ML041210872
| ML041210872 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Quad Cities  |
| Issue date: | 04/23/2004 |
| From: | Kim T NRC/NRR/DRIP/RLEP |
| To: | Exelon Generation Co |
| Kim T J, NRR/DRIP/RLEP, 415-1392 | |
| References | |
| TAC MB6839, TAC MB6840, TAC MB6841, TAC MB6842 | |
| Download: ML041210872 (51) | |
Text
April 23, 2004 APPLICANT: Exelon Generating Company, LLC FACILITY:
Dresden Nuclear Power Station, Units 2 and 3 Quad Cities Nuclear Power Station, Units 1 and 2
SUBJECT:
AUDIT REPORT RELATED TO THE LICENSE RENEWAL APPLICATION FOR DRESDEN NUCLEAR POWER STATION AND QUAD CITIES NUCLEAR POWER STATION (TAC NOS. MB6839, MB6840, MB6841, AND MB6842)
The Nuclear Regulatory Commission (NRC) staff conducted an audit of the applicants supporting documentation associated with the subject license renewal application (LRA) at the applicants offices located in Warrenville, IL, during the periods of October 7-8, 2003, and verified the program enhancement through a subsequent March 15-17, 2004, audit. The purpose of the audit was to verify the consistency of the applicants aging management programs (AMPs) described in the LRA with the corresponding AMPs specified in NUREG-1801, Generic Aging Lessons Learned (GALL) Report. The NRC audit team examined 37 of the 38 AMPs that the applicant stated were consistent with the corresponding AMPs specified in the GALL Report. The remaining AMP (B.1.38) is a new program for inaccessible medium-voltage cables, which has been reviewed separately by the technical staff. The results of the audit are provided in the enclosed Audit Report.
/RA/
Tae Kim, Senior Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249 50-254, 50-265
Enclosure:
As stated cc w/enclosure: See next page
April 23, 2004 APPLICANT: Exelon Generating Company, LLC FACILITY:
Dresden Nuclear Power Station, Units 2 and 3 Quad Cities Nuclear Power Station, Units 1 and 2
SUBJECT:
AUDIT REPORT RELATED TO THE LICENSE RENEWAL APPLICATION FOR DRESDEN NUCLEAR POWER STATION AND QUAD CITIES NUCLEAR POWER STATION (TAC NOS. MB6839, MB6840, MB6841, AND MB6842)
The Nuclear Regulatory Commission (NRC) staff conducted an audit of the applicants supporting documentation associated with the subject license renewal application (LRA) at the applicants offices located in Warrenville, IL, during the periods of October 7-8, 2003, and verified the program enhancement through a subsequent March 15-17, 2004, audit. The purpose of the audit was to verify the consistency of the applicants aging management programs (AMPs) described in the LRA with the corresponding AMPs specified in NUREG-1801, Generic Aging Lessons Learned (GALL) Report. The NRC audit team examined 37 of the 38 AMPs that the applicant stated were consistent with the corresponding AMPs specified in the GALL Report. The remaining AMP (B.1.38) is a new program for inaccessible medium-voltage cables, which has been reviewed separately by the technical staff. The results of the audit are provided in the enclosed Audit Report.
/RA/
Tae Kim, Senior Project Manager License Renewal Section A License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249 50-254, 50-265
Enclosure:
As stated cc w/enclosure:
Accession no.: ML041210872 Document Name: C:\\ORPCheckout\\FileNET\\ML041210872.wpd OFFICE PM:RLEP LA:RLEP SC:RLEP-B SC:RLEP-A PD:RLEP NAME TJKim (KCorp for)
YEdmonds SWest (w/comments)
SLee PTKuo Date 03/24/04 04/15/04 04/05/04 04/15 /04 04/23/04 OFFICIAL AGENCY RECORD
DISTRIBUTION: Applicant: Exelon, Dated: April 23, 2004 Accession no.: ML041210872 HARD COPY RLEP RF T.J. Kim (PM)
E-MAIL:
PUBLIC D. Matthews F. Gillespie C. Grimes RidsNrrDe E. Imbro G. Bagchi K. Manoly W. Bateman J. Calvo R. Jenkins P. Shemanski J. Fair S. Black B. Boger D. Thatcher R. Pettis G. Galletti C. Li M. Itzkowitz R. Weisman M. Mayfield A. Murphy S. Smith (srs3)
S. Duraiswamy Y. L. (Renee) Li RLEP Staff L. Kozak, RIII M. Ring, RIII
Enclosure U. S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Reactor Regulation Division of Regulatory Improvement Programs License Renewal and Environmental Impacts Program Directorate Docket Nos:
50-237; 50-249 50-254; 50-265 License No:
DPR-19; DPR-25 DPR-29; DPR-30 Applicant:
Exelon Generating Company, LLC Facility:
Dresden Nuclear Power Station, Units 2 and 3 Quad Cities Nuclear Power Station, Units 1 and 2 Location:
Exelon Generation Companys Cantera Offices 4300 Winfield Road Warrenville, IL 60555 Dates:
October 7-8, 2003 & March 15-17, 2004 Auditors:
T. Kim, Senior Project Manager, RLEP/NRR J. Eads, Project Manager, RLEP/NRR M. Lintz, Project Manager, RLEP/NRR G. Suber, Project Manager, RLEP/NRR L. Kozak, Senior Reactor Inspector, RIII F. Baxter, Contractor B. Gitnick, Contractor K. Green, Contractor M. Patterson, Contractor S. Traiforos, Contractor Approved by:
Pao-Tsin Kuo, Program Director License Renewal & Environmental Impacts Program Directorate Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation
AUDIT REPORT RELATED TO THE AGING MANAGEMENT PROGRAMS ASSOCIATED WITH THE LICENSE RENEWAL APPLICATION FOR DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3, AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 1.0 Scope of Audit On October 7-8, 2003, the Nuclear Regulatory Commission (NRC) staff conducted an audit of the applicants supporting documentation associated with the subject license renewal application (LRA) at the applicants offices located in Warrenville, IL. The purpose of the audit was to verify the consistency of the applicants aging management programs (AMPs) described in the LRA with the corresponding AMPs specified in NUREG-1801, Generic Aging Lessons Learned (GALL) Report. A follow-up audit was conducted on March 15-17, 2004, to examine the applicants program enhancements since the first audit.
The Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800) provides guidance to the staff for reviewing a license renewal application (LRA). The Standard Review Plan and accompanying Regulatory Guide (RG)-1.188, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating Licenses, allow an applicant to reference, in its LRA, AMPs specified in the GALL Report, provided that the applicants AMP is consistent with the corresponding AMP specified in the GALL Report. The AMPs specified in the GALL Report have been reviewed and accepted by the staff for license renewal and, therefore, no further staff review is required for those plant AMPs that the applicant has determined (and identified in the LRA) to be consistent with the corresponding AMPs in the GALL Report. If an applicant credits an AMP for being consistent with a corresponding AMP in the GALL Report, it is incumbent on the applicant to ensure that the plant AMP contains (and, is consistent with) all of the elements of the referenced GALL program. The applicants determination should be documented in an auditable form and maintained on site.
The audit team examined 37 of the 38 AMPs that the applicant stated were consistent with the corresponding AMPs specified in the GALL Report. The remaining AMP (B.1.38) is a new program for inaccessible medium-voltage cables, which has been reviewed separately by the technical staff. Any exceptions or enhancements noted by the applicant in the LRA have been reviewed by the audit team and NRCs technical staff, and the results will be documented in a Safety Evaluation Report. The audit team evaluated each of the 10 attributes of an applicants AMP against the corresponding AMP attributes specified in the GALL Report. The audit team reviewed the applicants license renewal aging management program basis documents, referred to as Aging Management Review Topical Reports (AMRTR), and related references for these AMPs, as well as selected implementing procedures. The audit team also reviewed the applicants responses to the staffs requests for additional information (RAIs), and interviewed the applicants engineering staff responsible for developing the AMPs described in the LRA. The audit team identified differences between the applicants AMPs and the corresponding AMPs specified in the GALL Report and evaluated whether they constituted a deviation from the GALL Report.
2.0 Audit Findings 2.1 Summary Based on the audit, the audit team concluded that for the most part the aging management programs are consistent with the corresponding GALL programs with deviations/enhancements as stated in the LRA, with few exceptions. For example:
Discrepancies were identified in the Fire Protection Program (B.1.18) relative to expanding sample sizes and frequency of penetration seal inspection. Paragraph B.1.18 in Section 2.2 of this Audit Report provides detailed information. The applicants planned program enhancements as a result of this audit was reviewed during a follow-up audit on March 15-17, 2004. The audit team determined that these enhancements to the program will ensure the applicants program is consistent with GALL.
On the One-Time Inspection Program (B.1.23), the team determined that the applicants sampling methodology is weak in terms of determining representative samples and sample sizes. Paragraph B.1.23 in Section 2.2 of this Audit Report provides detailed information. The applicants planned program enhancements as a result of this audit was reviewed during a follow-up audit on March 15-17, 2004. The audit team determined that these enhancements to the program will ensure the applicants program is consistent with GALL.
On the Selective Leaching Program (B.1.24), the audit team identified four separate discrepancies. Each individual discrepancy can be considered relatively minor in significance, but in the aggregate, the audit team concluded that this aging management program, as found, may reduce the effectiveness of the GALL program. Paragraph B.1.24 in Section 2.2 of this Audit Report provides detailed information. The applicants planned program enhancements as a result of this audit was reviewed during a follow-up audit on March 15-17, 2004. The audit team determined that these enhancements to the program will ensure the applicants program is consistent with GALL.
A public exit meeting with the applicant to discuss the audit findings was held on October 22, 2003, at the Exelon Generation Companys Cantera Offices.
2.2 Details B.1.1 ASME Section XI, Subsections IWB, IWC, and IWD (ISI PROGRAM)
In Appendix B.1.1 of the LRA, the applicant states that the Dresden and Quad Cities inservice inspection AMP for ASME Section XI inservice inspection for Subsections IWB, IWC and IWD is consistent with GALL AMP XI.M1. This AMP is credited for managing aging in the reactor coolant system (RCS) including reactor internals, and RCS piping and components, except the reactor vessel and structures. The following exception and enhancement were noted in the LRA by the applicant: (1) the applicants program specifies ASME Section XI, Subsections IWC and IWD for the Dresden isolation condenser since it is classified as ISI Class 2 on the tube side and ISI Class 3 on the shell side, whereas GALL AMPs XI.M1 specifies that the aging of the isolation condenser is to be managed by ASME Section XI, Subsection IWB (for Class 1 components); and (2) the current Code of record for Dresden and Quad Cities is the 1989 Edition of ASME Section XI, whereas GALL AMPs XI.M1 specifies the 1995 ASME Section XI Code Edition with 1996 Addenda. The applicant committed to enhance its program to be consistent with the requirements of the 1995 ASME Section XI Code Edition with 1996 Addenda. The above exception and enhancement noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables for the B.1.1 program. This existing program consists of performing visual, surface, and volumetric nondestructive examinations of piping and components at various intervals in accordance with the 1989 edition of the ASME Boiler and Pressure Vessel Code, Subsection XI. Exelon has committed to enhance this program to the 1995 ASME code edition with 1996 Addenda. The audit team noted that this update has already occurred. The audit team also reviewed AMR topical reports (AMP Basis Documents): M05, Steam and Reactor Grade Water, M09, Heat Exchangers, M13, Reactor Pressure Vessel, and M14, Reactor Internals. The audit team also reviewed implementing procedures Dresden Units 2 & 3 ISI Program Plan for the 4th 10 Year Inspection Interval, ER-AA-330, Conduct of Inservice Inspections, and the applicants response to RAI B.1.1.
On the basis of its review of the AMP, including the associated program basis documents, response to relevant RAI, and by sampling site implementing procedures and commitments (action tracking items), the audit team determined that this AMP is consistent with the corresponding GALL AMP XI.M1, with the enhancement and the exception as noted in the LRA.
B.1.2 Water Chemistry In Appendix B.1.2 of the LRA, the applicant stated that the Water Chemistry aging management program is consistent with GALL program XI.M2, Water Chemistry, with enhancements and exceptions. The following exceptions and enhancements were noted in the LRA by the applicant:
The Dresden and Quad Cities water chemistry programs are based on EPRI-TR-103515-Rev. 2, while the GALL program references Revision 1; The GALL program indicates that hydrogen peroxide is monitored to mitigate degradation of structural materials. Dresden and Quad Cities programs do not monitor for hydrogen peroxide; The GALL program indicates that the condensate storage tank, demineralized water storage tank, and torus (pressure suppression pool) water are sampled for dissolved oxygen. The Dresden and Quad Cities programs do not sample for dissolved oxygen; The GALL program indicates that water quality (pH and conductivity) is maintained in accordance with established guidance. Dresden and Quad Cities programs do not monitor pH in the condensate storage tank, demineralized water storage tank, or torus (pressure suppression pool) water; Aging of standby liquid control (SBLC) system components not in the reactor coolant pressure boundary section of SBLC system relies on monitoring of SBLC makeup water chemistry. The makeup water is monitored in lieu of the storage tank. The effectiveness of the water chemistry program will be verified by a One-Time VT-3 inspection of a Dresden SBLC pump discharge valve casing and a Quad Cities SBLC pump casing as discussed in the One-Time Inspection (B.1.23) aging management program; The applicant indicates that the Dresden and Quad Cities Water Chemistry programs will be enhanced by revising procedures to provide for increased sampling to verify corrective actions taken to address abnormal chemistry conditions, and the Quad Cities procedure for turbine building sample panel collection will be revised to assure maintenance of the chemistry integrity of samples. These enhancements are scheduled for implementation prior to the period of extended operation.
The above exceptions and enhancements noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables for water chemistry. The audit team also reviewed implementing procedure CY-AB-120-100, Reactor Water Chemistry, and Action Tracking Item 101522.02.05 for procedure CY-AB-120-110, Revision 5, Condensate and Feedwater Chemistry.
The audit team identified a difference in several attributes, e.g., scope of program, preventive actions, and monitoring and trending, regarding condensate and feedwater chemistry. In the program description, the applicant states that feedwater chemistry is controlled through procedure CY-AB-120-110, Condensate and Feedwater Chemistry.
