IR 05000220/2005011

IR 05000220-05-011, 05000410-05-011; February 14 - 18, February 28 - March 4, 2005, April 4-8 and December 12-15, 2005. Nine Mile Point, Units 1 & 2; Report of Inspection of the Proposed Aging Management Procedures and Compliance with 10 CF

ML060610616
Person / Time
Site:	Nine Mile Point
Issue date:	03/02/2006
From:	White A Engineering Region 1 Branch 1
To:	O'Connor T Nine Mile Point
References
IR-05-011
Download: ML060610616 (32)

Text

rch 2, 2006

SUBJECT:

NINE MILE POINT NUCLEAR STATION - NRC LICENSE RENEWAL INSPECTION REPORT 05000220/20050011 and 05000410/2005011

Dear Mr. OConnor:

On December 15, 2006, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of your application for renewal of the Nine Mile Point Nuclear Station (NMPNS),

Units 1 and 2 license. The enclosed inspection report documents the final inspection findings which were discussed on January 26, 2006, with Mr. James Hutton, and other members of your staff, at an exit meeting available for public observation at the Assembly Hall, Town of Scriba, 42 Creamery Road, Oswego, NY.

The inspection was conducted in accordance with NRC Manual Chapter 2516, Policy and Guidance for the License Renewal Inspection Program, using NRC Inspection Procedure 71002, License Renewal Inspections. The inspection evaluated the methodology you proposed to address the requirement under 10 CFR 54.4 (a)(2) to identify non-safety systems that affect the function of safety systems and to determine the efficacy of selected aging management programs referenced in your application. Our inspection found that your license renewal activities were being implemented as described in your license renewal application.

The documentation supporting your application was in an auditable and retrievable form.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Duncan White, Acting Branch Chief Engineering Branch 1 Division of Reactor Safety Docket Nos. 50-220, 50-410 License Nos. DPR-63, NPF-69

Enclosure:

Inspection Report 05000220/2005011 and 05000410/2005011

Mr. Timothy OConnor 2

REGION I==

Docket Nos. 50-220, 50-410 License Nos. DPR-63, NPF-69 Report No. 05000220/2005011 and 05000410/2005011 Licensee: Nine Mile Point Nuclear Station, LLC (NMPNS)

Facility: Nine Mile Point, Units 1 and 2 Location: 348 Lake Road Oswego, NY 13126 Dates: February 14 - 18, February 28 - March 4, 2005 April 4 - 8, 2005, and December 12 - 15, 2005 Inspectors: M. Modes, Team Leader G. Meyer, Senior Reactor Engineer F. Bower, Senior Resident PBAPS T. OHara, Reactor Engineer C. Hott, Reactor Engineer S. Chaudhary, Reactor Engineer T. Burns, Reactor Engineer Approved by: Duncan White, Acting Branch Chief Engineering Branch 1 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000220/2005011, 05000410/2005011; February 14 - 18, February 28 - March 4, 2005,

April 4-8 and December 12-15, 2005. Nine Mile Point Nuclear Power Station, Unit 1 and Unit 2; report of inspection of the proposed aging management procedures and compliance with 10 CFR 54.4(a)(2) for the Nine Mile Point Nuclear Power Station, Unit 1 and Unit 2 application for renewed license.

This inspection of License Renewal activities was performed by six regional engineering inspectors and one resident inspector. The inspection program followed was NRC Manual Chapter 2516 and NRC Inspection Procedure 71002.

The NMPNS methodology for determining compliance with 10 CFR 54.4 (a)(2), as described in the application, appears to be rigorous enough to identify all the systems, structures, and components that should be within scope. In the case of the aging management programs, the team was able to conclude that the programs will reasonably manage the effects of aging.

This inspection did not identify any findings as defined in NRC Manual Chapter 0612.

ii

REPORT DETAILS

4OA2 Other

a.

