IR 05000528/2025012

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NRC Inspection Report 05000528/2025012 and 05000529/2025012 and 05000530/2025012
ML25118A219
Person / Time
Site: Palo Verde  Arizona Public Service icon.png
Issue date: 05/01/2025
From: Greg Warnick
NRC/RGN-IV/DORS/EB2
To: Heflin A
Arizona Public Service Co
Drake J
References
IR 2025012
Download: ML25118A219 (1)
v • d • e


Text

May 01, 2025

SUBJECT:

PALO VERDE NUCLEAR GENERATING STATION - LICENSE RENEWAL PHASE 2 INSPECTION REPORT 05000528/2025012 AND 05000529/2025012 AND 05000530/2025012

Dear Adam Heflin:

On March 21, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Palo Verde Nuclear Generating Station and discussed the results of this inspection with R.

Meeden, Vice President, Nuclear Engineering and other members of your staff. The results of this inspection are documented in the enclosed report.

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

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

Sincerely, Gregory G. Warnick, Chief Engineering Branch 2 Division of Operating Reactor Safety Docket Nos. 05000528; 05000529; 05000530 License Nos. NPF-41; NPF-51; NPF-74

Enclosure:

As stated

Inspection Report

Docket Numbers:

05000528, 05000529 and 05000530

License Numbers:

NPF-41, NPF-51 and NPF-74

Report Numbers:

05000528/2025012, 05000529/2025012 and 05000530/2025012

Enterprise Identifier:

I-2025-012-0002

Licensee:

Arizona Public Service

Facility:

Palo Verde Nuclear Generating Station

Location:

Tonopah, AZ

Inspection Dates:

March 03, 2025 to March 21, 2025

Inspectors:

S. Campbell, Senior Reactor Systems Engineer

M. Davis, Trans And Storage Safety Inspector

J. Drake, Senior Reactor Inspector

N. Okonkwo, Reactor Inspector

A. Saunders, Reactor Inspector

Approved By:

Gregory G. Warnick, Chief

Engineering Branch 2

Division of Operating Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a License Renewal Phase 2 inspection at Palo Verde Nuclear Generating Station, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

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

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2516, Policy and Guidance for The License Renewal Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL

===71003 - Post-Approval Site Inspection for License Renewal The team conducted a Phase 2 license renewal inspection. The following aging management programs (AMPs) were evaluated by the team:

  • 13-LS-A102, Water Chemistry, XI.M1
  • 13-LS-A103, Reactor Head Closure Stud Bolting, XI.M2
  • 13-LS-A105, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components (PWRs only), XI.M11A
  • 13-LS-A106, Flow-Accelerated Corrosion, XI.M17
  • 13-LS-A107, Bolting Integrity, XI.M18
  • 13-LS-A109, Open-Cycle Cooling Water System, XI.M20
  • 13-LS-A110, Closed-Cycle Cooling Water System, XI.M21
  • 13-LS-A111, Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems, XI.M23

  • 13-LS-A112, Fire Protection, XI.M26
  • 13-LS-A113, Fire Water System, XI.M27
  • 13-LS-A114, Fuel Oil Chemistry, XI.M30
  • 13-LS-A115, Reactor Vessel Surveillance, XI.M31
  • 13-LS-A116, One-Time Inspection, XI.M32
  • 13-LS-A117, Selective Leaching, XI.M33
  • 13-LS-A118, Buried Piping and Tanks Inspection Program, XI.M34
  • 13-LS-A119, One-Time Inspection of ASME Code Class 1 Small-Bore Piping, XI.M35
  • 13-LS-A120, External Surfaces Monitoring of Mechanical Components, XI.M36
  • 3-LS-A122, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, XI.M38
  • 13-LS-A123, Lubricating Oil Analysis, XI.M39
  • 13-LS-A125, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements - ALEE, XI.E1
  • 13-LS-A126, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, XI.E3
  • 13-LS-A131, Masonry Walls, XI.S5
  • 13-LS-A132, Structures Monitoring, XI.S6
  • 13-LS-A133, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, XI.S7
  • 13-LS-A135, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, XI.E2
  • 13-LS-A137, Fuse Holders
  • 13-LS-A201, Time-Limited Aging Analyses (TLAA) - Metal Fatigue Reactor Coolant Pressure Boundary, X.M1
  • 13-LS-A202, TLAA - Environmental Qualification of Electrical Components, X.E1
  • 13-LS-A203, TLAA - Concrete Containment Tendon Prestress, X.S1 Areas toured:
  • tendon gallery
  • nuclear steam supply systems
  • auxiliary buildings
  • fuel buildings
  • fuel oil storage tanks
  • turbine building The licensee had 41 aging management programs and 63 commitments:

In the Safety Evaluation Report (SER), the following commitments were closed or deleted: 47, 48, 49, 52 In the Phase 1 inspections for Units 1 and 2, the following commitments were closed:

  • A0 - Updating USAR Chapter 19 and Commitment 1
  • A1.2 - Water Chemistry and Commitment 4
  • A1.5 - Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors and Commitment 7
  • A1.6 - Flow-Accelerated Corrosion and Commitment 8
  • A1.9 - Open-Cycle Cooling Water System and Commitment 11
  • A1.10 - Closed-Cycle Cooling Water System and Commitment 12
  • A1.12 - Fire Protection and Commitment 14
  • A1.21 - 13-LS-A121, Reactor Vessel Internals - B2.1.16, NUREG 1801 Program, XI.M16A with Commitment 23
  • A1.23 - Lubricating Oil Analysis and Commitment 25
  • A1.30 - Appendix J and Commitment 32
  • A1.31 - Masonry Walls Program and Commitment 33 The following aging management programs and commitments remain open:
  • 13-LS-A118, Buried Piping and Tanks Inspection Program, XI.M34 and Commitment 20
  • 13-LS-A122, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components XI.M38 and Commitment 24 The Unit 3 Phase 1 inspection will review the commitments that remain open for potential closure.

Post-Approval Site Inspection for License Renewal===

Main article: IP 71003
(1) A1.0 13-LS-A100, PVNGS Aging Management Program Evaluation Report - Quality Assurance for Aging Management Programs (IQMB-1/B1.3) with Commitment 2 (Regulator Commitment Tracking System Action Item RCTSAI 3246887)

This is an existing program credited for license renewal. The program implements the requirements of 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Processing Plants. The Quality Assurance Program includes the elements of corrective action, confirmation process, and administrative controls and is applicable to all safety-related and non-safety related systems, structures, and components (SSCs) that are subject to aging management activities. This aging management program is closed.

Commitment 2 - This existing program is credited for license renewal and procedures will be enhanced to include those non-safety related SSCs requiring aging management within the scope of the quality assurance program to address the elements of corrective actions, confirmation process, and administrative controls.

The inspectors reviewed the program basis documents, administrative procedures and implementing procedures to verify that the licensee developed the program as described in the license renewal application. The inspectors confirmed the licensee completed the required commitments and implemented the procedures or administrative controls associated with this program prior to the period of extended operation (PEO). The inspectors concluded that the program would continue to effectively manage the effects of aging through the PEO and concluded that the licensee met the conditions of Commitment 2. This commitment is closed.

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

(2) A1.1 13-LS-A101, PVNGS Aging Management Program Evaluation Report - ASME Section XI Inservice Inspection (ISI), Subsections IWB, IWC, and IWD - B2.1.1, NUREG 1801 Program XI.M1 with Commitment 3 (RCTSAI 3246890)

This is an existing program that implements requirements for inservice inspection, repair and replacement. The ISI program is consistent with the requirements of ASME Section XI, IWB, IWC, and IWD for inservice inspection, repair, and replacement of ASME Class 1, 2, and 3 components. The PVNGS ISI program scope includes ASME Section XI, Subsections IWB-1100, IWC-1100, and IWD-1100 for Class 1, 2, and 3 components and includes pressure-retaining components and their integral attachments. The PVNGS ASME Class 1, 2, and 3 components which are exempt from volumetric and surface examination requirements, but not exempt from visual exam requirements, meet the criteria of ASME Section XI, IWB-1220, IWC-1220, and IWD-1220. 10 CFR 50.55a exceptions to Code requirements are listed in the ISI program manual. This aging management program is closed.

Commitment 3 - The ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program (XI.M1) is an existing program that manages cracking, loss of fracture toughness, and loss of material in Class 1, 2, and 3 piping and components within the scope of license renewal. The program includes periodic visual, surface, volumetric examinations and leakage tests of Class 1, 2 and 3 pressure-retaining components, including welds, pump casings, valve bodies, integral attachments, and pressure-retaining bolting. PVNGS inspections meet ASME Section XI requirements. The PVNGS ISI program meets the requirements of ASME Section XI 2013 edition. PVNGS will use the ASME Code Edition consistent with the provisions of 10CFR50.55a during the subsequent intervals, including the PEO. Note that when the aging management program was initially developed, PVNGS was in the third ISI interval. The station has since transitioned to the fourth ISI interval. (Reference 13-LSA101, section 3.1 for scope).

This commitment is associated with the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program (XI.M1). Commitment 3, as worded in the SER and the Updated Safety Analysis Report (UFSAR), is: SER Commitment Wording (NUREG-1961 Appendix A) Existing ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program is credited for license renewal. This commitment is closed.

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

(3) A1.2 13-LS-A102, Water Chemistry, XI.M1 with Commitment 4 (RCTSAI 3246891)

This is an existing program consistent with the Generic Aging Lessons Learned (GALL)report. The water chemistry program manages cracking, denting, loss of material, reduction in heat transfer, and wall thinning in the primary and secondary water systems.

The licensee credits an existing water chemistry program for license renewal that uses current industry standards. This aging management program is closed.

Commitment 4 - The existing water chemistry program is credited for license renewal.

The inspectors reviewed the existing water chemistry program to ensure that the licensee would continue to manage the effects of aging during the PEO. The inspectors interviewed the program owner and reviewed the UFSAR supplement, implementing documents, condition reports, and the implementing procedure specification 74DP-9CY04, Systems Chemistry Specification, that the licensee updates on an ongoing basis to comply with current EPRI guidelines that supports the implementation of the chemistry program. The inspectors verified that the licensee uses their current program with no additional enhancements and no exceptions. The inspectors also performed a walkdown of the chemistry lab. This commitment is closed.

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

(4) A1.3 13-LS-A103, Reactor Head Closure Stud Bolting, XI.M2 with Commitment 5 (RCTSAI 3246892)

This is an existing program that is consistent with NUREG-1801 Revision 2,Section XI.M3, Reactor Head Closure Studs with the exception that the actual yield strength of the bolting material for the reactor closure studs may be greater than the 150 ksi yield strength recommended by NUREG-1339. The program conducts ASME Section XI inspections of reactor vessel flange stud hole threads, reactor head closure studs, nuts, and washers to manage cracking and loss of material. The program includes periodic visual and volumetric examinations of reactor vessel flange stud hole threads, reactor head closure studs, nuts, and washers and performs visual inspection of the reactor vessel flange closure during primary system leakage tests. The program implements ASME Section XI Code, Subsection IWB, 2001 Edition through the 2003 addenda.

Reactor vessel flange stud hole threads, reactor head closure studs, nuts, and washers are identified in ASME Section XI Tables IWB-2500-1 and are within the scope of license renewal. PVNGS follows the preventive measures in Regulatory Guide 1.65. PVNGS uses a lubricant on reactor vessel flange stud hole threads, reactor head closure stud and nut threads, and washer faces after reactor head closure stud, nut, and washer cleaning, and examinations are complete. In conformance with 10 CFR 50.55a(g)(4)(ii),the ISI program is updated during each successive 120-month inspection interval to comply with the requirements of the latest edition of the Code specified twelve months before the start of the inspection interval. PVNGS will use the ASME Code Edition consistent with the provisions of 10 CFR 50.55a during the PEO. Potential cracking and loss of material conditions in reactor vessel flange stud hole threads, reactor head closure studs, nuts, and washers are detected through visual or volumetric examinations in accordance with ASME Section XI requirements in PVNGS procedures every ten years. These inspections are conducted during refueling outages. Reactor vessel studs are removed from the reactor vessel flange each refueling outage. Studs, nuts, and washers are stored in protective racks after removal. Reactor vessel flange holes are plugged with watertight plugs during cavity flooding. These methods ensure the holes, studs, nuts, and washers are protected from borated water during cavity flooding.

Reactor vessel flange leakage is detected prior to reactor startup during reactor coolant system pressure testing each refueling outage. This aging management program is closed.

Commitment 5 - The Reactor Head Closure Studs program will conduct ASME Section XI inspections of reactor vessel flange stud hole threads, reactor head closure studs, nuts, and washers to manage cracking and loss of material. The program includes periodic visual and volumetric examinations of reactor vessel flange stud hole threads, reactor head closure studs, nuts, and washers and performs visual inspection of the reactor vessel flange closure during primary system leakage tests. The PVNGS program implements ASME Section XI Code, Subsection IWB, 2001 Edition through the 2003 addenda. Reactor vessel flange stud hole threads, reactor head closure studs, nuts, and washers are identified in ASME Section XI Tables IWB-2500-1 and are within the scope of license renewal. PVNGS follows the preventive measures in Regulatory Guide 1.65.

PVNGS uses a lubricant on reactor vessel flange stud hole threads, reactor head closure stud and nut threads, and washer faces after reactor head closure stud, nut, and washer cleaning, and examinations are complete.

The inspectors interviewed the program owner and reviewed the UFSAR supplement, periodic visual results and volumetric exams and results of the reactor vessel flange, reactor closure studs, nuts, and washers from previous outages. The inspectors verified that the licensee uses their current program procedures, and that PVNGS plans to replace moly-disulfide on the reactor vessel closure studs and nuts in all three units with the replacement lubricant Fel-Pro N-5000. This commitment is associated with the Reactor Head Closure Studs Program (XI.M3). This commitment is closed.

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

(5) A1.4 13-LS-A104, Boric Acid Corrosion, XI.M10 with Commitment 6 (RCTSAI 3246893)

This is an existing program that is consistent with NUREG-1801 Revision 2,Section XI.M10, Boric Acid Corrosion. The program covers any structures or components on which boric acid corrosion may occur (e.g., steel, copper alloy > 15 percent zinc, and aluminum) and electrical components onto which borated reactor water may leak. The program includes provisions in response to the recommendations of NRC Generic Letter 88-05. Generic Letter 88-05 provides a program consisting of systematic measures to ensure that corrosion caused by leaking borated coolant does not lead to degradation of the leakage source or adjacent structures and components and provides assurance that the reactor coolant pressure boundary will have an extremely low probability of abnormal leakage, rapidly propagating failure, or gross rupture. This aging management program is closed.

Commitment 6 - Existing Boric Acid Corrosion Program is credited for license renewal.

The program manages loss of material due to boric acid corrosion and includes provisions to identify, inspect, examine and evaluate leakage, and initiate corrective actions. The program relies in part on implementation of recommendations of NRC Generic Letter 88-05, Boric Acid Corrosion of Carbon Steel Reactor Pressure Boundary Components in PWR Plants. The program also includes examinations conducted during ISI pressure tests performed in accordance with ASME Section XI requirements. The program addresses recent operating experience noted in NRC Regulatory Issue Summary 2003-13, NRC Review of Responses to Bulletin 2002-01, Reactor Pressure Vessel Head Degradation and Reactor Coolant Pressure Boundary Integrity (which includes NRC Bulletin 2002-01, 2002-02, and NRC Order EA-03-009) and NRC Bulletin 2003-02, Leakage from Reactor Pressure Vessel Lower Head Penetrations and Reactor Coolant Pressure Boundary Integrity. This commitment is closed.