However, the other attributes do not identify the requirements for condensate and feedwater chemistry or reference the guidelines for condensate and feedwater chemistry from BWRVIP-29. The audit team questioned this apparent oversight. The applicant agreed that omission of the condensate and feedwater chemistry procedure in several of the attributes was an administrative error. The applicant further stated that it is committed to controlling feedwater chemistry in accordance with the corporate procedure as stated in the program description, and as evidenced by Action Tracking Item 101522.02.05 (for Dresden) and 101562.02.07 (for Quad Cities). The basis document for the Water Chemistry AMP is contained in portions of eight AMRTRs. The applicant indicated that the applicable attributes in the corresponding AMRTRs will be clarified to include condensate and feedwater chemistry.
The audit team noted that the applicant is taking action to enhance applicable station procedures to increase sampling to verify the effectiveness of corrective actions taken to address an abnormal chemistry condition as stated in the LRA. Increased sampling whenever corrective actions are taken to address an abnormal chemistry condition is consistent with GALL.
The audit team identified a difference in the scope of program attribute for spent fuel pool chemistry. In the Exelon Aging Management Program Ten Element Review tables, the applicant states that spent fuel pool chemistry periodic monitoring for detrimental contaminants such...dissolved oxygen...are controlled by procedure CY-AB-120-300.
The audit team reviewed various aspects of the implementing procedure and noted that dissolved oxygen is not monitored. The applicant confirmed that the inclusion of dissolved oxygen in the table is an administrative error, and that the procedure is correct. The applicant indicated that the applicable attributes in the Exelon Aging Management Program Ten Element Review tables will be revised to correct the error.
Based on the review of the AMPs basis documents, implementing procedures and action tracking items, the audit team determined that this AMP is consistent with GALL program XI.M2, with the enhancements and the exceptions as noted in the LRA.
B.1.3 Reactor Head Closure Studs Program In Appendix B, Section 1.3 of the LRA, the applicant states that its reactor head closure stud aging management program is consistent with GALL program XI.M3, Reactor Head Closure Studs, with two exceptions. These exceptions are with respect to the NUREG-1801 specification that the inspections be carried out in accordance with the requirements of ASME Section XI, Subsection IWB, Table IWB 2500-1. Table IWB 2500-1 specifies volumetric (radiographic, ultrasonic, or eddy current) inspection for studs in place and both surface (magnetic particle, liquid penetration, or eddy current) and volumetric examination of studs when removed. Instead of a surface examination, the Dresden and Quad Cities plants utilize a VT-1 visual inspection, as granted under relief requests CR-13 and CR-11, respectively. Likewise, instead of a volumetric examination with a conventional UT, the Dresden and Quad Cities reactor closure head studs are examined by end-shot UT, as approved in relief request CR-12.
The LRA also indicates that the current code of record for the Dresden and Quad Cities inspection programs is the 1989 Edition of ASME Section XI, rather than the 1995 Edition through the 1996 Addenda, as specified in NUREG-1801. The applicant stated that its inspection program will be revised to be consistent with these NUREG-1801 requirements prior to the period of extended operation. These exceptions noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
This AMP is credited with managing aging-related cracking and loss of material in reactor head closure bolts. The applicant stated in the LRA that the Dresden and Quad Cities reactor head closure studs AMP activities have detected aging degradation and have implemented appropriate corrective actions to maintain system and component intended functions, including prompt repair or replacement of degraded components prior to failure.
The audit team reviewed the license renewal aging management program basis document M13, Reactor Pressure Vessel.
The audit team noted that the applicant did not reference the use of stable lubricants to mitigate the aging effects of the studs, under the preventative action attribute, as referenced in GALL. The applicant stated that stable lubricants were used and agreed to update its basis document M13 (License Renewal Change Request LRCR 2003-289).
The audit team determined that addressing the use of stable lubricants, thus revising the attribute for preventive action, would make this attribute consistent with the GALL AMP.
On the basis of its review of this AMP, GALL AMP XI.M3, and the updated program basis document, the audit team determined that this AMP is consistent with the GALL AMP XI.M3, with the exceptions as noted in the LRA.
B.1.4 BWR Vessel ID Attachment Welds Program In Appendix B, Section 1.4 of the LRA, the applicant states that its BWR vessel ID attachment welds aging management program is consistent with GALL program XI.M4, BWR Vessel ID Attachment Welds. This AMP is credited with managing crack initiation and growth due to SCC and IGSCC in the vessel ID attachment welds.
The applicant identified one exception to NUREG-1801. GALL Program XI.M4 indicates that the BWR water chemistry control is in accordance with BWRVIP-29, which references the 1993 revision of EPRI-TR-103515, BWR Water Chemistry Guidelines.
However, as previously discussed in paragraph B.1.2 of this audit report, the Dresden and Quad Cities Water Chemistry Programs are based on the 2000 revision of EPRI-TR-103515-R2.
The LRA also indicates that the current code of record for the Dresden and Quad Cities inspection programs is the 1989 Edition of ASME Section XI, rather than the 1995 Edition through the 1996 Addenda, as specified in NUREG-1801. The applicant stated that its inspection program will be revised to be consistent with these NUREG-1801 requirements prior to the period of extended operation.
The above exception and enhancement noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
The applicant stated that the program incorporates the inspection and evaluation recommendations of BWRVIP-48, Vessel ID Attachment Weld Inspection and Evaluation Guidelines, as well as the water chemistry recommendations of EPRI-TR-103515-R2, BWR Water Chemistry Guidelines. The applicant further stated that because of the incorporation of these recommendations, the program is consistent with GALL Program XI.M4, BWR Vessel ID Attachment Welds.
The audit team reviewed the license renewal aging management program basis document M13, Reactor Pressure Vessel. For the detection of aging effects attribute, the audit team noted that the applicant required VT-3 visual examination in lieu of the more detailed EVT-1 visual examination, in station in-vessel examination procedures DTS 0200-02 and QCTS 0740-04. The applicant agreed that EVT-1 was the appropriate examination and agreed to update the station procedures (License Renewal Change Request LRCR 2003-263). The audit team determined that updating these station procedures to require EVT-1 will make this attribute consistent with GALL.
On the basis of its review of this AMP, GALL AMP XI.M4, and the updated program basis document, the audit team determined that this AMP is consistent with the GALL AMP XI.M4, with the exception and enhancement as noted in the LRA.
B.1.5 BWR Feedwater Nozzle In Appendix B.1.5 of the LRA, the applicant stated that the BWR Feedwater Nozzle aging management program is consistent with GALL program XI.M5, "BWR Feedwater Nozzle," with no exceptions. The applicant also stated that the program enhances the inservice inspections specified in ASME Code Section XI with the recommendations of General Electric (GE) NE-523-A71-0594, Alternate BWR Feedwater Nozzle Inspection Requirements.
This AMP is credited with managing aging-related cracking in reactor feedwater nozzles.
The applicant stated in the LRA that the Dresden and Quad Cities BWR Feedwater Nozzle Program activities have detected indications of cracking due to cyclic loading on feedwater nozzles prior to loss of their intended function. The indications were repaired by grinding and reexamination or the thermal sleeve was replaced. The applicant also stated that the Dresden and Quad Cities feedwater nozzles have been modified to mitigate cracking by removing the stainless steel cladding.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables, which state that the current ASME Section XI programs use the 1989 edition of the ASME code. These tables also state that the program will be updated (enhanced to the 1995 ASME Code Edition with 1996 Addenda) prior to the period of extended operation. This enhancement to the applicants feedwater nozzle aging management program was not noted in the LRA. However, this is a moot point, as the update has already been completed. The audit team also reviewed the applicant's aging management review topical reports AMRTR-M05, Steam and Reactor Grade Water Environment, and AMRTR-M13, Reactor Pressure Vessel.
Topical Report GE-NE-523-A71-0594, Alternate BWR Feedwater Nozzle Inspection Requirements, was reviewed along with the Dresden Station ISI Program Plan for the 4th 10-Year Inspection Interval. The requirements of the topical report and the current version of the ASME Code have been addressed in the plan. Procedures ER-AA-330-002, Inservice Inspection of Welds and Components as well as ER-AA-330-009, ASME Section XI Repair-Replacement Program were reviewed to confirm that aging management commitments were tracked at the level of implementing procedures, thus providing confidence in the applicants continued compliance. It was noted that the action tracking sub-assignments lacked specificity. The audit team determined, however, that Procedure LS-AA-110, "Commitment Management," appears to provide adequate control over regulatory commitments even when the action tracking record is worded in general terms.
On the basis of the review of this AMP, AMRTRs-M05 and -M13, and the implementing procedures, the audit team determined that AMP B.1.5, as enhanced, is consistent with the GALL program XI.M5.
B.1.6 BWR Control Rod Drive Return Line Nozzle In Appendix B.1.6 of the LRA, the applicant stated that the control rod drive return line nozzle aging management program is consistent with GALL program XI.M6, "BWR Control Rod Drive Return Line Nozzle," with one exception and an enhancement.
Augmented inspections specified in NUREG-0619, BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking, are not performed because the control rod drive return line nozzles have been capped. The CRD return line nozzles remain within the ISI program plan as documented in the ISI Program Plan 4th 10-Year Inspection Interval. The LRA also indicated that the current code of record for the Dresden and Quad Cities inspection programs is the 1989 Edition of ASME Section XI, rather than the 1995 Edition through the 1996 Addenda, as specified in NUREG-1801. The applicant stated that its inspection program will be revised to be consistent with these NUREG-1801 requirements prior to the period of extended operation.
The above exception and enhancement noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
This AMP is credited with managing aging-related cracking in the CRD return line nozzles. The applicant stated in the LRA that the Dresden and Quad Cities BWR Control Rod Drive Return Line Nozzle Program activities have detected indications of cracking aging effects on CRD return line nozzles prior to loss of their intended function.
The indications were repaired by flaw removal or weld overlay.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables. The tables state that the current ASME Section XI programs use the 1989 edition of the ASME code, but the program would be updated (enhanced) prior to the period of extended operation. This enhancement to the applicants program was also noted in the LRA (This update has already occurred). The audit team also reviewed AMR topical report AMR M13, Reactor Pressure Vessel, which is the basis document for this AMP. Other documents reviewed included ER-AA-330-002, Inservice Inspection of Welds and Components, ER-AA-330-009, ASME Section XI Repair-Replacement Program, and action tracking item 101562.06.01.
On the basis of the review of this AMP, GALL AMP XI.M6, AMR topical reports M05 and M13, and the implementing procedures, the audit team determined that this AMP is consistent with GALL AMP XI.M6, with the enhancement and the exception as noted in the LRA.
B.1.7 BWR Stress Corrosion Cracking In Appendix B.1.7 of the LRA, the applicant stated that the BWR stress corrosion cracking aging management program is consistent with GALL program XI.M7, BWR Stress Corrosion Cracking, with one exception and an enhancement. GALL Program XI.M7 indicates that the BWR water chemistry control is in accordance with BWRVIP-29, which references the 1993 revision of EPRI TR-103515, BWR Water Chemistry Guidelines. However, as previously discussed in paragraph B.1.2 of this audit report, the Dresden and Quad Cities Water Chemistry Programs are based on the 2000 revision of EPRI TR-103515-R2.
The LRA also indicates that the current code of record for the Dresden and Quad Cities inspection programs is the 1989 Edition of ASME Section XI, rather than the 1995 Edition through the 1996 Addenda, as specified in NUREG-1801. The applicant stated that its inspection program will be revised to be consistent with these NUREG-1801 requirements prior to the period of extended operation.
The above exception and enhancement noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
According to the applicant, the BWR stress corrosion cracking aging management program activities have detected flaw indications in reactor coolant pressure boundary piping prior to loss of intended functions of the component. Examples are indications on the reactor vessel safe ends, and recirculation piping. The applicants engineering staff evaluated these indications and, where necessary, performed repairs in accordance with ASME Section XI and station procedural requirements. The LRA indicates that periodic self-assessments of program activities have been performed and will continue to be performed to identify areas that need improvement. The applicant states that when problems have been identified, corrective actions have been taken to prevent recurrence.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables. The tables state that the current ASME Section XI programs use the 1989 edition of the ASME code, but the program would be updated (enhanced) prior to the period of extended operation. This enhancement to the applicants program was also noted in the LRA (This update has already occurred). The audit team also reviewed AMR topical reports AMR M05, Steam and Reactor Grade Water Environment, and AMR M13, Reactor Pressure Vessel, which are the basis documents for this AMP.
The audit team also reviewed the applicants responses to the staffs RAI B.1.7 and RAI 3.1-24 which addressed plant-specific experience related to IGSCC.
On the basis of its review of this AMP, GALL AMP XI.M7, the associated program basis document, relevant RAI responses, AMR topical reports, and commitment items list, the audit team determined that this AMP is consistent with the GALL AMP XI.M7, with the exception and enhancement as noted in the LRA.
B.1.8 BWR Penetrations Program In Appendix B, Section 1.8 of the LRA, the applicant states that its BWR penetrations aging management program is consistent with GALL program XI.M8, BWR Penetrations. As specified in GALL program XI.M8, the applicants program incorporates the inspection and evaluation recommendations of BWRVIP-27, BWR Standby Liquid Control System/Core Plate P/SLC Inspection and Flaw Evaluation Guidelines, and BWRVIP-49, Instrument Penetration Inspection and Flaw Evaluation Guidelines. The program also incorporates the water chemistry recommendations of EPRI TR-103515-R2, BWR Water Chemistry Guidelines.
The applicant identified two exception to NUREG-1801: (1) GALL Program XI.M8 indicates that the BWR water chemistry control is in accordance with BWRVIP-29, which references the 1993 revision of EPRI TR-103515, BWR Water Chemistry Guidelines, whereas the Dresden and Quad Cities Water Chemistry Programs are based on the 2000 revision of EPRI TR-103515-R2, as previously noted in paragraph B.1.2 of this Audit Report; and (2) LRA also indicates that the program uses relief request ISI CR-01 that provides for inspection of the inner radius of the Dresden and Quad Cities standby liquid control system nozzles by a VT-2 examination, instead of the normal volumetric inspection required by the ASME Code. The applicant also identified an enhancement which would revise the current Code of record for the Dresden and Quad Cities ISI programs from the 1989 Edition of ASME Section XI to the 1995 Edition through the 1996 Addenda, as specified in NUREG-1801, prior to the period of extended operation.
