IR 05000373/2015008

IR 05000373/2015008; 05000374/2015008; 09/28/2015 - 10/16/2015; LaSalle County Station, Units 1 & 2; License Renewal Inspection. (Sns)

ML15323A064
Person / Time
Site:	LaSalle
Issue date:	11/18/2015
From:	Christine Lipa NRC/RGN-III/DRS/EB2
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2015008
Download: ML15323A064 (47)

Text

UNITED STATES ber 18, 2015

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2 LICENSE RENEWAL SCOPING, SCREENING, AND AGING MANAGEMENT INSPECTION REPORT 05000373/2015008; 05000374/2015008

Dear Mr. Hanson:

On October 16, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed a License Renewal inspection at your LaSalle County Station, Units 1 and 2. On October 16, 2015, the NRC inspectors discussed the results of this inspection with Mr. Harold Vinyard, and other members of your staff. The results of this inspection are documented in the enclosed report.

The purpose of this inspection was to examine activities that support the license renewal application for LaSalle County Station, Units 1 and 2. The inspection addressed the processes of scoping and screening plant equipment to select equipment subject to an aging management review, and development and implementation of aging management programs to support a period of extended operation. As part of the inspection, the NRC examined procedures and representative records, interviewed personnel, and visually examined accessible portions of various systems, structures, or components, to verify license renewal boundaries, and to observe any equipment aging effects.

The team concluded that the scoping, screening, and existing aging management license renewal activities, were generally conducted as described in LaSalle County Station, Units 1 and 2, License Renewal Application and as supplemented through your responses to requests for additional information from the NRC. The team also concluded that documentation supporting the application was generally in an auditable and retrievable form. In addition, the team concluded the implementation of the proposed aging management programs, as described in the License Renewal Application with the proposed enhancements and, as supplemented through your responses to NRC requests for additional information and inspection observations, should provide reasonable assurance that the intended functions of vital plant systems, structures, and components will be maintained through the period of extended operation. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Christine Lipa, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-373; 50-374 License Nos. NPF-11; NPF-18

Enclosure:

Inspection Report 05000373/2015008; 05000374/2015008

REGION III==

Docket Nos: 05000373; 05000374 License Nos: NPF-11; NPF-18 Report No: 05000373/2015008; 05000374/2015008 Licensee: Exelon Generation Company, LLC Facility: LaSalle County Station, Units 1 and 2 Location: Marseilles, IL Dates: September 28 - October 16, 2015 Inspectors: Stuart Sheldon, Senior Reactor Engineer (Lead)

Benny Jose, Senior Reactor Engineer Jennifer Bishop, Reactor Engineer Michael Jones, Reactor Engineer Gerard ODwyer, Reactor Engineer Lionel, Rodriguez, Reactor Engineer Approved by: Christine Lipa, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

Inspection Report 05000373/2015008; 05000374/2015008; 09/28/2015 - 10/16/2015; LaSalle

County Station, Units 1 & 2; License Renewal Inspection.

This inspection of the applicant's license renewal scoping, screening, and aging management processes was performed by five inspectors based in the Region III office. The team applied U.S. Nuclear Regulatory Commission (NRC) Manual Chapter 2516 and NRC Inspection Procedure 71002 as guidance for performing this inspection. No findings as defined in NRC Manual Chapter 0612 were identified.

NRC-Identified and Self-Revealing Findings

No findings of significance were identified

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

INSPECTION SCOPE

This inspection was conducted by U.S. Nuclear Regulatory Commission (NRC)

Region III inspectors. The inspection was performed in accordance with NRC Manual Chapter 2516 and NRC Inspection Procedure (IP) 71002, License Renewal Inspection, dated November 23, 2011.

This inspection looked at both the applicants scoping and screening methodology and Aging Management Programs (AMPs), as described in the applicants license renewal application (LRA) titled, Application for Renewed Operating Licenses, dated December 9, 2014, (ADAMS Accession Nos. ML14343A840, ML14343A841, ML14343A842, ML14343A883, and ML14343A897), and as revised in subsequent correspondence from the applicant to the NRC.

The Attachments to this report list the documents reviewed, and the acronyms used.

2. VISUAL OBSERVATION OF PLANT EQUIPMENT

During this inspection, the team performed walkdowns of portions of plant systems, structures, and components (SSCs). These walkdowns were intended to determine the acceptability of the scope boundaries, to observe the current condition of the SSCs, and to assess the likelihood that a proposed AMP would successfully manage the associated aging effects. Specifically, the team conducted walkdowns of accessible portions of:

• Auxiliary Building;

• Condensate Storage Tanks;

• Containment Tendons;

• Cooling Lake Intake Flume;

• Diesel Fuel Oil Storage Tanks;

• Diesel Generator Buildings;

• Fire Protection and Fire Water System in Turbine Building and Reactor Building;

• Lake Screen House ;

• Masonry Walls in Reactor Building, Auxiliary Building and Turbine Building;

• Turbine Building;

• Unit 2 Core Standby Cooling System- Essential Cooling Water System Divisions 1, 2 and 3 Pump Rooms;

• Unit 2 Service Air System;

• Unit 2 Nonessential Cooling Water System; and

• U1 Standby Liquid Control System.

Any issues identified were entered into the applicants Corrective Action Program (CAP)and are listed under documents reviewed.

3. REVIEW OF SCOPING AND SCREENING METHODOLOGY

In order to assess the applicants scoping and screening methodology, the team reviewed a sample of SSCs including nonsafety-related SSCs that the applicant determined were not within the scope of license renewal in accordance with Title 10, Code of Federal Regulations (CFR), Part 54.4(a)(2). Specifically, the team reviewed applicable documents, interviewed applicant staff, and conducted walkdowns of accessible portions of the following SSCs:

• Cathodic Protection System;

• Diesel Generator Buildings;

• Miscellaneous Instrumentation System The team also reviewed documentation evaluating the equipment associated with the regulated events listed in 10 CFR 54.4(a)(3).

Based on the portions of systems reviewed, the team concluded the applicant had performed scoping and screening of SSCs in accordance with the methodology described in the LRA and the rule.

4. REVIEW OF AGING MANAGEMENT PROGRAMS

The team assessed the adequacy of current implementation of existing AMPs credited in the applicants LRA. This included verification the current AMPs would ensure aging effects would be managed so that there was reasonable assurance an SSCs intended function would be maintained throughout the period of extended operation. For those programs indicated by the applicant as being consistent with NUREG-1801, Generic Aging Lessons Learned (GALL) Report, the team confirmed the applicants program included the GALL attributes. For those programs which the applicant indicated were new or being enhanced, the team confirmed commitments existed and were sufficient to support future implementation. For those programs where the applicant indicated they intended to take exception to the GALL, the team reviewed the exceptions against the GALL recommendations and evaluated the acceptability of the applicants proposal.

The team also conducted walkdowns of selected in-scope SSCs to assess how plant equipment was being maintained under the current operating license and to visually observe examples of nonsafety-related equipment determined to be in-scope due to their proximity to safety-related equipment and their potential for failure due to aging effects.

The inspectors reviewed the following AMPs referenced by their section in the applicants LRA.

(1) American Society of Mechanical EngineersSection XI Inservice Inspection, Subsections IWB, IWC, and IWD (B.2.1.1)

The Inservice Inspection (ISI) Program is an existing program intended to be consistent with the program described in NUREG-1801, Rev. 2,Section XI.M1, [American Society of Mechanical Engineers] ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD. The program is intended to manage the aging effects of cracking and reduction in fracture toughness for ASME Class 1, 2, and 3 piping and components exposed to the reactor coolant environment using visual, surface, and/or volumetric and leakage testing as specified in the ASME Code Edition of record,Section XI, for Class 1, 2, and 3 pressure-retaining components and their integral attachments. The examinations, scheduling, acceptance criteria, flaw evaluation, and re-examinations are in accordance with the requirements identified in ASME Section XI with NRC-approved alternatives. Repair and replacement activities for these components are covered in Subsection IWA of the ASME Code Edition of record.

Additional limitations, modifications, and augmentations approved under the provisions of 10 CFR 50.55a with NRC-approved alternatives are included as a part of this program. Every 10 years this program is updated to the latest ASME Section XI Code Edition and addendum approved by the NRC per 10 CFR 50.55a.

The team reviewed the License Renewal Program basis documentation, implementing procedures, ISI Program documents, completed ISI records, corrective action documents, and the LRA. The team also interviewed the responsible applicant staff.

