IR 05000400/2007007
| ML072530894 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/10/2007 |
| From: | James Shea Division of Reactor Safety II |
| To: | Duncan R Carolina Power & Light Co |
| References | |
| IR-07-007 | |
| Download: ML072530894 (54) | |
Text
September 10, 2007Carolina Power & Light CompanyATTN:Mr. Robert IIVice President - Harris PlantShearon Harris Nuclear Power PlantP. O. Box 165, Mail Code: Zone 1New Hill, NC 27562-0165SUBJECT:SHEARON HARRIS NUCLEAR POWER PLANT - NRC INSPECTION REPORT05000400/2007007
Dear Mr. Duncan:
On July 27, 2007, the NRC completed an inspection regarding the application for licenserenewal for your Shearon Harris reactor facility. The enclosed report documents the inspectionresults, which were discussed on July 27, 2007, with Mr. C. L. Burton and other members ofyour staff in an exit meeting open for public observation at the New Horizons Fellowship facility,820 East Williams St., Apex NC.The purpose of this inspection was an examination of activities that support the application for arenewed license for the Harris facility. The inspection consisted of a selected exam ination ofprocedures and representative records, and interviews with personnel regarding implementationof your aging management programs to support license renewal. For a sample of plantsystems, inspectors performed visual examination of accessible portions of the systems toobserve any effects of equipment aging.The inspection concluded that your license renewal activities were generally conducted asdescribed in your License Renewal Application. The inspection also concluded that existingprograms to be credited as aging management programs (AMPs) for license renewal aregenerally functioning well. The applicant had established implementation plans in the plantAction Request system to track the committed future actions for license renewal to ensure theyare completed. In walking down plant systems and examining plant equipment, the inspectorsfound no significant adverse conditions, and it appears plant equipment was being maintainedadequately.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public ins pection in theNRC Public Document Room or from the Publicly Available Records (PARS) component of CP&L2NRC's document system(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Joseph W. Shea, DirectorDivision of Reactor SafetyDocket No.:50-400License No.:NPF-63
Enclosure:
NRC Inspection Report 05000400/2007007 w/Attachments: 1. Supplemental Information 2. Aging Management Programs Selected for Review 3. List of Acronyms Used
REGION IIDocket No:50-400License No:NPF-63Report No:05000400/2007007Licensee:Carolina Power and Light CompanyFacility:Shearon Harris Nuclear Power Plant, Unit 1Location:5413 Shearon Harris RoadNew Hill, NC 27562Dates:July 9, 2007 through July 27, 2007Inspectors:C. Julian, Inspection Team LeaderL. Lake, Senior Reactor InspectorB. Miller, Reactor InspectorR. Moore, Senior Reactor InspectorT. Nazario, Reactor InspectorApproved by:G. Hopper, ChiefEngineering Branch 3Division of Reactor safety Enclosure
SUMMARY OF FINDINGS
IR 05000400/2007-007; July 9, 2007 - July 27 2007; Shearon Harris Nuclear Power Plant,Unit 1; License Renewal Inspection Program, Aging Management Programs.This inspection of License Renewal (LR) activities was performed by five regional officeengineering inspectors. The inspection program followed was NRC Manual Chapter 2516 andNRC Inspection Procedure 71002. This inspection did not identify any "findings" as defined inNRC Manual Chapter 0612.The inspection concluded that LR activities were being conducted as described in the LicenseRenewal Application (LRA). The inspection also concluded that existing programs to becredited as aging management programs (AMPs) for license renewal are generally functioningwell.The applicant had established implementation plans in the plant Action Request system to trackthe committed future actions for license renewal to ensure they are completed. The inspectorsobserved a few instances where enhancements could be made to the AMP descriptiondocuments. The applicant included in the documents several enhancements pointed out by theinspectors.In walking down plant systems and examining plant equipment the inspectors found nosignificant adverse conditions and it appears plant equipment was being maintained adequately.Attachment 1 to this report contains a partial list of persons contacted and a list of documentsreviewed. The Aging Management Programs selected for review during this inspection arelisted in Attachment 2 to this report. Attachment 3 is a list of acronyms used in this report.
Enclosure
REPORT DETAILS
I.Inspection ScopeThis inspection was conducted by NRC Region II inspectors to interview applicantpersonnel and to examine a sample of documentation which supports the licenserenewal application (LRA). This inspection reviewed the implementation of theapplicant's Aging Management Programs (AMPs). The inspectors reviewed supportingdocumentation to confirm the accuracy of the LRA conclusions. For a sample of plantsystems, inspectors performed visual examination of accessible portions of the systemsto observe any effects of equipment aging. Attachment 1 of this report lists the applicantpersonnel contacted and the documents reviewed. The Aging Management Programsselected for review during this inspection are listed in Attachment 2 to this report. A listof acronyms used in this report is provided in Attachment 3.II.FindingsA.Visual Observation of Plant EquipmentDuring this inspection, the inspectors performed walkdown inspections of portions ofplant systems, structures, and components (SSCs) to determine their current conditionand to observe any effects of equipment aging. Overall the material condition at Harriswas good and no significant aging management issues were identified. The followingSSCs were observed: High Head Safety Injection SystemContainment Spray SystemComponent Cooling Water SystemResidual Heat Removal SystemDiesel Generators and BuildingVarious Cranes in the Scope of LRSpent Fuel PoolsFire Pumps Containment Building and Auxiliary BuildingService Water Intake StructuresElectrical Transformer AreaSwitchyardDams and Water Control StructuresAdditionally, at the request of NRR, the inspectors reviewed the applicant's screeningand scoping analysis for the following non-safety related systems to assess theimplementation of 10 CFR 54.4(a)(2):Service Water Screen Wash systemNon-Essential Chilled Water SystemWaste Processing Building Cooling Water systemTurbine Generator Lube Oil System 4EnclosureThe review included the applicant's calculation that assessed the system andcomponent applicability to 10 CF R 54.4(a)(2), applicable plant drawings, and visuallyexamining the in-plant configuration to attempt to identify any non-safety related systemslocated in proximity to safety related systems to assess the implementation of 10 CFR54.4(a)(2). The inspectors concluded that the applicant had appropriately implementedthe criteria of 10 CFR 54.4(a)(2) in identification of in-scope SSCs for these systems.The inspectors visually examined the Diesel Service Water Pipe Tunnel and identifiedno potential for spatial interaction between non-safety related and safety related SSCswithin the tunnel.The inspectors visually examined the service water intake structure and the adjacentcooling tower makeup strainer pit and identified no potential for spatial interactionbetween non-safety and safety related SSCs at this location. The inspectors reviewed the Security Power System diesel manual, system drawings,and the scoping calculation document and field inspected the system equipment. Nocomponents were identified that were incorrectly omitted from the aging managementreview.B.Review of Mechanical Aging Management Programs1.One Time Inspection ProgramThis is a new program that uses one-time inspections to verify the effectivenessof an aging management program and confirm the absence of an aging effect forthe period of extended operations on SSCs identified in the aging managementreview. This program will verify the effectiveness of the Water Chemistry, Fuel OilChemistry, and the Lubrication Analysis Programs. The program inspections willinclude a combination of Non Destructive Examinations (NDE) by qualifiedpersonnel following procedures consistent with ASME Code and 10 CFR 50,Appendix B. The required program elements and general statement of scope areidentified in the application, section B.2.18, One-Time Inspection Program. Theprogram scope and methodology are described in calculation HNP-P/LR- 0632,License Renewal Aging Management Program Description of the One -TimeInspection Program, Rev. 2. The SSCs within the scope of the program areidentified in the program description. A representative sample of these SSCs willreceive one time inspections. The program implementation plan is documentedin AR188046-13, One Time Inspection Program Implementation Plan. The plan stated that the sample will be devel oped and the program comp leted prior to theperiod of extended operation. The inspectors reviewed the program description,the implementation plan, the scope identification in the application, anddiscussed the program development and implementation with the responsiblestation staff.
