passive components that support this active function, the trisodium phosphate baskets and the containment sump, are necessary for the CS system to perform the fission-product removal function. The trisodium phosphate baskets were identified as subject to an AMR (Table 3.3A-1 of Appendix A to the LRA). The containment sump is included within the scope of license renewal (Figure 5.15-1 in Appendix A to the LRA) and is subject to an AMR (Table 3.3A-1 of Appendix A to the LRA). Therefore, the staff finds that the SCs required to support this intended function have been adequately dispositioned.

In response to NRC Question No. 5.6.4, regarding exclusion of the non-safety-related emergency dousing function of the CS system from the scope of license renewal, the applicant referenced Section 6.7.2 of the UFSAR. This section explains that the CS system is capable of dousing the charcoal filters in the iodine removal units. Although not specifically mentioned in Section 5.6.1.2 and Table 5.6-1 of Appendix A to the LRA, the applicant confirmed that the containment spray nozzles are clearly shown as within the scope of license renewal in Figure 5.6-1 of Appendix A to the LRA. The CS system supplies spray water to the iodine removal units via piping, valves, and nozzles downstream of normally shut isolation valves. The primary purpose of the dousing system is to cool the charcoal, should overheating occur during their use following a design-basis accident. Open Item 2.2.3.17.2.1-1 questioned whether this ability to provide fire protection was required by 10 CFR 50.48.

In the July 2, 1999, response to Open Item 2.2.3.17.2.1-1, the applicant stated that it performed an analysis supporting a 10 CFR 50.59 evaluation (Log No. 90-B-061-086-R2, dated December 4, 1990). The analysis showed that the maximum post-LOCA charcoal bed temperature would not cause iodine desorption or charcoal bed ignition. This resulted in a plant modification, which isolated the emergency dousing system from service in modes 1 through 4. Manual valves may be opened in modes 5 and 6, so that the dousing system is available to provide fire protection during maintenance activities. The applicant removed the charcoal filter dousing system from the CCNPP Fire Hazards Analysis (FHA) on June 4, 1997. This is consistent with the guidance of Section F.1(a) of Appendix A to Branch Technical Position (BTP) APCSB 9.5-1, which states that fire suppression systems should be provided based on the FHA. Furthermore, the BTP does not specify an automatic fixed suppression system for the charcoal filter unless there is a hazard that could jeopardize safe plant shutdown.

Therefore, the emergency dousing system is not within the scope of license renewal on the basis that the emergency dousing function of the CS system is not credited as part of the current licensing basis for meeting the requirements of 10 CFR 50.48 in accordance with the guidance of Appendix A to BTP APCSB 9.5-1. Therefore, the staff concludes that the emergency dousing system piping, valves, and nozzles downstream of the normally shut isolation valves are not within the scope of license renewal and Open Item 2.2.3.17.2.1-1 is closed.

As described above, the staff has reviewed the information in Section 5.6 of Appendix A to the LRA and the additional information submitted by the applicant in response to the staff's RAIs. On the basis of that review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the portions of the CS system and the associated structures and components thereof that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.17.2.2 Containment Spray System Subject to an Aging Management Review

In Section 5.6.1.2 of Appendix A to the LRA, the applicant identified the structures and components of the CS system that are within the scope of the license renewal. The applicant divided those structures and components into device types not subject to an AMR and device-types subject to an AMR (listed in Table 5.6-1 of Appendix A to the LRA). The staff reviewed the information submitted by the applicant to verify that the grouping was correct.

The applicant has used the following CS system functions as a basis for determining whether or not components are subject to an AMR:

To maintain electrical continuity and/or provide protection of the electrical system,
To maintain the pressure boundary of the system (liquid and/or gas), and
To restrict flow to specified value in support of the design-basis earthquake response.

The staff finds this methodology acceptable because it should result in the appropriate components identified for an AMR.

Of the device types within the scope of the license renewal rule, 27 device types are electrical/instrumentation components. The staff reviewed the device types that are electrical/instrumentation components to verify that the applicant did not omit electrical/instrumentation components that should be subject to an AMR.

Of the 27 components, the applicant classified the following 17 as having only active functions and, therefore, not requiring an AMR:

coil
flow indicator
hand switch
power lamp indicator
MOV operator
position indicating lamp
control valve operator
fuse
current/pneumatic device
4-kV motor
relay
position switch
voltage current device
hand indicator controller
ammeter
125/250-V dc motor
solenoid valve

The following five device-types are evaluated in Section 2.2.3.32, "Cables," or Section 2.2.3.35, "Instrumentation Line," of this SER:

flow transmitter
pressure switch
pressure transmitter
control/power cabling
instrument tubing/valves

The following five electrical/instrumentation components evaluated in this section were classified as subject to an AMR (only pressure boundary/body):

control valve
flow element
MOV
temperature element
temperature indicator

The remaining device types listed in Table 5.6-1, including the piping, hand valve, heat exchanger, pump/drive assembly, relief valve, and check valve, were reviewed to verify that the applicant did not omit components that should be subject to an AMR. The staff finds no omissions or mistakes in classification of these components. On the basis of the applicant's reasoning, the staff agrees with the applicant's determination, which is consistent with 10 CFR 54.21(a)(1), except for solenoid valves.

The basis for excluding solenoid valves from an AMR may be valid provided that the pressure boundary provided by the valve body is not relied upon for the system intended functions, as is described for the safety injection system in Section 2.2.3.28.1 of this SER. The solenoid valve pressure boundary function has been properly included in the scope of the AMR for other systems (for example, reactor coolant system in Section 2.2.3.9.2.2). Verification of the appropriate exclusion basis for solenoid valves in the containment spray system and the compressed air system (see Section 2.2.3.15.2.2) was identified as Confirmatory Item 2.2.3.17.2.2-1 in the previous SER.

In the July 2, 1999 letter, the applicant stated that the bodies of the solenoid valves in the containment spray system do not perform a pressure boundary intended function, i.e., they do not form part of the pressure boundary for the CS system. Because the applicant now provides the appropriate exclusion basis from an AMR for solenoid valves in the containment spray system, Confirmatory Item 2.2.3.17.2.2-1 is closed.

The staff has reviewed the information submitted in Section 5.6 of Appendix A to the LRA and additional information submitted by the applicant in response to the staff's RAIs. On the basis of its review, the staff finds that there is a reasonable assurance that the applicant has appropriately identified the structures and components for the CS system subject to an AMR in accordance with the requirements in 10 CFR 54.21(a)(1).

2.2.3.18 Diesel Fuel Oil System

In Section 5.7, "Diesel Fuel Oil (DFO) System," of Appendix A to the LRA, the applicant described the DFO system and the DFO system components that are within the scope for license renewal, and identified which of those components are subject to an AMR.

2.2.3.18.1 Summary of Technical Information in the Application

The DFO system provides a reliable source of fuel oil to the emergency diesel generators (EDGs), the auxiliary heating boiler, the SBO generator, and the diesel-driven fire pump. The DFO system for the three EDGs consists of two (Nos. 11 and 21) seismic Category I, above-ground fuel oil storage tanks (FOSTs) and associated piping and valves. The pumps that transfer the fuel oil from the tanks to the EDGs are within the scope of license renewal, but they are addressed in the EDG system section (Section 5.8) of Appendix A to the LRA and evaluated in Section 2.2.5.8 of this SER. As a result of the system level scoping, the applicant identified that, pursuant to 10 CFR 54.4(a), the portions of the DFO system that are within the scope of license renewal include all components (electrical, mechanical, and instrument) and their supports, from the unloading station to the FOSTs, the FOSTs, supply headers, including cross-connects, and piping to just upstream of the Y-strainer installed in the suction pipe to the DFO transfer pumps. The fuel oil transfer pump suction line, transfer pumps, and the day tanks are evaluated as part of the EDG system in Section 2.2.5.8 of this SER. The application described all the intended functions of the DFO system that were determined necessary for license renewal based on the requirements of 10 CFR 54.4. The DFO system is within the scope of license renewal based on 10 CFR 54.4(a). The applicant identified the following intended functions of the DFO system based on 10 CFR 54.4(a)(1):

Provide vital auxiliary function to the power distribution system by supplying fuel oil to the EDGs during design-basis events.
Maintain the pressure boundary of the system.

The applicant also identified the following intended function of the DFO system based on the requirements of 10 CFR 54.4(a)(3):

For fire protection -- Provide essential fuel oil to EDGs and the diesel fire pump to ensure safe shutdown in the event of a postulated fire (includes isolation of nonessential auxiliary boiler and SBO DFO).

On the basis of the three intended functions listed above, the applicant identified 13 device types in the DFO system that have at least one intended function and, therefore, are within the scope of license renewal. Of these 13 device types, the applicant identified four that are subject to an AMR and not otherwise addressed in one of the commodity reports. These four device types are above-ground and underground piping, check valves, hand valves, and the FOSTs. The applicant also identified that maintenance of the pressure boundary is the only passive intended function associated with the DFO system that is not addressed by one of the commodity evaluations of Appendix A to the LRA.

The applicant indicated that some components in the DFO system that are common to many systems have been included in the separate commodity reports which address those components for the entire plant. Therefore, the following components were not included in the sections on individual systems:

Structural supports for piping, cables, and components, which are evaluated for the effects of aging in Section 3.1, "Component Supports," of Appendix A to the LRA.
Electrical control and power cabling, which is evaluated in Section 6.1, "Cables," of Appendix A to the LRA.
Instrument tubing and piping and their associated supports, instrument valves and fittings, and the pressure boundaries of the instrument themselves, which are all evaluated in Section 6.4, "Instrument Lines," of Appendix A to the LRA.

2.2.3.18.2 Staff Evaluation

The staff reviewed Section 5.7 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the DFO system components within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR to meet the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding the DFO system (NRC letter to BGE dated February 13, 1998), and by letter dated July 30, 1998, the applicant responded to those RAIs.

2.2.3.18.2.1 Diesel Fuel Oil System Within the Scope of License Renewal

During the first step of its evaluation, the staff reviewed portions of the UFSAR, including the flow diagrams for the DFO system, to determine if there were any portions of the DFO system piping or other components that might perform intended functions that were not described in the LRA. Essentially all portions of the DFO system were determined to perform at least one intended function and, therefore, essentially all portions and components of the DFO system are within the scope of license renewal and are identified as such by the applicant, either in Section 5.7 of Appendix A to the LRA or in other sections of the LRA. The staff reviewed the few remaining components of the DFO system to verify that they do not have any intended functions. The staff also reviewed the UFSAR to determine if there were any additional system functions that were not identified as intended functions in the LRA and verified that those additional functions did not meet the scoping requirements of 10 CFR 54.4.

However, in the LRA, the applicant identified a non-safety-related line from FOST No. 21 to diesel generating room waste oil collecting tank (WOCT) No. 11 as not within the scope of license renewal. The applicant also did not identify or discuss a non-safety-related line from the concrete enclosure of FOST No. 21 that, according to the UFSAR, can be used to supply the EDGs in the event of the FOST's rupture. By letter dated February 19, 1998, the staff asked the applicant (identified as NRC Question No. 3 in the applicant's response) to provide further justification as to why neither of these lines were considered within the scope of license renewal since they appeared to perform the intended function of maintaining the DFO system pressure boundary during some design-basis events. The applicant responded to the RAI by letter dated July 30, 1998, indicating that the line from the FOST enclosure is not relied upon to remain functional during or following any design-basis events. The FOST enclosure is designed to protect the seismic Category I FOST No. 21 from tornado missiles and the FOST is not postulated to rupture as a result of any design-basis event. The applicant also noted that the line to WOCT No. 11 from FOST No. 21 is the FOST overfill line and there is no potential for draining the FOST if the line should rupture. Although the simplified drawing in Section 5.7 of Appendix A to the LRA showed this line coming out the bottom of the tank, it actually comes out near the top. As a result of the staff's review of the applicant's responses, the staff concurred with the applicant that these lines do not perform any intended functions important to license renewal and are not required to be within the scope of license renewal. Thus, the staff did not find any components that were not already identified by the applicant as being within the scope of license renewal.

As described above, the staff has reviewed the information presented in Section 5.7 of Appendix A to the LRA in addition to the information sent by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds reasonable assurance that the applicant has appropriately identified the portions of the DFO system and its associated structures and components (device types) that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.18.2.2 Diesel Fuel Oil System Subject to an Aging Management Review

In Section 5.7.1.2 of Appendix A to the LRA, the applicant identified which structures and components of the diesel fuel oil (DFO) system were within the scope of the license renewal. The applicant divided those structures and components into device types not subject to an AMR and device types subject to an AMR (listed in Table 5.7-1 of Appendix A to the LRA). The staff reviewed all the information submitted by the applicant to verify that the grouping of the DFO system structures and components was correct. As described in detail below, the staff finds reasonable assurance that the applicant has identified all the structures and components for the DFO system that are subject to an AMR in accordance with 10 CFR Part 54.21(a)(1).

The applicant identified 16 device types that need to be considered for an AMR. The staff reviewed all the components within the scope of the rule and verified that all the components were considered in these 16 device types. Of the 16 device types within the scope of the license renewal rule, 9 are electrical/instrumentation components. The staff reviewed the device types that are electrical/instrumentation components to verify that the applicant identified all the components subject to an AMR that perform an intended function without moving parts or without a change in configuration or properties and that are not subject to replacement based on qualified life or specified time period. Of the nine electrical/instrumentation device types, the applicant classified the following six as having only active functions and therefore not requiring an AMR:

fuse
transformer
hand switch
indicating lamp
motor
relay

Three components that include level switches, electrical control and power cabling, and instrument tubing and valves, are evaluated in Section 2.2.3.32, "Cables;" or Section 2.2.3.35, "Instrument Lines" of this SER. No electrical/instrumentation components evaluated in this section were classified as subject to an AMR. The staff agrees with the applicant's determination of active components, which is consistent with 10 CFR 54.21(a)(1).

The staff also reviewed the non-electrical components in the diesel fuel oil system in order to determine whether the applicant has properly identified the structures and components subject to an AMR. The staff reviewed the information in Table 5.7-1 of Appendix A to the LRA to ascertain that the applicant has identified all components that are subject to an AMR.

The staff reviewed the information in Section 5.7.1.3 of Appendix A to the LRA and additional information submitted by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the structures and components in the diesel fuel oil system that are subject to an AMR in accordance with the requirements in 10 CFR 54.21(a)(1).

2.2.3.19 Emergency Diesel Generator System

In Section 5.8, "Emergency Diesel Generator (EDG) System," of Appendix A to the LRA, the applicant described the EDG system, its intended functions, and the associated structures and components of the EDG system that are within the scope of license renewal and identified which of those structures and components are subject to an AMR.

2.2.3.19.1 Summary of Technical Information in the Application

As described in the LRA, the EDGs are designed to provide a dependable onsite power source capable of automatically starting and supplying the essential loads necessary to safely shut down the plant and maintain it in a safe-shutdown condition. Four EDGs (1A, 1B, 2A, and 2B) are provided for the plant, although each unit requires only one EDG to supply the minimum power requirements for its engineered safety features (ESF) equipment. In addition, there is a fifth non-safety-related diesel generator (EDG-0C) that is identified as the SBO diesel generator. EDGs 1B, 2A, and 2B were part of the original plant design and are located in the same seismic Category I structure. EDG 1A and EDG 0C were installed more recently and each is located in its own separate structure. The EDG 1A structure is seismic Category I, but the SBO diesel generator structure is not designed to seismic Category I requirements since the SBO diesel generator is not required to withstand the effects of an earthquake. The auxiliary systems for the four EDGs (1A, 1B, 2A, and 2B) are also designed to seismic Category I requirements, but the SBO diesel generator auxiliaries are not. The auxiliary systems that support the EDGs are diesel fuel oil, lube oil, service water (SRW), starting air, keep-warm systems, instrumentation/controls, and intake and exhaust air.

EDG 1A and EDG 0C were furnished by Societe Alsacienne de Constructions Mechaniques de Mullhouse (SACM) and EDGs 1B, 2A, and 2B were furnished by Fairbanks Morse.

The license renewal rule, 10 CFR Part 54, recognizes that diesel engines and associated generators are active components and excludes them from the group of equipment that is subject to an AMR [10 CFR 54.21(a)(1)(i)]. All auxiliary components supplied as part of the engine and located on the engine skid (on the engine side of the auxiliary subsystem flexible couplings) are considered by the applicant and the staff to be part of the engine for the purposes of license renewal. The applicant stated that the passive, long-lived components associated with the engine auxiliaries outside the skid boundary and electrical equipment are subject to an AMR.

On this basis the boundaries of the EDG system for this license renewal evaluation are:

Diesel Fuel Oil (DFO) System: The boundary between the DFO system [see Section 5.7, "Diesel Fuel Oil System," of Appendix A to the LRA] and the EDG system is just upstream of the Y-strainers installed in the suction pipe to the fuel oil transfer pumps.
Service Water System (SRW): The boundary between the SRW system (LRA Section 5.17) and the EDG system is at the diesel cooler/SRW interface expansion joints (expansion joints are included in the EDG system section) and at the interface of SRW piping with the starting air subsystem air compressor.
4-kV Transformers and Buses System: The boundary between the EDG system and the 4-kV transformers and buses system is at the EDG side of the 4-kV breakers.
Engineered Safety Features Actuation System (ESFAS): The boundary of the EDG system with the ESFAS is at the contact outputs from relay cabinets C67/68 for both Units 1 and 2.

The applicant stated that the following typical components are associated with the EDG auxiliaries outside the skid boundary:

EDG fuel oil day tanks
EDG starting air receivers
EDG fuel oil transfer pumps
EDG drip tanks
EDG drip tank pumps
EDG intake
EDG exhaust mufflers
EDG intake filters

Structures and components of the EDG system are within the scope of license renewal based on 10 CFR 54.4(a). The applicant stated that the following intended functions of the EDG system are based on the requirements of 10 CFR 54.4(a)(1) and 54.4(a)(2):

To provide the vital auxiliary power supply for components used to mitigate design-basis events (DBEs).
To maintain the pressure boundary of the system (liquid or gas or both).
To maintain electrical continuity or protect the electrical system or both.
To maintain mechanical operability or protect the mechanical system or both.
To provide seismic integrity or protect safety-related components or both.

In Appendix A to the LRA, the applicant also identified the following intended function of the EDG system based on the requirements of 10 CFR 54.4(a)(3):

For environmental qualification -- Provide information used to assess the environs and plant conditions during and after an accident.
For fire protection -- to provide vital auxiliary power for components used to ensure safe shutdown in the event of a postulated severe fire.