The team concluded the continued implementation of the ISI Program, as described in the LRA, should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(2) Water Chemistry (B.2.1.2)

The Water Chemistry aging management program is an existing program that is intended to be consistent with the program described in NUREG-1801,Section XI.M2, Water Chemistry, with one exception to use more recent guidance. The program manages loss of material, cracking, and fouling in components exposed to a treated water environment through periodic monitoring and control of water chemistry. The Water Chemistry Program monitors and controls water chemistry parameters such as pH, chloride, conductivity, and sulfate. The applicants program is based on Boiling Water Reactor Vessel and Internals Project (BWRVIP)-190, [Boiling Water Reactor]

BWR Water Chemistry Guidelines - Mandatory, Needed, and Good Practice Guidance, Revision 1 which is a revision to the guidance cited in NUREG-1801.

The team reviewed the LRA, License Renewal Program basis documentation, plant specific operating history documents, recent surveillance results, and corrective action documents. The team compared implementing procedures against industry guidance to verify the applicants program was consistent with NUREG-1801,Section XI.M2.

In addition, the team interviewed the AMP owner, and other applicant staff.

The team concluded continued implementation of the Water Chemistry AMP, as described in the LRA, should provide reasonable assurance the applicable aging effects will be managed for the period of extended operation, consistent with the licensing basis.

(3) Reactor Head Closure Stud Bolting (B.2.1.3)

The Reactor Head Closure Stud Bolting Program is an existing program intended to be consistent with the program described in NUREG-1801, Rev. 2,Section XI.M3, Reactor Head Closure Stud Bolting, with the following two exceptions.

NUREG-1801 recommends, as a preventive measure, using bolting material that has an actual measured yield strength less than 1,034 megapascals (150 kilo-pounds per square inch) for closure studs to reduce the potential for stress corrosion cracking (SCC) or intergranular stress corrosion cracking (IGSCC). LaSalle is taking an exception to NUREG-1801 because they have test data indicating that all installed bolting components on Unit 1, and 12 of the studs on Unit 2 may have an actual measured yield strength greater than the recommendation. LaSalle is also taking an additional exception to NUREG-1801 because they have test data indicating that uninstalled replacement studs previously purchased for Units 1 and 2 may have an actual measured yield strength greater than the recommendation.

The program intends to manage the aging effects of cracking due to SCC or IGSCC, and loss of material due to wear or corrosion, for reactor vessel closure stud bolting.

It intends to do this by the use of ISI examinations required by the ASME Code of record,Section XI, and the use of preventive measures. The program uses ISI visual, surface, and volumetric examination and inspection requirements to detect cracking, loss of material, and leakage. Acceptance criteria and evaluation of indications are in accordance with ASME Section XI. Preventive measures used to address reactor head closure stud degradation, as recommended in NUREG-1339 and NRC Regulatory Guide (RG) 1.65, include avoiding the use of metal-plated stud bolting, use of an acceptable surface treatment, and use of stable lubricants.

The team reviewed the License Renewal Program basis documentation, aging management review documents, implementing procedures, completed ISI records, corrective action documents, and the LRA. The team also interviewed the responsible applicant staff.

The team concluded the continued implementation of the Reactor Head Closure Stud Bolting Program, as described in the LRA with the proposed exceptions, should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(4) Boiling Water Reactor Vessel ID Attachment Welds (B.2.1.4)

The BWR Vessel Inside Diameter (ID) Attachment Welds Program is an existing program intended to be consistent with the program described in NUREG-1801, Rev. 2,Section XI.M4, BWR Vessel ID Attachment Welds. The program is intended to manage the aging effects of cracking of reactor vessel internal attachments in conformance with the guidelines of BWRVIP-48-A. The guidelines of BWRVIP-48-A include inspection recommendations and evaluation methodologies for the attachment welds between the vessel wall, and vessel ID brackets that attach safety-related components to the vessel. The guidelines include: information on the geometry of the vessel ID attachments; evaluate susceptible locations and safety consequences of failure; provide recommendations regarding the method, extent, and frequency of inspection; and discuss acceptable methods of evaluating the structural integrity significance of flaws detected during these examinations.

The program also provides for repair and/or replacement, as needed, to maintain the ability to perform the intended function. The program is applicable to structural welds for BWR reactor vessel internal integral attachments and provides reasonable assurance of the long-term integrity, and safe operation of BWR vessel ID attachment welds.

The team reviewed the License Renewal Program basis documentation, implementing procedures, completed inspection records, corrective action documents, and the LRA.

The team also interviewed the responsible applicant staff.

The team concluded the continued implementation of BWR Vessel ID Attachment Welds Program, as described in the LRA, should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(5) Boiling Water Reactor Feedwater Nozzle (B.2.1.5)

The BWR Feedwater Nozzle Program is an existing program intended to be consistent with the program described in NUREG-1801, Rev. 2,Section XI.M5, BWR Feedwater Nozzle. The program is intended to manage the aging effects of cracking due to cyclic loading in the feedwater nozzles. It monitors for cracking through the use of examinations performed in accordance with the recommendations GE-NE-523-A-71-0594, Rev. 1, and the requirements of the ASME Code Edition of record,Section XI. Cracking is evaluated and dispositioned in accordance with the ASME Code. The licensee has also implemented recommendations in NUREG-0619, BWR Feedwater Nozzle and CRD Return Line Nozzle Cracking, to mitigate or prevent thermally induced fatigue cracking of the feedwater nozzles.

The team reviewed the License Renewal Program basis documentation, existing plant drawings, implementing procedures, program documents, completed inspection records, and the LRA. The team also interviewed the responsible applicant staff.

The team concluded continued implementation of the BWR Feedwater Nozzle Program, as described in the LRA, should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(6) Boiling Water Reactor Control Rod Drive Return Line Nozzle (B.2.1.6)

The BWR Control Rod Drive (CRD) Return Line Nozzle Program is an existing program intended to be consistent with the program described in NUREG 1801, Rev. 2,Section XI.M6, BWR CRD Return Line Nozzle. The program is intended to manage the aging effect of cracking of the CRD return line nozzle through the performance of inspections in accordance with the ASME Code Edition of record. Cracking found during ISIs is evaluated in accordance with ASME Code Section XI requirements.

The licensee implemented the recommendations in NUREG-0619 to mitigate cracking due to thermal fatigue. The CRD return line nozzles for Units 1 and 2 were capped and the CRD return lines to the reactor vessels were removed and not rerouted prior to power operations. Therefore, consistent with the recommendations of NUREG-0619, no augmented ISI examinations are required.

The team reviewed the License Renewal Program basis documentation, implementing procedures, design documents, completed inspection records, and the LRA. The team also interviewed the responsible applicant staff.

The team concluded continued implementation of the BWR CRD Return Line Nozzle Program, as described in the LRA, should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(7) Boiling Water Reactor Stress Corrosion Cracking (B.2.1.7)

The BWR SCC Program is an existing program intended to be consistent with the program described in NUREG-1801, Rev. 2,Section XI.M7, BWR SCC. The program is intended to manage SCC and IGSCC in stainless steel and nickel-based alloy piping and piping welds containing reactor coolant. Scheduled volumetric examinations are conducted to detect IGSCC and leakage of coolant in accordance with the methods, inspection guidelines, and flaw evaluation criteria delineated in:

(1) the ASME Code Edition of record;

(2) NUREG-0313, Revision 2;

(3) NRC Generic Letter (GL) 88-01, including its Supplement 1; and

(4) NRC-approved BWRVIP-75-A. The program also includes preventive measures such as induction heating stress improvement and mechanical stress improvement to minimize SCC. Reactor coolant water chemistry is also controlled to reduce susceptibility to SCC or IGSCC.

The team reviewed the License Renewal Program basis documentation, implementing procedures, completed inspection records, corrective action documents, responses to request for additional information (RAIs), and the LRA. The team also interviewed the responsible applicant staff.

The team concluded continued implementation of the BWR SSC Program, as described in the LRA and with acceptable resolution of the associated RAIs, should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(8) Boiling Water Reactor Penetrations (B.2.1.8)

The BWR Penetrations Program is an existing program intended to be consistent with the program described in NUREG-1801, Rev. 2,Section XI.M8, BWR Penetrations.

The program is intended to manage the aging effect of cracking of the instrument penetrations, CRD housing and incore-monitoring housing (ICMH) penetrations, and the standby liquid control (SLC)/Core Plate differential pressure (dP) penetrations due to cyclic loading or SCC and IGSCC. The program monitors the penetrations as part of the ISI Program per the ASME Code Edition of record,Section XI, and uses the inspection and flaw evaluation recommendations of NRC-approved BWRVIP-49-A for instrumentation penetrations, BWRVIP-47-A for CRD housing and ICMH penetrations, and BWRVIP-27-A for SLC/Core Plate dP penetrations.

