IR 05000382/2024012

License Renewal Phase 2 Inspection Report 05000382/2024012

ML24325A382
Person / Time
Site:	Waterford
Issue date:	11/21/2024
From:	Greg Warnick NRC/RGN-IV/DORS/EB2
To:	Sullivan J Entergy Operations
Smith W
References
IR 2024012
Download: ML24325A382 (1)

Text

November 21, 2024

SUBJECT:

WATERFORD STEAM ELECTRIC STATION, UNIT 3 - LICENSE RENEWAL PHASE 2 INSPECTION REPORT 05000382/2024012

Dear Joseph Sullivan:

On October 9, 2024, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Waterford Steam Electric Station, Unit 3 and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No findings or violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely, Gregory G. Warnick, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket No. 05000382 License No. NPF-38

Enclosure:

As stated

Inspection Report

Docket Number:

05000382

License Number:

NPF-38

Report Number:

05000382/2024012

Enterprise Identifier:

I-2024-012-0008

Licensee:

Entergy Operations, Inc.

Facility:

Waterford Steam Electric Station, Unit 3

Location:

Killona, LA

Inspection Dates:

September 09, 2024 to October 09, 2024

Inspectors:

L. Brookhart, Senior Spent Fuel Storage Inspector

M. Davis, Trans and Storage Safety Inspector

S. Graves, Senior Reactor Inspector

A. Saunders, Reactor Inspector

C. Smith, Senior Reactor Inspector

B. Tharakan, Technical Assistant

Approved By:

Gregory G. Warnick, Chief

Engineering Branch 2

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a license renewal phase 2 inspection at Waterford Steam Electric Station, Unit 3, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===71003 - Post-Approval Site Inspection for License Renewal Inspection Procedure 71003, Post-Approval Site Inspection for License Renewal, recommended that the inspection be conducted shortly before the period of extended operation.

The period of extended operation is the additional 20 years beyond the original 40-year licensed term. The period of extended operation for Waterford Steam Electric Station, Unit 3, will begin after midnight on December 18, 2024.

The inspectors evaluated whether the licensee:

(1) completed actions required to comply with the license renewal license condition and commitments;

(2) implemented the aging management programs that agreed with those approved in the safety evaluation report and described in the safety analysis report;

(3) followed the guidance in Nuclear Energy Institute (NEI) 99-04, Guidelines for Managing NRC Commitment Changes, for changing license renewal commitments and followed the guidance in 10 CFR 50.59 when making changes to the license renewal supplement;

(4) identified, evaluated, and incorporated newly identified structures, systems, and components into their aging management programs; and (5)implemented operating experience review and corrective action programs that account for aging effects.

The Safety Evaluation Report Related to the License Renewal of Waterford Steam Electric Station, Unit 3 [ML18228A668], lists 34 commitments and 41 aging management programs. The inspectors reviewed 33 of the commitments and 38 aging management programs. The inspectors completed reviews for 32 commitments. The NRC previously completed reviews for Commitment 5 and three aging management programs (Nickel Alloy Inspection, Containment Leak Rate, and Containment Inservice Inspection) in Inspection Report 5000382/2022011

[ML22189A054]. As detailed in the report, the inspectors completed reviews for all aging management programs and commitments, with the exception of the neutron-absorbing material monitoring program and its associated Commitment 17. This program will be reviewed in a future inspection.

For each aging management program reviewed, the inspectors reviewed program documents, license renewal documents, the safety analysis report, and the safety evaluation report.

Supporting documents reviewed included implementing procedures, work orders, inspection reports, engineering evaluations, calculations, database entries, and condition reports. The inspectors interviewed program owners and license renewal program personnel.

The inspectors walked down the following areas of the plant to inspect for signs of aging:

• component cooling water pumps

• component cooling water heat exchangers

• auxiliary component cooling water fans

• component cooling water wet tower basins

• emergency diesel generator train A

• emergency diesel fuel oil storage tank A

• security diesel

• control room

• fire pump house

• various reactor auxiliary building masonry walls

• primary/secondary sample labs in reactor auxiliary building

• spent fuel pool

• cathodic protection control panel

• switchyard

• fire water storage tanks The inspectors determined that the licensee described their aging management programs and commitments in Chapter 18 of their Final Safety Analysis Report (FSAR). The inspectors paraphrased most of the commitments listed in the aging management program reviews. For the actual wording refer to the safety evaluation report and any license basis changes. The inspectors listed specific documents reviewed in the attachment.

Post-Approval Site Inspection for License Renewal===

(1)18.1.1 Bolting Integrity Program This existing program manages loss of preload, cracking, and loss of material for the closure bolting of pressure-retaining components using preventive and inspection activities. The licensee used applicable industry standards and guidance documents to delineate the program. This program interfaces with several other programs.

Commitment 1 specified:

Enhance the bolting integrity program to:

• Include submerged pressure retaining bolting.

• Inspect and monitor high strength (>150 ksi) bolting locations.

• Require volumetric examination per ASME Code Section XI, Table IVB-2500-1, for high strength closure bolting when actual yield strength of the bolts were greater than or equal to 150 ksi.

• Specify opportunistic inspection of normally submerged dry cooling tower area sump pump discharge piping bolting.

• Specify visual inspection of a representative sample of closure bolting from components with an internal environment of a clear gas, such as air or nitrogen. A representative sample will be 20 percent of the population (for each material/environment combination) up to a maximum of 25 fasteners during each 10-year period of the period of extended operation.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and closure documents.

The inspectors reviewed documentation from the licensee that changed two of the above commitments. During this inspection, the inspectors reviewed License Basis Document Change Request (LBDCR) 23-02 to this program, where the licensee identified that the station did not use any high strength pressure-retaining fasteners with a diameter greater than 2 inches. Therefore, the licensee removed those two commitments from the Updated Final Safety Analysis Report (UFSAR), Chapter 18.1.1. The inspectors identified one issue related to these two commitments, specifically meeting the above commitments when procuring new high strength pressure retaining bolts in the future. The details of this issue are described in the observation titled High Strength Bolts in the Inspection Results section of this report.

The inspectors confirmed the licensee completed the remaining required commitments and implemented the procedures associated with this program prior to the period of extended operation. Based on the review of the procedures, inspection work-orders, work control program documents, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(2)18.1.2 Boric Acid Corrosion Program This existing program manages the loss of material and increase in connection resistance for components on which borated water may leak. The program includes

(a) visual inspection of external surfaces that are potentially in an environment of borated water leakage, including mechanical, electrical and structural components;

(b) timely identification of leak path and removal of boric acid residues; (c)assessment of degradation due to corrosion, if any; and

(d) follow-up inspection for adequacy. The licensee implemented the Boric Acid Corrosion Control Program (BACCP) in response to NRC Generic Letter (GL) 88-05 and industry operating experience.

The inspectors reviewed the UFSAR supplement for aging management, aging management program basis documents, implementing procedures, and documentation of completed inspection activities. The inspectors also reviewed corrective actions, work orders, and held discussions with the BACCP owner to discuss the BACCP inspection activities related to the health of the program and any emerging trends. The inspectors concluded that the station's implementing procedures are adequate to implement the BACCP, and the program implementation was appropriate and in accordance with station and corporate procedures.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(3)18.1.3 Buried and Underground Piping and Tanks Inspection Program This new program manages loss of material for the external surfaces of buried and underground piping composed of any material through preventive, mitigative, and inspection activities. Preventive and mitigative actions include selection of component materials, external coatings for corrosion control, backfill quality control and the application of cathodic protection.

Cathodic protection is used for additional protection of buried piping and tanks. The cathodic protection system is monitored and trended annually in accordance with the national association of corrosion engineers (NACE) standards SP-0169, Control of External Corrosion on Underground or Submerged Metallic Piping Systems, and RP-0285, Standard Recommended Practice Corrosion Control of Underground Storage Tank Systems by Cathodic Protection. Inspection activities include non-destructive evaluation of pipe or tank wall thickness, and visual inspection of the exterior, as permitted by opportunistic or directed excavations. The program includes carbon steel (including fire protection system gray cast iron), and concrete components.

There is no stainless steel, copper or aluminum alloy in the scope of the program.

There are no tanks in the scope of the program.

Commitment 2 specified:

• Implement the buried and underground piping and tanks inspection program as described in the License Renewal Application (LRA).

As part of the Buried and Underground Piping and Tank Aging Management Program the site is classified into different Preventive Action Categories, as stated in LR-ISG-2015-01, "Changes to Buried and Underground Piping and Tank Recommendations."

One of the requirements of the Preventive Action Category C is to maintain the Cathodic Protection System with an 85 percent or greater availability.

The inspectors reviewed a March 2022 electrical maintenance job that was performed under work order (WO) 575517. The inspectors noted that the cathodic protection rectifier failed the function and one of the phases were burnt and needed replacement. The system has not been restored to an availability status in a timely manner (condition report CR-WF3-2023-00377) and the availability has fallen to 80 percent. As a result of this unavailability of the cathodic protection system, the site moved to Preventive Action Category F, which requires three unplanned inspections of the in-scope piping backfilled with concrete prior to the period of extended operation. The backfill inspection requirements include excavation of the top surfaces and at least 50 percent of the side surface to visually inspect for cracks in the backfill that could admit groundwater to the external surfaces of the component. To meet Preventive Action Category E requirements, soil testing has been performed to confirm the soil is not corrosive within the 10 years prior to the period of extended operation. This soil testing was completed and the results were acceptable. The site has entered Preventive Action Category E, which would require two inspections prior to the period of extended operation (which were completed) and two inspections for each 10-year interval until the availability of the Cathodic Protection System reached 85 percent or greater. Once the cathodic protection system availability reaches 85 percent, the Protective Action Category will change to a Preventive Action Category C, eliminating the need for further inspections.

The inspectors reviewed the recent March 2024 cathodic protection system survey and confirmed the system was tested in accordance with national association of corrosion engineers standard practice SP-01-69. The inspectors confirmed that the negative potential did not exceed -1000 mV and had a minimum of 100 mV polarization.

The inspectors confirmed the licensee completed the remaining required commitments and implemented the procedures associated with this program prior to the period of extended operation. Based on the review of the procedures, inspection work-orders, work control program documents, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(4)18.1.4 Coating Integrity This new program manages the effects of aging through periodic visual inspections of coatings/linings applied to the internal surfaces of in-scoped components and includes piping, piping components, heat exchangers, and tanks exposed to closed-cycle cooling water, raw water, treated water, treated borated water, waste water, fuel oil, and lubricating oil where loss of coating or lining integrity could impact the intended functions of the components. For coated surfaces that do not meet the acceptance criteria, physical testing is performed where physically possible in conjunction with coating repair or replacement. Baseline inspections of in-scoped components were required to be completed in the 10-year period prior to the period of extended operation, in order to establish the condition of coatings/linings prior to entering the period of extended operation. Continued periodic inspection, of the in-scoped components, initially ranged from 4-6 years after the period of extended operation, with options to extend the inspection interval on certain components if the internal coatings were found to have no degradation. Additionally, a one-time inspection of the internal coating for the 11-foot diameter carbon steel circulating water piping was approved as an exception to the periodic inspection requirement.

Commitment 3 specified:

• Implement the coating integrity program as described in the LRA.

The licensee created this new program to meet the guidance in LR-ISG-2013-01 and to align with the approved programs at other Entergy sites. The inspectors reviewed procedures, completed inspections and examinations, engineering reports, and the license renewal implementing documentation. The inspectors also reviewed procedure EN-DC-225, Internal Coatings Integrity Program, that implemented the detailed inspection requirements described in LR-ISG-2013-01 and the commitments as described in the LRA. From review of the completed coatings inspections, the inspectors determined that the licensee would be performing their coatings inspections on the intervals as allowed by their commitments, except for the 11-foot diameter carbon steel circulating water piping which was subjected to a one-time inspection.

The inspectors confirmed the licensee completed the required commitments and implemented the procedures associated with this program prior to the period of extended operation. Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(5)18.1.5 Compressed Air Monitoring Program This existing program manages loss of material in compressed air systems by periodically monitoring the air for moisture and contaminants and by inspecting system internal surfaces. Air quality is maintained in accordance with limits based on consideration of manufacturer recommendations as well as guidelines in EPRI NP-7079, EPRI TR-108147, ASME OM-S/G-1998 (Part 17), and ANSI/ISA-S7.0.01-1996.