5EnclosureThe inspectors concluded that the applicant had provided adequate guidance toensure aging effects will be appropriately assessed and managed. Whenimplemented, there is reasonable assurance that the intended function of theSSCs within the scope of this program will be maintained through the period ofextended operation.2.Selective Leaching of Materials ProgramThis new program will perform one time visual inspections/examinations todetermine whether loss of material due to selective leaching is occurring andwhether the process will affect the intended function of the SSCs. Evidence ofselective leaching will result in expanded sampling as appropriate andengineering evaluation. The program scope will include SSCs of copper alloyswith zinc content greater than 15 % and gray cast iron exposed to raw water,treated water, lubricating oil, hydraulic fluid, fuel oil, wetted air/gas or soilenvironment. The required program elements and general statement of scopeare identified in the application, section B.2.19. The implementation plandocumented in AR 188046-07, included selection of a sample population,procedure development to define the one-time examination methodology andacceptance criteria, and examinations scheduled to be completed prior to theperiod of extended operation. The inspectors reviewed the program description,HNP-P/LR-0633, Program Description of the Selective Leaching of MaterialsProgram and the implementation plan, and discussed the program developmentand implementation with the responsible station staff. The inspectors noted theimplementation plan did not include a provision for training the plant staffresponsible for performing the visual and qualitative examinations for selectiveleaching or indicate who was responsible for performing the examinations. Theinspectors also noted inconsistent wording between the application appendix Bprogram description and similar description in the program description calculationand the implementation plan related to actions to be taken when evidence ofselective leaching was identified. Following the discussion with the applicant onthis issue, actions were initiated to revise the program description and implementation plan to address these items.The inspectors concluded that the applicant conducted adequate historic reviewsof plant specific and industry experience information to determine aging effects. The applicant had provi ded adequate guidance to ensure aging effects will beappropriately assessed and managed. When implemented, there is reasonableassurance that the intended function of the SSCs within the scope of thisprogram will be maintai ned throughout the period of ext ended operations. 3.Buried Piping and Tanks Inspection Program This is a new program that will manage the aging effects on the external surfacesof buried carbon steel or cast iron piping. There are no buried tanks included inthe scope of this program. Aging effects include loss of material due to generalpitting and crevice corrosion and MIC. Aging effects are managed by preventive 6Enclosuremeasures to mitigate the aging effects, i.e. protective coatings and inspections,and visual inspections for evidence of coating damage or degradation. Buriedcomponents will be inspected when they are excavated for any reason. Theprogram requires that at least one buried piping inspection be performed everyten years. A corporate procedure has been developed for implementation of thisprogram, which requires revision to incorporate Harris site specific information. The inspectors reviewed the description of the program in application sectionB.2.20 and calculation HNP-P/LR-0634 which stated the criteria andmethodology for the program activities and identified the SSCs within the scopeof this program. Additionally the inspectors reviewed the programimplementation plan documented in AR-188046-06 and discussed the programwith the assigned responsible staff. The station excavation procedure had beenrevised to incorporate the license renewal requirements of this program.The inspectors concluded that the applicant conducted adequate historic reviewsof plant specific and industry experience information to determine aging effects. The applicant had provi ded adequate guidance to ensure aging effects will beappropriately assessed and managed. When implemented, there is reasonableassurance that the intended function of the SSCs within the scope of thisprogram will be maintai ned throughout the period of ext ended operations. 4.Water Chemistry Program This is an existing program to mitigate the aging effects on component surfacesthat are exposed to water as process fluid by monitoring and controlling waterchemistry based on the latest version of Electric Power Research Institute (EPRI)PWR Primary and Secondary Water Chemistry Guidelines. The programincludes periodic monitoring, control, and mitigation of known detrimentalcontaminants below levels known to result in loss of material, cracking and flowblockage. The program is described in Section B.2.2 of the application andcalculation HNP-P/LR-0600. The implementation plan is described in AR1888048-03. There are no enhancements planned for this program. Theimplementation plan items were to annotate procedures to identify licenserenewal credited activities. The inspectors reviewed the program documentation,discussed the program with responsible station staff, and reviewed existingprocedures which implemented the scope and actions of this program. Theinspectors reviewed trending of critical chemistry parameters and reviewed theidentification and resolution of conditions in which chemistry parameter limitswere exceeded. Additionally, the inspectors reviewed past NRC inspections andapplicant self assessments of the water chemistry program.The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.
7Enclosure5.Fuel Oil Chemistry Program This is an existing program with planned enhancements, to manage the agingeffects of loss of material to fuel oil tanks and piping by minimizing exposure tofuel oil contaminants such as water and microbiological organisms. This isaccomplished by verifying the quality of new oil before introduction into the storage tanks; addition of a stabilizer corrosi on inhibitor, and biocide; andperiodic sampling to assure that the tanks are free of water and particulate. Tanks in the scope of this program include the main fuel oil storage tanks for theemergency diesel (EDG), security diesel, and the diesel driven fire pump (DDFP)as well as the EDG and security diesel day tanks. Enhancements include a onetime ultrasonic thickness measurement inspection of the diesel fuel oil storagetank building tank liners, development of work activities to increase sampling andinspection of the security diesel and DDFP fuel oil tanks, establishment oftrending for measured parameters and establishment of administrative limits forparticulate. Additionally, the enhancements include identification in implementingprocedures of activities credited for license renewal. Enhancements arescheduled to be implemented by the beginning of the extended period ofoperations (10/25/2026). The program is described in Section B.2.16 of theapplication and calculation HNP-P/LR-0631. The implementation plan forenhancements was described in AR 188047-13. The inspectors reviewed theprogram documentation, discussed the program with responsible stationpersonnel and reviewed existing procedures which implemented the scope andactivities of this program. The inspectors reviewed results of previousinspections of fuel oil tanks and procedures and results for fuel oil tank sampling.The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented and enhanced, there is reasonable assurance that the intended function of the SSCs will be maintainedthrough the period of extended operation.6.One Time Inspection of American Society of Mechanical Engineers (ASME)Class 1 Small Bore Piping This new program will manage the aging effect of cracki ng due to thermal,mechanical and intergranular stress corrosion via volumetric examinations toidentify cracking in ASME Class 1 Small Bore Piping. Small bore piping is lessthan NPS 4 size. Volumetric examinations for small bore socket welds will not bedone. Inspection of small bore piping socket welds will continue to be by VT-2inspection as is done in the current, 2 nd interval, In-service Inspection (ISI)Program Plan. A one time volumetric examination of a sample of small bore buttwelds will be performed in lieu of volumetric examination of socket welds. Thesample population will be at least 10 percent or based on an NRC approved risk-informed inspection plan. The acceptance criteria stated is that loss of systemfunction will not occur and loss of RCS boundary does not occu r during period of 8Enclosureextended operation. The program will be implemented and inspectionscompleted and evaluated within the last five years of the current licensing period,prior to the period of extended operation. The program was described generallyin Section B.2.21 of the application and specifically in calculation HNP-P/LR-0610. The calculation identified and prioritized the small bore piping in the scopeof this program. The implementation plan was described in AR 188046-09 whichidentified the specific program elements to be included in the fourth interval ISIProgram Plan. The inspectors reviewed the program documentation, discussedthe program with responsible applicant personnel, and verified the existing ISIProgram Manual identified this new program as an augmented ISI program and alicense renewal commitment to be implemented in the fourth ISI interval. The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. When implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.7.Closed-Cycle Cooling Water (CCCW) System Program This existing program manages the aging effects of closed cooling water loopswith controlled chemistry, such as the Component Cooling Water system,Essential Services Chilled Water, and Jacket Water systems for the EDG,security diesel and the diesel driven fire pump. The program relies onmaintenance of corrosion inhibitor concentrations within specified limits. Surveillance testing and inspection in accordance with EPRI report for CCCWsystems is performed to evaluate system and component performance. Theprogram is described in Section B.2.11 of the application and calculation HNP-P/LR-0627, License Renewal Aging Management Program Description of theClosed-Cycle Cooling Water System Program. The implementation plan isdescribed in AR188048-06. There are no enhancements planned for thisprogram. The implementation plan included actions to revise existing programimplementing procedures to identify license renewal credited activities. Theinspectors reviewed the program documentation, discussed the program withresponsible station personnel and reviewed existing procedures whichimplemented the scope and activities of this program. Additionally, theinspectors reviewed trend information from the period of 2000 to 2006 whichdemonstrated that corrosion inhibitor concentrations have been maintained withinthe specified limits for the treated water provided for EDG jacket water, essentialchilled water, DDFP coolant and the reactor building component cooling system.The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed.
9Enclosure As implemented, there is reasonable assurance that the intended function of theSSCs will be maintained through the period of ex tended oper ation.8.Open-Cycle Cooling Water (OCCW) System ProgramThis existing program manages the aging effects caused by biofouling, corrosion,erosion and silting on open cooling water systems which includes the EmergencyService Water system and the safety related portion of the Normal Service Watersystem. The program implements the recommendations of GL 89-13, ServiceWater System Problems Affecting Safety-Related Equipment. The program isdescribed in Section B.2.10 of the application and calculation HNP-P/LR-0602,Open-Cycle Cooling Water System Program. The implementation plan isdescribed in AR 188048-09. There are no enhancements to this program. Theimplementation plan included actions to revise the existing station service waterprogram procedure to identify license renewal credited activities. The inspectorsreviewed the program documentation, discussed the program with responsiblestation personnel and reviewed existing procedures which implemented thescope and activities of this program. The inspectors reviewed NRC inspectionsand applicant self assessments of the existing program implementation duringthe past 10 years. Additionally, the inspectors reviewed the corrective actions foridentified equipment degradation.The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.9.Boraflex Monitoring Program This existing program, with enhancements, monitors the aging effects of theBoraflex neutron absorbing material in the spent fuel pools (SFPs) to assure thatno unexpected degradation would occur that would compromise the criticalityanalysis for the spent fuel storage racks. The program relies on periodic inspection, testing and analysis of test coupons and monitoring of silicon levels toassure the required 5 percent subcriticality is maintained. The program isdescribed in Section B.2.12 of the application and calculation HNP-P/LR-0644,Boraflex Monitoring Program. The implementation plan is described inAR188047-06 and includes actions to incorporate program enhancementsrevising the implementing procedures to provide guidance for performance ofmore direct measurement of actual boron areal density, gap formation in Boraflexpanels and the use of the EPRI RACKLIFE predictive computer code. Currentlythese parameters are monitored via calculation from coupon testing. The duedate for the enhancements was prior to the period of extended operations(10/25/26).