License Renewal

(1) Inspection Scope This inspection was conducted by NRC Region I inspectors in order to verify that documentation, procedures, guidance, and personnel, appropriately supports the license renewal application. This inspection reviewed the proposed methodology used to comply with 10 CFR 54.4(a)(2). The efficacy of the methodology was verified by independently evaluating selected systems, structures, and components (SSCs) against the rule and comparing the results with those obtained by using the applicants proposed methodology. The systems were selected based on insights from the staffs review of the license renewal application, uniqueness, safety impact, and risk insights. The inspection evaluated whether the scoping process adequately includes non safety-related SSCs whose failure could prevent safety-related SSCs from accomplishing a safety function. These non safety-related SSCs should be included within the scope of license renewal in order to provide protection against safety function failure in cases where the safety-related structure or component is not itself impaired by age-related degradation, but is vulnerable to failure from the failure of another structure or component that may be so impaired. Consideration of hypothetical failures that could result from system interdependencies that are not part of the current licensing bases and that have not been previously experienced is not required. It should be noted that the scoping criterion required under 10 CFR 54.4(a)(2) does not apply to functions identified in 10 CFR 54.4(a)(3) Regulated Events.

This inspection also reviewed the proposed procedures for managing the effects of aging in the systems, components, and structures determined, previously, to be within the scope of license renewal and for which an aging effect applied. The aging management program can be either an existing program, an existing program modified for the purpose of aging management, or a new program credited with managing the aging effects on within scope systems in the Nine Mile Point Nuclear Power Station (NMPNS). The team selected a sample of aging management procedures to verify the adequacy of the applicants documentation and to determine if adequate evaluations as well as industry experience and historical reviews were conducted to determine all the aging effects managed by an aging management program. For the selected aging management procedure, systems were reviewed to determine wether the proposed aging management procedure would adequately manage the effects of aging in that system. The inspectors interviewed applicant personnel to confirm the accuracy of the license renewal application conclusions. For a sample of plant systems and structures determined to require aging management, inspectors performed a visual examination of accessible portions of the systems to observe aging in effect in those systems. These inspection techniques were used to conclude if there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

During the inspection period of February 14 - 18, February 28 - March 4, 2005, it was mutually concluded that the quality of the NMPNS application, supporting information, and referenced programs, needed to be improved. The NRC and NMPNS further mutually agreed to defer the next steps in the application review process in order to give NMPNS adequate time to improve the quality of their submittal. In order to assist NMPNS, the NRC inspection team issued an interim report (Inspection Report 05000220/2005006 and 05000410/2005006) recording the areas identified by the team that needed NMPNS attention. Attachment 2 of this report contains a discussion of the resolution of those areas identified in the interim report.

(2) Observations and Findings Scoping of Non Safety-Related Systems, Structures, and Components To assess the thoroughness and accuracy of the screening and scoping of non-safety related (NSR) SSCs, as required in 10 CFR 54.4(a)(2), the inspectors reviewed NMP program guidance procedures and summaries of results for Units 1 and 2. The inspectors determined the applicants procedures to be consistent with the guidance in Sections 3, 4, and 5 of Appendix F to NEI 95-10, Revision 5 (related to NSR scoping for current licensing basis, NSR directly connected to safety-related, and NSR not directly connected to safety-related, respectively). Also, the inspectors determined the summary of scoping results and drawings demonstrated an appropriate application of the guidance.

In addition to preliminary technical reviews, the applicant had confirmed the scoping and screening results during walkdowns of all applicable plant areas by qualified plant personnel. The inspectors interviewed personnel and independently inspected numerous areas within the plant to confirm that appropriate SSCs had been included within the license renewal scope that SSCs excluded from the license renewal scope had an acceptable basis, and that the boundary for within/outside scope within the systems were appropriate, including anchors. For SSCs selected from the results, the inspectors confirmed that the in-plant configuration was accurate and acceptably categorized, and for SSCs selected within the plant, the inspectors confirmed that the categorization result in program documents was appropriate. The in-plant areas and systems reviewed included the:

• Unit 1 Reactor Building;

• Turbine Building;

• Off-gas Building;

• Intake Structure;

• Rad-waste Building;

• Fire Protection System;

• Feedwater System;

• Reactor Building Ventilation System;

• Unit 2 Reactor Building;

• Turbine Building;

• Service Water Valve Pit;

• Condensate Storage Tank Building;

• Turbine Building Closed Loop Cooling System;

• Electro-hydraulic Control System;

• Radiation Monitoring System; and

• Fire Protection System.