This existing program manages loss of material in compressed air systems by monitoring air samples for moisture and contaminants and by inspecting internal surfaces within compressed air systems.

Commitment 4 specified:

Enhance the compressed air monitoring program to:

• Apply consideration of the guidance of ASME OM-S/G-1998 (Part 17), EPRI NP-7079, and EPRI TR-108147 to the limits specified for the air system contaminants.

• Include opportunistic visual inspections of accessible internal surfaces of system components.

The inspectors reviewed the aging management program basis document, implementing procedures, completed work activities, and corrective action documents. The inspectors confirmed the licensee completed the required commitments and implemented the procedures associated with this program prior to the period of extended operation.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(6)18.1.8 Diesel Fuel Monitoring Program This existing program manages loss of material and reduction of heat transfer due to fouling for tanks, piping, and other metal components subject to aging management review that are in an environment of diesel fuel oil.

Commitment 6 specified:

Enhance the diesel fuel monitoring program to:

• Include the auxiliary diesel generator fuel oil tank and the emergency diesel generator (EDG) fuel oil feed tanks.

• Monitor and trend water content, sediment, particulates, and microbiological activity in the fuel oil tanks within the scope of the program at least quarterly.

• Include provisions to obtain a representative sample from the lowest point in the tank, if tank design does not allow for multi-level sampling.

• Include periodic cleaning and internal visual inspection of tanks within the scope of the program. In the areas of any degradation identified during the internal inspection, a volumetric inspection shall be performed. In the event an internal inspection cannot be performed due to design limitations, a volumetric examination shall be performed. Perform cleaning and internal inspections at least once during the 10-year period prior to the period of extended operation and at succeeding 10-year intervals.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed program activities, and held discussions with site personnel and fleet program owners. Specifically, the inspectors verified the fuel quality chemistry analyses for new diesel fuel receipt, diesel tank inspection results, trends, performed walkdowns of the accessible portions of the diesel generator and their associated tanks and discussed the program with the system engineers.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(7)18.1.9 Environmental Qualification (EQ) of Electric Components Program This existing aging management program is consistent with NUREG-1801,Section X.E1 and includes an exception. The EQ program manages component thermal, radiation, and cyclical aging using aging evaluations based on 10 CFR 50.49 qualification methods.

As required by 10 CFR 50.49, EQ components are refurbished, replaced or their qualification is extended prior to reaching the aging limits established in the evaluation. Reanalysis of an aging evaluation addresses attributes of analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions. Some aging evaluations for EQ components are time-limited analyses for license renewal.

The inspectors verified that procedure EN-DC-164, Environmental Qualification Program, revision 8, was updated to address aging effects. The inspectors selected several Plant Qualification Evaluations (PQE) of risk significant qualification to ensure the component analysis was acceptable and found no errors. The inspectors noted that the change package for the specific and general qualification evaluations will not be issued until October 2024. The inspectors determined that when the change package is issued the replacement schedule for those components would also be generated.

The inspectors reviewed the aging management program basis document, implementing procedures, completed work activities, and corrective action documents. The inspectors confirmed the licensee completed the required commitments and implemented the procedures associated with this program prior to the period of extended operation.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(8)18.1.10 External Surfaces Monitoring Program This existing program manages aging effects of components fabricated from metallic, elastomeric, and polymeric materials through periodic visual inspection of external surfaces for evidence of loss of material, cracking, and change in material properties. When appropriate for the component and material, physical manipulation, such as pressing flexing and bending, is used to augment visual inspections to confirm the absence of elastomer hardening and loss of strength. External surfaces monitoring program is also credited for situations where the material and environment combinations are the same for the internal and external surfaces such that the external surfaces are representative of the internal surfaces. The licensee performed visual inspection of external surfaces of in-scope mechanical components and monitors external surfaces of metallic components for systems within the scope of license renewal for loss of material and leakage. This program required no enhancements or exceptions.

Commitment 9 specified:

Enhance the external surfaces monitoring program to:

• Include instructions to perform a 100 percent visual inspection of accessible flexible polymeric component surfaces. The visual inspection should identify indicators of loss of material due to wear to include dimensional change, surface cracking, crazing, scuffing, and for flexible polymeric materials with internal reinforcement, the exposure of reinforcing fibers, mesh, or underlying metal. In addition, 10 percent of the available flexible polymeric surface area should receive physical manipulation to augment the visual inspection to confirm the absence of hardening and loss of strength (e.g., HVAC flexible connectors).

• Conduct representative inspections during each 10-year period on insulated surfaces of each material type (e.g., steel, stainless steel, copper alloy, aluminum) in an air-outdoor or condensation environment.

• Revise external surfaces monitoring program procedures as follows:

o Remove insulation in order to perform a visual inspection of a representative sample of insulated indoor component surfaces in a condensation environment and outdoor component surfaces. The inspections shall include a minimum of 20 percent of the in-scope piping length for each material type (e.g., steel, stainless steel, copper alloy, aluminum), or for components with a configuration which does not conform to a 1-foot axial length determination (e.g., valve, accumulator), 20 percent of the surface area. Alternatively, insulation can be removed and a minimum of 25 inspections performed that can be a combination of 1-foot axial length sections and individual components for each material type.

o Include inspection locations based on the likelihood of corrosion under insulation (i.e., components experiencing alternate wetting and drying in environments where trace contaminants could be present and for components that operate for long periods of time below the dew point).

o Allow subsequent inspections to consist of an examination of the exterior surface of the insulation for indications of damage to the jacketing or protective outer layer of the insulation, if the following conditions are verified in the initial inspection: no loss of material due to general, pitting or crevice corrosion, beyond that which could have been present during initial construction, and no evidence of cracking.

o Ensure that if the external visual inspections of the insulation reveal damage to the exterior surface of the insulation or there is evidence of water intrusion through the insulation (e.g., water seepage through insulation seams or joints), periodic inspections under the insulation will continue at such intervals that would ensure the component's intended function.

• Provide guidance that removal of tightly adhering insulation that is impermeable to moisture is not required unless there is evidence of damage to the moisture barrier. However, the entire population of in-scope piping component surfaces that have tightly adhering insulation will be visually inspected for damage to the moisture barrier with the same frequency as for other types of insulation inspections. These inspections will not be credited towards the inspection quantities for other types of insulation.

• Include the following acceptance criteria:

o Stainless steel should have a clean shiny surface with no discoloration.

o Other metals should not have any abnormal surface indications.

o Flexible polymeric materials should have a uniform surface texture and color with no cracks and no dimensional change, no abnormal surface with the material in an as-new condition with respect to hardness, flexibility, physical dimensions, and color.

o Rigid polymeric materials should have no erosion, cracking, checking, or chalking.

The inspectors determined that the work orders required to perform the required walkdowns are in the process of being issued in October 2024. The inspectors were able to close the program due to all the approvals for creating the work orders were completed. The inspectors determined EN-DC-17, "System Walkdowns," revision 8, met commitment requirements.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(9)18.1.11 Fatigue Monitoring Program This existing program monitors the number of pressure and temperature transient cycles and periodically compares this cycle count with the design limits for cycle counts to ensure that the fatigue sensitive components remain within their allowable design. Monitoring the cycle count ensures that pressure and thermal cycles are maintained within their design limits and tracked to identify abnormal trends toward their design limits. The fatigue monitoring program monitors the number of transient cycles that are considered in the fatigue analyses for all fatigue usage locations.

Commitment 8 specified:

Enhance the fatigue monitoring program to:

• Monitor and track additional critical thermal and pressure transients for components that have been identified to have a fatigue time-limited analysis.

• Develop a set of fatigue usage calculations that consider the effects of the reactor water environment for a set of sample reactor coolant system components. This sample shall include the location identified in NUREG/CR-6260 and additional plant-specific component locations in the reactor coolant pressure boundary if they are found to be more limiting than those considered in NUREG/CR-6260. Fatigue correction factors (Fen) shall be determined using the formulae listed in LRA, Section 4.3.3.

• The methodology for determining limiting locations will be based on EPRI report 1024995, Environmentally Assisted Fatigue Screening, Process and Technical Basis for Identifying EAF Limiting Locations, with the following modifications.

o Components in one thermal zone will not be used to bound components in different thermal zones.

o Comparisons between components will use a Fen calculated with realistic dissolved oxygen values, worst case (minimum) metal strain rate, worst case (maximum) sulfur in the metal and maximum metal service temperature.

o A Fen for one material will not be used to bound the Fen for a location of a different material.

• Analysts will ensure that comparisons to determine limiting locations will compare usage values that are determined with comparable methods. For example, a component with a low fatigue usage value determined with a refined analysis may be more limiting than a component with a higher cumulative usage factor determined with a simplified analysis.

• Environmentally assisted fatigue analysis using NUREG/CR-6909 will not use average temperature for complex transients. For simple transients that use average temperature, when the minimum temperature is below the threshold temperature, the maximum and threshold temperature will be used to calculate the average temperature.

• Provide updates of the fatigue usage calculations on an as-needed basis if an allowable cycle limit is approached or in a case where a transient definition has been changed, unanticipated new thermal events are discovered, or the geometry of components has been modified.

All actions are complete, and all fatigue locations have been identified. The usage factors have been determined to be less than 1, with the exception of the charging inlet nozzles.

The inspectors reviewed ASME Section XI Appendix L analyses that were performed for the charging inlet nozzles. The Appendix L flaw tolerance analysis demonstrated that flaws will not grow to an unacceptable size between in-service examinations based on conservative ASME Section XI Appendix L methodology. The results show the limiting location at both nozzles as the safe-end to pipe weld. Both of the charging nozzle safe-end to pipe welds will be examined by ultrasonic testing every 10 years to support the Appendix L evaluations.

The inspectors confirmed that the charging pump nozzle examinations, required by the fatigue monitoring program, were translated into the in-service inspection program and the 10 year inspection frequency guidance was contained in procedures SEP-ISI-104, PE-002-003 & CEP-COS-0110.

The inspectors inquired how the recent plant trips were accounted for in the plant fatigue analyses. Due to this question, the licensee reviewed data and found they had not been updating the cycle counting as required by the program. This is detailed as an observation in the Inspection Results section of the report.

The inspectors confirmed the licensee completed the remaining required commitments and implemented the procedures associated with this program prior to the period of extended operation. Based on the review of the procedures, inspection work-orders, work control program documents, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(10)18.1.12 Fire Protection Program This existing program manages cracking, loss of material, delamination, separation, and change in material properties (shrinkage, loss of material) through periodic visual inspection of components and structures with a fire barrier intended function (seals, fire barrier walls, ceilings, floor, and other fire-resistant materials, such as flamastic, fire wrapping, spray-on fire proofing material). The program also performs periodic visual and functional testing of fire doors to ensure their operability.

The program includes visual inspections of not less than 10 percent of each type of penetration fire seal at least once per refueling cycle. Visual inspections of the fire barrier walls, ceilings, and floors in structures within the scope of license renewal are performed at a frequency of at least once per refueling cycle. The frequency of visual inspections of the fire door surfaces and functional testing of fire door closing mechanism and latches is at least once per refueling cycle.

Commitment 9 specified:

Enhance the fire protection program to:

• Perform an inspection at least once per refueling cycle of fire barrier walls, ceilings, and floors for any signs of degradation, such as spalling, loss of material caused by chemical attack, or reaction with aggregates.

• Inspect fire-rated doors for any degradation of door surfaces at least once per refueling cycle.

• Provide acceptance criteria of no significant indications of concrete spalling, and loss of material of fire barrier walls, ceilings, and floors and in other fire barrier materials.

• Provide acceptance criteria that specify no surface degradation of fire doors.

The inspectors reviewed implementing procedures, aging management program basis document, work orders, surveillances, inspections, and test results. The inspectors walked down fire protection equipment and discussed the fire protection program details with the program owner. The inspectors noted that the commitment requires a look for degradation of doors, however, the licensee did not have a specific definition for degradation. The inspectors observed that degradation could be defined to eliminate interpretation by craft and engineering.