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

(6) A1.5 13-LS-A105, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components, XI.M11A with Commitment 7 (RCTSAI 3246894)

This is an existing program that manages cracking due to primary water stress corrosion cracking (PWSCC) and loss of material due to boric acid wastage in nickel-alloy pressure vessel head penetration nozzles and includes the reactor vessel closure head, upper vessel head penetration nozzles and associated welds. The program for Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors (Upper Head Nickel-Alloy AMP) was developed by PVNGS to respond to NRC Order EA-03-009. ASME Code Case N-729-4, subject to the conditions specified in 10 CFR 50.55a(g)(6)(ii)(D)(2) through (6), has superseded the requirements of NRC Order EA-03-009. The inspectors reviewed the aging management program basis document, implementing procedures, and documentation of completed inspection activities. The inspectors concluded that the station's implementing procedures are adequate to implement these required programs, and the program appears to be implemented appropriately in accordance with station procedures. This aging management program is closed.

Commitment 7 - This commitment is associated with the Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Program (XI.M11A). This program provides measures for monitoring to detect degradation prior to loss of intended function by conducting non-destructive examinations of the nozzles and the associated welds. Detection of cracking (including cracking induced by PWSCC) is accomplished through implementation of a combination of non-destructive examinations such as bare metal visual examination and surface and volumetric examinations. The Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors program (XI.M11A) was evaluated in the license renewal application and in the Safety Evaluation Report (SER, NUREG-1961) against NUREG-1801 Revision 1,Section XI.M11A, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors, and was found to be consistent without enhancement or exception.

Subsequent to issuance of the application and associated SER, the Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors program was evaluated against the guidance of NUREG-1801 Revision 2 Section XI.M11B, Cracking of Nickel-Alloy Components and Loss of Material Due to Boric Acid-Induced Corrosion in Reactor Coolant Pressure Boundary Components (PWRs only) and was found to be consistent in conjunction with the Boric Acid Corrosion AMP XI.M10 and the Nickel-Alloy Aging Management Program. The aging management for the aging effect of loss of material of the upper vessel head due to wastage is also included in the Boric Acid Corrosion Program. Aging management for cracking due to PWSCC in all other reactor coolant pressure boundary locations that contain Alloy 600 are included in the Nickel-Alloy Aging Management Program. The Alloy 600 Management Program Plan maintains the integrity and operability for all other nickel-alloy components. This commitment is closed.

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

(7) A1.6 13-LS-A106, Flow-Accelerated Corrosion, XI.M17 with Commitment 8 (RCTSAI 3246895)

This is an existing program that manages wall thinning caused by flow-accelerated corrosion and various erosion mechanisms. This program includes performing

(a) an analysis to determine critical locations,
(b) limited baseline inspections to determine the extent of thinning at these locations, and
(c) follow-up inspections to confirm the predictions or repairing or replacing components as necessary. This aging management program is closed.

Commitment 8 - The existing flow-accelerated corrosion program is credited for license renewal. Prior to the PEO, the program will be enhanced to clarify the guidance for the susceptible small-bore piping components and to verify the trace chromium content of the carbon steel pipe replacement. The commitment was modified to delete the enhancement in Commitment 8 that referred to the chromium content of replacement piping. The PVNGS flow-accelerated corrosion program has a provision that replacement piping should be flow-accelerated corrosion resistant. The deleted enhancement was to strengthen the requirement for obtaining material certification for the chromium content in the piping.

The inspectors interviewed the program owners, and reviewed the aging management program notebook, implementing work orders, procedures, and completed work orders.

The inspectors confirmed the licensee completed the required commitments and implemented the procedures or administrative controls associated with this program prior to the PEO.

The inspectors verified this aging management program commitment was inspected during Inspection Procedure 71003 Phase 1 inspection (ML22349A079) conducted on December 18, 2023. The inspectors concluded the program will continue to effectively manage the effects of aging through the PEO and concluded the licensee met the conditions of Commitment 8 and was closed during the 2023 inspection.

Based on our review of the actions implemented related to the flow-accelerated corrosion program, the inspectors concluded the program will continue to effectively manage the effects of aging through the PEO and concluded that the licensee met the conditions of Commitment 8. This commitment is closed.

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

(8) A1.7 13-LS-A107, Bolting Integrity, XI.M18 with Commitment 9 (RCTSAI 3246896)

This is an existing program that manages cracking, loss of material, and loss of preload for pressure-retaining closure bolting. The program includes preload control, selection of bolting material, use of lubricants or sealants, and performance of periodic inspections for indication of aging effects consistent with industry and NRC guidance. This aging management program is closed.

Commitment 9 - The existing bolting integrity program manages cracking, loss of material, and loss of preload for pressure-retaining bolting within the scope of license renewal. ASME component support bolting is not within the scope of this program but is managed under the scope of ASME Section XI, Subsection IWF. The program includes preload control, selection of bolting material, use of lubricants/sealants consistent with EPRI good bolting practices, and performance of periodic inspections for indication of aging effects. The program is supplemented by inservice inspection requirements established in accordance with ASME Section XI, Subsections IWB, IWC, and IWD for ASME Class pressure-retaining bolting and the External Surfaces Monitoring program.

This program does not manage the aging of reactor head closure stud bolting (AMP XI.M3) or structural bolting (AMPs XI.S1, XI.S3, XI.S6, XI.S7, and XI.M23).

The inspectors interviewed the program owner and reviewed the UFSAR supplement, condition reports, NRC commitments and specified procedures such as 30DP-9MP02, Fastener Tightening/Preload, revision 11 and 73TI-9ZZ17, Visual Examinations of Welds, Bolting, and Components, revision 30a. The PVNGS Bolting Integrity Program manages the aging effects associated with pressure boundary bolting through performance of periodic inspections, material selection and control, and bolting preload control maintenance. The program also includes repair and replacement controls and requirements on the selection of thread lubricants, consideration of lubricant use on torque determinations, and assembly requirements (e.g., bolting/torque patterns). The inspectors verified that the licensee uses their current program with some enhancements including ASME Section XI and one exception captured in the reactor head closure studs program for replacing lubricant. The licensee plans to replace moly-disulfide on the reactor vessel closure studs and nuts in all three units with the replacement lubricant Fel-Pro N-5000. The inspectors identified no issues of concern as a part of this review of the aging management program and considered the evaluation of this aging management program complete. This commitment is closed.

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

(9) A1.8 13-LS-A108, Steam Generators, XI.M19 with Commitments 10, (RCTSAI 3246897), 61, (RCTSAIs 3561775 [Unit 1], 3561777 [Unit 2], 3561779 [Unit 3]), and 62 (RCTSAI 3561782 [Unit 1], 3561784 [Unit 2], 3561788 [Unit 3])

This is an existing program that manages cracking, loss of material, reduction of heat transfer, and wall thinning of the steam generator tubes, plugs, sleeves, and secondary side steam generator internal components. The program provides preventive measures in the form of predictive assessment, tube plugging, foreign material exclusion, foreign object search, secondary side cleaning and maintenance, and maintaining the chemistry. The program detects degradation through non-destructive examinations, visual inspection, and in situ pressure testing. The program includes the preventive measures, degradation assessment, steam generator inspection, integrity assessment, primary and secondary chemistry controls, leakage monitoring, and required maintenance and repair activities necessary to manage secondary side steam generator internals (including tube supports) and the integrity of the primary pressure boundary formed by the steam generator tubes and plugs. The aging management measures employed include non-destructive examination, visual inspection, sludge removal, tube plugging, in situ pressure testing and maintaining the chemistry environment by removal of impurities and addition of chemicals to control pH and oxygen. Non-destructive examination inspection scope and frequency, and primary-to-secondary leak rate monitoring are conducted consistent with the requirements of PVNGS technical specifications. The licensee evaluates tube integrity in accordance with the structural integrity performance criteria specified in technical specifications which encompasses and exceeds the requirements of Regulatory Guide 1.121. In addition, technical specifications include accident induced leakage performance criterion and operational leakage performance criterion. The steam generator management practices are consistent with NEI 97-06, "Steam Generator Program Guidelines. The Steam Generator Tube Integrity program (XI.M19) is an existing program implemented via procedure 81DP-9RC01 and other station procedures. This aging management program is closed.

Commitment 10 - This program includes preventive measures, degradation assessment, steam generator inspection, integrity assessment, primary and secondary chemistry controls, leakage monitoring, and required maintenance and repair activities necessary to manage secondary side steam generator internals (including tube supports) and the integrity of the primary pressure boundary formed by the steam generator tubes and plugs. The aging management measures employed include non-destructive examination, visual inspection, sludge removal, tube plugging, in situ pressure testing and maintaining the chemistry environment by removal of impurities and addition of chemicals to control pH and oxygen.

Non-destructive examination inspection scope and frequency, and primary-to-secondary leak rate monitoring are conducted consistent with the requirements of technical specifications. The licensee evaluates tube integrity in accordance with the structural integrity performance criteria specified in technical specifications which encompasses and exceeds the requirements of Regulatory Guide 1.121. The existing Steam Generator Tube Integrity program is credited for license renewal. This commitment is closed.

Commitment 61 - This is a one-time inspection associated with the steam generator tube integrity aging management program (XI.M19) and addresses the concern regarding potential failure of the steam generator (SG) reactor coolant system pressure boundary due to possible PWSCC of the steam generator divider plate bar welds in all units and the divider plate bars in Unit 2.

The primary water chemistry program alone may not be effective in managing the aging effect of cracking due to PWSCC in SG divider plate assembly components fabricated from Alloy 600 and its associated weld metals. Potential failure of SG reactor coolant system pressure boundary due to PWSCC of SG divider plate bar welds in all units and divider plate bars in Unit 2. This commitment is closed.

Commitment 62 - This commitment is associated with the steam generator tube integrity aging management program (XI.M19) and addresses the concern regarding potential failure of the SG primary-to-secondary pressure boundary due to PWSCC cracking of tube-to-tubesheet welds.

The licensee elected to perform an evaluation (Condition Report AI 20-08573-002)comparing EPRI Technical Reports 1014982, 1020988 and 3002002850 to the current SG design. The option was revised based upon findings from EPRI Technical Reports 1014982, 1020988, and 30020022850 and the direction in the NRC Interim Staff Guidance as documented in PVNGS Engineering Study Evaluation of License Renewal Commitments #61 & #62 and Recommended Action and PVNGS Commitment 61 and 62 Proposed Action Plan Steam Generator Tubing Integrity Aging Management Program. EPRI conducted analysis of tube-to-tubesheet welds using materials and geometry identical to the PVNGS configuration (Alloy 690 tubes welded to Alloy 82 cladding) and concluded that if the tube-to-tubesheet final weld chromium content was sufficient then the welds can be considered as not susceptible to SCC. The study further concluded that tubesheet bowing produces a compressive stress field on the bottom of the tubesheet, so there is no tensile stress driving crack propagation into the tubesheet.

The NRC issued License Renewal Interim Staff Guidance, LR-ISG-2016-01 that if these conditions were met, then the applicant will perform general visual inspections of the tubesheet region looking for evidence of cracking. The licensee steam generators meet these conditions, and the licensee revised this commitment to include the visual inspections of the tubesheets at least once every three outages or 72 effective full power months. This commitment is closed.

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

(10) A1.9 13-LS-A109, Open-Cycle Cooling Water System, XI.M20 with Commitment 11 (RCTSAI 3246898)

This is an existing program that manages the loss of material and reduction of heat transfer for components exposed to the raw water. The program includes surveillance techniques to manage aging effects caused by biofouling, corrosion, erosion and silting in the open-cycling water system and in structures and components cooled by the open-cycling cooling water system for the PEO. The systems involved are essential spray ponds, essential cooling water system heat exchangers, emergency diesel generator jacket water, emergency diesel lube oil, and emergency diesel generator turbo air intercooler heat exchangers. The inspectors reviewed the procedures, records, and conducted discussions with licensee personnel. This aging management program is closed.

Commitment 11 - The existing Open-Cycle Cooling Water System program is credited for license renewal, and prior to the PEO, the program will be enhanced to clarify guidance in the conduct of piping inspections using non-destructive examination techniques and related acceptance criteria.

This aging management program was inspected on December 11, 2024, in report ML24345A055 with no associated open actions. During walkdowns and record reviews, the inspectors noted internal corrosion of the diesel generator lube oil systems on all three units. The licensee noted that they are utilizing the corrective action program, and the inspectors found this acceptable. The inspectors determined the licensee met Commitment 11 and implemented actions to manage the effects of aging based on the review of the procedures, records, and interviews with licensee personnel. This commitment is closed.

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

(11) A1.10 13-LS-A110, Closed-Cycle Cooling Water System, XI.M21 with Commitment 12 (RCTSAI 3246899)

This is an existing program that manages the loss of material, cracking, and reduction in heat transfer for components. The program includes maintenance of system corrosion inhibitor concentrations and chemistry parameters following the guidance of EPRI 3002000590 to minimize aging, periodic testing, inspections to evaluate system, and component performance. Inspection methods include visual, ultrasonic testing, and eddy current testing. The inspectors reviewed the procedures, records, and conducted discussions with licensee personnel. This aging management program is closed.

Commitment 12 - This existing program is credited for license renewal. The inspectors interviewed the program owners, performed walkdowns of the diesel generators, and essential cooling water system with the program owners. The inspectors reviewed the aging management program notebook, implementing work orders, procedures, and completed work orders and determined the licensee has met Commitment 12 and implemented actions to manage the effects of aging. This commitment is closed.

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

(12) A1.11 13-LS-A111, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, XI.M23 with Commitment 13 (RCTSAI 3246900)

This is an existing program that manages the loss of material for all cranes, trolley and hoist structural components. The program is credited for license renewal and manages loss of material for all cranes, trolley and hoist structural components, fuel handling equipment and applicable rails within the scope of license renewal. Visual inspections will assess conditions such as loss of material due to corrosion of structural members, visible signs of rail wear, and loss of preload due to loose bolts, missing or loose nuts, and other conditions indicative of loss of preload. Preventive maintenance procedures have been enhanced to inspect for loss of material due to corrosion or rail wear. This aging management program is closed.

Commitment 13 - The existing inspection of Overhead Heavy Load and light load (Related to Refueling) Handling systems program is credited for license renewal. The inspectors noted that prior to the PEO procedures will be enhanced to inspect for loss of material due to corrosion or rail wear. This commitment is closed.

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

(13) A1.12 13-LS-A112, Fire Protection, XI.M26 with Commitment 14 (RCTSAI 3246901; 3554175)

This is an existing program credited with managing loss of material for fire rated barriers including fire rated doors, fire dampers, and the Halon system. This program manages the aging effects on all actuation signals, valves, nozzles, and discharges of the Halon and CO2 system. The program is credited with managing concrete cracking, spalling, and loss of material for fire barrier walls, ceilings, and floors. This program looks for increased hardness, shrinkage, and loss of strength to fire barrier penetration seals. This program credits periodic visual inspections of fire barrier penetration seals, fire dampers, and structural fire barriers (walls, ceilings, and floors), drop tests of fire dampers and functional tests on fire rated doors to ensure they can perform their intended functions.

This program includes periodic visual inspections and functional testing of the Halon, CO2 system, and fire rated doors. The inspections of fire doors ensure the integrity to detect aging affects. The inspectors reviewed the procedures, records, and conducted discussions with licensee personnel. This aging management program is closed.

Commitment 14 - The existing fire protection program is credited for license renewal and prior to the PEO procedures will be enhanced to perform the testing of the Electro-Thermal Links (ETLs) and functional testing of the Halon and CO2 dampers every 18 months or at the frequency specified in the current licensing basis in effect upon entry into the PEO.

The inspectors verified this aging management program commitment has already been inspected during Inspection Procedure 71003 Phase 1 inspection (ML22349A079)conducted on December 18, 2023. The inspectors concluded the program will continue to effectively manage the effects of aging through the PEO. The details in the description of the aging management program were verified and include the following procedure enhancements:

  • Start trending requirements for the diesel-driven fire pump.
  • Visual inspection of the fuel supply line to detect degradation.
  • Inspect for mechanical damage, corrosion, and loss of material of the Halon discharge pipe header and the CO2 system discharge nozzles.
  • Stat the qualification requirements for inspecting penetration seals, fire rated doors, fire barrier walls, ceilings, and floors.