10EnclosureThe inspectors reviewed the program documentation, discussed the programwith responsible station personnel and reviewed existing procedures whichimplemented the scope and activities of this program.
Additionally, theinspectors reviewed a self-assessment of the spent fuel program performed in 2004.The SFPs at this station store both PWR (Harris and Robinson plant fuel) andBWR (Brunswick plant fuel) fuel assemblies. The storage racks installed duringconstruction were made with Boraflex and credited the Boraflex to maintain asubcriticality margin and did not credit the pool borated water. The racks builtduring the later SFP construction used Boral. The racks that use Boral ratherthan Boraflex were not subject to the age related degradation of the Boraflex. The applicant performed a criticality analysis for the PWR storage racks whichcredited fuel pool borated water and not Boraflex to maintain the required sub-criticality margin and submitted the results to the NRC in Technical Specificationamendment request 121 which was approved via a safety evaluation report,dated March 10, 2006. Therefore the PWR spent fuel storage racks are notwithin the scope of the Boraflex aging management program under the currentlicensing basis or the extended period of operation. Currently, the applicant isdeveloping a similar criticality review for BWR storage racks but continuing tomonitor the BWR racks via the Boraflex monitoring program until adequate sub-criticality margin is verified for BWR storage racks without crediting Boraflex. The BWR criticality analysis and subsequent amendment request are scheduledto be completed at the end of 2008. Until the criticality analysis is complete and the amendment request is approved, the BWR racks will be within the scope ofthe Boraflex monitoring program under the current licensing basis and theextended period of operation. The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, with enhancements, there is reas onable assurance that the intended function of the SSCs will bemaintained through the period of extended operation.10.ASME Section XI, Subsection IWB, IWC, and IWD In-Service Inspection (ISI)ProgramThe ISI program is an existing program credited in the LRA for managingcracking, loss of preload, loss of material, and reduction of fracture toughness inseveral systems which require inspections in accordance with ASME Section XI. The program covers selected safety-related systems and components includingReactor Vessel and Internals, Reactor Coolant, Chemical and Volume Control,Safety Injection, Residual Heat Removal and Steam Generators. The ISIprogram detects degradation of components by using specified volumetricexaminations, surface examinations and pressure tests. Because the ASMECode is a consensus document that has been widely used over a long period, it 11Enclosurehas been shown to be generally effective in managing aging effects in Class 1, 2,and 3 components and their integral attachments in light-water cooled powerplants. The extent and schedule of the inspection and test techniques prescribedby the program are designed to maintain structural integrity and ensure thataging effects will be discove red and repaired before the loss of intended functionof the component. Inspection can reveal cracking, loss of material due tocorrosion, leakage of coolant and indications of degradation due to wear orstress relaxation, such as verification of clearances, settings, physicaldisplacements, loose or missing parts, debris, wear, erosion, or loss of integrityat bolted or welded connections.It should be noted that certain inspection requirements have been modified bythe HNP Risk Informed Inservice Inspection Program as an alternative to SectionXI requirements for Class 1, and Class 2, piping welds. The Risk InformedInservice Inspection Program was developed in accordance with themethodology contained in the NRC-approved Electric Power Research Institutetopical report "Revised Risk - Informed Inservice Inspection EvaluationProcedure, Final Report," TR-112657, Progress Energy letter dated April 27,2005, as supplemented by Progress Energy letter dated October 21, 2005, whichrequested from NRC the relief to implement the HNP Risk Informed InserviceInspection Program. The NRC staff's evaluation and conclusions contained inNRC letter dated March 8, 2006, authorize the HNP Risk Informed InserviceInspection Program for the remainder of the second 10-year ISI interval at HNP,on the basis that the alternative provides an acceptable level of quality andsafety.The inspectors reviewed the calculations, reviewed applicable proceduresincluding HNP ISI-100, and HNP-ISI-002, that serve as the governing plantprocedures that assure compliance with ASME code ISI requirements, the ASMEBoiler and Pressure Vessel Code Section XI Repair and Replacement Program,PLP-605, that governsSection XI repair and replacement activities, the ASMEBoiler and Pressure Vessel Code Section XI Pressure Test Program, PLP-652,that implements the Section XI pressure testing requirements, and exceptions tocode requirements, which are granted by approved relief requests andperiodically reviewed in accordance with provisions of 10CFR50.55a. Theseexceptions (Relief Requests) are not considered exceptions to the NUREG-1801LR criteria.The inspectors also reviewed the LR program description calculation, theprogram implementation plans, the ISI plan, SSC inspection results from the lastoutage, and discussed the program with plant personnel. HNP self-assessmentsand audits of the ISI program identified program weaknesses which werecaptured in the applicant corrective action program. These corrective actions willbe monitored during future NRC inspections.
12EnclosureThe inspectors concluded that the ISI Program was in place and includedelements described in the LRA. The applicant had specifically identified ISIprocedures to be credited for LR and for each of the LR required AMPs, theapplicant had established implementation plans under NTM Action Request188048 to ensure that all LR future actions are tracked and completed. Whenimplemented as described, there is reasonable assurance that adequateinspections required by ASME will be performed through the extended period and there is reasonabl e assurance that the intended function of the SSCs will bemaintained through the period of extended operation.11.Reactor Head Closure Studs ProgramThe applicant has maintained an ongoing periodically updated existing programfor inspection of reactor vessel studs as part of the ISI program. The closurehead stud assemblies are inspected under the HNP ISI Program which conformsto ASME Code,Section XI. Table IWB-2500-1 specifies examinationrequirements for the reactor vessel closure stud for bolting each refueling outage. The applicant has previously inspected the studs and has appropriatelyscheduled reinspection. In addition, the applicant has implemented controls toassure use of approved lubricants via maintenance procedures.The inspectors reviewed the LR program description calculation, the programimplementation plan, and site procedures, and discussed the program withapplicant personnel. The inspectors concluded that the Reactor Head ClosureStuds Program was in place, and included elements described in the LRA. Theapplicant had specifically identified procedures to be credited for LR and hadestablished a tracking mechanism under NTM Action Request 188048-05 toensure that all LR future actions are tracked and completed. When implementedas described, there is reasonable assurance that adequate inspections requiredby ASME will be performed through the extended period and t here is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.12.Nickel-Alloy Nozzles and Penetrations ProgramThe Nickel-Alloy Nozzles and Penetrations Program is a new program credited inthe LRA as an aging management program for primary water stress corrosioncracking (PWSCC) in all Nickle-Alloy Reactor coolant System (RCS) componentsincluding the Reactor Vessel Head (RVH) and internals. The applicant plans tomaintain involvement in ongoing industry initiatives and plans to utilize the ASMESection XI program for evaluation and repair/replacement of components. Theapplicant has conducted RVH inspections required by NRC Bulletins andrequired by NRC Order EA-03-009 issued on February 11, 2003. During RFO-11, the RPV head was visually examined to satisfy the requirements of the Orderand to provide a baseline for future inspections.
13EnclosureSubsequently, the NRC issued a Revised Order EA-03-009 which revises certainaspects of the original Order. The applicant has not identified leaks through theRVH to date and these activities are subject to on-going NRC inspections.The Order (as amended) provides criteria for determining a plants susceptibilitycategory ("High", "Moderate", "Low", and "Replaced"). The Harris Plant is in thecategory of plants considered to be of "low" susceptibility to PWSCC. Thesusceptibility category wa s determined in HNP Calc ulation HNP-M/MECH-1091. This calculation is revised periodically to incorporate actual operating experience. The current revision of the calculation projects the category to remain "low"through operating Cycle 34. Beginning with Cycle 35, the calculation projects theranking to be "moderate" through Cycle 40 (60-years of operation).This aging management program directly manages only the aging effect thatproduces cracking. Although the program includes a requirement to inspect forloss of material, these inspections are performed primarily to identify signs ofcracking in the vessel head penetration nozzles. The aging effect of "loss ofmaterial" of the RPV head is managed by the HNP Boric Acid CorrosionProgram. However the Boric Acid Corrosion Program credits the visualinspection of the RPV head required by the NRC Order to manage the "loss ofmaterial" aging effect so that RPV head inspections are not duplicated. In orderto implement the requirements of the NRC Order (as amended), an augmentedprogram was added to HNP-ISI- 002, HNP ISI Program Plan for the 2 nd Interval. The HNP Inservice Inspection Program is administratively controlled by HNPprocedure ISI- 100, Inservice Inspection Program. One of the purposes of ISI-100 is to identify the augmented inspection programs to which HNP is committed. The current revision to ISI-100 does not identify the augmented inspectionprograms required by NRC Order EA-03-009 (as amended) therefore a programenhancement has been identified and is tracked in NTM Action Request 188047.The inspectors reviewed the LR program description calculation, the programimplementation plan, the applicant NRC Bulletin responses and responses toNRC Order EA-03-009 which included inspection results, and held discussionswith applicant personnel responsible for the inspections. The applicant hasidentified that the Nickel-Alloy Nozzles and Penetrations Program will beenhanced to reflect current industry experience and specifically identifiedprocedures to be credited for LR. There is an established tracking mechanismunder NTM Action Request 188047-12 to ensure that all LR future actions aretracked and completed. When implemented as described, there is reasonable assurance that adequate inspections required by NRC Order EA-03-009 will beperformed through the extended period and there is reasonable assurance thatthe intended function of the SSCs will be maintai ned through t he period ofextended operation.