The inspectors confirmed the licensee completed the required commitments and implemented the procedures associated with this program prior to the period of extended operation.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(11)18.1.13 Fire Water System Program and Commitment 10 This existing program manages loss of material, flow blockage due to fouling, and loss of coating integrity for in-scope long-lived passive water-based fire suppression system components using periodic flow testing and visual inspections in accordance with NFPA 25 (2011 Edition). In addition, the fire water system pressure is monitored such that a loss of system pressure is immediately detected and corrective action is initiated. When visual inspections are used to detect loss of material and fouling, the inspection technique is capable of detecting surface irregularities that could indicate wall loss due to corrosion, corrosion product deposition, and flow blockage due to fouling.

Commitment 10 specified:

Enhance the fire water system program procedures to:

• Inspect for loss of fluid in the glass bulb heat responsive elements.

• Perform an inspection of each building's wet pipe fire water system every 5 years by opening a flushing connection at the end of one main and by removing a sprinkler toward the end of one branch line for the purpose of inspecting the interior for evidence of loss of material and the presence of foreign organic or inorganic material that could result in flow obstructions or blockage of a sprinkler head. The inspection method used shall be capable of detecting surface irregularities that could indicate wall loss below nominal pipe wall thickness due to corrosion, corrosion product deposition, and flow blockage due to fouling. Ensure procedures require a follow-up volumetric wall thickness evaluation where irregularities are detected.

• Perform an internal inspection every 5 years for evidence of loss of material and the presence of foreign organic or inorganic material that could result in flow obstructions or blockage of a sprinkler head of the dry piping downstream of preaction valves. The inspection shall be performed by opening a flushing connection, removing the most remote sprinkler head, and using a method capable of detecting surface irregularities that could indicate wall loss below nominal pipe wall thickness due to corrosion, corrosion product deposition, and flow blockage due to fouling.

• Perform an internal inspection every 5 years for evidence of loss of material and the presence of foreign organic or inorganic material that could result in flow obstructions or blockage of a sprinkler head of the dry piping downstream of the automatic deluge valves. The inspection shall be performed by opening a flushing connection, removing the most remote sprinkler head, and using a method capable of detecting surface irregularities that could indicate wall loss below nominal pipe wall thickness due to corrosion, corrosion product deposition, and flow blockage due to fouling.

• Perform an inspection of the nozzles associated with the charcoal filters for loss of material and foreign or organic material when the charcoal is replaced in water tanks in accordance with NFPA 25 (2011 Edition), Sections 9.2.6, including sub-steps.

• Remove strainers every 5 years and after each actuation to clean and inspect for damage and corroded parts.

• Specify that sprinkler heads are tested or replaced in accordance with NFPA-25 (2011 Edition), Section 5.3.1.

• Conduct a flow test or flush sufficient to detect potential flow blockage or conduct a visual inspection of 100 percent of the internal surface of piping segments that cannot be drained or piping segments that allow water to collect in each 5-year interval, beginning 5 years prior to the period of extended operation.

• Perform volumetric wall thickness inspections of 20 percent of the length of piping segments that cannot be drained or piping segments that allow water to collect each 5-year interval of the period of extended operation. Measurement points shall be obtained to the extent that each potential degraded condition can be identified (e.g., general corrosion, Microbiologically Induced Corrosion). The 20 percent of piping that is inspected in each 5-year interval is in different locations than previously inspected piping.

• Perform a blockage evaluation if the flowing pressure decreases by more than 10 percent from the original main drain test or previous main drain tests.

• Flow test the charcoal filter unit's manual deluge valve systems with air on an annual basis to ensure there are no obstructions. If obstructions are found, the system shall be cleaned and retested.

• Open and close hydrant valves slowly while performing flow tests to prevent surges in the system. The program shall also require full opening of the hydrant valve.

• Verify the hydrants drain within 60 minutes after flushing or flow testing.

• Ensure the training and qualification of the individual performing the evaluation of fire water storage tank coating degradation is in accordance with ASTM International standards endorsed in Regulatory Guide (RG) 1.54, including limitations, if any, identified in RG 1.54 on a particular standard.

• Ensure a fire water tank is not returned to service after identifying interior coating blistering, delamination or peeling unless there are only a few small intact blisters surrounded by coating bonded to the substrate as determined by a qualified coating specialist, or the following actions are performed:

o Any blistering in excess of a few small intact blisters that are not growing in size or number, or blistering not completely surrounded by coating bonded to the substrate is removed.

o Any delaminated or peeled coating is removed.

o The exposed underlying coating is verified to be securely bonded to the substrate as determined by an adhesion test endorsed by RG 1.54 at a minimum of three locations.

o The outermost coating is feathered and the remaining outermost coating is determined to be securely bonded to the coating below via an adhesion test endorsed by RG 1.54 at a minimum of three locations adjacent to the defective area.

o Ultrasonic testing is performed where there is evidence of pitting or corrosion to ensure the tank meets minimum wall thickness requirements.

o An evaluation is performed to ensure downstream flow blockage is not a concern.

o A follow-up inspection is scheduled to be performed within 2 years and every 2 years after that until the coating is repaired, replaced, or removed.

o Revise Fire Water System Program procedures to determine the extent of coating defects on the interior of the fire water tanks by all of the following methods when conditions such as interior pitting, corrosion, or coating failure are identified during visual examination.

o Dry film thickness measurements at random locations to determine overall thickness of the coating.

o Spot-wet sponge testing or dry film testing to identify holidays in the coating to detect pinholes, cracks, or other compromises in the coating. Special attention shall be given to sharp edges such as ladder rungs, nuts, and bolts.

o Adhesion testing in accordance with ASTM D3359, ASTM D4541, or equivalent testing endorsed by RG 1.54 at a minimum of three locations.

o Ultrasonic testing where there is evidence of pitting or corrosion to determine if the tank thickness meets the minimum thickness criteria.

o Tanks with flat bottoms shall be vacuum box tested at bottom seams in accordance with test procedures found in NFPA 22, Standard for Water Tanks for Private Fire Protection.

• Include acceptance criteria for the fire water tanks' interior coating that include:

o Indications of peeling and delamination are not acceptable.

o Blisters are evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including limitations, if any, identified in RG 1.54 on a particular standard.

Blisters should be limited to a few intact small blisters that are completely surrounded by sound coating/lining bonded to the substrate. Blister size and frequency should not be increasing between inspections (e.g., reference ASTM D714-02, "Standard Test Method for Evaluating Degree of Blistering of Paints").

o Indications such as cracking, flaking, and rusting are to be evaluated by a coatings specialist qualified in accordance with an ASTM International standard endorsed in RG 1.54 including limitations, if any, identified in RG 1.54 on a particular standard.

o As applicable, wall thickness measurements, projected to the next inspection, meet design minimum wall requirements.

o When conducting adhesion testing, results meet or exceed the degree of adhesion recommended in plant-specific design requirements specific to the coating/lining and substrate.

• Include acceptance criteria of no abnormal debris (i.e., no corrosion products that could impede flow or cause downstream components to become clogged). Any signs of abnormal corrosion or blockage will be removed, its source and extent of condition determined and corrected, and entered into the corrective action program.

• Specify replacement of any sprinkler heads that show signs of leakage, excessive loading, corrosion, or loss of fluid in the glass bulb heat responsive element.

• Perform an obstruction evaluation if any of the following conditions exist:

o There is an obstructive discharge of material during routine flow tests.

o An inspector's test valve is clogged during routine testing.

o Foreign materials are identified during internal inspections.

o Sprinkler heads are found clogged during removal or testing.

o Pin hole leaks are identified in fire water piping.

o After an extended fire water system shutdown (greater than one year).

o There is a 50 percent increase in time it takes for water to flow out the inspector test valve after the associated dry valve is tripped when compared to the original acceptance criteria or last test.

• Evaluate for Microbiologically Induced Corrosion if tubercules or slime are identified during any internal inspections of fire water piping.

• Perform preaction valve trip testing every 3 years with the manual isolation valve closed.

The inspectors reviewed the aging management program basis documents, implementing procedures, completed work orders and surveillances satisfying the testing and examination requirements for the program, plant operating experience, and corrective action documents. The inspectors interviewed plant personnel and walked down fire water system equipment, including the fire pumps and jockey pumps, fire water storage tanks, fire water deluge system, fire brigade hoses, sprinkler systems in the turbine building, transformer deluge sprinklers, and associated piping and valves.

The inspectors verified that fire protection procedures and work orders accounted for the license renewal commitments incorporated Commitment 10. The inspectors verified that procedures were updated to look for and take the following actions with regards to the fire water storage tanks: Training and qualification of the individual performing the inspections are in accordance with ASTM standards endorsed by RG 1.54, the acceptance criteria for interior coatings is updated, perform an extent of condition on the interior if defects are identified, and if defects are found, the tanks are not returned to service until after a qualified coating specialist or additional actions are taken.

The inspectors verified that the licensee inspected the inside of the firewater storage tank and created several condition reports to address the issues. The inspectors verified the licensee is taking the actions to correct the conditions.

The inspectors determined that the licensee started planning for the 50-year sprinkler testing and/or replacement. The inspectors reviewed the inspections of the dry-pipe and determined that there was standing water in all of the thirteen dry-pipes. The inspectors verified in some cases there was mud build up that completely obstructed the entire diameter of the pipe. The inspectors verified that if the dry-pipe system was required to actuate it would still be able to actuate even with mud buildup in the pipes. The licensee was not able to perform a 100 percent inspection of the pipe and has created a license basis change request deviation and is planning to add low point drains so that the pipes will not have to be 100 percent inspected.

Based on the review of the procedures and records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of significance associated with the aging management program.

(12)18.1.14 Flow-Accelerated Corrosion Program This existing program manages loss of material caused by wall thinning for piping and components subject to flow-accelerated corrosion. This program includes conducting appropriate analysis and baseline inspections, determining the extent of thinning, performing follow-up inspections, and taking corrective actions as necessary. The program implements nondestructive methods including ultrasonic testing, radiographic testing, and visual inspections to assure structural integrity. The program also manages the effects of aging caused by other wall-thinning mechanisms (erosion) that may be identified through industry or plant-specific operating experience. The program relies on implementation of guidelines published by Electric Power Research Institute (EPRI) in NSAC-202L, Recommendations for an Effective Flow Accelerated Corrosion Program, and on internal and external operating experience.

Commitment 11 specified:

Enhance the flow-accelerated corrosion (FAC) program to:

• Manage wall thinning due to erosion mechanisms from cavitation, flashing, liquid droplet impingement, and solid particle impingement.

• Include susceptible locations based on the extent-of-condition reviews in response to plant-specific or industry operating experience, and EPRI TR-1011231, "Recommendations for Controlling Cavitation, Flashing, Liquid Droplet Impingement, and Solid Particle Erosion in Nuclear Power Plant Piping," and NUREG/CR-6031, "Cavitation Guide for Control Valves".

• Ensure piping and components replaced with FAC-resistant material and subject to erosive conditions are not excluded from inspections.

• Include the need for continued wall thickness measurements of replaced piping until the effectiveness of the corrective action is assured.

• Evaluate wall thinning due to erosion from cavitation, flashing, liquid droplet impingement, and solid particle impingement when determining a replacement type of material.

The inspectors reviewed the aging management program basis document, implementing procedures, completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors confirmed the licensee completed the required commitment and examinations, implemented the procedures associated with this program prior to the period of extended operation.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(13)18.1.15 Inservice Inspection Program This is an existing program, consistent with the Generic Aging Lessons Learned (GALL) Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD, designed to manages cracking, loss of material, and reduction in fracture toughness for ASME Class 1, 2, and 3 pressure-retaining components including welds, pump casings, valve bodies, integral attachments, and pressure-retaining bolting, as well as nickel alloy and cast austenitic stainless steel (CASS)components. The program uses periodic volumetric, surface, and visual examination and leakage testing as specified in ASME Section XI code, and updates the program every 10 years to conform to the latest ASME Section XI code edition and addendum approved by the NRC in 10 CFR 50.55a.

The licensee revised the UFSAR information using LBDCR 2024-001 to delete the original commitment to revise lnservice Inspection Program procedures to include a supplemental inspection of Class 1 CASS components that do not meet the material selection criteria of NUREG-0313, revision 2, with regard to ferrite and carbon content. The change document details that ASME Section XI Code requirements currently provide for inspections (UT and VT2 examinations) to ensure detection of cracking in Class 1 CASS components before loss of intended function should cracking occur, thus no supplemental inspections are required. The inspectors questioned aspects of the LBDCR related to previous approval for this approach at a different licensee, and the licensee clarified that this approach, including use of the Water Chemistry Control Primary and Secondary Program, ensures that water quality is maintained at a level that minimizes the potential for cracking, and there was no Waterford 3 or industry operating experience related to cracking of Class 1 CASS piping in pressurized water reactors. The inspectors had no concerns with this change.