The inspectors determined the personnel involved in the process were knowledgeable and appropriately trained, and that the applicant had implemented an acceptable method of screening and scoping of non-safety related SSCs.

One Time Inspection Program The One-Time Inspection Program is a new aging management program intended to verify the effectiveness of other aging management programs, or verify an aging management program is not required, by confirming that unacceptable degradation has not occurred and the intended function of a component will be maintained during the extended period of operation. Additionally, the One-Time Inspection Program will be used to confirm that an aging effect is occurring so slowly as to not affect the component or structures intended function. The One-Time Inspection Program will be implemented prior to the period of extended operation. Programs covered by this program:

Water Chemistry. The program applies to stagnant or low flow areas only.

Samples will be aggregated based on similar characteristics.

Fuel Oil Program. This program applies to above and below ground fuel oil tanks.

Small Bore Class 1 Piping. This program applies to Class 1 piping less than four inches directly connected to the reactor coolant pressure boundary with inspections using existing non-destructive evaluation processes. This program will require further development because there is currently no completely reliable method of non-destructively examining this configuration.

Selective Leaching. This program will sample underground piping vulnerable to this aging effect. The sample size will be selected from the entire population in a manner that will provide 90% confidence that 90% of the population does not have the degradation.

The applicant plans to use American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI techniques to monitor and inspect parameters for degradation. The terminology and methodology for selecting samples are planned to be consistent with EPRI TR-107514, Age-Related Degradation Inspection Method and Determination.

Based on discussions with applicant personnel and reviews of supporting documents, the inspectors concluded that the applicant has plans to develop adequate guidance for implementation of the One-Time Inspection Program. Therefore, the One-Time Inspection Program will provide reasonable assurance that the program will adequately manage the effects of aging.

Closed-Cycle Cooling Water System Program The closed-cycle cooling water system program is an existing program that manages the loss of material and fouling of components exposed to closed-cycle cooling water environments. The applicable piping systems include: the Unit 1 and Unit 2 reactor building closed loop cooling systems; the Unit 1 control room heating, ventilation, and air-conditioning system; the Unit 2 control building chilled water system; the heat exchanger jacket water cooling portions of the Unit 1 emergency diesel generator system; the Unit 2 standby diesel generator protection system; and, a portion of the Unit 1 turbine building closed loop cooling system. The program activities included chemistry monitoring, surveillance testing, and component inspections in a manner consistent with EPRI TR-107396.

Based on discussions with applicant personnel and reviews of supporting documents, the inspectors concluded that the applicant has adequate guidance for implementation of the closed-cycle cooling water system program. Therefore, the closed-cycle cooling water system program will provide reasonable assurance that the program will adequately manage the effects of aging.

Open-Cycle Cooling Water System Program The Open-Cycle Cooling Water System (OCCWS) Program is an existing program that manages aging of components exposed to raw, untreated water. The program activities included:

(a) surveillance and control of biofouling (including biocide injection);

(b) verification of heat transfer capabilities for components cooled by the service water system;

(c) inspection and maintenance;

(d) walkdown inspections; and,

(e) review of maintenance, operating and training practices and procedures.

Inspections could include visual, ultrasonic testing, and eddy current testing methods.

The OCCWS is based on the recommendations of GL 89-13. The OCCWS Program includes checking for erosion-corrosion of system components.

The applicant plans to use functional surveillance testing and inspections as part of the OCCWS program to indirectly verify that loss of material due to corrosion has not negated the heat removal capability of the applicable systems.