The above exception and enhancement noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
This AMP is credited with managing crack initiation and growth due to SCC, including IGSCC, in the BWR instrument penetrations and standby liquid control nozzles. The applicant stated that no instrument penetration or standby liquid control nozzle indications have been reported at the Dresden and Quad Cities.
The audit team reviewed license renewal aging management program basis document M13, Reactor Pressure Vessel. The audit team noted that the applicant evaluation of indications was to be conducted, consistent with BWRVIP-27 and BWRVIP-49, as documented in station procedures DTS 0200-02 and QCTS 0740-04, under the acceptance criteria attribute, as referenced in GALL program XI.M8. However, the audit team noted that these station procedures had only a limited discussion of how evaluations were to be performed. The applicant stated that procedure ER-AA-330-002, which is referenced in both station procedures (DTS 0200-02 and QCTS 0740-04),
contains detailed evaluation requirements. The audit team reviewed procedure ER-AA-330-002, and determined that no additional action was required to make this attribute consistent with the GALL AMP.
On the basis of its review of this AMP, GALL AMP XI.M8, and the associated program basis document, the audit team determined that this AMP is consistent with the GALL program XI.M8, with the exceptions and enhancement as noted in the LRA.
B.1.9 BWR Vessel Internals Program In Appendix B, Section 1.9 of the LRA, the applicant states that its BWR vessel internals aging management program is consistent with GALL program XI.M9, BWR Penetrations. The applicants program, in accordance with GALL program XI.M9, incorporates the inspection and evaluation recommendations of BWRVIP guidelines as well as BWR Water Chemistry Guidelines specified in EPRI TR-103515-R2.
The applicant identified one exception to GALL program XI.M9 in that the Dresden and Quad Cities Water Chemistry Programs are based on the 2000 revision of EPRI-TR-103515-R2, whereas GALL Program XI.M9 references the 1993 revision of EPRI-TR-103515, as noted previously in paragraph B.1.2 of this Audit Report. The applicant also identified an enhancement which would revise the current Code of record for the Dresden and Quad Cities ISI programs from the 1989 Edition of ASME Section XI to the 1995 Edition through the 1996 Addenda, as specified in NUREG-1801, prior to the period of extended operation. The above exception and enhancement noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
This AMP is credited with managing crack initiation and growth due to SCC, including IGSCC, in the BWR vessel internals. The applicant stated that the BWR vessel internals aging management activities have detected cracking in several vessel internals including Quad Cities access hole covers and core spray piping at Dresden Unit 3. The applicant also reported that a jet pump beam assembly failed at Quad Cities Unit 1 in January 2002. All similar beams at Dresden and Quad Cities have been replaced with beams fabricated with an improved heat treatment in accordance with BWRVIP-41 to increase the resistance to IGSCC.
The audit team reviewed license renewal aging management program basis document M14, Reactor Internals. For the detection of aging effects attribute, the audit team noted that the applicant did not specifically require the detailed EVT-1 visual examination of the top guide in station in-vessel examination procedures DTS 0200-02 and QCTS 0740-04. The applicant agreed that EVT-1 was the appropriate examination and agreed to update the station procedures (License Renewal Change Request LRCR 2003-257). The audit team determined that updating these station procedures to require EVT-1 will make this attribute consistent with GALL Program XI.M9.
The audit team noted that the applicant evaluation of indications was to be conducted, consistent with BWRVIP-27 and BWRVIP-49, as documented in station procedures DTS 0200-02 and QCTS 0740-04, under the acceptance criteria attribute, as referenced in GALL. However, the audit team noted that these station procedures had only a limited discussion of how evaluations were to be performed. The applicant stated that procedure ER-AA-330-002, which is referenced in both station procedures, contains detailed evaluation requirements. The audit team The audit team reviewed procedure ER-AA-330-002, and determined that no additional action was required to make this attribute consistent with the GALL Program XI.M9.
On the basis of its review of this AMP, GALL AMP XI.M9, and the updated program basis document, the audit team determined that this AMP is consistent with the GALL Program XI.M9, with the exception and enhancement as noted in the LRA.
B.1.10 Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)
In Appendix B.1.10 of the LRA, the applicant stated that the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) aging management program is consistent with GALL program XI.M13, "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)." This is a new program for managing loss of fracture toughness in CASS reactor internals within the scope of license renewal. The program will be implemented prior to the period of extended operation. The applicant stated that the program will include a component-specific evaluation of the loss of fracture toughness. For those components where loss of fracture toughness may affect function of the component, an inspection will be performed as part of the station ISI program.
The audit team reviewed the applicant's AMR topical report AMRTR M.14, Reactor Vessel Internals, and Request for Additional Information RAI B.1.10, dated August 7, 2003. This RAI requested confirmation that the criteria given in GALL AMP XI.M13 will be applied to determine whether loss of fracture toughness affects function of the CASS vessel internals. In addition, the applicant was asked to confirm that a supplemental inspection program that is qualified for detecting the critical flaw size with adequate margin will be provided.
In its response dated October 3, 2003, the applicant confirmed that it will apply the acceptance criteria specified in GALL AMP XI.M13 to determine whether loss of fracture toughness affects function of the CASS vessel internals. The applicant also confirmed that it will perform supplemental inspection of components that do not meet the acceptance criteria. The supplemental inspection will include an enhanced visual inspection for detecting critical flaw size in accordance with BWRVIP-03, which has the ability to achieve a 0.0005-in. resolution, as specified in GALL AMP XI.M13.
The audit team reviewed draft procedure ER-AB-331-101, Evaluation for Thermal Aging/Neutron Embrittlement of Reactor Internal Components," which confirmed that the criteria given in GALL AMP XI.M13 will be used to determine whether loss of fracture toughness affects function of the CASS vessel internals. The audit team also verified that the applicants commitment tracking system includes an action tracking item to ensure that the procedure is implemented prior to the period of extended operation.
On the basis of its review of this AMP, GALL AMP XI.M13, AMR topical report M14, the applicants response to RAI B.1.10, and the proposed implementing procedure and administrative controls, the audit team determined that this AMP is consistent with GALL AMP XI.M13.
B.1.11 Flow Accelerated Corrosion In Appendix B.1.11 of the LRA, the applicant stated that the flow accelerated corrosion (FAC) aging management program is consistent with GALL program XI.M17, Flow-Accelerated Corrosion, with an enhancement. The enhancement involves expanding the program scope to include main steam piping within the scope of license renewal.
The applicant stated that this enhancement is scheduled for implementation prior to the period of extended operation. The above enhancement noted by the applicant in the LRA has been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
The applicants FAC aging management program is based on EPRI guidelines found in NSAC-202L-R2, Recommendations for an Effective Flow Accelerated Corrosion Program. The program predicts, detects, and monitors for loss of material by wall thinning in piping, fittings, and valve bodies due to FAC. The applicant states that analytical evaluations and periodic examinations of locations that are most susceptible to wall thinning due to FAC are used to predict the amount of wall thinning in pipes and fittings. Program activities include analyses to determine critical locations, baseline inspections to determine the extent of thinning at these critical locations, and follow-up inspections to confirm the predictions. Repairs and replacements are performed as necessary. The applicant states that operating experience has shown that the program can determine susceptible locations for FAC, predict component degradation, and detect wall thinning in piping and valves due to FAC.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables for Flow-Accelerated Corrosion. The audit team also reviewed AMR topical reports AMR M05, Steam and Reactor Grade Water Environment, which is the basis document for this AMP.
On the basis of its review of this AMP, GALL AMP XI.M17, the associated program basis document, relevant RAI responses, AMR topical reports, and commitment items list, the audit team determined that this AMP is consistent with the GALL AMP XI.M17, with the enhancement as noted in the LRA.
B.1.12 Bolting Integrity Program In Appendix B, Section 1.12 of the LRA, the applicant states that its bolting integrity aging management program is consistent with GALL program XI.M18, Bolting Integrity, with the following exceptions: (1) the GALL program XI.M18 specifies that EPRI TR-104213, Bolted Joint Maintenance and Applications Guide, is used as a basis for evaluation of the structural integrity of non-safety related bolting. The Dresden and Quad Cities programs address the guidance contained in EPRI TR-104213 but do not specifically cite its use; (2) the GALL program XI.M18 specifies that the program covers all bolting within the scope of license renewal including structural bolting. The Dresden and Quad Cities bolting integrity programs do not address structural bolting. The Structures Monitoring Program (B.1.30) covers aging management of structural bolting; (3) the GALL program XI.M18 specifies that the program covers all bolting within the scope of license renewal including bolting for Class 1 NSSS component supports. The Dresden and Quad Cities bolting integrity programs do not address Class 1 NSSS component support bolts which are covered under the ASME Section XI, Subsection IWF aging management program (B.1.27); and (4) the GALL program XI.M18 specifies that the program generally includes periodic inspection for loss of preload. The Dresden and Quad Cities programs do not include inspections for loss of preload because loss of preload in a mechanical joint is a design driven effect and not an aging effect.
The applicant also identified two enhancements which will be required to make the AMP consistent with GALL program XI.M18. The program will be revised to be in accordance with the 1995 Edition through the 1996 Addenda and approved relief requests of ASME Section XI for inservice inspection of Class 1, 2, and 3 components. Also, the program will provide for formal inspections of bolted joints in diesel generator components and performing periodic inspection of components with bolted joint is in high humidity/
moisture areas (pump vaults). These enhancements will be implemented prior to the period of extended operation.
The above exceptions and enhancements noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
The applicant states that Dresden and Quad Cities have experienced isolated cases of bolting degradation attributed to aging effects due to loss of material and cracking.
System engineer walkdowns have also identified incidental surface rust on exterior component surfaces. In all cases, the existing inspection and testing methodologies have discovered deficiencies and corrective actions were implemented prior to loss of system or component intended functions.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables for Bolting Integrity Aging Management Program. The audit team also reviewed license renewal aging management program basis document M08 External Environment. The audit team noted that the applicant did not reference the pertinent EPRI document and NUREG in the implementing station procedures. The applicant agreed that it was appropriate to reference these documents and agreed to update the station procedures (License Renewal Change Request LRCR 2003-266).
On the basis of its review of this AMP, GALL AMP XI.M18, and the associated program basis document, the audit team determined that this AMP is consistent with the GALL AMP XI.M18, pending the acceptability of exceptions and enhancements as noted in the LRA and being reviewed by the NRCs technical staff.
B.1.13 Open Cycle Cooling Water System In Appendix B.1.13 of the LRA, the applicant stated that the Open Cycle Cooling Water System aging management program is consistent with GALL program XI.M20, Open Cycle Cooling Water System, with the following enhancements and exceptions: (1) the program will provide for inspection of cooling water pump internal lining, additional heat exchangers and sub-components, and inspection of external surfaces of various submerged pumps and piping; (2) the program will provide for new periodic component inspections in the pump vaults that have a high humidity/moisture environment; and (3) while NUREG-1801 specifies program testing and inspections on an annual and during refueling outage basis, the Dresden and Quad Cities open-cycle cooling water system aging management program activities provide for adjustment of inspection intervals due to specific inspection results as stated in the response to GL 89-13. The above exceptions and enhancements noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
The applicants Open-Cycle Cooling Water System program is an existing aging management program that manages loss of material, cracking, buildup of deposits and flow blockage aging effects in cooling water systems that are tested and inspected in accordance with the guidelines of GL 89-13. The applicant states that the operating experience of the Dresden and Quad Cities Nuclear Stations has shown that its open-cycle cooling water system aging management activities have detected aging degradation and implemented appropriate corrective actions to maintain system and component intended function. The applicant also states that the program consists of system test procedures, inservice testing, periodic component inspections, piping nondestructive examinations, station maintenance inspections, component preventive maintenance testing, inservice inspections, and inspections for the Class 3 portions of raw water system. The LRA credits system and component tests, visual inspections, NDE, flushing and chemical treatment to ensure that aging effects are managed such that system and component functions are maintained. The applicant also identifies that inservice inspections of the Class 3 portions of the raw water systems are also conducted to provide periodic leakage detection of the above ground and buried piping, but external surfaces of buried components are managed by the Buried Piping and Tanks Inspection Aging Management Program (AMP B.1.25).
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables for Open Cycle Cooling Water System. The audit team also reviewed license renewal aging management program basis documents M02, M04, M08, and M09, procedure ER-AA-340-1001, Revision 1, GL 89-13 Program Implementation Instructional Guide, and Action Tracking Item 101522.20.03 associated with procedure DFPP 4123-09, 2/3 Service Water to Fire System Crosstie Flow Test.
The audit team identified a discrepancy between the applicants program and the GALL program XI.M20. The GALL program XI.M20 includes inspection and monitoring of protective coating in the OCCW system. However, the applicants program, as described in its Aging Management Program Ten Element Review Tables, does not include inspection of protective coatings for aging effects. The audit team reviewed ER-AA-340-1001, Revision 1, GL 89-13 Program Implementation Instructional Guide, to determine whether protective coatings are inspected, trended, and corrected. Steps 4.3.4 through 4.3.7 do contain guidance on inspection, corrective action and trending of protective coatings. The audit team determined that although the Exelon Aging Management Program Ten Element Review Tables do not specifically mention inspection and monitoring of protective coatings, the procedural guidance reviewed does provide for the inspection, maintenance, and trending of protective coatings.
On the basis of its review of this AMP, GALL AMP XI.M20, aging management program basis documents, implementing procedures, and action tracking items, the audit team determined that this AMP is consistent with GALL AMP XI.M20, with the enhancements and exceptions noted in the LRA.