The inspectors reviewed the aging management program basis document, implementing procedures, license basis change documents and documentation of completed program activities and inspection results. The inspectors confirmed the licensee implemented this program prior to the period of extended operation.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(14)18.1.16 Inservice Inspection - IWF Program This existing program manages aging effects for ASME Class 1, 2, and 3 piping and component supports affecting general mechanical and structural condition or degradation. The program is implemented through plant procedures which provide administrative controls for the conduct of activities that are necessary to fulfill the requirements of ASME Section XI, as mandated by 10 CFR 50.55a. The implementing procedures use recommendations in NUREG-1339 and industry recommendations in EPRI NP-5769, NP-5067, and TR-104213 to ensure proper specification of bolting material, lubricant, and installation torque.

The program uses nondestructive examination techniques to include verification of clearances, settings and physical displacements and identification of loose or missing parts, debris, corrosion, wear, erosion, or the loss of integrity at welded or bolted connections.

Commitment 12 specified:

Enhance the ISI-IWF program to:

• Include the preventive actions for storage of ASTM A325, ASTM F1852, and ASTM A490 bolting from Section 2 of Research Council on Structural Connections publication, "Specification for Structural Joints Using ASTM A325 or A490 Bolts.

• Specify that detection of aging effects will include monitoring anchor bolts for loss of material, loose or missing nuts and bolts, and cracking of concrete around the anchor bolts.

• Revise plant procedures to specify the following conditions as unacceptable:

o Loss of material due to corrosion or wear, which reduces the load bearing capacity of the component support.

o Debris, dirt, or excessive wear that could prevent or restrict sliding of the sliding surfaces as intended in the design basis of the support.

o Cracked or sheared bolts, including high strength bolts, and anchors.

• Revise plant procedures to include assessment of the impact on the inspection sample representativeness if components that are part of the sample population are reworked.

The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed program activities and inspection results. The inspectors confirmed the licensee completed the required commitment and implemented the procedure revisions associated with this program prior to the period of extended operation.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(15)18.1.17 Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems Program This existing program manages loss of material and loss of preload for bolting for all cranes, bridges, trolley and hoist structural components, fuel handling equipment, and crane rail wear within the scope of license renewal. This includes visual inspection of structural components and structural bolts for loss of materials caused by corrosion of structural members and bolting, loss of materials caused by wear of rails, and loss of preload for bolted connections. Prior to June 18, 2024, the licensee was required to complete the below enhancements to existing overhead crane program.

Commitment 13 specified:

Enhance the program to:

• Monitor crane rails for loss of material due to wear; monitor structural components of the bridge, trolley and hoists for deformation, cracking, and loss of material due to corrosion; and monitor structural connections for loose or missing bolts, nuts, pins or rivets and any other conditions indicative of loss of bolting integrity.

• Specify inspection frequency in accordance with ASME B30.2 or other appropriate standard in the ASME B30 series. Infrequently used cranes and hoists will be inspected prior to use. Bolted connections will be visually inspected for loose or missing bolts, nuts, pins or rivets at the same frequency as crane rails and structural components.

• Require that significant loss of material due to wear of crane rails and any sign of loss of bolting integrity will be evaluated in accordance with ASME B30.2 or other appropriate standard in the ASME B30 series.

• Specify that maintenance and repair activities will utilize the guidance provided in ASME B30.2 or other appropriate standard in the ASME B30 series.

The inspectors reviewed the aging management program basis document, implementing procedures, nondestructive evaluation reports, crane inspection reports, completed work orders, and commitment closure documentation. The inspectors verified the various crane inspection procedures included enhancement commitments prior to the June 18, 2024, deadline. The procedures included the appropriate inspection frequency, inspection of various components and materials, and disposition of issues identified would follow the appropriate ASME B30 series standard.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(16)18.1.18 Internal Surfaces in Miscellaneous Piping and Ducting Components Program This new program manages the effects of aging using opportunistic visual inspections of the internal surfaces of metallic piping, piping components, ducting, elastomeric components, and other components during periodic surveillances or maintenance activities when the surfaces are accessible.

The licensee will perform an assessment of opportunistic inspections to ensure a representative sample, in each 10-year period during the period of extended operation, for each material-environment-aging effect combination. The licensee will complete directed inspections to a representative sample of 20 percent of the population with a maximum of 25 components for each material-environment-aging effect combination during the 10-year period under review. Where practical, inspections will focus on the components most susceptible to aging due to time in service and severity of operating conditions.

For metallic components visual inspection will be used to detect evidence of loss of material and reduction of heat transfer due to fouling. For non-metallic components, visual inspections and physical manipulation or pressurization will be used to detect evidence of surface irregularities. Visual examinations of elastomeric components will be accompanied by physical manipulation such that changes in material properties are readily observable. The sample size for physical manipulation will be at least 10 percent of accessible surface area.

Commitment 14 specified:

• Implement the internal surfaces in miscellaneous piping and ducting components program as described in the LRA.

The inspectors reviewed the aging management program basis document, implementing procedures, and held discussions with site personnel and fleet program owners. The inspectors reviewed procedure SEP-AMP-WF3-001, WF3 Opportunistic Inspections for Aging Management Programs, and confirmed the licensee developed opportunistic inspection programs for internal surfaces in miscellaneous piping and ducting components.

The inspectors concluded that the licensee appropriately implemented the program prior to the period of extended operation. However, because this is a new program and inspections will begin during the period of extended operation, there were no examination results for the inspectors to review.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(17)18.1.19 Masonry Wall Program This existing program manages aging effects for each masonry wall within the scope of license renewal. Masonry walls are visually examined at a frequency selected to ensure there is no loss of intended function between inspections.

This existing program, implemented as part of the structures monitoring program, manages cracking of masonry walls. The program required four enhancements and incorporates the guidance provided in Bulletin 80-11, Masonry Wall Design and Information Notice 87-67, Lessons Learned from Regional Inspections of Licensee Actions in Response to NRC IE Bulletin 80-11.

Commitment 15 specified:

Revise plant procedures to:

• Ensure masonry walls located for in-scope structures are included in the scope of the masonry wall program.

• Include monitoring gaps between the structural steel supports and masonry walls that could potentially affect wall qualification.

• Specify that masonry walls will be inspected at least once every 5 years with provisions for more frequent inspections in areas where significant aging effects (missing blocks, cracking, etc.) are observed to ensure there is no loss of intended function.

• Include acceptance criteria for masonry wall inspections that ensure observed aging effects (cracking, loss of material, or gaps between the structural steel supports and masonry walls) do not invalidate the wall's evaluation basis or impact its intended function.

The inspectors reviewed the aging management program basis document, implementing procedures, work orders, and completed inspection results. The inspectors interviewed the program owner, reviewed license renewal implementing documents, drawings, implementing procedures, and industry standards. The inspectors confirmed that procedure EN-DC-150, Condition Monitoring of Maintenance Rule Structures, revision 18, implemented the requirements to inspect masonry walls at 5-year intervals and sections that specified the requirement to identify nonconforming conditions, including gaps. The inspectors confirmed the licensee completed the required commitments and implemented the procedures associated with this program prior to the period of extended operation.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(18)18.1.20 Metal Enclosed Bus Inspection Program This new program, consistent with the GALL report, inspects and manages the effects of aging on non-segregated metal enclosed electrical buses (MEB). The program inspects and manages the safety-related 4.16 kV MEBs between switchgear 3A3-S, 3AB3-S and 3B3-S, and the safety-related 480V MEBs between 3A31-S, 3AB31-S and 3B31-S.

The program provides for the visual inspection of enclosure internal surfaces to detect aging effects, including cracking and loss of material, foreign debris, excessive dust buildup, and evidence of moisture intrusion. Bus insulating material is visually inspected for signs of aging due to thermal/thermoxidative degradation of organics/thermoplastics, radiation-induced oxidation, moisture/debris intrusion, or ohmic heating, as indicated by embrittlement, cracking, chipping, melting, swelling, discoloration, or surface contamination. The internal bus insulating supports are inspected for structural integrity and signs of cracks. Bus external surfaces are visually inspected for loss of material due to general pitting, and crevice corrosion.

Accessible elastomers (e.g., gaskets, boots, and sealants) are inspected for degradation, including surface cracking, crazing, scuffing, and changes in dimensions, discoloration, hardening, and loss of strength. A sample of accessible bolted electrical connections are tested for excessive heating caused by increased connection resistance using thermography or by measuring connection resistance with a micro-ohmmeter.

Commitment 16 specified:

• Implement the metal enclosed bus inspection program as described in the LRA.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors walked down accessible MEBs with licensee staff to inspect material conditions, discuss operating experience and lessons learned from previous bus inspections. The inspectors verified procedure EN-DC-349, "Metal Enclosed Bus Inspection Procedure," had identified the parameters and acceptance requirements for the program. The inspectors confirmed the licensee completed the required commitment and inspections, and implemented the program requirements prior to the period of extended operation.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(19)18.1.21 Neutron-Absorbing Material Monitoring Program This is an existing program designed to detect degradation of the neutron absorbing properties of the material within the Spent Fuel Pool storage racks to prevent an inadvertent criticality event. This program provides controls for monitoring the loss of material or loss of neutron absorption capability of the Boral, which is the neutron absorbing material in the Spent Fuel Pool storage racks.

Commitment 17 specified:

• Compare measurements from periodic inspections to prior measurements, and relate coupon measurement results to the performance of the spent fuel neutron absorber materials considering differences in exposure conditions, vented/non-vented test samples, spent fuel racks, etc. Ensure the predicted Boron-10 areal density will be sufficient to maintain the subcritical conditions required by technical specifications until the next coupon test.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed program activities, and held discussions with site personnel and fleet program owners. The inspectors determined the licensee had not fully implemented the commitment. Contrary to license renewal commitment documented in FSAR Section 18.1.21, the Neutron Absorbing Material Monitoring (NAMM) program procedure NE-001-106 does not specify comparison of periodic inspections to prior measurements, and relate coupon measurement results to the performance of the spent fuel neutron absorber materials considering differences in exposure conditions, vented/non-vented test samples, spent fuel racks, etc. Also, contrary to license renewal commitment in FSAR Section 18.1.21, the 2024 NAMM program vendor surveillance report does not explicitly address ensuring that the predicted Boron-10 areal density will be sufficient to maintain the subcritical conditions required by technical specifications until the next coupon test. The vendor surveillance report stated that was outside the scope of the contract. The vendor did provide recommendations to aid the licensee in performing an evaluation of the Boron-10 areal density to ensure that subcritical conditions are sufficiently maintained until the next coupon test. The vendor also suggested the licensee consider increasing the frequency or shortening the testing window, which is currently set at 10 years.

Based on the review of the procedures, test results, and discussions with licensee and fleet personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program. However, considering the commitment was not fully implemented, this aging management program commitment will remain open and be reviewed by the NRC during a Phase 3 license renewal inspection. The timing of those inspections will be dependent on the outcomes of two condition reports written by the licensee to address the inspectors concerns with this aging management program, specifically CR-WF3-2024-02177 and CR-WF3-2024-04837, as well as any subsequent condition reports and evaluations that are completed by the licensee to fully implement this commitment. This issue is documented as an observation in the Inspection Results section of the report.

(20)18.1.23 Non-EQ Electrical Cable Connections Program This one-time program consists of a representative sample of electrical connections within the scope of license renewal, which is inspected or tested at least once prior to the period of extended operation to confirm that there are no aging effects requiring management during the period of extended operation. Cable connections included in this program are those connections susceptible to age-related degradation resulting in increased resistance of connection due to thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, or oxidation.

The connections inspected are medium and low voltage, defined as less than 35 KV, circuit loading (high loading), connection type, and location (high temperature, high humidity, vibration). This inspection is performed prior to the period of extended operation.

Commitment 18 specified:

• Implement the non-EQ electrical cable connections program as described in the LRA.