14Enclosure13.Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS) ProgramThe CASS program, as an aging management program, monitors for the effectsof reduction in fracture toughness due to thermal embrittlement of CASScomponents within Class 1 boundaries. Although the synergistic effects fromthermal aging and neutron irradiation embrittlement have not yet been defined byindustry data, these effects will be considered and incorpor ated into the programas data becomes available. The applicant's program involves inspections and/orevaluations and does not provide guidance for mitigation of aging effects. Theprogram will be periodically updated to incorporate new industry knowledge.For the components within the scope of this program, the program consists ofeither supplemental examination of the affected component based on the neutronfluence to which the component has been exposed, or component specificevaluation to deter mine the component's susceptibility to loss of fracturetoughness. The program will implement a supplemental examinati on as part of the ISI Program during the period of ex tended operation. This program will beidentified as an "augmented inspection" in HNP procedure ISI-100, "Control ofthe Inservice Inspection and Testing Activities". This program manages agingeffects for CASS reactor internals components. Specifically, the componentswithin the scope of this program include the bottom mounted instrumentationcolumn cruciforms and the upper support column spiders. The augmentedinspections will be performed along with vi sual inspections of the core supportstructure already required by ASME Code Section XI. The program also allowsfor a component-specific evaluation to determine t he component's susceptibilityto "loss of fracture toughness" using the methodology outline in the NUREG-1801program elements. Using this methodology, if it can be determined that thecomponent is not susceptible to loss of fracture toughness, then thesupplemental examination is not necessary. In order to determi ne susceptibilityto thermal aging, the evaluation must consider the screening criteria described inthe May 19, 2000 NRC letter on the subject of thermal aging embrittlement ofCASS components. The applicant's analyses have shown that no additionalinspections are warranted for piping, fittings, and valves and that the ongoingsurface inspections for reactor coolant pump casings performed under the ISIprogram are sufficient. The inspectors reviewed the LR program description calculation, the programimplementation plan, a vendor analysis of CASS components, and helddiscussions with applicant personnel. The inspectors concluded that the CASScomponents and piping have been appropriately evaluated for adequacy ofongoing inspections which provides reasonable assurance that CASS materialswill be appropriately monitored. Ther e is an established tracking mechanismunder NTM Action Request 188046-11 to ensure that all LR future actions aretracked and completed. When implemented as described, there is reasonable assurance that adequat e inspections and ev aluations required by ASME will beperformed through the extended period and there is reasonable assurance thatthe intended function of the SSCs will be maintai ned through t he period ofextended operation.
15Enclosure14.Reactor Vessel Surveillance ProgramThe Reactor Vessel (RV) Surveillance Program is an existing program credited inthe LRA as an aging management program for managing reactor vesselirradiation embrittlement. The applicant's program consists of periodic testing ofRV surveillance capsules and updating of calculations for irradiationembrittlement. The applicant also imposes temperature/pressure limits on plantoperations. The applicant has recently recalculated the projected degree ofreduction of Upper Shelf Energy and Pressurized Thermal Shock ReferenceTemperature, confir ming that all requirements will continue to be met for the 60year proposed license period.The inspectors reviewed the LR program description calculation, the programimplementation plan, site procedures, and capsule test results. In addition, theinspectors held a discussion of the program with responsible applicantpersonnel. The inspectors concluded that the Reactor Vessel SurveillanceProgram was in place, had been implemented, and was consistent with thedescription presented in the LRA. Historic reviews to determine aging effectshad been conducted, and adequate guidance had been provided to reasonablyensure that aging effects of irradiation embrittlement of the RV will beappropriately managed. There is an established tracking mechanism under NTMAction Request No.188047-08 to ensure that all LR future actions are trackedand completed. When implemented as described, there is reasonable assurance that the requi red testing and evaluations will be performed through the extendedperiod and there is reasonable assurance that the intended function of the RVwill be maintained through the period of ex tended oper ation.15.Flux Thimble Tube Inspection ProgramThis program is an existing program which assures periodic inspections inresponse to NRC Bulletin 88-09, Thimble Tube Thinning in WestinghouseReactors. The program manages loss of material on the bottom mounted fluxthimble tubes due to wear. As required by NRC Bulletin 88-09, the applicant hasestablished and implemented an inspection program to periodically confirmthimble tube integrity and to perform any corrective measures necessary tomaintain thimble tube integrity within the program acceptance criteria. Thisprogram is formally implemented by Engineering Test Procedure EPT-114, EddyCurrent Testing Requirements for the Incore Instrumentation Thimbles. TheHNP program consists of testing and inspection that monitor flux thimble tubewall thickness using eddy current testing to determine actual wall thickness andcalculates the predicted wear of each thimble at the next scheduled inspection. This is an ongoing program which will continue into the period of extendedoperation.The inspectors reviewed the LR program description calculation, the programimplementation plan, reviewed the applicable plant procedures, reviewed thelatest inspection results, and held discussions with responsible applicantpersonnel. The inspectors concluded that the Flux Thimble Tube Inspection 16EnclosureProgram was in place, had been properly implemented, and was consistent withthe description in the LRA. There is an established tracking mechanism underNTM Action Request No. 188047-04 to ensure that all enhancements and LRfuture actions are tracked and completed. When implemented as described, there is reasonabl e assurance that t he required testing and evaluations will beperformed through the extended period and there is reasonable assurance thatthe intended function of the flux thimbles will be maintained thr ough the period ofextended operation.16.ASME Section XI, Subsection IWE ProgramThis is an existing program credited in the LRA for monitoring aging of thereactor containment which includes visual examination of the steel containmentliner and integral attachments, containment hatches and airlocks, seals, gaskets,and moisture barriers, and pressure-retaining bolting in accordance with ASMESection XI. The frequency and scope of examinations specified in 10 CFR50.55a and Subsection IWE ensure that aging effects would be detected beforethey would compromise the design basis requirements.
Progress Energycorporate procedure EGR-NGGC-0015, "Containment Inspection Program," andHNP procedures EST-924, "ASME Section XI Subsection IWE General VisualInspection," and HNP IWE/IWL- 001, "First Containment Inspection IntervalContainment Inspection Program, " serve as the governing plant procedures thatassure compliance with ASME Section XI requirements. As an alternative tocertain Section XI requirements, HNP intends to incorporate the requirementsidentified in ASME Code Case N-604.10CFR50a(b)(2)(ix) specifies additional requirements for inaccessible areas andstates that the licensee is to evaluate the acceptability of inaccessible areaswhen conditions exist in accessible areas that could indicate the presence of, orresult in, degradation to such inaccessible areas. HNP once previously identifiedliner corrosion at the interface between the base slab and the liner and linercorrosion below the base slab. Corrective actions included removal of themoisture barrier, removal of corrosion, UT measurement to ensure designminimum thickness, recoating, and replacement of the moisture barrier. HNPconducted visual and ultrasonic inspections just below the moisture barrier sealfor wear, corrosion, damage, surface cracks, or other defects that may violate theleak-tight integrity and determined the condition of the inaccessible portion of thecontainment liner below the moisture barrier to be acceptable for continuedservice. No corrosion was identified during follow-up inspections in subsequentplant outages. The inspectors reviewed these evaluations and found them to beacceptable.The inspectors reviewed the LR program description calculation, the programimplementation plan, reviewed the applicable plant procedures, reviewed recentinspection results, and held discussions with responsible applicant personnel. The inspectors concluded that the IWE Inspection Program was in place, hadbeen properly implemented, and was consistent with the description in the LRA. There is an established tracking mechanism under NTM Action Request 188047-17Enclosure16 to ensure that all enhancements and LR future actions are tracked andcompleted. When implemented as described, there is reasonable assurance that the required inspections and evaluations will be performed through the extendedperiod and there is reasonable assurance that the intended function of thereactor containment will be maintained through the period of ext ended operation.17.ASME Section XI, Subsection IWL ProgramThis program is an existing program credited in the LRA for aging managementof accessible and inaccessible pressure retaining primary containment concreteby performing inspections required by ASME Section XI. The program is inaccordance with ASME Code,Section XI, Subsection IWL, 1992 Edition, 1992Addenda and consists of periodic visual inspection of the reinforced concretecontainment structure for degradation conditions such as corrosion, cracks,distortion, efflorescence, exposed reinforcing steel, popout, scaling, and spalling. The frequency and scope of examination of accessible areas are sufficient toensure that aging effects are detected before the design basis requirementswould be compromised. The HNP concre te containment does not utilize a post-tensioning system; therefore, the IWL requirements associated with a post-tensioning system are not applicable.The ASME Section XI, Subsection IWL Program is implemented and maintainedin accordance with the general requirements for engineering programs includingHNP IWE/IWL-001. The first concrete examination or baseline was performedduring the first inspection period (09/09/98 to 09/08/01) in the first containmentinspection interval. HNP will perform successive examinations of concretecomponents classified as Class CC at least once every five years based on thedate of the baseline inspection. The implementation schedule for theperformance of examinations has been prepared and is shown in HNP IWE/IWL-001.Plant-specific operating experience (OE) includes assessments, performed onboth a plant specific and corporate basis, dealing with program development,effectiveness, and implementation. The HNP ASME Section XI, Subsection IWLprogram is continually being upgraded based upon industry and plant-specificexperience. Additionally, plant OE is shared between Progress Energy sitesthrough regular peer group meetings, a common corporate sponsor, and outageparticipation of program managers from other Progress Energy sites.The inspectors reviewed the LR program description calculation, the programimplementation plan, reviewed the applicable plant procedures, reviewed recentinspection results, and held discussions with responsible applicant personnel.The inspectors concluded that the IWL Inspection Program was in place, hadbeen properly implemented, and was consistent with the description in the LRA. There is an established tracking mechanism under NTM Action Request 188048-04 to ensure that all enhancements and LR future actions are tracked andcompleted.
