ML042880347

Audit and Review Report for Plant Aging Management Reviews and Programs

ML042880347
Person / Time
Site:	Cook
Issue date:	09/22/2004
From:	Information Systems Labs
To:	NRC/NRR/DRIP/RLEP
Cranston G, NRR/DRIP/RLEP, 415-2073
References
GS-23F-0060-L
Download: ML042880347 (294)

Text

D.C. Cook Audit & Review Report Audit and Review Report for Plant Aging Management Reviews and Programs Donald C. Cook Nuclear Plant, Units 1 & 2 Docket Nos.: 50-315 & 50-316 September 22, 2004 Prepared by Information Systems Laboratories, Inc.

11140 Rockville Pike Rockville, MD 20852 Contract No. GS-23F-0060-L Prepared for License Renewal and Environmental Impacts Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

D.C. Cook Audit & Review Report Table of Contents ABBREVIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . viii

1. Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2. Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

3. Summary of Information in the CNP License Renewal Application . . . . . . . . . . . . . . . . 3 3.1 D. C. Cook LRA Tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3.1.1 CNP LRA Table 1 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.1.2 CNP LRA Table 2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

4. Audit and Review Scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

5. Audit and Review Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 5.1 CNP LRA AMPs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 5.2 CNP LRA AMRs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 5.3 NRC-Approved Precedents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 5.4 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 5.5 Documents Reviewed by the Project Team . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 5.6 Commitments to be Included in the Safety Evaluation Report . . . . . . . . . . . . . . 9

6. Exit Meeting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

7. Audit and Review Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 7.1 Aging Management Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 7.1.1 BURIED PIPING INSPECTION (CNP AMP B.1.6) . . . . . . . . . . . 9 7.1.1.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 7.1.1.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . . 9 7.1.1.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 10 7.1.1.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 7.1.1.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 10 7.1.1.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 7.1.1.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 7.1.2 CAST AUSTENITIC STAINLESS STEEL (CASS) EVALUATION (CNP AMP B.1.7) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 7.1.2.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 7.1.2.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 13 7.1.2.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 13 7.1.2.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 7.1.2.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 13 7.1.2.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 7.1.2.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 7.1.3 CONTAINMENT LEAKAGE RATE TESTING (AMP B.1.8) . . . . 15 7.1.3.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 7.1.3.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 15 7.1.3.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 15 i

D.C. Cook Audit & Review Report 7.1.3.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 7.1.3.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 16 7.1.3.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 7.1.3.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 7.1.4 DIESEL FUEL MONITORING (AMP B.1.10) . . . . . . . . . . . . . . . 17 7.1.4.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 7.1.4.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 17 7.1.4.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 17 7.1.4.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 7.1.4.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 20 7.1.4.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 7.1.4.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 7.1.5 FIRE PROTECTION (AMP B.1.11.1) . . . . . . . . . . . . . . . . . . . . 22 7.1.5.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 7.1.5.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 22 7.1.5.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 22 7.1.5.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 7.1.5.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 25 7.1.5.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 7.1.5.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 7.1.6 FIRE WATER SYSTEM (AMP B.1.11.2) . . . . . . . . . . . . . . . . . . 26 7.1.6.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 7.1.6.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 27 7.1.6.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 27 7.1.6.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 7.1.6.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 30 7.1.6.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 7.1.6.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 7.1.7 FLOW-ACCELERATED CORROSION (AMP B.1.12) . . . . . . . 31 7.1.7.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 7.1.7.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 32 7.1.7.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 32 7.1.7.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 7.1.7.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 32 7.1.7.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 7.1.7.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 7.1.8 HEAT EXCHANGER MONITORING (AMP B.1.13) . . . . . . . . . 33 7.1.8.1 Review of the AMP Against the Program Elements . . . 34 7.1.8.2 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 7.1.8.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 7.1.9 INSERVICE INSPECTION - ASME SECTION XI, SUBSECTIONS IWB, IWC, and IWD (AMP B.1.14) . . . . . . . . . . . . . . . . . . . . . . 38 7.1.9.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 7.1.9.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 39 7.1.9.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 39 7.1.9.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 7.1.9.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 39 ii

D.C. Cook Audit & Review Report 7.1.9.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 7.1.9.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 7.1.10 INSERVICE INSPECTION - ASME SECTION XI, SUBSECTION IWE (AMP B.1.15) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 7.1.10.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 7.1.10.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 41 7.1.10.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 41 7.1.10.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 7.1.10.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 43 7.1.10.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 7.1.10.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 7.1.11 INSERVICE INSPECTION - ASME SECTION XI, SUBSECTION IWF (AMP B.1.16) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 7.1.11.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 45 7.1.11.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 45 7.1.11.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 7.1.11.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 45 7.1.11.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 7.1.11.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 7.1.12 INSERVICE INSPECTION - ASME SECTION XI, SUBSECTION IWL (AMP B.1.17) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 7.1.12.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 7.1.12.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 46 7.1.12.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 47 7.1.12.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 7.1.12.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 48 7.1.12.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 7.1.12.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 7.1.13 INSERVICE INSPECTION - ASME SECTION XI, AUGMENTED INSPECTIONS (AMP B.1.18) . . . . . . . . . . . . . . . . . . . . . . . . . 50 7.1.13.1 Review of the AMP Against the Program Elements . . . 50 7.1.13.2 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 7.1.13.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 7.1.14 INSTRUMENT AIR QUALITY (AMP B.1.19) . . . . . . . . . . . . . . . 55 7.1.14.1 Review of the AMP Against the Program Elements . . . 55 7.1.14.2 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 7.1.14.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 7.1.15 NON-EQ INSTRUMENTATION CIRCUITS TEST REVIEW (AMP B.1.21) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 7.1.15.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 7.1.15.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 60 7.1.15.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 61 7.1.15.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 7.1.15.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 61 7.1.15.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 7.1.15.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 iii

D.C. Cook Audit & Review Report 7.1.16 NON-EQ INSULATED CABLES AND CONNECTIONS (AMP B.1.22) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63 7.1.16.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 63 7.1.16.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 63 7.1.16.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 64 7.1.16.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 64 7.1.16.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 64 7.1.16.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 7.1.16.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 7.1.17 OIL ANALYSIS (AMP B.1.23) . . . . . . . . . . . . . . . . . . . . . . . . . . 65 7.1.17.1 Review of the AMP Against the Program Elements . . . 66 7.1.17.2 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 7.1.17.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 7.1.18 PRESSURIZER EXAMINATIONS (AMP B.1.24) . . . . . . . . . . . 70 7.1.18.1 Review of the AMP Against the Program Elements . . . 71 7.1.18.2 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 76 7.1.18.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76 7.1.19 PREVENTIVE MAINTENANCE (AMP B.1.25) . . . . . . . . . . . . . 76 7.1.19.1 Review of the AMP Against the Program Elements . . . 76 7.1.19.2 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 82 7.1.19.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82 7.1.20 REACTOR VESSEL INTERNALS CAST AUSTENITIC STAINLESS STEEL (AMP B.1.28) . . . . . . . . . . . . . . . . . . . . . . 82 7.1.20.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 83 7.1.20.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 83 7.1.20.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 84 7.1.20.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84 7.1.20.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 84 7.1.20.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 84 7.1.20.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85 7.1.21 SERVICE WATER SYSTEM RELIABILITY (AMP B.1.29) . . . . 85 7.1.21.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 85 7.1.21.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 85 7.1.21.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 86 7.1.21.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87 7.1.21.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 88 7.1.21.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 88 7.1.21.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89 7.1.22 SMALL BORE PIPING PROGRAM (AMP B.1.30) . . . . . . . . . . 89 7.1.22.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 89 7.1.22.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 89 7.1.22.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 90 7.1.22.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90 7.1.22.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 90 7.1.22.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 90 7.1.22.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91 iv

D.C. Cook Audit & Review Report 7.1.23 STRUCTURES MONITORING - STRUCTURES MONITORING (AMP B.1.32) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91 7.1.23.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 91 7.1.23.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 91 7.1.23.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 92 7.1.23.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92 7.1.23.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 93 7.1.23.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 93 7.1.23.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94 7.1.24 STRUCTURES MONITORING - CRANE INSPECTION PROGRAM (AMP B.1.33) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94 7.1.24.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . . 94 7.1.24.2 Consistency with the GALL Report . . . . . . . . . . . . . . . . 94 7.1.24.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . . 95 7.1.24.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 95 7.1.24.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . . 97 7.1.24.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . . 97 7.1.24.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98 7.1.25 STRUCTURES MONITORING - DIVIDER BARRIER SEAL INSPECTION (AMP B.1.34) . . . . . . . . . . . . . . . . . . . . . . . . . . . 98 7.1.25.1 Review of the AMP Against the Program Elements . . . 98 7.1.25.2 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . 103 7.1.25.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 103 7.1.26 STRUCTURES MONITORING - ICE BASKET INSPECTION (AMP B.1.35) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 103 7.1.26.1 Review of the AMP Against the Program Elements . . 104 7.1.26.2 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . 107 7.1.26.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 107 7.1.27 STRUCTURES MONITORING - MASONRY WALL (AMP B.1.36)

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108 7.1.27.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . 108 7.1.27.2 Consistency with the GALL Report . . . . . . . . . . . . . . . 108 7.1.27.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . 108 7.1.27.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108 7.1.27.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . 109 7.1.27.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . 109 7.1.27.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109 7.1.28 SYSTEM TESTING (AMP B.1.37) . . . . . . . . . . . . . . . . . . . . . 110 7.1.28.1 Review of the AMP Against the Program Elements . . 110 7.1.28.2 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . 115 7.1.28.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 116 7.1.29 SYSTEM WALKDOWN (AMP B.1.38) . . . . . . . . . . . . . . . . . . 116 7.1.29.1 Review of the AMP Against the Program Elements . . 116 7.1.29.2 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . 121 7.1.29.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 121 7.1.30 WALL THINNING MONITORING (AMP B.1.39) . . . . . . . . . . . 121 7.1.30.1 Review of the AMP Against the Program Elements . . 121 7.1.30.2 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . 125 v