Based on discussions with applicant personnel and reviews of supporting documents, the inspectors concluded that the applicant has plans to develop adequate guidance for implementation of the Open-Cycle Cooling Water System program. Therefore, the Open-Cycle Cooling Water System program will provide reasonable assurance that the program will adequately manage the effects of aging.

Systems Walkdown Program The systems walkdown program (SWP) is an existing program requiring enhancement to manage the aging effects for accessible external surfaces of selected systems and structures. The SWP is credited with managing the loss of material from external surfaces (aging effect) of pumps, valves, piping, bolts, heat exchangers, tanks, expansion joints, electrical penetrations, electrical enclosures and cabinets, HVAC components, and other carbon steel components. Program activities include system engineer walkdowns (i.e., field evaluations of system components to assess system performance and material condition), evaluation of inspection results, and appropriate corrective actions.

Although the SWP is not described in the Generic Aging Lessons Learned (GALL), the program was evaluated against the ten

(10) elements described in Appendix A of NUREG-1800. Procedure S-TDP-REL-0101 was revised in its entirety to address specific aging management attributes and issued August 18, 2005. The procedure includes very specific guidance related to aging management including attachments that contain system specific aging management walkdown checklists. Attachment 6, for example, gives specific periodicity guidance and Attachment 7 gives very specific guidance related to the license renewal rule.

The inspectors concluded the applicant had conducted adequate evaluations as well as industry experience and historical reviews to determine aging effects managed by an aging management program (AMP). The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

Water Chemistry Control Program The water chemistry control program is an existing program credited with managing the aging effects in the reactor vessel and internals and connected primary systems, as well as the condensate and feedwater systems at both Units. The aging effects are managed by the monitoring and control of system chemistry to minimize the effects of corrosion and crack initiation in system materials. The water chemistry program conforms to the guidelines in the boiling water reactor vessel and internals project (BWRVIP-29) and EPRI TR-103515. The inspectors reviewed the chemistry procedures and the sampling results for both Units and confirmed that the requirements of BWRVIP-29 and EPRI TR-103515 were being followed.

The inspectors concluded the applicant had conducted adequate evaluations as well as industry experience and historical reviews to determine aging effects managed by an AMP. The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

Flow-Accelerated Corrosion Program The flow-accelerated corrosion program is an existing program modified for the purpose of aging management. The program is credited with managing the erosion and corrosion aging effects in high-energy carbon and low alloy steel piping systems at both Units. The aging effects are managed by identifying erosion and corrosion inside affected system piping and by predicting wear rates to support the proactive replacement of system piping. Additionally, the program provides for periodic system reviews and visual inspections during component disassembly for repair or replacement.

The inspectors reviewed selected portions of the condensate, feedwater and main steam systems which are subject to erosion and corrosion and determined that the program was monitoring the appropriate portions of these systems. The inspectors also reviewed the piping ultrasonic testing wall thickness results from previous inspections and reviewed the CHECKWORKS computer analysis of the future wall thickness forecasts. The inspectors noted that in all instances where pre-emptive piping replacement was accomplished, the replacement piping material used was more resistant to erosion and corrosion than the original piping material.

The inspectors concluded the applicant had conducted adequate evaluations as well as industry experience and historical reviews to determine aging effects managed by an AMP. The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

Boraflex Monitoring Program The boraflex monitoring program is an existing program credited with managing the aging effects in the boraflex spent fuel storage racks in both Units. The aging effects are managed by periodic monitoring of representative samples of the boraflex material and through sampling of the spent fuel pool silica concentrations. The data from these monitoring programs are then used to verify that the required 5% sub-criticality margin is maintained in both spent fuel pools. The inspectors reviewed the operation of the spent fuel pool cooling systems and the records of silica sampling and past inspection reports from boraflex coupon examinations. Based upon this review, the inspector, concluded that the licensee had implemented an appropriate program for managing the aging of the boraflex material in the spent fuel racks.