The inspectors reviewed completed work documents and periodic test results performed to ensure fire protection program equipment continues to be able to perform intended functions. The inspectors reviewed the program basis documents, administrative procedures, and implementing procedures to verify that the licensee developed the program as described in the license renewal application. The inspectors confirmed the licensee completed the required commitments and implemented the procedures/administrative controls associated with this program prior to the PEO. This commitment is closed.

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

(14) A1.13 13-LS-A113, Fire Water System, XI.M27 with Commitment 15 (RCTSAI 3246902)

This is an existing program that manages the aging of piping (including water-based piping that is normally drained), piping components, pump casings, sprinkler heads, tanks, fittings, valve bodies, hose stations, and hydrants. The program focuses on the loss of material caused by pitting, crevice, galvanic corrosion, microbiological corrosion, or biofouling of carbon 7 steel, stainless-steel, cast-iron, copper, bronze, brass, galvanized, and ductile iron components in the water-based fire protection systems.

Periodic fire water component inspections, tests, fire main flushing, sprinkler inspections, and flow tests are performed in accordance with National Fire Protection Association (NFPA) 25, Standard for the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems, 2002 Edition, to ensure that the water-based fire protection system can perform its intended function. The inspectors reviewed the procedures, records, and interviewed licensee personnel. This aging management program is closed.

Commitment 15 - That the existing fire water system program is credited for license renewal, and prior to the PEO, the following enhancements will be implemented:

  • Specific procedures will be enhanced to include review and approval requirements under the Nuclear Administrative Technical Manual (NATM).
  • Procedures will be enhanced to be consistent with the current code of record or NFPA 25-2002 Edition.
  • Procedures will be enhanced to field service test a representative sample or replace sprinklers prior to 50 years in service and test thereafter every 10 years to ensure that signs of degradation are detected in a timely manner.
  • Procedures will be enhanced to be consistent with NFPA 25 Section 7.3.2.1, 7.3.2.2, 7.3.2.3, and 7.3.2.4.

The inspectors noted that this program had been inspected in previous Inspection Procedure 71003 Phase 1 inspections (ML22349A079 and ML24345A055) and the commitment remained open based on incomplete actions. The inspectors verified that actions associated with work order 5570252 and plans to assess the 50-year field service test representative sprinkler sample or replace all their sprinkler heads were completed.

The inspectors reviewed the program basis documents, administrative procedures, and implementing procedures to verify that the licensee developed the program as described in the license renewal application. The inspectors confirmed the licensee completed the required commitment requirements and implemented the procedures/administrative controls associated with this program prior to the PEO.

The inspectors noted that the licensee is having challenges with selective leaching and corrosion on the inside of their fire water piping and valves. The licensee was aware of the issue and is addressing it through their corrective action program. This commitment is closed.

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

(15) A1.14 13-LS-A114, Fuel Oil Chemistry, XI.M30 with Commitment 16 (RCTSAI 3246903)

This is an existing program that manages loss of material in tanks, components, and piping exposed to diesel fuel oil. The program includes periodic removal of accumulated water found in tanks, periodic draining, cleaning, and inspection of fuel oil storage tanks.

This aging management program is closed.

Commitment 16 - The licensee performs volumetric examinations to assess identified degradation or where internal visual inspection is not possible. The licensee maintains fuel oil quality by monitoring and controlling fuel oil contamination. Technical specifications provide limits for both new and stored fuel oil for use in emergency diesel generators (EDGs). The licensee follows manufacturer fuel oil quality recommendations for the portable diesel-driven fire water pump tanks, portable diesel electric generator fuel oil tanks, and the portable caddy fuel oil tanks. The licensee enhanced procedures to extend the scope of the program to include the station blackout generator (SBOG) fuel oil storage tank and SBOG skid fuel tanks. Specifically, the licensee enhanced procedures to include the following:

(1) Ten-year periodic draining, cleaning, and inspections on the diesel-driven fire pump day tanks, the SBOG fuel oil storage tank, and SBOG skid fuel tanks, and
(2) Ultrasonic testing (UT) or pulsed eddy current (PEC)thickness examination will be conducted to detect corrosion-related wall thinning if degradation is found during the visual inspections and once on the tank bottoms for the EDG fuel oil storage tanks, EDG fuel oil day tanks, diesel-driven fire pump day tanks, SBOG fuel oil storage tanks, and SBOG skid fuel tanks. The one-time UT or PEC examination on the tank bottoms will be performed before the PEO.

The inspectors interviewed the program owner and reviewed the UFSAR supplement, implementing documents, condition reports, and procedure 74DP-9DF01, Diesel Fuel Oil Testing Program, revision 15a, that supports the implementation of fuel oil chemistry program. The inspectors also reviewed procedure 31ST-9DF02, Diesel Fuel Oil Tank Condensate Removal, revision 13a, for sampling and removal of any condensate accumulated in the bottom of the diesel fuel oil storage tanks. The inspectors also observed a chemistry tech take samples from the 3A diesel fuel oil storage tank vault and analyze the results in the on-site chemistry lab.

Additionally, the inspectors reviewed the results of the licensees one-time inspections performed for this commitment in report APSROLI00020-REEPT-004, One-Time Inspection Program [NUREG-1801 Program XI.M32] Pre-PEO Inspection Results, revision 0, dated February 14, 2025. The inspectors identified no issues of concern as a part of this review of the aging management program and considered the evaluation of this aging management program complete. This commitment is closed.

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

(16) A1.15 13-LS-A115, Reactor Vessel Surveillance, XI.M31 with Commitment 17 (RCTSAI 3246904)

This existing surveillance program manages loss of fracture toughness for the reactor vessel caused by exposure to neutron fluence. The licensee had removed and tested surveillance capsules containing specimens of the limiting beltline material and associated weld metal, and weld heat affected zone metal. The program provides sufficient data for monitoring irradiation embrittlement at the end of the PEO and determines the need for any operating restrictions on the inlet temperature, neutron spectrum, and neutron flux. This aging management program is closed.

Commitment 17 - The existing Reactor Vessel Surveillance program is credited for license renewal and is partially complete. Prior to 50 effective full power years (EFPY), if an 80-year second PEO is anticipated, actions would be taken to request approval to withdraw remaining standby capsules at equivalent clad-base metal exposures not exceeding the 72 EFPY expected for the possible 80-year second PEO (at about 50 to 54 actual operating EFPY). Schedule changes must be approved by the NRC, as required by 10 CFR 50 Appendix H and as discussed in NRC Administrative Letter 97-04, NRC Staff Approval for Changes to 10 CFR Part 50, Appendix H, Reactor Vessel Surveillance Specimen Withdrawal Schedules. The need to monitor vessel fluence following removal of the remaining standby capsules, and ex-vessel or in-vessel methods, would be addressed prior to removing the remaining capsules. If 80 years of operation is not chosen, there will be no implementing documents.

The inspectors interviewed the program owners, and reviewed the aging management program notebook, implementing work orders, procedures, and completed work orders.

The inspectors confirmed the licensee completed the required commitments and implemented the procedures or administrative controls associated with this program prior to the PEO. The inspectors verified that tracking mechanisms and processes were in place to modify commitment and request appropriate regulatory approvals, as necessary, should the licensee proceed with a second PEO. This commitment is closed.

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

(17) A1.16 13-LS-A116, One-Time Inspection, XI.M32 with Commitment 18 (RCTSAIs 3246906 [Unit 1]; 3247258 [Unit 2]; 3247259 [Unit 3])

This new one-time aging management program conducts visual examinations of components in the water chemistry, fuel oil chemistry, and lubricating oil analysis programs to verify the effectiveness of the aging management activities performed by those programs. The licensee selected a representative sample size of 20 percent of the population (defined as components having the same material, environment, and aging effect combination) or a maximum of 25 components. This sample will be based on criteria such as the longest service period, most severe operating conditions, lowest design margins, lowest or stagnant flow conditions, high flow conditions, and highest temperature. This aging management program is closed.

Commitment 18 - The one-time inspection program is a new program that will be implemented prior to the PEO and is credited for license renewal. Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

The inspectors reviewed the implementing procedure 73DP-9EE05, One-Time Inspection Program, and the aging management program notebook, implementing work orders, and completed work orders, and then had discussions with the program owner to understand the actions taken. This commitment is closed.

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

(18) A1.17 13-LS-A117, Selective Leaching, XI.M33 with Commitment 19 (RCTSAIs 3246908 [Unit 1]; 3247260 [Unit 2]; 3247261 [Unit 3]; 3563030)

This new one-time condition monitoring program evaluates whether loss of material has been caused by selective leaching for gray cast-iron, ductile iron, and copper alloys (except for inhibited brass) containing greater than 15 percent zinc or greater than 8 percent aluminum components that are exposed to raw water, treated water, closed cooling water, or ground water. The program includes visual inspection and hardness measurement or other industry-accepted mechanical inspection techniques such as destructive testing, scraping, or chipping of selected components to determine whether selective leaching affects the component intended functions. If the licensee identifies selective leaching, the licensee will expand the sample to include locations for follow-up examinations or evaluations. This aging management program is closed.

Commitment 19 - This is a new program that will be implemented prior to the PEO.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

The inspectors reviewed the implementing procedure 73DP-9EE06, "One-Time Inspection for Selective Leaching Degradation of Components," and had discussions with the program owner to understand the actions taken. The inspectors performed walkdowns of two removed check valves that had experienced selective leaching: Valve Check Discharge Side of ESP PUMP SPA-P01 (1PSPAV041) and Valve Check for ESP PUMP SPB-P01 DISCHARGE LINE (2PSPBV012). The licensee conducted visual and ultrasonic inspections of both valves and destructive testing on 1PSPAV041. This commitment is closed.

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

(19) A1.18 13-LS-A118, Buried Piping and Tanks Inspection Program, XI.M34 with Commitment 20 (RCTSAIs: 3246909 [Unit 1]; 3247263 [Unit 2]; 3247264 [Unit 3])

This existing condition and performance monitoring program manages cracking, loss of material, and change in surface conditions of buried and underground components in the auxiliary saltwater, diesel generator fuel transfer, fire protection, and makeup water systems. The program includes preventive measures (i.e., coatings, backfill quality, and cathodic protection), inspections, and, as appropriate, performance monitoring activities.

Visual inspections monitor the condition of protective coatings and wrappings and directly assess the surface condition of components with no protective coatings or wraps. Evidence of wall loss beyond minor scale observed during visual inspections of buried piping will require a supplemental surface examination and/or volumetric non-destructive testing. The program includes opportunistic inspection of buried piping and tanks as they are excavated or on a planned basis if opportunistic inspections have not occurred. This aging management program remains open.

Commitment 20 - The Buried Piping and Tanks Inspection program is a new program that will be implemented prior to the PEO. Within the ten-year period prior to entering the PEO an opportunistic or planned inspection of buried tanks at the PVNGS site will be performed. Prior to the PEO, the Buried Piping and Tanks Inspection program will include provisions to;

(1) ensure electrical power is maintained to the cathodic protection system for in-scope buried piping at least 90 percent of the time (e.g., monthly verification that the power supply circuit breakers are closed or other verification that power is being provided to the system), and
(2) ensure that the National Association of Corrosion Engineers (NACE) cathodic protection system surveys are performed at least annually. Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

The inspectors reviewed procedures 83DP-0AP01, Buried Piping and Tanks Program, and 70DP-0MR02, "Maintenance Rule Monitoring Process," the cathodic protection maintenance rule SSC scoping, the aging management program notebook, implementing work orders, and completed work orders, and then had discussions with the program owner to understand the actions taken. The inspectors performed walkdowns of the cathodic protection system, currently excavated catholically protected piping, and an inspection of the internals of Unit 3 train A diesel fuel oil storage tank.

Based on review of the actions implemented related to the buried piping and tanks program, the inspectors concluded that although the program will continue to effectively manage the effects of aging through the PEO, parameters and/or methodologies have not been established to ensure electrical power is maintained to the cathodic protection system for in-scope piping at least 90 percent of the time (monthly verification that the power supply circuit breakers are closed or other verification that power is being provided to the system) and concluded that the licensee has not fully met the conditions of Commitment 20. This commitment remains open.

(20) A1.19 13-LS-A119, One-Time Inspection of ASME Code Class 1 Small-Bore Piping, XI.M35 with Commitment 21 (RCTSAI 3246910 [Unit 1]; 3247265 [Unit 2]; 3247266

[Unit 3])

This one-time inspection program provides assurance that aging of ASME Code Class 1 small-bore piping is not occurring, or that the aging effects are not significant, such that a plant-specific aging management program is not warranted. Volumetric butt and socket weld examinations were conducted in accordance with industry standards to ensure no signs of degradation were identified. This aging management program is closed.

Commitment 21 - The one-time inspection program conducts one-time inspections of plant system piping and components to verify the effectiveness of the water chemistry program (19.1.2), fuel oil chemistry program (19.1.14), and lubricating oil analysis program (19.1.23). The aging effects to be evaluated by the one-time inspection program are loss of material, cracking, and reduction of heat transfer. This commitment is closed.

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

(21) A1.20 13-LS-A120, External Surfaces Monitoring of Mechanical Components, XI.M36 with Commitment 22 (RCTSAI 3246911 [Unit 1], 3247272 [Unit 2], 3247273

[Unit 3])

This is a new program that will be implemented prior to the PEO. The program manages loss of material for stainless-steel, steel, aluminum, and copper alloy manages loss of components; and cracking, loss of material due to wear, hardening, and loss of strength for elastomer components. The program includes those systems and components within the scope of license renewal that require external surface monitoring. Visual inspections conducted during engineering walkdowns will be used to identify aging effects and leakage. Physical manipulation during the visual inspections must also be used to verify absence of hardening or loss of strength for elastomers. This aging management program is closed.

Commitment 22 - This is a new program that will be implemented prior to the PEO and is credited for license renewal.

During walkdowns, the inspectors noted that there were signs of rust on the outside of pipes in the essential cooling water, and other locations around the site that the licensee had not identified. The inspectors determined the site was having challenges with identifying corrosion during walkdowns. The inspectors concluded the program should continue to effectively manage the effects of aging through the PEO if implemented properly. The licensee met the conditions of Commitment 22. This commitment is closed.

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

(22) A1.21 13-LS-A121, Reactor Vessel Internals - B2.1.16, NUREG 1801 Program, XI.M16A with Commitment 23 (RCTSAI 3246912 [Unit 1]; 3247274 [Unit 2]; 3247276

[Unit 3])

This new program addresses various forms of cracking; loss of material induced by wear; loss of fracture toughness due to neutron irradiation embrittlement, or void swelling; dimensional changes due to void swelling and irradiation growth; loss of preload due to thermal and irradiation-enhanced stress relaxation or creep. The program also addresses aging effects related to Reactor Coolant System Nickel-Alloy Pressure Boundary Components and the Pressurizer Spray Heads via the XI.M11A Nickel-Alloy Penetration Nozzles and Plant Specific Nickel-Alloy aging management programs.

Commitment 23 is specific to reactor vessel internals. This aging management program is closed.

Commitment 23 - This is a new program that will be implemented prior to the PEO and is credited for license renewal.

The inspectors verified this commitment has already been inspected by an Inspection Procedure 71003 Phase 1 inspection (ML24345A055) conducted on December 11, 2024. The inspectors did not identify any findings or violations of more than minor significance for this aging management program during the previous inspection.

The inspectors reviewed the implementing procedures and the aging management program notebook, implementing work orders, and completed work orders, and then had discussions with the program owner to understand the actions taken. This commitment is closed.