The inspectors reviewed the sampling plan, aging management program basis document, completed work orders, and corrective action documents. The inspectors discussed the results of the inspections with the program owner. Procedure WF3-EE-00002, Non-EQ Electrical Cable Connections Program Inspection, prescribed implementation of the one-time inspections. The inspectors verified that the licensee used infrared thermography to measure for heat generated because of increased resistance at the connections. The licensee identified several areas that required a condition report (i.e., CR-2022-00163, CR 2022-00132, CR-2022-00146, and CR-2023-14508). These hotspots were internal connections to an active component that are not part of the aging management program. The inspectors reviewed CR-WF3-2022-06298 for a hotspot on the emergency diesel generator (EDG) that if failed would cause the EDG to become inoperable. The inspectors interviewed the licensee and reviewed documentation and determined the actions taken were acceptable.

Based on the review of the procedures, work orders, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(21)18.1.24 Non-EQ Inaccessible Power Cables (>/= 400 V) Program This was a new program, consistent with the GALL Report AMP XI.E3, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, with one exception to the preventive actions program element. The in-scope inaccessible power cables included in the program are the 480 V electric motor-driven fire pump supply cable, and the 480 V electric motor-driven jockey fire pump cable. The program is credited with managing aging effects through condition monitoring actions, including periodic testing and visual inspections. The exception to the preventive actions program element removes the requirement to perform increased manhole inspection frequency if water is found in the manholes during periodic inspections. The site elevation is such that for the in-scope manholes, water cannot be prevented from entering and wetting the in-scope cables.

The licensee's program is implemented by fleet procedure EN-DC-346, Cable Reliability Program, which implements the requirements for inspections and testing.

In-scope cables are tested at least once every six years. There are no splices in these underground cables, and there is no current history of water treeing in cables that operate at less than 2 kV. Manhole inspections will assess any visible cable and cable support damage due to exposure to significant moisture, and periodic cable testing will provide reasonable assurance that each cable will continue to perform its intended function through the period of extended operation.

Commitment 19 specified:

• Implement the non-EQ inaccessible power cables (>/= 400 V) program as described in the LRA.

The licensee revised the UFSAR information using LBDCR 23-020 to remove the requirement for event-driven manhole inspections from the program. The inspectors had no concerns with this change as inclusion of event-driven inspections would appear to provide no added value to the program as the in-scope cables are continuously wetted.

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors verified procedure EN-DC-346, Cable Reliability Program," had identified the parameters and acceptance requirements for the program. The inspectors confirmed the licensee completed the required commitment and inspections, and implemented the program requirements prior to the period of extended operation.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(22)18.1.25 Non-EQ Sensitive Instrumentation Circuits Test Review Program This new monitoring program manages the aging effects of cable degradation on sensitive, high-voltage, low-signal cables exposed to adverse localized equipment environments caused by heat, radiation, and moisture (i.e., neutron flux monitoring instrumentation and process radiation monitoring) can be maintained consistent through the period of extended operation. The review of calibration results or findings of testing will be performed once every 10 years, with the first review occurring before the period of extended operation.

The following cables shall be tested:

• excore neutron flux monitoring system

• radiation monitoring

• process monitoring system - component cooling water monitors

• area radiation monitoring system - channels 28-31

• area radiation system - fuel handling building

• airborne monitoring system - main control room monitors Commitment 20 specified:

• Implement the non-EQ sensitive instrumentation circuits test review program as described in the LRA.

The inspectors reviewed the license renewal program basis documents, completed work orders, cable routing and plant drawings, and corrective action documents.

The inspectors verified test report WF3-EP-23-00001, Non-EQ Sensitive Instrumentation Circuits Test Review Program Report. The inspectors identified that no condition report was created on a channel A degraded excore shielding cable. The shielding did not adversely affect the operation of the equipment.

Based on the review of the procedures and records, the inspectors did not identify any additional findings or violations of more than minor significance for this aging management program.

(23)18.1.26 Non-EQ Insulated Cables and Connections Program This new program monitors the loss of insulated cables and connections exposed to adverse localized environments caused by heat, radiation, and moisture, and can be maintained consistent with the current licensing basis through the period of extended operation. An adverse localized environment is a condition in a limited plant area that is significantly more severe than the plant design environment for the cable or connection insulation materials.

The program consists of accessible insulated cables and connections installed in adverse localized environments to be visually inspected at least once every 10 years for cable jacket and connection insulation surfaces anomalies, such as embrittlement, discoloration, cracking, melting, swelling, or surface contamination, that could indicate incipient conductor insulation aging degradation from temperature, radiation, or moisture.

Commitment 21 specified:

• Implement the non-EQ insulated cables and connections program as described in the LRA.

The inspectors reviewed procedure EN-DC-348, Non-EQ Insulated Cables and Connections Inspection, revision 8. The inspectors determined that the requirements for an adverse localized environment as detailed in the procedure were adequate. The inspectors also reviewed the specific cable temperatures and radiation dose for a specific cable type to reach 60 years and did not identify any issues.

Additionally, the inspectors reviewed the results of the licensee inspections found in WF3-EP-23-00004, Non-EQ Insulated Cable and Connection Inspection Report.

The results determined two locations with elevated temperature and condition reports were generated (CR-2022-05766 and CR-2022-05823). The inspectors inquired what actions had been done with those areas. The inspectors determined that the licensee has a plan to inspect the adverse localized environment cables in November 2024.

Based on the review of the procedures, records and discussion with licensee personnel, the inspectors did not identify any findings or violation of more than minor significance for this aging management program.

(24)18.1.27 Oil Analysis Program This existing program ensures that loss of material and reduction of heat transfer are not occurring by maintaining the quality of lubricating oil. The licensee uses analysis and periodic sampling to detect evidence of abnormal wear rates, moisture contamination, excessive corrosion, and oil degradation. The program ensures that contaminants (primarily water and particulates) remain within acceptable limits. This program interfaces with the one-time inspection program and the preventative maintenance aging management program.

The inspectors reviewed the aging management program basis document, implementing procedures, completed program activities, and held discussions with the site program owner, fleet program owner, and system engineer. Specifically, the inspectors verified the dew point data, particulates data for oil samples, and trends.

The inspectors confirmed the licensee implemented the procedures associated with this program prior to the period of extended operation.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(25)18.1.28 One-Time Inspection Program This new program manages loss of material, cracking, and reduction of heat transfer due to fouling. This program verifies system-wide effectiveness of other aging management programs using one-time inspection activities that verify unacceptable aging effects are not occurring, or are occurring at a rate that will not cause a loss of intended function during the period of extended operation. The program consists of one-time inspections of selected components in different environments to verify the effectiveness of the Water Chemistry Control, Diesel Fuel Monitoring, and Oil Analysis Programs. In addition, one-time inspections were performed on the reactor vessel flange leak detection line and plant stack radiation monitor stainless steel tubing exposed to outdoor air.

Acceptance criteria was based on applicable ASME or other appropriate standards, design basis information, or vendor-specified requirements and recommendations.

Indications or relevant conditions were evaluated. The need for follow-up examinations was evaluated based on inspection results.

The program included activities to verify effectiveness of aging management programs and activities to confirm the insignificance of aging effects as described below:

• Water Chemistry Control - Primary and Secondary Program - One-time inspection activity verified the effectiveness of the Water Chemistry Control - Primary and Secondary Programs by confirming that cracking, loss of material, and reduction of heat transfer were not occurring.

• Oil Analysis Program - One-time inspection activity verified the effectiveness of the Oil Analysis Program by confirming that cracking, loss of material, and reduction of heat transfer were not occurring.

• Diesel Fuel Monitoring Program - One-time inspection activity verified the effectiveness of the Diesel Fuel Monitoring Program by confirming that loss of material or reduction of heat transfer due to fouling were not occurring.

• Reactor vessel flange leak detection line - One-time inspection activity confirmed that cracking and loss of material were not occurring.

• Plant stack radiation monitor stainless steel tubing exposed to air-outdoor - One-time inspection activity confirmed that cracking was not occurring.

This program required no enhancements or exceptions.

Commitment 22 specified:

• Implement the one-time inspection program as described in the LRA.

During inspections of carbon steel components in a treated water environment the licensee identified two issues for further evaluation. Both instances were identified as cases of erosion, and were entered into the licensee's corrective action program as CR-WF3-2022-2592 and CR-WF3-2023-16802. The inspectors reviewed the licensee's actions and had no concerns.

The inspectors reviewed the aging management program basis document, implementing procedures, completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors confirmed the licensee implemented the commitment and completed the required examinations associated with this program prior to the period of extended operation.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(26)18.1.29 One-Time Inspection - Small-Bore Piping Program This new one-time program manages cracking of ASME Code Class 1 piping less than four inches nominal pipe size (NPS 4) and greater than or equal to one-inch nominal pipe size (NPS 1) in systems that have not experienced cracking. The program included a sampling approach, selecting 10 Class 1 butt welds and 7 small-bore Class 1 socket welds for examination. Sample selection was based on susceptibility to stress corrosion, cyclic loading (including thermal, mechanical, and vibration fatigue), thermal stratification, thermal turbulence, dose considerations, and operating experience. The program included volumetric (ultrasonic) testing examinations conducted in accordance with ASME Section XI.

Commitment 23 specified:

• Implement the one-time inspection - small-bore piping program as described in the LRA.

The inspectors reviewed the aging management program basis document, implementing procedures, completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors confirmed the licensee implemented the commitment and completed the required examinations associated with this program prior to the period of extended operation.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(27)18.1.30 Periodic Surveillance and Preventive Maintenance (PSPM) Program This existing program provides timely detection of aging effects through periodic testing and inspections primarily conducted during scheduled periodic maintenance activities. The licensee established inspection intervals to provide for timely detection of degradation. Inspection intervals are dependent on the component material and environment and take into consideration industry and plant-specific operating experience and manufacturers recommendations. The extent and schedule of inspections and testing are designed to assure detection of component degradation prior to loss of intended functions.

Commitment 24 specified:

• Enhance the periodic surveillance and preventive maintenance program as described in the LRA.

The inspectors reviewed the aging management program basis document, implementing procedures, inspection results of completed program activities, and held discussions with site personnel and fleet program owners.

The inspectors reviewed the following UFSAR/commitment change to the program:

• LBDCR 2022-033 revised the inspection frequency to once per 10 years consistent with the changes proposed in NRC's interim staff guidance document LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation.

This is consistent with the frequency of other periodic inspection programs, such as, the Internal Surfaces in Miscellaneous Piping and Ducting Components Program and this frequency was approved by the NRC for River Bend's PSPM program.

The inspectors confirmed the licensee completed the required commitments and implemented the procedures associated with this program prior to the period of extended operation. Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(28)18.1.31 Protective Coating Monitoring and Maintenance Program This existing program manages aging of Service Level I coatings inside the containment building where failure could adversely affect post-accident fluid systems that could impair safe shutdown. The program includes visual inspections of surfaces for missing or degraded coatings, including blistering, discoloration, flaking (scaling),peeling, and other signs of distress. Prior to the period of extended operation, the licensee was required to complete the below enhancements to the Protective Coating Monitoring and Maintenance Program.

Commitment 25 specified:

• Revise procedures to specify visual inspections of coatings near sumps or screens associated with the emergency core cooling system (ECCS).

The inspectors reviewed the aging management program basis document, implementing procedures, documentation of completed program activities, and held discussions with the site. The inspectors reviewed the refueling outage containment coatings inspection reports for outages 21-25 which included the conditions of the coatings inside the containment. The inspectors did not identify any significant coating issues in these areas.

The licensee incorporated the enhancement activities to inspect the coatings near sumps and screens associated with the ECCS into procedure EN-DC-220, "Safety-Related Coatings Program," revision 7. The inspectors confirmed the licensee completed the required commitments and implemented the procedures associated with this program prior to the period of extended operation.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(29)18.1.32 Reactor Head Closure Studs Program This existing program manages cracking and loss of material for reactor head closure stud bolting using in-service inspection and preventive measures. The licensee performs visual examinations to identify cracking and loss of material in the connecting studs. Surface or volumetric examinations of the reactor vessel head closure studs detect and size cracks in these connections.

Commitment 26 specified:

Enhance the reactor head closure studs program to:

• Ensure that replacement studs are fabricated from bolting material with actual measured yield strength less than 150 ksi.

• Exclude the use of molybdenum disulfide (MoS2) on the reactor vessel closure studs.