On the basis of the intended functions listed above, the applicant stated that the portion of the EDG system that is within the scope of license renewal consists of piping, components (e.g., heat exchangers, pumps, valves, and tanks), component supports, and instrumentation and cables supporting operation of the EDGs through the diesel lube oil, diesel fuel oil, diesel starting air, diesel combustion air, and diesel cooling water subsystems. The applicant identified 48 EDG system device types (i.e., component types) of the EDG system that are designated as within the scope of license renewal because they fulfill at least one of the intended functions.

The applicant also stated that some components in the EDG system that are common to many systems have been included in the separate commodity report sections of the LRA which address those components for the entire plant. Therefore, the following components were not included in the individual system sections:

Structural supports for piping, cables, and components, which are evaluated for the effects of aging in Section 3.1, "Component Supports," of Appendix A to the LRA.
Electrical control and power cabling, which is evaluated in Section 6.1, "Cables," of Appendix A to the LRA.
Instrument tubing and piping and the associated supports, instrument valves and fittings, and the pressure boundaries of the instrument themselves, which are all evaluated in Section 6.4, "Instrument Lines," of Appendix A to LRA.

For the new SACM diesel generators, EDG 1A and 0C, the applicant performed a one-time procedure to identify the components that passively support the pressure boundary or Class 1E functions that are also common with the existing Fairbanks Morse EDG components. The components of the SACM diesels were mapped to their corresponding components of the Fairbanks Morse EDGs. The applicant indicated that the mapping procedure gave assurance that all SACM components have been evaluated for an AMR through the evaluation process used for the Fairbanks Morse EDGs. The results of this mapping procedure are summarized below.

Diesel Lube Oil

No plausible aging was identified for any SACM diesel lube oil components.

Diesel Fuel Oil

Plausible aging was identified for the SACM diesel fuel oil tanks, basket strainer, tornado damper, and flame arrestor. In each case the material, environment, and age-related degradation mechanisms (ARDMs) for these SACM components were the same as the material, environment, and ARDMs for the corresponding Fairbanks Morse components.

Diesel Starting Air

No plausible aging was identified for the corresponding SACM diesel starting air components even though plausible aging was identified for the corresponding Fairbanks Morse diesel starting air components. The SACM diesel starting air components are SS and are subject to dry air; the corresponding Fairbanks Morse components are carbon steel and are subject to moist air.

Diesel Combustion Air

Plausible aging was identified for the SACM combustion air intake air filter and piping. In each case, the material, environment, and ARDMs for these SACM components are the same as the material, environment, and ARDMs for the corresponding Fairbanks Morse components. Plausible aging was identified for the SACM combustion air exhaust air muffler and piping. The material, environment, and ARDMs for the SACM exhaust muffler are the same as for the corresponding Fairbanks Morse muffler. The SACM exhaust piping is chromium-molybdenum; the Fairbanks Morse diesel exhaust piping is carbon steel. Therefore, the SACM exhaust piping is subject to a subset of the ARDMs affecting the Fairbanks Morse diesel exhaust piping.

Diesel Cooling Water

Plausible aging was identified for the SACM cooling water piping, tanks, and valves. These SACM components are made of the same material and are subject to the same ARDMs as the corresponding Fairbanks Morse piping, tanks, and valves even though the process fluid is different. The process fluid for the SACM diesel cooling water is a solution of ethylene glycol antifreeze in demineralized water. The process fluid for the Fairbanks Morse jacket cooling water is service water treated with hydrazine. The aging of the SACM radiators is expected to be bounded by the aging of the Fairbanks Morse jacket water cooling system piping.

In the few instances in which there was not a corresponding EDG component for a new SACM component, there were no plausible ARDMs from the material/environment characteristics of the new SACM component. Therefore, for purposes of license renewal, the aging, and thus the management of aging, for the new SACM diesel auxiliary systems are enveloped by the aging and management program for the Fairbanks Morse diesel auxiliary systems. Any aging discovered by the aging management program for the Fairbanks Morse diesels will result in corrective action and a review for applicability to the corresponding SACM auxiliary system.

Of the 48 device types the applicant identified as within the scope of license renewal, the applicant identified 11 that are subject to an AMR. These 11 device types are piping, filter, muffler, drain trap, Y-strainer, relief valve, check valve, hand valve, pump, accumulator, and tank. The applicant further stated that maintenance of the pressure boundary of the liquid or gas or both is the only passive intended function associated with the EDG system not addressed by one of the commodity evaluations in other sections of Appendix A to the LRA.

2.2.3.19.2 Staff Evaluation

The staff reviewed Section 5.8 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified and listed the EDG system components subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review the staff requested additional information regarding the EDG system (NRC letters to BGE dated August 27 and September 24, 1998), and by letter dated November 4, 1998, the applicant responded to those RAIs.

2.2.3.19.2.1 Emergency Diesel Generator System Within the Scope of License Renewal

During the first step of its evaluation, the staff reviewed portions of the UFSAR, including the flow diagrams for the EDG system, to determine if there were any system components that the applicant did not identify as within the scope of license renewal but that were necessary to perform one of the identified intended functions of the EDG system. The staff also reviewed the design basis for the EDG system as described in the UFSAR to determine if there were any additional system functions that were intended functions and, therefore, might require the functioning of components of the EDG system that the applicant did not identify as within the scope of license renewal.

The staff's review of the UFSAR and flow diagrams, which included reviewing the functions of components identified as being outside the scope of license renewal, did not uncover any additional structures or components of the EDG system that should have been within the scope of license renewal. The applicant stated that virtually all of the components of the EDG system are within the scope of license renewal. However, the staff did request additional information via NRC Question No. 5.8.1 to help ensure there were no omissions from the applicant's list of components within the scope of license renewal. Figure 5-8.1 of Appendix A to the LRA is a simplified drawing that identifies the EDG system boundary for the diesel air starting system and appeared, to the staff, to indicate that a check valve upstream (air supply to the receiver) of the air receiver is not within the scope of license renewal. As this check valve appears to be a license renewal interface between the air receiver and the air compressor piping, the staff asked the applicant to clarify whether the check valve is within the scope of license renewal. In its response, the applicant verified that the check valve and the piping between the check valve and the air receiver were within the scope of license renewal.

As a result of its review, the staff also did not identify any additional intended functions that could result in additional components (components not identified by the applicant) being within the scope of license renewal and hence, possibly subject to an AMR.

As described above, the staff has reviewed the EDG system information presented in Section 5.8 of Appendix A to the LRA and the additional information sent by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds that there is reasonable assurance that the applicant has appropriately identified those EDG system structures and components (device types) within the scope of license renewal in accordance with the requirements in 10 CFR 54.4.

2.2.3.19.2.2 Emergency Diesel Generator System Subject to an Aging Management Review

The applicant divided structures and components within the scope of license renewal into device types not subject to an AMR and device types subject to an AMR (listed in Table 5.8-2 of Appendix A to the LRA). The staff reviewed the information to verify that the grouping was correct.

Of the device types within the scope of the license renewal rule, 35 device types were considered to be electrical/instrumentation components. The staff reviewed the device types that are electrical/instrumentation components to verify that the applicant did not omit electrical/instrumentation components within the scope of the rule that should be subject to an AMR. Of the 35 components, the applicant classified the following 28 as having only active functions and, therefore, not requiring an AMR:

annunciator
circuit breaker
control switch
voltage regulator
EDG
isolator
fan
fuse
governor
hand switch
indicator
indicating light
motor
relay
speed controller
speed indicator
speed switch
temperature controller
temperature switch
temperature transmitter
transformer
indicating lamp
position-indicating light
disconnect

The following seven components are evaluated in Section 2.2.3.32, "Cables"; Section 2.2.3.33, "Electrical Commodities"; or Section 2.2.3.35, "Instrument Lines," of this SER.

level indicator
pressure switch
control/power cabling
level switch
pressure indicator
motor control center
instrument tubing/valves

No electrical/instrumentation components evaluated in this section were classified as subject to an AMR. The remaining device types listed in Table 5.8-2 of Appendix A to the LRA, including the piping, filter, muffler, drain trap, Wye strainer, relief valve, check valve, hand valve, pump, accumulator, and tank were reviewed to verify that the applicant did not omit components that should be subject to an AMR. One device type (heat exchanger) is a skid-mounted component on the Fairbanks Morse EDG, and therefore, is not subject to an AMR. On the basis of the applicant's reasoning, the staff agrees with the applicant's determination, which is consistent with 10 CFR 54.21(a)(1).

The staff has reviewed the information submitted in Section 5.8 of Appendix A to the LRA and additional information submitted by the applicant in response to the staff's RAIs. On the basis of its review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the structures and components subject to an AMR for the EDG system in accordance with the requirements in 10 CFR 54.21(a)(1).

2.2.3.20 Feedwater System

In Section 5.9, "Feedwater System (FWS)," of Appendix A to the LRA, the applicant described the portion of the FWS and its associated structures and components that are within the scope of license renewal, and identified which of those structures and components are subject to an AMR.

2.2.3.20.1 Summary of Technical Information in the Application

As described in Appendix A to the LRA, the FWS transfers condensate from the condensate system to the steam generators (SGs), raises the temperature of the feedwater to increase plant efficiency, and controls the rate of flow to the SGs to match the steam flow demand by the plant turbine generators. The major components of the FWS are piping, steam-driven pumps, high-pressure feedwater heaters, regulating valves, isolation valves, and header check valves. Also included are SG secondary-side pressure and level instrumentation loops. This instrumentation provides SG level control information as well as the protective functions of SG isolation and auxiliary feedwater (AFW) initiation.

During the system level scoping evaluation, the applicant identified that the portion of the FWS within the scope of license renewal pursuant to 10 CFR 54.4(a) includes all components (electrical, mechanical, and instrument) and their supports, from the inlet side of the motor-operated feedwater isolation valves to the SG nozzle. Also included are SG secondary-side water level and pressure-indicating instrumentation loops, including the root isolation valves and all downstream components (valves, tubing, instruments). The LRA describes all the intended functions of the FWS that it determined were necessary for license renewal based on the requirements of 10 CFR 54.4.

Structures and components of the FWS are within the scope of license renewal based on 10 CFR 54.4(a). The applicant identified the following intended functions of the FWS based on the requirements of 10 CFR 54.4(a)(1) and 54.4(a)(2):

Provide containment overpressure protection.
Prevent reverse flow from the SG via check valve closure.
Send signals to the engineered features actuation system (ESFAS) and provide SG isolation.
Provide signals to the reactor protective system (RPS).
Provide signals to the auxiliary feedwater actuation system (AFWAS).
Maintain the pressure boundary of the system.
Maintain electrical continuity or protect the electrical system or both.

In Appendix A to the LRA, the applicant also identified the following intended functions of the FWS based on the requirements of 10 CFR 54.4(a)(3):

For fire protection--Monitor steam generator level to support safe shutdown in the event of a postulated severe fire.
For environmental qualification--Maintain functionality of electrical equipment as addressed by the applicant's Environmental Qualification Program, and provide information used to assess the plant and environs condition during and following an accident.
For SBO--Provide steam generator level indication.

On the basis of the intended functions listed above, the applicant identified 20 device types (or component types) in the FWS that were designated as within the scope of license renewal because they fulfill at least one of the intended functions. Of the 20 device types, the applicant identified 5 that are subject to an AMR: piping, check valves, hand valves, motor-operated valves (MOVs), and temperature elements. The applicant further noted that maintenance of the pressure boundary is the only passive intended function associated with the FWS that is not already addressed by one of the commodity evaluations in other sections of Appendix A to the LRA.

The applicant also stated that some components in the FWS that are common to many systems have been included in the separate commodity report sections of the LRA that address those components for the entire plant. Therefore, the following components were not included in the individual system sections:

Structural supports for piping, cables, and components, which are evaluated for the effects of aging in Section 3.1, "Components Supports," of Appendix A to the LRA;
Electrical control and power cabling, which is evaluated in Section 6.1, "Cable," of Appendix A to the LRA; and
Instrument tubing and piping and the associated supports, instrument valves and fittings, and the pressure boundaries of the instrument themselves, which are all evaluated in Section 6.4, "Instrument Lines," of Appendix A to the LRA.

2.2.3.20.2 Staff Evaluation

The staff reviewed Section 5.9 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the FWS components within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding the FWS (NRC letter to BGE dated February 13, 1998), and by letter dated July 30, 1998, the applicant responded to those RAIs.

2.2.3.20.2.1 Feedwater System Within the Scope of License Renewal

During the first step of its evaluation, the staff reviewed portions of the UFSAR, including the flow diagrams for the FWS, to determine if there were any system components that the applicant did not identify as within the scope of license renewal but were necessary to perform one of the identified FWS intended functions. The staff also reviewed the design basis for the FWS as described in the UFSAR to determine if there were any additional system functions that were intended functions and, therefore, might require FWS components that the applicant identified as not within the scope of license renewal to be within the scope of license renewal.

The staff's review of the UFSAR and flow diagrams did not uncover any additional structures or components of the FWS that should have been within the scope of license renewal. However, one of the intended functions of the FWS is to isolate feedwater flow to the steam generators. This function is performed by the motor-operated main feedwater isolation valve (MFIV) and associated instrumentation and controls, which are within the scope of license renewal. If the MFIV fails to close on demand, backup isolation is provided by the automatic tripping of the main feedwater pumps, condensate booster pumps, and the heater drain pumps. Section 5.9 of Appendix A to the LRA appeared to only identify the MFIV (and associated instrumentation and controls) as performing this intended function. Therefore, in NRC Question No. 5.9.8 (NRC letter to BGE dated February 13, 1998), the staff asked the applicant to provide justification for excluding the components that perform the backup isolation function. In its response, the applicant stated that it considers the function of steam generator isolation to include the backup means of stopping FWS flow, that is, the tripping of the FWS pumps, condensate booster pumps, and the heater drain pumps. Therefore, in accordance with the scoping process, the applicant determined that any component required to accomplish the tripping function is within the scope of license renewal. The applicant further stated that the only functions performed by the FWS components required to trip the pumps are active and, as such, the components do not require an AMR. The applicant also stated that the cables and other electrical components associated with the intended functions of the FWS are addressed by the commodity reports in Section 6.0 of Appendix A to the LRA. The staff concurs with the applicant's response and did not identify any additional components related to the backup function that should be within the scope of license renewal.

In its review, the staff also did not identify any additional intended functions that could result in additional components (components not identified by the applicant) being within the scope of license renewal and hence, possibly subject to an AMR.

As described above, the staff has reviewed the information presented in Section 5.9 of Appendix A to the LRA and the additional information sent by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds reasonable assurance that the applicant has appropriately identified those FWS structures and components (device types) within the scope of license renewal in accordance with the requirements in 10 CFR 54.4.

2.2.3.20.2.2 Feedwater System Subject to an Aging Management Review

In Section 5.9.1.2 of Appendix A to the LRA, the applicant identified which structures and components of the feedwater system (FWS) are within the scope of license renewal. The applicant divided those structures and components into device types not subject to an AMR and device types subject to an AMR (listed in Table 5.9-1 of Appendix A to the LRA). The staff reviewed all the information presented by the applicant to verify that the applicant's grouping was correct.

The applicant identified 26 device types that need to be consider for an AMR. The staff reviewed all the components within the scope of the rule for the FWS and verified that all the components were considered in these 26 device types. Of 26 device types within the scope of license renewal rule, 22 device types are electrical/instrumentation components. The staff reviewed the device types that are electrical/instrumentation components to verify that the applicant did not omit any that should be subject to an AMR. Of the 22 components, the applicant classified the following 15 as having only active functions and, therefore, not requiring an AMR:

fuse
power lamp indicator
pressure indicator
transformer
position switch
hand switch
level indicator
relay
power supply
current/current device
level recorder
temperature relay
position indicating lamp
125 VDC motor
solenoid valve

Two device types, SG level transmitter and SG pressure transmitter, are either subject to periodic replacement or are evaluated in another AMR. Of the 20 SG level transmitters, 8 are evaluated in Section 4.2.1, "Environmentally Qualified Equipment," of this SER. All remaining SG level and pressure transmitters (pressure boundary only) in the FWS are subject to an AMR and are evaluated in Section 2.2.3.35, "Instrument Lines," of this SER.

Three device types, panel, control/power cabling, and instrument tubing/valves, are evaluated in Section 2.2.3.32, "Cables;" 2.2.3.33, "Electrical Commodities"; or Section 2.2.3.35, "Instrument Lines," in this SER. Two electrical/instrumentation components, MOV and temperature element, evaluated in this section were classified as subject to an AMR (only pressure boundary/body). The staff agrees with the applicant's determination, which is consistent with 10 CFR 54.21(a)(1).

The staff also reviewed the non-electrical components in the feedwater system in order to determine whether the applicant has properly identified the structures and components subject to an AMR. The staff reviewed the information in Table 5.9-1 of Appendix A to the LRA to ascertain that the applicant has identified all components that are subject to an AMR. The staff found that the applicant had identified all the non-electrical structures and components that perform its intended function without moving parts or without a change in configuration or properties and that are not replaced based on qualified life or specified time period.

The staff has reviewed the information in Section 5.9.1.3 of Appendix A to the LRA and additional information submitted by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds reasonable assurance that the applicant has appropriately identified the structures and components in the FWS subject to an AMR in accordance with the requirements in 10 CFR 54.21(a)(1).

2.2.3.21 Fire Protection

In Section 5.10 "Fire Protection," of Appendix A to the LRA, the applicant described the systems and the components credited with performing fire protection (FP) functions that are within the scope of license renewal, and identified which of those components are subject to an AMR. By letters dated September 2, September 4, and September 24, 1998, the staff issued requests for additional information (RAIs) regarding the FP systems and components. By letters dated November 16 and December 10, 1998, the applicant responded to those RAIs.

2.2.3.21.1 Summary of Technical Information in the Application

The applicant stated that system level scoping found that of the 122 systems and structures at CCNPP, 66 were within the scope of license renewal. The applicant used the CCNPP FP plan, required in 10 CFR 50.48, "Fire protection," and various licensing-basis documents that addressed the applicant's commitments, as information to prepare the FP screening tool described in Section 2.0 of Appendix A to the LRA.