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

(23) A1.22 13-LS-A122, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components, XI.M38 with Commitment 24 (RCTSAI 3246914 [Unit 1],

3247277 [Unit 2], and 3247278 [Unit 3])

This is a new program that will be implemented prior to the PEO. Industry and plant-specific operating experience will be evaluated in the development and implementation of this program to manage cracking, loss of material, wear, hardening and loss of strength. The program includes surfaces of piping, piping components, ducting and other components that are not covered by other aging management programs. In addition, domestic water, oily waste, and fire protection components with integral elastomer or cement mortar linings are also included in this program. The program performs visual inspections to detect aging effects that could result in a loss of component intended function. The visual inspections will be conducted during periodic maintenance, predictive maintenance, surveillance testing and corrective maintenance.

Additionally, visual inspections may be augmented by physical manipulation or pressurization to detect hardening and loss of strength of both internal and external surfaces of elastomers. The program also includes volumetric evaluation to detect stress corrosion cracking of the internal surfaces of stainless-steel components exposed to diesel exhaust. A representative sample of 20 percent of the population (defined as components having the same material, environment, and aging effect combination) or maximum of 25 components per population is inspected in each 10-year period of the PEO. The program owner will conduct periodic examinations during PEO to ensure the program is performing sufficient inspections and generate additional inspections as required. The inspectors reviewed the aging management program basis document, implementing procedures, and held discussions with site personnel including the internal surface program owner. The inspectors also walked down portions of the oily waste system for all three units. The inspectors reviewed procedure 73DP-9EE07, Internal Surface Inspections, revision 1, and confirmed that the licensee identified opportunities to conduct inspections for the new internal surfaces program. However, the licensee is still updating work order instructions and revising the implementation procedure (73DP-9EE07). The inspectors had questions about the training of maintenance personnel because the detection of aging effects identified in the commitment states, in part, that all inspections are carried out using plant-specific procedures by inspectors qualified through plant-specific programs. The implementation procedure states that both maintenance personnel and engineering personnel will perform the visual inspections.

However, the licensee is having the bulk of the visual inspections carried out by maintenance personnel. The inspectors had questions about how maintenance personnel would be able to identify specific acceptance criteria contained in the aging management program based on the generic training. The plant-specific qualified program for maintenance personnel that the licensee is taking credit for is the general maintenance training program and field guide EPRI 1007933. The licensee stated that the maintenance program provides the maintenance personnel with the basic conduct of maintenance fundamentals to just spot general observations of aging effects and to write a condition report so that engineering can readily assess the issue. This aging management program remains open.

Commitment 24 - Industry and plant-specific operating experience is evaluated to inform the development and implementation of the program. Repetitive task RT 204386 initiates an annual review of operating experience by the program owners using the guidance of NEI 14-13 revision 2, Use of Operating Experience for Age-Related Degradation and Aging Management Programs. In addition, the program has been evaluated and informed with the guidance of the GALL report, revision 2, and LR-ISG-2012-02 and the first inspections are required in the PEO.

The inspectors concluded that the licensee is in the process of completing the program prior to the PEO. The inspectors noted that this is a new program, and inspections will begin during the PEO, there were no examination results for the inspectors to review.

The inspectors also noted that the licensee is updating the implementation procedure, work orders, and completing the training of maintenance personnel. This commitment remains open.

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

(24) A1.23 13-LS-A123, Lubricating Oil Analysis, XI.M39 with Commitment 25 (RCTSAI 3246915)

This existing program manages loss of material and reduction of heat transfer for components within the scope of license renewal that have surfaces exposed to lubricating and hydraulic oils. The program will ensure the lubricating and hydraulic oil environment in mechanical systems is maintained to the required quality. The program monitors and controls oil contaminants, primarily water and particulates, within acceptable limits, thereby preserving an environment that is not conducive to aging effects. Monitoring and trending of oil analysis results identifies the potential for component aging before loss of component intended function occurs. The program includes acceptance criteria based on vendor and industry guidelines. The inspectors reviewed the program basis documentation, UFSAR supplement, work orders, aging management review documents, and existing procedures. The inspectors interviewed the system owner and verified that the licensee performed adequate historic reviews of plant-specific experience to determine aging effects. The inspectors reviewed procedure 73DP-9EE05, One-Time Inspection Program, revision 8, that provided directions for implementing the one-time inspection program. The inspectors identified no issues during the review of this aging management program and determined, through review of documentation, that the licensees current program was sufficient to manage the aging effects as described in the SER and the UFSAR. This aging management program is closed.

Commitment 25 - The existing Lubricating Oil Analysis program is credited for license renewal. The Lubricating Oil Analysis program manages loss of material and reduction of heat transfer for components with surfaces exposed to lubricating and hydraulic oils.

The applicant also stated that the program ensures that it maintains lubricating and hydraulic oil environments in mechanical systems to the required quality based on vendor and industry guidelines. The program monitors and controls oil contaminants, primarily water and particulates within acceptable limits, thereby preserving an environment that is not conducive to aging effects and that selected components aging will be tracked so that corrective actions can be taken before a loss of intended function occurs. The program is implemented through plant procedures that address sampling, testing, and management of samples and schedules and its effectiveness was verified through the one-time inspection program.

The inspectors reviewed the results of the licensees one-time inspections performed for this commitment in report APSROLI00020-REEPT-004, One-Time Inspection Program

[NUREG-1801 Program XI.M32] Pre-PEO Inspection Results, revision 0, dated February 14, 2025. The inspectors identified no issues of concern as a part of this review of the aging management program and considered the evaluation of this aging management program complete. This commitment is closed.

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

(25) A1.24 13-LS-A124, Electrical Cables and Connections Not Subject to 10 CFR 50.49 EQ Requirements - B2.1.24, NUREG 1801 Program, XI.E1 with Commitment 26 (RCTSAI 3246917)

This is a new program that manages the aging effects of embrittlement, melting, cracking, swelling, surface contamination, or discoloration to ensure that the electrical cables and connections within the scope of license renewal not subject to environmental qualification (EQ) requirements of 10 CFR 50.49 can perform the intended function through the PEO. Non-EQ cables and connections within the scope of license renewal in accessible areas with adverse environments were visually inspected for signs of localized accelerated aging on their outer insulation or jacket material. The inspections searched for signs of aging included embrittlement, discoloration, cracking, melting, swelling and surface contamination. The acceptance criteria was the absence of anomalous indication of degradation. Implementing procedures include 82DP-0EE01 Electrical Aging Management for inspection guidelines, and 37TI-9ZZ01 Infrared Thermography Inspection of Plant Components for inspection testing and acceptance criteria. This aging management program is closed.

Commitment 26 - This new program will be implemented prior to the PEO. Industry and plant-specific operating experience will be evaluated in the development and implementation of this program. Walkdowns are credited with identifying adverse localized environments with in-scope cables and connections and will be performed at least once every 10 years, with the first walkdowns completed before the PEO.

The inspectors reviewed the aging management program notebooks, implementing procedures, completed program activities in Regulator Commitment Tracking System Action Item (RCTSAI) 3246917, and held discussions with the program owner.

Specifically, the inspectors reviewed completed work orders, the results of the walkdowns in report APSROLI-00011-REPT-001, and corrective action documents. The inspectors confirmed the licensee has implemented the requirements of this program prior to the PEO. This commitment is closed.

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

(26) A1.25 13-LS-A125, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements - ALEE, XI.E1 with Commitment 27 (RCTSAI 3246919)

This is an existing program that manages embrittlement, cracking, melting, discoloration, swelling, or loss of dielectric strength leading to reduced insulation resistance in the aging of the non-EQ cables and connections used in sensitive instrumentation circuits with sensitive, high-voltage low-level signals within the Ex-Core Neutron Monitoring and Radiation Monitoring Systems. The program assures the intended functions of these sensitive, high-voltage, low-signal cables exposed to adverse localized environments caused by heat, radiation, and moisture can be maintained consistent with the current licensing basis through the PEO. The licensee has implemented change requests LDCR 19-F025 and LDCR 22-F007 to update UFSAR Chapter 19, for changes and updates within the scope of the aging management program calibration surveillance tests, specified in the implementing procedures, are used to manage the aging of the cable insulation and connections for non-EQ area radiation monitors so that instrumentation circuits perform their intended functions. When an instrumentation channel is found to be out of calibration during routine surveillance testing, troubleshooting is performed on the loop, including the instrumentation cable and connections. A review of calibration results and procedure enhancements will be completed prior to the PEO and every 10 years thereafter. This aging management program is closed.

Commitment 27 - The existing program is credited for license renewal, and prior to the PEO procedures will be enhanced to identify license renewal scope, require cable testing of non-EQ ex-core neutron monitoring cables, require an evaluation of the calibration results for non-EQ area radiation monitors, and require acceptance criteria for cable testing be established based on the type of cable and type of test performed.

The inspectors held discussions with the program owner, reviewed the aging management program basis document, implementing procedures, documentation of completed inspection activities as RCTSAI 3246919, corrective action program evaluation of related issues, UFSAR and commitment closure documents. The inspectors confirmed the licensee completed the required commitments and implemented the procedure enhancements associated with this program prior to the PEO. This commitment is closed.

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

(27) A1.26 13-LS-A126, Inaccessible Power Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, XI.E3 with Commitment 28 (RCTSAI 3246920)

This is an existing program, originally consistent with the GALL report, NUREG-1801, revision 1, and amended to reflect expansion of scope to include low voltage power cables above 400V as directed by the GALL report, revision 2. The program is credited with managing the aging effects of in-scope inaccessible power cables with operating voltage greater than or equal to 400V that have the potential to be exposed to moisture that lasts more than a few days. The program includes periodic inspection of manholes containing in-scope cables for water accumulation and removal of water as necessary.

Manhole inspection for water collection is performed at least annually and diagnostic testing of cables is performed at least every six years. Manholes are also inspected whenever more than 0.3 inches of rain falls within a 24-hour period. The implementing procedures for the program include 82DP-0EE01, Electrical Aging Management, and 91DP-0EN31-01 Management of Sumps and Manholes Administrative Guideline.

Program requirements were compared to those in the GALL report, NUREG-1801, revision 2, and the program scope amended to include low voltage power cables, address manhole inspection and cable testing criteria. This aging management program is closed.

Commitment 28 - The Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements program is credited for license renewal, and that prior to the PEO procedures will be enhanced to:

(1) extend the scope of the program to include low voltage (400V and above) non-EQ inaccessible power cables and associated manholes, and
(2) perform the cable manhole inspections for water collection and verify the cable support structures are intact on at least an annual frequency and perform the cable testing on at least a six-year frequency.

The inspectors performed walkdowns of selected in-scope manholes, reviewed the aging management program notebook, implementing procedures, plant drawings for manholes, completed program activities, and held discussions with the site program owner. Specifically, the inspectors reviewed completed work orders, Cable Testing and Manhole Inspection Results report APSROLI~00011-REPT-003, and corrective action documents. The licensee removed manhole inspection covers for visual inspections. The inspectors confirmed the licensee has implemented the requirements of this program prior to the PEO. This commitment is closed.

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

(28) A1.27 13-LS-A127, ASME Section XI, Subsection IWE, XI.S1 with Commitment 29 (RCTSAI 3246921)

This is an existing program that manages cracking, loss of material, loss of sealing, loss of preload, and loss of leak tightness by providing aging management of the steel liner of the concrete containment building, including the containment liner plate and its integral attachments, containment hatches and airlocks, and pressure-retaining bolting.

Subsection IWE inspections are performed to identify and manage any containment liner aging effects that could result in loss of intended function. The program is supplemented with the applicable requirements of 10 CFR 50.55a(b)(2)(ix). This aging management program is closed.

Commitment 29 - This existing program is credited for license renewal. The existing program has exceptions that are consistent with the program elements in GALL report aging management program XI.SI, ASME Section XI, Subsection IWE. The program manages loss of material and loss of sealing of the steel liner of the concrete containment building.

For the inspection interval from July 18, 2008 to July 17, 2018, for Unit 1; from March 18, 2007 to March 17, 2017, for Unit 2; and from January 11, 2008 to January 10, 2018, for Unit 3; PVNGS performs containment inservice inspections in accordance with the 2001 Edition of ASME Section XI, Subsection IWE, with the 2002 and 2003 addenda, supplemented with the applicable requirements of 10 CFR 50.55a(b)(2)(ix). The licensee will conduct inspections to identify and manage any containment liner degradation due to loss of material that could result in loss of intended function. Included in this inspection program are the containment liner plate and its integral attachments, such as piping and electrical penetrations, access hatches, the fuel transfer tube, and pressure-retaining bolting. The licensee uses a general visual examination to identify indications of degradation. All areas requiring augmented examination, per criteria IWE-1240 and IWE-2420, receive a detailed visual inspection and Article IWE-3000 specifies acceptance criteria for components subject to IWE exam requirements. This commitment is closed.

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

(29) A1.28 13-LS-A128, ASME Section XI, Subsection IWL, XI.S2 with Commitment 30 (RCTSAI 3246922)

This is an existing program that manages cracking, loss of bond and loss of material (spalling, scaling), increase in porosity and permeability (spalling, scaling), and cracking.

The licensee will perform periodic visual inspections of reinforced concrete and unbonded post-tensioning systems associated with the reactor containment building.

Inspection methods specified in IWL-2500 include visual examination supplemented by testing. The licensee tested the tendons for yield strength, ultimate tensile strength, and elongation in selected sample tendons. The licensee analyzed the tendon corrosion protection medium (grease) for alkalinity, water content, and soluble ion concentrations.

This aging management program is closed.

Commitment 30 - The existing ASME Section XI, Subsection IWL program is credited for license renewal. The existing program as consistent with the GALL report aging management program XI.S2, ASME Section XI, Subsection IWL. The program manages cracking, loss of material, and increase in porosity and permeability of the concrete containment building and post-tensioned system. Included in this inspection program are the concrete containment structure (includes all accessible areas of the concrete dome, cylinder walls, and buttresses) and the post-tensioning system (includes tendons, end anchorages, and concrete surfaces around the end anchorages). The applicant visually examines concrete surface areas for indications of distress or deterioration. It measures tendon prestress forces by lift-off and examines tendon wires for corrosion or mechanical damage.

For the inspection interval from August 1, 2001 to July 31, 2011, the applicant performed IWL inservice inspections in accordance with the 1992 Edition of ASME Section XI (with 1992 Addendum), Subsection IWL, supplemented with the applicable requirements of 10 CFR 50.55a(b)(2) and additional commitments. The licensee stated that the IWL inservice inspection program is consistent with the 2001 edition of ASME Section XI, Subsection IWL, including the 2002 and 2003 Addenda. In conformance with 10 CFR 50.55a(g)(4)(ii), the licensee updates the IWL inservice inspection program during each successive 120-month inspection interval to comply with the requirements of the latest edition of the Code, specified twelve months before the start of the inspection interval, as required by 10 CFR 50.55a(g)(4)(ii). This commitment is closed.

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

(30) A1.29 13-LS-A129, ASME Section XI, Subsection IWF, XI.S3 with Commitment 31 (RCTSAI 3246923)

This is an existing program that manages loss of material, cracking, fatigue, loss of preload, and loss of mechanical function. This program includes supports of Class 1, 2, and 3 components and subassemblies that include support members, structural bolting, high strength structural bolting, support anchorage to the building structure, accessible sliding surfaces, constant and variable load spring hangers, guides, stops, and vibration isolation elements. This aging management program is closed.

Commitment 31 - This is an existing program that is credited for license renewal. The program provides a systematic method for periodic non-destructive examination, visual examination and testing of systems, structures and components to ensure the integrity of component pressure boundaries and supports and is implemented by the Fourth Inspection Interval Inservice Inspection Program Summaries, 4-INTISI-1, 4INT-ISI-2, 4-INT-ISI-3 and the associated procedures, 73TI-9ZZ18, 73DP-0EE16, 73DP-9ZZ17, 30DP-9MP02, 73DP-9EE02, and 73DP-9XI03. The program includes support members, structural bolts, support anchorage, accessible sliding surfaces, spring hangers, guides, and stops.