D.C. Cook Audit & Review Report 7.1.30.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 126 7.1.31 WATER CHEMISTRY CONTROL - PRIMARY AND SECONDARY WATER CHEMISTRY (AMP B.1.40.1) . . . . . . 126 7.1.31.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . 126 7.1.31.2 Consistency with the GALL Report . . . . . . . . . . . . . . . 126 7.1.31.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . 127 7.1.31.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 127 7.1.31.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . 128 7.1.31.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . 129 7.1.31.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 129 7.1.32 WATER CHEMISTRY CONTROL - CLOSED COOLING WATER CHEMISTRY CONTROL (AMP B.1.40.2) . . . . . . . . . . . . . . . . 129 7.1.32.2 Consistency with the GALL Report . . . . . . . . . . . . . . . 130 7.1.32.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . 130 7.1.32.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 132 7.1.32.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . 132 7.1.32.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . 133 7.1.32.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 134 7.1.33 WATER CHEMISTRY CONTROL - AUXILIARY SYSTEMS WATER CHEMISTRY CONTROL PROGRAM (AMP B.1.40.3)

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 134 7.1.33.1 Review of the AMP Against the Program Elements . . 134 7.1.33.2 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . 139 7.1.33.3 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 139 7.1.34 ENVIRONMENTAL QUALIFICATION OF ELECTRICAL COMPONENTS (AMP B.2.1) . . . . . . . . . . . . . . . . . . . . . . . . . 139 7.1.34.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . 139 7.1.34.2 Consistency with the GALL Report . . . . . . . . . . . . . . . 140 7.1.34.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . 140 7.1.34.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 140 7.1.34.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . 140 7.1.34.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . 141 7.1.34.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 141 7.1.35 FATIGUE MONITORING (AMP B.2.2) . . . . . . . . . . . . . . . . . . 141 7.1.35.1 Program Description . . . . . . . . . . . . . . . . . . . . . . . . . . 142 7.1.35.2 Consistency with the GALL Report . . . . . . . . . . . . . . . 142 7.1.35.3 Exceptions to the GALL Report . . . . . . . . . . . . . . . . . . 142 7.1.35.4 Enhancements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 143 7.1.35.5 Operating Experience . . . . . . . . . . . . . . . . . . . . . . . . . 143 7.1.35.6 UFSAR Supplement . . . . . . . . . . . . . . . . . . . . . . . . . . 143 7.1.35.7 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 144 7.2 Aging Management Reviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 144 7.2.1 CNP LRA Section 3.1 - Aging Management of Reactor Vessel, Internals, and Reactor Coolant System . . . . . . . . . . . . . . . . . 146 7.2.1.1 Aging Management Evaluations That Are Consistent With the GALL Report, for Which No Further Evaluation Is Required . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 146 7.2.1.2 Aging Management Evaluations That Are Consistent With vi

D.C. Cook Audit & Review Report the GALL Report, for Which Further Evaluation Is Recommended . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 149 7.2.1.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report . . . . . . . 157 7.2.2 CNP LRA Section 3.2 - Aging Management of Engineered Safety Features Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 165 7.2.2.1 Aging Management Evaluations That Are Consistent With the GALL Report, for Which No Further Evaluation Is Required . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 165 7.2.2.2 Aging Management Evaluations That Are Consistent With the GALL Report, for Which Further Evaluation Is Recommended . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 166 7.2.2.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report . . . . . . . 169 7.2.3 CNP LRA Section 3.3 - Aging Management of Auxiliary Systems

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 174 7.2.3.1 Aging Management Evaluations That Are Consistent with the GALL Report, for Which No Further Evaluation Is Required . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 174 7.2.3.2 Aging Management Evaluations That Are Consistent with the GALL Report, for Which Further Evaluation Is Recommended . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 176 7.2.3.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report . . . . . . . 182 7.2.4 CNP LRA Section 3.4 - Aging Management of Steam and Power Conversion Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 196 7.2.4.1 Aging Management Evaluations That Are Consistent With the GALL Report, for Which No Further Evaluation Is Required . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 197 7.2.4.2 Aging Management Evaluations That Are Consistent With the GALL Report, for Which Further Evaluation Is Recommended . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 197 7.2.4.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report . . . . . . . 201 7.2.5 CNP LRA Section 3.5 - Aging Management of Structures and Component Supports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 204 7.2.5.1 Aging Management Evaluations That Are Consistent With the GALL Report, for Which No Further Evaluation Is Required . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 205 7.2.5.2 Aging Management Evaluations That Are Consistent With the GALL Report, for Which Further Evaluation Is Recommended . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 205 7.2.5.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report . . . . . . . 221 7.2.6 CNP LRA Section 3.6 - Aging Management of Electrical and Instrumentation and Controls . . . . . . . . . . . . . . . . . . . . . . . . . 227 7.2.6.1 Aging Management Evaluations That Are Consistent With the GALL Report, for Which No Further Evaluation Is vii

D.C. Cook Audit & Review Report Required . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 227 7.2.6.2 Aging Management Evaluations That Are Consistent With the GALL Report, for Which Further Evaluation Is Recommended . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 228 7.2.6.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report . . . . . . . . . . . . . . . . . . . . . . . . 228 Project Team and Applicant Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . A1-1 Elements of an Aging Management Program for License Renewal . . . . . . A2-1 Audit and Review Followup items . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A3-1 List of Documentation Reviewed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A4-1 List of Commitments to be Included in Appendix A of the Safety Evaluation Report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A5-1 viii

D.C. Cook Audit & Review Report ABBREVIATIONS ACI American Concrete Institute AEP American Electric Power AMP aging management program AMR aging management review ANSI American National Standards Institute ASME American Society of Mechanical Engineers ASTM American Society for Testing Materials ATWS anticipated transients without scram B&PV boiler and pressure vessel B&TA bolting and torquing activities BWR boiling water reactor CASS cast austenitic stainless steel CE Combustion Engineering CEDM control element drive mechanism CLB current licensing basis CNP Donald C. Cook Nuclear Plant, Units 1 and 2 CO2 carbon dioxide DE NRC Division of Engineering DIPM NRC Division of Inspection Program Management ECCS emergency core cooling system EDG emergency diesel generator EPRI Electric Power Research Institute EQ environmental qualification ESW essential service water FAC flow-accelerated corrosion GALL generic aging lessons learned GL generic letter HVAC heating, ventilation and air conditioning I&M Indiana Michigan Power Company IASCC irradiation assisted stress corrosion cracking IGA intergranular attack ISG interim staff guidance ISI inservice inspection ISL Information Systems Laboratories, Inc.

ITG Issues Task Group ix

D.C. Cook Audit & Review Report ABBREVIATIONS (continued)

LRA license renewal application MIC microbiologically influenced corrosion NDE nondestructive examination NEI Nuclear Energy Institute NFPA National Fire Protection Association NPS nominal pipe size NRC U.S. Nuclear Regulatory Commission NRR NRC Office of Nuclear Reactor Regulation PTS pressurized thermal shock PWSCC primary water stress corrosion cracking RAI request for additional information RCP reactor coolant pump RLEP-B NRC License Renewal and Environmental Impacts Program, Section B SAT spray additive tank SBO station blackout SC structures and component SCC stress corrosion cracking SER safety evaluation report SG steam generator SOPI system operational performance inspection SRP-LR Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants SSC systems, structures, and components TLAA time-limited aging analyses UFSAR updated final safety analysis report WCAP Westinghouse commercial atomic power x

D.C. Cook Audit & Review Report Audit and Review Report Plant Aging Management Reviews and Programs for Donald C. Cook Nuclear Plant, Units 1 & 2

1. Introduction By letter dated October 31, 2003, Indiana Michigan Power Company (I&M), submitted to the U.S. Nuclear Regulatory Commission (NRC) its application for renewal of Facility Operating Licenses Nos. DPR-58 and DPR-74 for Donald C. Cook Nuclear Plant, Units 1 and 2, respectively (ML033070179). The applicant requested renewal of the operating licenses for an additional 20 years.

In support of the staff's safety review of the Donald C. Cook Nuclear Plant, Units 1 and 2 (CNP), license renewal application (LRA), between December 2003 and April 2004, an NRC team leader from the License Renewal and Environmental Impacts Program, Section B (RLEP-B), led a project team that audited and reviewed certain aging management reviews (AMRs) and associated aging management programs (AMPs) that were developed by the applicant to support the CNP LRA. The project team included both NRC staff and contractor personnel provided by Information Systems Laboratories, Inc. (ISL), RLEP-B's technical contractor. Attachment 1 lists the project team members as well as other NRC staff and ISL personnel who supported the project team's review.

The project team performed its work in accordance with the requirements of Title 10 of the Code of Federal Regulations, Part 54 (10 CFR 54), Requirements for Renewal of Operating Licenses for Nuclear Power Plants; the guidance provided in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (SRP-LR), dated July 2001; the guidance provided in NUREG-1801, Generic Aging Lessons Learned (GALL)

Report, dated July 2001; and the Audit and Review Plan for Plant Aging Management Reviews and Programs - Donald C. Cook Nuclear Plant, Units 1 and 2" (ML042670493).

Overall, for its assigned scope of work, the project team concluded that the applicants aging management activities and programs will adequately manage the effects of aging on structures and components, so that their intended functions will be maintained consistent with the CNP current licensing basis (CLB) for the period of extended operation.

This audit and review report documents the results of the project teams audit and review work.

The team performed its work at NRC Headquarters, Rockville, Maryland; at ISL offices in Rockville, Maryland; and at the applicants offices at the CNP plant site near Benton Harbor, Michigan. The project team conducted site visits during the week of December 15, 2003, March 1, 2004 and April 12, 2004. The team conducted a public exit meeting at the applicants Bridgman, Michigan, offices on April 15, 2004. Attachment 1 lists the applicant personnel and other individuals contacted by the project team in support of the work documented in this audit and review report. It also lists those attending the public exit meeting.

1

D.C. Cook Audit & Review Report

2. Background In 10 CFR 54.4 the scope of license renewal is defined as those systems, structures, and components (SSCs) (1) that are safety-related; (2) whose failure could affect safety-related functions; or (3) that are relied on to demonstrate compliance with the NRC's regulations for fire protection, environmental qualification (EQ), pressurized thermal shock (PTS), anticipated transients without scram (ATWS), and station blackout (SBO). An applicant for a renewed license must review all SSCs within the scope of license renewal to identify those SCs subject to an AMR. The SCs subject to an AMR are those that perform an intended function without moving parts or without a change in configuration or properties, and that are not subject to replacement based on qualified life or specified time period. Pursuant to 10 CFR 54.21(a)(3),

an applicant for a renewed license must demonstrate that the effects of aging will be managed in such a way that the intended function or functions of those SCs will be maintained, consistent with the CLB, for the period of extended operation. 10 CFR 54.21(d) requires that the applicant submit a supplement to the updated final safety analysis report (UFSAR) that contains a summary description of the programs and activities for managing the effects of aging.