The FP screening tool defines two categories of FP functions. The first category is the FP function, which includes equipment and facilities important to safety that provide for detecting, fighting, and extinguishing fires. This equipment and these facilities are necessary to protect safety-related (SR) equipment and structures from fire or explosion. This function does not include FP equipment or facilities protecting NSR equipment and structures. The second category is the safe shutdown function, which applies to systems that provide for safe shutdown of the plant in the event of a severe fire. Therefore, the evaluations pertaining to safe shutdown identified those components that are required for compliance with these regulations. The safe-shutdown function includes the capability to provide the following:

reactor coolant system (RCS) pressure and inventory control;
reactivity control;
heat removal (hot standby or cold shutdown) from the RCS; and
process monitoring.

For the 66 systems and structures that the applicant identified during the system-level scoping as within the scope of license renewal, those with FP functions were identified using the FP screening tool. The FP screening tool showed that 42 of the 66 systems and structures within the scope of license renewal have one or more FP-intended functions. Of the 42 systems and structures identified in Table 5.10-1 of Appendix A to the LRA, the applicant evaluated 26 of these SR systems and structures within their respective sections of the LRA. These systems and structures fall into one of the three following categories and are not discussed further in Section 5.10 of Appendix A to the LRA:

structures with components that provide a fire barrier;
fluid systems with components that provide part of a pressure boundary (PB) in systems with only safety-related (SR) PB components; and
electrical systems with components that perform only active electrical functions.

Of the 26 systems and structures identified, 5 structures with components that provide a fire barrier are addressed in Sections 3.3A, 3.3B, 3.3C, and 3.3E of Appendix A to the LRA. Eight fluid systems with components that provide part of a pressure boundary (PB) in systems with only SR PB components are addressed in Sections 5.6, 5.8, 5.9, 5.11A, 5.11B, 5.11C, 5.15, and 5.16 of Appendix A to the LRA. Finally, there are 13 electrical systems with components that perform FP-intended functions. Those systems require no further evaluation in Section 5.10 because their FP intended functions are addressed in other commodity evaluations.

The remaining 16 systems and structures are within the scope of license renewal, and are addressed in Section 5.10 of Appendix A to the LRA. Nine of the remaining systems and structures that perform FP-intended functions have both SR and NSR PB components. The applicant addressed the SR portions of these systems and structures in Sections 4.1, 5.1, 5.2, 5.3, 5.4, 5.7, 5.12, and 5.17 of Appendix A to the LRA. The applicant addressed the NSR PB portions of these systems and structures in Section 5.10 of Appendix A to the LRA. Seven of the remaining systems and structures rely almost entirely on NSR components to perform their FP-intended functions. The applicant addressed these in Section 5.10 of Appendix A to the LRA.

For some of the systems and structures with FP-intended functions, the applicant performed component-level scoping in two ways. The applicant either produced a detailed list of components that contribute to an intended function of the system or structure, or defined a boundary (or envelope) of the important pressure-retaining features of the system in terms of major components or interfaces with other systems, and identified the specific device types that fell within that boundary (or envelope).

The applicant also indicated that, in separate commodity reports, it included some components with FP functions that are common to many systems. These reports address those components for the entire plant. Therefore, the following components were not included in the individual systems and structure sections:

Structural supports for piping, cables, and components, which are evaluated for the effects of aging in Section 3.1 of Appendix A to the LRA;
Electrical control and power cabling, which are evaluated in Section 6.1 of Appendix A to the LRA;
Electrical panels that support and/or protect electrical components, which are evaluated in Section 6.2 of Appendix A to the LRA; and
Instrument tubing and piping and their associated supports, instrument valves and fittings, and the pressure boundaries of the instrument themselves, which are all evaluated in Section 6.4 of Appendix A to the LRA.

2.2.3.21.2 Staff Evaluation

The Commission's regulations in 10 CFR 54.4(a)(3) define all systems, structures, and components relied upon in safety analyses or plant evaluations to demonstrate compliance with 10 CFR 50.48 (the NRC regulation governing fire protection) as included within the scope of license renewal.

The Commission's regulations in 10 CFR 54.21(a)(1) state that for those systems, structures, and components within the scope of this part, as delineated in 10 CFR 54.4, the integrated plant assessment (IPA) must identify and list those structures and components subject to an AMR. The staff reviewed Section 5.10 of Appendix A to the LRA, as supplemented by letters dated November 16 and December 10, 1998, and the other documentation discussed below, to determine whether there is reasonable assurance that the applicant has appropriately identified the components and supporting structures that serve FP-intended functions, and are within the scope of license renewal in accordance with 10 CFR 54.4 and are subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1).

2.2.3.21.2.1 Fire Protection Within the Scope of License Renewal

This evaluation is to determine whether the applicant has properly identified the systems, structures, and components within the scope of license renewal, pursuant to 10 CFR 54.4. As described in more detail below, the staff reviewed selected structures and components that the applicant did not identify as within the scope of license renewal to verify that they do not have any intended function.

As part of the evaluation, the staff reviewed portions of the UFSAR concerning the FP system and made a comparison between the diagrams in Appendix A to the LRA as supplemented and Section 9.9 of the UFSAR "Calvert Cliffs Nuclear Power Plant Fire Protection Program," to determine if there were any additional portions of the system piping and other components that the applicant should have identified as within the scope of license renewal. In Section 5.10 of Appendix A to the LRA, the applicant stated that 66 systems and structures were within the scope of license renewal. The staff also reviewed the UFSAR for any safety-related system functions that were not identified as intended functions in Appendix A to the LRA to verify that no structure or component having an intended function was omitted from the scope of the rule. On the basis of its review, the staff found no omissions.

The applicant applied its FP screening tool to the 66 systems and structures within the scope of license renewal, and credited 42 systems and structures with performing FP functions. The staff sampled portions of the 24 systems and structures without FP functions to verify that the tool properly screened systems and structures with FP functions. For example, the staff reviewed the information in Section 9.7, "Spent Fuel Pool Cooling and Storage," of the UFSAR and found that the system has no intended functions for FP. The staff found no omissions of systems or structures with FP-intended functions in the sample.

Of the 42 systems and structures performing FP-intended functions, 26 are SR systems and structures evaluated elsewhere in the LRA by the applicant. The staff sampled several of these systems and structures and found that FP-intended functions were identified as system intended functions in the referenced sections. Table 1 lists the 26 systems and the location of the evaluations in the LRA.

Table 1: Systems and Structures Addressed Outside of Section 5.10 of Appendix A to the LRA

System	LRA Section*	System	LRA Section*
Intake Structure	3.3C	Electrical 125-V dc Distribution	Addressed in commodity evaluations
Primary Containment	3.3A	Electrical 4-kV Transformers and Buses	Addressed in commodity evaluations
Barriers/Barrier Penetrations	Addressed as part of structures in Sections 3.3A/B/C/E	Electrical 480-V Transformers and Buses	Addressed in commodity evaluations
Auxiliary Building	3.3E	Instrument AC	Addressed in commodity evaluations
Turbine Building	3.3B	Vital Instrument AC	Addressed in commodity evaluations
Saltwater	5.16	Annunciation	Addressed in commodity evaluations
Emergency Diesel Generators	5.8	Control Rod Drive Mechanism and Electrical	Addressed in commodity evaluations
Control Room HVAC	5.11C	Nuclear Instrumentation	Addressed in commodity evaluations
Auxiliary Building and H&V	5.11A	Main Turbine	Addressed in commodity evaluations
Feedwater	5.9	Fire and Smoke Detection	Addressed in commodity evaluations
Safety Injection	5.15	Lighting and Power Receptacles	Addressed in commodity evaluations
Primary Containment H&V	5.11B	Plant Communications	Addressed in commodity evaluations
Containment Spray	5.6	Electrical 480-V Motor Control Centers	Addressed in commodity evaluations

*In Appendix A to the LRA

The remaining 16 systems within the scope of license renewal are addressed in Section 5.10 of Appendix A to the LRA. The staff verified that they were required by the FP plan because they meet at least one FP-intended function. Nine of these systems perform passive FP-intended functions and have both SR and NSR PB components. The SR portions of these nine systems are addressed in other sections of Appendix A to the LRA, while the NSR portions of these systems are addressed in Section 5.10 of Appendix A to the LRA. The other seven systems rely almost entirely on NSR components to perform their FP-intended functions and are entirely addressed in Section 5.10. Table 2 lists the 16 systems that have NSR components and structures that perform FP-intended functions. For the nine systems that have SR components or structures that perform FP-intended functions, Table 2 provides a reference to the appropriate sections of Appendix A to the LRA where the structure or component is evaluated.

Table 2: Systems and Structures Addressed in Section 5.10 of Appendix A to the LRA (NSR PB portions only)

System	LRA Section *	System	LRA Section*
Service Water	5.17 (SR portion) 5.10 (NSR portion)	Main Steam	5.12 (SR portion) 5.10 (NSR portion)
Component Cooling	5.3 (SR portion) 5.10 (NSR portion)	Well and Pretreated Water	5.10
Compressed Air	5.4 (SR portion) 5.10 (NSR portion)	Liquid Waste	5.10
Diesel Fuel Oil	5.7 (SR portion) 5.10 (NSR portion)	Fire Protection	5.10
Auxiliary Feedwater	5.1 (SR portion) 5.10 (NSR portion)	Plant Heating	5.10
Chemical and Volume Control	5.2 (SR portion) 5.10 (NSR portion)	Demineralized Water and Condensate Storage	5.10
Reactor Coolant	4.1 (SR portion) 5.10 (NSR portion)	Condensate	5.10
Nitrogen and Hydrogen Gas System	5.12 (SR portion) 5.10 (NSR portion)	Plant Drains	5.10

*In Appendix A to the LRA

To help ensure that the applicant had appropriately identified all FP-intended functions, the staff asked the applicant to clarify how it had applied its FP screening tool. NRC Question

No. 5.10.6 asked the applicant to verify that it had captured changes to such documents as the Interactive Cable Analysis, and other FP program documentation, to form the FP screening tool. The applicant assured the staff that it had updated the FP screening tool, and that it had used the latest versions of licensing documents in its formulation. The staff reviewed the applicant's response and did not find any omissions of FP functions by the applicant.

However, during the review of Section 5.17 of Appendix A to the LRA, the staff found that nozzles that perform a dousing function for the charcoal beds were not included within the scope of license renewal and were not subject to an AMR. This issue was being tracked by Open Item No. 2.2.3.17.2.1-1 and further discussion of its closure is provided in Section 2.2.3.17.2.1 of this SER.

As described above, the staff has reviewed the information submitted in Section 5.10 of Appendix A to the LRA and the additional information submitted by the applicant in response to the staff's RAIs. On the basis of its review the staff concludes there is reasonable assurance that the applicant has appropriately identified the portions of the FP program that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.21.2.2 Fire Protection Subject to an Aging Management Review

After the staff determined which structures and components were within the scope of license renewal, the staff determined whether the applicant properly identified the structures and components subject to an AMR from among those identified as being within the scope of license renewal. The staff reviewed selected structures and components that the applicant identified as being within the scope of license renewal to verify that the applicant has identified these structures and components as subject to an AMR if they perform intended functions without moving parts or without a change in configuration or properties, and are not subject to replacement based on a qualified life or specified time period.

In a letter dated November 20, 1996, the staff informed the applicant that as an acceptable method of component-level scoping, identification of systems and components subject to review must enable the staff to readily determine from onsite drawings or lists whether a particular system or component is subject to an AMR. In the LRA, for most systems and structures within the scope of license renewal, the applicant submitted a detailed list of components contributing to an intended function of the system or structure. For the systems with passive NSR FP- intended functions, component-level scoping was performed by defining the boundary (or envelope) of the important pressure-retaining features of the system in terms of major components or interfaces with other systems, and by identifying the specific device types that fell within that boundary (or envelope) in Section 5.10 of Appendix A to the LRA. Using this method, the FP components subject to an AMR in Section 5.10 of Appendix A to the LRA can be readily determined from review of the drawing references, which meets the criteria stated in the November 20, 1996, letter.

Table 3 identifies the portions of the 16 systems that have passive, long-lived NSR FP components and structures performing FP-intended functions. The passive FP-intended functions for the 16 systems, not evaluated in other sections, consist of maintaining the pressure boundary of the system liquid or gas, and providing drainage of fire-fighting water in rooms containing SR equipment. The portions of the 16 systems identified in Table 3 below are subject to an AMR. All other portions of these systems used for FP-intended functions are SR and addressed elsewhere in the LRA as discussed in Section 2.2.3.21.2.1 of this SER.

Table 3: Summary of FP Structures and Components Evaluated for AMR in Section 5.10 of Appendix A to the LRA (NSR Portion, Only)

System	NSR Portion of System Within the Scope of LR and Subject to an AMR	Passive FP-intended Function (not addressed in other evaluations)
Well and Pretreated Water	Components in the flow path from the well water pumps to the Primary Water Storage Tanks and the associated pretreated water booster pumps	Maintain pressure-retention capability of the system (liquid/gas)
Service Water	Components that retain pressure in the cooling process flow paths to the instrument air and plant air compressors	Maintain the PB of the system liquid
Fire Protection	Pressure-retaining fire-fighting equipment that performs an FP-intended function or a safe shutdown intended function	Maintain pressure-retaining capability of the system (liquid/gas)
Component Cooling	Components in the head tank makeup flow paths and the flow paths to and from the reactor coolant waste evaporator	Maintain the PB of the system liquid
Compressed Air	All NSR components of the system	Maintain the PB of the system (liquid/gas)
Diesel Fuel Oil	NSR piping and components related to the diesel-driven fire pump	Maintain the PB of the system liquid
Plant Heating	NSR components in the main process flow paths shown as normally open on the system drawings	Maintain the PB of the system (liquid/gas)
Auxiliary Feedwater	The AFW spool piece for the fire hose connections, AFW isolation valves from CSTs 11 and 21, and the piping between the isolation valves and the CSTs	Maintain the PB of the system (liquid/gas)
Demin. Water and Condensate Storage	Limited to CSTs 11 and 21, associated level instruments, emergency hose connections, and all pressure-retaining piping and components up to the first isolation valve on all headers to and from the tanks	Maintain the PB of the system (liquid/gas)
Chemical and Volume Control	Limited to the NSR piping and valves that constitute the flow path from the reactor coolant pump controlled bleedoff lines to the letdown subsystem	Maintain the PB of the system (liquid/gas)
Condensate	Components in the makeup flow path to the SRW and CC head tanks from the fire hose connection	Maintain the PB of the system (liquid/gas)
Plant Drains	Piping and valves in the floor drain lines from rooms containing SR equipment	(1) Maintain pressure-retaining capability of the system (liquid/gas) (2) Provide drainage of fire-fighting water in rooms containing SR equipment
Reactor Coolant	Piping and associated components in the controlled bleedoff lines from the reactor coolant pumps to the CVCS	Maintain the PB of the system (liquid/gas)
Liquid Waste	Components in the flow paths from the sump pump discharge check valves serving areas containing SR equipment to the waste processing subsystems	(1) Maintain the PB of the system (liquid/gas) (2) Provide drainage of fire-fighting water in rooms containing SR equipment
Nitrogen and Hydrogen	Limited to the NSR excess flow check valves	Maintain pressure-retaining capability of the system gas
Main Steam	Pressure-retaining piping and components located downstream of the MSIVs up to the next isolation valves, i.e., turbine bypass valves, moisture separator reheater isolation valves, main turbine stop valves, main feed pump turbine stop valves, and steam seal isolation valve	Maintain the PB of the system (liquid/gas)

To verify whether the applicant had properly identified the structures and components subject to an AMR from among the structures and components with NSR FP-intended functions that have been identified as within the scope of license renewal, the staff performed the following review. The applicant identified structures and components as subject to an AMR if they perform their intended functions without moving parts or without a change in configuration or properties, and are not subject to replacement on the basis of a qualified life or specified time period. The staff compared the information in the UFSAR with the information in the application for selected structures and components. Specifically, the staff reviewed the flow diagrams in Figures 9-6 and 9-25 of the UFSAR for the component cooling system and the CVCS, and Figures 9-23 and 9-28 of the UFSAR for the compressed air system to verify which portions of the system were subject to an AMR. On the basis of the findings of this review and the description of the systems found in Section 5.10 of Appendix A to the LRA, the staff found no omissions of long-lived, passive structures or components within the scope of license renewal that are subject to an AMR. Therefore, the staff has reasonable assurance that the applicant identified all passive, long-lived NSR structures and components with FP-intended functions that are subject to an AMR.

The staff has reviewed the information in Section 5.10 of Appendix A to the LRA and additional information submitted by the applicant in response to the staff's RAIs. On the basis of its review of selected structures and components, the staff finds that there is reasonable assurance that the applicant has appropriately identified the structures and components for the FP program to meet the requirements stated in 10 CFR 54.21(a)(1).

2.2.3.22 Auxiliary Building Heating and Ventilation System

In Section 5.11A, "Auxiliary Building Heating and Ventilation System (ABHVS)," of Appendix A to the LRA, the applicant described portions of the ABHVS and the components therein that are within the scope of license renewal, and identified which of those components are subject to an AMR.

2.2.3.22.1 Summary of Technical Information in the Application

The ABHVS consists of fans, air handling units, dampers, filters, coolers, controls, and ductwork that provide air, in some cases filtered and tempered, to various rooms in the auxiliary and radwaste buildings. A negative pressure, with respect to ambient conditions in surrounding spaces, is normally maintained in the auxiliary building to ensure that clean areas do not become contaminated through the ventilation system. Areas serviced by the system are the switchgear rooms (each unit), diesel generator rooms (three total), auxiliary feedwater (AFW) pump room (each unit), service water (SRW) heat exchanger room (each unit), main steam line penetration area (each unit), waste processing area (each unit), emergency core cooling system (ECCS) pump rooms (each unit), the fuel handling areas (shared between units), and general areas of the auxiliary building. Exhaust air from the waste processing areas, ECCS pump rooms, and the fuel handling areas is passed through a roughing filter and a high-efficiency particulate air (HEPA) filter to remove potentially radioactive particulate contamination preceding discharge through the plant vent. Exhaust air from the ECCS pump room and the fuel handling area can also be routed through separate charcoal filters to remove radioactive iodine in the event of a loss-of-coolant accident or fuel handling incident, respectively.

The air in the switchgear rooms is temperature controlled the year round by redundant heating, ventilating, and air conditioning (HVAC) units and refrigeration systems. The HVAC units and refrigeration components are redundant, but the supply and return ducts to the switchgear rooms are not.