B.1.14 Closed Cycle Cooling Water System In Appendix B.1.14 of the LRA, the applicant stated that the Closed Cycle Cooling Water (CCCW) System aging management program is consistent with GALL program XI.M21, Closed Cycle Cooling Water System, with enhancements. The enhancements consist of procedure revisions to provide for monitoring of specific parameters in accordance with EPRI TR-107396 guidance and to provide for monitoring pH and ammonia in the Dresden diesel generator jacket water. The above enhancements noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
The applicants Closed-Cycle Cooling Water System program is an existing aging management program that manages loss of material, cracking and buildup of deposit through the use of preventive measures to minimize corrosion by maintaining inhibitors and by performing non-chemistry monitoring consisting of inspection and NDE based on industry-recognized guidelines of EPRI-TR-107396. The applicant states that its closed-cycle cooling water system aging management activities have detected aging degradation in heat exchangers prior to loss of system intended function. The applicants engineering evaluations have resulted in various specific component and programmatic corrective actions. The applicant also states that performance monitoring provides indications of degradation in closed-cycle cooling water systems, with plant operating conditions providing indications of degradation in normally operating systems.
Station maintenance inspections and NDE provide condition monitoring of heat exchangers exposed to closed-cycle cooling water environments.
The audit team reviewed the Exelon Aging Management Program Ten Element Review Tables for Closed Cycle Cooling Water System, Revision 2. The audit team also reviewed license renewal aging management program basis documents M02, M09, and M11, implementing procedure CY-AA-120-400, Revision 5, Closed Cooling Water Chemistry, and Action Tracking Item 101562.21.16 for the SBO diesel inspection.
On the basis of its review of this AMP, GALL AMP XI.M21, aging management program basis documents, implementing procedures, and action tracking items, the audit team determined that this AMP is consistent with GALL AMP XI.M21, with the enhancements noted in the LRA.
B.1.15 Inspection of Overhead Heavy Load and Light Loads In Appendix B.1.15 of the LRA, the applicant stated that the Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems AMP is consistent with GALL program XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, with the exception that the applicant does not provide for tracking the magnitude and number of lifts because administrative controls are implemented to ensure that only allowable loads are handled and fatigue of structural elements is not expected. The applicant also states that the enhancements will provide for specific inspections for rail wear and proper crane travel on rails, and the program will provide for specific inspections for corrosion of crane structural components. The above noted exception and enhancements have been reviewed separately by the NRCs technical staff and the results will be documented in a Safety Evaluation Report.
The AMP is credited with managing aging due to the loss of material of bridge and trolley crane components for the refueling systems. The audit team reviewed the applicants Aging Management Program Ten Element Review for Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems. The audit team also reviewed license renewal aging management program basis document AMRTR-S02, Primary Containment and Structural Steel, and the associated implementing procedures.
On the basis of its review of this AMP, GALL AMP XI.M23, aging management program basis documents, implementing procedures, and action tracking items, the audit team determined that this AMP is consistent with GALL AMP XI.M23, with the exception and enhancements as noted in the LRA.
B.1.16 Compressed Air Monitoring In Appendix B.1.16 of the LRA, the applicant stated that the compressed air monitoring aging management program is consistent with GALL program XI.M24, Compressed Air Monitoring, with the following enhancements and exceptions: (1) the program will provide for new periodic inspections for those portions of instrument air distribution piping at Dresden and Quad Cities that are within the scope of the rule; (2) the program will provide for periodic blowdowns of instrument air distribution piping at Dresden; (3)
NUREG-1801 indicates that the program is based on responses to GL 88-14 and INPO SOER 88-01, Instrument Air System Failures, as well as EPRI NP-7079-1990, EPRI-TR-108147, Compressor and Instrument Air System Maintenance Guide, ASME OM-S/G-1998, and ANSI/ISA-S7.0.01-1996. The Dresden and Quad Cities programs are based on the guidance provided in the GL 88-14 and ANSI/ISA-S7.3-1975 documents, which are part of the current licensing basis; and (4) NUREG-1801 indicates that inservice inspection and testing is performed to verify proper air quality, and confirm that maintenance practices, emergency procedures, and training are adequate to ensure that the intended function of the air system is maintained. Inservice inspections at Dresden and Quad Cities do not verify air quality because air quality testing is performed in accordance with specific procedures based on ANSI/ISA-S7.3-1975.
Maintenance practices, emergency procedures, and training are plant performance issues that are not directly related to aging management of the instrument air. Aging management consists of air quality tests and pressure decay tests of MSIV and safety/relief valve pneumatic system including accumulators, piping, and check valves, and periodic inspections to verify the integrity of the systems.
The above enhancements and exceptions noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
The compressed air monitoring aging management program activities manage loss of material due to general, crevice, and pitting corrosion for portions of the instrument air system within the scope of license renewal. Program activities consist of air quality testing, pressure decay testing, and visual inspections at various system locations.
According to the applicant, Dresden has experienced recent occurrences of corrosion, corrosion product buildup and dirt buildup in instrument air system piping, positioners, and valve operators. The program enhancement of providing periodic blowdowns of instrument air distribution piping is being done to address this condition. Testing and monitoring activities are implemented through station specific procedures and assigned tasks. The applicant indicates that Quad Cities has not experienced a failure of a pneumatic component within the scope of license renewal due to corrosion, corrosion product buildup, or dirt buildup since 1993. The Quad Cities experience is consistent with the implementation of corrective actions in response to GL 88-14.
The audit team reviewed the Exelon Aging Management Program Ten Element Review for Compressed Air Monitoring. The audit team also reviewed license renewal aging management program basis documents M01, Compressed Gas and Ventilation Air, implementing procedure DTS 4700-01, Sampling Unit 2 (3) Instrument Air, and Action Tracking Item 101562.24.02 for procedure QCOS 4700-02, Inboard MSIV and Target Rock Valve Pneumatic System Leak Test.
On the basis of its review of this AMP, GALL AMP XI.M24, aging management program basis documents, implementing procedures, and action tracking items, the audit team determined that this AMP is consistent with GALL AMP XI.M24, pending the acceptability of exceptions and enhancements noted in the LRA and being reviewed by the NRCs technical staff.
B.1.17 BWR Reactor Water Cleanup System In Appendix B.1.17 of the LRA, the applicant stated that the BWR reactor water cleanup system aging management program is consistent with GALL program XI.M25, "BWR Reactor Water Cleanup System," with the exception that the Dresden and Quad Cities water chemistry programs are based on EPRI-TR-103515-Rev. 2, while the GALL program references Revision 1. This exception is also discussed in paragraph B.1.2, Water Chemistry Program, of this audit report.
The applicant states that Dresden and Quad Cities have satisfactorily completed all actions requested in NRC GL 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance, and have replaced the RWCU system piping with piping that is resistant to IGSCC in accordance with NRC GL 88-01, NRC Position on Intergranular Stress Corrosion Cracking (IGSCC) in BWR Austenitic Stainless Steel Piping." The applicant concluded that inspection of RWCU piping is not required. The applicant stated that operating experience has shown that, since replacing the RWCU system piping with IGSCC-resistant piping, there have been no adverse trends detected in the chemistry program.
The audit team reviewed AMRTR-M.05, Steam and Reactor Grade Water Environment. In addition, the staff position delineated in Generic Letter 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping was compared with the actions taken at Dresden/Quad Cities. The audit team also examined the ISI Program Plan 4th 10-Year Inspection Interval (Dresden 2 & 3). Relevant exceptions to the BWR water chemistry guidelines are discussed under AMP B.1.2, Water Chemistry.
During the audit, the audit team confirmed the following technical information relating to this AMP with the applicant at the request of the NRCs technical staff:
All in-scope portions of the RWCU system piping outboard of the second isolation valves were replaced with ASTM SA312 or SA376 Gr. TP316L with a carbon content of less than 0.035%. RWCU piping inboard of the second isolation valve has not been replaced with IGSCC resistant piping.
The RWCU piping that is inboard of the second isolation valve is Class 1 and 2 piping that is managed by the ISI Program (B.1.1), ASME Section XI, Subsections IWB, IWC, and IWD. All the RWCU piping and welds on the in-scope portion outboard of the second isolation valves were replaced. The replacement piping and weld metal does meet the material compositions as described in NUREG-1801, AMP XI.M25.
All the RWCU piping and welds on the in-scope portion outboard of the second isolation valves were replaced with piping and weld material that meet the material compositions as described in NUREG-1801, AMP XI.M25. Screening criteria 1(a),
(b), and (c) of NUREG-1801, AMP XI.M25 do not apply to this piping.
In a letter to the NRC, dated August 20, 1993, the licensee committed to replace all RWCU IGSCC susceptible outboard supply and return line piping and the regenerative heat exchangers with IGSCC resistant materials at both Dresden and Quad Cities.
License Renewal Boundary Drawings LR-DRE-M-30 and LR-QDC-M-47-1 show the piping design table for the in-scope portion of the RWCU piping outboard of the second isolation valves to be table AQ. Dresden specification K-4080 and Quad Cities specification R-4411 provide the material specification for piping design table AQ. Design table AQ provides the information on the piping material: all in-scope portions of the RWCU system piping outboard of the second isolation valves were replaced with ASTM SA312 or SA376 Gr. TP316L with a carbon content of less than 0.035%.
Based on the above information, the applicant confirmed that the ten elements of the GALL program, "BWR Reactor Water Cleanup System," as specified in NUREG-1801, AMP XI.M25 (with the exception of Water Chemistry Program as noted in the LRA) are applicable to Dresden and Quad Cities, and that the applicants program B.1.17 is consistent with GALL AMP XI.M25, with the exception as noted in the LRA.
On the basis of its review of this AMP, GALL AMP XI.M25, AMR topical report M.05, and the ISI Program plan, the audit team determined that this AMP is consistent with GALL AMP XI.M25, with the exception as noted in the LRA.
B.1.18 and B.1.19 Fire Protection and Fire Water System In Appendices B.1.18 and B.1.19 of the LRA, the applicant states that the Dresden and Quad Cities fire protection and fire service water AMPs are consistent with the GALL AMP XI.M26, Fire Protection, and GALL AMP XI.M27, Fire Service Water, programs, respectively. The applicant also identifies exceptions and enhancements in Appendices B.1.18 and B.1.19 of the LRA. These exceptions and enhancements were reviewed separately by the NRCs technical staff and the results will be documented in a Safety Evaluation Report.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables for the fire protection and fire water systems. The audit team also reviewed the Dresden and Quad Cities fire protection program AMR topical report M15, which is the basis documents for these AMPs, as well as the site fire protection program document, CY-AA-211, and the applicants responses to RAIs B.1.18-1 and B.1.19-2. The audit team determined that the applicants fire protection program differed from the GALL AMP XI.M26 in two attributes: Monitoring and Trending and Corrective Action.
The GALL AMP XI.M26, Monitoring and Trending attribute specifies visual inspection of penetration seals to detect cracking, seal separation from walls and components, and rupture and puncture of seals. The visual inspection (VT-1 or equivalent) of 10% of each type of seal in walkdowns is performed at least once every refueling outage. If any sign of degradation is detected within that 10%, the scope of the inspection and frequency is expanded to ensure timely detection of increased hardness and shrinkage of the penetration seal before the loss of the component intended function. The applicants fire protection implementing procedures, DFPS 4175-02 and DFPS 4175-03, require a sampling of 10% of the penetration seal population. However, the acceptance criteria stated in these procedures is that the percentage of inoperable seals should be less than 5% of the sample population. The audit team therefore determined that the applicants fire protection program, as currently implemented, is not consistent with GALL.
In the Corrective Action attribute, The GALL AMP states that the frequency of inspection will be expanded whenever the inspection identifies inoperable fire protection seals. However, the Dresden and Quad Cities fire protection program does not expand the seal inspection sample frequency but relies on the corrective action process to determine whether a change in frequency is necessary. This difference is considered an exception to the GALL which was not captured in the Dresden and Quad Cities LRA or RAI responses.
During a follow-up audit on March 15-17, 2004, the applicant stated that the Dresden and Quad Cites fire protection aging management program will be revised to perform a visual inspection (VT-1 or equivalent) on a 10% sample population of each type of fire seal on a refueling outage frequency. Additionally, the program will be revised to expand the sample population by 10% if any of the inspected seals are found to have abnormal degradation that could prevent the seal from performing its intended function.
The sample population will continue to increase until a 10% fire seal sample population shows no abnormal degradation or significant change in appearance. The applicant stated that the program enhancements will be implemented prior to the extended period of operation. The audit team determined that this enhancement to the program will make the applicants program consistent with the GALL AMP XI.M26. The audit team verified that this enhancement was included in the applicants formal commitment as documented in the Safety Evaluation Report (SER) with Open Items dated February 2004.
The applicant stated that the Exelon Fire Protection Program takes exception with the NUREG 1801 criteria to expand the seal inspection sample frequency. The frequency of inspection is automatically expanded by the fact that the sample population increases when abnormal degradation is found. The frequency returns to a refueling outage frequency when no abnormal degradation is found in a 10% sample population. If any of the seal inspections identify age related degradation, then a condition report will be generated to document the degradation in the corrective action process. The corrective action process will determine whether a change in frequency is necessary. The audit team determined that this exception is acceptable since the applicants proposed enhancement will automatically expand the frequency of inspection by the fact that the sample population increases when abnormal degradation is found.
On the basis of its review of the Dresden and Quad Cities fire protection and fire service water AMPs, the associated program basis document AMR M05, implementing procedures, and responses to RAIs, the audit team determined that the Dresden and Quad Cities fire protection/fire water system programs are consistent with the GALL, with an additional enhancement and an additional exception that were not previously captured in the LRA or RAI responses.
B.1.20 Aboveground Carbon Steel Tanks In Appendix B.1.20 of the LRA, the applicant stated that the aboveground carbon steel tanks AMP is consistent with GALL program XI.M29, Aboveground Carbon Steel Tanks, with an enhancement. The enhancement will provide for initiating documentation of inspection results of periodic system engineer walk-downs of the nitrogen storage tanks. The LRA contains a commitment that this enhancement will be implemented at both Dresden and Quad Cities prior to the period of extended operation.
The applicants above ground carbon steel tanks aging management program provides for management of loss of material aging effects for outdoor carbon steel nitrogen storage tanks. The program also provides for the application of paint as a corrosion preventive measure and for periodic visual inspections to monitor degradation of the paint and any resulting metal degradation. The LRA notes that the Dresden and Quad Cities outdoor carbon steel storage tanks have not experienced leakage or degradation due to loss of material. The applicant states that the nitrogen storage tanks are above ground and are not directly supported by earthen or concrete foundations. Therefore, inspection of the sealant or caulking at the tank/foundation interface and inspection of inaccessible tank locations does not apply.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables for aboveground carbon steel tanks. The audit team also reviewed license renewal aging management program basis documents M08, External Environment.