The inspectors concluded the applicant had conducted adequate evaluations as well as industry experience and historical reviews to determine aging effects managed by an AMP program. The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

Compressed Air Monitoring Program (Unit 1 only)

The compressed air monitoring program (Unit 1) is an existing program modified to manage the aging effects in Unit 1 compressed air systems. The aging effects are managed by periodic maintenance and inspection of the system compressors and air dryers and by inspections of the exterior system piping. The inspectors reviewed the results of the maintenance and inspection procedures completed on the system compressors and air dryers. The inspectors noted that the external piping inspections were not sufficient to monitor the internal condition of the system piping. Thus, the licensee has committed to develop an additional program feature to monitor the internal condition of the system piping before the period of extended operation.

The inspectors concluded the applicant had conducted adequate evaluations as well as industry experience and historical reviews to determine aging effects managed by an AMP program. The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

BWR Vessel Internals Program The BWR vessel internals program is an existing program credited with managing the material and crack growth aging affects in reactor vessel internal systems. The aging effects are managed by material inspections and by controlling the reactor water chemistry. The inspectors reviewed the inspection program for the reactor vessel internals in both Units. The inspectors reviewed the records of past inspections and numerous deviation event reports (DERs) which had been generated to document the reporting and evaluation of past inspection results. The licensees reactor vessel internals inspection program is based upon the BWRVIP program documents. All of the BWRVIP reports, except BWRVIP-76, have been approved by the NRC for the aging management of BWR reactor vessel internals.

The inspectors concluded the applicant had conducted adequate evaluations as well as industry experience and historical reviews to determine aging effects managed by an AMP program. The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

Torus Monitoring Program (Unit 1 only)

The torus monitoring program is an existing program credited with managing the degradation of the torus wall thickness aging effects. The aging effects are managed by periodically measuring the wall thickness and by comparing the results to predicted values developed from past thickness measurements.

The inspectors reviewed the data collected during the last set of torus wall measurements and the projections for future wall thickness measurements. The present thickness measurements and the present corrosion rates predict that the torus wall thickness will remain above the minimum thickness through the period of extended operation. The program commits the licensee to measuring the torus wall thickness for each outage and recalculating the time to reach minimum wall thickness.

The inspectors concluded the applicant had conducted adequate evaluations as well as industry experience and historical reviews to determine aging effects managed by an AMP program. The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

Non-Environmentally Qualified (EQ) Electrical Cables and Connections Program The non-EQ electrical cables and connections program is a new program credited with managing the aging effects of in-scope cables and connections that are not subject to the environmental qualification requirements of 10 CFR 50.49. The aging effects result from exposure to adverse localized environments caused by heat, radiation, and moisture. Connections include connectors, splices, electrical penetration assembly pigtails, terminal blocks, and fuse blocks.

The aging effects will be managed by inspecting a representative sample of cables and connections for jacket surface anomalies in each identified adverse localized environment every ten years. If unacceptable anomalies are identified, the inspection sample will be expanded and corrective actions will be implemented. The team reviewed program bases documents, DERs, and industry guidance. The inspectors also conducted interviews and performed walkdowns with plant personnel.

The inspectors concluded the applicant had conducted adequate evaluations as well as industry experience and historical reviews to determine aging effects managed by an AMP program. The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

Non-EQ Fuse Holder Inspection Program The non-EQ fuse holder inspection program is a new program credited with managing the aging effects of fuse holder metallic clamps at Nine Mile Point Nuclear Station and that is not subject to the environmental qualification requirements of 10 CFR 50.49. The aging effects result from exposure to environmental stressors such as radiation, moisture, fatigue, mechanical stress, vibration, electrical transients, oxidation, corrosion, thermal cycling, and chemical contamination.

The aging effects are planned to be managed by monitoring the condition of all in-scope fuse holder metallic clamps subject to the applicable environmental stressors every ten years. This condition monitoring is planned to be achieved by thermography, contact resistance testing, or other appropriate proven testing method. The team reviewed program bases documents, DERs, and industry guidance. The inspectors also conducted interviews and performed walkdowns with plant personnel.