The SRP-LR provides staff guidance for reviewing applications for license renewal. The GALL Report is a technical basis document. It summarizes staff-approved AMPs for the aging of a large number of SCs that are subject to an AMR. It summarizes the aging management evaluations, programs, and activities credited for managing aging for most of the SCs used by commercial nuclear power plants, and serves as a reference for both the applicant and staff reviewers to quickly identify those AMPs and activities that the staff has determined will provide adequate aging management during the period of extended operation. If an applicant commits to implementing these staff-approved AMPs, the time, effort, and resources used to review an applicant's LRA will be greatly reduced, thereby improving the efficiency and effectiveness of the license renewal review process. The GALL Report identifies (1) SSCs, (2) component materials, (3) the environments to which the components are exposed, (4) the aging effects associated with the materials and environments, (5) the AMPs that are credited with managing the aging effects, and (6) recommendations for further applicant evaluations of aging effects and their management for certain component types.

The GALL Report is treated in the same manner as an approved topical report that is generically applicable. An applicant may reference the GALL Report in its LRA to demonstrate that its programs correspond to those that the staff reviewed and approved in the GALL Report.

If the material presented in the LRA is consistent with the GALL Report and is applicable to the applicant's facility, the staff will accept the applicant's reference to the GALL Report. In making this determination, the staff considers whether the applicant has identified specific programs described and evaluated in the GALL Report but does not conduct a review of the substance of the matters described in the GALL Report. Rather, the staff confirms that the applicant concluded that the approvals set forth in the GALL Report apply to its programs.

If an applicant takes credit for a GALL program, it is incumbent on the applicant to ensure that the plant program contains all the program elements (also called attributes) of the referenced GALL program. These elements are described in SRP-LR, Appendix A.1, "Aging Management Review - Generic (Branch Technical Position RLSB-1)." In addition, the conditions at the plant must be bounded by the conditions for which the GALL program was evaluated. The applicant 2

D.C. Cook Audit & Review Report must certify in its LRA that it completed the verifications and that they are documented and retained in an auditable form.

3. Summary of Information in the CNP License Renewal Application The CNP LRA closely follows the standard LRA format presented in Nuclear Energy Institute (NEI) guidance, NEI 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54-The License Renewal Rule, Revision 3, April 2001. Section 3 of the CNP LRA provides the results of the AMR for SCs that the applicant identified as subject to an AMR.

3.1 D. C. Cook LRA Tables D. C. Cook LRA Tables 3.0-1, 3.0-2, and 3.0-3 provide descriptions of the mechanical, structural, and electrical service environments, respectively, used in the AMRs to determine the aging effects requiring management. Results of the AMRs are presented in two table types.

The first is Table 3.X.1 where the 3" indicates the table pertaining to the Chapter 3 AMR; the X indicates the table number from Volume 1 of the GALL Report (see the definition table below); and the 1" indicates that this is the first table type (Table 1) in Section 3.X. For example, in the reactor coolant system subsection, this is Table 3.1.1, and in the engineered safety features subsection, this is Table 3.2.1.

X Definition 1 Reactor Coolant System 2 Engineered Safety Features Systems 3 Auxiliary Systems 4 Steam and Power Conversion Systems 5 Structures and Component Supports 6 Electrical and Instrumentation and Controls The second table type is Table 3.X.2-Y where 3" again indicates the CNP LRA section number; X again indicates the table number from Volume 1 of the GALL Report; the 2" indicates that this is the second table type (Table 2) in Section 3.X; and Y indicates the system table number. For example, within the reactor coolant system subsection, the AMR results for the reactor vessel and control element drive mechanism pressure boundary are presented in Table 3.1.2-1, and the results for the reactor vessel internals are in Table 3.1.2-2. In the engineered safety features subsection, the emergency core cooling system results are presented in Table 3.2.2-1, and the containment spray system results are in Table 3.2.2-2.

The applicant compared the CNP AMR results with information set forth in the tables of the GALL Report and provided the results of its comparisons in two table types that correlate with the two table types described above.

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D.C. Cook Audit & Review Report 3.1.1 CNP LRA Table 1 CNP LRA Table 1 provides a summary comparison of how the CNP AMR results align with the corresponding table of Volume 1 of the GALL Report. These tables are essentially the same as Tables 1 through 6 of the GALL Report, except that the "Type" column was replaced by an "Item Number" column, and the "Item Number in GALL" column was replaced by a "Discussion" column. The "Item Number in GALL" column provides a means to identify in CNP LRA Table 2 the corresponding component type in CNP LRA Table 1. The Discussion column includes further information. The following are examples of information that might be contained within the Discussion column:

(1) information on further evaluation required or reference to the location of that information (2) the name of a plant-specific program being used (3) exceptions to the GALL Report assumptions (4) a discussion of how the line item is consistent with the corresponding line item in the GALL Report, when it may not be obvious (5) a discussion of how the line item differs from the corresponding line item in the GALL Report, when it may appear to be consistent Information in the table columns described below is taken directly from Volume 1 of the GALL Report: component, aging effect/mechanism, AMPs, further evaluation recommended. The Discussion column explains, in summary, how the CNP evaluations and programs align with Volume 1 of the GALL Report.

3.1.2 CNP LRA Table 2 CNP LRA Table 2 provides the detailed results of the AMRs for those SCs that are subject to an AMR. There is a Table 2 for each of the AMR systems within a GALL Report system group.

For example, the engineered safety features system group contains tables specific to emergency core cooling, containment spray, containment cooling, containment penetrations, and hydrogen control. Table 2 consists of the following nine columns.

Component Type. Column 1 identifies the component types that are subject to an AMR.

The component types are listed in alphabetical order. In the structural tables, component types are sub-grouped by material.

Intended Function. Column 2 identifies the license renewal intended functions for the listed component types. Definitions and abbreviations of intended functions are listed in Table 2.0-1 in Section 2 of the CNP LRA.

Material. Column 3 lists the particular materials of construction for the component type being evaluated.

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D.C. Cook Audit & Review Report Environment. Column 4 lists the environment to which the component types are exposed. Internal and external service environments are indicated. A description of these environments is provided in Table 3.0-1, Table 3.0-2, and Table 3.0-3 for mechanical, structural, and electrical components, respectively.

Aging Effect Requiring Management. Column 5 lists the aging effects identified as requiring management for the material and environment combinations of each component type.

Aging Management Programs. Column 6 lists the programs used to manage the aging effects requiring management.

GALL Report Volume 2 Item. Column 7 documents identified consistencies of factors listed in Table 2 of the CNP LRA with the GALL Report by noting the appropriate GALL Report item number. Each combination of the following factors listed in Table 2 is compared to the GALL Report to identify those consistencies: component type, material, environment, aging effect requiring management, and AMP. If there is no corresponding item number in the GALL Report for a particular combination of factors, Column 7 is left blank.

Table 1 Item. Column 8 is a cross reference from Table 2 to Table 1. Each combination of the following that has an identified GALL Report item number also has a Table 1 line item reference number: component type, material, environment, aging effect requiring management, and AMP. Column 8 lists the corresponding line item from Table 1. If there is no corresponding item in the GALL Report, Volume 1, Column 8 is left blank.

Notes. Column 9 contains notes that are used to describe the degree of consistency with the line items in the GALL Report. Notes that use letter designations are standard notes based on the letter from A. Nelson, NEI, to P. T. Kuo, NRC, U.S. Nuclear Industrys Proposed Standard License Renewal Application Format Package, Request NRC Concurrence, dated January 24, 2003 (ML030290201). (Note that the staff concurred in the format of the standardized format for LRAs by letter dated April 7, 2003, from P.T. Kuo, NRC, to A. Nelson, NEI (ML030990052).) Notes that use numeric designators are specific to CNP. The letter notes are described in detail in Section 7.2 of this report.

CNP LRA Table 2 contains the AMR results and indicates whether the results correspond to line items in Volume 2 of the GALL Report. Table 2 provides the following information: (1) component type, (2) component intended function, (3) material environment, (4) aging effect requiring management, and (5) AMPS credited.

Correlations between the combination in CNP LRA Table 2 and a combination for a line item in Volume 2 of the GALL Report are identified by the GALL Report item number in Column 7. If Column 7 is blank, the applicant did not identify a corresponding combination in the GALL Report. If the applicant identified a GALL Report line item, the next column provides a reference to a Table 1 row number. This reference corresponds to the GALL Report, Volume 2, roll-up to the GALL Report, Volume 1 tables. Many of the GALL Report evaluations refer to 5

D.C. Cook Audit & Review Report plant-specific programs. In these cases, the applicant considers the CNP evaluation to be consistent with the GALL Report if the other elements are consistent. Any AMP suitable for management of a particular aging effect is considered to be consistent with the GALL Report for line items referring to a plant-specific or alternate program if it has been reviewed and determined to be consistent with the seven program elements (attributes) used to review the plant-specific program.

4. Audit and Review Scope The AMRs and associated AMPs that the project team reviewed are identified in the Audit and Review Plan for Plant Aging Management Reviews and Programs - Donald C. Cook Nuclear Plant, Units 1 and 2 ," (CNP audit and review plan). The project team examined 35 of the CNP LRA AMPs and associated AMRs. The project team reviewed AMPs and AMRs that the applicant claimed were consistent with the GALL Report. The project team also reviewed certain plant-specific AMPs.

The applicant noted that some of its AMPs, including some that were reviewed by the project team, although described as consistent with the GALL Report, contain some deviations from the GALL Report. These deviations are of two types:

Exceptions to the GALL Report - Exceptions are specified GALL criteria that the applicant does not intend to meet or implement.

Enhancements to the GALL Report - Enhancements are revisions or additions to plant procedures or program activities that the applicant will implement prior to the period of extended operation. Enhancements may expand, but not reduce, the scope of an AMP.

The project team reviewed all of the AMRs in the tables in Chapter 3 of the CNP LRA except those assigned to the Office of Nuclear Reactor Regulation (NRR), Division of Engineering (DE) staff. They were either consistent with the GALL Report, as identified by Notes A through E in the CNP LRA Table 3.X.2-Y (from Column 9 of the Table 2s discussed in Section 3 of this report), or reviewed and accepted by the project team on the basis of an NRC-approved precedent (see Section 5.3 below).

5. Audit and Review Process The project team followed the process detailed in the CNP audit and review plan. This process is summarized below.