The team reviewed the License Renewal Program basis documentation, implementing procedures, completed inspection records, a program self-assessment, and the LRA.

The team also interviewed the responsible applicant staff.

The team concluded continued implementation of the BWR Penetrations Program, as described in the LRA, should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(9) Boiling Water Reactor Vessel Internals (B.2.1.9)

The BWR Vessel Internals Program is an existing program that, with the following enhancements, is intended to be consistent with the program described in NUREG-1801, Rev. 2,Section XI.M9, BWR Vessel Internals. The applicant, under commitment number nine of the LRA, plans to enhance their existing program by performing assessments of reactor vessel internal components fabricated from cast austenitic stainless steels (CASS) to determine their susceptibility to loss of fracture toughness due to thermal aging embrittlement and neutron irradiation embrittlement.

The information will then be used to specify required periodic inspections of CASS components determined to be susceptible, with initial inspections to be performed either prior to or within 5 years after entering the period of extended operation.

The program is intended to manage the aging effects of cracking, loss of material, and loss of fracture toughness for BWR vessel internal components due to SCC, IGSCC, or irradiation-assisted stress corrosion cracking using inspection and flaw evaluation in accordance with Section XI of the ASME Code Edition of record, and applicable BWRVIP reports. The BWR vessel internal components included in the program are the core shroud, core plate, core spray, shroud support, jet pump assembly, low-pressure coolant injection (LPCI) coupling, top guide, CRD housings, lower plenum, and steam dryer. The effects of cracking are monitored by the use of in-vessel visual inspection and volumetric examination techniques. The program also includes inspections of components fabricated from X-750 material to identify cracks that may be indicative of degradation due to thermal aging and neutron irradiation embrittlement.

The team reviewed the License Renewal Program basis documentation, corrective action documents, implementing procedures, completed inspection records, responses to RAIs, and the LRA. The team also interviewed the responsible applicant staff.

The team concluded the continued implementation of the BWRVIP with the proposed enhancements, as described in the LRA and with adequate resolution of the associated RAIs, should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(10) Flow-Accelerated Corrosion (B.2.1.10)

The Flow Accelerated Corrosion (FAC) AMP is an existing program that is intended to be consistent with the program described in NUREG-1801,Section XI.M17, Flow Accelerated Corrosion, as modified by License Renewal Interim Staff Guidance (ISG)

License Renewal ISG 2012 01, Wall Thinning Due to Erosion Mechanisms with one proposed exception. The program manages the loss of material due to wall thinning caused by FAC for carbon steel piping and components through:

(a) performing an analysis to determine systems susceptible to FAC;

(b) conducting appropriate analysis to predict wall thinning;

(c) performing wall thickness measurements based on wall thinning predictions and operating experience; and

(d) evaluating measurement results to determine the remaining service life and the need for replacement or repair of components.

The exception identified during NRC audit (ML15196A115) was that LRA Section B.2.1.10 stated the FAC Program is based on NSAC-202L, Revision 3; however the program had been revised to incorporate Revision 4 which had not been approved by the NRC for License Renewal. The Office of Nuclear Reactor Regulation (NRR) issued RAI B.2.1.10, which required justification of the use of Revision 4 vice Revision 3. Applicant responded in letter RS-15-193 (ML15218A421)with justifications for the use of Revision 4 vice Revision 3.

The team reviewed the LRA, License Renewal Program basis documentation, implementing procedures, program documents, and procedures. The team also interviewed the FAC AMP owner, other knowledgeable site personnel, corporate License Renewal personnel, and reviewed the determination of systems susceptible to FAC.

The team concluded that other than the exception, which will be evaluated in the Safety Evaluation Report (SER), the AMP appears to be consistent with the GALL Report and should provide reasonable assurance that the aging effects will be managed. In addition, the final evaluation of the AMP, the response to the RAI and the proposed exception will be documented in the SER.

(11) Bolting Integrity (B.2.1.11)

The Bolting Integrity AMP is an existing program intended to be consistent with the program described in NUREG-1801,Section XI.M18, Bolting Integrity, with six enhancements as described in the LRA and revised by RAI response letter RS-15-194 dated August 6, 2015. The program manages the aging affects associated with closure bolting on pressure retaining joints within the scope of license renewal for loss of preload, cracking, and loss of material due to corrosion with enhancements to include various non-pressure retaining bolting. This program credits inspection of pressure retaining bolted joints which is performed in accordance with the applicable requirements ofASME Section XI, and plant operating experience and includes consideration of the guidance contained in NUREG-1339, Resolution of Generic Safety Issue 29: Bolting Degradation or Failure in Nuclear Power Plants, Electric Power Research Institute (EPRI) documents NP 5769, Degradation and Failure of Bolting in Nuclear Power Plants, and TR 104213, Bolted Joint Maintenance and Application Guide.

The team reviewed License Renewal Program basis documentation, existing inspection procedures, corrective action documents, and the LRA. The team also interviewed the AMP owner, other responsible site and corporate applicant staff and associated license renewal contractors. The team also walked down a sample of safety-related pressure retaining bolting on the components of the plant open cycle cooling water system (Essential Cooling Water System (ECWS)) located inside the Unit 2 Division 1, 2, and 3 ECWS pump rooms for evidence of visible leakage or other age-related degradation. No significant issues were identified.

A previous NRC Audit (ML15196A115) verified that Enhancements 1 and 5 had been implemented. During this inspection, the team verified that Enhancements 2, 3, 4, and 6 had also been accomplished or would be accomplished before the period of extended operation.

The team concluded continued implementation of the Bolting Integrity AMP, as described in the LRA with the proposed enhancements should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation. The final evaluation of the program with enhancements will be documented in the SER.

(12) Open-Cycle Cooling Water System (B.2.1.12)

The Open-Cycle Cooling Water (OCCW) system AMP is an existing program that, with enhancements, is intended to be consistent with the program described in NUREG-1801,Section XI.M20, OCCW System. The program manages loss of material and fouling for safety related service water system components and some non-safety-related service water systems (as described in the LRA) fabricated from carbon steel, copper alloys, and stainless steel and exposed to raw water as described in the LaSalle response to NRC GL 89-13, and the LRA.

This existing program will include four enhancements as described in the LRA.

These enhancements, as documented in Commitment 12, are to perform a minimum of 10 microbiologically influenced corrosion (MIC) degradation inspections for aboveground piping in the Essential and Non-Essential Cooling Water Systems every 24 months until the rate of MIC occurrences no longer meets the criteria for recurring internal corrosion; select an inspection method that will provide indication of suitable wall thickness to perform inspections on a representative sample of buried piping to supplement the aboveground piping inspection locations; and perform visual inspections of the interior surface of buried portions of the Essential Cooling Water System and Non-Essential Cooling Water System whenever the piping internal surface is made accessible due to maintenance and repair activities.

The team reviewed License Renewal Program basis documentation, existing procedures and surveillance results, corrective action documents, license renewal boundary drawings, and the LRA. The team also interviewed the licensees designated AMP owner, other responsible applicant staff and associated license renewal contractors and corporate staff. The team walked down portions of the nonsafety-related Unit 2 Non-Essential Service Water System, and did not identify any evidence of visible leakage or other age-related degradation. The team also conducted walkdowns of portions of the safety-related OCCW systems, which include the subsystems of residual heat removal service water, diesel generator cooling water and emergency makeup. No significant issues were identified.

The team concluded the implementation of the OCCW system AMP, as described in the LRA with the proposed enhancements, should provide reasonable assurance that the aging effects will be managed, consistent with the licensing basis, during the period of extended operation. The final evaluation of the program with enhancements will be documented in the SER.

(13) Closed Treated Water Systems (B.2.1.13)

The Closed Treated Water Systems AMP is an existing program that is intended to be consistent with the program described in NUREG-1801,Section XI.M21A, Closed Treated Water Systems. This is a mitigating and condition monitoring program that includes:

(a) nitrite-based water treatment, including pH control and the use of corrosion inhibitors to modify the chemical composition of the water such that the function of the equipment is maintained and such that the effects of corrosion are minimized;

(b) chemical testing of the water to ensure that the water treatment program maintains the water chemistry within acceptable guidelines; and

(c) inspections to determine the presence or extent of corrosion, stress corrosion cracking, or fouling.