The ventilation system for the auxiliary building areas in which the Fairbanks Morse diesel generators are housed is designed to limit room temperature to a maximum of 120 �F in summer and a minimum of 60 �F in winter. When the emergency diesel generator (EDG) is running, its room is pressurized and the excess air is forced out through a weatherproof exhaust opening over the outside door. Hot water unit heaters maintain a minimum temperature of 60 �F when the diesel generator is shut down.

There are "normal" and "emergency" air cooling systems for the AFW pump room. During normal plant operation, one self-contained HVAC unit maintains the temperature in this room at 90 �F or below. During the emergency mode of operation, redundant fans circulate air between the AFW pump room and the fan equipment room through a system of connecting ductwork, and the rooms are maintained at 120 �F or below. The SRW heat exchanger room is provided with forced air ventilation by separate supply and exhaust fans and dampers to maintain the room temperature low enough for equipment operability in post-accident situations. The main steam pipe tunnel between the MSIV room and the turbine building is cooled by fans that force air from the turbine building into the main steam pipe tunnel.

The waste processing area in the auxiliary building is maintained at a negative pressure with respect to ambient conditions in surrounding spaces. A common air supply system, consisting of three 50 percent capacity air handling units, supplies outdoor air for ventilation of the common waste processing area. The exhaust system draws air from the waste processing areas and forces it through the HEPA filter bank, to the main exhaust plenums. The plant's redundant main exhaust fans force the air past the radioactivity monitors and out through the exhaust stacks.

The ECCS pump rooms are served by a ventilation subsystem to control room temperature and provide proper cooling of the safety injection and containment spray pumps. The subsystem consists of one cooling unit for each ECCS pump room, cooling unit fans, and an ECCS pump room exhaust system that contains a roughing filter, a HEPA filter, a charcoal filter, and dampers. Saltwater is circulated through the air cooling coils to remove heat.

Two 50-percent-capacity air handling units provide filtered air to the fuel handling area. A separate exhaust system draws air through a manifold and HEPA filters and feeds it into the main plant vent of Unit 1. During the movement of fuel over the spent fuel pool, air from the fuel handling area is diverted through charcoal filters after it leaves the HEPA filters to minimize the release of radioactive material in the event of a fuel handling accident. The exhaust fans are capable of maintaining a negative pressure with respect to ambient conditions in surrounding spaces of the building. Unit heaters maintain a minimum temperature of 60 �F in the winter.

In the LRA, the applicant identified the following intended functions for the ABHVS based on 10 CFR 54.4(a)(1) and 54.4(a)(2):

To supply air to the battery ventilation system in response to a design basis event (DBE);
To initiate letdown line isolation to provide radiological release control during a loss-of-coolant accident;
To provide ventilation for, and remove potentially radioactive contaminated air from, the ECCS pump room in response to a DBE;
To provide HVAC for, and remove potentially radioactive contamination from, the fuel handling area in response to a DBE;
To provide HVAC to the electrical switchgear room in response to a DBE;
To provide ventilation to the diesel generator rooms in response to a DBE;
To provide ventilation to the AFW pump room in response to a DBE;
To provide ventilation to the SRW heat exchanger room in response to a DBE;
To maintain electrical continuity and/or provide protection of the electrical system;
To maintain the pressure boundary of the system (liquid and/or gas); and
To maintain structural integrity to support proper operation of other ABHVS components.

The following ABHVS intended functions were determined on the basis of the requirements of 10 CFR 54.4(a)(3):

For fire protection (10 CFR 50.48)--To provide alternate ventilation to the AFW pump room during a fire, and
For environmental qualification (10 CFR 50.49)--To maintain functionality of electrical equipment as addressed by the environmental qualification program and to provide information used to assess the plant and environs condition during and following an accident.

On the basis of the intended functions stated above, the portions of the ABHVS that are identified by the applicant as within the scope of license renewal include all safety-related components in the system (electrical, mechanical, and instrument) and their supports. The applicant identified a total of 46 device types as within the scope of license renewal. Of these 46 device types, the applicant identified 9 that are subject to an AMR. The 9 device types are damper, HVAC duct, fan, filter, gravity damper, manual damper, hand valve, heat exchanger, and pressure differential indicator. The applicant also indicated that the ABHVS pressure boundary is the only passive intended function associated with the ABHVS that is not addressed in one of the commodity evaluations in the LRA. Therefore, only the pressure-retaining function for the 9 device types subject to an AMR was considered.

The applicant also indicated that some components that are common to many systems have been included in the separate commodity reports that address those components for the entire plant. Therefore, the following components were not included in the individual system sections:

Structural supports for piping, cables, and components, which are evaluated for the effects of aging in Section 3.1 of Appendix A to the LRA;
Electrical control and power cabling, which is evaluated in Section 6.1 of Appendix A to the LRA; and
Process and instrument tubing and tubing supports, which are all evaluated in Section 6.4 of Appendix A to the LRA.

2.2.3.22.2 Staff Evaluation

The staff reviewed Section 5.11A of Appendix A the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the ABHVS components and supporting structures within the scope of license renewal in accordance with 10 CFR 54.4, and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding the ABHVS (NRC letter dated September 4, 1998), and by letter dated November 16, 1998, the applicant responded to the RAIs.

2.2.3.22.2.1 Auxiliary Building Heating and Ventilation System Within the Scope of License Renewal

The staff reviewed portions of the UFSAR, including Section 9.8, "Plant Ventilation Systems," to determine if there were any portions of the system that the applicant did not identify as within the scope of license renewal that should have been so identified. The staff also reviewed Section 9.8 of the UFSAR to determine if there were any safety-related system functions that were not identified as intended functions in the LRA, and to determine if there were structures and components having intended functions that might have been omitted from consideration within the scope of license renewal. The staff also reviewed the system to determine if any structures or components not identified in the LRA as within the scope of the rule should have been so identified under 10 CFR 54.4(a)(2) or 54.4(a)(3). The staff compared the safety-related functions described in the UFSAR to those identified in the LRA.

To help ensure that those portions of the ABHVS identified as not within the scope of license renewal did not perform any intended functions and, therefore, would not be subject to an AMR, the staff requested additional information from the applicant based on the information in the UFSAR and the LRA. In NRC Question No. 5.11.2, the staff noted that Section 5.11A.1.1 in "System Level Scoping" summarizes the system boundaries and components within the scope of license renewal for the ABHVS. The drawings showing the system scoping boundaries were not included. The corresponding drawings for these systems in the UFSAR for CCNPP are not detailed enough for the staff to clearly understand the system renewal scope. By a letter dated November 16, 1998, the applicant sent Figure 5.11A-1 showing the scoping boundaries for the ABHVS. On the basis of the applicant's response that included a drawing showing the correct scoping boundaries, the staff agrees that the applicant identified the system level scoping boundaries, and that those LRA boundaries correctly separate system components within these boundaries from those that are outside.

As described above, the staff has reviewed the information submitted in Section 5.11A of Appendix A to the LRA and the applicant's response to the staff's RAI. On the basis of that review, the staff finds reasonable assurance that the applicant has appropriately identified the portions of the ABHVS and the associated structures and components thereof that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.22.2.2 Auxiliary Building Heating and Ventilation System Subject to an Aging Management Review

On the basis of the intended system functions listed above, the applicant emphasized that the portions of the ABHVS system that are within the scope of license renewal include all safety-related components in the system (electrical, mechanical, and instrumentation) and their supports. The applicant described the subsystems and such associated devices as accumulators, check valves, and dampers. The applicant identified 46 device types. Of the 46 device types associated with the ABHVS system the applicant identified 25 device types that have only active functions and do not require an AMR. Of the 46 device types, 10 do not require a detailed evaluation of specific aging mechanisms because they are considered part of a complex assembly. These complex assemblies perform their intended functions with moving parts. These 10 device types are piece-parts of the mechanism, and therefore, are not subject to an AMR, and two of them (panels and pressure differential indicator switches) are evaluated in other sections of Appendix A to the LRA. As a result of this screening process, all components of the remaining 9 device types are subject to a detailed evaluation of aging mechanisms as part of an AMR: damper, HVAC duct, fan, filter, gravity damper, manual damper, hand valve, heat exchanger, and pressure differential indicator.

Of the device types (including the three electrical/instrumentation device types discussed below) within the scope of the license renewal rule, 32 are electrical/instrumentation components. The staff reviewed the device types that are electrical/instrumentation components to verify that the applicant did not omit any electrical/instrumentation components that should be subject to an AMR. Of the 32 device types, the applicant classified the following 23 as having only active functions and, therefore, not requiring an AMR:

disconnect switch/link
fuse
hand switch
converter/relay
power lamp indicator
level device (relay)
480-V motor (feed from MCC)
480-V motor
125/250-V dc motor
temperature device (relay)
pressure transmitter
relay
position controller
temperature transmitter
control valve
pressure converter (relay)
temperature controller
position switch
temperature element
temperature switch
motor operator
temperature indicating controller
position indicating lamp

Four device types (pressure indicator, pressure switch, temperature control valve, and solenoid valve) do not require a detailed evaluation of specific aging mechanisms because they are considered part of a complex assembly whose only passive function is closely linked to active performance of the refrigeration units.

Three device types (electrical control/power cabling, instrument tubing/valves, and pressure differential indicator switch) are evaluated in Section 2.2.3.32, "Cables," and Section 2.2.3.35, "Instrument Lines," of this SER. The remaining two electrical/instrumentation components (fan and pressure differential indicator) evaluated in this section are classified as subject to an AMR.

The staff has reviewed the information in Section 5.11A of Appendix A to the LRA and additional information submitted by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds reasonable assurance that the applicant has appropriately identified the ABHVS system structures and components subject to an AMR in accordance with the requirements in 10 CFR 54.21(a)(1).

2.2.3.23 Primary Containment Heating and Ventilation System

In Section 5.11B, "Primary Containment Heating and Ventilation (H&V) System," of Appendix A to the LRA, the applicant described portions of the primary containment H&V system and the components therein that are within the scope of license renewal, and identified which of those components are subject to an AMR.

2.2.3.23.1 Summary of Technical Information in the Application

As described in Appendix A to the LRA, the primary containment H&V system is designed to remove heat from the containment atmosphere during normal plant operations and accident conditions via the containment air recirculation and cooling subsystem. The subsystem is independent of the containment spray and safety injection systems. The subsystem for each unit consists of four cooling units, an air mixing plenum, and the distributing ductwork and piping, all located inside the containment. Service water is circulated through the air cooling coils to remove heat.

In the LRA, the applicant identified the following intended functions for the primary containment H&V system based on 10 CFR 54.4(a)(1) and 54.4(a)(2):

Control containment temperature and pressure;
Provide containment atmosphere filtration and radiation control;
Collect and process containment penetration leakage into the penetration rooms;
Filter hydrogen purge air for radiation control following DBEs;
Measure pressure in the containment penetration rooms;
Provide containment atmosphere pressure source to ESFAS instrumentation for protective actuation;
Isolate the containment;
Maintain electrical continuity and provide protection or both of the electrical system;
Maintain the pressure boundary of the system; and
Provide seismic integrity and protection or both of safety-related components.

The applicant also determined that the following were intended functions of the primary containment H&V system based on the requirements of 10 CFR 54.4(a)(3):

For post-accident monitoring--Provide information used to assess the condition of the plant and its environs during and following an accident, and
For equipment qualification--Maintain functionality of electrical components as addressed by the EQ program.

On the basis of the intended functions stated above, the portions of the primary containment H&V system that are identified by the applicant as within the scope of license renewal are all safety-related components in the system (electrical, mechanical, and instrument) and their supports. The applicant listed 38 device types that are within the scope of license renewal. It also identified 3 additional primary containment H&V system device types (panels, cables, and instrument lines) that are evaluated by the applicant in Sections 6.1, 6.2, and 6.5 of Appendix A to the LRA. Of these 41 device types, the applicant identified 12 that are subject to an AMR. The 12 device types are piping (Code HB), five valve types (check, control, motor operated, solenoid, and hand valve), damper, duct, fan, filter, gravity damper, and heat exchanger. The applicant further indicated that containment and system pressure boundary integrity are the only passive intended functions associated with the primary containment H&V system that are not addressed in one of the commodity evaluations of the LRA. Therefore, only the pressure-retaining function for the 12 device types subject to an AMR was considered.

The applicant also stated that some components in the primary containment H&V system that are common to many systems have been evaluated in the separate commodity reports that address those components for the entire plant. Therefore, the following components were not included in the individual system sections:

Structural supports for piping, cables, and components that are evaluated for the effects of aging in Section 3.1 of Appendix A to the LRA;
Electrical control and power cabling that is evaluated in Section 6.1 of Appendix A to the LRA; and
Instrument tubing and piping and their associated supports, instrument valves and fittings, and the pressure boundaries of the instrument themselves, which are all evaluated in Section 6.4 of Appendix A to the LRA.

2.2.3.23.2 Staff Evaluation

The staff reviewed Section 5.11B of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the primary containment H&V system components and supporting structures within the scope of license renewal in accordance with 10 CFR 54.4, and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding the primary containment H&V system (NRC letter to BGE dated September 2, 1998), and by letter dated November 16, 1998, the applicant responsed to those RAIs.

2.2.3.23.2.1 Primary Containment Heating and Ventilation System Within the Scope of License Renewal

The staff reviewed portions of the UFSAR, including Section 6.5, "Containment Air Recirculation and Cooling System," and compared them to the diagrams in Appendix A to the LRA to determine if there were any additional portions of the system piping and other components that the applicant should have identified as within the scope of license renewal. The staff also reviewed Section 6.5 of the UFSAR to determine if there were any safety-related system functions that were not identified as intended functions in Appendix A to the LRA to verify that no structure or component having an intended function was omitted from the scope of license renewal.

Section 6.5.4 of the UFSAR describes piping that transfers the condensate leaving the coils to the containment sump. The staff asked the applicant (NRC Question No. 5.11.4) to provide the basis for excluding this piping from the scope of license renewal. In response to NRC Question No. 5.11.4, the applicant stated that in the event the drainage lines fail, the condensate would drain from the main sump of the cooling coil housing directly onto the containment floor and eventually to the sump. The cooling coil units would still be able to perform their intended function. Additionally, in response to the staff's desire to clarify the applicant's response to NRC Question No. 5.11.4, during a December 9, 1998, teleconference, the applicant verified that containment air cooler condensate was not credited as fluid available for recirculation. The credited volume of fluid in the containment at the time of recirculation is equal to the sum of the minimum usable refueling water tank volume and the minimum usable volume of the four safety injection tanks. On the basis of the applicant's response, which is summarized in the NRC meeting summary dated March 19, 1999, the staff agrees that the non-safety-related drainage lines do not perform any of the system- intended functions as defined in 10 CFR 54.4(a)(1), (2), and (3), and are not within the scope of license renewal.

Section 5.11B.1.2 in Appendix A to the LRA states that ductwork downstream of the fusible links is not within the scope of license renewal. The containment air recirculation and cooling system provides cooling air via this ductwork to the SG compartment and reactor vessel annulus. As a result, the staff questioned whether the ductwork should be within the scope of license renewal. To clarify the staff's question, a conference call was made on December 9, 1998 to the applicant's staff. In response to the call, the applicant stated that cooling via this ductwork was credited in the long-term thermal aging analysis, which supports the applicant's EQ program. Because the staff was considering whether non-safety-related support systems, such as ductwork, credited in analyses that support programs such as EQ, are within the scope of license renewal, this was identified as Open Item 2.2.3.23.2.1-1 in the previous SER.

By letter dated September 28, 1999, the applicant stated that the failure of ductwork, which contributes to providing the normally expected environments, will not prevent the execution of the critical safety functions identified in 10 CFR 50.49(b)(1) during and following a design basis accident. In addition, the applicant stated that during or following a design basis accident, the cavity cooling function is assumed to be unavailable. The applicant added that any failure of the cavity cooling system, or any of its components, would be treated as a degraded condition and operability of the affected system, structure, or component would be evaluated, including affects on 10 CFR 50.49(b) equipment.

In a letter to the Nuclear Energy Institute dated August 5, 1999, the NRC staff issued additional guidance to identify SSCs within the scope of license renewal under 10 CFR 54.4. In this

letter, the staff concluded that, based on the applicant's current licensing basis, those SSCs required to comply with, and operate within, the Commission's regulations, identified in 10 CFR 54.4(a)(3), need to be considered.

Since the applicant stated that the failure of the cavity cooling system ductwork will not prevent the satisfactory completion of any critical safety function during and following a design basis accident, the ductwork is not required to be within the scope of license renewal. Therefore, Open Item 2.2.3.23.2.1-1 is closed.

As described above, the staff has reviewed the information in Section 5.11B of Appendix A to the LRA, the additional information documented in the NRC meeting summary dated March 19, 1999, and the applicant's response to the staff's RAIs. On the basis of the review discussed above, the staff finds reasonable assurance that the applicant has appropriately identified the portions of the primary containment H&V system and the associated structures and components thereof, that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.23.2.2 Primary Containment Heating and Ventilation System Subject to an Aging Management Review

The applicant applied a scoping process as delineated in Section 2.0 of Appendix A for identifying device types subjected to an AMR for the primary containment H&V system. The applicant listed 38 device types that are within the scope of license renewal. They also identified 3 additional primary containment H&V system device types (component supports, cables, and instrument lines) that are evaluated by the applicant in Sections 3.1, 6.1, and 6.4 of Appendix A to the LRA. Of the 41 device types, 21 were determined to perform their intended function with moving parts or with a change in configuration or properties and did not require an AMR. Eight device types were evaluated in other sections of the LRA. The remaining 12 device types, which were determined to require an AMR, are check valve, control valve, damper, HVAC duct, fan, filter, gravity damper, piping (Code HB), hand valve, heat exchanger, motor-operated valve, and solenoid valve.

The staff reviewed all the information submitted by the applicant and verified that the applicant identified all structures and components of the primary containment H&V system within the scope of the rule as required under 10 CFR 54.4(a). Of the total 41 device types within the scope of the license renewal rule, 30 device types are electrical/instrumentation components. The staff reviewed these device types to determine which electrical/instrumentation components should be subject to an AMR. Of these electrical/instrumentation components, the applicant classified the following 19 as having only active functions and, therefore, not requiring an AMR:

coil
voltage/current device
fuse
hand switch
ammeter
480-V motor
125/250-V dc motor
MOV operator
pressure-indicating alarm
pressure indicator
pressure-indicating differential
relay
temperature element
temperature indicator
power supply
position indicating lamp
position switch
480-V motor (feed from MCC)
power lamp indicator

The staff agrees with the applicant's determination that these device types perform their functions with moving parts or with a change in configuration or properties.