5.1 CNP LRA AMPs For the CNP LRA AMPs for which the applicant claimed consistency with the AMPs in the GALL Report, the project team determined consistency. The team reviewed the AMP descriptions and compared seven of the 10 program elements for those AMPs (as defined in Branch Technical Position RLSB-1 of SRP-LR, Appendix A.1) to the corresponding program elements for the GALL AMPs (Attachment 2 shows the 10 program elements from the SRP-LR). As discussed in the CNP audit and review plan, the project team did not review program elements 6

D.C. Cook Audit & Review Report 7, Corrective Action, 8, Confirmation Process, or 9, Administrative Controls. These elements were reviewed by the NRR, Division of Inspection Program Management (DIPM) and the results documented in Section 3 of the safety evaluation report (SER) related to the CNP LRA.

For each CNP LRA AMP that has one or more of the deviations defined in Section 4 of this report, i.e., exception or enhancement, the project team reviewed each deviation to determine whether it was acceptable and whether the AMP, as modified by the applicant, would adequately manage the aging effects for which it is credited. In some cases, the project team identified differences that the applicant did not identify between the GALL AMPs credited by the applicant and CNP LRA AMPs. In these cases, the team reviewed the difference to determine whether or not it is acceptable, and whether or not the AMP, as modified by the difference, would adequately manage the aging effects.

For those CNP LRA AMPs that are not included in the GALL Report, i.e., those based on an NRC-approved precedent, the project team reviewed the AMP against the seven program elements within its review scope. On the basis of its audit and reviews, the project team determined whether the AMPs would manage the aging effects for which they are credited (see Section 5.3 below).

5.2 CNP LRA AMRs The AMRs in the GALL Report fall into two broad categories:

Those that the GALL Report concludes are adequate to manage aging of the components referenced in the GALL Report.

Those for which the GALL Report concludes that aging management is adequate, but further evaluation is recommended for certain aspects of the aging management process.

For its AMR reviews, the project team determined that the AMRs reported by the applicant to be consistent with the GALL Report are consistent with the GALL Report and concluded that the plant-specific AMRs reported to be justified on the basis of an NRC-approved precedent are technically acceptable and applicable. For component groups evaluated in the GALL Report for which the applicant claims consistency with the GALL Report, and for which the GALL Report recommends further evaluation, the project team reviewed the applicants evaluation to determine whether it adequately addresses the issues for which the GALL Report recommended further evaluation.

5.3 NRC-Approved Precedents To help facilitate the staff review of its LRA, an applicant may reference NRC-approved precedents to demonstrate that its non-GALL programs correspond to programs that the staff had approved for other plants during its review of previous applications for license renewal.

When an applicant elects to provide precedent information, the team determines whether the material presented in the precedent is applicable to the applicants facility, determines whether the plant program is bounded by the conditions for which the precedent was evaluated and 7

D.C. Cook Audit & Review Report approved, and verifies that the plant program contains the program elements (or attributes) of the referenced precedent. In general, if the project team determines that these conditions are satisfied, it will use the information in the precedent to frame and focus its review of the applicants program.

It is important to note that precedent information is not a part of the CNP LRA; it is supplementary information voluntarily provided by the applicant as a reviewers aid. The existence of a precedent, in and of itself, is not a sufficient basis to accept the applicants program. Rather, the precedent facilitates the review of the substance of the matters described in the applicants program. As such, in its documentation of its reviews of programs that are based on precedents, the precedent information is typically implicit in the evaluation rather than explicit. If the project team determines that a precedent identified by the applicant is not applicable to the particular plant program for which it is credited, it refers the program to NRR, Division of Engineering (DE) for review in the traditional manner, i.e., as described in the SRP-LR, without consideration of the precedent information. As noted in Section 4 of this audit and review report, the applicant chose to provide precedent information to support its selection of certain CNP programs. Therefore, some of the project team reviews documented in this audit and review report considered precedent information in the manner described above.

5.4 UFSAR Supplement Consistent with the SRP-LR, for the AMRs and associated AMPs that it reviewed, the project team also reviewed the UFSAR supplement that summarizes the applicants programs and activities for managing the effects of aging for the period of extended operation.

5.5 Documents Reviewed by the Project Team In performing its work, the project team relied heavily on the CNP LRA, the SRP-LR, and the GALL Report. The project team also examined the applicants precedent review documents and AMP basis documents (a catalog of the documentation used by the applicant to develop or justify its AMPs), and other applicant documents, including selected implementing procedures, to verify that the applicants activities and programs will adequately manage the effects of aging on SCs.

Any discrepancies or issues discovered during the audit and review that required a formal response on the docket are documented in this audit and review report. If an issue was not docketed or was not resolved prior to issuing this audit and review report, a request for additional information (RAI) was prepared by the project team describing the issue and the information needed to disposition the issue. The RAI, if needed, is included and dispositioned in the SER related to the CNP LRA. The list of RAIs associated with the audit and review is provided in Attachment 3 to this audit and review report. characterizes the nature and extent of the teams reviews of the applicants documents and lists the documents reviewed by the project team. During its site visits, the project team also conducted detailed discussions and interviews with the applicants license renewal project personnel and others with technical expertise relevant to aging management.

5.6 Commitments to be Included in the Safety Evaluation Report 8

D.C. Cook Audit & Review Report lists and identifies commitments made by the applicant that were reviewed by the project team.

6. Exit Meeting The project team held a public exit meeting with the applicant on April 15, 2004, to discuss the results of its audits and reviews of the AMPs and AMRs assigned to the team. These discussions reflected the teams work and its results, as documented in this audit and review report.

7. Audit and Review Results The project teams audit and review activities for the CNP LRA AMPs and AMRs, and its conclusions, are documented below.

7.1 Aging Management Programs The project teams audit and review activities for the CNP LRA AMPs and its conclusions regarding these programs are documented below. The audit and review was performed in accordance with the guidance contained in the CNP audit and review plan in the manner summarized above.

7.1.1 BURIED PIPING INSPECTION (CNP AMP B.1.6)

In the CNP LRA, Appendix B, Section B.1.6, the applicant states that the CNP AMP B.1.6, "Buried Piping Inspection," is a new program that will be initiated prior to the period of extended operation. The applicant states that this AMP will be consistent with GALL AMP XI.M34, "Buried Piping and Tanks Inspection," with an exception.

7.1.1.1 Program Description The applicant states, in the CNP LRA, that the buried piping inspection program will include (a) preventive measures to mitigate corrosion and (b) inspections to manage the effects of corrosion on the pressure-retaining capability of buried carbon steel components. The applicant also states that preventive measures will be implemented in accordance with standard industry practice for maintaining external coatings and wrappings. Buried components will be inspected when excavated during maintenance.

7.1.1.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.6 will be consistent with the GALL AMP XI.M34, with an exception.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for CNP AMP B.1.6, including Engineering Report LRP-EAMP-01, Section 3.2, "Buried Piping Inspection Program,"

which provides an assessment of how the GALL AMP elements are addressed by the CNP LRA buried piping inspection program.

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D.C. Cook Audit & Review Report The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documentation against GALL AMP XI.M34 for consistency.

7.1.1.3 Exceptions to the GALL Report The applicant states the exception to the GALL Report elements as follows:

Element: 4: Detection of Aging Effects Exception: Buried tanks and piping will be inspected only when excavated during maintenance activities, not based on a scheduled inspection frequency.

The GALL Report identifies the following criteria for the detection of aging effects program element associated with the exception taken:

Periodic inspection of susceptible locations to confirm that coating and wrapping are intact is an effective method to ensure that corrosion of external surfaces has not occurred and the intended function is maintained.

Buried piping and tanks are inspected when they are excavated during maintenance. The inspections are performed in areas with the highest likelihood of corrosion problems, and in areas with a history of corrosion problems.

The GALL Report program description in GALL AMP XI.M34 recommends further evaluation of an applicant's operating experience with buried components in determinations of the adequacy of this program element.

The project team reviewed the applicants operating experience with excavations over the past few years and, based on the review as well as the applicant's discussion of this exception in the CNP LRA, finds that the frequency of excavating buried components for maintenance activities will be sufficient to provide reasonable assurance that the effects of aging will be identified prior to loss of intended function. Problems discovered in piping require evaluation and reporting under the plant's corrective action program, which may necessitate expanding the inspection scope. Excavating such components solely to perform inspections could pose undue risk of damage to protective coatings. The project team finds this exception to be acceptable.

7.1.1.4 Enhancements None 7.1.1.5 Operating Experience The applicant states, in the CNP LRA, that there have been multiple excavations at the site which provide some plant-specific operating experience even though the buried piping inspection program is a new program. The piping and valves that were uncovered and inspected were of the same material (carbon steel) or a less corrosion-resistant material (e.g.,

Lake Township water and station drainage piping) than the buried piping and tanks in the scope of this program. The review did not identify catastrophic failures of similar components.

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D.C. Cook Audit & Review Report Failures of fuel oil tanks and piping have been small leaks resulting from localized corrosion such as pitting.

In the CNP LRA, the applicant states that future inspection results from similar excavations are expected to be indicative of the condition of fuel oil system components. Industry and plant-specific operating experience will be considered in the development of this program, as appropriate.

The project team reviewed the documentation for multiple excavations performed at the site for several maintenance activities such as repairs to Lake Township water, fire protection, and station drainage piping. These excavations indicate that corrosion has not been a problem.

The project team also reviewed the site soil characteristics as presented in the CNP UFSAR Table 5.2-2 and basis documents. Soil acidity values are close to the neutral pH value of 7.0, the lowest soil resistivity value was 21,000 Ohm-cm, and values as high as 727,000 Ohm-cm have been recorded. These relatively high soil resistivity values mitigate concerns with corrosion of buried structures.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that CNP AMP B.1.6 will adequately manage the aging effects that have been observed at the applicant's plant.

7.1.1.6 UFSAR Supplement The applicant provides its UFSAR supplement for the buried piping inspection program in the CNP LRA, Appendix A, Section A.2.1.6, which states that the buried piping inspection program will manage the effects of corrosion on the pressure-retaining capability of buried carbon steel piping and tanks. This program will include periodic inspections and preventive measures to mitigate corrosion. Preventive measures will be in accordance with standard industry practice for maintaining external coatings and wrappings. Buried pipes will be inspected when they are excavated during maintenance.