There are no Class MC supports at PVNGS. The program is consistent with the GALL report aging management program XI.S3, ASME Section XI, Subsection IWF. The licensee stated that the program provides a systematic method for periodic non-destructive examination, visual examination, and testing of SSCs to ensure the integrity of component pressure boundaries and supports. The licensee stated that the program manages loss of material, cracking, and loss of mechanical function that could result in loss of intended function for Class 1, 2, and 3 component supports. In conformance with 10 CFR 50.55a(g)(4)(ii), the inservice inspection program is updated during each successive 120-month inspection interval to comply with the requirements of the latest edition of the ASME Code specified by 10 CFR 50.55a(g)(4)(ii). This commitment is closed.

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

(31) A1.30 13-LS-A130, 10 CFR 50, Appendix J, XI.S4 with Commitment 32 (RCTSAI 3246924)

This is an existing program that manages loss of material, loss of leak tightness, and loss of sealing. The program monitors leakage rates through the containment pressure boundary, including the penetrations and access openings in order to detect degradation of containment pressure boundary. Seals, gaskets, and bolted connections are also monitored under the program. Containment leak rate tests are performed to ensure that leakage through the primary containment, and systems and components penetrating primary containment, does not exceed allowable leakage limits specified in the technical specifications. Corrective actions are taken if leakage rates exceed established administrative limits for individual penetrations or the overall containment pressure boundary. The inspectors reviewed the procedures, records, and conducted discussions with licensee personnel. This aging management program is closed.

Commitment 32 - This existing program is credited for license renewal. The inspectors note this program was previously inspected on December 18, 2023 (ML23349079). The inspectors concluded the program will continue to effectively manage the effects of aging through the PEO. There were no items left open during the previous inspection. The inspectors reviewed completed work documents and periodic test results performed to ensure the Appendix J program continues to be implemented properly. The inspectors reviewed the procedures, records, and conducted discussions with licensee personnel and concluded the licensee met requirements. This commitment is closed.

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

(32) A1.31 13-LS-A131, Masonry Walls, XI.S5 with Commitment 33 (RCTSAI 3246926)

This is an existing program implemented as part of the Structures Monitoring program, that manages cracking, missing or broken locks, spalling and mortar deterioration of masonry walls. This program required no enhancements or exceptions and incorporates the guidance provided in Bulletin 80-11, Masonry Wall Design, and Information Notice 87-67, Lessons Learned from Regional Inspections of Licensee Actions in Response to NRC IE Bulletin 80-11. Prior to the PEO, the implementing procedures will be enhanced to specify American Concrete Institute (ACI) 349.3R-96 as the reference for qualification of personnel to inspect structures under the Masonry Walls program, which is part of the Structures Monitoring program. The program includes masonry walls in the auxiliary and turbine buildings that support safety-related piping or equipment, or whose failure could prevent a safety-related system from performing its safety function. The fire protection aging management program evaluates that fire protection function of masonry walls that are considered fire barriers. This aging management program is closed.

Commitment 33 - This existing Masonry Walls program is credited for license renewal and prior to the PEO, procedures will be enhanced to specify ACI 349.3R-96 as the reference for qualification of personnel to inspect structures under the Masonry Walls program, which is part of the Structures Monitoring program.

The inspectors reviewed the UFSAR supplement, the aging management program basis document, implementing procedures, work orders, and completed inspection results.

The inspectors interviewed the program owner and walked down selected masonry block walls in Units 1 and 3 turbine, control, and auxiliary buildings. The inspectors selected a sample of walls to confirm the licensee had appropriately reinforced the walls as required to withstand seismic and fire protection events for which they were designed.

The inspectors confirmed that the licensee had included specific masonry wall inspection acceptance criteria in procedure 81DP-0ZZ01, Civil, System, Structure and Component Monitoring Program, which has been revised to include ACI 349.3R-96 qualification criteria.

The inspectors observed that cracks in the masonry wall previously identified in prior Phase 1 license renewal program inspections were being addressed in condition report CR 24-11778, with action items to analyze the cracks and evaluate the structural integrity of the affected masonry walls. The licensee initiated condition report CR 25-02320 for the additional cracks identified during the walkdown of the Units 1 and 3 buildings for analysis and evaluation. The inspectors also reviewed RCTSAI for the program to verify the completion of actions on the commitment activities. The inspectors confirmed the licensee has implemented the requirements of this program prior to the PEO. This commitment is closed.

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

(33) A1.32 13-LS-A132, Structures Monitoring, XI.S6 with Commitment 34 (RCTSAI 3246927)

This is an existing program, originally implemented in response to 10 CFR 50.65 (Maintenance Rule), that manages cracking, loss of material, and change in material properties by monitoring the condition of structures and structural supports that are within the scope of license renewal. The program provides inspection guidelines and walkdown checklists for concrete elements, structural steel, masonry walls, treated wood, structural features (e.g., caulking, sealants, roofs, etc.), structural supports, and miscellaneous components such as doors. The program includes all masonry walls and water-control structures within the scope of license renewal and monitors settlement for each major structure and inspects the supports for equipment, piping, conduit, cable tray, HVAC, and instrument components. The scope of the Structures Monitoring program does not include the inspection of the supports specifically inspected per the requirements of the ASME Section XI Inservice Inspection program. Though coatings may have been applied to the external surfaces of structural members, no credit was taken for these coatings in the determination of aging effects for the underlying materials. The Structures Monitoring program evaluates the condition of the coatings as an indication of the condition of the underlying materials. This aging management program is closed.

Commitment 34 - This existing program is credited for license renewal, and prior to the PEO the Structures Monitoring program will be enhanced to specify ACI 349.3R-96 as the reference for qualification of personnel to inspect structures under the Structures Monitoring program. For structures within the scope of license renewal, the program will be enhanced to establish the frequency of inspection for each unit at a 5-year interval, with the exception of exterior surfaces of the following non-safety related structures, below-grade structures, and structures within a controlled interior environment, which will be inspected at an interval of 10 years:

  • fire pump house (yard structures)
  • radwaste building
  • station blackout generator structures
  • turbine building The program will be enhanced to quantify the acceptance criteria and critical parameters for monitoring degradation, and to provide guidance for identifying unacceptable conditions requiring further technical evaluation or corrective action. Procedures will also be enhanced to incorporate applicable industry codes, standards and guidelines (e.g.,

ACI 349.3R-96, ANSI/ASCE 11-90, etc.) for acceptance criteria.

The inspectors performed a system walkdown, reviewed the aging management program notebook, updated implementing procedures, gap analysis and completed program activities, and held discussions with the site program owner, and system engineer. The inspectors reviewed updated implementation procedures, completed inspections contained in the completed work orders and corrective action documents.

The primary implementing procedure for the Structures Monitoring program is procedure 81DP-0ZZ01, Civil System, Structure, and Component Monitoring Program. Additional implementing documents include procedures 70DP-0MR02, Maintenance Rule, 73ST-1/2/3ZZ12, Settlement Monitoring Program, 30DP-9MP02, Fastener Tightening /

Preload, 81DP-0EE10, Design Change Process, and equipment reliability engineering templates (ERETs) 3323328 and 3324300. These ERETs ensure that successive program inspections are conducted within the specified frequency. The inspectors observed that the external bus structural supports for the metal enclosed bus are to be monitored under the Structures Monitoring program, however, procedure 81DP-0ZZ01, Civil System, Structure, and Component Monitoring Program, has not included the specificity on how the monitoring of the bus external structural supports will be accomplished. The licensee established condition report CR 25-02206 to address this observation. This commitment is closed.

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

(34) A1.33 13-LS-A133, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, XI.S7 with Commitments 35 (RCTSAI 3246928) and 56 (RCTSAI 3484623)

This is an existing program that manages cracking, movement (e.g., settlement, heaving, deflection), loss of material, loss of form, loss of bond, loss of strength, and increase in porosity and permeability caused by extreme environmental conditions, and the effects of natural phenomena on water-control structures. Although not committed to Regulatory Guide 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, the program includes all structural components within the scope of license renewal addressed by the regulatory guides, as well as their attributes. The scope includes monitoring of structural steel and structural bolting associated with water-control structures, and miscellaneous steel (e.g., bar racks). The inspectors interviewed the program owner and reviewed the UFSAR supplement, implementing documents, condition reports, and specified procedures that included 70DP-0MR02, Maintenance Rule Monitoring Process, revision 1 and 81DP-0ZZ01, Civil System Structure, and Component Monitoring Program, revision 30. The inspectors also walked down areas of the units captured in the structure monitoring program to review the condition of structures and supports throughout the site. This aging management program is closed.

Commitment 35 - The existing program is credited for license renewal and prior to the PEO, procedures will be enhanced to specify that the essential spray ponds inspections include concrete below the water level. This commitment is closed.

Commitment 56 - The rework/repair of the spray pond walls above the waterline was completed by December 31, 2024. The inspectors interviewed the program owner and reviewed the UFSAR supplement, implementing documents, condition reports, and work order instructions related to spray pond wall repairs. The inspectors also walked down the essential spray pond walls after completion of the repairs. The inspectors concluded that the program would continue to effectively manage the effects of aging through the PEO and the licensee met the conditions of Commitment 56. This commitment is closed.

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

(35) A1.34 13-LS-A134, Nickel-Alloy Aging Management with Commitment 36 (RCTSAI 3260208/3246929)

This is an existing program that manages cracking due to PWSCC in all reactor coolant pressure boundary locations that contain Alloy 600, with the exception of SG tubing and reactor vessel internals. This aging management program is closed.

Commitment 36 - The existing nickel-alloy aging management program is credited for license renewal and manages cracking due to SCC in most components fabricated from alloy 600 (including alloy 82/182 weld metal) in the reactor coolant and engineering safety features systems. The program uses inspections, mitigation techniques, repair or replace activities and monitoring of operating experience to manage the aging of alloy 600.

The inspectors verified this aging management program commitment has already been inspected by an Inspection Procedure 71003 Phase 1 inspection (ML24345A055)conducted on December 11, 2024. The inspectors did not identify any findings or violations of more than minor significance for this aging management program during the 2024 inspection.

The inspectors reviewed the implementing procedures and the aging management program notebook, implementing work orders, and completed work orders, and then had discussions with the program owner to understand the actions taken. Based on review of the actions implemented related to the nickel-alloy aging management program, the inspectors concluded the program will continue to effectively manage the effects of aging through the PEO. This commitment is closed.

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

(36) A1.35 13-LS-A135, Insulation Material for Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, XI.E2 with Commitment 37 (RCTSAI 3246930 [Unit 1],

3247228 [Unit 2], 3247231 [Unit 3])

This is a new program that will manage the aging effects of the cables and connections used in instrumentation circuits with sensitive, high-voltage, low-level current signals within the nuclear instrumentation and radiation monitoring systems. This aging management program is closed.

Commitment 37 - This is a new program that will be implemented prior to the PEO.

Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

The inspectors reviewed the UFSAR supplement, work documents, the program evaluation report document, as well as revised procedure 82DP-0EE01, Electrical Aging Management, revision 7, which contained procedural steps on how to inspect these components to satisfy Commitment 37. The inspectors confirmed the licensee completed the required commitments and implemented the procedure enhancements associated with this program prior to the PEO. This commitment is closed.

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

(37) A1.313-LS-A136, Metal Enclosed Bus - B2.1.36, NUREG 1801 Program, XI.E4 with Commitment 38 (RCTSAIs 3246932 [Unit 1]; 3247220 [Unit 2]; 3247221 [Unit 3])

This is a new program for metal enclosed bus (MEB) that manages the effects of loose connections, embrittlement, cracking, melting, swelling, chipping or discoloration of insulation, loss of material of bus enclosure assemblies, hardening of boots, gaskets, and sealants, and cracking of internal bus supports to ensure that MEBs within the scope of license renewal are capable of performing their intended function. The MEBs within the scope of this program are those used during station blackout recovery. This aging management program is closed.

Commitment 38 - This new program will be completed before the PEO and once every 10 years thereafter. Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

The inspectors reviewed the UFSAR supplement, work documents, the program evaluation report document, as well as revised procedure 82DP-0EE01, Electrical Aging Management, revision 7, which contained procedural steps on how to inspect MEB sections to satisfy Commitment 38. The inspectors reviewed RCTSAIs 3246932 (Unit 1),3247220 (Unit 2), and 3247221 (Unit 3) to ensure completion of action items associated with MEB for all the units. Additionally, the inspectors reviewed condition reports, work orders and data from the inspections. The inspectors verified that inconsistencies in procedure for MEB inspection, identified during the previous license renewal inspection were documented in condition reports, CR 24-11612 & 24-11613 for evaluation and resolution.

The inspectors observed that the metal enclosed bus work instructions for inspections need to clarify the acceptance criteria for the contact resistance measured during the cleaning and inspection of MEBs within the scope of the license renewal. The licensee documented this issue in condition report CR 25-02960.

The inspectors confirmed the licensee completed the required commitments and implemented the procedure enhancements associated with this program prior to the PEO. This commitment is closed.

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

(38)13-LS-A137, Fuse Holders with Commitment 50 (RCTSAI 3409443)

This is a new program that manages fatigue aging mechanisms and increased resistance of connection of fuse holders to ensure that fuse holders within the scope of license renewal can perform their intended function. Specific fatigue aging mechanisms managed include thermal cycling, ohmic heating, electrical transients, mechanical fatigue, frequent manipulation, and vibration. Specific increased resistance of connection aging mechanisms includes chemical contamination, corrosion, and oxidation. The fuses within the scope of license renewal are not frequently removed or replaced and located outside of active devices in circuits that perform a license renewal intended function.

This aging management program is closed.

Commitment 50 - The Fuse Holders program is a new program that will be implemented prior to the PEO and once every 10 years thereafter. Industry and plant-specific operating experience will be evaluated in the development and implementation of this program.

The licensee conducted thermography as the test method for the Fuse Holders program, to ensure the fuse holder clip connections did not exhibit indications of loose, relaxed, or corroded connections by unacceptable temperature measurements. To ensure acceptable connection integrity and testing at normal or full load condition, the thermography images are conducted and coordinated with the annual 8-hour fire protection emergency lighting tests. The acceptance criteria for thermography are based on the rise above reference temperature. The testing is performed at least once every 10 years during the PEO with the first tests completed prior to the PEO (pre-PEO). The 10-year inspection interval provides two data points during a 20-year period, which characterizes the degradation rate. In reviewing the results of the thermography infrared scan, the inspectors observed that the acceptance criteria for thermography were based on the rise above reference temperature. However, the thermography scan reports did not specify the reference temperature, as specified in procedure 37TI-9ZZ01, section 4.5.6, for determining the heat rise above reference. The licensee issued condition report CR 25-02996 to evaluate and correct this condition.

The inspectors reviewed the UFSAR supplement, the aging management program basis document, implementing procedures, work orders, corrective actions and completed inspection results and held discussions with the program owner. The inspectors also reviewed RCTSAI 3409443 to verify the completed actions on the commitment activities.

The inspectors confirmed that the licensee implemented the requirements of this program prior to the PEO. This commitment is closed.

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

(39)13-LS-A201, TLAA - Metal Fatigue Reactor Coolant Pressure Boundary, X.M1 with Commitments 55, (RCTSAI 3469024), 57, (RCTSAI 3488220), 58, (RCTSAI 3488223),60, (RCTSAI 3531679), and 63, (RCTSAI 3563689)

This is an existing program, enhanced for license renewal, that manages fatigue usage caused by anticipated cyclic strains. The program criteria ensure fatigue usage remains within allowable limits for components of the reactor coolant system. This aging management program is closed.

Commitment 55 - The transient Standby to SI hot leg injection check valve stroke test to standby (using the HPSI pump), will be added to the cycle-counting surveillance procedure 73ST-9RC02 by August 25, 2010, and that the transient cycle-counting procedure would be updated to include Transient 25 (license renewal amendment LRA Table 4.3-3).

The inspectors verified that cycle-counting surveillance procedure was updated to include Transient 25 via Amendment 14 dated April 28, 2010, and the licensees enhanced metal fatigue program will monitor this transient during the PEO to ensure that it does not exceed the design limit. This commitment is closed.