The following 11 electrical/instrumentation device types are subjected to an AMR:

disconnect switch/link
480 V control station
pressure differential indicator switch
pressure transmitter
control valves
MOVs
disconnect switch/link
480-V control station
pressure differential indicator switch
pressure transmitter
solenoid valves

Of the 11 device types, 8 (disconnect switch/link, 480-V control station, pressure differential indicator switch, pressure transmitter, disconnect switch/link, 480 V control station, pressure differential indicator switch, and pressure transmitter) are evaluated in Section 6.1, "Cable"; Section 6.2, "Electrical Commodities"; or Section 6.4, "Instrumentation Line," of the application. The 3 remaining electrical/instrumentation components device types (control valve, MOV, and solenoid valve) are evaluated in this section.

The staff also reviewed the 11 non-electrical device types. Of these 11 device types, 2 device types (piston operators and hydrogen recombiners) were determined to require a moving parts, or a change in configuration or properties. The remaining 9 non-electrical device types (check valves, dampers, duct, fan, filter, gravity damper, piping, hand valves, and heat exchangers) were determined to require an aging management review.

The staff asked a number of questions related to the exclusion of certain components (e.g., the fusible link associated with the containment air cooler blowdown door [NRC Question No. 5.11.3], and electric hydrogen recombiners [NRC Question Nos. 5.11.6 and 5.11.7]) from an AMR. The applicant explained that such components were excluded for one of the following reasons: (1) they were active components, and were not within the scope of license renewal, (2) they were not safety-related, and did not affect the functioning of other safety-related structures, systems, and components, or (3) they were evaluated in other sections of Appendix A to the LRA. The staff reviewed the applicant's justification and determined that it was consistent with the requirements in 10 CFR 54.21(a)(1). The staff finds the determination of the primary containment H&V system non-electrical device types subject to an AMR consistent with the requirements in 10 CFR 54.21(a)(1).

The staff reviewed the information in Section 5.11B of Appendix A to the LRA and additional information submitted by the applicant in response to applicable RAIs. On the basis of this review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the structures and components in the primary containment H&V system subject to an AMR in accordance with the requirements in 10 CFR 54.21(a)(1).

2.2.3.24 Control Room and Diesel Generator Buildings' Heating, Ventilation, and Air Conditioning Systems

In Section 5.11C of Appendix A to the LRA, the applicant identified portions of the CRHVACS and DGBHVACS and the components therein that are within the scope of license renewal, and identified which of those components are subject to an AMR.

2.2.3.24.1 Summary of Technical Information in the Application

The CRHVACS provides ventilation to the control room, the Units 1 and 2 cable spreading rooms, and the Units 1 and 2 battery rooms. The control room and cable spreading rooms are supplied by a single, year-round air conditioning system serving Units 1 and 2. Air handling equipment and refrigeration units are redundant, but the ductwork is not. The control room and cable spreading room areas have a third source of cooling, which is not safety-related, in the form of a water chiller supplying a second set of coils in the safety-related air handling systems. If airborne contamination occurs at the fresh-air intake, a self-contained recirculation system is automatically initiated through a post-LOCA filter system. The control room air is then processed through HEPA and charcoal filters. The air conditioning system is divided into three supply and return duct systems: one for each of the two cable spreading rooms and one for the control room. Each branch contains isolation dampers that are automatically closed if smoke is detected within the branch. The remaining branches continue to serve the other two zones without interruption.

Smoke can be evacuated from the isolated zone by means of an auxiliary fan, motorized dampers, and an outside-air intake. The battery rooms are separately ventilated. Heated and filtered air is supplied to the four battery rooms and the reserve 125-V dc battery room on the 27-foot and 45-foot levels of the auxiliary building, using one supply fan, one exhaust fan, a heating coil, a roughing filter, and motor-operated dampers. Separate supply and exhaust fans are utilized to maintain a negative pressure in these rooms, with respect to the surrounding areas, to preclude the hydrogen concentration in the air from reaching the explosive limit. Upon loss of either fan, sufficient ventilation is provided by the remaining fan to preclude the possibility of hydrogen accumulation within the battery rooms.

As described in the LRA, the DGBHVAC provides ventilation, heating and cooling for the buildings in which two new diesel generators are located. These two new diesel generators were placed into operation in 1995. Because of the unusual circumstances pertaining to these HVAC systems (i.e., they were placed into service approximately 20 years after other similar HVAC systems at CCNPP, and they have a design life of 45 years), an AMR process separate and unique from that used for other plant systems and structures was used. Since aging of the existing control room HVAC system equipment is some 20 years ahead of the aging of the HVAC system equipment in the diesel generator buildings, and since this equipment is just at the beginning of its design life, aging management of the new equipment can be deferred and then be based on future results of aging management from similar equipment groups associated with the control room HVAC system.

In the LRA, the applicant identified the following intended functions for the CRHVACS on the basis of 10 CFR 54.4(a)(1) and stated that all passive functions of the DGBHVACS are equivalent to the CRHVACS's passive intended functions:

To provide HVAC to the control room, cable spreading rooms, and battery rooms to ensure habitability during design-basis events, limit reactor protective system/ engineered safety features actuation system temperatures, and minimize hydrogen accumulation;
To provide seismic integrity and/or protection of safety-related components;
To maintain the pressure boundary of the system (liquid and/or gas); and
To maintain electrical continuity and/or provide protection of the electrical system.

The applicant also determined that the following were intended functions of the CRHVACS based on the requirements of 10 CFR 54.4(a)(3):

Provide technical support center supply and exhaust ventilation duct isolation to confine or retard a fire in the TSC from spreading to adjacent areas; and
Detect smoke, maintain ventilation in unaffected zones, and remove smoke/supply fresh air to affected zones in the event of a fire in the control room or cable spreading rooms.

On the basis of the intended functions stated above, the portions of the CRHVACS that are identified by the applicant as within the scope of license renewal include all safety-related components in the system (electrical, mechanical, and instrument) and their supports. The applicant identified a total of 45 device types as within the scope of license renewal. Of these 45 device types, the applicant identified 10 that are subject to an AMR. The 10 device types are analyzer element, gravity damper, damper, heat exchanger, HVAC duct, hand valve, fan, temperature transmitter, filter, and radiation element. The applicant also indicated that maintenance of the CRHVACS's pressure boundary is the only passive intended function associated with the CRHVACS that is not addressed in one of the commodity evaluations of the LRA. Therefore, only the pressure-retaining function for the 10 device types subject to an AMR was considered.

Structural supports for piping, cables, and components, which are evaluated for the effects of aging in Section 3.1 of Appendix A to the LRA;
Electrical control and power cabling, which is evaluated in Section 6.1 of Appendix A to the LRA; and
Process and instrument tubing and tubing supports, which are all evaluated in Section 6.4 of Appendix A to the LRA.

2.2.3.24.2 Staff Evaluation

The staff reviewed Section 5.11C of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the CRHVACS components and supporting structures within the scope of license renewal in accordance with 10 CFR 54.4, and those subject to an AMR have been identified in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding the CRHVACS (NRC letter dated September 4, 1998), and by letter dated November 16, 1998, the applicant responded to the RAI's.

2.2.3.24.2.1 Control Room and Diesel Generator Buildings' HVAC System Within the Scope of License Renewal

The staff reviewed portions of the UFSAR, including Section 9.8, "Plant Ventilation Systems," to determine if there were any portions of the system that the applicant did not identify as within the scope of license renewal that should have been so identified. The staff also reviewed Section 9.8 of the UFSAR to determine if there were any safety-related system functions that were not identified as intended functions in the LRA and to determine if there were any structures and components having intended functions that might have been omitted from consideration within the scope of license renewal. The staff also compared the safety-related functions described in the UFSAR to those identified in the LRA.

To help ensure that those portions of the CRHVACS identified as not within the scope of license renewal did not perform any intended functions and, therefore, would not be subject to an AMR, the staff requested additional information from the applicant on the basis of information in the UFSAR and the LRA. In NRC Question No. 5.11.1, the staff noted that Sections 5.11C.1.1 and 5.11C.1.4 in system level scoping provide a summary description of the system boundaries and components within the scope of license renewal for both the CRHVACS and DGBHVACS. The drawings showing the system scoping boundaries were not included. The corresponding drawings for these systems in the UFSAR for CCNPP do not have sufficient details for the staff to clearly understand the system renewal scope. By a letter dated November 16, 1998, the applicant sent Figures 5.11C-1, -2, and -3 depicting the scoping boundaries for the CRHVACS and DGBHVACS. On the basis of the applicant's response, the staff agrees that these figures identify the system level scoping boundaries, and that those LRA boundaries correctly separate system components within these boundaries from those that are outside.

As described above, the staff has reviewed the information submitted in Section 5.11C of Appendix A to the LRA and the applicant's response to the staff's RAI. On the basis of that review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the portions of the CRHVACS and DGBHVACS and the associated structures and components thereof that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.24.2.2 Control Room and Diesel Generator Buildings' HVAC System Subject to an Aging Management Review

A. Control Room Heating, Ventilation, and Air Conditioning Systems

The applicant identified a total of 45 device types of the control room HVAC system as within the scope of license renewal. Of these 45 device types, 17 have only active functions and do not require an AMR, 4 device types are evaluated in other sections of Appendix A to the LRA, and 14 device types do not require a detailed evaluation of specific aging mechanisms because they are considered part of a complex assembly whose only passive function is closely linked to active performance. All components of the following 10 device types are subject to an AMR: analyzer element, damper, HVAC duct, fan, filter, gravity damper, heat exchanger, hand valve, radiation element, and temperature transmitter.

Of the device types (including the three electrical/instrumentation device types evaluated in other sections of Appendix A to the LRA) within the scope of the license renewal rule, 32 device types are identified as electrical/instrumentation components. The staff reviewed these 32 device types to verify that the applicant did not omit any electrical/instrumentation components that should be subject to an AMR. Of the 32 components, the applicant classified the following 17 as having only active functions and, therefore, not requiring an AMR:

control valve
converter/relay
480-V motor (feed from MCC)
pressure converter (relay)
miscellaneous indicating lamp
pressure control valve
hand switch
motor operator
power lamp indicator
480-V motor
temperature controller
position-indicating lamp
fuse
125/250-V dc motor
position switch
relay
coil

Seven device types (flow gauge, level gauge, pressure indicator, pressure switch, temperature switch, solenoid valve, and temperature control valve) are associated with the refrigeration units. The refrigeration units perform their intended function (that is, refrigeration) with moving parts. These seven device types are piece parts of the refrigeration units and are, therefore, not subject to an AMR.

Five components (electrical control/power cabling, instrument tubing, flow switch, disconnect switch/link, and pressure differential indicator) are evaluated in Section 2.2.3.32, "Cables"; Section 2.2.3.33, "Electrical Commodities"; or Section 2.2.3.35, "Instrument Line," of this SER.

Four electrical/instrumentation components (analyzer element, fan, radiation element, and temperature transmitter) evaluated in this section were classified as subject to an AMR (pressure-retaining function only).

B. Diesel Generator Buildings' Heating, Ventilation, and Air Conditioning System

The applicant stated that the two new diesel generators began operation at CCNPP in 1995. These diesel generators are located in two separate buildings that are dedicated for housing them. The diesel generator buildings' HVAC system provides ventilation, heating, and cooling for these building spaces. Because of the unique circumstances pertaining to these HVAC systems (i.e., they were placed into service approximately 20 years after other similar HVAC systems at CCNPP, and they have a design life of 45 years), an AMR process separate and unique from that used for other plant systems and structures was used. Since aging of the existing control room HVAC system equipment is some 20 years ahead of the aging of the diesel generator buildings' HVAC system equipment, and since this equipment is just at the beginning of its design life, aging management of the new equipment can be deferred and then can be based on the future results of aging management from similar equipment groups associated with the control room HVAC system.

Moreover, the applicant explained that all passive intended functions of the diesel generator buildings' HVAC system are equivalent to the control room HVAC system's passive intended functions. Common attributes, like intended functions, component configuration, material, and service conditions, lead to the conclusion that the effects of aging for these components will be very similar between systems. The aging management programs for the control room HVAC system will provide 20 years of experience for application to the diesel generator buildings' HVAC system. Therefore, there are no new programs or modifications to existing programs needed to manage the aging of the diesel generator buildings' HVAC system.

Regarding the diesel generator buildings' HVAC system, in Section 5.11C.1.4 of Appendix A to the LRA, the applicant explained that the newly installed diesel generator building's HVAC system is similar to the HVAC system in the control room, and it was subject to an AMR process separate and unique from that used for other plant systems and structures. The applicant also stated that the aging management of the new equipment can be deferred, and be based on future results of aging management from similar equipment groups associated with the control room's HVAC system. The applicant demonstrated that the environmental conditions (temperature, moisture content in the air, etc.) and hardware configurations of the diesel generator building's HVAC system are similar to environmental conditions and hardware configuration in the control room in Section 3.6.2.1.4 of this SER.

The staff has reviewed the information in Section 5.11C of Appendix A to the LRA and additional information submitted by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the control room HVAC system structures and components subject to an AMR in accordance with the requirements in 10 CFR 54.21(a)(1).

2.2.3.25 Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydrogen Systems

In Section 5.12, "Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydrogen Systems," of Appendix A to the LRA, the applicant described the identified systems, their intended functions, and the associated structures and components of each system that are within the scope of license renewal, and identified which of those structures and components are subject to an AMR. As described in the LRA, the applicant's main steam (MS) System AMR report includes the extraction steam and nitrogen and hydrogen systems in its scope. The steam generator blowdown system (SGBS) is considered part of the MS system and the portions of the SGBS that are inside the containment are included in the scope of this section of the LRA as part of the main steam system. In Section 5.12 of Appendix A to the LRA, the applicant stated that the portion of the extraction steam system that is within the scope of license renewal is no longer used. The piping was used for reactor vessel head washdown and no longer was exposed to an extraction steam environment. The piping is included in this section of the LRA because it penetrated containment.

2.2.3.25.1 Summary of Technical Information in the Application

As described in the LRA, the MS system (including SGBS piping and isolation valves, as applicable) serves as the flow path for SG output steam to the main high-pressure turbines, the moisture separator reheaters, main feedwater pump turbines, the AFW pump turbines, and the steam seal regulator. The system also provides overpressure protection for the SGs and automatic removal of nuclear steam supply system (NSSS) stored energy and sensible heat following a turbine and reactor trip. The MS system provides the necessary operator control of SG pressure and reactor coolant system (RCS) temperature during plant cooldown and heatup, and a means of heat removal during hot standby and plant cooldown. In addition, the MS system removes excessive moisture from the high-pressure turbine exhaust before it enters the low-pressure turbines via the reheat subsystem.

The applicant stated that during normal plant operations, steam is generated in the SGs and flows through an MS header from each SG to the main turbine high-pressure stop valves. Located in each MS header, at the exit of each SG inside the containment, is a flow restrictor. The main steam isolation valve (MSIV) in each header, outside the containment, represents the downstream terminus of the safety-related MS piping (and the portion of the system within the scope of license renewal). The two MS headers are cross-connected downstream of the MSIVs. Main steam also flows from each of the MS headers, downstream of the containment penetration and upstream of the MSIVs, through air-operated valves, to the AFW turbines when the AFW system is operated. Downstream of the MSIVs, a branch line serves as a steam flow path from each MS header to the moisture separator reheaters and to the steam seal regulator (from No. 11/21 headers only). Another branch line connects to the main feedwater pump turbines.

One atmospheric dump valve (ADV) and eight MS safety valves (MSSVs) are connected to each MS header between the containment penetration and the MSIV. These valves are normally shut and, when opened, exhaust MS to the atmosphere. Four turbine bypass valves are connected to the branch header (downstream of the MSIVs) that supplies MS to the main feedwater pump turbines. These valves are also normally shut and, when operated, exhaust steam to the main condenser.

As described by the applicant in Section 5.12 of Appendix A to the LRA, the function of the extraction steam system is to increase the temperature of the feedwater before it enters the SG, which results in an increase in overall plant efficiency, to minimize thermal shock to the SGs, and to assist in removing moisture from the high-pressure turbine third stage by supplying steam to the first stage of the moisture separator reheater. Wet steam is directed from the three highest stage pressure feedwater heaters in the condensate and feedwater systems en route to the heater drain tanks. Wet steam from the lowest stage pressure feedwater heaters is cascaded to the previous stage feedwater heater and eventually recovered in the condenser.

The function of the nitrogen and hydrogen systems as described by the applicant is to store and distribute the required amounts of nitrogen for normal plant operations, to provide nitrogen for backup to the instrument air system (however, the applicant said that this is currently not in service), and to supply hydrogen to the main generators, the volume control tanks, and the radiological chemistry explosive gas storage room.

The nitrogen and hydrogen system consists of two independent subsystems supplying gases for normal plant operation. The nitrogen subsystem can be further divided into two subsystems, the storage system and the distribution system. The storage system contains an insulated storage tank that is kept pressurized by a combination of ambient and electric vaporizers. The hydrogen system is a common subsystem consisting of hydrogen gas bottles, a truck fill connection, pressure control unit, distribution header, and the associated piping, valves, and controls. The hydrogen subsystem interfaces with one main generator and the chemical and volume control system; however, none of the interfaces are within the scope of license renewal.

The applicant stated that only the nitrogen portion of the nitrogen and hydrogen system is within the scope of license renewal and, therefore, the system is referred to as the nitrogen system in the LRA scoping evaluation. During its review, the staff did verify that the hydrogen portion of the system does not perform any intended functions for license renewal. Since the hydrogen portion of the system does not perform any intended functions, the staff agrees with the applicant's approach and the staff's evaluation only covers the nitrogen system.

Structures and components of the MS system (including piping and isolation valves of the SGBS), extraction steam system, and nitrogen system are within the scope of license renewal based on 10 CFR 54.4(a). The applicant identified the following intended functions of the MS system (and SGBS, as applicable) based on the requirements of 10 CFR 54.4(a)(1) and 54.4(a)(2):

Maintain the pressure boundary of the system (liquid or gas or both).
Provide closure of the SGBS isolation valves on receipt of a containment spray actuation signal to reduce the heat load on the service water system.
Provide SG overpressure protection/decay heat removal.
Provide SG MS line isolation.
Provide motive steam to AFW pump turbines on receipt of an auxiliary feedwater actuation signal.
Maintain electrical continuity or protect the electrical system or both.
Maintain mechanical operability or protect the mechanical system or both.
Restrict flow to a specified value in support of a DBE response.