The applicant states that the buried piping inspection program will be initiated prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.1.7 Conclusion Since this is a new program, final determination of its acceptability will not be made until the details of the final AMP have been submitted to the NRC staff and reviewed, which shall occurprior to the period of extended operation. This commitment is documented in Attachment 5 of this report for inclusion in the SER related to the CNP LRA. On the basis of its audit and review, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are expected to be consistent with the GALL Report. In addition, on the basis of its review of the exception to the GALL Report, the project team finds that the applicant has described a program that will adequately manage the effects of aging so 11

D.C. Cook Audit & Review Report that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.2 CAST AUSTENITIC STAINLESS STEEL (CASS) EVALUATION (CNP AMP B.1.7)

In the CNP LRA, Appendix B, Section B.1.7, the applicant states that CNP AMP B.1.7, "CASS Evaluation," is a new program that will be initiated prior to the period of extended operation.

The applicant states that the CNP AMP B.1.7 will be consistent with GALL AMP XI.M12, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)."

The program is credited with managing reduction in fracture toughness due to thermal aging embrittlement of CASS components.

7.1.2.1 Program Description The applicant states, in the CNP LRA, that the reactor coolant system components will be inspected in accordance with the American Society for Mechanical Engineers (ASME)

Section XI. The CASS evaluation program will include a determination of the susceptibility of the CASS components to thermal aging embrittlement based on casting method, molybdenum content, and percent ferrite. The applicable components are identified by reference to susceptible CASS heats in the Westinghouse Commercial Atomic Power report, WCAP-15131, "Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Design Basis for CNP Units 1 and 2 Nuclear Power Plants." The applicable CNP components will be limited to main reactor coolant system CASS (hot, cold, and cross-over legs only), including all elbows.

The stainless steel safe ends connected to the reactor vessels are forgings and are not susceptible to reduction of fracture toughness by thermal embrittlement.

The applicant states that for potentially susceptible components, aging management will be achieved using additional inspections and a component-specific flaw tolerance evaluation.

Screening for susceptibility to thermal aging will not be required for pump casings and valve bodies. The existing ASME Section XI inspection requirements, including the alternative requirements of ASME Code Case -481 for pump casings, will be adequate for all pump casings and valve bodies.

By letter dated April 23, 2004 (ML041270484), the applicant states that CNP AMP B.1.7 has been revised, for clarity, changing the words "additional inspections and a component-specific flaw tolerance evaluation" to "volumetric inspections or a component-specific flaw tolerance evaluation." The applicant states that this revised language is consistent with the GALL Report.

The applicant further states that if a flaw tolerance evaluation is used, the appropriate method for flaw tolerance will be chosen when the evaluation is initiated, prior to the end of the current operating period.

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D.C. Cook Audit & Review Report Consistent with GALL AMP XI.M12, CNP AMP B.1.7 states that all CASS pump casings and valve bodies are covered by the ASME Section XI inspection requirements, including the requirements of ASME Code Case -481.

By letter dated October 31, 2003 (ML033070177), the applicant committed to develop program details, including additional volumetric inspections or flaw tolerance evaluations. Scheduling of piping visual examinations will be conducted following ASME Section XI, IWB-2400. The monitoring and trending requirements for volumetric inspections will be identified prior to the period of extended operation.

7.1.2.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.7 will be consistent with GALL AMP XI.M12.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.7, including Engineering Report LRP-EAMP-01, Section 3.3, "Cast Austenitic Stainless Steel Evaluation Program," which provides an assessment of the AMP elements' consistency with GALL AMP XI.M12.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documents against GALL AMP XI.M12 for consistency.

7.1.2.3 Exceptions to the GALL Report None 7.1.2.4 Enhancements None 7.1.2.5 Operating Experience The applicant states, in the CNP LRA, that the CASS evaluation program is a new program for which there is no operating experience. Electric Power Research Institute (EPRI) TR-1000976, "Evaluation of Thermal Aging Embrittlement for Cast Austenitic Stainless Steel Components," is a primary basis document for the applicant's review of relevant operating experience. The applicant states that industry and plant-specific operating experience are factored into development of the AMP.

The applicant also states that it monitors national research activities and plant experiences with CASS material through its participation in the Westinghouse Owners Group. Based on its review of relevant industry operating experience, the applicant states that this program will provide reasonable assurance that the aging effects will be managed so that the applicable components will continue to perform their intended functions consistent with the CLB for the period of extended operation.

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D.C. Cook Audit & Review Report The project team recognizes that the corrective action program, which captures internal and external plant operating experience issues, will provide reasonable assurance that operating experience is reviewed and incorporated in the future to provide objective evidence to support the conclusion that the effects of aging are adequately managed.

7.1.2.6 UFSAR Supplement The applicant provides its UFSAR supplement for the CASS evaluation program in the CNP LRA, Appendix A, Section A.2.1.7. The applicant states in Appendix A that the program will augment the inspection of RCS components in accordance with the ASME Boiler and Pressure Vessel Code,Section XI. CNP AMP B.1.7 will require additional inspections and component-specific flaw tolerance evaluations. The program will manage the effects of loss of fracture toughness in RCS CASS components susceptible to thermal aging embrittlement using these additional inspections and component-specific flaw tolerance evaluations.

By letter dated April 23, 2004 (ML041270484), the applicant states that Section A.2.1.7 has been revised, for clarity, changing the words "additional inspections and a component-specific flaw tolerance evaluation" to "volumetric inspections or a component-specific flaw tolerance evaluation." The applicant states that this revised language is consistent with the GALL Report.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.2.7 Conclusion Since this is a new program, final determination of its acceptability will not be made until the details of the final AMP have been submitted to the NRC staff and reviewed, which shall occur prior to the period of extended operation. The commitment to submit the program for review is documented in Attachment 5 of this report for inclusion in the SER related to the CNP LRA. On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistencies with the GALL Report are consistent with the GALL Report. Since the GALL Report is acceptable to the staff, the project team concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.3 CONTAINMENT LEAKAGE RATE TESTING (AMP B.1.8)

In the CNP LRA, Appendix B, Section B.1.8, the applicant states that CNP AMP B.1.8, "Containment Leakage Rate Testing," is consistent with GALL AMP XI.S4, "10 CFR 50, Appendix J."

7.1.3.1 Program Description 14

D.C. Cook Audit & Review Report The applicant states, in the CNP LRA, that as described in 10 CFR 50, Appendix J, containment leak rate tests are required to assure that (a) leakage through primary reactor containment and systems and components penetrating primary containment shall not exceed allowable values specified in the technical specifications or associated bases and (b) periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during the service life of the containment and systems and components penetrating primary containment.

The applicant also states, in the CNP LRA, that the structures and components within scope for this AMP include: containment penetrations, containment buildings, compressed air systems, and bulk commodities. The containment leak rate program includes the performance of Type A, Type B, and Type C tests.

7.1.3.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.8 is consistent with GALL AMP XI.S4.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.8, including Engineering Report LRP-EAMP-01, Section 4.5, "Containment Leak Rate Program," which provides an assessment of the AMP elements' consistency with GALL AMP XI.S4. In addition, the project team also reviewed CNP EHI-5300, Rev. 1, D.C. Cook Nuclear Plant Containment Leakage Rate Testing Program (Appendix J).

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documents against GALL AMP XI.S4 for consistency.

7.1.3.3 Exceptions to the GALL Report None 7.1.3.4 Enhancements None 7.1.3.5 Operating Experience The applicant states, in the CNP LRA, that this program and the integrated leakage rate test method used have been benchmarked against the Appendix J program and leakage rate test method at other facilities. The program is consistent with comparable industry programs. An interface with industry peers is actively maintained to stay abreast of industry Appendix J issues and initiatives.

The applicant states, in the CNP LRA, that a self-assessment of the containment leakage rate testing program performed in 1999 identified several weaknesses with the program. A subsequent assessment in 2000 found that program improvements that were implemented following the previous self-assessment resolved the majority of the issues. A check of the 15

D.C. Cook Audit & Review Report program status in 2003 found that improvements have continued, which indicates that CNP is actively and critically self-assessing this program and implementing corrective actions, as necessary.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.8 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.3.6 UFSAR Supplement The applicant provides its UFSAR supplement for the containment leakage rate testing program in the CNP LRA, Appendix A, Section A.2.1.8. The applicant states in Appendix A that, as described in 10 CFR 50, Appendix J, containment leak rate tests are required to assure that (a) leakage through the primary reactor containment and SCs penetrating primary containment do not exceed allowable values and (b) periodic surveillance of reactor containment penetrations and isolation valves is performed so that proper maintenance and repairs are made during the service life of the containment. This program manages loss of material, cracking, and change in material properties, as applicable, for the equipment constituting the containment pressure boundary.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.3.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistencies with the GALL Report are consistent with the GALL Report. Since the GALL Report is acceptable to the staff, the project team concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.4 DIESEL FUEL MONITORING (AMP B.1.10)

In the CNP LRA, Appendix B, Section B.1.10, the applicant states that the CNP AMP B.1.10, "Diesel Fuel Monitoring," is consistent with GALL AMP XI.M30, "Fuel Oil Chemistry Program,"

with exceptions.

7.1.4.1 Program Description The applicant states, in the CNP LRA, that the diesel fuel monitoring program ensures that adequate diesel fuel quality is maintained to prevent corrosion of the fuel oil systems associated with the EDGs, diesel-driven fire pump, and security diesel.

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D.C. Cook Audit & Review Report 7.1.4.2 Consistency with the GALL Report In the CNP LRA the applicant states that CNP AMP B.1.10 is consistent with GALL AMP XI.M30, with exceptions.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.10, including Engineering Report LRP-EAMP-01, Section 4.7, "Diesel Fuel Monitoring Program," which provides an assessment of how the GALL AMP elements are addressed by the CNP LRA diesel fuel monitoring program.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documentation against GALL AMP XI.M30 for consistency.

7.1.4.3 Exceptions to the GALL Report The applicant states, in the CNP LRA, that the exceptions to the GALL Report elements as follows Elements: 1: Scope of Program 3: Parameters Monitored/Inspected 4: Detection of Aging Effects Exception: This program does not address, or monitor and sample for microbiologically influenced corrosion (MIC).

Element: 2: Preventive Actions Exception: No additives are used beyond what the refiner adds during production.

Elements: 3: Parameters Monitored/Inspected 6: Acceptance Criteria Exceptions: (1) Only American Society for Testing Materials (ASTM) Standard D 1796 is used for determination of water and sediment, rather than Standards D 1796 and D 2709.

(2) The CNP AMP specifies the method of ASTM Standard D 2276 with 0.8 Fm filter, instead of the modified ASTM Standard D 2276, Method A, with a 3 Fm filter.

Element: 4: Detection of Aging Effects Exception: The program does not include ultrasonic measurements of tank bottoms.