The program will be enhanced to inspect a representative sample of piping and components at least once every 10 years during the period of extended operation.

The team reviewed the LRA, License Renewal Program basis documentation, plant specific operating history documents, recent surveillance results, and corrective action documents. The team compared implementing procedures against industry guidance in EPRI TR-1007820, Closed Cooling Water Chemistry Guideline Rev.1 to verify the applicants program was consistent with NUREG-1801,Section XI.M21A. In addition, the team interviewed the AMP owner, and other applicant staff.

The team concluded continued implementation of the Closed Treated Water Systems AMP, as described in the LRA, should provide reasonable assurance the applicable aging effects will be managed for the period of extended operation, consistent with the licensing basis.

(14) Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems (B.2.1.14)

The Inspection of Overhead Heavy-Load and Light-Load (Related to Refueling)

Handling Systems AMP is an existing program that, with enhancement, is intended to be consistent with the program described in NUREG 1801,Section XI.M23, Inspection of Overhead Heavy-Load and Light-Load (Related to Refueling) Handling Systems.

This program is intended to manage the effects of loss of material on the bridge rails, bridge, and trolley structural components for those cranes, hoists, rigging beams, and refueling equipment used to handle light-loads that are within the scope of license renewal. The program will also manage loss of preload of associated bolted connections. The components are in an air indoor or treated water environment.

Enhancements include providing additional guidance to consistently include inspection of structural components, rails, and bolting for loss of material due to corrosion; rails for loss of material due to wear; and bolted connections for loss of preload.

The team reviewed License Renewal Program basis documentation, implementing inspection procedures, response to RAIs, Condition Reports, and the LRA. In addition, the team interviewed the responsible applicant staff and performed walkdowns and remote visual inspection of the refueling crane and auxiliary building hoists for visible evidence of structural degradation and cracks. No significant concerns were identified during the walkdown.

The team concluded the implementation of the Overhead Heavy-Load and Light-Load (Related to Refueling) Handling Systems AMP, as described in the LRA with the proposed enhancements, should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(15) Compressed Air Monitoring (B.2.1.15)

The Compressed Air Monitoring AMP is an existing program which, with an enhancement, is intended to be consistent with NUREG-1801,Section XI.M24, Compressed Air Monitoring," with an exception to monitor dew point quarterly as opposed to recording and trending daily dew point readings. The program manages material loss in compressed air systems by periodically monitoring air samples for moisture and contaminants, and inspecting internal surfaces within compressed air systems. Current program activities include that periodic internal visual inspections of critical components are performed to detect signs of corrosion and air quality is monitored, and trended to determine if alert levels or limits are being approached or exceeded.

The team reviewed the License Renewal Program basis documentation, implementing procedures, CAP documents, procedures, work documents and the LRA. The team walked down portions of the Unit 2 Service Air System and did not identify any issues (e.g., instances of previously unidentified corrosion). The team also interviewed the Compressed Air AMP owner, and other knowledgeable site and corporate license renewal personnel.

The team concluded implementation of the Aboveground Metallic Tanks AMP as described in the LRA should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation. The final evaluation of the program with enhancements and proposed exception will be documented in the SER.

(16) Fire Protection (B.2.1.16)

The Fire Protection AMP is an existing Condition Monitoring Program that, with enhancements, is intended to be consistent with the program described in NUREG-1801,Section XI.M26, Fire Protection. This program includes fire barrier and low-pressure carbon dioxide system visual inspections and functional tests. The Fire Barrier Inspection Program requires periodic visual inspection of fire barrier penetration seals, fire barrier walls, ceilings, floors, and other materials that perform a fire barrier function. Periodic visual inspection of and functional testing of the fire rated doors and visual inspection of fire rated dampers is performed to ensure their functionality is maintained. The program also includes visual inspections and periodic functional tests of the low-pressure carbon dioxide fire suppression systems using the National Fire Protection Association (NFPA) codes and standards for guidance.

The applicant has proposed the following enhancements to the program in the LRA:

• Perform periodic visual inspection of combustible liquid spill retaining curbs.

• Perform periodic visual inspection for identifying corrosion that may lead to loss of material on the external surfaces of the low-pressure carbon dioxide fire suppression systems.

• Provide additional inspection guidance to identify aging effects as follows:

• Fire barrier walls, ceilings, and floors degradation such as spalling, cracking, and loss of material for concrete.

• Elastomeric fire barrier material degradation such as loss of material, shrinkage, separation from walls and components, increased hardness, and loss of strength.

• Provide additional inspection guidance to identify degradation of fire barrier penetration seals for aging effects such as loss of material, cracking, increased hardness, shrinkage, and loss of strength.

The team reviewed License Renewal Program basis documents, program health report, condition reports, aging management review documents, and existing procedures. The team also interviewed the program owner to determine current condition and results of the inspection and surveillance requirements. To evaluate the material condition of components managed by this AMP, the team conducted walkdowns of the carbon dioxide tanks, and the fire protection piping in turbine and reactor buildings.

The team concluded the implementation of the Fire Protection AMP should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(17) Fire Water System (B.2.1.17)

The Fire Water System AMP is an existing program that, with enhancements, is intended to be consistent with the program described in NUREG-1801,Section XI.M27, Fire Water System." This program manages loss of material and biofouling for components in fire water systems. The program is implemented using inspection and monitoring activities, including flush test and testing or replacing sprinkler heads using the guidance of NFPA Standard 25, 2011 Edition. The applicant has proposed 10 enhancements to the program in the LRA to perform various tests including volumetric, visual and flow in different sections and components of the fire water system.

The team reviewed program basis documentation, AMP documents, existing procedures and surveillance results, condition reports, license renewal boundary drawings, and the application. The team also interviewed responsible applicant staff and conducted walkdowns of accessible portions of the fire water system, including components such as pumps, sprinklers, hose stations, and piping.

The team concluded the implementation of the Fire Water System AMP, as described in the LRA with the proposed enhancements, should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(18) Aboveground Metallic Tanks (B.2.1.18)

The Aboveground Metallic Tanks AMP is an existing program intended to be consistent with the program described in NUREG-1801,Section XI.M29, Aboveground Metallic Tanks, as modified by License Renewal ISG-2012-02 with enhancements. During the audit, the staff identified a difference between the LRA AMP and the GALL Report AMP that should have been identified as an exception. The evaluation of the staff-identified difference will be documented in the SER.

The team reviewed License Renewal Program basis documentation, drawings, tank photos, CAP documents, work order documents and effectiveness data. The team interviewed the AMP owner, other responsible applicant site and corporate staff and associated license renewal contractors. During an NRC audit (ML15196A115)degradation of the caulking at the bottoms of the Unit 1 Condensate Storage Tank (CST)and the Unit 2 CST was identified and entered into the CAP. The team conducted walkdowns of the in-scope Unit 1 CST and Unit 2 CST. During the walkdowns, the inspectors identified that the caulking at the bottom of the tanks had been repaired and was in good condition.

The team concluded implementation of the Aboveground Metallic Tanks AMP as described in the LRA should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

The final evaluation of the program with enhancements and the NRR staff-identified difference will be documented in the SER.

(19) Fuel Oil Chemistry (B.2.1.19)

The Fuel Oil Chemistry AMP is an existing program that, with enhancements, is intended to be consistent with the program described in NUREG-1801,Section XI.M30, Fuel Oil Chemistry. This program includes surveillance and maintenance activities that monitor fuel oil chemistry to provide assurance that contaminants are maintained at acceptable levels, verify the programs effectiveness through inspections that confirm the insignificance of any aging effects. The program will be enhanced to include additional chemistry sampling and periodic inspections of fuel oil storage equipment.

The team reviewed the LRA, License Renewal Program basis documentation, plant specific operating history documents, surveillance results, work orders, and corrective action documents. In addition, the team interviewed the AMP owner, and other applicant staff.

The team concluded continued implementation of the Fuel Oil Chemistry AMP, as described in the LRA, should provide reasonable assurance the applicable aging effects will be managed for the period of extended operation, consistent with the licensing basis.

(20) Reactor Vessel Surveillance (B.2.1.20)

The Reactor Vessel Surveillance AMP is an existing program that is intended to be consistent with the program described in NUREG 1801,Section XI.M31, Reactor Vessel Surveillance, with two proposed enhancements and a proposed exception.