18EnclosureWhen implemented as described, there is reasonable assurance that the required inspections and evaluations will be performed and there is reasonable assurance that the intended function of the reactor containment will bemaintained through the period of extended operation.18.ASME Section XI, Subsection IWF ProgramThis program is an existing program credited in the LRA for aging managementof nuclear component hangers, snubbers and supports by conductinginspections required by ASME Section XI and is part of the overall ISI program atHNP described in procedure ISI-002, HNP ISI Program Plan - 2nd Interval. Asan acceptable alternative to parts of article IWF of Section XI, HNP incorporatesCode Case N-491-2. The applicable code for snubber attachments andfasteners is the ASME OM Code, Subsection ISTD, 1995 Edition with 1996Addenda and Code Case OMN-13.The ASME Section XI, Subsection IWF Program is implemented and maintainedin accordance with the general requirements for engineering programs describedin procedure ISI-100, Control of Inservice Inspection and Testing Activities. Component supports, snubber attachments and fasteners are inspected inaccordance with procedure ISI-202, Safety Related Component Support(Hangers and Snubbers) Examination and Testing Program, and hydraulic andmechanical snubber attachments and fasteners are inspected in accordance withprocedure PLP-106, Technical Specification Equipment List Program and CoreOperating Limits Report. The parameters monitored or inspected include: 1.Deformations or structural degradations of fasteners, springs, clamps, or othersupport items; 2. Missing, detached, or loosened support items; 3. Arc strikes,weld splatter, paint scoring, roughness, or general corrosion on close tolerancemachined or sliding surfaces; 4. Improper hot or cold settings of spring supportsand constant load supports; 5. Misalignment of supports; 6. Improper clearancesof guides and stops. The visual inspection would be expected to identifyrelatively large cracks.Plant-specific OE includes assessments, performed on both a plant specific andcorporate basis, dealing with program development, effectiveness, andimplementation. Additionally, plant OE is shared between Progress Energy sites.The inspectors reviewed the LR program description calculation, the programimplementation plan, reviewed the applicable plant procedures, reviewed recentinspection results, and held discussions with responsible applicant personnel. The inspectors concluded that the IWF Inspection Program was in place, hadbeen properly implemented, and was consistent with the description in the LRA. There is an established tracking mechanism under NTM Action RequestNo.188048-07 to ensure that all enhancements and LR future actions are trackedand completed. When implemented as described, there is reasonable assurance that the requi red inspections and evaluations will be performed and there is reasonable assurance that the intended function of the SSCs will be maintainedthrough the period of extended operation.
19Enclosure19.Flow Accelerated Corrosion (FAC) ProgramThe FAC program, as described in Section B.2.7 of the LRA, is an existingprogram that provides for the prediction, detection, and monitoring of FAC in plant piping so that the probability of a leak or rupture is minimized. Thisprogram contains one enhancement to provide a consolidated exclusion bases document (a FAC susceptibility analysis). The inspectors found that thisenhancement has already been completed. The FAC program is based on theEPRI guideline NSAC-202L-R2, which includes requirements for the identificationof locations susceptible to FAC, baseline inspections to determine the extent ofthinning, and performing follow-up inspections for trending wall loss andcorrosion rates. This empirical data, along with plant and industry operatingexperience, is used to predict when the minimum wall thickness will be reachedso that proper repair or replacement activities can be performed prior to leak orrupture. Additionally, the Secondary Chemistry Strategic Plan is credited towardthis program for limiting the effects of aging due to FAC.The inspectors reviewed the implementation plan, program description, a recentself-assessment, and held discussions with licensee personnel. The programcoordinator tracks equipment and piping projected to need replacement up to 15-20 years into the future to ensure proper planning activities can be performed. Additionally, industry operating experience is continuously evaluated andappropriately incorporated into the program. The inspectors concluded that there is reasonable assurance this program will effectively manage the aging effectsdue to FAC during the period of extended operation.20.Bolting Integrity ProgramThe Bolting Integrity Program, as described in Section B.2.8 of the LRA, is anexisting program that has one enhancement and one exception with respect tothe Generic Aging Lessons Learned (GALL) report (NUREG-1801). Theexception involves the licensee's use of their site-specific ASME Section XI CodeEdition rather than the Edition specified in NUREG-1801. This appropriatelyensures the licensee maintains compliance with 10 CFR 50.55a. Theenhancement includes a change to procedure MMM-010, "Threaded FastenerTightening Procedure," to prohibit the use of molybdenum disulfide lubricantssince NUREG-1339 identifies it as a potential contributor to stress corrosioncracking.The inspectors reviewed the program description, implementation plan, and helddiscussions with licensee personnel. This program includes bolting within thescope of license renewal and relies on recommendations delineated in NUREG-1339, "Resolution of Generic Safety Issue 29: Bolting Degradation or Failure inNuclear Power Plants." This program consists of essentially two components:bolting inspection and bolting maintenance. The former component takes creditfor the inspections performed under ASME Section XI Subsections IWB, IWC,and IWD as part of the Inservice Inspection Program, and also for inspectionsperformed under the External Surfaces Monitoring Program. ASME Section XI, 20EnclosureSubsection IWF does not apply to this program since no high strength structuralbolting was identified during the licensee's Aging Management Review process. The latter component (bolting maintenance) utilizes standard industry guidancedocuments from EPRI to manage maintenance and installation activities. Thisguidance has been incorporated into site procedures. The inspectors concludedthat the Bolting Integrity Program is a functioning program, includes elements described in the LRA, and there is reasonabl e assurance that it will effectivelymanage the effects of aging during the period of extended operation. 21.Steam Generator Tube Integrity ProgramThe Steam Generator Tube Integrity Program, as described in Section B.2.9 ofthe LRA, is an existing program that is credited for the aging management oftubes, tube plugs, tube supports, and secondary-side components whose failurecould prevent the steam generator from fulfilling its intended safety function. Theinspectors reviewed HNP-P/LR-0604, the license renewal program descriptionfor ensuring steam generator tube integrity. One enhancement was made to theprogram in order to be consistent with the GALL (NUREG-1801). This changewas to enhance the wording in the program document to specifically state thatdegraded tube plugs and secondary side components are evaluated forcorrective actions. The inspectors verified that this change was made inprocedure EGR-NGGC-0208, Steam Generator Integrity Program.The licensee had submitted a request which was approved by the NRC for achange to the Technical Specifications in accordance with TSTF-449, Revision 4. The NRC approval letter was reviewed by the inspectors. These new TechnicalSpecifications require implementation of a steam generator program inaccordance with the intent of NEI 97-06, Revision 2. The licensee's currentprogram has already been implementing the guidance of NEI 97-06. Thisprogram includes requirements for inspection, assessment, monitoring,maintenance and repair activities performed in accordance with appropriateindustry standards (i.e., EPRI guidance documents). The inspectors helddiscussions with the steam generator program coordinator and reviewed programactivities and found that the program was being implemented in accordance withits description. Additionally, the NRC concluded by letter dated May 19, 2005(regarding Generic Letter 2004-01), that the licensee's SG tube inspectionpractices were in compliance with existing tube inspection requirements. Theinspectors concluded that the existing Steam Generator Tube Integrity Programis being effectively implemented, includes the elements described in the LRA, and there is reas onable assurance that this program will effectively manage theeffects of aging during the period of extended operation.22.Inspection of Internal Surfaces in Miscellaneous Piping and Ducting ComponentsProgramThis program, as described in Section B.2.24 of the LRA, is a new programconsistent with the GALL (NUREG-1801). This program involves the visualinspection for evidence of degradation on internal surfaces of piping, piping 21Enclosureelements, ducting, and components not within the scope of other agingmanagement programs. Such degradation may include a change in materialproperties, cracking, flow blockage, loss of material, or reduction of heat transfer. This inspection program will be accomp lished, in large part, using existingpredictive maintenance, preventive maintenance, surveill ance testing, andperiodic testing activities that provide an opportunity to perform an internalsurface visual inspection. The licensee has begun development of this new program by identifying thepiping and components within the scope of this program and has categorizedthese items into different Component Groups based on the item's material,environment, and aging mechanism. Within each Component Group, thelicensee will select a sample for inspection that will be representative of the mostsusceptible location(s) and therefore bound the entire Group. For inspectionsrequired by this program that can not be accomplished in accordance withexisting work order tasks (e.g. preventive maintenance or surveillance testingactivities), the first such inspection will be conducted before the period ofextended operation. The results of these inspections will be evaluated todetermine future inspection