The audit team determined that the applicant had added an exception to the Program Scope attribute, namely, the inclusion of aluminum storage tanks. The applicant had originally grouped the above ground aluminum tanks in AMP B.1.25, Buried Piping and Tanks Inspection. In RAI B.1.25, the staff questioned the relevance of B.1.25 for the aboveground aluminum tanks. The applicants response to RAI B.1.25 stated that the correct AMP should have been B.1.20. The applicant has since revised AMP B.1.20 to implement this position.
On the basis of its review of this AMP, the associated program basis document, the applicants response to RAI B.1.25, the relevant station administrative procedure and a sample of implementing procedures, the audit team determined that this AMP is consistent with GALL program XI.M29, with the enhancement noted in the LRA and the exception noted in the RAI response.
B.1.21 Fuel Oil Chemistry In Appendix B.1.21 of the LRA, the applicant stated that the fuel oil chemistry AMP is consistent with GALL program XI.M30, Fuel Oil Chemistry with the following enhancements and exceptions:
The fuel oil chemistry program will provide for inspection of the fuel oil storage tank interiors for corrosion during the regularly scheduled tank cleaning and the performance of engineering evaluations in the event corrosion of the tank interiors is found. The applicant stated that the enhancement is scheduled for implementation at Dresden and Quad Cities prior to the period of extended operation.
Corrosion mitigation activities are not performed for the Quad Cities Unit 1 underground fuel oil storage tank because it is constructed of fiberglass.
The Dresden and Quad Cities programs use ASTM D2709 as specified by ASTM D975 for analysis of grades 1-D and 2-D fuel used at the stations.
The Dresden and Quad Cities programs use ASTM D5452 as the preferred method of analysis.
Dresden and Quad Cities particulate tests utilize filters with a pore size of 0.8 µm instead of 3.0 µm because 0.8 µm filters provide conservative results. The applicant stated that the use of 0.8 µm filters is consistent with use of ASTM D5452.
Quad Cities does not add stabilizers because grade 1-D low sulfur fuel oil is used and stored fuel is periodically sampled and analyzed for quality. Dresden and Quad Cities do not add corrosion inhibitors because fuel oil storage tank bottoms are periodically sampled and analyzed for corrosion products in accordance with ASTM D4057 and ASTM D2709. Dresden and Quad Cities employ sample techniques and particulate contamination detection methods that identify fuel degradation or the presence of corrosion products at an early stage.
Dresden and Quad Cities emergency diesel generator do not have the capability of being sampled. As an alternative, Dresden and Quad Cities sample for water and sediment from the bottom of the associated storage tanks quarterly and particulate from the fuel oil transfer pump discharge line on a monthly basis in accordance with approved procedures. The applicant does not perform multilevel sampling of other fuel oil day tanks (isolation condenser makeup pump [Dresden only], fire pump, and station blackout) because the tanks are small and experience a high turnover of fuel due to routine diesel engine operations. Additionally, ASTM D4057, Table 4, Spot Sampling Requirements, indicates that multilevel sampling is not required for tanks with a capacity less than 42,000 gallons. The fuel oil storage tanks and day tanks at Dresden and Quad Cities are 15,000 gallons or smaller.
At Dresden, the results of analysis of new fuel oil are reviewed for acceptability, but are not trended. In the event the quantitative oil acceptance criteria in plant procedures are approached or exceeded the fuel oil is restored to within limits or an action request or condition report is initiated.
These enhancements and exceptions have been reviewed separately by the NRCs technical staff and the results will be documented in a Safety Evaluation Report.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables for fuel oil chemistry. The audit team also reviewed the aging management program basis document AMRTR-M03, Oil/Fuel Oil, implementing procedure DOS 6600-01, Diesel Generator Surveillance Tests, and Action Tracking Item 101562.30.03 for procedure CY-QC-110-630, Diesel Fuel Oil Sampling.
The audit team identified a potential discrepancy in the Detection of Aging Effects attribute between the applicants program and GALL program XI.M30. GALL program XI.M30 specifies that an ultrasonic testing (UT) measurement of the tank bottom surface ensures that significant degradation is not occurring. The audit team reviewed the ten element comparison tables and the implementing procedure for the applicants AMP to determine if the requirement for UT measurements had been included. The tables and the procedure did not contain the requirement. This difference had not been identified as an exception in the LRA. The applicant stated that it does plan to perform fuel oil tank UT thickness measurements to verify the effectiveness of the fuel oil chemistry program. The UT thickness checks are described in Exelon Ten Element Table for Aging Management Program B.1.23H, One-Time Inspection of Lubricating Oil and Fuel Tank Bottoms, Piping and Components, and HPCI Lubricating Oil Flexible Hoses. The audit team reviewed the B.1.23H program (described in paragraph B.1.23 of this audit report), and concluded that the B.1.23H program does address UT measurement of the tank bottom surface, consistent with GALL program XI.M30. The audit team notes that the applicant has generated License Renewal Change Request 2003-303 to add a cross-reference to the B.1.23H one-time inspection program in the Ten Element Table for the Fuel Oil Chemistry Program.
On the basis of its review of this AMP, aging management program basis documents, implementing procedure, and an action tracking item, the audit team determined that this AMP is consistent with GALL program XI.M30, pending the acceptability of the exceptions and enhancements as noted in the LRA and being reviewed by the NRCs technical staff.
B.1.22 Reactor Vessel Surveillance In Appendix B.1.22 of the LRA, the applicant stated that the reactor vessel surveillance AMP is consistent with GALL program XI.M31, "Reactor Vessel Surveillance," with enhancements. The program is implemented through station procedures that conform to the requirements of 10 CFR Part 50, Appendix H, Reactor Vessel Material Surveillance Program Requirements. Neutron embrittlement for the period of extended operation is predicted using the chemistry tables and Position 1.3, Limitations, as described in RG 1.99, Revision 2, Radiation Embrittlement of Reactor Vessel Materials.
The applicant has enhanced the program by making it consistent with BWRVIP-78, BWR Vessel and Internals Project: BWR Integrated Surveillance Program Plan, BWRVIP-86, BWR Vessel and Internals Project: BWR Integrated Surveillance Program Implementation Plan, and the corresponding NRC safety evaluation reports. The enhanced program provides for capsule testing consistent with BWRVIP-78 and BWRVIP-86 saving the withdrawn capsules for future reconstitution. Existing capsules not included in the integrated surveillance program will be maintained in the vessels as a contingency for the future. The applicant stated that the enhanced program will be consistent with GALL AMP XI.M31, Reactor Vessel Surveillance.
The audit team reviewed the Exelon Aging Management Program Review tables for reactor vessel surveillance (GALL AMP XI.M31 has a different format with 8 elements).
The audit team reviewed AMR M13, Reactor Pressure Vessel, RAI B.1.22, and a proposed revision to the Dresden/Quad Cities UFSAR. The proposed UFSAR revision states, Prior to the period of extended operation the program will be consistent with BWRVIP-78, Integrated Surveillance Program, and BWRVIP-86, BWR Integrated Surveillance Program Implementation Plan. This statement addresses the issue raised in the RAI. Action Tracking Item ATI 162518.01 contains the applicants commitment to enhance the procedure for reactor vessel surveillance.
On the basis of its review of this AMP, AMR topical report M13, and the applicants commitment to enhance this AMP to endorse the on BWRVIP-78 and -86, the audit team determined that this AMP is consistent with GALL AMP XI.M31.
B.1.23 One-Time Inspection In Appendix B.1.23 of the LRA, the applicant stated that the new one-time inspection program is consistent with GALL program XI.M32, One-Time Inspection. The applicant has developed 13 separate ten element comparison tables for each system/component listed in the Appendix B.1.23 of the LRA:
One-Time Inspection - Torus Chemistry Verification (B.1.23A)
One-Time Inspection - ADS Piping (B.1.23B)
One-Time Inspection - Ventilation Systems (B.1.23C)
One-Time Inspection - Compressed Gas Systems (B.1.23D)
One-Time Inspection - HPCI and RCIC (Quad Cities Only), LPCI (DresdenOnly),
and RHR (Quad Cities Only) (B.1.23E)
One-Time Inspection - Vent and Drain Management (B.1.23F)
One-Time Inspection - (AMR M02 NSR / SR Interaction) (B.1.23G)
One-Time Inspection of Lubricating Oil and Fuel Tank Bottoms, Piping and Components, and HPCI Lubrication Oil Flexible Hoses (B.1.23H)
One-Time Inspection of Condensate Water Components (B.1.23I)
One-Time Inspection - Cracking in Class 1 Piping Less Than 4 Inch NPS Exposed to Reactor Coolant (B.1.23J)
One-Time Inspection - SBLC Chemistry Verification (B.1.23K)
One-Time Inspection - Lubrite Base Plates (B.1.23L)
Fuel Pool Cooling and Demineralizer System Pipe Inspection (Dresden Only)
(B.1.23M)
GALL program XI.M32, One-Time Inspection, specifies that the elements of the program include (a) determination of the sample size based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience; (b) identification of the inspection location in the system or component based on the aging effect; (c) determination of the examination technique, including acceptance criteria that would be effective in managing the aging effect for which the component is examined; and (d) evaluation of the need for follow-up examinations to monitor the progression of any aging degradation.
The audit team determined that the applicants methodology for determining representative samples and sample size for One-Time inspection was weak with no documented basis. For example, the ten element aging management program table for B.1.23A, One-Time Inspection-Torus Chemistry Verification, Revision 3, specifies an UT inspection of one ECCS suction strainer flange at one of the four units, and visual inspection of a HPCI torus suction check valve at each site; however, there was no documented engineering basis to demonstrate that the components selected were representative of torus water chemistry conditions at all four units.
During a follow-up audit on March 15-17, 2004, the applicant provided the audit team a sample basis document for One-Time inspections which described basis for selected samples and sample population, as well as sample expansion criteria. The applicant also increased the sample sizes for several of the One-Time inspections including B.1.23A. As a result of this audit, the AMP inspection and various RAIs, the applicant intended to make many changes to the One-Time inspection program, in addition to developing several periodic inspection programs rather than relying only on One-Time inspections. Some changes to the One-Time and periodic inspection programs were included as commitments in the SER with open items dated February 2004. The applicant stated that other changes identified since the SER with open items was issued, will be documented as commitments in the response to the SER with open items due April 16, 2004.
On the basis of its review of the AMP, the associated program basis document, implementing procedures, responses to relevant RAIs, and the program enhancements, the audit team determined that the applicants aging management program is consistent with the GALL program XI.M32.
B.1.24 Selective Leaching In Appendix B.1.24 of the LRA, the applicant stated that the Selective Leaching of Materials AMP is consistent with GALL program XI.M33, "Selective Leaching of Materials," with a noted exception. The applicant has taken an exception to hardness testing for identification of selective leaching in components. The GALL Program XI.M33 recommends both visual inspection and Brinell hardness testing to assess the potential for selective leaching. The technical justification for this exception was included in the applicants response to RAI B.1.24, and it was reviewed by the NRCs technical staff. The review results will be documented in a Safety Evaluation Report.
The Selective Leaching of Materials aging management program consists of numerous One-Time inspections to determine if selective leaching of materials is occurring. The scope of the program includes susceptible components within the scope of license renewal that are exposed to chemically treated water, demineralized water, raw water and ground water, and moist ventilation and gas environments. Susceptible component materials are gray cast iron, copper alloys with less than 85% copper, aluminum-bronze, and Muntz metal.
The LRA indicates that this new program will consist of One-Time inspections including visual inspection or other appropriate examination methods of components of the different susceptible materials selected from each applicable environment. The purpose of the program is to determine if loss of material due to selective leaching is occurring.
If selective leaching is occurring, the program provides for evaluation as to the effect it will have on the ability of the affected components to perform their intended function for the period of extended operation, and the need to expand the sample of components to be tested. The applicant states that the Dresden and Quad Cities Selective Leaching of Materials program will be implemented prior to the period of extended operation.
The audit team reviewed the Exelon Ten Element Aging Management Program Review tables for selective leaching, as well as the applicable basis documents AMRTRs. The audit team identified the following discrepancies:
The GALL Selective Leaching AMP specifies that inspection in support of this AMP be completed just before the beginning of the license renewal period; however, the applicants Ten Element Aging Management Program Review tables for selective leaching states that inspections may be performed anytime prior to the period of extended operations. This exception to GALL is not identified as an exception nor is any bases provided to support such an exception.
The GALL Selective Leaching AMP specifies that brass and bronze components within treated water systems be inspected for selective leaching; however, the applicants Ten Element Aging Management Program Review tables for selective leaching and the associated implementing documents do not include requirements for inspection of brass and bronze components within treated water systems. The AMRTR-M11 for Chemically Treated Water does identify that the Selective Leaching AMP is applicable for managing specific aging effects in components subject to chemically treated water environments within the boundary of license renewal, however selective leaching inspections for treated water systems are not included in current program implementing documents or commitment matrixes.
Contrary to the AMP description contained in the ten element comparisons table, certain AMP elements are not captured in the program documents which implement the Selective Leaching AMP. The ten element comparison table states that follow-up examinations or evaluations will be performed on component material samples where indications of selective leaching is identified and that additional analysis as part of the engineering evaluation is required including requirements for additional component inspections of like materials in a like environment. This requirement is not captured in either the work activity or in the commitment tracking program. The work instruction merely states that when evidence of selective leaching is present that a CR be generated. Although the generic CR process does require and investigation be completed, the specific requirements of this AMP for what must be included in this evaluation are not captured.
In the area of Operating Experience, the GALL selective leaching AMP does acknowledge that this is a new program and states that this program should be consistent with years of industry practice; however, the applicants ten element comparison table states that operating experience is not applicable to this program because it is a new program. The AMRTR documents that credit this AMP also do not identify any operating experience related to this AMP. The ten element comparison table states that for operating experience, the effectiveness of detecting this specific aging mechanism will be assessed at the time when the inspection are performed, however no commitments or implementing documents capture this commitment.
While each individual discrepancies noted above can be considered relatively minor in significance, the audit team concluded that, in the aggregate, the applicants selective leaching program, as found, may reduce the effectiveness of the GALL program XI.M33.