The multiple aspects of the proposed exception related to neutron fluency levels are specified in the applicants response to RAI B.2.1.20-2 in docketed letter RS-15-165 (ML15176A348) dated June 25, 2015. The final evaluations of the AMP, enhancements, proposed exception and licensee responses to RAI B.2.1.20-1 through RAI B.2.1.20-4 will be documented in the SER.

The program manages the aging effect of reduction of fracture toughness of reactor vessel materials.

The team reviewed License Renewal Program basis documentation, implementing procedures, the LRA, corrective action documents and plant specific operating history documents. In addition, the team interviewed the AMP owner, other responsible applicant site and corporate staff and associated license renewal contractors.

The team concluded continued implementation of the Reactor Vessel Surveillance AMP, as described in the LRA with enhancements and one potential exception should provide reasonable assurance the aging effects will be managed for the period of extended operation, consistent with the licensing basis. The final evaluation of the AMP, proposed exception, enhancements and RAI responses will be documented in the SER.

(21) One-Time Inspection (B.2.1.21)

The One-Time Inspection Program is a new program intended to be consistent with the program described in NUREG-1801,Section XI.M32, One-Time Inspection.

Inspections that verify unacceptable degradation is not occurring will be performed within the 10 years prior to the period of extended operation. This program will be used to verify the system-wide effectiveness of the Water Chemistry, Fuel Oil Chemistry, and Lubricating Oil Analysis Programs which are designed to prevent or minimize aging to the extent that it will not cause a loss of intended function during the period of extended operation. Determination of the sample size will be 20 percent of the components in each material-environment-aging effect group up to a maximum of 25 components.

Identification of inspection locations will be based on the potential for the aging effect to occur. Examination techniques will use established Non-Destructive Examination methods with a demonstrated history of effectiveness in detecting the aging effect of concern, including visual, ultrasonic, and surface techniques. Acceptance criteria will be based on applicable ASME or other appropriate standards, design basis information, or vendor-specified requirements and recommendations. Any indication or relevant condition of degradation will be evaluated.

The team reviewed License Renewal Program basis documentation and interviewed responsible applicant staff.

The team concluded implementation of the One-Time Inspection Program, as described in the LRA, should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(22) Selective Leaching (B.2.1.22)

The Selective Leaching AMP is a new program intended to be consistent with the program described in NUREG-1801,Section XI.M33, "Selective Leaching" as modified by LR-ISG-2011-03 and LR-ISG-2012-02. The program includes inspections to verify the absence of selective leaching to ensure the integrity of components that may be susceptible to this aging mechanism. These components include those made of gray cast iron and copper alloy (with greater than 15 percent zinc or greater than 8 percent aluminum) exposed to raw water, closed cycle cooling water, treated water, waste water or soil. This AMP will include one-time visual inspection, supplemented by hardness measurements (where feasible, based on form and configuration) or mechanical examination techniques to determine whether loss of materials due to selective leaching is occurring and whether selective leaching will affect the ability of the components to perform their intended function for the period of extended operation.

The team reviewed the associated AMP basis document, plant specific operating history documents including corrective action documents, scoping and screening reports, and the LRA. In addition, the team interviewed responsible applicant and site staff. The team was unable to review the implementing documents associated with this new program because they were being developed at the time of this inspection The team concluded implementation of the Selective Leaching AMP as described in the LRA should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(23) One-time Inspection of ASME Code Class 1 Small-Bore Piping (B.2.1.23)

The Unit 1 One-Time Inspection of ASME Code Class 1 Small-Bore Piping program is a new program intended to be consistent with the program described in NUREG-1801, Rev. 2,Section XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping. The program is intended to manage the aging effect of cracking in Unit 1 ASME Code Class 1 small-bore piping with a nominal pipe size less than 4 inches and greater than or equal to 1 inch, by augmenting the requirements of the ASME Code Edition of record,Section XI. The program includes pipes, fittings, branch connections, and full penetration (butt) and partial penetration (socket) welds. The augmented ASME Code Section XI requirements include a one-time volumetric examination of a sample of small-bore piping butt welds and socket welds. The program also includes controls to implement a plant-specific periodic inspection aging management program if small-bore piping cracking caused by IGSCC or fatigue is identified through the one-time inspections or other Unit 1 operating experience.

The team reviewed License Renewal Program basis documentation, operating experience, corrective action documents, engineering changes, responses to RAIs, and the LRA. The team also interviewed the responsible applicant staff.

The team concluded implementation of the new Unit 1 One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program, as described in the LRA and with adequate resolution of the associated RAIs, should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(24) External Surfaces Monitoring of Mechanical Components (B.2.1.24)

The External Surfaces Monitoring Program is a new program that is intended to be consistent with the program described in NUREG 1801,Section XI.M36, External Surfaces Monitoring of Mechanical Components, as modified by LR ISG 2012 02, "Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation, and LR ISG 2013 01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In Scope Piping, Piping Components, Heat Exchangers, and Tanks, dated November 14, 2014. The program manages aging effects of components fabricated from metallic and elastomeric components such as piping, piping components, ducting, and other components within the scope of license renewal exposed to air-indoor uncontrolled, air-outdoor, and condensation environments through periodic visual inspection. The program manages the aging effects of cracking, hardening and loss of strength, loss of material, and reduced thermal insulation resistance of metallic and elastomeric materials through visual inspection of external surfaces. Visual inspections will be supplemented by physical manipulation, when appropriate, to detect hardening and loss of strength in elastomers.

The team reviewed License Renewal Program basis documentation, AMP documents, existing procedures, and Action Requests. The team also interviewed responsible applicant staff. The team was unable to review some implementing documents associated with this new program because they were being developed at the time of this inspection The team concluded implementation of the External Surfaces Monitoring of Mechanical Components AMP as described in the LRA should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(25) Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

The Inspection of Internal Surfaces In Miscellaneous Piping And Ducting Components AMP is a new program intended to be consistent with the program described in NUREG-1801,Section XI.M38, Internal Surfaces in Miscellaneous Piping and Ducting Components, as modified by LR-ISG-2012-02.

The program will manage internal surfaces of metallic and elastomeric components such as piping, piping components and piping elements, ducting components, tanks, heat exchanger components, elastomers, and other components that are exposed to environments of condensation, diesel exhaust, and waste water environments. The program also consists of visual inspections of the internal surfaces of elastomeric components that are exposed to condensation, augmented by physical manipulation to detect hardening or loss of strength where appropriate. The program will manage the aging effects of loss of material, reduction of heat transfer, flow blockage, and cracking for metallic components. The program will also manage the aging effects of loss of material and hardening and loss of strength for elastomeric components. The program includes provisions for visual inspections of the internal surfaces of components not managed under other AMPs.

The team reviewed the AMP basis document, applicable NRC requests and RAIs, implementing procedures, and Updated Final Safety Analysis Report changes proposed for the AMP. The team also interviewed the AMP owner and other responsible applicant staff.

The team concluded implementation of the Internal Surfaces in Miscellaneous Piping and Ducting Components AMP as described in the LRA should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(26) Lubricating Oil Analysis (B.2.1.26)

The Lubricating Oil Analysis AMP is an existing program that is intended to be consistent with the program described in NUREG-1801,Section XI.M39, Lubricating Oil

Analysis.

The program includes periodic sampling and analysis, and trending to confirm the oil environment is not conducive to loss of material or reduction of heat transfer.

The team reviewed the LRA, License Renewal Program basis documentation, plant specific operating history documents, oil sample results, and corrective action documents. In addition, the team interviewed the AMP owner, and other applicant staff.

The team concluded continued implementation of the Lubricating Oil Analysis AMP, as described in the LRA, should provide reasonable assurance the applicable aging effects will be managed for the period of extended operation, consistent with the licensing basis.

(27) Monitoring of Neutron-Absorbing Materials Other Than Boraflex (B.2.1.27)

The Monitoring of Neutron-Absorbing Materials Other Than Boraflex AMP is an existing program that is intended to be consistent with the program described in NUREG-1801,Section XI.M40, Monitoring of Neutron-Absorbing Materials Other than Boraflex.

This program includes periodic inspection and analysis of test coupons of the neutron-absorbing material in the spent fuel storage racks to determine if the neutron absorbing capability of the material has degraded. This program ensures that a 5 percent sub-criticality margin in the spent fuel pool is maintained during the period of extended operation by monitoring for loss of material, changes in dimension, and loss of neutron-absorption capacity of the material.

The team walked reviewed License Renewal Program basis documentation, existing procedures, recent surveillance results, and calculations. In addition, the team interviewed the AMP owner, and other applicant staff.