intervals. If evidence of degradation is found, thecondition will be address ed through the corrective action process.Since this is a new program, it has not yet been fully developed. Specifically, thesample size and specific methodology for sample selection within eachComponent Group has not been fully determined. However, when this programis implemented as conceptually developed and intended, there is reasonableassurance that it will effectively manage the effects of aging within the scope ofthe program.23.Lubricating Oil Analysis ProgramThe Lubricating Oil Analysis Program, described in Section B.2.25 of the LRA, isan existing program that will be enhanced to formalize additional r equirements inprogram documents/procedures. These requirements include oil analysis forparticle count and moisture, and additional analyses for viscosity, neutralizationnumber, and flash point if oil is not changed in accordance with the componentmanufacturer's recommendations. Additionally, when particle counts are high,procedures will require ferrography or elemental analysis to identify wear orcorrosion products. These requirements are currently performed in the existingprogram, however, they have not been formally included in program documents.The Lubricating Oil Analysis Program does not have specific particle countthresholds for acceptance criteria of oil analysis results. The program relies onthe Lubricating Oil Program Engineer and the oil sample technologists to reviewall analysis parameters to identify trends or signs of equipment problems. Theinspectors reviewed the database maintained for tracking and trending oil sampleresults. The program engineer is required to complete specific lube oil trainingrequirements to ensure he/she possesses the technical knowledge to identifyadverse trends or equipment problems based on these oil analyses. The 22Enclosureinspectors verified the training record for the current program engineer. Additionally, the inspectors reviewed the most recent calibration certification forthe oil particulate counter instrument. A sample of corrective action documentswere also reviewed to ensure that appropriate actions were taken in response toadverse trends in oil sample results. A review of plant operating experience didnot identify any equipment failures due to lube oil contamination.Based upon review of this aging management program, supporting documents,and discussions with licensee personnel, there is reasonable assurance that theLubricating Oil Analysis Program will effectively manage plant aging issues withinthe scope of this program during the period of extended operation.24.Fire Protection ProgramThe HNP Fire Protection Program is an existing program that provides agingmanagement of the diesel-driven fire pump fuel oil supply line and credited firebarrier assemblies including fire doors, penetration seals, fire wrap, barrier walls,barrier ceilings and floors, and seismic joint filler. The program is implementedthrough various plant procedures. The inspectors reviewed Calculation HNP-P/LR-0612, Rev. 1 License Renewal Aging Management Program Description ofthe Fire Protection Program. The document states that the HNP Fire ProtectionProgram with certain enhancements will be consistent with NUREG-1801,Section XI.M26. The procedure for periodic inspections of penetration seals willbe enhanced to include inspections for signs of degradation. The program will include a periodic test procedure for inspections of barrier walls, ceilings, andfloors on at least an 18-month interval. The enhanced procedure will specify thatif any fire barrier wall, ceiling or floor fails to meet the acceptance criteria, theUnit Senior Control Operator shall be immediately notified and if the fire barriercannot be returned to an operable status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, mitigating actions shall be implemented. Also the monthly operability test procedure for the diesel-drivenfire pump will be enhanced to include a visual inspection of the insulated fuel oilsupply piping for signs of leakage. Additionally the enhanced procedures willinclude minimum qualification requirements for inspectors. The inspectorsreviewed Action Request (AR) 1888047-20, Action Plan - Fire ProtectionProgram Implementation Plan, which tracks the commitments to perform thesefuture procedure enhancements.As operating experience history, the inspectors reviewed numerous applicantNuclear Assurance Section (NAS) assessments dating back to 1999. Thesewere critical assessments and records show that corrective actions were takenwhere appropriate. The inspectors reviewed a sample of the quarterly systemhealth reports. The inspectors reviewed the open AR that documents the failureof HEMYC fire wrap to fully meet performance criteria during NRC sponsoredtesting and the future action plan to perform further testing to demonstrateadequate HEMYC performance. The NRC has previously been presented theapplicants action plan for resolving these issues and found them satisfactory.
23EnclosureThe inspectors examined the records of a sample of various fire protection equipment periodic surveillance tests. The records were retrievable and reflectthat equipment passed the tests or corrective actions were taken and asuccessful retest performed. The inspectors concluded that the fire protectionprogram is functioning as intended.The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation. 25.Fire Water System ProgramThe Fire Water System Program includes system pressure monitoring, fireprotection piping wall thickness evaluations, periodic flow and pressure testing inaccordance with applicable National Fire Protection Association commitmentsand periodic visual inspection of overall system condition. The inspectorsreviewed Calculation HNP-P/LR-0611, Rev 1, License Renewal AgingManagement Program Description of the Fire Water System Program. Thedocument states that this is an existing program that, following enhancement, willbe consistent with NUREG-1801,Section XI.M27. Enhancements includerevising the program to incorporate a requirement to perform non-intrusivebaseline pipe thickness measurements at various locations, prior to theexpiration of current license and trending periodic measurements through theperiod of extended operation. The inspection intervals will be determined byengineering evaluations performed after each inspection of the fire protection piping, to detect degradation prior to the loss of the system capability. Also theapplicant will either replace the sprinkle r heads prior to reaching their 50 yearservice life, or revise site procedures to perform field service testing by arecognized testing laboratory of representative samples from one or moresample areas. The inspectors reviewed AR NTM - 1888047-17, Fire WaterSystem Program Implementation Plan, which tracks the commitments to performthese future procedure enhancements.The inspectors reviewed a sample of the system health reports for the Fire Watersystem. The reports reflected adequate system performance with no pipingleaks indicating degradation.The inspectors examined the trending data records of the fire water systemperiodic surveillance flow tests since 1999. The records reflect that equipmentpassed the tests and shows no signs of degrading. The inspectors concludedthat the fire water system program is functioning as intended.The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will be 24Enclosureappropriately assessed and managed. As implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.26.Boric Acid Corrosion Program This is an existing program to ensure that leaking borated coolant does not leadto the degradation of the leakage source or adjacent mechanical, electrical andstructural components susceptible to boric acid corrosion. This includes visualinspection of external surfaces and implementing appropriate corrective actions. The program is described in Section B.2.4 of the LRA and calculation HNP-P/LR-0601. The implementation plan is described in AR 188048-01. The inspectorsreviewed the program documentation, discussed the program with responsiblestation staff, reviewed self-assessments, and reviewed existing procedures whichimplemented the scope and actions of this program.
Additionally, the inspectorsreviewed several samples of evaluation reports and action report documents. The inspectors also reviewed NRC inspection report 05000400/2006003 whichdocuments the most recent boric acid corrosion program inspection conducted atthe site. This report documented samples of engineering evaluations completedfor evidence of boric acid found on systems containing borated water to verifythat the minimum design code required section thickness had been maintainedfor the affected components. The inspectors concluded that the applicant hadconducted adequate historic reviews of plant specific and industry experience todetermine aging effects. The applicant had provided adequate guidance toensure aging effects will be appropriately assessed and managed. Asimplemented, there is reasonable assurance that the intended function of theSSCs will be maintained through the period of ex tended oper ation.27.External Surfaces Monitoring ProgramThis existing program with enhancements is a condition monitoring program forpiping, piping components, ducting, and other equipment. The program isdescribed in Section B.2.22 of the application and calculation HNP-P/LR-0614. The implementation plan is described in AR 188047-11. The inspectorsreviewed the program documentation, discussed the program with responsibleapplicant personnel, and reviewed existing procedures which implemented thescope and actions of this program. The program will be enhanced to include aspecific list of systems to be managed by the program which will be added to the program document. Other enhancements will include t he incorporation of achecklist for evaluating inspection findings and the commitment to performinspections of inaccessi ble components during intervals that will provide reasonable assurance that the effects of aging will be managed. During theinspection, the inspectors noted that the proposed changes to this program didnot clearly specify the periodicity at which the inaccessible components would beinspected or the method by which they would be inspected. As a result, thelicensee proposed to revise procedure TMM-117, System Walkdowns andObservations to clearly define inaccessible components and specify periodicity ofwalkdowns.