Commitment 57 - No later than two years prior to the PEO, PVNGS will confirm the conservatism of the Fen (fatigue environmental) value of 1.49 using the methods specified in NUREG/CR-6909 and will use the Fen calculated using the NUREG/CR-6909 methods if it is more conservative than the 1.49 value. This commitment is closed.

Commitment 58 - No later than two years prior to the PEO, PVNGS will perform a reanalysis of the pressurizer heater penetrations to consider environmentally assisted fatigue (EAF) effects using the formulas and methodology given in NUREG/CR-6909.

This commitment is closed.

Commitment 60 - The reactor coolant system transient and cycle tracking procedure (73ST-9RC02) and UFSAR Section 3.9.1 will be enhanced to discuss corrective actions that need to be taken prior to ASME Section III fatigue design limits being exceeded and to state that corrective actions may be required for other fatigue-related analyses, such as certain ASME Section XI supplemental fatigue flaw growth or cycle-dependent fracture mechanics evaluations that are dependent on the number of occurrences of design transients. This commitment is closed.

Commitment 63 - No later than two years prior to the PEO, PVNGS will confirm that the plant-specific components listed in LRA Table 4.3-11 (except the pressurizer surge line pressurizer elbow) are bounding for the generic NUREG/CR-6260 locations and the additional location (pressurizer heater penetrations). If locations are found that are not bounded by the Table 4.3-11 components, PVNGS will perform new analyses as necessary to bound such locations and no later than two years prior to the PEO, PVNGS will confirm that Table 4.3-11 locations selected for EAF analyses consist of the most limiting cumulative usage factor (CUF) locations for the plant (beyond the generic EAF locations identified in the NUREG/CR-6260 guidance). If the Table 4.3-11 locations are not bounding, PVNGS will perform an EAF analysis for the additional CUF locations not bounded by the Table 4.3-11 locations. If the component with the most limiting CUF is composed of nickel-alloy, the methodology used to perform the EAF calculation for nickel-alloy will be consistent with NUREG/CR-6909. This commitment is closed.

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

(40)13-LS-A202, TLAA - Environmental Qualification (EQ) of Electrical Components, X.E1 with Commitment 40 (RCTSAI 3246935)

This is an existing program that manages the effects of aging of EQ equipment, such that the components maintain their intended function(s) for the PEO. Environmental qualification components not qualified for the current license term must be replaced or requalified before reaching their aging limits. Reanalysis is an acceptable method to extend the qualified life of an EQ component and involves analytical methods, data collection, assumptions, acceptance criteria, and corrective actions. This aging management program is closed.

Commitment 40 - The existing program is credited for license renewal and maintaining qualification through the extended license renewal period requires that existing EQ evaluations be re-evaluated.

The inspectors verified that procedure 88DP-0EQ01, Environmental Qualification Program, was updated to address aging management as applicable to PVNGS. The inspectors verified that reanalysis of aging evaluations to extend the qualifications of components was performed and all components that were required to be replaced before the PEO have already been replaced. The inspectors reviewed the components that are required to be replaced before the 60-year date and verified there was a replacement schedule planned. The inspectors reviewed the plant qualification evaluations and did not identify any concerns. The inspectors reviewed the corrective action program for this commitment and determined the licensee dispositioned their results. This commitment is closed.

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

(41)13-LS-A203, TLAA - Concrete Containment Tendon Prestress, X.S1 with Commitments 41 (RCTSAI 3246937) and 53 (RCTSAI 3429933).

This is an existing program, within the ASME Section XI Subsection IWL program, that manages the loss of tendon prestress aging effect in the post-tensioning system and is consistent with supplemental requirements of 10 CFR 50.55a. The post-tensioning system consists of inverted-U-shaped vertical tendons, extending up through the basemat, through the full height of the cylindrical walls and over the dome, and horizontal circumferential (hoop) tendons, at intervals from the basemat to about the 45-degree elevation of the dome. The basemat is conventionally reinforced. The tendons are ungrouted, in grease-filled glands. The design basis of the containment system requires that the average prestresses of the tendons in the horizontal dome and cylinder hoop tendon subgroups, and in the vertical tendon group, remain above their respective minimum required values. The minimum required values are from the original design bases and assumptions. In order to ensure that the design basis continues to be met, the acceptance criteria require that the prestress in each tendon remains above, or within a stated tolerance below the predicted lower limit. The predicted lower limit described in NUREG-1801 is functionally equivalent to the first action level of the PVNGS and IWL 3221.1 acceptance criteria, at 95 percent of the predicted force line.

This program, as enhanced by Commitment 41, manages loss of tendon prestress for the extended licensed operating period for Units 1, 2, and 3. It is implemented via the ASME Section XI Subsection IWL 3rd Inspection Interval Program Plan (3INTIWL-13)which describes the IWL program and addresses the third interval, first 5-year and second 5-year containment inservice inspections. It also contains the scheduling and scope selection requirements for this commitment. Unit-specific surveillance procedures (73ST-1(2/3)ZC01) provide detailed instructions for completing the inspections. These procedures compare regression analysis trend lines of the individual lift-off values of tendons surveyed to date, in each of the vertical and hoop tendon groups, with the minimum required value and predicted lower limit for each tendon group, to the end of the licensed operating period. Appropriate corrective actions are required if future values indicated by the regression analysis trend line drop below the predicted lower limit or minimum required value. The regression analyses are updated for tendons of the affected unit and for a combined dataset of all three units following each inspection of an individual unit. The program also defines specific action levels for additional inspections and corrective actions and specifies acceptance criteria for additional inspections and corrected conditions. This aging management program is closed.

Commitment 41 - The existing program is credited for license renewal. The program was enhanced to continue to compare regression analysis trend lines of the individual lift-off values of tendons surveyed to date, in each of the vertical and hoop tendon groups, with the minimum required value and predicted lower limit for each tendon group, to the end of the licensed operating period, and to take appropriate corrective actions if future values indicated by the regression analysis trend line drop below the predicted lower limit or minimum required value. The regression analyses will be updated for tendons of the affected unit and for a combined dataset of all three units following each inspection of an individual unit. Prior to the PEO, procedures will be enhanced to require an update of the regression analysis for each tendon group of each unit, and of the joint regression of data from all three units, after every tendon surveillance. The documents invoke and describe regression analysis methods used to construct the lift-off trend lines, including the use of individual tendon data in accordance with Information Notice (IN) 99-10, Degradation of Prestressing Tendon Systems in Prestressed Concrete Containments.

The tendon integrity test procedure was revised to extend the list of surveillance tendons to include random samples for the year 45 and 55 surveillances. This commitment is closed.

Commitment 53 - This commitment was added to reflect the results of the Unit 1 25-year tendon surveillance data regression analysis, which were submitted to the NRC in a license renewal amendment on May 28, 2010. Commitment 53 was a standalone commitment to implement changes to LRA Table 4.5-1. The commitment was added via Amendment 13 and was implemented/completed via Amendment 15. This commitment is closed.

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

(42) Commitment 1 (RCTSAI 3247244) UFSAR Updates Commitment 1 was implemented by incorporating the summary descriptions of aging management programs, time-limited aging analyses, and license renewal commitments contained in LRA Appendix A, Updated Final Safety Analysis Supplement, as required by 10 CFR 54.21(d), into Revision 16A of the UFSAR for PVNGS Units 1, 2, and 3 in the update required by 10 CFR 50.71(e) following the issuance of the renewed operating licenses. This commitment is closed.

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

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

  • On March 21, 2025, the inspectors presented the NRC inspection results to R. Meeden, Vice President, Nuclear Engineering and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Corrective Action

Documents

CR

25-02442, 12-00473, 13-00736, 16-02355, 17-01704, 15-

11492, 17-03201, 18-13238, 19-11147, 22-11147, 24-

04007, 21-08451, 21-000021, 21-12001, 21-12978, 22-

04313, 22-04314, 22-00493, 23-09402, 25-02423, 20-

06726, 21-02586, 21-13945, 22-03984, 22-039612, 23-

08766, 23-08848, 24-01907, 24-01908, 24-02545, 24-

2546, 25-01787, 25-01790, 20-11819, 20-11810, 20-

11823, 20-11811, 20-11813, 20-11975, 20-12393, 21-

07963, 21-07965, 21-10813, 21-13755, 21-14546, 22-

01575, 22-01732, 22-01735, 22-03498, 22-03649, 22-

05303, 22-06821, 23-02992, 23-02996, 23-02994, 23-

09114, 23-09597, 23-10709, 23-10887, 23-11131, 23-

11132, 23-11709, 23-11710, 23-11711, 23-11712, 23-

11713, 23-11717, 24-00969, 24-00971, 24-01238, 24-

01590, 24-02292, 24-02402, 24-02407, 24-02405, 24-

2411, 24-02412, 24-02415, 24-02418, 24-02398, 24-

2406, 24-02404, 24-02413, 24-02395, 24-02396, 24-

2401, 24-02397, 24-02417, 24-05178, 24-06506, 24-

06499, 24-06502, 24-06504, 24-06500, 24-06503, 24-

06501, 24-06683, 24-06694, 24-06696, 24-06695, 24-

06692, 24-06697, 24-06686, 24-06685, 24-07280, 24-

07655, 24-08205, 24-08204, 24-08201, 24-08202, 24-

09136, 24-09144, 24-09137, 24-09141, 24-09143, 24-

09146, 24-09139, 24-09278, 24-09280, 24-09256, 24-

263, 24-09270, 24-09271, 24-09262, 24-09264, 24-

265, 24-09268, 24-09273, 24-09277, 24-09435, 24-

09438, 24-09436, 24-11075, 24-11980, 24-11983, 24-

11982, 24-13471, 25-01187, 25-01189, 24-10707, 24-

01786, 25-02935, 22-10069, 20-06994, 20-12794, 23-

10585, 24-08223, 23-11175, 23-02750, 22-05530, 21-

03854, 21-03854, 22-10089, 23-03095, 23-01816, 22-

2680, 23-09807, 22-07432, 22-05530, 22-09356, 22-

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

08840, 22-08676, 22-08123, 23-07985, 23-07986, 23-

08409, 17-08117, 19-13211, 21-06707, 22-05873, 23-

05324, 23-13139, 24-09001, 24-12408, 24-00360, 25-

2386, 23-10254, 24-11612, 19-02451, 25-01050, 24-

11613, 24-11614, 24-11778, 24-13431, 21-09827, 18-

264, 14-01510

71003

Corrective Action

Documents

Resulting from

Inspection

CR

25-02206, 25-02254, 25-02260, 25-02289, 25-02289, 25-

296, 25-02302, 25-02303, 25-02304 25-02307, 25-

2308, 25-02310, 25-02311, 25-02312, 25-02317, 25-

2318,

25-02319, 25-02320, 25-02321 25-02322, 25-02323, 25-

2326, 25-02328, 25-02330, 25-02333, 25-02334, 25-

2336, 25-02337, 25-02338, 25-02343, 25-02348, 25-

2358,

25-02359, 25-02361, 25-02367, 25-02379, 25-02386, 25-

2389, 25-02390, 25-02391, 25-02392, 25-02405, 25-

2423, 25-02429, 25-02442, 25-02445, 25-02504, 25-

2553, 25-02564, 25-02620, 25-02741, 25-02913, 25-

2935, 25-02960, 25-02972, 25-02994, 25-02996

71003

Drawings

13-E-ZYP-

015

Non-Segregated Bus Arrangement Plan & Sections (Unit 3,

Train B) Sht. 6

006

71003

Drawings

13-E-ZYP-

015

Non-Segregated Bus Arrangement Plan & Sections (Unit 3,

Train A) Sht 5

006

71003

Drawings

01-E-QBA-001

Single Line Diagram Essential Lighting System Lighting

Panels

006

71003

Drawings

01-E-SEB-001

Elementary Diagram Ex-Core Neutron Monitoring System

Cabling Block Diagram

010

71003

Drawings

13-E-ZVU-0006,

Sht. 1 of 3

Underground Electrical Duct Layout Plot Plan Sheet 1

ZV06

039

71003

Drawings

13-E-ZVU-0006,

Underground Electrical Duct Sections & Details ZV06

039

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Sht. 2 of 3

71003

Drawings

13-E-ZVU-0006,

Sht. 3 of 3

Underground Electrical Duct Layout Plot Plan ZV06

039

71003

Drawings

13-E-ZVU-0007,

Sht. 1 of 3

Underground Electrical Duct Layout Plot Plan Sht. 2 ZV07

044

71003

Drawings

13-E-ZVU-0007,

Sht. 2 of 3

Underground Electrical Duct Sections & Details ZV07

044

71003

Drawings

13-E-ZVU-0007,

Sht. 3 of 3

Underground Electrical Duct Sections & Details ZV07

044

71003

Drawings

13-E-ZVU-0008,

sht. 1 of 7

Underground Electrical Duct Layout Plot Plan sht. 3 ZV08

044

71003

Drawings

13-E-ZVU-0008,

Sht. 2

Underground Electrical Duct Sections & Details ZV08

044

71003

Drawings

13-E-ZVU-0008,

Sht. 3

Underground Electrical Duct Sections & Details ZV08

044

71003

Drawings

13-E-ZVU-0008,

Sht. 4

Underground Electrical Duct Sections & Details ZV08

044

71003

Drawings

13-E-ZVU-0008,

sht. 5

Underground Electrical Duct Sections & Details ZV08

044

71003

Drawings

13-E-ZVU-0008,

Sht. 6

Underground Electrical Duct Sections & Details ZV08

044

71003

Drawings

13-E-ZVU-0008,

Sht. 7

Underground Electrical Duct Sections & Details ZV08

044

71003

Drawings

13-E-ZVU-0009,

Sht. 1 of 2

Underground Electrical Duct Sections & Details sheet 4

ZV09

25

71003

Drawings

13-E-ZVU-0009,

Sht. 2 of 2

Underground Electrical Duct Sections & Details sheet 4

ZV09

25

71003

Drawings

13-E-ZVU-0011,

Sht. 1

Underground Electrical Duct Layout Plot Plan Sheet 6

ZV11

27

71003

Drawings

13-E-ZVU-0011,

Sht. 2

Underground Electrical Duct Layout Plot Plan Sheet 6

ZV11

27

71003

Drawings

13-E-ZVU-0011,

Sht. 3

Underground Electrical Duct Layout Plot Plan Sheet 6

ZV11

27

71003

Drawings

13-E-ZVU-0011,

Station Blackout Gas Turbine Generators Exposed Conduit

27

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

sht. 4

Plan

71003

Drawings

13-E-ZVU-0012

Underground Electrical Duct Layout Plot Plan Sheet 7

ZV12

018

71003

Drawings

13-E-ZYP-015

Non-Segregated Bus Arrangement Plan & Sections (Unit 1,

Train A) Sht 1 of 6

006

71003

Drawings

13-E-ZYP-015

Non-Segregated Bus Arrangement Plan & Sections (Unit 2,

Train B) Sht 4

006

71003

Drawings

13-E-ZYP-015

Non-Segregated Bus Arrangement Plan & Sections (Unit 2,

Train A) Sht 3

006

71003

Drawings

13-E-ZYP-015

Non-Segregated Bus Arrangement Plan & Sections (Unit 1,

Train B) Sht 2 of 6

006

71003

Drawings

13-E-ZYU-0002

Transformer Yard Conduit Plan

008

71003

Drawings

13-N001-1304-

00154

13-N001-1304-00154 Ex-core Containment Cabling

Diagram

20

71003

Drawings

E015-00025

Expansion Joint & 3 HR Fire Stop Run 10A & Run No. 12

006

71003

Drawings

E015-00039

Expansion Joint & 3 HR Fire Stop Run 11

004

71003

Drawings

E015-00041-10A

5KV, 1200 Amp, 3PH, 3W, Bar Type Tot. Enc. Bus Duct

003

71003

Drawings

EN1009-A00007

1EPBAS03 Layout Unit 1 Train A (S03) Installation Layout.