The team concluded continued implementation of the Neutron-Absorbing Material Monitoring Program, as described in the LRA, should provide reasonable assurance the applicable aging effects will be managed, consistent with the license basis, for the period of extended operation.

(28) Buried and Underground Piping (B.2.1.28)

The Buried and Underground Piping AMP is existing program that will be enhanced to be consistent with the program described in NUREG-1801,Section XI.M41, Buried and Underground Piping and Tanks, as modified by LR-ISG-2011-03, Changes to the GALL Report, Revision 2, AMP XI.M41, Buried and Under Ground Piping and Tanks.

The program manages the external surface aging effects of cracking and loss of material for buried and underground piping in soil and air-outdoor environments. The program manages aging through preventive, mitigative (e.g., coatings, backfill quality, and cathodic protection), and inspection activities for piping and components within the scope of license renewal.

The Buried and Underground Piping AMP will be enhanced, prior to the period of extended operation, to:

• Manage cracking for stainless steel piping, utilizing a method that has been demonstrated to be capable of detecting cracking, whenever coatings are removed and expose the base material.

• Ensure all underground carbon steel Essential Cooling Water System and Non-Essential Cooling Water System piping and components within the scope of license renewal are coated in accordance with Table 1 of National Association of Corrosion Engineers (NACE) SP0169-2007.

• Define acceptable coating conditions as coating exhibiting either no evidence of degradation, or, the type and extent of coating damage evaluated as insignificant by an individual possessing a NACE Coating Inspector Program Level 2 or 3 operator qualification, or by an individual who has attended the EPRI Comprehensive Coatings Course and completed the EPRI Buried Pipe Condition Assessment and Repair Training Computer Based Training Course.

• Perform inspection quantities of buried piping within the scope of license renewal in accordance with LR-ISG-2011-03, Element 4.b and Table 4a, during each 10-year period, beginning 10 years prior to the period of extended operation.

The number of inspections of buried piping will be based upon the as-found results of cathodic protection system availability and effectiveness.

• Perform direct visual inspections of underground Essential Cooling Water System and Non-Essential Cooling Water System piping within the scope of license renewal during each 10-year period, beginning 10 years prior to the period of extended operation

• Double the inspection sample sizes within the affected piping categories if adverse indications are detected during inspection. If adverse indications are found in the expanded sample, an analysis will be conducted to determine the extent of condition and extent of cause. The size of the follow-up inspections will be determined based on the analysis. Timing of the additional inspections will be based on the severity of the identified degradation and the consequences of leakage. In all cases, the additional inspections will be performed within the same 10-year inspection interval in which the original adverse indication was identified. Expansion of sample size may be limited by the extent of piping subject to the observed degradation mechanism.

• Use only the -850mV polarized potential criterion specified in NACE SP0169-2007 for acceptance criteria for steel piping and determination of cathodic protection system effectiveness in performing cathodic protection surveys. Alternatively, soil corrosion probes may also be used to demonstrate cathodic protection effectiveness during the annual surveys. An upper limit of -1200mV for pipe-to-soil potential measurements of coated pipes will also be established, so as to preclude potential damage to coatings.

• Conduct an extent of condition evaluation if observed coating damage caused by non-conforming backfill has been evaluated as significant. The extent of condition evaluation will be conducted to ensure that the as-left condition of backfill in the vicinity of the observed damage will not lead to further degradation.

The inspectors reviewed the applicable License Renewal Program basis documentation and existing procedures related to the program. The inspectors interviewed the buried and underground piping AMP owner, other relevant plant staff and associated license renewal staff.

The inspectors concluded implementation of the Buried and Underground Piping AMP as described in the LRA, with the proposed enhancements, should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(29) ASME Section XI, Subsection IWE (B.2.1.29)

The ASME Section XI, Subsection IWE Program is an existing program that, with enhancements, is intended to be consistent with the program described in NUREG-1801,Section XI.S1, ASME Section XI, Subsection IWE. This program provides for periodic visual and volumetric examinations of steel containments and steel liners for concrete containments to determine general mechanical and structural condition or degradation. The program is credited in the LRA to provide for periodic examination of the steel containments and steel liners for concrete containments and also includes the drywell floor, the down comers, and the connecting piping, their supports, containment hatches, airlocks, moisture barriers and pressure retaining bolting. The ASME Section XI, Subsection IWE Program is implemented through plant procedures which provide administrative controls, including corrective actions, for the conduct of activities that are necessary to fulfill the requirements of ASME Section XI, as mandated by 10 CFR 50.55a(b)(2).

The team reviewed the License Renewal Program basis documentation, implementing procedures, condition reports, responses to RAIs and the LRA. The team also interviewed the program owner and the responsible site engineer. LaSalle was operating during this inspection period which precluded observation of physical condition of containment surfaces and components, however a walkdown was completed during the Unit 2 outage with no concerns identified.

The team concluded continued implementation of the ASME Section XI, Subsection IWE Program, as described in the LRA with the proposed enhancements should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(30) ASME Section XI, Subsection IWL (B.2.1.30)

The ASME Section XI, Subsection IWL Program is an existing program that, with enhancements, is intended to be consistent with the program described in NUREG-1801,Section XI.S2, ASME Section XI, Subsection IWL. This program includes periodic visual examinations and testing of reinforced and pre-stressed concrete containments, which includes reinforced concrete and unboned post tensioning systems. The ASME Section XI, Subsection IWL Program is implemented through plant procedures which provide administrative controls, including corrective actions, for the conduct of activities that are necessary to fulfill the requirements of ASME Section XI, as mandated by 10 CFR 50.55a The team reviewed the License Renewal Program basis documentation, implementing procedures, condition reports, and the LRA. The team also interviewed the program owner and the responsible site engineer and performed walkdowns of the vertical and horizontal tendons. No significant concerns were identified during the walkdowns.

The team concluded continued implementation of the ASME Section XI, Subsection IWL Program, as described in the LRA with the proposed enhancements should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(31) ASME Section XI, Subsection IWF (B.2.1.31)

The ASME Section XI, Subsection IWF Program is an existing program that, with enhancements, is intended to be consistent with the program described in NUREG-1801,Section XI.S3, ASME Section XI, Subsection IWF. This program includes periodic visual examinations of ASME Class 1, 2, 3, and MC piping and component supports to determine general mechanical and structural condition or degradation of component supports, such as verification of clearances, settings, physical displacements, loose or missing parts, debris, corrosion, wear, erosion, or the loss of integrity at welded or bolted connections. The ASME Section XI, Subsection IWF Program is implemented through plant procedures which provide administrative controls, including corrective actions, for the conduct of activities that are necessary to fulfill the requirements of ASME Section XI, as mandated by 10 CFR 50.55a The team reviewed the License Renewal Program basis documentation, implementing procedures, responses to RAIs, condition reports, and the LRA. The team also interviewed the program owner and the responsible site engineer.

The team concluded continued implementation of the ASME Section XI, Subsection IWF Program, as described in the LRA with the proposed enhancements should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(32) 10 CFR Part 50, Appendix J (B.2.1.32)

The 10 CFR Part 50, Appendix J Program is an existing program intended to be consistent with the program described in NUREG-1801,Section XI.S4, Title 10 CFR Part 50, Appendix J. This program consists of tests performed in accordance with the regulations and guidance provided in 10 CFR Part 50, Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, Option B, Regulatory Guide 1.163, Performance-Based Containment Leak-Testing Program, Nuclear Energy Institute 94-01, Industry Guideline for Implementing Performance-Based Options of 10 CFR Part 50, Appendix J, and American National Standards Institute/ANS 56.8, Containment System Leakage Testing Requirements.

The team reviewed the License Renewal Program basis documentation, implementing procedures, condition reports, and the LRA. The team also interviewed the program owner and the responsible site engineer.

The team concluded continued implementation of the 10 CFR Part 50, Appendix J Program, as described in the LRA should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(33) Masonry Walls (B.2.1.33)

The Masonry Wall Program is an existing program that, with enhancements, is intended to be consistent with the program described in NUREG-1801,Section XI.S5, Masonry Walls. This program manages masonry walls for loss of material and cracking and is implemented as part of the structures monitoring AMP (B.2.1.34). This AMP relies on inspection activities and was based on guidance provided in IE 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.

The team reviewed License Renewal Program basis documentation, implementing inspection procedures, responses to RAIs, Condition Reports, and the LRA. The team also interviewed the program owner and the responsible site engineer and performed walkdowns of a sample of masonry walls in the reactor building, auxiliary building and secondary containment for visible evidence of structural degradation and cracks. No significant concerns were identified during the walkdown.