During a follow-up audit on March 15-17, 2004, the audit team noted that the applicant had not yet revised the ten element program description for the selective leaching program to remove the words may be performed anytime and replace them with just before. The applicant has defined just before as during the last 5 years of the current operating license. A license renewal change request existed to make the changes during a future update of the program documents. The applicant agreed with the audit team that the sample population should include components that contain a chemically treated environment. As such, the applicant committed to replace 3 of the 10 sample components at each site with components that contain a chemically treated environment.
The applicant also committed to revise the work request instruction and the associated action tracking file that will provide additional instructions for ensuring that the proper analysis is performed if selective leaching is discovered during any of the inspections.
The additional instructions will also provide guidance concerning additional component selections. The applicant concurs that the effectiveness of the selective leaching program should be evaluated once the scheduled inspections have been completed.
The applicant committed to develop an action tracking item at each site to evaluate the collective results of each selective leaching inspection and determine the effectiveness of detecting this specific aging mechanism. The action tracking file will contain sufficient direction to ensure that corrective actions will be taken to improve inspection techniques and select additional sample locations if the original inspections are proven to be ineffective.
The applicant indicated that the commitments associated with the Selective Leaching aging management program would be included in the applicants response letter to the SER with open items. With the appropriate commitments indicated above the audit team determined that these enhancements to the program will ensure the applicants program is consistent with GALL.
B.1.25 Buried Piping and Tanks Inspection The applicants Buried Piping and Tanks Inspection aging management program is discussed in LRA Section B.1.25, Buried Piping and Tanks Inspection. The applicant states that with enhancements, the program is consistent with the ten elements of GALL aging management program XI.M34, Buried Piping and Tanks Inspection. The applicants program consists of preventive and condition monitoring measures to manage loss of material due to corrosion from external environments for buried piping and tanks in the scope of license renewal. This AMP will be implemented at Dresden and Quad Cities prior to the period of extended operation.
The applicants program takes exception to GALL aging management program XI.M34 which specifies that buried piping and tanks are inspected when they are excavated during maintenance. The applicant stated that access to buried components does not occur on specified frequencies, therefore the applicants program includes the use of piping and component coatings and wrappings, and enhancements that include periodic pressure testing, buried tank leakage checks, inspections of buried tank internal surfaces, and inspections of the ground above buried tanks and piping. The program enhancements also include one-time internal ultrasonic testing (UT) of buried steel tanks, a one-time internal UT of the bottom of an outdoor aluminum storage tank, and a one-time visual inspection of the external surface of a buried piping section. The above enhancements and exceptions noted by the applicant in the LRA have been reviewed separately by the NRCs technical staff, and the results will be documented in a Safety Evaluation Report.
The audit team reviewed the applicants ten element comparison table for this AMP.
The audit team also reviewed the license renewal aging management program basis document M08, External Environment. GALL aging management program XI.M34 specifies periodic inspection of coatings and wrappings to ensure that corrosion of external surfaces has not occurred. Since plant operating experience demonstrated that excavation of piping is infrequent, it is not likely that the occasion to visually inspect the external surfaces of the piping would occur. The applicant proposed a series of test and a one-time inspection of buried fire protection piping to ensure that leakage would be detected. The audit team determined that alternate approach to detection of aging effects was acceptable.
On the basis of its review of this AMP, GALL AMP XI.M34, and the associated program basis document, the audit team determined that this AMP is consistent with the GALL AMP XI.M34, pending the acceptability of the exceptions and enhancements noted in the LRA and being reviewed by the NRCs technical staff.
B.1.26 ASME Section XI, Subsection IWE The Quad Cities program complies with Subsection IWE for steel containments (Class MC) of ASME Section XI, 1992 Edition including 1992 Addenda. The Dresden program utilizes a relief request. The relief request permits utilization of the 1998 Edition of Subsection IWE of ASME Section XI in its entirety instead of the 1992 Edition and Addenda. The applicant states that the ASME Section XI, Subsection IWE aging management program is consistent with the ten elements of GALL aging management program XI.S1, "ASME Section XI, Subsection IWE," specified in NUREG-1801, with the following exceptions:
NUREG-1801 indicates that ASME Section XI, Subsection IWE and the additional requirements specified in 10 CFR 50.55a(b)(2) constitute an existing mandated program applicable to managing aging of a steel containment. The NUREG-1801 evaluation covers both the 1992 Edition with the 1992 Addenda and the 1995 Edition with the 1996 Addenda of ASME Section XI, Subsection IWE, as approved in 10 CFR 50.55a. The Dresden program utilizes a relief request. The Dresden program is based on the 1998 Edition of Subsection IWE of ASME Section XI as provided for in Relief Request MCR-02.
NUREG-1801 indicates that pressure retaining weld visual examinations and pressure retaining dissimilar metal welds surface examinations are optional. These requirements are not part of the Dresden program because it is based on the 1998 Edition of Subsection IWE of ASME Section XI as provided for in Relief Request MCR-02.
NUREG-1801 indicates that bolt preload is checked by either a torque or tension test. The Dresden and Quad Cities programs do not provide for checking of bolt preload by either torque or tension test because acceptance is based on Appendix J testing of associated bolted components and general visual examination. This practice is consistent with Dresden Relief Request MCR-02 and Quad Cities Relief Request CR-24.
NUREG-1801 indicates that the program provides for examination of seals, gaskets and moisture barriers by visual methods prescribed in ASME Section XI, Subsection IWE The Dresden program uses Relief Request MCR-02 and the Quad Cities program uses Relief Request CR-21 as the basis for not routinely inspecting seals and gaskets, and the extent of surface examination of moisture barriers. Aging management program 10 CFR Part 50, Appendix J (B.1.28) provides for monitoring of seals and gaskets. Seals and gaskets are inspected only when sealed or gasketed components are disassembled for maintenance. Moisture barriers, which are accessible, are examined for tears, cracks or other damage that would allow intrusion of moisture, using general visual criteria.
These exceptions have been reviewed separately by the NRCs technical staff and the results will be documented in a Safety Evaluation Report.
As described in LRA Section B.1.26, the ASME Section XI, Subsection IWE aging management program is credited with managing aging of the primary containment for loss of material. The basic program requires visual examination. Limited surface or volumetric examination is conducted when IWE requires augmented examination. It is implemented through station plans and procedures and covers steel containment shells and their integral attachments.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables for this program. The audit team also reviewed AMR topical report (AMP Basis Document): S02, Primary Containment and Structural Steel, implementing procedures Dresden Units 2 & 3 ISI Program Plan for the 4th 10 Year Inspection Interval, ER-AA-330, Conduct of Inservice Inspections, and the applicants response to RAI B.1.26 and found it acceptable.
On the basis of its review of this AMP including the associated program basis document, responses to relevant RAI, and by sampling site implementing procedures and commitments (action tracking items), the audit team determined that this AMP is consistent with the corresponding GALL AMP XI.S1, with the exceptions noted in the LRA.
B.1.27 ASME Section XI, Subsection IWF The applicant states in LRA Section B.1.27 that, with an enhancement, the ASME Section XI, Subsection IWF aging management program is consistent with the ten elements of GALL aging management program XI.S3, "ASME Section XI, Subsection IWF," specified in NUREG-1801. The ASME Section XI, Subsection IWF aging management program is credited for visual examination of component and piping supports within the scope of license renewal for loss of material and loss of mechanical function aging effects. The program is implemented through station procedures, which provide for visual examination of inservice inspection Class 1, 2, and 3 supports in accordance with the requirements of ASME Section XI, Subsection IWF, 1989 Edition and Code Case N-491-1. The applicant states that, for license renewal, the program will be enhanced (scheduled for implementation prior to the period of extended operation) to provide for inspection of Class MC component supports consistent with NUREG-1801, Chapter III, Section B1.3. This enhancement has been separately reviewed by the NRCs technical staff and the results will be documented in a Safety Evaluation Report.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables for this program. The audit team also reviewed AMR topical report AMRTR-S05, "Component Supports," which is the applicants basis document for this AMP, and the applicants response to RAI B.1.27 and found it acceptable.
On the basis of its review of this AMP including the associated program basis document, responses to relevant RAI, and by sampling site implementing procedures and commitments (action tracking items), the audit team determined that this AMP is consistent with the corresponding GALL AMP XI.S3, with the enhancement as noted in the LRA.
B.1.28 10 CFR Part 50, Appendix J In Appendix B.1.28 of the LRA, the applicant states that the 10 CFR Part 50, Appendix J aging management program is consistent with GALL program XI.S4. The 10 CFR Part 50, Appendix J aging management program is credited for aging management of pressure boundary degradation due to loss of material in the primary containment and various systems penetrating primary containment. The program also manages changes in material properties of gaskets, O-rings, and packing materials for the primary containment pressure boundary access points.
The program consists of tests performed in accordance with the regulations and guidance provided in 10 CFR 50 Appendix J, Primary Reactor Containment Leakage Testing for Water-Cooled Power Reactors, Option B, Regulatory Guide 1.163, Performance-Based Containment Leak-Testing Program, NEI 94-01, Industry Guideline for Implementing Performance-Based Options of 10 CFR Part 50, Appendix J, ANSI/ANS 56.8, Containment System Leakage Testing Requirements, and station procedures. Containment leak rate tests are performed to assure that leakage through the primary containment and systems and components penetrating primary containment does not exceed allowable leakage limits specified in the Technical Specifications. An integrated leak rate test (ILRT) is performed during a period of reactor shutdown at the frequency specified in 10 CFR Part 50, Appendix J, Option B. Local leak rate tests (LLRT) are performed on isolation valves and containment access penetrations at frequencies that comply with the requirements of 10 CFR 50 Appendix J, Option B.
Under Operating Experience, the applicant indicates that the industry has found that 10 CFR Part 50, Appendix J testing has been effective in maintaining the pressure integrity of the containment boundaries, including identification of leakage within the various systems pressure boundaries. The Dresden and Quad Cities facilities have demonstrated experience in effectively maintaining the integrity of the containment boundaries as evidenced by the selection of Option B of 10 CFR 50 Appendix J leakage testing requirements. Both stations have experienced "as found" LLRT results in excess of individual containment penetration administrative limits. Evaluations were performed and corrective actions were taken to restore the individual penetration leakage rates to within the established administrative leakage limits in accordance with the Appendix J testing program.
The audit team reviewed the Exelon Aging Management Program Ten Element Review table for the 10 CFR Part 50, Appendix J for AMP B.1.28. The audit team compared the attributes of B.1.28 to XI.S4, and found that the applicant had addressed all the attributes of XI.S4. The audit team also reviewed AMR topical report AMRTR-S02, "Primary Containment and Structural Steel," which is the applicants basis document for this AMP, and the associated implementing procedures. On the basis of its review of this AMP, GALL AMP XI.S4, the associated program basis document, license renewal change requests and commitment items list, the audit team determined that this AMP is consistent with GALL AMP XI.S4.
B.1.29 Masonry Wall Program In Appendix B.1.29 of the LRA, the applicant stated that the masonry wall AMP is consistent with GALL program XI.S5, Masonry Wall Program. The masonry wall program, which is part of the structures monitoring program, is based on guidance provided in I. E.Bulletin 80-11, Masonry Wall Design, and Information Notice 87-67, Lessons Learned from Regional Inspections of Licensee Actions in Response to I. E.Bulletin 80-11, and is implemented through station procedures. The program provides for inspections of masonry walls within the scope of license renewal for cracking. The program includes all masonry walls that perform intended functions in accordance with 10 CFR 54.4, and is credited for management of aging effects so that the established evaluation basis for each masonry wall within the scope of license renewal remains valid through the period of extended operation.
The audit team reviewed the Exelon Aging Management Program Ten Element Review table comparing GALL AMP XI.S5, Masonry Wall Program and the corresponding attributes of the Dresden and Quad Cities AMP B.1.29. The audit team also reviewed AMR topical report AMRTR-S01, which is the applicants basis document for this AMP, and the associated implementing procedure, ER-MW-450 Structures Monitoring.
On the basis of its review of this AMP, GALL AMP XI.S5, the associated program basis document, license renewal change requests and commitment items list, the audit team determined that this AMP is consistent with GALL AMP XI.S5.
B.1.30 Structures Monitoring Program In Appendix B.1.30 of the LRA, the applicant stated that, with enhancements, this AMP is consistent with GALL AMP XI.S6, Structures Monitoring Program, with the following enhancements: (1) the program will provide for periodic reviews of chemistry data on below-grade water to confirm that the environment remains non-aggressive for the license renewal term for the aging mechanisms of corrosion of embedded steel and aggressive chemical attack of concrete; (2) the program will provide for inspections of structural steel components in secondary containment, flood barriers, electrical panels and racks, junction boxes, instrument racks and panels, offsite power structural components and their foundations, and the Quad Cities discharge canal weir as part of the ultimate heat sink; (3) the program will provide for inspection of a sample of non-insulated indoor piping external surfaces at locations immediately adjacent to periodically inspected piping supports; (4) program procedures will reference specific insulation inspection criteria for existing cold weather preparation and inspection procedures for outdoor insulation, and establish new inspections for various indoor area piping and equipment insulation; (5) the program will provide for inspection parameter specificity for non-structural joints, roofing, grout pads, and isolation gaps; and (6) the program will extend inspection criteria to the structural steel, concrete, masonry walls, equipment foundations, and component support sections of the program to provide consistency with NUREG-1801 component supports. Enhancements are scheduled for implementation prior to the period of extended operation. These enhancements have been reviewed separately by the NRCs technical staff and the results will be documented in a Safety Evaluation Report.
The structures monitoring program is credited for aging management of various structures and external surfaces of mechanical components within the scope of license renewal. The program, which was developed for structures monitoring under 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, is based on the guidance in Regulatory Guide 1.160 Revision 2, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and NUMARC 93-01 Revision 2, Industry Guidelines for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and implemented through procedures. The program includes monitoring of below-grade water chemistry to demonstrate that the environment remains non-aggressive. The program is not credited for managing protective coatings. The program will provide for visual inspections of structures and components not included in the ASME Section XI, Subsection IWF (B.1.27) aging management program.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables comparing the attributes of this AMP to GALL AMP XI.S6. The audit team also reviewed the applicants responses to RAIs 3.3-7, 3.5-12 and B.1.30. RAI B.1.30 clarified the implementing procedure for structural steel, concrete, masonry walls, equipment foundations, and component support sections. RAI 3.3-7 addressed both corrosion and the use of the Structures Monitoring Program for managing the aging effects of non-structural components in the service water systems.