Element: 5: Monitoring and Trending Exception: Water and particulate contamination and biological activity are not trended.

The GALL Report identifies the following criteria for the scope, parameters monitored/

inspected, and detection of aging effects program elements associated with the exception taken 17

D.C. Cook Audit & Review Report The program is focused on managing the conditions that cause general, pitting, and MIC of the diesel fuel tank internal surfaces. The program serves to reduce the potential of exposure of the tank internal surface to fuel oil contaminated with water and microbiological organisms.

The AMP monitors fuel oil quality and the levels of water and microbiological organisms in the fuel oil, which cause loss of material of the tank internal surfaces.

Degradation of the diesel fuel oil tank cannot occur without exposure of the tank internal surfaces to contaminants in the fuel oil, such as water and microbiological organisms. Periodic multilevel sampling provides an assurance that fuel oil contaminants are below acceptable levels.

The applicant states, in the CNP LRA, that plant-specific operating experience has not indicated significant problems related to MIC. The applicant attributes the lack of such problems to minimizing water contamination in the diesel fuel storage tanks. The applicant also states that the diesel fuel monitoring program has been effective at managing aging effects since, in its 25 years of operating experience, no evidence of microbial degradation of the fuel or MIC-related corrosion to fuel system components has been observed. On the basis of its review of operating experience for the diesel fuel monitoring program (see Section 7.1.4.5, below), the project team finds this exception to be acceptable.

The GALL Report identifies the following criterion for the preventive actions program element associated with the exception taken The quality of fuel oil is maintained by additions of biocides to minimize biological activity, stabilizers to prevent biological breakdown of the diesel fuel, and corrosion inhibitors to mitigate corrosion.

The applicant states in the CNP LRA that the diesel fuel contains a comprehensive additive package provided by the refiner and certified by the supplier that has a higher percentage of a straight-run distillation component (instead of catalytically cracked), which lends greater resistance to fuel degradation by oxidation. Further, the storage system, which maintains the fuel at a nearly constant temperature of 55EF, enhances the diesel fuel's long-term stability.

Additionally, the applicant states that, in its 25 years of operating experience, no evidence of microbial degradation of the fuel or MIC-related corrosion to fuel system components has been observed. On the basis of its review of operating experience for the diesel fuel monitoring program (see Section 7.1.4.5, below), the project team finds this exception to be acceptable.

The GALL Report identifies the following criteria for the parameters monitored/inspected, and acceptance criteria program elements associated with the exceptions taken The ASTM Standard D 4057 is used for guidance on oil sampling. The ASTM Standards D 1796 and D 2709 are used for determination of water and sediment contamination in diesel fuel.

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D.C. Cook Audit & Review Report Modified ASTM Standard D 2276, Method A, is used for determination of particulates. The modification consists of using a filter with a pore size of 3.0 Fm, instead of 0.8 Fm.

The project team determined that of the three standards recommended by the GALL Report, only the guidance presented in ASTM Standard D 1796 applies to fuel oils with the viscosity of that used at CNP, and therefore finds this exception to be acceptable.

The guidance in the GALL Report concerning the use of modified ASTM Standard D 2276, Method A, allows for use of a filter with a larger (3.0 Fm) pore size for detection of particulates.

The project team noted that use of a filter with a smaller (0.8 Fm) pore size would not increase the likelihood that aging effects would go undetected and thus potentially affect the ability of components to perform their intended functions consistent with the CLB during the period of extended operation. The project team finds the applicant's use of ASTM Standard D 2276 to be acceptable.

The GALL Report identifies the following criterion for the detection of an aging effects program element associated with the exception taken Corrosion may occur at locations in which contaminants may accumulate, such as a tank bottom, and an ultrasonic thickness measurement of the tank bottom surface ensures that significant degradation is not occurring.

The applicant states, in the CNP LRA, that internal surfaces of tanks that are drained for cleaning are visually inspected for degradation. CNP technical specifications require that EDG fuel oil storage tanks either be drained and cleaned or that their contents undergo a filtering test every 10 years. The project team reviewed recent fuel oil operating experience, which included an ultrasonic thickness measurement of the tank bottom surface in 1995 and visual tank inspections of both EDG fuel oil storage tanks in 1996 (i.e., draining, cleaning, and inspecting).

In 1995, the applicants results of the ultrasonic measurements indicated that the tank plates were within the manufacturer's tolerance of a new plate. No measurable corrosion was detected and no corrosion was observed during the visual tank inspections. In addition, the project team determined that the introduction of fuel oil contaminants into the tanks, which cause degradation of tank bottoms, is mitigated by the applicant through compliance with diesel fuel oil standards and periodic sampling.

The applicant states, in Section 4.7.B.4 of Engineering Report LRP-EAMP-01, that corrosion may occur at locations in which contaminants accumulate, such as the tank bottom, and an ultrasonic thickness measurement of the tank bottom surface ensures that significant degradation is not occurring. The project team pointed out that this statement in the applicant's program basis document is inconsistent with the exception taken to perform ultrasonic thickness measurements to check for significant degradation. The applicant responded that ultrasonic thickness measurements will not be performed on the tank bottom surface because of the above operating experience and periodic technical specifications requirements to visually inspect the tanks every ten years.

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D.C. Cook Audit & Review Report On the basis of its review of operating experience, the 10 year visual inspection requirement in CNP technical specifications, and the controls provided to minimize introduction of fuel oil contaminants into the tanks, the project team finds this exception to be acceptable.

The GALL Report identifies the following criterion for the monitoring and trending program element associated with the exception taken:

Water and biological activity or particulate contamination concentrations are monitored and trended at least quarterly. Based on industry operating experience, quarterly sampling and analysis of fuel oil provide for timely detection of conditions conducive to corrosion of the internal surface of the diesel fuel oil tank before the potential loss of its intended function.

The applicant states that its corrective action program provides reasonable assurance that trends of repeated failures to meet acceptance criteria will be identified and addressed with appropriate corrective actions. On the basis of its review of operating experience for the diesel fuel monitoring program (see Section 7.1.4.5, below), the project team finds this exception to be acceptable.

7.1.4.4 Enhancements None 7.1.4.5 Operating Experience The applicant states, in the CNP LRA, that its review of relevant condition reports demonstrates that this program has been improved through evaluation of site and industry operating experience. As an example, the procedure that implements technical specification surveillance requirements for sampling diesel fuel was found to be inadequate in providing explicit instructions for consideration of the dyes that are used to identify the type of the fuel. A condition report documented the procedural deficiency and provided a root cause analysis to resolve the issues. Corrective actions were implemented to prevent recurrence.

The applicant also states that the diesel fuel monitoring program has been effective at managing aging effects since in its 25 years of operating experience, no evidence of microbial degradation of the fuel or MIC-related corrosion to fuel system components has been observed.

The project team reviewed records of the ultrasonic measurements of wall thickness performed on tanks AB and CD in 1995. The results indicated that the ultrasonic thickness measurements were within manufacturing tolerances for new material. Because of the detection of sediment of iron oxide in the tanks, both tanks were cleaned in 1996. Based on the observed condition of the tank walls, the sediment was attributed by the applicant to sources outside the tanks. The applicant uses the criteria from ASTM D4176-82, which specifies "clear and bright appearance" for monitoring particulate contamination of the new fuel prior to its addition to the storage tanks.

The project team noted that problems with implementing this procedure have been reported in CR P-00-10937.

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D.C. Cook Audit & Review Report The project team also reviewed Section 4.7.B.10 of Engineering Report LRP-EAMP-01, which addresses condition report results and refers to CR-00-10937 and resulting revisions to procedure 12-THP-6020-CHM-307, Emergency Diesel Fuel Oil, that implements the technical specification requirements. On the basis of corrective actions taken and documentation to the effect that filters remain free of indications of particulate contamination, the project team finds this to be acceptable.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that CNP AMP B.1.10 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.4.6 UFSAR Supplement The applicant provides its UFSAR supplement for the diesel fuel monitoring program in the CNP LRA, Appendix A, Section A.2.1.10, which states that the diesel fuel monitoring program ensures that adequate diesel fuel quality is maintained to prevent corrosion of the fuel oil systems associated with the emergency diesel engines, diesel-driven fire pump, and security diesel. This program manages aging effects on the internal surfaces of diesel fuel oil tanks and components, as applicable, within the scope of license renewal. The program monitors fuel oil quality and the contaminant concentrations in the fuel oil. Visual inspections of tanks drained for cleaning ensures that significant degradation is not occurring. This program manages the loss of material and cracking, as applicable, for fuel oil system components.

By letter dated April 23, 2004 (ML041270484), the applicant states that Appendix A, Section A.2.1.10 was revised to clarify that the program monitors fuel oil quality and contaminant concentrations using ASTM standards specified in the plant technical specifications. The applicant states that this revision was made for completeness.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.4.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the exceptions to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.5 FIRE PROTECTION (AMP B.1.11.1) 21

D.C. Cook Audit & Review Report In the CNP LRA, Appendix B, Section B.1.11.1, the applicant states that the CNP AMP B.1.11.1, "Fire Protection," will be consistent with GALL AMP X.M26, "Fire Protection," with exceptions.

7.1.5.1 Program Description The applicant states, in the CNP LRA, that the fire protection program includes a fire barrier inspection and a diesel-driven fire pump inspection. The fire barrier inspection requires periodic visual inspection of fire barrier penetration seals and fire barrier walls, ceilings, and floors; and periodic visual inspection and functional tests of fire-rated doors to ensure that their operability is maintained. The diesel-driven fire pump inspection requires that the pump be periodically tested to ensure that the fuel supply line can perform the intended function. The program includes periodic inspection and testing of the halon/carbon dioxide (CO2) fire suppression system.

7.1.5.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.11.1 will be consistent with GALL AMP XI.M26, with exceptions.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.11.1, including Engineering Report LRP-EAMP-01, Section 4.10.1, "Fire Protection Program," which provides an assessment of how the GALL AMP elements are addressed by the fire protection program.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documentation against GALL AMP XI.M26 for consistency.

7.1.5.3 Exceptions to the GALL Report The applicant states, in the CNP LRA, that exceptions to the GALL Report elements as follows Elements: 3: Parameters Monitored/Inspected 4: Detection of Aging Effects Exceptions: (1) Fire doors clearances are inspected when fire doors are physically removed for maintenance or repair or for new installations, not bi-monthly.

(2) Function tests of fire doors are performed every six months (to verify the operability of automatic hold-open, closing mechanisms, and latches), not daily, weekly, or monthly.