The team concluded continued implementation of the Masonry Wall Program, as described in the LRA with the proposed enhancements, should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(34) Structures Monitoring (B.2.1.34)

The Structures Monitoring AMP is an existing program that, with enhancements, is intended to be consistent with the program described in NUREG-1801,Section XI.S6, Structures Monitoring. This program is intended to implement the requirements of 10 CFR 50.65.

This program was based on Revision 2 of Nuclear Management and Resources Council 93 01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and Revision 2 of RG 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. This program relies on periodic visual inspections and condition monitoring of concrete structures, steel components, elastomers, and masonry block walls. This program also includes elements of the masonry walls AMP (B.2.1.33) and Water Control Structures AMP (B.2.1.35).

The team reviewed License Renewal Program basis documentation, implementing inspection procedures, responses to RAIs, Condition Reports, scoping and screen reports, aging management review, and the LRA. The team also interviewed the program owner and the responsible site engineer and performed walkdowns of the auxiliary building and the diesel generator building for visible evidence of structural degradation and cracks. No significant concerns were identified during the walkdown.

The team concluded continued implementation of the Structures Monitoring AMP, as described in the LRA with the proposed enhancements, should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(35) Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants (B.2.1.35)

The RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants AMP is an existing program that, with enhancements, is intended to be consistent with the program described in NUREG-1801,Section XI.S7, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants. This program manages the aging effects of the canals, intake structures, intake flume, and other water controls structures associated with emergency cooling water systems or flood protection.

In addition to reinforced concrete, this program includes steel piling, structural steel, bolting, and miscellaneous steel components associated with the water-control structures. This program relies on inspection and surveillances based on Revision 1 of RG 1.127.

The team reviewed License Renewal Program basis documentation, implementing inspection procedures, responses to RAIs, condition reports, and the LRA. The team also interviewed the program owner and the responsible site engineer and performed a walkdown of the Lake Screen House and Cooling Lake Intake Flume. No significant concerns were identified during the walkdown.

The team concluded continued implementation of the RG 1.127, Inspection of Water Control Structures Associated with Nuclear Power Plants AMP, as described in the LRA with the proposed enhancements, should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(36) Protective Coating Monitoring and Maintenance Program (B.2.1.36)

The Protective Coating Monitoring and Maintenance Program is an existing mitigative and condition monitoring program that is intended to be consistent with the program described in NUREG-1801,Section XI.S8, Protective Coating Monitoring and Maintenance Program.

The program manages the aging of Service Level I coatings applied to carbon steel and concrete surfaces inside containment that are exposed to Air-indoor and treated water environments, for Loss of Coating Integrity/Blistering, Cracking, Flaking, Peeling, and Physical Damage. This program ensures only that the Service Level I coatings maintain adhesion so as to not affect the intended function of the ECCS suction strainers.

The LRA describes this AMP as comparable with Revision 1 or the latest revision of RG 1.54, Quality Assurance Requirements for Protective Coatings Applied to Water Cooled Nuclear Power Plants, which was identified as an acceptable method for developing this AMP by Section XI.S8, of NUREG-1801.

The team reviewed License Renewal Program basis documentation, existing procedures and inspection results, condition reports, and the LRA. The team also interviewed responsible applicant staff. LaSalle Units 1 and 2 were at full power during this inspection period which precluded observation of physical condition of coatings.

Instead, the team reviewed recent outage related inspections and work orders where the condition of Service Level I coatings were assessed.

The team concluded implementation of the Protective Coating Monitoring and Maintenance Program, as described in the LRA, should provide reasonable assurance the aging effects will be managed for the period of extended operation consistent with the licensing basis.

(37) Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (B.2.1.37)

The Non-Environmental Qualification (EQ) Insulated Cables and Connections AMP is a new program that is intended to be consistent with the program described in NUREG-1801,Section XI.EI., Insulation Material for Electrical Cables and Connections not Subject to 10 CFR 50.59 EQ Requirements. The program will be a Conditioning Monitoring Program that provides reasonable assurance that intended functions of insulated cables and connections exposed to adverse localized environments (caused by heat, radiation, or moisture) can be maintained consistent with the current licensing basis through the period of extended operation. Accessible insulated cables and connections within scope of license renewal installed in an adverse localized environment will be visually inspected, at least every 10 years, for cable and connection jacket surface anomalies such as embrittlement, discoloration, cracking, swelling, or surface contamination. If unacceptable conditions or situation is identified the applicant will enter it into the CAP.

The team reviewed the License Renewal Program basis documents and confirmed the applicant had a commitment in place to implement the program prior to the period of extended operation. The team also interviewed the Non-EQ Insulated Cables and Connections Program owner to determine how and when the testing and monitoring requirements for this AMP will be developed and implemented.

The team concluded implementation of the Non-EQ Insulated Cables and Connections AMP as described in the LRA should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(38) Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits (B.2.1.38)

The Insulation Material for Non-EQ Electrical Cables and Connections used in Instrumentation Circuits is a new program that is intended to be consistent with the program described in NUREG-1801,Section XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrumentation Circuits. The program will manage the aging effects of applicable cables in the Neutron Monitoring, Process Radiation Monitoring, and area Radiation Monitoring Systems. This AMP will provide reasonable assurance that the intended function of sensitive, high-voltage, low-current cables exposed to adverse localized environments can be maintained consistent with the current licensing basis through the extended period of operation.

This will be accomplished by reviewing calibration and surveillance testing results every 10 years with the first review occurring prior to the extended period of operation. Cable tests for the in-scope local power range monitors is every 6 months, and for source range and intermediate range monitors is every 2 years. Neutron Monitoring System cable test results will be periodically monitored via performance monitoring once every 10 years.

The team reviewed the License Renewal Program basis documents and confirmed the applicant had a commitment in place to implement the program prior to the period of extended operation. The team also interviewed the staff responsible for Non-EQ instrumentation circuits subject to sensitive, high-voltage, and low-level signals, to determine current practice and test procedures to be developed under the program.

The team concluded implementation of the Insulation Material for Non-EQ Electrical Cables and Connections used in Instrumentation Circuits as described in the LRA should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(39) Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (B.2.1.39)

The Non-EQ Inaccessible Power Cables AMP is a new program that is intended to be consistent with the program described in NUREG-1801,Section XI.E3, Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements. This program will manage the aging effect of reduced insulation resistance on inaccessible power cables that have a license renewal intended function. The cables that are included in this program are routed underground in conduits, duct banks or direct buried. In scope cables exposed to significant moisture will be tested, using a proven commercially available test, at least every 10 years. The program will also include periodic inspections of manholes within scope of this program at least once every year. In addition, inspections of manholes for water after events such as heavy rains or flooding will be performed. Inspection frequency of the manholes will be adjusted as necessary.

The team reviewed the License Renewal Program basis documents, condition reports, and confirmed the applicant had a commitment in place to implement the program prior to the period of extended operation. The team also interviewed the Non-EQ Inaccessible Power Cables Program owner.

The team concluded implementation of the Non-EQ Inaccessible Power Cables AMP as described in the LRA should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(40) Metal Enclosed Bus (B.2.1.40)

The Metal Enclosed Bus (MEB) Inspection AMP is an existing program that is consistent with the program described in NUREG-1801,Section XI.E4, MEB. The program includes inspections of internal and external portions of MEB to identify age related degradation of the bus, bus connections, the bus enclosure, and the bus insulators.

This program inspects the internal portions of the MEB for cracks, corrosion, foreign debris, excessive dust buildup, and evidence of water intrusion. The program will be enhanced to provide internal and external inspection of insulating material and metallic and elastomeric components. The program will be enhanced to also inspect 20 percent of the metal enclosed bolted connections on a frequency of every 10 years. The bus insulation will be visually inspected for signs of reduced insulation resistance, such as embrittlement, cracking, chipping, melting, swelling, discoloration, or surface contamination, which may indicate overheating or aging degradation. The internal bus insulating supports will be visually inspected for structural integrity and signs of cracks.

The team reviewed License Renewal Program basis documents and confirmed the applicant had an existing MEB Program. The team also interviewed the program owner to determine how and when the enhancements for this AMP will be developed and implemented.

The team concluded the MEB Inspection AMP as described in the LRA should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(41) Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (B.2.1.41)

The Non-EQ Electrical Cables Connections AMP is a new program that is intended to be consistent with the program described in NUREG-1801,Section XI.E6, Electrical Cables Connections Not Subject to 10 CFR 50.49 EQ Requirements.