In Appendix A to the LRA, the applicant also identified the following intended functions of the MS system based on the requirements of 10 CFR 54.4(a)(3):

For environmental qualification--Maintain the functionality of electrical components as addressed by the EQ program.
For fire protection--Provide RCS heat removal in the event of a fire (addressed in Section 5.10, "Fire Protection," of Appendix A to the LRA).
For SBO--Provide SG overpressure protection/decay heat removal.
For SBO--Provide SG steam line isolation.
For SBO--Provide motive steam to AFW pump turbines on receipt of an AFW actuation signal.
For SBO--Provide valve position indication and manual closure of MSIV bypass isolation valves following a loss of AC power.

The applicant also identified the following intended functions of the extraction steam system based on the requirements of 10 CFR 54.4(a)(1) and 54.4(a)(2):

To provide containment isolation
To maintain electrical continuity or protect the electrical system or both

For the nitrogen system, the applicant identified the following intended functions based on the requirements of 10 CFR 54.4(a)(1) and 54.4(a)(2):

To provide containment isolation
To maintain the pressure boundary of the system

The applicant did not identify any intended functions for the extraction steam or nitrogen systems based on 10 CFR 54.4(a)(3).

The extraction steam piping within the scope of license renewal is the containment penetration piping for reactor head washdown. The portions of the nitrogen system within the scope of license renewal is the containment penetration piping and the piping to the SGs via the surface blowdown piping.

On the basis of the MS system intended functions listed above, the applicant identified that the portions of the MS system that are within the scope of license renewal, and addressed in Section 5.12 of Appendix A to the LRA, include all piping, components supports, instrumentation, and cables for the sections of the MS system from the SG outlet to the MSIVs, AFW branch header to AFW stop control valves, surface and bottom blowdown to containment isolation control valves, the safety-related MS system drains up to the flow restrictors of the motor-operated valves, and the air supply piping to the AFW stop control valves.

The applicant identified 34 device types in the MS system that were designated as within the scope of license renewal because they have at least one intended function. Five of those device types are common to many other plant systems and have been included in the instrument line commodity evaluation in Section 6.4, "Instrument Lines," of Appendix A to the LRA. These five device types are flow transmitters, level switches, pressure indicators, pressure switches, and pressure transmitters. One additional device type, hand valves, has also been evaluated in Section 6.4 of Appendix A to the LRA for those hand valves that have a specific function associated with an instrument.

The portions of the extraction steam system within the scope of license renewal consist of piping, component supports, and hand valves associated with the extraction steam containment penetrations and two Class 1E fuses and their associated cables, panels, and supports. Three device types (Class GB piping, fuses, and hand valves) were determined by the applicant to be within the scope of license renewal because they have at least one intended function. The applicant indicated that there were no extraction steam system device types that are included in separate commodity evaluations.

The portions of the nitrogen system within the scope of license renewal consist of piping, component supports, and check and hand valves associated with the SG blowdown and containment penetrations 20A, 20B, and 20C. The applicant identified the following four device types in the nitrogen system that are designated as within the scope of license renewal: Class HB piping, Class EB piping, check valve types, and hand valve types.

For all the systems in Section 3.12 of Appendix A to the LRA, the applicable component supports, cables, and electrical components are addressed in the commodity evaluation sections for those commodities (i.e., Sections 3.1, 6.1, and 6.2).

Of the 34 device types in the main steam system, which the applicant identified as within the scope of license renewal, the applicant identified the following 18 device types as subject to an AMR: Class HB piping, Class EB piping, accumulator, eight valve types (check, control, flow control, hand, motor-operated, relief, pressure control, and solenoid valves), encapsulation, flow elements, flow orifices, heat exchangers, current/pneumatic devices, temperature elements, and tanks.

Of the three device types identified for the extraction steam system that are within the scope of license renewal, the applicant determined that fuses perform its intended function(s) with moving parts or with a change in configuration or properties. Therefore, the two remaining device types (Class GB piping and hand valves) are included in the AMR of Section 5.12 of Appendix A to the LRA. Additionally, all four of the device types in the nitrogen system that are within the scope of license renewal are included in this AMR.

In addition, the applicant identified device types from three other systems that were included in the applicant's main steam system AMR report. These are the encapsulations for the feedwater system and chemical and volume control system per the auxiliary building AMR report, and hand valves from the chemical addition system.

2.2.3.25.2 Staff Evaluation

The staff reviewed Section 5.12 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has appropriately identified the main steam, steam generator blowdown, extraction steam, and nitrogen and hydrogen system components within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding these systems (NRC letters to BGE dated August 31 and September 24, 1998), and by letter dated November 16, 1998, the applicant responded to those RAIs.

2.2.3.25.2.1 Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydrogen Systems Within the Scope of License Renewal

During the first step of its evaluation, the staff reviewed portions of the UFSAR, including the flow diagrams for the MS system, SGBS extraction steam system, and the nitrogen and hydrogen systems to determine if there were any components that the applicant did not identify as within the scope of license renewal but that were necessary to perform one of the identified intended functions of these systems. The staff also reviewed the design basis for the systems as described in the UFSAR to determine if there were any additional system functions that were intended functions and, therefore, might require certain components that the applicant did not identify to be within the scope of license renewal.

The staff's review of the UFSAR and flow diagrams did not reveal any additional structures or components of the MS system, SGBS system, extraction steam system, and nitrogen and hydrogen systems that should be within the scope of license renewal. The staff's review involved sampling various components and interface points that were identified as not being within the scope of the rule. No component or structure omissions were identified. The applicant stated that only the nitrogen portion of the nitrogen and hydrogen system is within the scope of license renewal and, therefore, the system is referred to as the nitrogen system in the LRA scoping evaluation. Since the hydrogen portion of the system does not perform any intended functions, the staff agreed with the applicant's approach and evaluated only the nitrogen system. As a result of the initial review, the staff did request additional information to help ensure there were no omissions from the applicant's list of components within the scope of license renewal. One of these RAIs, NRC Question No. 5.12.6, asked the applicant to clarify if the scope included the MSIVs and if the scope extends to the first restraint downstream of each MSIV. In its response, the applicant verified that the piping between the MSIVs and the next downstream anchor is within the scope of license renewal. The applicant further indicated that this piping is addressed in Section 3.1A, "Piping Segments That Provide Structural Support," of Appendix A to the LRA. The staff's evaluation of Section 3.1A is contained in Section 2.2.3.2 of this SER.

During its review, the staff also requested additional information regarding extraction steam piping inside the containment that was abandoned in place. In NRC Question No. 5.12.7, the staff asked the applicant to identify if this piping was seismically supported and whether it was in the seismic Category II/I equipment program. Additionally, the staff asked the applicant to address similar abandoned piping in other systems. The applicant stated that all abandoned equipment was reviewed and most was determined not to be located in the proximity of seismic Category I equipment and if some is, it is considered as seismic Category II/I equipment and has been determined to be seismically adequate. The applicant noted that all items in the plant are observed during the course of system and structure walkdowns and during system maintenance. During these activities, degradation that may exist is documented, evaluated, and resolved in accordance with the applicant's corrective action program. For these reasons, the applicant has determined that abandoned piping and equipment are not within the scope of license renewal. Because this abandoned equipment does not have a fluid operating environment and the maintenance of the pressure boundary is not required, plus the fact that equipment supports are addressed in Section 3.1, "Component Supports," of Appendix A to the LRA, the staff concurs with the applicant that this piping does not have to be within the scope of license renewal. As a result of its review, the staff also did not identify any additional intended functions that could result in additional components (components not identified by the applicant) being within the scope of license renewal.

As described above, the staff has reviewed the information presented in Section 5.12 of Appendix A to the LRA and the additional information sent by the applicant in response to the staff's RAIs. On the basis of this review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the structures and components (device types) of the MS system, SGBS, extraction steam system, and nitrogen and hydrogen systems within the scope of license renewal in accordance with the requirements in 10 CFR 54.4.

2.2.3.25.2.2 Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydrogen Systems Subject to an Aging Management Review

The staff focused its evaluation of this section on whether the applicant has properly identified the structures and components subject to an AMR from among the systems, structures, and components that have been identified within the scope of license renewal. The staff reviewed selected structures and components identified by the applicant within the scope of license renewal to verify that they have been identified as subject to an AMR if they perform an intended function without moving parts or without a change in configuration and properties and are not subject to replacement based on a qualified life or specified time period. The staff compared the information in the UFSAR with the information in the application to select the structures and components.

The applicant divided the structures and components into device types not subject to an AMR and device types subject to an AMR (listed in Tables 5.12-1, 5.12-2, and 5.12-3 of Appendix A to the LRA). The staff reviewed the information submitted by the applicant to verify that the grouping was correct and found no omissions in classification. Therefore, the staff finds reasonable assurance that the applicant has identified the structures and components subject to an AMR for the main steam, steam generator blowdown, extraction steam, and nitrogen and hydrogen systems.

Of 38 device types within the scope of the license renewal rule, 24 are electrical/instrumentation components. The staff reviewed the device types that are electrical/instrumentation components to verify that the applicant did not omit any electrical/instrumentation components that should be subject to an AMR. Of the 24 components, the applicant classified the following 11 as having only active functions and, therefore, not requiring an AMR.

fuse
hand switch
pressure-indicator controls
position switch indicating lamp
hand controller
current/current device
relay
miscellaneous indicating lamp
hand-indicator controller
power lamp indicator
position switch

The following seven device types are evaluated in Section 2.2.3.32, "Cables"; Section 2.2.3.33, "Electrical Commodities"; or Section 2.2.3.35, "Instrumentation Lines," of this SER.

flow transmitter
pressure switch
panel
level switch
pressure transmitter
pressure indicator
control power cabling

The following six electrical/instrumentation components evaluated in this section were classified as subject to an AMR (only pressure boundary/body).

control valve
MOV
flow element
solenoid valve
current/pneumatic device
temperature element

The staff agrees with the applicant's determination of the components subject to an AMR and that the 11 components excluded from an AMR perform their functions with moving parts or by changing configuration or properties, which is consistent with 10 CFR 54.21(a)(1).

Fourteen device types within the scope of license renewal are mechanical components or structural supports. The structural supports for piping, cables, and components are evaluated in Section 2.2.3.1, "Component Supports," of this SER.

The remaining 13 device types are piping and mechanical components that perform passive functions. These device types are listed in Tables 5.12-1, 5.12-2, and 5.12-3 of Appendix A to the LRA. Some device types appear more than once in these tables. The staff finds that the applicant included all of these device types as subject to an AMR, which is acceptable.

The staff has reviewed the information presented in Section 5.12 of Appendix A to the LRA. On the basis of its review of selected structures and components, the staff finds reasonable assurance that the applicant has appropriately identified the structures and components subject to an AMR for the main steam, steam generator blowdown, extraction steam, and nitrogen and hydrogen systems in accordance with the requirements in 10 CFR 54.21(a)(1).

2.2.3.26 Nuclear Steam Supply System Sampling System

In Section 5.13, "Nuclear Steam Supply System Sampling System," of Appendix A to the LRA, the applicant described the structures and components of the NSSS sampling system at the plant site that are within the scope of license renewal, and identified which of these are subject to an AMR.

2.2.3.26.1 Summary of Technical Information in the Application

The NSSS sampling system is designed to permit the sampling of liquids, steam, and gases for radioactive and chemical control of plant primary fluids. The NSSS sampling system is comprised of five subsystems: reactor coolant sampling, steam generator blowdown sampling, radioactive miscellaneous waste sampling, gas analyzing sampling, and post-accident sampling.

	Reactor Coolant Sampling
	The reactor coolant sampling subsystem samples liquids and gases for analysis and control of chemical and radiochemical concentrations. The reactor coolant sampling subsystem consists of a SS sink enclosed inside a hood. The hood is ventilated by an individual blower through a high-efficiency filter. The hood contains piping, valves, coolers, instrumentation, and sample vessels necessary to take liquid and gaseous samples from various systems.
	Steam Generator Blowdown Sampling
	The steam generator blowdown sampling subsystem provides a means for sampling liquids from the steam generators to detect conditions that cause carryover, corrosion, and fouling of heat transfer surfaces, and to aid in detection of a possible reactor coolant-to-steam generator leak. This subsystem also provides a means for sampling reactor coolant makeup water. The steam generator blowdown sampling subsystem consists of one conditioning rack-panel unit and one ventilating hood installed for each unit; these are located inside the same sampling room as the reactor coolant sample hoods. The conditioning rack section of the steam generator blowdown subsystem contains isolation valves, primary coolers, rod-in-tube devices, an isothermal bath, and a chiller.
	Radioactive Miscellaneous Waste Sampling
	The radioactive miscellaneous waste sampling subsystem provides a means for sampling liquids from various radioactive waste processing systems to determine the chemical and radiochemical content preceding discharge, and to aid in evaluating the performance of waste system components. The radioactive miscellaneous waste sampling subsystem is located inside the ventilating hood for the Unit 1 steam generator blowdown sampling subsystem, and is used to obtain samples from which the chemical and radiochemical content of miscellaneous waste is determined. This subsystem is common to both units.
	Gas Analyzing Sampling
	The gas analyzing sampling subsystem provides a means for sampling gases to determine (1) the hydrogen concentration of the containment atmosphere and the reactor coolant waste tanks and (2) the oxygen concentration in the pressurizer quench tanks and various miscellaneous waste systems. This subsystem also provides a means for obtaining grab samples of gases in the containment atmosphere in the post-accident environment. This subsystem consists of two hydrogen analyzer cabinets, two hydrogen sample select cabinets with separate manifolds for isolation valves and sample selection solenoid valves, and one oxygen analyzer cabinet with a manifold for isolation valves. The two analyzer cabinets used for hydrogen measurement each include a sample pump, cooler, tubing, valves, and analyzer element. The analyzer cabinet used for oxygen grab sample measurement includes a sample pump, cooler, piping, valves, and a sample syringe port.
	Post-Accident Sampling
	The original post-accident sampling system (PASS) is no longer in service because of high maintenance and the unreliability of the system. The applicant modified the reactor coolant sampling and gas analyzing subsystem to provide a post-accident capability that relies, with one exception, on grab sample analyses to meet regulatory requirements for both the RCS and the containment atmosphere.

The LRA described the intended functions of the components in the NSSS sampling system and identified the systems, structures, and components considered within Section 5.13 of Appendix A to the LRA that are within the scope of license renewal, as defined in 10 CFR 54.4(a). These SSCs include accumulators, air dryers, piping, valves and valve operators, panels, instruments, sample vessels, heat exchangers, pumps, and associated electrical devices. Among these structures and components, the applicant identified the following device types as subject to an AMR: piping, accumulator, analyzer element, check valve, control valve, control valve operator, air dryer, flow indicator, flow indicator controller, flow orifice, hand valve, heat exchanger, pressure control valve, pressure indicator, pressure switch, pump/driver assembly, and solenoid valve. The applicant also identified electrical panels, electrical components, and cables as subject to an AMR.

2.2.3.26.2 Staff Evaluation

The staff reviewed Section 5.13 of Appendix A to the LRA, as well as additional information from the UFSAR and the piping and instrumentation drawings (P&IDs), to determine whether there is reasonable assurance that the applicant has identified and listed those structures and components for the NSSS sampling system that are within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements in 10 CFR 54.4 and 10 CFR 54.21(a)(1).

2.2.3.26.2.1 NSSS Sampling System Within the Scope of License Renewal

In the first step of its evaluation, the staff determined whether the applicant has properly identified the systems, structures, and components within the scope of license renewal. In Section 5.13.1.2 of Appendix A to the LRA, the applicant has identified the portion of the NSSS sampling system that is within the scope of license renewal, which includes all safety-related components (electrical, mechanical, and instrument) and their supports. The staff has reviewed the information in Section 5.13 of Appendix A of the LRA. On the basis of that review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the structures or components within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.26.2.2 NSSS Sampling System Subject to an Aging Management Review

The applicant has described the safety-related portion of the following subsystems that perform their intended function without moving parts or without changes in configuration or properties and categorized those structures and components into device types subject to an AMR (listed in Table 5.13-1 of Appendix A to the LRA).

RCS sample header isolation control valves (CVs), including all intervening piping and the connected test/vent/drain root valves;
Containment isolation solenoid-operated valves (SOVs) in the sample return lines from the reactor coolant sample hoods to the reactor coolant drain tank and the piping between these valves, including RCS tubing inside the containment;
Piping in the RCS sample headers between the RCS and the CVs, the test valves connected to this piping, and the isolation valves in the flow path;
Sample cooler in each of the reactor coolant sample hoods, including the shell and tubes; the hand valves in the sample lines from the charging pump discharge and the low pressure safety-injection pump discharge;
Steam generator (SG) blowdown sampling subsystem components from both the sample points in the SG blowdown piping through the tubes in the sample cooler, up to and including the rod-in-tube pressure-reducing hand valves downstream of the sample coolers in the conditioning racks;
Radioactive miscellaneous waste sampling subsystem hand valves in the spent fuel pool filter and demineralizer sampling lines including the sample coolers; and
All gas-analyzing sampling subsystem piping and components associated with sampling analysis of gases for hydrogen concentration, including the lines provided for sampling of oxygen concentration for each unit's pressurizer quench tank, the containment isolation SOVs, and the piping between these valves and the quench tanks.

The applicant has divided those structures and components of the NSSS sampling system into two groups of device types: one group of device type that is not subject to an AMR and the other that is subject to an AMR. The staff reviewed 100 percent of the information submitted in the application to verify that the applicant's grouping is correct.

Of the 36 device types within the scope of the license renewal rule, 24 device types are electrical/instrumentation components and the remaining 12 are mechanical components. The staff reviewed all device types in the scope of license renewal to verify that the applicant did not omit any device type that should be subject to an AMR. Of the 24 components, the applicant classified the following 14 as having only active functions and, therefore, not requiring an AMR:

analyzer alarm
analyzer indicator
analyzer recorder
analyzer converter (relay)
circuit breaker
voltage/current device
fuse
hand switch
power lamp indicator
relay
temperature controller
heater
position indicating lamp
position switch

Two device types, panel and control/power cabling, are evaluated in Section 2.2.3.32, "Cables"; and Section 2.2.3.33, "Electrical Commodities," of this SER. The following eight electrical/ instrumentation components are evaluated in this section; they were classified as subject to an AMR (only pressure boundary/body):

analyzer element
control valve
control valve operator
flow indicator
flow-indicator controller
pressure indicator
pressure switch
solenoid valve

The staff agrees with the applicant's determination, which is consistent with 10 CFR 54.21(a)(1).