(3) Visual inspection and functional tests of the halon/CO2 fire suppression system are performed every 18 months, not every six months. Consistent with Interim Staff Guidance (ISG) 04, Fire Protection System Piping, inspections for charging pressure, valve lineups, and automatic mode of operation are not credited for aging management.

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D.C. Cook Audit & Review Report Element: 5: Monitoring and Trending Exception: Trending for this program is performed via the applicants corrective action program.

The GALL Report identifies the following criteria for the parameters monitored/inspected and the detection of aging effects program elements associated with those exceptions taken Hollow metal fire doors are visually inspected at least once bi-monthly for holes in the skin of the door. Fire door clearances are also checked at least once bi-monthly as part of an inspection program.

Function tests of fire doors are performed daily, weekly, or monthly (which may be plant-specific) to verify the operability of automatic hold-open, release, closing mechanisms, and latches.

Periodic visual inspection and function tests are to be performed at least once every six months to examine the signs of degradation of the halon/carbon dioxide fire suppression system.

The applicant states, in the CNP LRA, that the inspection intervals are determined by engineering evaluation to detect degradation of the fire doors prior to the loss of intended function. ISG -04 revised criteria for GALL AMP XI.M26 parameters monitored/inspected and the detection of aging effects program elements to no longer require fire doors to be visually inspected or function tested on a specific frequency. Rather, the applicant can establish a plant-specific interval to verify the integrity of door surfaces and for clearances, with plant-specific inspection intervals to be determined by engineering evaluation to detect degradation of the fire doors. The applicant's program meets ISG-04. Therefore, the project team finds this exception to be acceptable.

The GALL Report identifies the following criteria for the monitoring and trending program element associated with the exception taken:

Fire pump performance is monitored during the periodic test to detect any degradation in the fuel supply lines. Periodic testing provides data (e.g.,

pressure) necessary for trending.

Halon/CO2 fire suppression system performance is monitored during the period test to detect any degradation in the system. These periodic tests provide data necessary for trending.

The applicant states that use of its corrective action program provides reasonable assurance that trends entailing repeat failures to meet acceptance criteria will be identified and addressed with appropriate corrective actions. On this basis, the project team finds this acceptable.

7.1.5.4 Enhancements The applicant states, in the CNP LRA, that the enhancements in meeting the GALL Report elements as follows 23

D.C. Cook Audit & Review Report Elements: 3: Parameters Monitored/Inspected 4: Detection of Aging Effects 5: Monitoring and Trending 6: Acceptance Criteria Enhancements: (1) Ensure that the CO2 and halon procedures require that conditions that may affect the performance of the system (e.g., corrosion, mechanical damage, or damage to dampers) are observed and degraded conditions are addressed.

(2) Enhance procedures to ensure that the diesel fuel supply line is monitored for degradation during performance testing.

The GALL Report identifies the following criteria for the parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria program elements associated with these enhancements (1) Material conditions that may affect the performance of the halon/CO2 system, such as corrosion, mechanical damage, or damage to dampers, are observed during the periodic function tests and inspections.

(2) The diesel-driven fire pump is under observation during performance tests such as flow and discharge tests, sequential starting capability tests, and controller function tests for detecting any degradation of the fuel supply line.

(1) The periodic function test and inspection performed at least once every six months detects degradation of the halon/CO2 fire suppression system before the loss of the component intended function.

(2) The performance tests on the diesel-driven fire pump detect degradation of the fuel supply lines before the loss of the component intended function.

(1) Periodic tests of the halon/CO2 fire suppression system provide data necessary for trending.

(2) Periodic tests of the fire pump provide data necessary for trending.

(1) Signs of corrosion and mechanical damage of the halon/CO2 fire suppression system are not acceptable.

(2) No corrosion is acceptable in the fuel supply line for the diesel-driven fire pump.

The applicant states, in the CNP LRA, that these enhancements will be implemented prior to the period of extended operation. The applicant states that these enhancements will ensure that material conditions that may affect performance of the halon/CO2 fire suppression system, 24

D.C. Cook Audit & Review Report such as corrosion, mechanical damage, or damage to dampers, are monitored and are subject to the corrective action program. The applicant also states that procedure 12-OHP-4030-066-121FD will be enhanced to ensure the diesel fuel supply line is monitored for degradation during performance testing.

On the basis that the applicant will revise and clarify the requirements in its plant procedures to further ensure that aging effects are detected and addressed, the project team finds these enhancements to be acceptable.

7.1.5.5 Operating Experience The applicant states, in the CNP LRA, that its condition report review found that minor problems with fire protection equipment have been identified and resolved. Self-assessments of the program were performed in 1995 and 2002. These assessments have identified no significant aging of fire protection components. This operating experience demonstrates that the fire protection program is effectively managing the effects of aging on fire protection equipment.

The applicant also states that this conclusion is corroborated by the findings of a 1998 NRC inspection that fire protection equipment was well-maintained.

The applicant further states that as a results of its review of the condition reports, self-assessments, and NRC inspections, it concludes that implementation of the existing fire protection program maintains fire protection equipment and meets applicable regulatory requirements, and thus this program is managing aging effects on fire protection equipment.

The project team reviewed operating experience for the fire protection program. Trending data did not identify deficiencies to this program. The applicant identified a self-assessment, SA-2002-DCC-003, "Fire Protection Program," that was performed in 2002. A review of the results confirmed that no significant aging of fire protection components was identified in the review. An NRC triennial fire protection inspection was held and documented in a July 16, 2003, inspection report to the applicant. Based on a review of the latest documentation, the project team concludes that operating experience for the fire protection program has been identified, and corrective actions, where needed, have been performed as a result.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.11.1 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.5.6 UFSAR Supplement The applicant provides its UFSAR supplement for the fire protection program in the CNP LRA, Appendix A, Section A.2.1.13, which states that the fire protection program includes fire barrier inspections and a diesel-driven fire pump inspection. The fire barrier inspections entail periodic visual inspection of fire barrier penetration seals, fire barrier walls, ceilings, and floors; and periodic visual inspection and functional tests of fire-rated doors. The diesel-driven fire pump inspection requires that the pump be periodically tested to ensure that the fuel supply line can perform its intended function. This program also includes periodic inspection and testing of the halon/CO2 fire suppression system. This program requires enhancements that will be implemented prior to the period of extended operation.

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D.C. Cook Audit & Review Report The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.5.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the exceptions and enhancements to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.6 FIRE WATER SYSTEM (AMP B.1.11.2)

In the CNP LRA, Appendix B, Section B.1.11.2, the applicant states that the CNP AMP B.1.11.2, "Fire Water System," will be consistent with GALL AMP XI.M27, "Fire Service Water,"

with exceptions and enhancements.

7.1.6.1 Program Description The applicant states that CNP AMP B.1.11.2 applies to water-based fire protection systems that consist of sprinklers, nozzles, fittings, valves, hydrants, hose stations, standpipes, and above ground and underground piping and components that are tested in accordance with the applicable National Fire Protection Association (NFPA) codes and standards. Such testing assures the minimum functionality of the systems. Also, these systems are normally maintained at the required operating pressure and monitored such that leakage resulting in the loss of system pressure is immediately detected and corrective actions initiated.

In addition, the applicant states that a sample of sprinkler heads will be inspected using the guidance in Section 2.3.3.1 of NFPA 25, "Inspection, Testing and Maintenance of Water-Based Fire Protection Systems." NFPA 25 states, in part, that, "...where sprinklers have been in place for 50 years, they shall be replaced or representative samples from one or more sample areas shall be submitted to a recognized testing laboratory for field service testing." NFPA 25 also contains guidance to perform this sampling every 10 years after the initial field service testing.

7.1.6.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.11.2 will be consistent with GALL AMP XI.M27, with exceptions and enhancements.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.11.2, including 26

D.C. Cook Audit & Review Report Engineering Report LRP-EAMP-01, Section 4.10.2, "Fire Water System Program" which provides an assessment of how the GALL AMP elements are addressed by the fire water system program.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documentation against GALL AMP XI.M27 for consistency.

7.1.6.3 Exceptions to the GALL Report The applicant states, in the CNP LRA, exceptions to the GALL Report elements as follows Element: 3: Parameters Monitored/Inspected Exception: The applicant does not implement NRC Generic Letter (GL) 89-13, "Service Water System Problems Affecting Safety-Related Equipment,"

commitments in the fire water system program.

Element: 4: Detection of Aging Effects Exception: (1) Fire hydrant hose gasket inspections are performed once per 18 months rather than annually.

(2) Fire hydrant hose hydrostatic tests and fire hydrant flow tests are performed at least once every three years rather than annually.

Element: 5: Monitoring and Trending Exception: Trending for this CNP AMP is performed via the applicants corrective action program.

The GALL Report identifies the following criterion for the parameters monitored/inspected program element associated with the exception taken GL 89-13 recommends periodic flow testing of infrequently used loops of the fire water system at the maximum design flow to ensure that the system maintains its intended function.

The applicant states, in the CNP LRA, that it verifies that every fire main segment (excluding individual system supplies) is clear of obstruction by performing a full-flow test at least once every three years. ISG-04 revised criteria for GALL AMP XI.M27 parameters monitored/inspected program element to no longer recommend use of GL 89-13 in determining the system's ability to maintain pressure and internal system corrosion conditions. Rather, ISG-04 recommends either periodic flow testing of the fire water system using the guidelines of NFPA 25, Chapter 13, Annexes A and D, at the maximum design flow, or periodic wall thickness evaluations to ensure that the system maintains its intended function. On the basis of the applicant's commitment to test fire water system components in accordance with the applicable NFPA codes and standards, the project team finds that this exception meet the criteria of ISG-04 and is, therefore, acceptable.

The GALL Report identifies the following criterion for the detection of aging effects program element associated with the exceptions taken 27

D.C. Cook Audit & Review Report Visual inspection of yard fire hydrants performed once every six months ensures timely detection of signs of degradation, such as corrosion. Fire hydrant hose hydrostatic tests, gasket inspections, and fire hydrant flow tests, performed annually, ensure that fire hydrants can perform their intended function and provide opportunities for degradation to be detected before a loss of intended function can occur.

The project team finds that the applicant proposed inspection frequencies are sufficient to detect aging effects which act over a considerable period of time. On the basis of the applicant's commitment to test fire water system components in accordance with the applicable NFPA 25 guidelines, the project team finds this exception to be acceptable.