25EnclosureThe inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.28.Inspection of Overhead Heavy Load and Light Load Handling Systems ProgramThe HNP Inspection of Overhead Heavy Load and Light Load Handling SystemsProgram is described in LRA section B.2.13 and calculation HNP-P/LR-0628. The program is an existing program that will be enhanced. The implementationplan is described in AR 188047-09. The inspectors reviewed crane inspectionrecords, procedures and work orders. The inspectors also verified that issuespertaining to aging management were appropriately addressed such as thoseidentified during inspections of the cranes. For license renewal, the followingcranes were identified as being within the scope of license renewal: polar crane,reactor cavity manipulator crane, jib cranes, and the fuel handling buildingcranes. The applicant plans to include requirements to inspect for bent ordamaged members, loose bolts/components, broken welds, abnormal wear ofrails, and corrosion of steel members and connections to ensure that agingeffects are monitored and managed.The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.29.Structures Monitoring ProgramThe Structures Monitoring Program (SMP) is an existing program which theapplicant plans to enhance for LR. The program is described in Section B.2.31of the LRA and calculation HNP-P/LR-0608. The implementation plan isdescribed in AR 188047-07. Some of the enhancements include identifying thecomplete list of systems and structures that credit the SMP for agingmanagement, requiring notification of the responsible engineer when below-grade concrete is exposed, requiring periodic ground water monitoring, andrequiring periodic inspection of inaccessible surfaces of concrete pipe. Theapplicant's existing program consists of periodic inspections and monitoring ofaccessible areas of structures. The SMP, specifically procedure CMP-012, PlantArea Excavation and Backfill, will be enhanced to notify the responsible engineerwhen below grade concrete is exposed, so an inspection can be performed priorto backfill.
26EnclosureThe inspectors reviewed AMP description documents for the SMP, selected plantinspection data, engineering documents, site procedures, drawings, correctiveaction documents, inspection reports and procedure EGR-NGGC-0351,"Condition Monitoring of Structures," which provides the guidance and periodicityrequired to manage the effects of aging. The inspectors also discussed theapplicable programs with responsible personnel and reviewed personnelqualifications.The inspectors conducted general walkdowns of the site, including the reactorbuilding, auxiliary building, service water intake st ructure, di esel generatorbuilding, and other applicable structures, systems or components related to theSMP. The inspectors verified that areas where signs of degradation such asspalling, cracking, leakage through concrete walls, corrosion of steel members,deterioration of structural materials and other aging effects had been previouslyidentified were addressed adequately by the SMP and/or the corrective actionprogram. The applicant maintains comprehensive inspection reports containingphotographic and wri tten documentation of areas inspected, thus facilitatingadequate monitoring of structural commodities and components.During a review of inspection records, the inspectors noted a minor issue thatduring a past performance of procedure EPT-168, Emergency Service WaterIntake and Screening Structures Inspection for the emergency service waterscreening structure bay 8, an area of spalled concrete was not appropriatelydispositioned. The size of the spalled concrete area met the criteria to requireadditional engineering review. In accordance with EGR-NGGC-0351, aresponsible engineer should have reviewed the dimensions of the spalled areaidentified by the diver during inspection. The applicant initiated AR 0024040 toaddress this issue. The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is a reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation. 30.RG 1.127- Inspection of Water-Control Structures Associated with Nuclear PowerPlants ProgramThe Water-Control Structur es Program includes inspection and surveillanceactivities for dams, slopes, canals, and other water-control structures. Thisprogram is described in Section B.2.32 of the LRA and calculation HNP-P/LR-0638. The implementation plan is described in AR 188047-10. The program willbe enhanced to include administrative controls to document visual inspections of the miscellaneous steel at the main dam and spill way, and revised to require anevaluation of concrete deficiencies. In addition, the applicant plans to require theinitiation of a nuclear condition report for degraded plant conditions. Theinspectors conducted walkdowns of the Emergency Service Water Intake 27EnclosureStructure, Emergency Service Water Screening Structure, Emergency ServiceWater Discharge Structure, the Main and Auxiliary Dams, and Spillways. Therewere no signs of abnormal seepage, erosion, unusual settlement or displacementof the areas inspected. The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is a reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation. 31.Masonry Wall ProgramThe Masonry Wall Program is an existing program implemented through theMaintenance Rule structures monitoring procedure EGR-NGGC-0351, "ConditionMonitoring of Structures." This program is described in Section B.2.30 of theLRA and calculation HNP-P/LR-0645. The implementation plan is described inAR 188047-05. The inspectors reviewed masonry wall inspection proceduresand inspection reports and discussed these with responsible personnel. Theapplicant will continue to address masonry wall considerations consistent withNRC IE Bulletin (IEB) 80-11, "Masonry Wall Design" and NRC Information Notice(IN) 87-67, "Lessons Learned from Regional Inspections of Licensee Actions inResponse to IE Bulletin 80-11." The applicant inspects, documents andphotographs masonry walls that appear to show signs of degradation on aperiodic basis. The inspectors noted some areas where minor cracking wasvisible on some masonry walls, all of which had been previously identified by theapplicant. Overall, the inspectors concluded that the applicant had conducted adequatehistoric reviews of plant specific and industry experience to determine agingeffects. The applicant had provided adequate guidance to ensure aging effectswill be appropriately assessed and m anaged. As implem ented, there isreasonable assurance that through the use of the existing programs (i.e. SMP,RG 1.127 and the Masonry Wall Programs) the intended function of the SSCswill be maintained through the period of ex tended oper ation.32.10 CFR Part 50, Appendix J ProgramThis program is described in LRA Section B.2.29 and calculation HNP-P/LR-0615. The program is an existing program requiring an enhancement to describethe evaluation and corrective actions to be taken when leakage rates do not meettheir specified acceptance criteria. The implementation plan is described in AR188047-15. This existing program monitors leakage rates through thecontainment liner/welds, penetrations, fittings, and access openings to detectdegradation of the pressure boundary. Acceptance criteria for leakage rates aredefined in plant technical specifications.
28EnclosureThe inspectors also reviewed and discussed with plant personnel the previousoutage reports, leak rate test results, and applicable procedures. This programfollows guidance established in Regulatory Guide 1.163, "Performance-BasedContainment Leak-Test Program," September 1995 and Nuclear Energy Institute(NEI) Guidelines 94-01, "Industry Guideline for Implementing PerformanceBased Option of 10 CFR Part 50, Appendix J." In addition, the applicant'sperformance based integrated leak rate testing (ILRT) monitors and trends itstest results to provide predictability of the extent of degradation and ensuretimely corrective action. ASME Section XI IWE and IWL programs addressSSCs where aging degradation is detected as a result of leak rate testing. During a review of the May 1997 ILRT records, the inspectors noted that theapplicant had identified that there was a potential for having a valve lineup thatwas not in accordance with Table 6.2.4.1 of the FSAR. This error was realizedprior to the performance of the ILRT in 1997, however, operating experience andlessons learned were not considered nor documented to preclude future valvelineup errors during ILRTs. As a result, the applicant issued AR 00240847 toaddress this issue through the corrective action program.Implementation of the Appendix J Program provides reasonable assurance thatthe aging effects will be managed such that co mponents and commoditiesassociated with the containment pressure boundary will continue to perform theirintended functions during the period of extended operation.C.Review of Electrical Aging Management ProgramsThe HNP LRA concluded that the only electrical components that require an agingmanagement program are electrical cables and connectors, metal enclosed electricalbusses, and a group of HNP site specific oil filled cables. Electrical equipment, includingcables, that are already subject to the 10 CFR 50.49 environmental qualification (EQ)program are age managed by that program. The applicant considers the EQ program subject to a Time Limited Aging Analysis (TLAA) to demonstrate that EQ components'qualified life can be extended an additional 20 years or to ensure that they will bereplaced at the appropriate time. The AMPs proposed by the applicant are as follows:
1. Electrical Cables and Connections Not Subject to 10 CFR 50.49 EnvironmentalQualification Requirements ProgramThe inspectors reviewed document HNP-P/LR-0664 which provides a descriptionof the Electrical Cables and Connections Not Subject to 10 CFR 50.49Environmental Qualification Requirements Program. This program is credited foraging management of cables and connections not included in the HNP EQProgram. Accessible electrical cables and connections installed in adverselocalized environments will be visually inspected at least once every 10 years forcable and connection jacket surface anomalies, such as embrittlement,discoloration, cracking, swelling, or surface contamination, which are precursorindications of conductor insulation aging degradation from heat, radiation, or