The audit team reviewed implementing procedure ER-MW-450, Structures Monitoring, and verified entries related to a sample of the enhancements listed in B.1.30 and items addressed in the RAIs responses. Action Tracking Items were sampled for commitments that address inspections and preventive maintenance activities pertaining to aging management. These commitments require changes to various procedures, including ER-MW-450.
On the basis of its review of this AMP, the associated program basis document, responses to relevant RAIs, implementing procedure, and the commitment tracking list, the audit team determined that this AMP is consistent with the GALL AMP XI.S6, with the enhancements as noted in the LRA.
B.1.31 RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants In Appendix B.1.31 of the LRA, the applicant stated that, with enhancements, the Dresden and Quad Cities AMP for RG 1.127 inspection of water-control structures associated is consistent with GALL program XI.S7, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants, with the following enhancements: (1) the program will provide for monitoring of crib house concrete walls and slabs with an opposing side in contact with river water and the Quad Cities discharge canal weir; and (2) procedures will be revised to emphasize inspecting for structural integrity of concrete and steel components and identify specific types of components to be inspected. Enhancements are scheduled for implementation prior to the period of extended operation. These enhancements have been reviewed separately by the NRCs technical staff and the results will be documented in a Safety Evaluation Report.
The LRA also states that this AMP is part of the structures monitoring program. This is consistent with GALL AMP XI.S7, which states in part that, for plants not committed to RG 1.127, Revision 1, aging management of water-control structures may be included in the Structures Monitoring Program (XI.S6). However, details pertaining to water-control structures are to incorporate the attributes described herein. This program consists of procedures that provide for condition monitoring of structural steel elements and concrete. With enhancements, the program provides for visual inspections of structural steel and concrete components within the scope of license renewal that are in the Unit 1 and Unit 2 and 3 crib houses at Dresden, and the Unit 1 and 2 crib house and discharge canal weir structure supporting the ultimate heat sink at Quad Cities. The program is credited for aging management of concrete and structural steel elements exposed to raw water and aging management of concrete not exposed to raw water, and is based on Regulatory Guide 1.127, Revision 1.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables which compared the attributes of this AMP to the attributes of the GALL program XI.S7. The audit team also reviewed AMR topical reports AMRTR-S01 and S02, which are the applicants basis documents for this AMP, and the associated implementing procedure, ER-MW-450 Structures Monitoring. In addition, the audit team reviewed the applicants responses to RAIs, including RAIs B.1.31, 3.5-12 and 2.4-7. The audit team reviewed two License Renewal Change Requests (LRCR) which had been initiated as a result of D-RAI 2.4-7 (Scoping and Screening): (1) LRCR No. 2003-38 adds intake (cold) and discharge (hot) canals to the scope of the Rule; and (2) LRCR No. 2003-39 adds outfall structures to the scope of the Rule to support the Ultimate Heat Sink.
On the basis of its review of this AMP, the associated program basis document, responses to relevant RAIs (including supplemental RAIs), implementing procedure, and the commitment tracking list, the audit team determined that this AMP is consistent with the GALL AMP XI.S7, with the enhancements as noted in the LRA.
B.1.32 Protective Coating Monitoring and Maintenance Program The applicant states in LRA Section B.1.32 that the protective coating monitoring and maintenance program is consistent with the ten elements of GALL aging management program XI.S8, "Protective Coating Monitoring and Maintenance Program," with the following enhancements: (1) procedure revisions will provide for thorough visual inspections of Service Level I coatings near sumps or screens associated with the emergency core cooling system; (2) procedure revisions will provide for pre-inspection reviews of previous reports so that trends can be identified; and (3) procedure revisions will provide for analysis of suspected reasons for coating failure. Enhancements are scheduled for implementation prior to the period of extended operation. These enhancements have been reviewed separately by the NRCs technical staff and the results will be documented in a Safety Evaluation Report.
The protective coating monitoring and maintenance program is credited for aging management of Service Level I coatings inside primary containment. Service Level I coatings are used in areas where the coating failure could adversely affect the operation of post-accident fluid systems and thereby impair safe shutdown. The program provides for visual inspections to identify any condition that adversely affects the ability of the coating film to function as intended. It is implemented through procedures based on the technical and quality requirements of Regulatory Guide 1.54, Revision 0, Quality Assurance Requirements for Protective Coatings Applied to Water Cooled Nuclear Power Plants, and ANSI N101 4-1972, "Quality Assurance for Protective Coatings Applied to Nuclear Facilities," and the guidance provided in EPRI TR-109937, "Guidelines on Nuclear Safety-Related Coating."
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables which compared the attributes of this AMP to the attributes of the GALL program XI.S8. The audit team also reviewed AMR topical report AMRTR-S02, Primary Containment and Structural Steel, which is the applicants basis document for this AMP, and the associated implementing procedures. In addition, the audit team reviewed the applicants responses to RAI B.1.32. The audit team noted that the applicants corporate procedure, ER-AA-330-008, and plant procedure, DTS 1600-11, taken together satisfied the 10 elements of the comparable GALL program.
On the basis of its review of this AMP, GALL AMP XI.S8, and the associated program basis documents, responses to RAI B.1.32, implementing procedure, and the commitment tracking list, the audit team determined that this AMP is consistent with the GALL AMP XI.S7, with the enhancements as noted in the LRA.
B.1.33 Non-EQ Electrical Cables and Connectors Not Subject to 10 CFR 50.49 Environmental Qualification Requirements In Appendix B.1.33 of the LRA, the applicant stated that the Non-EQ Electrical Cables and Connectors Not Subject to 10 CFR 50.49 Environmental Qualification Requirements AMP is consistent with GALL program XI.E1, Electrical Cables and Connectors Not Subject to 10 CAR 50.49 Environmental Qualification Requirements. This aging management program addresses cables and connections within the scope of license renewal that are subject to an adverse environment. It also identifies and manages cables and connections subject to an adverse localized environment. The aging management program for electrical cables and connections not subject to 10 CFR 50.49 environmental qualification requirements is a new program.
Cables and connections subject to an adverse environment are managed by inspection of a sample of these components. Selected cables and connections from accessible areas, which represent, with reasonable assurance, the cables and connections in adverse environments are inspected. They are inspected for signs of accelerated age-related degradation. Additional inspections, repair or replacement are initiated as appropriate. Samples of cables and connections found to be located in adverse localized areas will be inspected prior to the period of extended operation, with an inspection frequency of at least once every 10 years. The scope of this program includes inspections of power, control and instrumentation cables and connections located in adverse localized areas, including the cables used in instrumentation circuits that are sensitive to reduction in conductor insulation resistance.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables which compared the attributes of this AMP to the attributes of the GALL program XI.E1. The audit team also reviewed AMR topical reports AMRTR-E01 and E02, which are the applicants basis documents for this AMP, and the associated implementing procedure, MA-AA-723-500, Inspection of Non EQ cables and Connections for Managing Adverse Localized Environments. In addition, the audit team reviewed the applicants responses to RAI B.1.33 and found them acceptable.
The audit team identified a potential inconsistency In the Corrective Actions attribute between the applicants program and GALL AMP XI.E1. GALL AMP XI.E1 specifies that when an unacceptable condition or situation is identified, a determination is made as to whether the same condition or situation is applicable to the other accessible or inaccessible cables or conditions. The applicants AMP limits unacceptable conditions or situations to those bounded by the sample population. The sample population is limited to accessible cables and connections, thereby precluding the consideration of inaccessible cables and connections as required by GALL. The applicant stated that it was their intent to include inaccessible cables and connections as required by GALL, however the wording chosen did not correctly state their position. The applicant generated License Renewal Change Request 2003-304 to revise the ten element program description for B.1.33 to include the following clarification: When an unacceptable condition in a sample population has been found, Exelon aging management program B.1.33 will require an [engineering] determination to verify whether the condition is applicable to accessible and inaccessible cables or connections bounded by the sample population.
On the basis of its review of this AMP, GALL AMP XI.E1, the associated program basis documents, responses to RAI B.1.33, implementing procedure, and the commitment tracking list, the audit team determined that this AMP is consistent with the GALL AMP XI.E1, with the noted clarification in the corrective actions attribute, as discussed above.
B.1.34 Fatigue Monitoring Program In Appendix B, Section 1.34 of the LRA, the applicant states that its metal fatigue of the reactor coolant pressure boundary aging management program is consistent with GALL program X.M1, Metal Fatigue of Reactor Coolant Pressure Boundary, with enhancements. The program provides means for monitoring fatigue stress cycles to ensure that the ASME Section III design fatigue cumulative usage factor (CUF) limit is not exceeded during the period of extended operation.
The enhancements will include the implementation of the EPRI-licensed FatiguePro cycle counting and fatigue usage factor tracking computer program. The computer program provides the capability for automated counting of fatigue stress cycles and automated calculation and tracking of fatigue CUFs at various locations. The program will permit calculating and tracking the cumulative usage factors for the reactor pressure vessel, Class 1 piping, the torus, torus vents, and torus attached piping and penetrations, at the monitoring locations stated in Sections 4.3 and 4.6 of the LRA. The program will also provide for tracking of fatigue stress cycles for the Dresden isolation condenser.
The audit team reviewed the LRA Sections 4.3 and 4.6. New corporate procedure ER-AA-470, Fatigue and Transient Monitoring Program, will shortly be in place.
Locations additional to those identified in NUREG/CR-6260 are included within the fatigue monitoring program scope. The applicant was not able to identify the version of FatiguePro that was in use, but knew that it was the latest version, and that it had been tailored for use at Dresden and Quad Cities. In addition to counting stress cycles, FatiguePro also performs on-line monitoring of transients, tracking fatigue usage factors on the selected components. FatiguePro software was recently installed and is currently undergoing testing and monitoring, so this newer capability is not yet in place, but the applicant stated that the software was to be accepted, and the implementing procedures to take effect, during 2004.
On the basis of its review of this AMP, GALL AMP X.M1, and the implementation of the FatiguePro software as described in the LRA and the corporate procedure, the audit team determined that the fatigue monitoring program, when FatiguePro is implemented, will be consistent with the GALL AMP X.M1.
B.1.35 Environmental Qualification (EQ) of Electrical Components In Appendix B.1.35 of the LRA, the applicant states that the Environmental Qualification (EQ) of Electrical Components AMP is consistent with GALL program X.E1, Environmental Qualification (EQ) of Electrical Components.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables which compared the attributes of this AMP to the attributes of the GALL program X.E1. The audit team also reviewed LRA Section 4.4, TLAA-Environmental Qualification of Electrical Equipment, which is the applicants basis documents for this AMP. In addition, the audit team reviewed the applicants responses to RAI 4.4-1. The audit team noted that the applicants response to RAI 4.4-1 documents the applicants compliance with GI-168, which is mentioned in GALL as a currently open generic issue with ongoing research directed at resolving the issue. This RAI response effectively closes out the GI-168 concerns. The audit team determined that this AMP is consistent with GALL AMP X.E1.
B.1.36 Boraflex Monitoring In Appendix B, Section 1.36 of the LRA, the applicant states that its Boraflex Monitoring aging management program is consistent with GALL program XI.M22, Boraflex Monitoring. The Boraflex Monitoring program is only applicable to Quad Cities because Dresden utilizes Boral as the neutron absorbing material in the spent fuel racks rather than Boraflex.
The Boraflex monitoring AMP consists of (1) neutron attenuation testing (blackness testing) to determine gap formation, (2) sampling for the presence of silica in the spent fuel pool (which accompanies the loss of boron carbide), and (3) analysis of criticality to assure that the required 5% subcriticality margin is maintained. This program is implemented in response to Generic Letter 96-04, Boraflex Degradation in Spent Fuel Pool Storage Racks. The Boraflex monitoring activities are based on the maintenance rule and on EPRI TR-108761, "A Synopsis of the Technology Developed to Address the Boraflex Degradation Issue."
The audit team reviewed the license renewal aging management program basis document, The Exelon Aging Management Program Ten Element Review for Boraflex Monitoring Aging Management Program, the AMRTR-S04, Fuel Storage and Handling Equipment, the applicants responses to RAI B.1.36, and the associated implementing procedures. Based on its review of the above documents, the audit team determined that this AMP is consistent with GALL program XI.M22.
B.1.37 Electrical Cables Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrument Circuits This is a new AMP that is not discussed in the LRA. This AMP was added to address electrical cables not subject to 10 CFR 50.49 environmental qualification requirements used in instrument circuits. The applicant has stated that this AMP is consistent with GALL program XI.E2, Electrical Cables Not Subject to 10 CAR 50.49 Environmental Qualification Requirements Used in Instrument Circuits, with an exception to the GALL requirements for monitoring and trending used to determine cable degradation. This exception has been reviewed separately by the NRCs technical staff and the results will be documented in a Safety Evaluation Report.
The audit team reviewed the Exelon Aging Management Program Ten Element Review tables which compared the attributes of this AMP to the attributes of the GALL program XI.E2. The audit team also reviewed AMR topical reports AMRTR-E01 and E02, which are the applicants basis documents for this AMP. On the basis of this review, the audit team determined that this AMP is consistent with GALL program XI.E2, with the exception of the monitoring and trending attribute discussed above.
B.1.38 Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 EQ Requirements This is a new AMP that is not discussed in the LRA. This AMP was added to address Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 EQ Requirements.
The applicant has stated that this AMP is consistent with GALL program XI.E3, Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 EQ Requirements.
This new aging managing program has been reviewed separately by the NRCs technical staff and the results will be documented in a Safety Evaluation Report.
TABLE OF AMPS REVIEWED BY THE AUDIT TEAM Applicants AMP GALL AMP LR-AMP Basis Document and Other Documents Reviewed B.1.1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD The AMP - Ten Element Review for Inservice Inspection (ISI)
Plan, Revision 2.