The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed program activities and held discussions with site personnel. The inspectors confirmed the licensee implemented the procedures associated with this program prior to the period of extended operation. One issue identified by the inspectors related to design procurement procedures did not ensure that replacement studs would be fabricated from bolting material with actual measured yield strength less than 150 ksi per Commitment 26(a). The details of this observation is titled High Strength Bolts in the Inspection Results section of this report.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(30)18.1.33 Reactor Vessel Internals Program The Reactor Vessel Internals program is an existing program, consistent with the GALL report after enhancement, credited with managing aging effects of vessel internal components providing core support through the implementation of Electric Power Research Institute (EPRI) Technical Reports materials reliability program (MRP) -227 and -228. Additional plant-specific activities not defined in MRP 227-A are implemented through commitment to Nuclear Energy Institute (NEI) 03-08, "Guideline for the Management of Materials Issues." The scope of the program applies the methodology and guidance in the most recently NRC-endorsed version of MRP-227, providing augmented inspection and flaw evaluation methodology for assuring the functional integrity of safety-related internals.

The program is designed to manage aging effects related to

(a) various forms of cracking, including stress corrosion cracking, primary water stress corrosion cracking, irradiation assisted stress corrosion cracking, or cracking caused by fatigue/cyclical loading;

(b) loss of material induced by wear;

(c) loss of fracture toughness caused by either thermal aging or neutron irradiation embrittlement;

(d) changes in dimensions caused by void swelling or distortion; and

(e) loss of preload caused by thermal and irradiation enhanced stress relaxation or creep.

Commitment 27 specified:

Enhance the reactor vessel internals program to:

• Include the inspections identified in the inspection plan in NRC submittal W3F1-2013-0070, dated December 16, 2013, including the inspection of the core stabilizing bolts as an addition to the ASME Section XI In-Service Inspection Program.

The licensee revised the UFSAR information using LBDCR 2022-022 to revise Section 18.1.33 to remove revision levels of documents including deletion of the -A at the end of MRP-227 and 228. The team did not identify any concerns with this change because the commitment to NEI 03-08 requires using the current revision level of these documents.

The inspectors reviewed the aging management program basis document, revised implementing procedures, completed inspection activities, corrective action program evaluation of related issues, and commitment closure documents. The inspectors confirmed the licensee implemented the commitment associated with this program prior to the period of extended operation.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(31)18.1.34 Reactor Vessel Surveillance Program The Reactor Vessel Surveillance Program is an existing program that manages reduction of fracture toughness for reactor vessel beltline materials using material data and dosimetry. The program includes all reactor vessel beltline materials as defined by 10 CFR Part 50, Appendix G, Section II.F, and complies with 10 CFR Part 50, Appendix H, for surveillance monitoring and includes reference to Appendix G of 10 CFR Part 50.

The objective of the Reactor Vessel Surveillance Program is to provide sufficient material data and dosimetry to

(a) monitor irradiation embrittlement at the end of the period of extended operation and

(b) establish operating restrictions on the inlet temperature, neutron spectrum, and neutron flux after a surveillance capsule is withdrawn for testing. If surveillance capsules are not withdrawn during the period of extended operation, operating restrictions are specified to ensure that the plant is operated under the conditions to which the surveillance capsules were exposed.

Capsules removed from the reactor vessel are tested and reported in accordance with ASTM E 185-82 to the extent practicable for the configuration of the specimens in the capsule. Any changes to the capsule withdrawal schedule, including the withdrawal schedule for spare capsules, must be approved by the NRC prior to implementation. Untested capsules placed in storage must be maintained for future insertion.

Commitment 34 specified:

Enhance the reactor vessel surveillance program to:

• Specify submittal of a withdrawal schedule for Capsule 277 degrees (Capsule W-277) to the NRC for review and approval within 1 year following the receipt of the renewed license.

The licensee submitted the withdrawal schedule for NRC approval via letter W3F1-2019-0001 on April 25, 2019 (ML19115A417). This was within one

(1) year following receipt of the renewed license (December 2018) and this action ensured that these commitments were satisfied. Specifically, the licensee proposed to change the withdrawal of Capsule W-277 from Standby to 48 effective full power years. The updated withdrawal schedule was approved by the NRC on October 15, 2019 (ML19282D892). The new schedule was incorporated into UFSAR table 5.3-10 via LBDCR 19-029.

The inspectors confirmed the licensee completed the required commitments and revised the procedures associated with this program prior to the period of extended operation.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(32)18.1.35 Selective Leaching Program This new program includes one-time visual inspections of selected components coupled with hardness measurement or other mechanical examination techniques to determine whether selective leaching causes a loss of material and to establish the extent of the sample size and frequency of the periodic program to inspect for selective leaching during the period of extended operation.

Commitment 28 specified:

• Enhance the program as described in the LRA.

The inspectors reviewed inspection results, engineering reports, work activities, implementing procedures and interviewed license renewal project personnel. The program was implemented within 5 years of the period of extended operation per the LRA. The inspectors determined that the licensee used the aging management program guidelines in NUREG-2191,Section XI.M33, Selective Leaching, for implementing the one-time selective leaching sample sizes and for developing the periodic program that will be implemented during the period of extended operation.

Specifically, the program sample size included selected components (20 percent the population with a maximum of 25 components) fabricated from gray cast iron and certain copper/zinc alloys that were in an environment of raw water, wastewater, treated water, or soil. The sample population focused on components most susceptible to aging due to time in service, severity of operating condition, and lowest design margin.

The inspectors confirmed the licensee completed the required commitments and implemented the procedures associated with this program prior to the period of extended operation. Based on the inspection results and only the presence of minor selective leaching discovered on the susceptible samples investigated, the licensee evaluated that no further samples were required. The inspectors concluded that the licensee completed the required actions and developed the Selective Leaching Program in accordance with NRC guidance documents.

Based on the review of the procedures, records, and discussion with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(33)18.1.37 Steam Generator Integrity Program This existing program manages aging effects for the steam generator tubes, plugs, sleeves, and secondary side components contained within the steam generator in accordance with the plant technical specifications and commitments to NEI 97-06.

The preventive and mitigative measures include foreign material exclusion programs and other primary and secondary side maintenance activities. The program has acceptance criteria for when a tube should be plugged based on wall thickness measurements. Condition monitoring assessments are performed to confirm that adequate tube integrity has been maintained since the previous inspection and operational assessments are performed to ensure that tube integrity will be maintained until the next scheduled inspection. The acceptance criteria are in accordance with the technical specifications.

Commitment 33 specified:

Enhance the steam generator integrity program to:

• Include general visual inspections of the partition plate, channel head, and tubesheet (primary side) with a frequency of at least once every 72 effective full power months.

The inspectors reviewed the aging management program basis document, implementing procedures, work orders, and completed inspection results. The implementing procedures captures the acceptance criteria, and the additional enhancement specified the commitment. Additionally, the original commitment stated a frequency of at least once every 72 effective full power months or every third refueling outage. The licensee submitted a license amendment request for NRC review that changed the frequency from at least once every 72 effective full power months to at least once every 96. The NRC issued the renewed license amendment on December 8, 2021.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(34)18.1.38 Structures Monitoring Program This existing program manages the effects of aging on structures and structural components, including structural bolting, within the scope of license renewal. The program was based on guidance in Regulatory Guide 1.160, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, revision 2, and NUMARC 93-01, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, revision 2, to satisfy the requirement of 10 CFR 50.65.

Commitment 30 specified:

Enhance the structures monitoring program to:

• Revise plant procedures to include the following in-scope structures:

o battery house 230kV switchyard o

control house 230kV switchyard o

fire pump house o

fire water storage tank foundations o

fuel oil storage tank foundation o

manholes, handholes and duct banks o

plant stack o

transformer and switchyard support structures and foundations

• Revise plant procedures to include a list of structural components and commodities within the scope of the program.

• Revise plant procedures to include periodic sampling and chemical analysis of ground water.

• Revise plant procedures to include the preventive actions for storage of ASTM A325, ASTM F1852, and/or ASTM A490 bolting from Section 2 of Research Council on Structural Connections publication, "Specification for Structural Joints Using ASTM A325 or A490 Bolts."

• Revise plant procedures to include the following parameters to be monitored or inspected:

o For concrete structures, base inspections on quantitative requirements of industry codes, standards and guidelines (e.g., ASCE 11, ACI 349.3R) and consideration of industry and plant-specific operating experience.

o For concrete structures and components include loss of material, loss of bond, increase in porosity and permeability, loss of strength, and reduction in concrete anchor capacity due to local concrete degradation.

o For chemical analysis of ground water, monitor pH, chlorides and sulfates.

• Revise plant procedures to include the following components to be monitored for the associated parameters:

o Anchor bolts (nuts and bolts) for loss of material, and loose or missing nuts and/or bolts.

o Elastomeric vibration isolators and structural sealants for cracking, loss of material, loss of sealing, and change in material properties (e.g.,

hardening).

• Revise plant procedures to include the following:

o Visual inspection of elastomeric material should be supplemented by feel or touch to detect hardening if the intended function of the elastomeric material is suspect. Include instructions to augment the visual examination of elastomeric material with physical manipulation of at least 10 percent of available surface area.

o Structures will be inspected at least once every 5 years with provisions for more frequent inspections of structures and components categorized as (a)(1) in accordance with 10 CFR 50.65.

• Inspect submerged structures at least once every 5 years.

• Sampling and chemical analysis of ground water at least once every 5 years.

The program owner will review the results and evaluate any anomalies and perform trending of the results.

• Revise plant procedures to inspect the safety injection tank and reactor coolant system supports with ASTM A-540 high-strength bolting greater than one-inch nominal diameter prior to the period of extended operation and at least once every 5 years thereafter. The periodic visual inspections are intended to detect whether a corrosive environment that supports stress corrosion cracking (SCC) potential exists or has existed since the previous inspection.

• Acceptance criteria for the inspections will be the absence of evidence of moisture, residue, foreign substances, or corrosion.

• Conditions that don't meet the acceptance criteria and thus indicate a potential corrosive environment that supports SCC will be entered into the corrective action program for evaluation.

• Revise plant procedures to include qualitative and quantitative acceptance criteria for A-540 bolts as follows:

o If moisture is present at or near a bolt or stud, factors considered in the evaluation include, but are not limited to:

source of leakage or condensation that supplied the moisture

proximity of the moisture to the bolt or stud

probable or analyzed chemical characteristics of the moisture, including the presence of contaminants

visible or likely pathway, if any, that the liquid traversed to arrive at or near the bolt or stud

amount of any corrosion on or near the bolt or stud

material condition of the coatings on the bolt or stud, and associated support

characteristics of any corrosion on or near the bolt or stud

proximity to the bolt or stud of any nearby evidence of corrosion

material condition of accessible concrete or grout near the bolt or stud o

If there is evidence that moisture had been present at or near a bolt or stud, but no moisture is present at or near a bolt or stud, factors considered by engineering include, but will not be limited to:

probable sources of past leakage or condensation that could have supplied the moisture

proximity to the bolt or stud to the evidence that moisture had been present

probable or analyzed chemical characteristics of any moisture residue, including the presence of contaminants

visible or likely pathway, if any, that the liquid may have traversed to arrive at or near the bolt or stud

amount of any corrosion on or near the bolt or stud

material condition of any coatings on the bolt or stud, and associated support

characteristics of any corrosion on or near the bolt or stud

proximity to the bolt or stud of any nearby evidence of corrosion

material condition of concrete or grout near the bolt or stud

• Should adverse conditions be identified during the examinations, engineering will determine if the bolting has been exposed to a corrosive environment with the potential to cause SCC. Bolts determined to have been exposed to a corrosive environment with the potential to cause SCC will be identified as within a population where SCC is a concern. A sample equal to 20 percent (rounded up to the nearest whole number) of the population, with a maximum sample size of 25 bolts, will be subject to volumetric examination. The selection of the samples will consider susceptibility to stress corrosion cracking (e.g., actual measured yield strength) and as-low-as-reasonably-achievable (ALARA) considerations.

The inspectors reviewed the aging management program basis document, implementing procedures, work orders, and completed inspection results. The inspectors interviewed the program owner, reviewed license renewal implementing documents, drawings, implementing procedures. The inspectors confirmed that procedure EN-DC-150, Condition Monitoring of Maintenance Rule Structures, revision 18, implemented the requirements to inspect structures at 5-year intervals and sections that specified the requirement to identify nonconforming conditions, and enhanced the structure monitoring program with additional inspection areas. The inspectors confirmed the licensee completed the required commitments and implemented the procedures associated with this program prior to the period of extended operation.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(35)18.1.36 Service Water Integrity Program This existing program manages loss of material and fouling in open-cycle cooling water systems as described in the licensee's response to NRC GL 89-13, Service Water System Problems Affecting Safety-Related Equipment. The program also includes inspections for loss of material caused by erosion. In addition, the program includes inspections of coatings for submerged piping in the standby service water basin.