001

71003

Drawings

EN1009-A00030

1EPBBS04 Layout 4KV Flex Diesel Generator Connection

to PB Switchgear-Unit 1 Train B (S04) Installation Layout

001

71003

Drawings

EN1009-A00076

3EPBAS03 Layout 4kV Flex Diesel Generator Connection

to PB Switchgear: Unit 3 Train A (S03) Installation Layout

2

71003

Drawings

EN1009-A00077

3EPBBS04 Layout 4kV Flex Diesel Generator Connection

to PB Switchgear Unit 3 Train B (S04) Installation Layout

2

71003

Drawings

EN1009-A00100

2EPBAS03 Layout 4 kV FLEX Diesel Generator

Connection to PB Switchgear: Unit 2 A Train (S03)

Installation Layout

003

71003

Drawings

EN1009-A00101

2EPBBS04 Layout 4 kV FLEX Diesel Generator

Connection to PB Switchgear-Unit 2 B Train (S04)

Installation Layout

004

71003

Drawings

M105-00023

DIESEL FUEL OIL STORAGE TANK

71003

Engineering

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Evaluations

71003

Engineering

Evaluations

13-CS-A032

Engineering Study Buried Piping and Tanks Program

Inspection Plan

Rev 5

71003

Engineering

Evaluations

13-LS-A118

PVNGS Aging Management Program Evaluation Report -

Buried Piping and Tanks Inspection - B2.1.18, NUREG

1801 Program XI.M34

Rev 11

71003

Engineering

Evaluations

13-LS-A134

PVNGS Aging Management Program Evaluation Report -

Nickel-Alloy Aging Management - B2.1.34, PSNI

004

71003

Engineering

Evaluations

23-10254-010

Unit 1 Pressurizer Thermowell Nozzle Leak - Level 1 SCAQ

Root Cause Analysis Report

5/31/2024

71003

Engineering

Evaluations

23-10254-028

Engineering Justification for Circumferential Crack of 1J-

RCE-TW-101

11/8/2024

71003

Engineering

Evaluations

4INT-INCO-06

PVNGS Alloy 600 Management

Program Plan

2

71003

Engineering

Evaluations

4INT-ISI-1, 4INT-

ISI-2, 4INT-ISI-3

4th Inspection interval Inservice Inspection Program

Summary Manual

2, 003,

003

71003

Engineering

Evaluations

APSROLI-00011

REPT-005

Fuse Holder Program [NUREG-1801 Program XI.E5] Pre-

PEO XI.E5 Credited Fuse Holder Tests

000

71003

Engineering

Evaluations

APSROLI-00011-

REPT-001

License Renewal Pre-PEO GALL XI.E1 Walkdown Results

Report Adverse Localized Environments (ALEs) Affecting

Insulated Cables and Connections

2

71003

Engineering

Evaluations

APSROLI-00011-

REPT-006

Non-EQ Cable Connections Program [NUREG-1801

Program XI.E6] Sample Plan Review & One-time

Inspection Results Summary

001

71003

Engineering

Evaluations

APSROLI-00012-

REPT-001

10CFR 54.37(b) Reviews from August 2017 to December

20 for Palo Verde Generating Station

000

71003

Engineering

Evaluations

APSROLI~00011-

REPT-002

NUREG-1801 Program XI.E2 Pre-PEO Cable Calibration

Surveillance Test Reviews and Cable Tests

001

71003

Engineering

Evaluations

APSROLI~00011-

REPT-003

Inaccessible Power Cables Program [NUREG-1801

Program XI.E3] Pre-PEO Cable Testing and Manhole

Inspections

2

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Engineering

Evaluations

APSROLI~00020-

REPT-001

Internal Surface Sample Plan CR AI 23-10445-005

000

71003

Engineering

Evaluations

APSROLI00020-

REPT-006

PVNGS New Periodic Inspections for

Selective Leaching Program

000

71003

Engineering

Evaluations

ASPROLI-00011-

REPT-010

One-Time Inspection of ASME Code Class 1 Small-Bore

Piping Program [NUREG-1801 Program XI.M35]

000

71003

Engineering

Evaluations

COR 24-9-007

Component Observation Report for Fire Pump House -

Concrete, Masonry Walls, Structural Steel/Miscellaneous

Steel, Fasteners.

2/05/2024

71003

Engineering

Evaluations

LR-ISG-2012-02

License Renewal Interim Staff Guidance

000

71003

Engineering

Evaluations

RP3-74ST-9SQ22

Surveillance Test Package Review Sheet for RP3 - 74ST-

9SQ22-STWO4822962-Unit1RU31

1/12/2018

71003

Engineering

Evaluations

Rpt. 24-11778-003

Level 3 Evaluation Report 24-11778-003 to evaluate

Cracks identified at the Pump House masonry wall during

the walkdown for License Renewal Masonry Wall Aging

Management Program inspection

11/14/2024

71003

Miscellaneous

Maintenance Rule Systems List

3/12/2025

71003

Miscellaneous

Evaluation of recommended changes to Aging

Management Program XI.M34, Buried Piping and Tanks

Inspection, based on LR-ISG-2015-01

11/9/2022

71003

Miscellaneous

Presentation

Presentation on Structures Monitoring (SMP) Aging

Management Program by Derek Morris

1/30/2025

71003

Miscellaneous

MR SSC Scoping For the System QH (Cathodic Protection

System)

11/19/2010

71003

Miscellaneous

Cathodic Protection Health Report

5/14/2025

71003

Miscellaneous

13-LS-A101

PVNGS Aging Management Program Evaluation Report -

ASME Section XI Inservice Inspection, Subsections IWB,

IWC, and IWD - B2.1.1, NUREG 1801 Program XI.M1

71003

Miscellaneous

13-LS-A104

PVNGS Aging Management Program Evaluation Report -

Boric Acid Corrosion - B2.1.4, NUREG 1801 Program

XI.M10

71003

Miscellaneous

13-LS-A105

Cracking of Nickel-Alloy Components and Loss of Material

Due to Boric Acid-Induced Corrosion in Reactor Coolant

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Pressure Boundary Components XI.M11A

71003

Miscellaneous

13-LS-A108

Steam Generators XI.M19

71003

Miscellaneous

13-LS-A125

Insulation Material for Electrical Cables and Connections

Not Subject to 10 CFR 50.49 EQ used in Instrumentation

Circuits

003

71003

Miscellaneous

13-LS-A126

Inaccessible Power Cables Not Subject to 10 CFR 50.49

EQ Requirements

000

71003

Miscellaneous

13-LS-A127

ASME Section XI Subsection IWE - B2.1.27, NUREG 1801

Program XI.S1

71003

Miscellaneous

13-LS-A128

ASME Section XI, Subsection IWL, XI.S2

71003

Miscellaneous

13-LS-A129

ASME Section XI, Subsection IWF XI.S3

71003

Miscellaneous

13-LS-A135

Electrical Cable Connections Not Subject to 10 CFR 50.49

Environmental Qualification Requirements - B2.1.35,

NUREG 1801 Program XI.E6

2

71003

Miscellaneous

13-LS-A136

PVNGS Aging Management Program Evaluation Report -

Aging Management Program for Metal Enclosed Bus -

B2.1.36, NUREG 1801 Program XI.E4

2

71003

Miscellaneous

13-LS-A137

Aging Management Program for Fuse Holders - B2.1.37,

NUREG 1801 Program XI.E5

2

71003

Miscellaneous

13-LS-A201

TLAA - Metal Fatigue Reactor Coolant Pressure Boundary

X.M1

71003

Miscellaneous

13-LS-A203

TLAA - Concrete Containment Tendon Prestress X.S1

71003

Miscellaneous

13-MC-HC-0001

Containment Building - Normal Heat Load Calculation

004

71003

Miscellaneous

20553A-14

Framatome Vendor certifications

10/11, 14, &

20/2023

71003

Miscellaneous

41NT-INCO-06

Units 1, 2 & 3 Alloy 600 Management Program Plan

Rev 2

71003

Miscellaneous

500660043

Executive Summary for Palo Verde Generating Station's

24 Cathodic Protection System Survey

71003

Miscellaneous

65DP-0QQ01

Industry Operating Experience Review

045

71003

Miscellaneous

70DP-9SP01

Spray Pond Piping Integrity Verification

009

71003

Miscellaneous

73DP-9ZZ21

Heat Exchanger Visual Inspection

71003

Miscellaneous

73ST-2ZC01

WO 4946644 grease test results pages

71003

Miscellaneous

AIM 240211391-

2Q-1

Palo Verde Generating Station U3R24 Steam Generator

Condition Monitoring Evaluation (April 2024 Outage)

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Miscellaneous

AIM2402113912Q2

Operational Assessment for PVNGS Unit 3 Steam

Generators, Cycles 25/26/27, Based on Eddy Current

Examination at U3R24, April 2024

04/2024

71003

Miscellaneous

Commitment #21

RCTSAI 3246901 One-Time Inspection of ASME Code

Class 1 Small-Bore Piping

000

71003

Miscellaneous

Commitment #1

RCTSAI 3247244 UFSAR Updates

71003

Miscellaneous

Commitment #11

RCTSAI 3246898 Open-Cycle Cooling Water System

Program (XI.M20)

71003

Miscellaneous

Commitment #12

RCTSAI 3246899 Closed-Cycle Cooling Water System

Program (XI.M21A)

71003

Miscellaneous

Commitment #13

RCTSAI 3246900 Inspection of Overhead Heavy Load and

Light Load (Related to Refueling) Handling Systems

Program (XI.M23)

71003

Miscellaneous

Commitment #15

RCTSAI 3246902 Fire Water System Program (XI.M27)

000

71003

Miscellaneous

Commitment #2

RCTSAI 3246887 Quality Assurance Program

71003

Miscellaneous

Commitment #22

External Surfaces Monitoring Program (XI.M36)

000

71003

Miscellaneous

Commitment #29

RCTSAI 3246921 ASME Section XI Inservice Inspection,

Subsection IWE Program (XI.S1)

71003

Miscellaneous

Commitment #3

RCTSAI 3246890 ASME Section XI Inservice Inspection,

Subsections IWB, IWC, and IWD Program (XI.M1)

71003

Miscellaneous

Commitment #30

RCTSAI 3246922 ASME Section XI Inservice Inspection,

Subsection IWL Program (XI.S2)

71003

Miscellaneous

Commitment #31

RCTSAI 3246923 ASME Section XI Inservice Inspection,

Subsection IWF Program (XI.S3)

71003

Miscellaneous

Commitment #32

RCTSAI 3246924 10 CFR 50, Appendix J Program (XI.S4)

000

71003

Miscellaneous

Commitment #39

RCTSAI 3246934 Metal Fatigue of Reactor Coolant

Pressure Boundary Program (X.M1)

71003

Miscellaneous

Commitment #4

RCTSAI 3246891 Water Chemistry Program (XI.M2)

71003

Miscellaneous

Commitment #41

RCTSAI 3246937 Concrete Containment Tendon Prestress

Program (X.S1)

71003

Miscellaneous

Commitment #5

RCTSAI 3246892 Reactor Head Closure Studs Program

(XI.M3)

71003

Miscellaneous

Commitment #53

RCTSAI 3429933 Tendon Survey Data Regression

Analysis

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Miscellaneous

Commitment #6

RCTSAI 3246893 Boric Acid Corrosion Program (XI.M10)

71003

Miscellaneous

Commitment #7

RCTSAI 3246894 Nickel-Alloy Penetration Nozzles Welded

to the Upper Reactor Vessel Closure Heads of Pressurized

Water Reactors Program (XI.M11A)

71003

Miscellaneous

Commitment #8

RCTSAI 3246895 Flow-Accelerated Corrosion Program

(XI.M17)

71003

Miscellaneous

Commitment #9

RCTSAI 3246896 Bolting Integrity Program (XI.M18)

71003

Miscellaneous

Commitment #10

RCTSAI 3246897 Steam Generator Tube Integrity Program

(XI.M19)

71003

Miscellaneous

Commitment #11

RCTSAI 3246898 Open-Cycle Cooling Water System

Program (XI.M20)

000

71003

Miscellaneous

Commitment #13

RCTSAI 3246900 Inspection of Overhead Heavy Load and

Light Load (Related to Refueling) Handling Systems

Program (XI.M23)

000

71003

Miscellaneous

EEQ-E159-001

Electrical Equipment Qualification Data File (EEQDF) EEQ-

E159-001, Revision 11, QualTech NP/EGS Grayboot A

Series Electrical Connectors

011

71003

Miscellaneous

EPID L-2020-LLR-

0145

Palo Verde Nuclear Generating Station, Unit 2 - Relief

Request 66 To Defer Inservice Inspection Of Containment

Tendon By 1 Year Due To The COVID-19 Pandemic

001

71003

Miscellaneous

EPID L-2021-LLR-

0050

Palo Verde Nuclear Generating Station Units 1, 2, And 3 -

Relief Request 67 For An Alternate Frequency To

Containment Unbonded Post-Tensioning System Inservice

Inspection

000

71003

Miscellaneous

EPID L-2022-LLR-

0011

Palo Verde Nuclear Generating Station, Unit 2-Relief

Request 69 To Extend Inservice Inspection Of Containment

Tendon By 4 Months Due To The COVID-19 Pandemic

000

71003

Miscellaneous

EQDF EEQ-D089-

001

EQ package for Transamerica Delaval, Inc. Gems Sensor

Division Liquid Level Transmitter

21

71003

Miscellaneous

ERET 3324300

Equipment Vaults Identified as Important To Plant

006

71003

Miscellaneous

ERET 2949005

Scheduling document for Fuse Holder Thermography

10/12/2023

71003

Miscellaneous

ERET 2983269

Calibrate Instrument 18 M-12 Week

11/21/2024

71003

Miscellaneous

ERET 3323328

QAG Missile Shield Doors - Security

2

71003

Miscellaneous

ERET 3814488

Med/Low Voltage Cable Test

2

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Miscellaneous

Heat Exchanger

Program

73DP-9ZZ11

018

71003

Miscellaneous

IMS 1071

A136 - Metal Enclosed Bus, Commitment #38

N/A

71003

Miscellaneous

IMS 1085

Response to the question concerning the braided

connections - how often inspected, how often replaced?