AMRTRs:
M05, Steam and Reactor Grade Water M09, Heat Exchangers M13, Reactor Pressure Vessel M14, Reactor Internals Dresden Units 2 & 3 ISI Program Plan for the 4th 10 Year Inspection Interval, Revision 1, 4-01-03 ER-AA-330, Revision 3, Conduct of Inservice Inspections Action Tracking Item 101562.01.01 RAI B.1.1 B.1.2, Water Chemistry XI.M2, Water Chemistry The AMP - Ten Element Review for Water Chemistry, Revision 3 AMRTRs-S05, M05, M06, S04, M09, M11, M13, and M14 CY-AB-120-100, Revision 5, Reactor Water Chemistry Action Tracking Item 101522.02.05 for procedure CY-AB-120-110, Revision 5, Condensate and Feedwater Chemistry B.1.3, Reactor Head Closure Studs Program XI.M3, Reactor Head Closure Studs The AMP - Ten Element Review for Reactor Head Closure Studs Program, Revision 3 AMRTR-M13, Reactor Pressure Vessel License Renewal Change Request LRCR 2003-289 B1.4, BWR Vessel ID Attachment Welds Program XI.M4, BWR Vessel ID Attachment Welds The AMP - Ten Element Review for BWR Vessel ID Attachment Welds Program AMRTR-M13, Reactor Pressure Vessel.
License Renewal Change Request LRCR 2003-263
Applicants AMP GALL AMP LR-AMP Basis Document and Other Documents Reviewed B.1.5, BWR Feedwater Nozzle XI.M5, BWR Feedwater Nozzle The AMP - Ten Element Review for BWR Feedwater Nozzle AMRTR-M05, Steam and Reactor Grade Water Environment AMRTR-M13, Reactor Pressure Vessel Topical Report GE-NE-523-A71-0594. Revision 1 Alternate BWR Feedwater Nozzle Inspection Requirements, 8/99 ISI Program Plan 4th 10-Year Inspection Interval Dres 2/ 3 ER-AA-330-002, ISI of Welds and Components ER-AA-330-009, ASME Section XI Repair-Replacement Program B.1.6, BWR Control Rod Drive Return Line Nozzle XI.M6, BWR Control Rod Drive Return Line Nozzle The AMP - Ten Element Review for BWR Control Rod Drive Return Line Nozzle AMRTR-M05, Steam and Reactor Grade Water Environment AMRTR-M13, Reactor Pressure Vessel ISI Program Plan 4th 10-Year Inspection Interval - Dres 2/ 3 Implementing Procedures:
LS-AA-110, Commitment Management ER-AA-330-002, ISI of Welds and Components ER-AA-330-009, ASME Section XI Repair-Replacement Program Action Tracking Item 101562.06.01 B.1.7, BWR Stress Corrosion Cracking XI.M.7, BWR Stress Corrosion Cracking The AMP - Ten Element Review for BWR Stress Corrosion Cracking AMRTR-M05, Steam and Reactor Grade Water Environment AMRTR-M13, Reactor Pressure Vessel RAI B.1.7 and RAI 3.1-24 B1.8, BWR Penetrations Program BWR Penetrations The AMP - Ten Element Review for BWR Penetrations AMRTR-M13, Reactor Pressure Vessel.
Implementing Procedures:
DTS 0200-02, QCTS 0740-04, and ER-AA-330-002
Applicants AMP GALL AMP LR-AMP Basis Document and Other Documents Reviewed B1.9. BWR Vessel Internals Program XI.M8, BWR Penetrations The AMP - Ten Element Review for BWR Vessel Internals Program AMRTR-M14, Reactor Internals License Renewal Change Request LRCR 2003-257 Implementing Procedures:
DTS 0200-02, QCTS 0740-04, and ER-AA-330-002 B.1.10, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)
XI.M13, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)
The AMP - Ten Element Review for Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)
AMRTR-M14, Reactor Vessel Internals Implementing Procedures:
ER-AB-331-101, Evaluation for Thermal Aging/Neutron Embrittlement of Reactor Internal Components (Draft)
LS-AA-110, Commitment Management Action Tracking Item 101562.13.01 D-RAI B.1.10 B.1.11, Flow-Accelerated Corrosion XI.M17, Flow-Accelerated Corrosion The AMP - Ten Element Review for "Flow-Accelerated Corrosion, Rev. 3 AMRTR-M05, Steam and Reactor Grade Water ER-AB-430, Conduct of Flow Accelerated Corrosion Activities, Rev. 1.
Calculation 030679, Dresden Unit 2 and 3 FAC Susceptible Non-Modeled Program, 9-23-03.
RAI 3.3.2.4.12 B1.12, Bolting Integrity Program XI.M18, Bolting Integrity The AMP - Ten Element Review for Bolting Integrity Program AMRTR-M08 External Environment License Renewal Change Request LRCR 2003-266
Applicants AMP GALL AMP LR-AMP Basis Document and Other Documents Reviewed B.1.13, Open Cycle Cooling Water System XI.M20, Open Cycle Cooling Water System The AMP - Ten Element Review for Open Cycle Cooling Water System, Revision 2 AMRTRs - M02, M04, M08, and M09 ER-AA-340-1001, Revision 1, GL 89-13 Program Implementation Instructional Guide Action Tracking Item 101522.20.03 for DFPP 4123-09, 2/3 Service Water to Fire System Crosstie Flow Test B.1.14, Closed Cycle Cooling Water System XI.M21, Closed Cycle Cooling Water System The AMP - Ten Element Review for Closed Cycle Cooling Water System, Revision 2 AMRTRs - M02, M09, and M11 CY-AA-120-400, Revision 5, Closed Cooling Water Chemistry Action Tracking Item 101562.21.16 for SBO Diesel ISI B.1.15, Inspection of Overhead Heavy Load and Light Load (Related to Refueling)
Handling Systems XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling)
Handling Systems The AMP - Ten Element Review for Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, Revision 2 AMRTR - S02, Primary Containment and Structural Steel Implementing Procedures:
MA-DR-MM-5-5801, Visual Inspection & Preventive Maintenance of Jib, Monorail, and Underhung Cranes with Integral Hoisting Mechanisms, Revision 1 DMS 5800-02, Overhead & Gantry Cranes Annual Inspection
& Preventive Maintenance, Revision 7 DMS 0800-01, Refueling Platform Pre-refueling Mechanical Inspection, Revision 5 QCMP 5800-02, Periodic Inspection & Preventive Maintenance Program for Overhead Cranes, Jib Cranes & Monorail Systems, Revision 18 RAI B.1.15 B.1.16, Compressed Air Monitoring XI.M24, Compressed Air Monitoring The AMP - Ten Element Review for Compressed Air Monitoring, Revision 2 AMRTR - M01, Compressed Gas & Ventilation Air DTS 4700-01, Revision 5, Sampling Unit 2 (3) Instrument Air Action Tracking Item 101562.24.02 for procedure QCOS 4700-02, Inboard MSIV and Target Rock Valve Pneumatic System Leak Test
Applicants AMP GALL AMP LR-AMP Basis Document and Other Documents Reviewed B.1.17, BWR Reactor Water Cleanup System XI.M25, BWR Reactor Water Cleanup System The AMP - Ten Element Review for BWR Reactor Water Cleanup System AMRTR - M05, Steam and Reactor Grade Water Environment Generic Letter 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping ISI Program Plan 4th 10-Year Inspection Interval Dres 2/3 ISI 107 sheets 1 & 2, ISI Class I RWCU Piping B.1.18, Fire Protection XI.M26, Fire Protection The AMP - Ten Element Review for Fire Protection, Revision 2 AMRTR - M15, Fire Protection Implementing Procedures:
DFPS 4175-02, Operating Fire Stop/Break Surveillance.
Revision 8.
DFPS 4175-07, Fire Door/Oil Spill Barrier Surveillance, Revision 18.
RAI B.1.18-1 B.1.19, Fire Water System XI.M27, Fire Water System The AMP - Element Review for Fire Water System, Revision 2 AMRTR - M15, Fire Protection CY-AA-211, Fire Protection Program RAI B.1.19-1 B.1.20, Aboveground Carbon Steel Tanks XI.M29, Aboveground Carbon Steel Tanks The AMP - Ten Element Review for Aboveground Carbon Steel Tanks AMRTR - M08, External Environment LRCR No. 2003-265 Proposed revision to LRA Section B.1.20 RAI B.1.25 B.1.21, Fuel Oil Chemistry XI.M30, Fuel Oil Chemistry The AMP - Ten Element Review for Fuel Oil Chemistry, Revision 2 AMRTR - M03, Oil/Fuel Oil DOS 6600-01, Revision 80, DG Surveillance Tests Action Tracking Item 101562.30.03 for procedure CY-QC-110-630, Diesel Fuel Oil Sampling
Applicants AMP GALL AMP LR-AMP Basis Document and Other Documents Reviewed B.1.22, Reactor Vessel Surveillance XI.M31, Reactor Vessel Surveillance The AMP - Ten Element Review for Reactor Vessel Surveillance AMR M.13, Reactor Pressure Vessel Action Tracking Item 162518.01 for new procedure to govern reactor vessel surveillance.
RAI B.1.22 B.1.23 (A-M),
One-Time Inspection XI.M32, One-Time Inspection The AMP - Ten Element Review for One-Time Inspection (A-M)
AMRTRs - M01, M02, M03, M05, M06, M11, S02, S04, and
- S05, B.1.24, Selective Leaching of materials Aging Management Program XI.M33, Selective Leaching of Materials The AMP-Ten Element Review for Selective Leaching of materials Aging Management Program AMRTRs - M02, M04, M05, M08, M09, and M15 B.1.25, Buried Piping and Tanks Inspection Aging Management Program XI.M34, Buried Piping and Tanks Inspection The AMP-Ten Element Review for Buried Piping and Tanks Inspection Aging Management Program AMRTR - M08, External Environment B.1.26, ASME Section XI, Subsection IWE XI.S1, ASME Section XI, Subsection IWE The AMP-Ten Element Review for ASME Section XI, Subsection IWE AMRTR - S02, Primary Containment and Structural Steel Dresden Units 2 & 3 ISI Program Plan for the 4th 10 Year Inspection Interval, Revision 1, 4-01-03 ER-AA-330, Revision 3, Conduct of Inservice Inspections RAI B.1.26
Applicants AMP GALL AMP LR-AMP Basis Document and Other Documents Reviewed B.1.27, ASME Section XI, Subsection IWF XI.S3, ASME Section XI, Subsection IWF The AMP - Ten Element Review for ASME Section XI, Subsection IWF AMRTR - S05, Component Supports Dresden Units 2 & 3 ISI Program Plan for the 4th 10 Year Inspection Interval, Revision 1, 4-01-03 ER-AA-330, Revision 3, Conduct of Inservice Inspections RAIs 3.5-13, 3.5-16, and B.1.27 B.1.28, 10 CFR Part 50, App. J XI.S4, 10 CFR Part 50, App. J The AMP - Ten Element Review for 10 CFR Part 50, App. J AMRTR - M01, S02 LRCR No. 2003-282, Revise Ten Element Review for Aging Management Program B.1.28, 10 CFR Part 50, App. J, Revision 2 B.1.29, Masonry Wall Program XI.S5, Masonry Wall Program The AMP - Ten Element Review for Masonry Wall Program AMRTR - S01 Procedure ER-MW-450, Structures Monitoring B.1.30, Structures Monitoring Program XI.S6, Structures Monitoring Program The AMP - Ten Element Review for Structures Monitoring Program AMRTR - S01, S02, S05, M08 ER-MW-450, Structures Monitoring RAIs B.1.30, 3.3-7, 3.5-12 B.1.31, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants XI.S7, RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants The AMP - Ten Element Review for RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants AMRTR - S01, S02 ER-MW-450, Structures Monitoring QCMPM 4400-12, Circulating Water Intake Bay Inspection QCMPM 4400-11, RHR Service Water Intake Bay Inspection DTS 3900-07, Unit 2/3 Cribhouse Inspection LRCRs No. 2003-38, 2003-39 RAIs B.1.31, 2.4-7, and 3.5-12
Applicants AMP GALL AMP LR-AMP Basis Document and Other Documents Reviewed B.1.32, Protective Coating Monitoring and Maintenance Aging Management Program XI.S8, Protective Coating Monitoring and Maintenance program The AMP - Ten Element Review for Protective Coating Monitoring and Maintenance Aging Management Program AMRTR - S02, Primary Containment and Structural Steel B.1.33, Non-EQ Electrical Cables and Connectors Not Subject to 10 CFR 50.49 Environmental Qualification Requirements XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements The AMP-Ten Element Review for Non-EQ Electrical Cables and Connectors Not Subject to 10 CFR 50.49 Environmental Qualification Requirements, Revision 2 AMRTR - E01, E02 Maintenance Procedure MA-AA-723-500, Inspection of Non-EQ Cables and Connections for Managing Adverse Localized Environments, Revision 0 RAIs B.1.33-1, B.1.33-2, B.1.33-3, B.1.33-4, B.1.33-5 B.1.34, Metal Fatigue of Reactor Coolant Pressure Boundary Aging Management Program X.M1, Metal Fatigue of Reactor Coolant Pressure Boundary The AMP - Ten Element Review for Metal Fatigue of Reactor Coolant Pressure Boundary Aging Management Program AMRTR - LRA Sections 4.3 & 4.6 B.1.35, EQ of Electrical Components Revision 3 X.E1, EQ of Electrical Components The AMP - Ten Element Review for EQ of Electrical Components Revision 3 LRA Sections 4.4 RAI 4.4-1 B.1.36, Boraflex Monitoring Aging Management Program XI.M22, Boraflex Monitoring The AMP - Ten Element Review for Boraflex Monitoring Aging Management Program AMRTR-S04, Fuel Storage and Handling Equipment B.1.37, Electrical Cables Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrument Circuits XI.E.2, Electrical Cables Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrument Circuits The AMP - Ten Element Review for Electrical Cables Not Subject to 10 CFR 50.49 EQ Requirements Used in Instrument Circuits, Revision 2 AMRTRs - E01 and E02 DIS 1600-16, Revision 13, Drywell High Radiation Monitor Group 2 Isolation Functional & Calibration Tests QCIS 2400-05, Revision 2, Unit 2 Div. II Drywell Radiation Monitor Calibration & Functional Test