Commitment 29 specified:

Revise service water integrity program procedures to:

• Flush redundant, infrequently flowed sections, and stagnant lines to ensure there is no blockage.

• Inspect selected low flow or stagnant areas and system low points such as drains.

The inspectors reviewed examination reports, work orders, procedures, drawings, completed work activities, completed inspections, and drawings. The inspectors interviewed license renewal program personnel and the program owner. The inspectors reviewed open cycle cooling water inspection activities that included loop flow tests, heat exchanger inspections including photographs, heat exchanger performance testing, eddy current testing, tube plugging, microbiologically induced corrosion inspections, and corrective actions. The inspectors determined that the licensee implemented their open-cycle cooling water inspection and assessment activities.

The inspectors questioned how the licensee could flush the cross-tie lines between the A and B wet cooling towers of the auxiliary component cooling water system. The licensee generated preventative maintenance change requests PMC-24-048796 and PMC-24-048797 for flushing the cross-tie line, and those actions are scheduled to be completed in refueling outage RFO25 (April 2025).

The inspectors determined that procedure EN-DC-184, NRC Generic Letter 89-13 Service Water Program, described that erosion would be evaluated as a condition in the service water system. The inspectors determined that the licensee inspects and evaluates erosion in the service water system with periodic internal inspections of the auxiliary component cooling water system flow control butterfly valves, ACC-126A and ACC-126B. The inspectors reviewed preventative maintenance identification PMIDs 23216-02 and 23217-02, which are the preventative maintenance tasks to look for erosion for the valves.

The inspectors confirmed the licensee completed the required commitments and implemented the procedures associated with this program prior to the period of extended operation.

Based on the review of the procedures, records, and discussions with licensee personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(36)18.1.39 Thermal Aging Embrittlement of Cast Austenitic Stainless Steel Program This is a new program, consistent with the GALL report, credited with managing reduction in fracture toughness caused by thermal aging embrittlement in susceptible American Society of Mechanical Engineers (ASME) Code Class 1 piping components (except for pump casings and valve bodies), made from cast austenitic stainless steel (CASS) with service conditions above 250 degree C (482 degrees F). This program augments the existing Boiler and Pressure Vessel Code,Section XI inspections requirements.

The licensee determined that the components identified as susceptible are the surge line piping and elbows, the safety injection nozzle safe ends, and the reactor coolant pump suction and discharge nozzle safe-ends. Susceptible components aging management is accomplished through qualified visual inspections, such as enhanced visual examination, qualified ultrasonic testing methodology, or component-specific flaw tolerance evaluation in accordance with ASME Section XI code.

Commitment 31 specified:

• Implement the thermal aging embrittlement of cast austenitic stainless-steel program as described in the LRA.

The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed program activities and inspection results. As allowed by the GALL report, the licensee performed a component-specific flaw tolerance evaluation using specific geometry, stress information, material properties, and ASME Code,Section XI to demonstrate that the thermally-embrittled material has adequate toughness, and for the maximum predicted fatigue crack growth for susceptible CASS components the postulated flaw will not grow beyond the tolerable flaw size after 60-years of crack growth. The inspectors confirmed the licensee completed the required commitment and implemented the procedures associated with this program prior to the period of extended operation.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(37)18.1.40 Water Chemistry Control - Closed Treated Water Systems Program The purpose of the Water Chemistry Control - Closed Treated Water Systems program is to manage aging effects caused by fouling, corrosion and cracking mechanisms. The program relies on monitoring and control of water chemistry based on EPRI Closed Cooling Water Chemistry Guidelines.

The program manages loss of material, reduction of heat transfer due to fouling, and cracking in the following closed treated water systems:

• component cooling water (CC or CCW)

• chilled water portion of HVAC (essential and supplemental)

• turbine building cooling water

• diesel generator jacket water for emergency diesel generators Commitment 40 specified:

• Revise Water Chemistry Control - Closed Treated Water Systems Program procedures to include high pressure fire water diesel pump jacket water system. [Further review of this enhancement determined that the fire water diesel pump jacket water system does not require the testing and action levels of the EPRI Closed Cooling Water Chemistry Guideline and the closed treated water system procedures. The fire water pump diesel engine is a simple diesel engine that uses antifreeze, which is periodically replaced. Therefore, an LBDCR and commitment change are recommended to provide for the periodic change out of the fire water pump diesel engine coolant.]

• Revise Water Chemistry Control - Closed Treated Water Systems Program procedures to specify water chemistry parameters monitored and the acceptable range of values for these parameters that are in accordance with EPRI 1007820, industry guidance, or vendor recommendations.

• Revise the Water Chemistry Control - Closed Treated Water Systems Program procedures to inspect accessible components whenever a closed treated water system boundary is opened. Ensure that a representative sample of piping and components is inspected at a frequency of at least every 10 years. These inspections will be conducted in accordance with applicable ASME Code requirements, industry standards, or other plant-specific inspection guidance by qualified personnel using procedures that are capable of detecting corrosion, fouling, or cracking. If visual examination identifies adverse conditions, additional examinations, including ultrasonic testing, are conducted.

• Revise the Water Chemistry Control - Closed Treated Water Systems Program procedures to define a representative sample as 20 percent of the population (defined as components having the same material, environment, and aging effect combination) with a maximum of 25 components.

Components inspected will be those with the highest likelihood of corrosion, fouling, or cracking.

• Revise the Water Chemistry Control - Closed Treated Water Systems Program procedures to perform treated water sampling and analysis of the closed treated water systems per industry standards and in no case greater than quarterly unless justified with an additional analysis.

• Revise the Water Chemistry Control - Closed Treated Water Systems Program procedures to provide acceptance criteria for inspections. Ensure system components meet system design requirements, such as minimum wall thickness.

The inspectors performed tours of the relevant areas of the plant containing the closed treated water systems, reviewed the implementing procedures, water chemistry sample results and trends, corrective action program evaluations of water chemistry conditions, and interviewed licensee personnel. The inspectors confirmed the licensee's existing Water Chemistry Control for Closed Treated Water Systems has been effective at managing aging effects.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

(38)18.1.41 Water Chemistry Control - Primary and Secondary Program There were no specific commitments to be reviewed for this aging management program.

The Water Chemistry Control - Primary and Secondary Program is an existing program that manages loss of material, cracking, and reduction of heat transfer in components in an environment of treated water through periodic monitoring and control of water chemistry. The Water Chemistry Control - Primary and Secondary Program monitors and controls water chemistry parameters such as pH, chloride, fluoride, and sulfate to keep peak levels of various contaminants below system specific limits. The program relies on monitoring and control of water chemistry based on the EPRI guidelines for primary water chemistry and secondary water chemistry.

The program includes inspections of components in the reactor coolant system, the engineered safety features, the auxiliary systems, and the steam and power conversion system for license renewal as described in FSAR Section 18.1.41 and listed in FSAR Table 18.4.1. The licensee relies upon the existing program to ensure that age-related degradation of primary and secondary systems from water chemistry issues are prevented or mitigated. The Primary and Secondary Water Chemistry Control Program includes sampling and analysis frequencies for chemical species, and corrective actions for control of primary and secondary water chemistry. These actions minimize contaminant concentration thereby managing loss of material and stress corrosion cracking. The program also provides for physical inspection of systems when they are opened for maintenance.

The inspectors reviewed the implementing procedures, water chemistry sample results and trends, corrective action program evaluations of water chemistry conditions, and interviewed licensee personnel. The inspectors confirmed the licensee's existing Primary and Secondary Water Chemistry Control Program has been effective at managing aging effects.

Based on the review of the procedures and records, the inspectors did not identify any findings or violations of more than minor significance for this aging management program.

INSPECTION RESULTS

Observation: High Strength Bolts 71003 The inspectors reviewed License Renewal Application Commitments 1(b), Commitment 1(c),and Commitment 26(a) to ensure the applicable programs' procedures adequately ensured the commitments would be met. Each of these commitments were related to high strength bolts (>150 ksi). Commitments 1(b) and 1(c) required additional inspection and volumetric testing of high strength pressure-retaining bolts >2" diameter every 10 years on a sampling basis. Commitment 26(a) required the licensee to ensure that all reactor head closure replacement studs had actual yield strength less than 150 ksi.

The licensee attempted to make procedural changes to licensee procedure EN-DC-141, "Design Inputs," revision 19, to control new purchases of high strength bolts for either pressure-retaining components or reactor head closure studs. However, the inspectors identified the wording in the procedure was inadequate to ensure that the procurement specifications for pressure-retaining bolts would receive for the required inspections per Commitment 1(b) and Commitment 1(c). Further, it circumvented the Commitment 26(a)requirements that replacement bolts for the reactor head would be less than 150 ksi. The licensee had not procured any high strength bolts, nor has any in service, and therefore was not a current issue. The licensee placed this issue into their corrective action program and initiated CR-WF3-2024-04858 to address the procedural oversight and ensure the commitments would be met for subsequent purchases of pressure-retaining bolts and reactor head closure studs.

Observation: Neutron Absorbing Material Monitoring Program 71003 The inspectors determined the licensee had not fully implemented license renewal Commitment 17. Contrary to license renewal commitment documented in FSAR Section 18.1.21, it appears the Neutron Absorbing Material Monitoring (NAMM) program procedure NE-001-106 does not specify comparison of periodic measurements to prior measurements, and relate coupon measurement results to the performance of the spent fuel neutron absorber materials considering differences in exposure conditions, vented/non-vented test samples, spent fuel racks, etc. Contrary to license renewal commitment in FSAR Section 18.1.21, the 2024 NAMM program vendor surveillance report does not explicitly address ensuring that the predicted Boron-10 areal density will be sufficient to maintain the subcritical conditions required by technical specifications until the next coupon test. The vendor surveillance report stated that was outside the scope of the contract. The vendor did provide recommendations to aid the licensee in performing an evaluation of the Boron-10 areal density to ensure that subcritical conditions are sufficiently maintained until the next coupon test. The vendor also suggested the licensee consider increasing the frequency or shortening the testing window, which is currently set at 10 years.

Based on the review of the procedures, test results, and discussions with licensee and fleet personnel, the inspectors did not identify any findings or violations of more than minor significance for this aging management program. However, considering the commitment was not fully implemented, this aging management program commitment will remain open and be reviewed by the NRC during Phase 3 license renewal inspections. The timing of those inspections will be dependent on the outcomes of two condition reports written by the licensee to address the inspectors' concerns with this aging management program, specifically CR-WF3-2024-02177 and CR-WF3-2024-04837, as well as any subsequent condition reports and evaluations that are completed by the licensee to fully implement this commitment.

Observation: Fatigue Monitoring Aging Management Program Cycle Counting 71003 During a review of the Fatigue Monitoring Aging Management Program, the inspectors questioned how the site was tracking the recent plant transients. Procedure PE-002-003, "Fatigue Monitoring Program," provides instructions for monitoring thermal and pressure transient cycles to ensure the ongoing validity of Waterford 3 design fatigue analyses. The procedure indicates that an engineering report should be prepared to document the number of accumulated cycles and projected cycles for each tracked transient (i.e. Cycle Count Report) typically on a two-cycle basis. Step 5.3.1.3 requires a condition report (CR) to be initiated if actual or projected cycles exceed design limits. Contrary to the above, only one cycle count report has been initiated since 2014. That report, covering operation from 2014 through 2020, was prepared by an engineering vendor in 2021. In addition, the 2021 report identified two pressurizer auxiliary spray transients with projected cycles exceeding design limits. No condition report was initiated to document and evaluate that condition.