As described above, the staff finds no omissions by the applicant; therefore, there is reasonable assurance that the applicant has identified the structures and components subject to an AMR for the NSSS sampling system.

The staff reviewed the information in Section 5.13 of Appendix A to the LRA and has determined that there is reasonable assurance that the applicant has appropriately identified the structures and components subject to an AMR for the NSSS sampling system to meet the requirements in 10 CFR 54.21(a)(1).

2.2.3.27 Radiation Monitoring System

In Section 5.14, "Radiation Monitoring System" (RMS), of Appendix A to the LRA, the applicant described portions of the RMS and their components that are within the scope for license renewal, and identified which of those components are subject to an AMR.

2.2.3.27.1 Summary of Technical Information in the Application

As described in Appendix A to the LRA, the RMS is designed to warn operating personnel about an increasing radiation level or abnormal radioactivity concentrations at selected points in the plant. This warning system may also indicate a system or component malfunction that needs operator action, or it may perform automatic protective actions to correct and/or isolate an abnormal condition to prevent an uncontrolled release of radioactive material to the environment. The RMS also monitors the releases of radioactive effluents from the plant so that the releases do not exceed allowable limits in accordance with 10 CFR Part 50, and are maintained ALARA in accordance with Appendix I to 10 CFR Part 50.

The RMS is divided into two subsystems: the area RMS and the process RMS. The area RMS includes area radiation monitors located throughout the plant, four containment area radiation monitors, and two containment high range gamma radiation monitors. The process RMS includes the plant's main vent radiation monitors, wide-range effluent gas radiation monitors, containment atmosphere radiation monitors, waste gas discharge radiation monitor, liquid waste processing discharge radiation monitor, condenser air removal discharge radiation monitor, component cooling system (CCS) radiation monitor, service water (SRW) system radiation monitor, steam generator blowdown tank discharge radiation monitor, steam generator blowdown recovery radiation monitor, atmosphere radiation monitors (includes the control room ventilation radiation monitor as well as other ventilation radiation monitors), and main steam effluent radiation monitors.

The RMS comprises the following types of equipment: piping/tubing (provides system flowpath and maintains pressure boundary), pumps (provide motive force to move fluids being sampled), valves (provide containment isolation and system alignment/isolation), filters (filter air to protect downstream components), and instrumentation/elements (provide information to operators and signals to control equipment).

The RMS is within the scope of license renewal based on 10 CFR 54.4(a). The following RMS intended functions were determined on the basis of the requirements of 10 CFR 54.4(a)(1) and 54.4(a)(2):

Provide containment area radiation signal to engineered safety features actuation system for containment isolation and radiological release control.
Provide containment high-range radiation signal for containment environment monitoring and for isolating the containment vent/hydrogen purge lines.
Maintain the pressure boundary of the system.
Provide containment isolation of the containment atmosphere and purge air monitor sampling line.
Monitor and record wide-range gaseous activity/release rate through the main plant vent and provide indications/alarms in the control room.
Monitor and record radiation levels indicative of effluent activity in the main steamlines and provide indications/alarms in the control room.
Provide testing capability and prevent spurious actuation of control room radiation monitoring circuitry.
Maintain electrical continuity and/or provide protection of the electrical system.
Provide seismic integrity and/or protection of safety-related components.

The applicant determined that the following were intended functions of the RMS based on the requirements of 10 CFR 54.4(a)(3):

Provide information to assess the environs and plant condition during and following an accident.
Maintain functionality of electrical equipment as addressed by the environmental qualification program.

On the basis of the intended functions listed above, the portions of the RMS that are identified by the applicant as within the scope of license renewal include the following equipment types: piping, components, component supports, instrumentation, panels, and cables associated with the following radiation monitors: containment area radiation monitors, containment high-range gamma radiation monitors, wide-range effluent gas radiation monitors, containment atmosphere radiation monitors, CCS radiation monitor, SRW system radiation monitor, control room ventilation radiation monitor, and main steam effluent radiation monitors. The shaded areas of Figures 5.14-1 through 5.14-8 of Appendix A to the LRA indicate the portions of the system within the scope of license renewal. The applicant identified a total of 33 device types within the scope of license renewal for this system. Of these 33 device types, the applicant identified 16 device types that were subject to an AMR. Of those 16 types, 5 were not evaluated as part of the RMS AMR, either because they are subject to a replacement program, they are evaluated in an AMR for another system, or they are evaluated in a commodity evaluation. The remaining 11 device types requiring an AMR specifically within the scope of the RMS are piping, check valve, control valve, hand valve, motor-operated valve, flow element, flow indicator, radiation element, filter, radiation test point, and solenoid valve. The applicant determined that for these 11 device types, retaining the pressure boundary and providing containment isolation are the only passive intended functions that are within the scope of the AMR for the RMS.

Both the low-range and mid/high-range pumps of the wide-range effluent gas radiation monitors are subject to maintenance replacement programs. The RMS components requiring an AMR that are evaluated in an AMR for another system are the component cooling system radiation monitor (evaluated in the CCS AMR), service water system radiation monitor (evaluated in the SRW system AMR), and control room ventilation radiation monitor (evaluated in the control HVAC [heating, ventilation, and air conditioning] system AMR).

The applicant also indicated that some components in the RMS that are common to many systems have been included in the commodity AMRs, which address those components for the entire plant. Therefore, they were not included in the individual system sections. These components are the following:

Structural supports for piping, cables, and components, which are evaluated for the effects of aging in Section 3.1 of Appendix A to the LRA;
Electrical cabling, which is evaluated in Section 6.1 of Appendix A to the LRA; and
Instrument tubing and piping and their associated fittings, instrument valves, and supports, which are all evaluated in Section 6.4 of Appendix A to the LRA.

2.2.3.27.2 Staff Evaluation

The staff reviewed Section 5.14 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has identified the RMS components and supporting structures that are within the scope of license renewal in accordance with 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding the RMS (NRC letter to BGE dated August 6, 1998), and by letter dated September 25, 1998, the applicant responded to those RAIs.

2.2.3.27.2.1 Radiation Monitoring System Within the Scope of License Renewal

As part of the first step of its evaluation, the staff reviewed portions of the UFSAR, including the piping and instrumentation diagrams (P&IDs) for the RMS, and compared them to the diagrams in Appendix A to the LRA to determine if there were any additional portions of the system piping and other components that the applicant should have identified as within the scope of license renewal. In an RAI, the staff identified the following radiation monitors and requested the bases for eliminating those monitors from the scope of license renewal: plant main vent monitor, waste gas discharge monitor, liquid waste processing discharge monitor, condenser air removal discharge monitor, steam generator blowdown tank discharge monitor, steam generator blowdown recovery monitor, and atmosphere monitor (other than the monitor for control room ventilation). In response to NRC Question No. 5.14.1, the applicant stated that the radiation monitors discussed above are non-safety-related and do not perform any of the system intended functions based on 10 CFR 54.4(a)(1), 54.4(a)(2), 54.4(a)(3), and 54.4(b). Further, the licensee clarified that although the non-safety-related plant main vents radiation monitors are not in the scope of license renewal, the safety-related wide-range effluent gas radiation monitors that monitor the plant main vents are in the scope. Although the non-safety-related containment atmosphere radiation monitors are not within the scope of license renewal, the containment penetrations, including the safety-related containment isolation valves, are within the scope of license renewal. Therefore, the staff finds the elimination of those monitors from the scope of license renewal acceptable because those monitors are non-safety-related and do not perform any of the functions specified in 10 CFR 54.4(a)(1), 54.4(a)(2), 54.4(a)(3) and 54.4(b).

During its review, the staff identified that in Figure 5.14-5, "Component Cooling System Radiation Monitors"; Figure 5.14-6, "Service Water System Radiation Monitors"; and Figure 5.14-7, "Control Room Ventilation Radiation Monitors" in Appendix A to the LRA, a number of radiation monitor instruments were not included in the scope of license renewal. The applicant explained in a telephone conference call on October 7, 1998, that the components functioning as a pressure boundary are within the scope of license renewal, but the components simply being used for the radiation monitoring function are not within the scope of license renewal because they do not perform a safety-related function. The staff finds this acceptable because those monitors are non-safety-related and do not perform any of the function specified in 10 CFR 54.4(a)(1), 54.4(a)(2), 54.4(a)(3), and 54.4(b). The staff also identified several valves in Figure 5.14-7, "Control Room Ventilation Radiation Monitors," and Figure 5.14-8, "Main Steam Effluent Radiation Monitors," as not being included within the scope of license renewal. The licensee explained that those valves are evaluated separately in Section 5.11C, "Control Room and Diesel Generator Building's Heating, Ventilating, and Air Conditioning Systems," and Section 5.12, "Main Steam, Steam Generator Blowdown, Extraction Steam, and Nitrogen and Hydrogen Systems," in Appendix A to the LRA.

The staff reviewed the UFSAR to determine if there were any safety-related system functions that were not identified as intended functions in the LRA to verify if there were any structures or components having intended functions that might have been omitted from within the scope of license renewal. As described in detail above, the staff found no omissions by the applicant. On the basis of the applicant's response and the supporting information in the UFSAR, the staff concludes that these portions of the RMS that were not identified as within the scope of license renewal did not perform any intended functions that would have designated these portions of the system to be within the scope of license renewal.

As described above, the staff has reviewed the information presented in Section 5.14 of Appendix A to the LRA and the additional information sent by the applicant in response to the staff's RAIs. On the basis of that review, the staff finds that there is reasonable assurance that the applicant has appropriately identified the portions of the RMS and the associated structures and components thereof that are within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.27.2.2 Radiation Monitoring System Subject to an Aging Management Review

In Section 5.14.1.2 of Appendix A to the LRA, the applicant identified which components from the radiation monitoring system (RMS) are within the scope of license renewal. The RMS is associated with the following radiation monitors: containment area radiation monitors, containment high-range gamma radiation monitors, wide-range effluent gas radiation monitors, containment atmosphere radiation monitors, component cooling system radiation monitor, service water system radiation monitor, control room ventilation radiation monitor, and main steam effluent radiation monitors. The applicant categorized structures and components into device types not subject to an AMR and device types subject to an AMR (listed in Table 5.14-1 of Appendix A to the LRA). The staff reviewed the information to verify that the applicant's grouping was correct. As described in detail below, the staff finds reasonable assurance that the applicant has identified the structures and components for the RMS that are subject to an AMR in accordance with 10 CFR 54.21(a)(1).

Of the device types within the scope of license renewal, 16 were determined to have passive intended functions and, therefore, to require an AMR. Of the 16 device types requiring an AMR, 12 are electrical/instrumentation components. The following five components are evaluated under Section 2.2.3.14, "Component Cooling System"; Section 2.2.3.30, "Service Water System"; Section 2.2.3.24, "Control Room and Diesel Generator Buildings' Heating, Ventilation, and Air Conditioning Systems"; Section 2.2.3.32, "Cables"; and Section 2.2.3.35, "Instrument Lines," of this SER.

CCS radiation element
SWS radiation element
control room ventilation radiation element
control/power cabling
instrumentation tubing/valves

The remaining seven electrical/instrumentation device types evaluated in this section were classified as subject to an AMR (only pressure boundary/body):

control valve
MOV
flow element
flow indicator
radiation test point
radiation element
solenoid valve

The staff also reviewed the non-electrical components in the radiation monitoring system in order to determine whether the applicant has properly identified the structures and components subject to an AMR. The staff reviewed the information in Table 5.14-1 of Appendix A to the LRA to ascertain that the applicant has identified all components that are subject to an AMR. The following components were identified as subject to an AMR:

piping
check valves
hand valves
filters

The staff has reviewed the information in Section 5.14.1.3 of Appendix A to the LRA and additional information submitted by the applicant in response to the staff's RAIs. On the basis of the staff's review of the information submitted by the applicant, the staff has determined that there is reasonable assurance that the applicant has appropriately identified the structures and components of the RMS that are subject to an AMR as required under 10 CFR 54.21(a)(1).

2.2.3.28 Safety Injection System

In Section 5.15, "Safety Injection System," of Appendix A to the LRA, the applicant described the structures and components of the safety injection (SI) system at the plant site that are within the scope for license renewal, and identified which of those structures and components are subject to an AMR.

2.2.3.28.1 Summary of Technical Information in the Application

As described in Appendix A to the LRA, the major functions of the SI system are to (a) supply emergency core cooling in the unlikely event of a loss-of-coolant accident (LOCA); and (b) increase shutdown margin after the rapid cooldown of the reactor coolant system (RCS) caused by a rupture of a main steam line. These functions are performed by injecting borated water into the RCS. The SI system is also utilized to (a) remove heat from the RCS during plant cooldown once RCS temperature is below 300 � F; (b) maintain suitable RCS temperatures during refueling and maintenance operations; and (c) provide storage capacity for borated water needed for spent fuel pool (SFP) and refueling pool operations. During normal plant operations, the SI system is maintained in a standby mode with components aligned for injection to the RCS.

The SI system consists of high-pressure and low-pressure subsystems that provide borated water to four SI headers, each connected to associated cold leg piping in the RCS. In addition to the associated piping, valves, controls, and instrumentation, the SI system for each CCNPP unit comprises the following major components:

Three electric motor-driven high-pressure safety injection (HPSI) pumps, each with an associated seal cooler;
Two electric motor-driven low-pressure safety injection (LPSI) pumps, each with an associated seal heat exchanger (HX);
Four safety injection tanks (SITs); and
A refueling water tank (RWT), with an associated electric motor-driven pump and heat exchanger (RWTHX).

The SI system is composed of the following categories of equipment and devices:

Piping--Convey borated water to perform system functions.
Valves--Control valves (CVs), check valves (CKVs), hand valves (HVs), motor-operated valves (MOVs), and relief valves (RLVs), which provide containment isolation and system alignment, isolation, and protection.
Instruments--Measure system flow rates, tank levels, and temperatures.
Tanks--Store borated water used for injection into the RCS and for refueling purposes.
HXs--Provide a heat sink for seal cooling water for system pumps, and prevent freezing of borated water in the RWT.
Pumps--Move borated water into the RCS, into the SITs, and into the RWT.

In Appendix A to the LRA, the applicant identified the following intended functions for the SI system and its components based on the requirements of 10 CFR 54.4(a)(1) and (2):

To provide borated water to the RCS for reactivity, pressure, and level control in response to design-basis events (DBEs) upon a safety injection actuation signal (SIAS);
To provide borated water passively to the RCS for reactivity, pressure, and, level control when RCS pressure drops below 200 psig;
To recirculate lost coolant back to the RCS and the containment spray (CS) system (recirculation mode);
To send a signal to the engineered safety features actuation system (ESFAS) for a recirculation actuation signal (RAS);
To provide long-term core flush via hot leg injection;
To provide containment isolation of the SI system during a loss-of-coolant accident;
To maintain the pressure boundary of the system (liquid and/or gas);
To maintain mechanical operability and/or protect the mechanical system;
To provide borated water from the RWT to the CS pumps;
To maintain electrical continuity and/or protect the electrical system;
To provide makeup water from the RWT to the SFP during a fuel handling incident; and
To restrict flow to a specified value in support of a DBE response.

The following SI system intended functions were determined based on the requirements of 10 CFR 54.4(a)(3):

For fire protection--To (a) provide RCS pressure and inventory control to ensure safe shutdown in the event of a severe fire, (b) provide RCS heat removal by realigning and operating in the shutdown cooling (SDC) mode, and (c) prevent inadvertent dumping of the SITs when RCS temperature is less than 300 �F;
For environmental qualification--To (a) provide information used to assess the environs and plant condition during and after an accident, and (b) maintain functionality of electrical components as addressed by the environmental qualification program; and
For station blackout--To (a) provide valve position indication and closure of containment isolation valves, and (b) provide RCS isolation to maintain RCS inventory.

All components of the SI system that meet the environmental qualification or station blackout criteria of 10 CFR 54.4(a)(3) are also safety-related.

On the basis of the intended functions described in Appendix A to the LRA, the portion of the SI system that is within the scope of license renewal includes all components (electrical, mechanical, and instrumental) and their supports associated with the storing and delivering of borated water to the RCS. The following system flowpaths allow transfer of borated water to the RCS interface at each of the four-loop inlet CKVs:

Injection mode flowpath (post-DBE operations after a SIAS; motive force provided by HPSI pumps)--from the RWT, through the running HPSI pumps (i.e., two of the three installed pumps), to the SI header CKVs and loop inlet CKVs by way of both (a) a main HPSI header and four main HPSI header MOVs and (b) an auxiliary HPSI header and four auxiliary HPSI header MOVs;
Injection mode flowpath (post-DBE operations after a SIAS; motive force provided by LPSI pumps)--from the RWT, through both LPSI pumps, into a common discharge header, through the LPSI flow CV, the four LPSI header MOVs, to the SI header CKVs and loop inlet CKVs;
Injection mode flowpath (post-DBE operations after RCS pressure drops below approximately 200 psig; motive force provided by pressurized SITs)--from each of the four SITs, through the open SIT outlet CKVs and SIT outlet MOVs, to the loop inlet CKVs;
Recirculation mode flowpath (post-DBE operations after a RAS; motive force provided by HPSI pumps)--from the interface with the containment emergency sump, through the containment sump discharge MOVs and through the HPSI injection mode flowpath described above; and
SDC mode flowpath (motive force provided by LPSI pumps)--from the RCS interface at the outlet of the SDC header return isolation MOV inside the containment, through the SDC header return isolation MOV outside the containment and through the LPSI injection mode flowpath described above, with a portion of the borated water passing through the shutdown cooling heat exchanger (SDCHX) LPSI inlet MOV into the CS system. After passing through the SDCHXs and the SDC temperature/flow CV in the CS system, this fluid reenters the SI system on the downstream side of the LPSI flow CV, rejoining the remainder of the borated water in the SDC mode flowpath.