The inspectors concluded the applicant had conducted adequate evaluations as well as industry experience and historical reviews to determine aging effects managed by an AMP program. The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

BWR Penetrations Program The BWR penetrations program is an existing program that is incorporated into the BWR Vessel Internals Program (BWRVIP). The BWR penetrations program is credited with managing the crack initiation and growth aging effects in BWR penetrations by implementing chemistry controls to minimize inter-granular stress corrosion cracking.

The aging effects are managed through augmented inspection, flaw evaluation, and repair as necessary in conformance with the NRC approved guidelines of BWRVIP-49 and BWRVIP-27. The inspectors reviewed BWR penetrations inspection results, BWR penetrations inspection schedules, BWRVIP documents, nuclear engineering reports, and DERs. The team also conducted interviews with plant personnel. Inspection results and DERs documented the applicants ability to identify and evaluate BWR penetrations flaws. The penetration schedules and scope were consistent with the guidelines of BWRVIP-49 and BWRVIP-27.

The inspectors concluded the applicant had conducted adequate evaluations as well as industry experience and historical reviews to determine aging effects managed by the BWR penetrations program. The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the BWR penetrations will be maintained through the period of extended operation.

Fire Protection Program The fire protection program is an existing program credited with managing the fire barrier aging effects in fire protection systems. The aging effects are managed by periodic inspection of fire barrier penetration seals, fire barrier walls, ceilings, and floors, and all fire rated doors. The program is credited with managing loss of material aging effects in fuel oil lines of the diesel driven fire pump through periodic testing of the pump. This aging management program will also manage the aging effects of in-scope carbon dioxide and halon suppression systems once enhancements are made to periodically inspect these systems. The inspectors reviewed the fire protection program as well as supporting documents to verify the effectiveness of the fire protection program. The inspectors also conducted interviews and performed walkdowns of various fire protection systems with plant personnel.

The inspectors concluded the applicant had conducted adequate evaluations as well as industry experience and historical reviews to determine aging effects managed by the fire protection program. The applicant has provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the fire protection systems will be maintained through the period of extended operation.

Fire Water System Program The fire water system program is an existing program modified for the purpose of aging management credited with managing the loss of material and biofouling aging effects in fire water systems in Nine Mile Point Station. The aging effects are managed by periodic maintenance, testing, and inspection of system piping and components in accordance with codes and standards.

The team reviewed program bases documents, completed testing and maintenance procedures, DERs, design documents, and industry guidance. The inspectors also conducted interviews and performed walkdowns of the fire water system with plant personnel. A large part of the fire water system is maintained in a pressurized state which provides the applicant with constant system integrity status. The piping internals are routinely inspected at various locations throughout the system for loss of material and biofouling. Enhancements the applicant has committed to include ultrasonic wall thickness testing at representative points in the system of above grade piping, as well as inspections of below grade piping, on the basis of opportunity, in accordance with the buried piping and tanks program.

The inspectors concluded the applicant had conducted adequate evaluations, as well as industry experience and historical reviews to determine aging effects managed by the fire water system program. The applicant has provided or is planning to provide adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the fire water system will be maintained through the period of extended operation.

Overhead Heavy Load and Light Load Handling Systems The overhead heavy load and light load handling systems program (crane inspection program) is an existing program that will be modified to be consistent with the requirements of NUREG-1801,Section XI.M23. The program manages loss of material due to corrosion of cranes. Program activities include periodic maintenance and pre-operational equipment inspections. The crane inspection activities are based on the applicable industry standards and NUREG-0612 guidance.

The inspectors reviewed the program described in the Program Attribute Assessment document. The crane inspection program at NMP is implemented through existing plant maintenance procedures, and are monitored in accordance with the maintenance rule requirements prescribed by 10 CFR 50.65. The inspectors also reviewed the maintenance rule implementing procedures and the inspection results to determine the effectiveness and relevance of the maintenance rule program to the aging management program. The inspectors observed that the program attributes were consistent with the GALL. Also, the team noted that the inspections have not identified any corrosion or material fatigue related degradation. Crane rails and other structural components of the crane are visually inspected on a routine basis for degradation, and functional tests are performed to assure their integrity.