As a result of the inspectors' review, the licensee initiated CR-WF3-2024-04962. Although the site's cycle count reporting had not been completed, the inspectors reviewed the licensee's preliminary analysis and determined there was adequate margin in the fatigue design analysis so as to not challenge the operability of any structure, system or component.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On October 9, 2024, the inspectors presented the license renewal, phase 2 inspection results to Joseph Sullivan, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

CWTR3-22-188

Waterford 3 EAF Evaluations

11/22/2023

LTR-SDA-22-017

Waterford Unit 3 License Renewal - ASME XI Appendix L

Evaluation Results for the Charging Nozzles

Calculations

WSES-18Q-301

MRP-146 ASSESSMENT OF NORMALLY STAGNANT

NON-ISOLABLE BRANCH LINES

Corrective Action

Documents

CR-WF3-

22-02592, 2023-16802, 2024-02177, 2024-04837, 2022-

00163, 2022-00132, 2022-00146, 2022-06298, 2022-05766,

22-05823

Corrective Action

Documents

Resulting from

Inspection

CR-WF3-2024-

2599, 04509, 04522, 04523, 04601, 04627, 04668, 04741,

04962, 04858, 04920

LBDCR 2020-036

Change the description of the ASME code edition used from

the 2001 Edition 2003 Addenda to the 2007 Edition 2008

Addenda for the aging management programs in chapters

18.1.6, 18.1.15, 18.1.32 and 18.1.39 of the FSAR

09/24/20

LBDCR 2022-022

LBPCR to remove revision levels of documents including

deletion of the -A at the end of MRP-227 and 228 in FSAR

Section 18.1. 33

08/20/2023

LBDCR 2022-033

PSPM Program change

LBDCR 2023-020

Change to remove the program provision to perform event-

driven manhole inspections

08/22/2023

LBDCR 2024-001

Delete commitment to revise lnservice Inspection Program

procedures to include a Supplemental inspection of Class 1

CASS piping components

01/17/2024

Engineering

Changes

LBDCR 23-0027

Bolting Integrity Program Changes

10/11/23

23-08-24

BURIED PIPING SOIL SAMPLING CORROSIVITY

ANALYSIS REPORT

06/01/2023

CCC 10862E

Cathodic Protection System Survey Underground Piping and

Grounding Waterford3

03/14/2024

EN-DC-348

Non-EQ Insulated Cables and Connections Inspection

008

71003

Engineering

Evaluations

PQE - WF3 -

SOLENOID VALVE

000

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

AVCo -

44400R97

PQE - WF3 -

Cameron

(ITT Barton) - 9A-CR3-580A-29

000

PQE - WF3 -

General Atomic

E-255-1047 Radiation detector

000

PQE - WF3 -

General Electric -

GE Test

CONTROL STATION

000

PQE - WF3 -

Okonite

NQRN-3 (MV Cables)

000

PQE - WF3 -

Rockbestos

QR-8802 CABLE

000

PQE - WF3 -

Rosemount

D2010015 TRANSMITTER

000

PQE - WF3 -

Weed

06-8680-003 RESISTANCE TEMP. DETECTOR

000

WF3-CS-14-

00001

WF3-CS-14-00001

WF3-EE-14-

00001

Electrical Screening and Aging Management Review

WF3-EE-24-

00001

Metal Enclosed Bus Inspection Program Review Report

WF3-EE-24-

00002

Non-EQ Electrical Cable Connections Program Inspection

000

WF3-EP-14-

00006

Aging Management Program Evaluation Results - Class 1

Mechanical

WF3-EP-14-

00007

Aging Management Program Evaluation Results Non-Class 1

Mechanical (One-Time Inspection)

WF3-EP-14-

00007-4

Aging Management Program Evaluation Results Non-Class 1

Mechanical (Service Water Integrity)

WF3-EP-14-

00008

Aging Management Program Evaluation Results

Civil/Structural, Section 3.3

WF3-EP-14-

Aging Management Program Evaluation Results - Electrical

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

00009

WF3-EP-19-

00015

Review of the Flow-Accelerated Corrosion Program for

License Renewal Implementation

WF3-EP-19-

00017

Review of the Inservice Inspection-IWF Program for License

Renewal Implementation

WF3-EP-19-

00021

Review of the Metal Enclosed Bus Inspection Program for

License Renewal Implementation

WF3-EP-19-

00025

Review of the Non-EQ Inaccessible Power Cables (>=400V)

Program for License Renewal Implementation

WF3-EP-19-

00029

Review of the One-Time Inspection Program for License

Renewal Implementation

WF3-EP-19-

00030

Review of the One-Time Inspection - Small-Bore Piping

Program for License Renewal Implementation

WF3-EP-19-

00034

Review of the Reactor Vessel Internals Program for License

Renewal Implementation

WF3-EP-19-

00040

Review of the Thermal Aging Embrittlement of Cast

Austenitic Stainless Steel Program for License Renewal

Implementation

WF3-EP-23-

00001

Non-EQ Sensitive Instrumentation Circuits Test Review

Program Report

WF3-EP-23-

00004

Non-EQ Insulated Cable and Connection Inspection Report

WF3-EP-24-

00002

Screening of Components for Thermal Aging Embrittlement

of CASS Components

WF3-EP-24-

00006

Waterford 3 One-Time Inspection Aging Management

Program Review (XI.M32)

WF3-EP-24-

00007

WF3 Selective Leaching Aging Management Program

Review

WF3-EP-24-

00011

Aging Management of CASS Piping for Waterford Steam

Electric Station, Unit 3 CASS Flaw Tolerance Evaluation

Final Report

WF3-ME-24-

00001

One-Time Inspection - Small Bore Piping Program Review

Miscellaneous

2353477

Vendor Report - EMSL Analytical, Inc. - Wipe Sample for

03/30/2023

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Chloride - Plant Vent Stack Radiation Monitor Sample Line

ATC-105

Cooling Tower Institute (CTI) Acceptance Test Code

2/01/2000

FTK-ESPP-

G00019

Implementing the Flow Accelerated Corrosion (FAC)

Program

LMT-PAUT-

WF3_RF24-001

Encoded Phased Array Ultrasonic Examination Report

License Renewal Socket Welded Joints Work Order #00559688-01, Line# 1RC1-171

04/06/2022

LMT-PAUT-

WF3_RF24-003

Encoded Phased Array Ultrasonic Examination Report

License Renewal Socket Welded Joints Work Order #00559689-01, Line# 1RC1-63RL2

04/13/2022

LMT-PAUT-

WF3_RF25-002

Encoded Phased Array Ultrasonic Examination Report

License Renewal Socket Welded Joints Work Order #00584445-01, Line# 1RC1-66RL2

10/22/2023

SEP-RVI-007

Waterford 3 Reactor Vessel Internals Inspection (RVII)

Program Plan

WF3-EP-20-

00001

WF3 RF23 FAC Post-Outage and Pass 2 Report

WF3-EP-24-

00001

WF3 RF-25 FAC Program Post Outage Report

NDE Reports

LMT-PAUT-

WF3_RF24-002

Encoded Phased Array Ultrasonic Examination Report

License Renewal Socket Welded Joints Work Order #00557439-01, Line# 2RC0 3/4-56

04/10/2022

CE-001-004

Periodic Analysis Scheduling Program

27

CE-001-004

Periodic Analysis Scheduling Program

330

CE-002-007

Maintaining Component Cooling Water Chemistry

2

CE-002-013

Maintaining Essential Services Chill Water Chemistry

308

CE-002-014

Maintaining Supplemental Chill Water

305

CE-002-015

Maintaining Turbine Component Cooling Water Chemistry

307

CE-002-019

Maintaining Diesel Generator Jacket Cooling Water

Chemistry

306

CE-002-030

Maintaining Diesel Fuel Oil

CEP-FAC-001

Flow Accelerated Corrosion Program Component Scanning

And Gridding Standard

Procedures

CEP-SG-001

Steam Generator Primary Side Examinations and

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Maintenance

CEP-SG-002

Steam Generator Secondary Side Examinations and

Maintenance

CEP-SG-003

Steam Generator Integrity Assessment

EN-CY-100

Conduct of Chemistry

011

EN-CY-101

Chemistry Activities

008

EN-DC-141

Design Inputs

EN-DC-164

Environmental Qualification (EQ) Program

008

EN-DC-178

System walkdowns

008

EN-DC-220

Safety-Related Coatings Program

Revision 7

EN-DC-225

Internal Coating Integrity Program

EN-DC-315

Flow Accelerated Corrosion Program

EN-DC-317

Steam Generator Program

EN-DC-319

Boric Acid Control Program

EN-DC-340

Microbiologically Induced Corrosion (MIC) Monitoring

Program

EN-DC-340

Microbiologically Induced Corrosion (MIC) Monitoring

Program

EN-DC-343

Underground Piping and Tanks Inspection and Monitoring

Program

EN-DC-346

Cable Reliability Program

EN-DC-349

Metal Enclosed Bus Inspection Procedure

EN-DC-363

Sensitive Instrumentation Circuits Review

EN-EV-112

Chemical Control Program

EN-FAP-LR-024

One-Time Inspection

EN-FAP-LR-025

Selective Leaching Inspection

EN-FAP-LR-026

License Renewal Non-EQ Electrical Cable Connection AMP

005

EN-MA-145

Maintenance Standard for Torque Applications

EN-MP-125

Control of Material

FP-001-024

Fire Prevention Inspection

003

ME-003-004

Fire Dampers

013

ME-003-006

Fire Barrier Penetrations Seals

319

ME-003-007

Fire Wrap Barriers

018

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

ME-003-009

Fire-Rated Walls, Floors, and Ceilings

2

MM-003-019

Diesel Generator Fuel Oil Storage Tank Inspection

MM-003-020

Fire Door Surveillance

003

MM-003-021

Sprinkler System Inspection (Safety Areas)

017

MM-004-201

Containment Building Polar Crane PM

308

MM-004-401

Fuel Handling Building Crane PM

MM-004-422

Sprinkler System Inspection (Non Safety Areas)

013

MM-004-870

Kranco Overhead Cranes PM

308

MM-006-016

HECA Adsorber Filter Unit Fill and Drain

013

MM-06-106

Plant Door Maintenance

335

NE-001-106

SFSR Boral Surveillance Program

006

OOP-009-004

Fire Protection

25

OP-903-055

Fire Main Flush and Hydrant Inspection

2

OP-903-057

Fire Protection System Flow Test

28

OP-903-058

Fire Hose Station Valve Cycling Check

016

OP-903-059

Sprinkler System Functional Test

017

PE-002-003

Fatigue Monitoring Program

RF-001-008

Reactor Head Studs and Alignment Pins

24

SEP-AMP-WF3-

001

WF3 Opportunistic Inspections for Aging Management

Programs

SEP-AMP-WF3-

2

WF3 Selective Leaching Inspection Program

SEP-BAC-WF3-

001

WF3 Boric Acid Corrosion Control Program (BACCP)

Program Section

SEP-FTP-WF3-

001

Reactor Vessel Fracture Toughness and Surveillance

Material Testing at Waterford 3

001

SEP-HX-WF3-

001

Generic Letter 89-13 Heat Exchanger Test Basis

SEP-ISI-104

Program Section For ASME Section XI, Division 1 WF3

Inservice Inspection Program

SEP-ISI-104

ASME Section XI WF3 Inservice Inspection Program

SEP-ISI-104

Program Section For ASME Section XI, Division 1 WF3

Inservice Inspection Program

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

SEP-ISI-104

Program Section For ASME Section XI, Division 1 WF3

Inservice Inspection Program

SEP-RVI-007

Waterford 3 Reactor Vessel Internals Inspection (RVII)

Program Plan

SEP-SG-WF3-

001

Waterford-3 (W3/WF3) Steam Generator Program

SEP-UIP-WF3

WF3 underground components inspection plan non-rad and

rad piping

UNT-005-013

Fire Protection Program

014

Work Orders

00554048, 00479729, 00481188, 00565296, 00562950,

00590730, 00590729, 00400699, 00401851, 00554048,

00565026, 00565294, 00171163, 00321291, 00493373,

00544078, 00544079, 00549467, 00549767, 00553156,

00553301, 00557439, 00557440, 00559688, 00559689,

00563785, 00563787, 00579504, 00582047, 00583556,

00583558, 00585170, 00585171, 00589604, 52653016,

2718842, 52782381, 52889099, 52891698, 52942342,

2491030, 52949313, 52960262, 52962053, 52964304,

2965521, 53001551, 53013041, 53013411, 53014403,

54005405, 54031295, 54042523, 54048059, 54048156,

54072105, 54083985, 54084913, 54084921, 54084923,

54140226, 54153657, 54057600, 00567682, 52320328,

2856745, 52939939, 52944989, 52966034, 52966222,

2966219