The following system flowpaths are part of the system pressure boundary and are also within the scope of license renewal for the SI system:

Minimum-flow recirculation flowpaths for pumps (motive force provided by associated pumps)--from the discharge headers for each HPSI and LPSI pump through an associated flow orifice and mini-flow return CKV, and from the CS system interface at the outlet of each CS pump mini-flow return CKV through the mini-flow return to RWT isolation MOVs, through the common RWT recirculation header back into the RWT.
Circulation flowpath for the RWT--from the RWT, through the RWT circulating pump, the tubes in the RWTHX, and back into the RWT. (The RWTHX bonnets, covers, tubes, and associated SS welds form a part of the SI system pressure boundary. The intended function for other subcomponent parts of the RWTHX (i.e., the shell and associated carbon steel welds, fittings, studs, nuts, and vessel supports) is to provide structural support for the tube assembly. A pressure boundary breach of the plant heating system will not impact this support function.)
SDC recirculation flowpaths--from the CS system interfaces in the SDC return header (a) through the SDCHX recirculation stop CV to the LPSI pump suction header, or (b) to the common RWT recirculation header, or (c) through the SI-to-CVCS flow instrumentation to the CVCS interface at the outlet of the SDC supply to the CVCS backup HV.
Leakoff return flowpaths for each SIT--from the SI system piping between the SIT outlet and loop inlet CKVs, through the SIT CKV leakage CV, through common leakoff return piping and a flow orifice to (a) to the liquid waste system interface at the outlet of the leakoff-to-reactor coolant drain tank CV, or (b) through the normally closed SI leakoff return header isolation HVs to the common RWT recirculation header.

Additional components that are part of the system pressure boundary along these flowpaths (e.g., piping, instruments, seal coolers and HXs for pumps, SIT fill-and-drain CVs, normally closed HVs, RLVs, solenoid-operated valves in instrument air supply piping) and their supports are also within the scope of license renewal for the SI system

On the basis of the intended functions stated above, 53 device types were listed from the portions of the SI system that are identified by the applicant as within the scope of license renewal. Of these 53 device types, the applicant identified 16 that are subject to an AMR. The 16 device types are Class CC piping (-CC), Class DC piping (-DC), Class GC piping (-GC), Class HC piping (-HC), check valve (CKV), control valve (CV), flow element (FE), flow orifice (FO), hand valve (HV), heat exchanger (HX), motor-operated valve (MOV), pump/driver assembly (PUMP), relief valve (RLV), temperature element (TE), temperature indicator (TI), tank (TK).

The applicant also indicated that some components in the SI system that are common to many systems have been included in the separate commodity reports addressing those components for the entire plant in Appendix A of the LRA. Therefore, they were not included in the individual system sections. These components are:

Except for the RWTHX supports that are addressed in this section of the SER, structural supports for piping, cables, and components are evaluated for the effects of aging in the Component Supports Commodity Evaluation in Section 3.1 of Appendix A to the LRA. The RWTHX supports are evaluated as subcomponents of the HX device type.
Electrical control and power cabling is evaluated for the effects of aging in the Electrical Cables Commodity Evaluation in Section 6.1 of Appendix A to the LRA. This commodity evaluation completely addresses the passive intended function of maintaining electrical continuity and/or protecting the electrical system for the SI system.
Instrument tubing and piping and the associated tubing supports, instrument valves, and fittings (generally everything from the outlet of the final root valve up to and including the instrument), and the pressure boundaries of the instruments themselves, are all evaluated for the effects of aging in the Instrument Lines Commodity Evaluation in Section 6.4 of Appendix A to the LRA. This commodity evaluation partially addresses the passive intended function of maintaining the pressure boundary of the system (liquid and/or gas) for the SI system.

2.2.3.28.2 Staff Evaluation

The staff reviewed Section 5.15 of Appendix A to the LRA to determine whether the applicant has identified with reasonable assurance that the SI system components and supporting structures are within the scope of license renewal per 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). This was accomplished in two steps, as described in the following two subsections.

2.2.3.28.2.1 Systems, Structures, and Components Within the Scope of License Renewal

As part of the first step of its evaluation, the staff reviewed portions of the UFSAR for the SI system, and compared the information in the UFSAR with the information in Appendix A to the LRA to determine if there were any portions of the system piping and other components that the applicant should have identified as within the scope of license renewal. The staff then reviewed structures and components outside the portion identified by the applicant and, as described below, requested that the applicant provide additional information and/or clarifications for selected structures and components to verify that they do not have any of the intended functions listed in 10 CFR 54.4(a). The staff also reviewed the UFSAR for any safety-related system functions that were not identified as intended functions in Appendix A to the LRA to verify that no structure or component having an intended function was omitted from consideration within the scope of license renewal.

After completing the initial review, by letter dated September 2, 1998, the staff issued RAIs regarding the SI system. By letter dated November 9, 1998, the applicant's responded to those RAIs. NRC Question No. 5.15.1 asked the applicant to clarify why solenoid valves were listed on page 5.15-12 of Appendix A to the LRA as having only active functions. 10 CFR 54.21(a)(1) states that valve bodies are passive

In response, the applicant stated that the SI system, as shown in the drawings on pages 5.15-6 and 5.15-7 of Appendix A to the LRA, do not include any solenoid valve bodies within the evaluation boundary. The key provided with the drawings shows the components are flow orifices, control valves, hand valves, check valves, motor-operated valves, relief valves, and spool pieces. Solenoid valves are used in the non-safety related air supply to control valves in the SI system. Therefore, solenoid valves do not provide the pressure boundary function in the SI system and, therefore, are not within scope. Page 5.15-12 of Appendix A to the LRA is, therefore, correct in identifying solenoid valves as one of the 29 device types having only active functions.

The staff reviewed the applicant's response and the function of the solenoid valves. Although the staff did not agree with the applicant's basis for omitting the solenoid valves from an AMR, the staff determined from a review of the UFSAR that the control air solenoid valves do not perform an intended function under 10 CFR 54.21(a)(1) and therefore, should not have been included within the scope of license renewal to begin with. Therefore, the staff finds the applicant's decision to omit the solenoid valves from an AMR is acceptable.

Page 6.3-3 (Revision 18) of the UFSAR indicates that a small drain valve controlled remotely from the control room is intended to drain any leakage from the RCS into the SI system. NRC Question No. 5.15.2 asked the applicant to indicate if this valve is subject to an AMR, and if it is, to cross-reference where this is addressed in Appendix A to the LRA; if it is not, to give the basis for its exclusion. The applicant responded by stating that the drain valves described above are associated with the SITs. The valves are pneumatically operated control valves 1(2)CV611, 1(2)CV621, 1(2)CV631, and 1(2)CV641. These valves are opened to allow draining RCS in-leakage to the SITs and are represented on Figure 5.15-1 of Appendix A to the LRA immediately to the left of the SIT. These valves were subjected to an AMR, and are considered in the SI portion of Appendix A to the LRA as control valves.

Page 6.3-14 (Revision 21) of the UFSAR indicates that the containment sump suctions are enclosed by particulate screens. NRC Question No. 5.15.3 asked the applicant to clarify whether these screens are subject to an AMR, and if they are, to cross-reference where they are addressed in Appendix A to the LRA; if they are not, to provide the basis for exclusion. The applicant stated in its response that the containment sump particulate screens are considered in Section 3.3A, "Primary Containment Structure," of Appendix A to the LRA, and that they are specifically identified on page 3.3A-6 under "Unique Components."

As described above, the staff has reviewed the information in Section 5.15 of Appendix A to the LRA and the additional information submitted by the applicant in response to the staff's RAIs. On the basis of that review, the staff finds reasonable assurance that the applicant has appropriately identified those portions of the SI system and the associated (supporting) structures and components that fall within the scope of license renewal in accordance with the requirements of 10 CFR 54.4.

2.2.3.28.2.2 Safety Injection Systems Subject to an Aging Management Review

The applicant described the components of the safety injection (SI) system that are subject to an AMR in Section 5.15.1.3 of Appendix A to the LRA. The applicant divided structures and components within the scope of license renewal into device types not subject to an AMR and device types subject to an AMR (listed in Table 5.15-1 of Appendix A to the LRA). The staff reviewed the information to verify that the applicant's grouping was correct. As described in detail below, the staff finds that the applicant has made no omissions in classification. Therefore, the staff finds reasonable assurance that the applicant has identified the structures and components subject to an AMR for the SI system.

Of the 56 device types within the scope of the license renewal rule, 43 device types are electrical/instrumentation components. The staff reviewed the device types that are electrical/instrumentation components to verify that the applicant did not omit any electrical/instrumentation components that should be subject to an AMR. Of the 43 components, the applicant classified the following 29 as having only active functions and, therefore, not requiring an AMR:

circuit breaker
disconnect switch/link
fuse
current/pneumatic device
level indicator
4-kV motor
4-kV local control station (disconnect/link)
solenoid valve
power supply
MOV operator
coil
voltage/current device
flow device (relay)
control valve operator
flow indicator controller
handswitch
power lamp indicator
level device (relay)
solenoid
temperature transmitter
position indicating lamp
level indicator alarm
125/250-V dc motor
relay
temperature recorder
position indicator
position transmitter
ammeter
position switch

The following nine device types are evaluated in Section 2.2.3.32, "Cables," or Section 2.2.3.35, "Instrumentation Lines," of this SER:

pressure transmitter
level switch
level transmitter (except as noted below)
flow indicator
pressure indicator
control/power cabling
flow transmitter
pressure switch
instrument tubing/valve

The containment emergency sump level transmitters are being addressed separately as components that are subject to periodic replacement based on a qualified life or specified time period and do not require an AMR.

The following five electrical/instrumentation components evaluated in this section were classified as subject to an AMR (only pressure boundary/body):

control valve
temperature element
flow element
temperature indicator
MOV

According to 10 CFR 54.21(a)(1), an AMR is required for long lived/passive components that perform an intended function without moving parts or are not subject to replacement based on a qualified life or specified time period. The staff agrees with the applicant's determination, which is consistent with 10 CFR 54.21(a)(1).

Thirteen device types are mechanical components or structural components. Except for the refueling water tank heat exchanger (RWTHX), structural supports for piping, cables, and components are addressed in Section 2.2.3.1, "Component Supports" of this SER. The applicant included the RWTHX supports as a subcomponent of the HX. In addition, the expansion joint was evaluated in Section 2.2.3.4, "Primary Containment Structure," of this SER.

The remaining 11 device types listed in Table 5.15-1 are mechanical components that perform passive functions. The staff agrees with the applicant's inclusion of these devices as requiring an AMR. The 11 mechanical component device types requiring an AMR are identified as follows:

Class CC piping
Class DC piping
Class GC piping
Class HC piping
Check valve
flow orifice
hand valve
heat exchanger
pump/driver assembly
relief valve (RLV)
tank

As discussed above, the staff has reviewed the information presented in Section 5.15 of Appendix A to the LRA and the additional information provided by the applicant in response to the staff's RAIs. On the basis of that review, the staff finds reasonable assurance that the applicant has appropriately identified and listed those structures and components subject to an AMR for the SI system to meet the requirements stated in 10 CFR 54.21(a)(1).

2.2.3.29 Saltwater System

In Section 5.16, "Saltwater (SW) System," of Appendix A to the LRA, the applicant described the SW system and identified the SW components that are within the scope of license renewal, and identified which of those within-scope components are subject to an AMR.

2.2.3.29.1 Summary of Technical Information in the Application

As described in the LRA, the SW system is a safety-related, open-loop cooling-water system designed to remove heat from various safety-related heat exchangers and coolers. Each unit has three SW pumps that provide the driving head to transport SW from the intake structure, through the system, to the circulating water discharge conduits. The system is designed so that each pump has sufficient head to provide adequate cooling water for the service water (SRW) system, component cooling (CC) system, and emergency core cooling system (ECCS) pump room coolers, as required by General Design Criterion 44 of 10 CFR Part 50, Appendix A.

The SW system for each unit consists of two subsystems. Each subsystem provides SW to an SRW heat exchanger, a CC heat exchanger, and an ECCS pump room air cooler in order to transfer heat from these heat exchangers and coolers to the Chesapeake Bay, which is the ultimate heat sink (UHS) for the plant. During normal operation, both subsystems in each unit are in operation with one pump running on each header and a third pump in standby. If needed, the standby pumps can be lined up to either supply header in their respective units. The SW flow through the SRW and CC heat exchangers is throttled to provide sufficient flow to the heat exchangers, while maintaining total subsystem flow below a maximum value.

Operation following a loss-of-coolant accident (LOCA) has two phases: before the recirculation actuation signal (RAS) and after the RAS. After a LOCA but before the RAS, each subsystem will cool an SRW heat exchanger and an ECCS pump room air cooler. Flow to the ECCS pump room cooler is initiated only if required because of high room temperature. There is no flow to the CC heat exchanger during this phase and system flow is not throttled.

When the RAS is received, the minimum required flow to each SRW heat exchanger is reduced, flow to the CC heat exchangers is restored, and the flow to the ECCS pump room coolers remains the same as it was before the RAS.

In identifying the scope of the SW system license renewal evaluation, the applicant made an exception to the LRA boundary convention. The SRW and CC heat exchangers were included in the scope of the SW system evaluation even though heat exchangers are normally considered part of the system they cool. This exception was made because age-related degradation is much more severe on the SW side of the heat exchangers.

In Appendix A to the LRA, the applicant identified the following intended functions for the SW system based on 10 CFR 54.4(a)(1) and 54.4(a)(2):

Provide the vital auxiliary function of supplying cooling water to the CC and SRW heat exchangers and the ECCS pump room air coolers during design-basis events.
Maintain electrical continuity or protect the electrical system or both.
Maintain the pressure boundary of the system (liquid or gas).
Restrict flow to a specified value in support of a DBE response.

The applicant also determined that the following were intended functions of the SW system based on the requirements of 10 CFR 54.4(a)(3):

For post-accident monitoring--Provide information used to assess the plant and environs condition during and following an accident.
For environmental qualification--Maintain functionality of electrical components as addressed by the environmental qualification (EQ) program.
For fire protection--Provide the UHS for SRW and CC systems to ensure safe shutdown in the event of a fire.

On the basis of the intended functions listed above, the portions of the SW system that are identified by the applicant as within the scope of license renewal include the following components: SW pumps and motors; the SRW and CC heat exchangers; the ECCS pump room air coolers; air accumulators for control valves; and the associated piping, valves, instruments, and controls. The applicant identified a total of 40 device types from within these SW components as being within the scope of license renewal. Of these 40 device types, the applicant identified 20 that are subject to an AMR. The 20 device types are: 6 types of piping (6 different materials), 6 valve types (check, control, relief, solenoid, pressure control, and hand valve), heat exchanger, flow orifice, pump/driver assembly, accumulator, basket strainer, current-to-pneumatic transducer, temperature indicator, and temperature test point. The applicant noted that instrument line manual drain equalization, isolation valves, and some instrument test points are evaluated for the effects of aging in the instrument line commodity evaluation in Section 6.4, "Instrument Lines," of Appendix A to the LRA. The applicant further indicated that maintenance of the pressure boundary for the liquid or gas or both in the SW system and ability to restrict flow to a specified value in support of a design-basis event, are the only passive intended functions associated with the SW system that are not addressed in one of the commodity evaluations of the LRA.

As identified by the applicant, some components in the SW system are common to many systems and, therefore, have been included in the separate commodity report sections, which address those components for the entire plant. Hence, the following common components were not included in the individual system sections:

Structural supports for piping, cables, and components, which are evaluated for the effects of aging in Section 3.1, "Components Supports," of Appendix A to the LRA;
Electrical control and power cabling, which is evaluated in Section 6.1, "Cables," of Appendix A to the LRA; and
Instrument tubing and piping and their associated supports, instrument valves and fittings, and the pressure boundaries of the instrument themselves, which are all evaluated in Section 6.4, "Instrument Lines," of Appendix A to the LRA.

2.2.3.29.2 Staff Evaluation

The staff reviewed Section 5.16 of Appendix A to the LRA to determine whether there is reasonable assurance that the applicant has identified and listed the SW system components and supporting structures within the scope of license renewal per 10 CFR 54.4 and subject to an AMR in accordance with the requirements of 10 CFR 54.21(a)(1). After completing the initial review, the staff issued RAIs regarding the SW system (NRC letters to BGE dated August 28 and September 24, 1998), and by letters dated November 2 and 12, 1998, the applicant responded to those RAIs.

2.2.3.29.2.1 Saltwater System Within the Scope of License Renewal

As part of the first step of its evaluation, the staff reviewed portions of the UFSAR, including the flow diagrams for the SW system, to determine if there were portions of the system piping and other components that the applicant did not identify as within the scope of license renewal. In the LRA, the applicant identified interface boundaries with six other systems. These six interfacing systems are the SRW system, the CC system, the auxiliary building heating and ventilation system (ECCS pump room coolers), the circulating water system, the compressed air system, and the engineered safety features actuation system (ESFAS). Most of the major SW system flow path piping and the interfaces with other systems are within the scope of license renewal. License renewal interface boundaries exist only at the interfaces with the circulating water system, which is not within the scope of license renewal. On the SW side of the interface boundary, the system piping and other components are within the scope of license renewal while on the other side of the interface boundary, (the circulating water side) the piping and other components are not within the scope of license renewal. The staff reviewed all the identified license renewal interface boundaries within the SW system in addition to all the identified interface boundaries with other systems, structures, and components. The staff also reviewed the system flow diagrams to verify that there were no significant interface boundaries that were not identified by the applicant in the LRA. If the portions of the SW system beyond the license renewal interface boundary (i.e., portions of the system that are not within the scope of license renewal) were verified by the staff to have no intended functions, then the components within those portions of the system were also deemed to have no intended function and were eliminated from further consideration. The staff also reviewed the UFSA

Safety Evaluation Report Related to the License Renewal of Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (NUREG-1705)

Contents

Table of Contents

Publication Information

Abstract

Summary

1 Introduction and General Discussion

1.1 Introduction

1.2 License Renewal Background

1.2.1 Safety Reviews

1.2.2 Environmental Reviews

1.3 Summary of Principal Review Matters

1.4 Summary of Open and Confirmatory Items

2 Structures and Components Subject to an Aging Management Review

2.1 Methodology for Identifying Structures and Components Subject to an Aging Management Review

2.2 Identification of Structures and Components Subject to an Aging Management Review

2.2.1 Introduction

2.2.2 Staff's Approach to the Evaluation

2.2.3 Systems, Structures, and Components