N/A

71003

Miscellaneous

IMS 1221

Provide WSL_Master Instruction related to XI.E1

N/A

71003

Miscellaneous

IMS 1235

IMS 1235 - Thermography and Contact Resistance

N/A

71003

Miscellaneous

IMS 1269

Questions about Reference Temperature (XI. E6)

N/A

71003

Miscellaneous

IMS 1299

Provide WO and Procedure from IMS 1241 IMS 1299

N/A

71003

Miscellaneous

IMS item 1079

Master Work Instruction - 2 week RM met tower to Inspect

electrical manholes and sumps for water if rain fall

N/A

71003

Miscellaneous

IMS item 1081

In-Scope LR Inaccessible Cables DCID List

N/A

71003

Miscellaneous

IMS1080

The actual WO/documentation of the last 2 phone calls to

the Met Tower/rain

N/A

N/A

71003

Miscellaneous

Intertek AIM Letter

AIM 200410780 2Q

U2R22 Steam Generator Operational Assessment

Evaluation - April 2020

04/2020

71003

Miscellaneous

Intertek AIM Letter

AIM 220111116 2Q

2U1R23 Steam Generator Operational Assessment

Evaluation - May 2022 - Oct 2022

000

71003

Miscellaneous

Intertek AIM Letter

AIM 220111116-

2Q-1

U1R23 Steam Generator Condition Monitoring Evaluation -

April 2022

04/2022

71003

Miscellaneous

Intertek AIM Report

AIM 230111234-

2Q-1

Condition Monitoring and Preliminary Operational

Assessment for U2R24 Steam Generators for the April

23 Inspection

000

71003

Miscellaneous

N/A

XI.E4 GALL Gap Analysis Change Summary

2/04/2018

71003

Miscellaneous

NEI 14-13 OE

Template

NEI 14-13 AMP Operating Experience (OE) Review

Screening Questions

2

71003

Miscellaneous

NEI-18-10

Monitoring the Effectiveness of Nuclear Power Plant

001

71003

Miscellaneous

Presentation on EQ

(X.E1)

Environmental Qualification (EQ) of Electrical Components

Program (X.E1) AMP Board James Rajewski (EQ Program

Owner) Brent Warren (EQ Program Co-owner)

N/A

71003

Miscellaneous

Presentation X1.E2

PVNGS License Renewal Commitment #27 NUREG-1801

Program XI.E2 by Andrew DiGuilio

2/06/2025

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Miscellaneous

RCTSAI 3246899

PVNGS License Renewal Commitment Notebook

COmmitment#12 Closed-Cycle Water System

000

71003

Miscellaneous

RCTSAI 3246901

PVNGS License Renewal Commitment Notebook

Commitment #14-Fire Protection Program

000

71003

Miscellaneous

RCTSAI 3246917

RCTSAI for Electrical Cables and Connections Not Subject

to 10 CFR 50.49 EQ

2/27/2025

71003

Miscellaneous

RCTSAI 3246919

RCTSAI for Existing Electrical Cables And Connections Not

Subject To 10 CFR 50.49 Environmental Qualification

Requirements Used In Instrumentation

2/28/2025

71003

Miscellaneous

RCTSAI 3246920

RCTSAI for Inaccessible Power Cables Not Subject to 10 CFR 50.49 EQ Requirements program

2/28/2025

71003

Miscellaneous

RCTSAI 3246926

Masonry Wall Program is credited for license renewal

2/28/2025

71003

Miscellaneous

RCTSAI 3246927

RCTSAI for Structures Monitoring Program

2/28/2025

71003

Miscellaneous

RCTSAI 3246932

RCTSAI for Metal Enclosed Bus program Unit 1

2/27/2025

71003

Miscellaneous

RCTSAI 3247220

RCTSAI for Metal Enclosed Bus program Unit 2

2/26/2025

71003

Miscellaneous

RCTSAI 3247221

RCTSAI for Metal Enclosed Bus program Unit 3

2/26/2025

71003

Miscellaneous

RCTSAI 3409443

RCTSAI for Fuse Holder Program

2/12/2025

71003

Miscellaneous

TAC NOS.

MA8738, MA8739

AND MA8740

Palo Verde Nuclear Generating Station, Units 1, 2, And 3 -

Evaluation Of Relief Requests Associated With

Containment Inservice Inspection Requirements

10/06/2000

71003

Miscellaneous

VTD-C490-00007

Vendor manual for COMBUSTION ENGINEERING INC.

OPERATION-Maintenance Instruction for Ex-Core Neutron

Flux

010

71003

Miscellaneous

VTD-K020-00004

Vendor Manual Rad Monitor Kaman Introduction and

Overview of Radiation Monitoring System.

2

71003

Miscellaneous

Wis 5683776

WIs 5683776 Unit 3 Work instruction is to inspect Section

11E of NBN-A06.

N/A

71003

Miscellaneous

Wis 5683777

WIs 5683777 Unit 1 Work instruction to inspect Section

11E of NBN-A06

N/A

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Miscellaneous

WorleyParsons

Report No.

PVNGS-TLAA

Review of Time-Limited Aging Analyses (TLAAs) for Palo

Verde Nuclear Generating Station, Units 1, 2, and 3

001

71003

Miscellaneous

WSL MI 244102

WSL MI 244102 Work instruction to perform inspection,

cleaning and maintenance of the Calvert bus.

N/A

71003

Miscellaneous

X1-E1 Presentation

AMP XI.E1 Presentation by Steven Stewart

03/13/2025

71003

Miscellaneous

XI-E6 Presentation

Palo Verde XI.E6 Aging Management Program

(Commitment # 37) Challenge Board

03/14/2025

71003

NDE Reports24-660

Visual Examination Report for APDSNV283

8/7/2024

71003

NDE Reports25-013

Visual Examination Report for 2PFPNL283

1/9/2025

71003

NDE Reports

APSROLI00020-

REPT-004

One-Time Inspection Program [NUREG-1801 Program

XI.M32] Pre-PEO Inspection Results

71003

Procedures

PVNGS Operations Quality Assurance Program

Description (QAPD)

003

71003

Procedures

2MT-9NB01

ESF and Normal Service Transformer Maintenance (Basis)

013a

71003

Procedures

01DP-0AP12

Condition Reporting Process

048

71003

Procedures

01DP-0IS12

Confined Space Entry

035

71003

Procedures

13-LS-A100

PVNGS Aging Management Program Evaluation Report

Quality Assurance for Aging Management Programs

(IQMB-1/B1.3)

001

71003

Procedures

13-LS-A106

PVNGS Aging Management Program Evaluation Report -

Flow-Accelerated Corrosion -B2.1.6, NUREG 1801

Program XI.M17

2

71003

Procedures

13-LS-A115

PVNGS Aging Management Program Evaluation Report -

Reactor Vessel Surveillance - B2.1.15, NUREG 1801

Program XI.M31

2

71003

Procedures

13-LS-A116

PVNGS Aging Management Program Evaluation Report -

One-Time Inspection - B2.1.16, NUREG 1801 Program

XI.M32

003

71003

Procedures

13-LS-A117

PVNGS Aging Management Program Evaluation Report-

Program XI.M33

2

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Procedures

13-LS-A121

PVNGS Aging Management Program Evaluation Report -

Reactor Vessel Internals - B2.1.16, NUREG 1801

Program XI.M16A

000

71003

Procedures

14DP-0FP004

Fire Protection Test Program Requirement

008

71003

Procedures

14DP-0FP38

Fire Protection Test Program

019

71003

Procedures

14DP-0FP44

Fire Protection Test Program Requirement

008

71003

Procedures

14FT-0FP04

Annual Fire Water Loop Test

26

71003

Procedures

14FT-9FP04

Annual Fire Pump Test

21

71003

Procedures

14FT-9FP08

C02 Fire Suppression System Functional Test

2

71003

Procedures

14FT-9FP10

Halon Fire Suppression System Functional Test

26

71003

Procedures

14FT-9FP13

Fire Hose Station Operational and Hydrostatic Test

014

71003

Procedures

14FT-9FP23

Fire Suppression water System Flow Test

010

71003

Procedures

14FT-9FP49

Deluge System Water Flow Test and Strainer Cleaning

20

71003

Procedures

30DP-9MP01

Conduct of Maintenance

085

71003

Procedures

30DP-9MP01

Conduct of Maintenance (Basis)

085a

71003

Procedures

30DP-9MP06

Preventive Maintenance Processes and Activities

036

71003

Procedures

30DP-9WP02

Maintenance Work Order Process and Control

079

71003

Procedures

30DP-9WP02

Maintenance Work Order Process and Control

79a

71003

Procedures

2FT-9QD01

Exide Emergency Lighting System 8 Hour Fire Protection

Service Test for QDN-F01 (Basis)

21a

71003

Procedures

2FT-9QD01

Exide Emergency Lighting System 8 Hour Fire Protection

Service Test for QDN-F01

21

71003

Procedures

2MT-9NB01

ESF and Normal Service Transformer Maintenance

013

71003

Procedures

33FT-9FP03

Halon Fire Suppression System Damper Functional Test

2

71003

Procedures

33FT-9FP04

Appendix A Fire Damper Surveillance Test

016

71003

Procedures

37TI-9ZZ01

Infrared Thermography Inspection of Plant Component

010

71003

Procedures

37TI-9ZZ01

Infrared Thermography Inspection of Plant Component

(Basis)

010a

71003

Procedures

3INT-INCO-06

Alloy 600 Management Program Plan

005

71003

Procedures

40DP-9OP08

Diesel Generator Test Record

055

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Procedures

40ST-9DG01

Diesel Generator A Test

2

71003

Procedures

40ST-9DG02

Diesel Generator B Test

057

71003

Procedures

4191699

Palo Verde Generating Station PM Basis

1/23/2025

71003

Procedures

65DP-0QQ01

Industry Operating Experience Review

045

71003

Procedures

70DP-0MR02

Maintenance Rule Monitoring Process

001

71003

Procedures

73DP-0AP06

HVAC System Performance Testing Program

001

71003

Procedures

73DP-0LR01

License Renewal Implementation Program

007

71003

Procedures

73DP-0LR01

License Renewal Implementation Program (Basis)

007a

71003

Procedures

73DP-0LR01-01

License Renewal Implementation Processes

2

71003

Procedures

73DP-9CL02

Containment Leakage Rate Testing Program

038

71003

Procedures

73DP-9EE02

Inservice Inspection Examination Activities

016

71003

Procedures

73DP-9EE04

External Surfaces Inspection

005

71003

Procedures

73DP-9EE05

One-Time Inspection Program

009

71003

Procedures

73DP-9EE06

One-Time Inspection for Selective Leaching Degradation of

Components

007

71003

Procedures

73DP-9EE07

Internal Surfaces Inspection

001

71003

Procedures

73DP-9EE08

One-Time Inspection of ASME Code Class 1 Small-Bore

Piping Program

000

71003

Procedures

73DP-9XI03

ASME Section XI Inservice Inspection

030

71003

Procedures

73DP-9XI08

Conduct of Dissimilar Metal Weld Ultrasonic Examinations

004

71003

Procedures

73DP-9ZZ14

Surveillance Testing (Basis)

2a

71003

Procedures

73DP-9ZZ15

Control of Reactor Vessel Material Surveillance Testing

005

71003

Procedures

73DP-9ZZ17

Repair and Replacement ASME Section XI

031

71003

Procedures

73DP-9ZZ21

Heat Exchanger Visual Inspection

008

71003

Procedures

73DP-9ZZ25

Component Reliability/Predictive Maintenance Program

010

71003

Procedures

73ST-9CL01

Containment Leakage Type B and C Testing

054

71003

Procedures

73ST-9CL02

Integrated Leakage Rate Test

015

71003

Procedures

73ST-9EW01

Essential Cooling Water Pumps-Inservice Test

035

71003

Procedures

73TI-0EE02

Unit 9719 Program Engineering

014

71003

Procedures

73TI-9RC09

Bare Metal Visual Examination of Reactor Vessel Upper

Head

008

71003

Procedures

73TI-9RC10

Bare Metal Visual Examination of Reactor Vessel Bottom

Head

006

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Procedures

73TI-9ZZ20

Visual Examination of Reactor Vessel Internals

013

71003

Procedures

73TI-9ZZ22

Visual Examination For Leakage

014

71003

Procedures

73Tl-9ZZ20

Visual Examination of Reactor Vessel Internals

013

71003

Procedures

74CH-9SC10

Secondary Systems Corrosion Product Sampling

26

71003

Procedures

74DP-9CY04

Systems Chemistry Specifications

2

71003

Procedures

74ST-9DF01

Diesel Generator Fuel Oil Surveillance Test

71003

Procedures

74ST-9SQ22

Train A Radiation Monitoring Calibration Test for Baseline

Area Monitors (Basis)

015a

71003

Procedures

74ST-9SQ22

Train A Radiation Monitoring Calibration Test for Baseline

Area Monitors

015

71003

Procedures

81DP-0CC28

Classification of Structures, Systems, and Components

018

71003

Procedures

81DP-0RA02

Flow-Accelerated Corrosion (FAC) Program Detail

Procedure

20

71003

Procedures

81DP-0ZZ01

Civil Systems, Structure and Component Monitoring

Program (Basis)

030a

71003

Procedures

81DP-0ZZ01

Civil Systems, Structure and Component Monitoring

Program

030

71003

Procedures

81DP-9RC03

PVNGS Integrated Materials Management Program

010

71003

Procedures

2DP-0EE01

Electrical Aging Management

71003

Procedures

2DP-0EE01

Electrical Aging Management (Basis)

07a

71003

Procedures

2DP-0EE05

Metal Enclosed Bus Aging Management (Basis)

000a

71003

Procedures

83DP-0AP01

Buried Piping and Tanks Program

010

71003

Procedures

84DP-0RM30

Record Management Control

038

71003

Procedures

87DP-0CC17

Control of Engineering Data in SWMS

2

71003

Procedures

88DP-0EQ01

Environmental Qualification Program (Basis)

006a

71003

Procedures

91DP-0EN31

Storm Water Collection System Management (Basis)

004a

71003

Procedures

91DP-0EN31

Storm Water Collection System Management

004

71003

Procedures

91DP-0EN31-01

Management of Sumps and Manholes Administrative

Guidelines

(Basis)

006a

71003

Procedures

91DP-0EN31-01

Management of Sumps and Manholes Administrative

Guidelines

006

71003

Procedures

93DP-0LC08

Regulatory Commitment Tracking

009

71003

Procedures

93DP-0LDPC08

Regulatory Commitment Tracking

009

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

71003

Procedures

93DP-0LDPC08

Regulatory Commitment Tracking (Basis)

009a

71003

Procedures

E109-00029

Accurate Corrosion Control Inc. (ACCI) Test Instructions for

The Cathodic Protection Annual Survey Palo Verde

Nuclear Generating Station

8/27/2024

71003

Procedures

PVNGS-AMP-

B2.1.17

PVNGS Aging Management Program Evaluation Report

Selective Leaching of Materials - B2.1.17

006

71003

Work Orders

264553, 4408414, 3380605, 3531603, 4231874, 4420094,

20164, 4420056, 4420058, 4602979, 4602973, 5076993,

5066998, 507703, 5077004, 50078370, 5079606, 5158836,

5570252, 5695353, 5307436, 4553128, 3370562, 3473801,

4495938, 5405987, 5405987, 5466656, 5024637, 5024646,

5419879, 4506710, 5578109, 5080550, 5242651,

242650, 5080550, 5359795, 5080555, 5080552, 5197132,

4963001, 5079963, 5080149, 5080146, 5080151,

5080575, 4963001, 5079963, 5080146, 5080149,

5080151, 5080575, 5197132, 5609201, 5363504, 5072941,

5072942, 5072943, 5072940, 5072938, 5072939, 5072934,

5072936, 5072937, 5599660, 5364232, 5364231, 5565996,

5364237, 5565997, 5622860, 5075400, 5075401, 5080420,

5080421, 5078210, 5078211, 5260127, 5473345, 5380965,

5610720, 5473344, 5610718, 5566907, 5380959, 4779119,

553915, 5079962, 5543354, 5326337, 5473344, 5380968,

5380964, 5345367, 5380961, 5380967, 5380957, 5053554,

5380963, 5473352, 5473357,5473355, 5473358,

5473353, 5380966, 5363504, 5415062, 5415060, 5415056,

5415057, 5415059, 5415061, 5415063, 5415065, 5415066,

5415067, 5584824, 5383105, 5535915, 5221912, 5383099,

269300, 5383094, 5383103, 5383104, 5383092, 5383093,

5383095, 5383096, 5383097, 5383098, 5383101, 5383102,

5383106, 5415064, 5415058, 5383104, 5079962, 5545667,

5545668, 5545669, 5079613, 5079616, 5079617, 4304441,

4844666, 5110315, 5111686, 5053668, 4844660, 4844665,

4844666, 4935529, 5176596, 5280435, 4841168, 4844674,

5145493, 5376813, 4181683, 5570390, 5645147, 5645588,

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

25029, 5320984, 5320986, 527306, 5320987, 5379054,

5383440, 5008474, 5386205, 5550566, 5386205, 5502737,

5548477, 4729319, 4909904, 5087725, 5548530, 5173752,

5378788, 5173754, 5378787, 4822962, 5697093, 5697094,

5386232, 5388618, 5391932, 5697028

71003

Work Orders

PMBD 249089,

249143, 2582345,

2713964, 2803422,

2845214, 249082,

249084, 249086

PVNGS Preventive Maintenance Program

000

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