Cable connections associated with this program are those connections which are susceptible to age-related degradation that are not subject to the requirements of 10 CFR 50.49. The program is a One-Time Testing Program, on a sampling basis, applicable to low and medium voltage cable connections, to confirm the absence of age-related degradation due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion and oxidation. The program consists of a representative sample of electrical connections within the scope of license renewal.

Testing may include thermography, contact resistance testing, or other appropriate testing methods. A representative sample of non-EQ electrical cable connections will be selected based on application (medium and low-voltage), circuit loading (high-loading),connection type, and location (high-temperature, high-humidity and vibration). The sample tested will be 20 percent of the population with a maximum sample size of 25 connections. The technical basis for the sample selected will be documented.

The team reviewed License Renewal Program basis documents, condition reports and confirmed the applicant had a commitment in place to implement the program prior to the period of extended operation. The team also interviewed the Non-EQ Electrical cables connections program owner to determine how and when the testing and monitoring requirements for this AMP will be developed and implemented.

The team concluded implementation of the Non-EQ Electrical Cables Connections AMP as described in the LRA should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(42) Service Level III and Service Level III Augmented Coatings Monitoring and Maintenance Program (B.2.2.1)

The Service Level III and Service Level III Augmented Coatings Monitoring and Maintenance Program is a new, plant-specific condition monitoring program that is intended to be consistent with the program described in NUREG-1801,Section XI.M42, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-scope Piping, Piping Components, Heat Exchangers, and Tanks, and Draft LR-ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-scope Piping, Piping Components, Heat Exchangers, and Tanks. This program manages the loss of coating integrity in heat exchangers, piping, piping components, piping elements, strainer bodies, and tanks exposed to raw water, waste water, and lubricating oil environments. This program manages the aging effect loss of coating integrity by visual inspections intended to identify internal coatings that do not meet acceptance criteria. Physical testing is intended to identify potential delamination of the coating. Internal coatings are visually inspected for signs of coating failures and precursors to coating failures including peeling, delamination, blistering, cracking, flaking, chipping, rusting, and mechanical damage.

The team reviewed License Renewal Program basis documentation, existing procedures, RAI Responses, and the LRA. The team also interviewed responsible applicant staff. LaSalle Units 1 and 2 were at full power during this inspection period which precluded observation of physical condition of coatings.

The team concluded implementation of the Service Level III and Service Level III Augmented Coatings Monitoring and Maintenance Program, as described in the LRA, with revisions as identified in Letter RS-15-165, Response to NRC Requests for Additional Information, Set 2, dated May 29, 2015, related to the LaSalle County Station, Units 1 and 2, License Renewal Application (TAC Nos. MF5347 AND MF5346), dated June 25, 2015, should provide reasonable assurance the aging effects will be managed for the period of extended operation consistent with the licensing basis.

(43) Unit 2 Inspection of ASME Code Class 1 Small-Bore Piping Program (B.2.2.2)

The Unit 2 Inspection of ASME Code Class 1 Small-Bore Piping program is a new plant-specific program that includes guidance described in NUREG-1801, Rev. 2,Section XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping.

This new program is intend to manage the aging effect of cracking in Unit 2 ASME Code Class 1 small-bore piping with a nominal pipe size less than 4 inches and greater than or equal to 1 inch, by augmenting the requirements of the ASME Code Edition of record,Section XI. The program includes pipes, fittings, branch connections, and full penetration (butt) and partial penetration (socket) welds. The augmented ASME Code Section XI requirements include volumetric examinations of a sample of small-bore piping butt welds and socket welds.

NUREG-1801, Rev. 2,Section XI.M35, suggests that a plant-specific AMP be developed to manage periodic inspections for systems that have experienced cracking and where operating experience indicates that design changes have not been implemented to effectively mitigate cracking. Since LaSalle Unit 2 experienced a failure of an ASME Code Class 1 small-bore piping socket weld in 2005 that was not demonstrated to have been effectively mitigated, the licensee developed a plant-specific program.

The program includes controls to perform an evaluation of all Unit 2 systems with ASME Code Class 1 small-bore piping to determine whether other welds are susceptible to the cause of the 2005 failure. Welds determined to be susceptible are then included in a population that will be inspected periodically. The rest of the ASME Code Class 1 small-bore piping welds determined not to be susceptible are included in a population that will be inspected via a one-time inspection prior to the period of extended operation.

If additional ASME Class 1 small-bore piping welds experience age-related failures, or cracking is identified by the inspections, the program uses the same evaluation process to identify additional susceptible welds to be included in the population to be inspected periodically.

The team reviewed operating experience, corrective action documents, engineering changes, and responses to RAIs. The team also interviewed the responsible applicant staff.

The team concluded implementation of the new plant-specific Unit 2 Inspection of ASME Code Class 1 Small-Bore Piping program, as described in the responses to RAIs and with adequate resolution of the associated RAIs, should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(44) Fatigue Monitoring (B.3.1.1)

The Fatigue Monitoring AMP is an existing program that enhancements is intended to be consistent with the program described in NUREG-1801,Section X.M1, Fatigue Monitoring. The program is intended to ensure that fatigue usage remains within allowable limits for components identified to have a Time Limited Aging

Analysis.

Program activities include monitoring and tracking the actual number of operational transients to ensure the number of cycles used in the design analysis is not exceeded, and component cumulative usage factors are maintained below the allowable limit.

The team reviewed License Renewal Program basis documentation, existing procedures and surveillance results, corrective action documents, work order documents, license renewal boundary drawings, and the LRA. The team also interviewed the AMP owner, other responsible applicant site and corporate staff and associated license renewal contractors.

The team concluded continued implementation of the Fatigue Monitoring AMP, as described in the LRA with the proposed enhancements, should provide reasonable assurance the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

(45) Concrete Containment Tendon Pre-Stress (B.3.1.2)

The Concrete Containment Tendon Pre-Stress AMP is an existing program with an enhancement that is intended to be consistent with the program described in NUREG-1801,Section X.S1, Concrete Containment Tendon Pre-Stress.

The team reviewed License Renewal Program basis documentation, existing procedures and surveillance results, corrective action documents, license renewal boundary drawings, and the LRA. The team also interviewed the AMP owner, other responsible site and corporate applicant staff and associated license renewal contractors.

The team concluded continued implementation of the Concrete Containment Tendon Pre-Stress AMP, as described in the LRA with the proposed enhancement as revised in docketed letter RS-15-194 dated August 6, 2015, (ML15218A424) should provide reasonable assurance the aging effects will be managed, consistent with the license basis, for the period of extended operation.

(46) Environmental Qualification of Electric Components (B.3.1.3)

The EQ of Electric Components AMP is an existing program, required by 10 CFR 50.49, which demonstrates that certain electrical components located in harsh environments are qualified to perform their safety function in those harsh environments. In the existing EQ Program components are refurbished, replaced, or their qualification is extended to 60 years by analysis. This program will continue to ensure EQ of the applicable components. This program is consistent with NUREG-1801,Section X.E1, EQ of Electric Components.

The team reviewed License Renewal Program basis documents, program health report, condition reports, aging management review documents, and existing procedures. The team also interviewed the program owner to determine current practice of extending components EQ life.

The team concluded, continued implementation of the EQ of Electric Components AMP will provide reasonable assurance that the aging effects will be managed, consistent with the licensing basis, for the period of extended operation.

5. EXIT MEETING SUMMARY

On October 16, 2015, the team presented the inspection results to Mr. Harold Vinyard and other members of the applicants staff. The applicant acknowledged the issues presented. The inspectors confirmed none of the potential report input discussed was considered proprietary.

The team noted that proprietary documents were reviewed during the course of the inspection. The applicant confirmed all such proprietary documents were returned and the likely content of the report would not involve proprietary material.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Applicant

H. Vinyard, LaSalle Station Plant Manager

M. Gallagher, Vice President, License Renewal

D. Warfel, License Renewal Manager

J. Hilditch, License Renewal Project Manager

J. Hufnagel, License Renewal Licensing Lead

P. Weyhmuller, License Renewal Technical Lead

C. Scheidt, LaSalle Station Licensing Lead

G. Becknell, License Renewal

D. Clohecy, License Renewal

M. Guthrie, License Renewal

J. Jordan, License Renewal

M. Kowalski, License Renewal

M. Miller, License Renewal

D. Spammer, License Renewal

P. Tamburro, License Renewal

LIST OF ITEMS

Opened, Closed, and Discussed

None