29Enclosuremoisture. An adverse localized environment is defined as a condition in a limitedplant area that is significantly more severe than the specified service conditionfor the electrical cable or connections. The aging effects of concern are reduced insulation resistance l eading to electrical failure. The sampling will consider thelocation of cables and connections inside and outside primary containment aswell as any other known adverse localized environments. The applicant intendsto identify hot spots and adverse localized environments through operatingexperience review, conversations with maintenance personnel and the use ofenvironmental surveys. The inspectors reviewed AR 188046-1 Non-EQ CableAging Management Program Implementation Plan which tracks the commitmentsto develop and implement this new program prior to the period of extendedoperation.This is a new program yet to be developed and thus there is no performancehistory. However, the commitments are identical to ones described in NUREG-1801 which the NRC has found acceptable.The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.2.Electrical Cables Not Subject to 10 CFR 50.49 Environmental QualificationRequirements Used in Instrumentation Circuits ProgramThe inspectors reviewed document HNP-P/LR-0665, Rev. 2, which provides adescription of the Electrical Cables Not Subject to 10 CFR 50.49 EnvironmentalQualification Requirements Used in Instrumentation Circuits Program. Thisprogram is credited for the aging management of radiation monitoring andneutron flux monitoring instrumentation cables not included in the EQ Program. Exposure of electrical cables to adverse localized environments caused by heator radiation can result in reduced insulation resistance (IR). A reduction in IR is aconcern for circuits with sensitive, low-level signals such as radiation monitoringand nuclear instrumentation circuits since it may contribute to signalinaccuracies. For radiation monitoring instrumentation circuits, the results of routine calibration tests will be used to identify the potential existence of cable aging degradation. This review will be perform ed at least once every 10 years,with the first review to be completed prior to the period of extended operation.For the Excore nuclear instrumentation system, field cables will be tested at leastonce every 10 years with the first testing to be completed prior to the period ofextended operation. Testing may include IR tests, time domain reflectometrytests, current versus voltage testing, or other testing judged to be effective indetermining cable insulation condition. The inspectors also reviewed AR188046-2 Non-EQ Instrument Cable Aging Management ProgramImplementation Plan which tracks the commitments to develop and implement 30Enclosurethis new program prior to the period of extended operation.This is a new program yet to be developed but the description is consistent withNUREG-1801,Section XI.E2, with excepti on that direct cable testing will beperformed as an alternative to instrument loop calibrations for neutron fluxmonitoring instrumentation circuits. The acceptance criteria will be determinedbased on the type of test selected for these cables.The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.3.Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49Environmental Qualification Requirements ProgramThe inspectors reviewed document HNP-P/LR-0666 which provides a descriptionof the Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49Environmental Qualification Requirements Program. This program is credited foraging management of cables not included in the EQ Program. In-scope,medium-voltage cables exposed to significant moisture and significant voltagewill be tested at least once every 10 years to provide an indication of thecondition of the conductor insulation. The specific type of test performed will bedetermined prior to the initial test, and is to be a proven test for detectingdeterioration of the insulation system due to wetting, such as power factor, partialdischarge, polarization index, or other testing that is state-of-the-art at the timethe test is performed. Significant moisture is defined as periodic exposures thatlast more than a few days (e.g., cable in standing water). Significant voltageexposure is defined as being subjected to system voltage for more than 25% ofthe time. This is a new program yet to be developed and its description isconsistent with NUREG-1801,Section XI.E3.The inspectors asked if periodic actions are being taken such as inspection forand removal of water collected in cable vaults and manholes containing normallyenergized safety related cables. The inspectors were told that a preventivemaintenance task is in place to quarterly measure the as found water level andpump out the water from both safety related cable vaults and non-safety relatedmanholes on a rotating basis. The inspectors were also told that safety relatedcable vaults are opened and visually inspected every ten years as part of thestructures monitoring program.The inspectors observed the water removal PM being performed for two safetyrelated cable vaults M523 and M72. The inspectors noted the workers weremeasuring and recording the as-found water level on the PM data sheet but therewas no trending of that information. The applicant promptly changed the PMinstructions to specify that the completed work order will be sent to the cable 31Enclosuresystem engineer for his trending use. The inspectors later participated with theapplicant in opening and examining the same two safety related cable vaults. The vaults contained a very small amount of water after the previous dayspumping. The cables and supports were in satisfactory condition. The inspectorexamined plant drawings which showed the number and location of all cablevaults and manholes on the site.The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.4.Metal Enclosed Bus Aging Management ProgramThe inspectors reviewed document HNP-P/LR-0667 which provides a descriptionof the Metal Enclosed Bus (MEB) Aging Management Program. This program iscredited for aging management of the isophase bus as well as all non-segregated 6.9 kV and 480 V MEB within the scope of License Renewal. Theprogram involves various activities conducted at least once every 10 years toidentify the potential existence of aging degradation. In this aging managementprogram, a sample of a ccessible bolted connections will be checked for looseconnection by using thermography or by measuring connection resistance usinga low range ohmmeter. In addition, the internal portions of the bus enclosure willbe visually inspected for cracks, corrosion, foreign debris, excessive dustbuildup, and evidence of moisture intrusion. The bus insulation will be visuallyinspected for signs of embrittlement, cracking, melting, swelling, or discoloration,which may indicate overheating or aging degradation. The internal bus supportswill be visually inspected fo r structural integrity and signs of cracks. Industryoperating experience has shown that a phase bus exposed to appreciable ohmicor ambient heating during operation may experience loosening of boltedconnections related to the repeated cycling of connected loads or of the ambienttemperature environment. This is a new program yet to be developed and itsdescription is consistent with NUREG-1801,Section XI.E4. The inspectors alsoreviewed AR 188046-4 Metal Enclosed Bus Aging Management ProgramImplementation Plan which tracks the commitments to develop and implementthis new program prior to the period of extended operation.
32EnclosureThe inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.5.Electrical Cable Connections Not Subject to 10 CFR 50.49 EnvironmentalQualification Requirements ProgramThe inspectors reviewed document HNP-P/LR-0668 which provides a descriptionof the program. This program is credited for aging management of cable connections not included in the HNP EQ Program. The program will beimplemented as a one-time inspection on a representative sample of non-EQcable connections within the scope of License Renewal prior to the period ofextended operation to provide an indication of the integrity of the cableconnections. The specific type of test performed will be determined prior to theinitial test, and is to be a proven test for detecting loose connections, such asthermography, contact resistance testing, bridge balance testing, or otherappropriate testing judged to be effective in determining cable connectionintegrity. The aging effect/mechanism of concern is loosening of bolted cableconnections. The factors considered for sample selection are application (high,medium and low voltage), circuit loading (high loading), and location (hightemperature, high humidity, vibration, etc.) in both indoor and outdoorenvironments. The technical basis for the sample selections of cableconnections to be tested will be provided. In addition, the program will includethe bolted connections on the overhead transmission conductors from the highvoltage bushings on the main power transformers to the switchyard bus. Thisprogram is to be implemented by the existing HNP preventive maintenance workrequest program.The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.6.Oil-Filled Cable Testing Program The inspectors reviewed document HNP-P/LR-0669 which provides a descriptionof the program. This program is credited for aging management of the high-voltage, oil-filled cables wh ich connect the HNP 230 kV Switchyard to the StartupTransformers. These cables are in scope for license renewal because theywould be the path used to recover off site power following a station blackoutevent. Periodic cable testing will be performed at least once every four years toprovide an indication of the condition of the cables insulation properties. Thespecific type of test performed will be deter mined prior to the in itial test, and is tobe a proven test for detecting deterioration of the insulation system, such as 33Enclosurepower factor (Doble), partial discharge, or other testing that is state-of-the-art atthe time the test is performed. The program will verify that the effects of agingfrom a loss of dielectric strength caused by thermal/ thermoxidative degradationof organics, voltage (partial discharge), moisture, or the presence of otherimpurities will be managed dur ing the period of extended operation. Theinspectors also reviewed AR 188046-16 Oil-Filled Cable Testi ng ProgramImplementation Plan which tracks the commitments to develop and implementthis new program prior to the period of extended operation.The inspectors concluded that the applicant had conducted adequate historicreviews of plant specific and industry experience to determine aging effects. Theapplicant had provided adequat e guidance to ensure aging effects will beappropriately assessed and managed. As implemented, there is reasonable assurance that the intended function of the SSCs will be maintained through theperiod of extended operation.4OA6Meetings, Including ExitOn July 27, 2007, the inspectors presented the inspection results to Mr. C. L. Burton andother members of the applicant staff in an exit meeting open for public observation at theNew Horizons Fellowship facility, 820 East Williams St., Apex NC. The inspectorsconfirmed that proprietary information was not provided or examined during theinspection.ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Applicant Personnel
- C. Burton, Director of Site Operations
- R. Duncan, Site Vice President
- R. Kitchen, Manager of Licensing
- C. Mallner, License Renewal, Mechanical Lead
- E. McCartney, Plant General Manager
- A. Ploplis, License Renewal, Electrical Lead
- R. Reynolds, License Renewal, Civil Lead
- B. Schneidman, License Renewal, Mechanical
- K. Stacy, Licensing Engineer
- R. Stewart, Supervisor, License Renewal
NRC personnel
- R. Hannah, Public Affairs Officer
- M. Heath, NRR Project Manager, License Renewal
- M. King, Resident Inspector
- P. O'Bryan, Senior Resident Inspector
- J. Shea, Director Division of Reactor Safety
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
None
2Attachment 1
LIST OF DOCUMENTS REVIEWED
Program Descriptions