The inspectors concluded the applicant had conducted adequate evaluations, as well as industry experience and historical reviews to determine aging effects managed by an AMP program. The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

Selective Leaching of Materials Program The selective leaching of materials program is a new program that is credited with managing the effects of aging in components that are susceptible to selective leaching.

This program is a part of the one time inspection program discussed in Section B2.1.21 of the application. The program covers the aging management of potentially susceptible components, such as valve bodies, valve bonnets, pump casings, and heat exchanger components in plant systems.

The inspectors reviewed the program described in the Program Attribute Assessment document, License Renewal Application, Section B2.1.21, and the draft maintenance/inspection procedure. The inspectors observed that the scope of the procedure identified areas, commodities, and components that require aging management review for one time inspection. The selective leaching of materials program includes the detection of loss of material and/or mechanical integrity due to selective leaching on internal surfaces of components made of gray cast iron, bronze, or brass that are exposed to raw water, treated water, or brackish water. The draft procedure appeared to be consistent with Section XI.M33 of the Generic Aging Lesson Learned (GALL) Report.

The inspectors concluded the applicant had conducted adequate evaluations, as well as industry experience and historical reviews to determine aging effects managed by an AMP program. The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

Structural Monitoring and Masonry Wall Program The structural monitoring and masonry wall program is an existing program credited with managing the aging effects in structures, including masonry walls. The masonry walls program is a part of a comprehensive Structural Monitoring Program that upon enhancement will be consistent with GALL Report,Section XI.S6, Structural Monitoring Program, and Section XI.S5, Masonry Walls Program.

The team reviewed the License Renewal Application, Sections B2.1.27 and B2.1.28, and the program Attribute Assessment document. The team observed that the structural monitoring, including masonry walls, are covered by the 10 CFR 50.65, Maintenance Rule. The NRC Regulatory Guide 1.160, Rev.2, and NUMARC 93-01, Rev. 2, provide guidance for an acceptable structural monitoring, including masonry walls, program. Also, NRC Bulletin 80-11, Masonry Wall Design, and NRC Information Notice 87-67, Lessons Learned from Regional Inspections of Licensee Actions in Response to IE Bulletin 80-11 provide an acceptable basis for a masonry wall program.

The team noted that the program, as detailed and discussed in the MR implementing procedures for Structural/Masonry Wall Program, was consistent with the GALL Report.

The current program implemented for satisfying MR covers safety-related structures.

However, a planned enhancement will include masonry fire walls in turbine buildings and screen houses in both Units. The team reviewed the historical monitoring and maintenance inspection results to determine the effectiveness of the existing program.

The inspectors concluded the applicant had conducted adequate evaluations, as well as industry experience and historical reviews to determine aging effects managed by an AMP program. The applicant provided adequate guidance to ensure aging effects are appropriately managed. Thus, there is reasonable assurance the effects of aging will be adequately managed and the intended function of the SSCs will be maintained through the period of extended operation.

SUMMARY The NMPNS methodology for determining compliance with 10 CFR 54.4 (a)(2), as described in the application, appears to be rigorous enough to identify all the SSCs that should be within scope.

In the case of the aging management programs, the team was able to conclude that the programs will reasonably manage the effects of aging.

ATTACHMENTS:

1.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Flaherty, Fleet Licensing Manager

S. Leonard, NMP Licensing

J. Dosa, Principle Engineer

D. Shaw, Supervisor Licensing

G. Wrobel, Ginna Licensing

D. Wilson, Ginna Licensing

B. Holston, Manager NMP Engineering

P. Mazzaferro, NMP Site Lead License Renewal

M. Fallin, NMP Anapolis Lead

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

None

Closed

None

Discussed

None