The GALL Report identifies the following criterion for the monitoring and trending program element associated with the exception taken Results of system performance testing are monitored and trended as specified by the NFPA codes and standards. Degradation identified by internal inspection is evaluated.

The applicant states, in the CNP LRA, that use of the corrective action program for monitoring and trending system performance provides reasonable assurance that trends entailing repeat failures to meet acceptance criteria will be identified and addressed with appropriate corrective actions. The project team reviewed the operating experience associated with this AMP. On the basis of this operating experience review and the applicant's commitment to test fire water system components in accordance with the applicable NFPA codes and standards, the project team finds that this exception is acceptable.

7.1.6.4 Enhancements The applicant states, in the CNP LRA, that the enhancements in meeting the GALL Report elements as follows Elements: 1: Scope of Program 4: Detection of Aging Effects Enhancement: A sample of sprinkler heads will be inspected using the guidance of NFPA 25, Section 2.3.3.1. The NFPA 25 also contains guidance to repeat this sampling every 10 years after the initial field service testing.

Elements: 1: Scope of Program 4: Detection of Aging Effects 5: Monitoring and Trending Enhancement: The program will be enhanced to implement the requirements of ISG-4 pertaining to nonintrusive measurement of pipe wall thickness.

The GALL Report identifies the following criterion for the scope of program and detection of aging effects program elements associated with the enhancement 28

D.C. Cook Audit & Review Report Sprinkler systems are inspected once every refueling outage to ensure that signs of degradation, such as corrosion, are detected in a timely manner.

ISG-04 revised criteria for GALL AMP XI.M27 detection of aging effects program element to recommend sprinkler head inspections before the end of the 50-year sprinkler head service life and at 10-year intervals thereafter during the extended period of operation to ensure that signs of degradation are detected in a timely manner. On the basis of the revised GALL criteria in ISG-04 and the applicant's commitment to rely upon applicable codes and standards to develop test procedures, the project team finds this enhancement to be acceptable.

The GALL Report identifies the following criteria for the scope of program, detection of aging effects, and monitoring and trending program elements associated with the enhancement Portions of fire protection suppression piping located aboveground and exposed to water are disassembled and visually inspected internally once every refueling outage.

Internal inspections of aboveground fire protection piping and the smaller diameter fire suppression piping are performed on system components (when they are disassembled) to identify evidence of loss of material due to corrosion.

Degradation identified by internal inspection of aboveground piping is evaluated.

ISG-04 revised criteria for GALL AMP XI.M27 scope, detection of aging effects, and monitoring and trending program elements to recommend non-intrusive (i.e., volumetric test) examinations of fire system piping to detect signs of internal corrosion as an alternative to disassembly of pipe segments for inspection. ISG-04 recommends that applicants perform baseline non-intrusive pipe wall thickness evaluations of their fire protection piping to detect this aging effect before the current license term expires. The staff further recommends, in ISG-04, that pipe wall thickness evaluations be performed at plant-specific intervals, determined by post-inspection engineering evaluations, during the period of extended operation. On the basis of the revised GALL criteria in ISG-04 and the applicant's commitment to rely upon applicable codes and standards to develop test procedures, the project team finds this enhancement to be acceptable.

7.1.6.5 Operating Experience The applicant states, in the CNP LRA, that operating experience for the fire water system is included with that for the fire protection system because the CNP procedures, self-assessments, and NRC inspections cover both programs as one. The applicant's condition report review found that minor problems with fire protection equipment have been identified and resolved. Self-assessments of the program were performed in 1995 and 2002. These assessments have identified no significant aging of fire protection components. This operating experience demonstrates that the fire protection program is effectively managing the effects of aging on fire protection equipment. The applicant also states that this conclusion is corroborated by the findings of a 1998 NRC inspection that fire protection equipment was well-maintained.

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D.C. Cook Audit & Review Report The applicant further states that as a results of its review of the condition reports, self-assessments, and NRC inspections, it concludes that implementation of the existing fire protection program maintains fire protection equipment and meets applicable regulatory requirements, and thus this program is managing aging effects on fire protection equipment.

The project team reviewed operating experience for the fire water system program. Trending data did not identify a need for improvement to this program. The applicant identified a self-assessment, SA-2002-DCC-003, "Fire Protection Program," that was performed in 2002. A review of the results confirmed that no significant aging of fire protection components was identified in the review. A NRC triennial fire protection inspection was held and documented in a July 16, 2003, inspection report to the applicant. Based on a review of the latest documentation, the project team concludes that operating experience for the fire water system program has been captured and program enhancements have been performed as a result.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.11.2 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.6.6 UFSAR Supplement The applicant provides its UFSAR supplement for the fire water system program in the CNP LRA, Appendix A, Section A.2.1.14, which states that the fire water system program applies to water-based fire protection systems that consist of sprinklers, nozzles, fittings, valves, hydrants, hose stations, standpipes, water storage tanks, and aboveground and underground piping and components that are tested in accordance with the applicable NFPA codes and standards.

Such testing assures the minimum functionality of the systems. These systems are normally maintained at required operating pressure and monitored such that leakage resulting in loss of system pressure is immediately detected and corrective actions initiated. A sample of sprinkler heads will be inspected using the guidance of NFPA 25. This program requires enhancements that will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.6.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the exceptions and enhancements to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

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D.C. Cook Audit & Review Report 7.1.7 FLOW-ACCELERATED CORROSION (AMP B.1.12)

In the CNP LRA, Appendix B, Section B.1.12, the applicant states that CNP AMP B.1.12, "Flow-Accelerated Corrosion," is consistent with GALL AMP XI.M17, "Flow-Accelerated Corrosion."

7.1.7.1 Program Description The applicant states, in the CNP LRA, that its flow-accelerated corrosion (FAC) program assures that the structural integrity of carbon steel lines containing high-energy fluids is maintained. This FAC program includes (a) an analysis to determine critical locations, (b) limited initial operational (i.e., baseline) inspections to determine the extent of thinning at these locations, and c) follow-up inspections to confirm the predictions, and (d) to repair or to replace components as necessary.

During its review, the project team noted that CNP LRA Section B.1.12 did not credit the FAC program for detecting aging effects in the main steam nozzles, consistent with CNP LRA Table 3.1.2-5. The applicant stated that it would revise CNP AMP B.1.12 to reflect the applicability of this AMP to these in-scope low-alloy steel components. By letter dated April 23, 2004 (ML041270484), the applicant stated that Section B.1.12 had been revised to state that the FAC program assures that the structural integrity of both carbon steel pipes containing high-energy fluids and the low-alloy steel steam generator main steam nozzles are maintained.

The project team reviewed the applicants response and concludes that it is acceptable.

7.1.7.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.12 is consistent with GALL AMP XI.M17.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.12, including condition reports, program procedures, and Engineering Report 12-EHP-5022-001-001, "Program for Implementing FAC Inspection Program NUREG-1801 XI.M17 Flow-Accelerated Corrosion," Rev. 1, which provides an assessment of the AMP elements' consistency with GALL AMP XI.M17.

The project team also reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documents against GALL AMP XI.M17 for consistency.

7.1.7.3 Exceptions to the GALL Report None 7.1.7.4 Enhancements None 7.1.7.5 Operating Experience 31

D.C. Cook Audit & Review Report The applicant states, in the CNP LRA, that a review of condition reports provides evidence of the effectiveness of its FAC program. As an example, a number of carbon steel components were replaced with stainless steel components in 2002 to preclude recurrence of inspection findings. In another instance, a 2002 condition report identified a specific component sample location that did not meet the FAC inspection criteria. Engineering evaluation based on operating history and experience determined the need to expand the number of sample locations and increase inspection requirements.

The applicant also states that its quarterly "health reports" are used by site management to track the performance of the FAC program. Performance indicators are used to determine if the FAC program is meeting industry and regulatory standards. These reports document inspection effectiveness in identifying components for replacement prior to failure.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.12 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.7.6 UFSAR Supplement The applicant provides its UFSAR supplement for the FAC program in the CNP LRA, Appendix A, Section A.2.1.15. The applicant states in Appendix A that the program includes (a) an analysis to determine critical locations, (b) limited baseline inspections to determine the extent of thinning at these locations, and ©) follow-up inspections to confirm the predictions, or component repair or replacement as necessary. This program assures that the structural integrity of carbon steel pipes containing high-energy fluids is maintained.

During its review, the project team noted that CNP LRA Section A.2.1.15 did not credit the FAC program for detecting aging effects in low-alloy steel components. The applicant stated that it would revise Appendix A to reflect the applicability of this AMP to in-scope low-alloy steel components. By letter dated April 23, 2004 (ML041270484), the applicant stated that Appendix A had been revised to state that the FAC program assures that the structural integrity is maintained for both carbon steel pipes containing high-energy fluids and the low-alloy steel steam generator main steam nozzles. The project team reviewed the applicants response and concludes that it is acceptable.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.7.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistencies with the GALL Report are consistent with the GALL Report. Since the GALL Report is acceptable to the staff, the project team concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

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D.C. Cook Audit & Review Report On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.8 HEAT EXCHANGER MONITORING (AMP B.1.13)

In the CNP LRA, Appendix B, Section B.1.13, the applicant describes CNP AMP B.1.13, "Heat Exchanger Monitoring."

The applicant states that CNP AMP B.1.13 is a plant-specific program. The applicant credits this program with inspecting heat exchangers for age-related degradation. If degradation is found, then an evaluation will be performed to evaluate its effects on the heat exchanger's design functions, including seismic operability.

The project team reviewed the documents listed in Attachment 4 of this audit and review report, in whole or in part, including CNP LRP-EAMP-01, Evaluation of Aging Management Programs, Rev. 2, Section 4.18, "Service Water System Reliability Program" and CNP LRP-NGPR-01, "Non-GALL Precedent Review for the LRA," Draft Rev. 0, Attachment B-5, "Heat Exchanger Monitoring Program," for the heat exchanger monitoring program and interviewed the applicant's technical staff.

7.1.8.1 Review of the AMP Against the Program Elements The project team reviewed CNP AMP B.1.13 against the AMP elements found in the SRP-LR, Appendix A.1, Section A.1.2.3 and SRP-LR Table A.1-1. The guidance described in the CNP audit and review plan was followed.

7.1.8.1.1 Scope of Program The applicant states in CNP AMP B.1.13 that the "scope of program" program element encompasses managing aging effects on heat exchangers in the following systems:

containment spray, emergency core cooling, containment equalization/hydrogen skimmer, component cooling water, emergency diesel generator, engineered safety features ventilation, control room ventilation, chemical and volume control, and auxiliary feedwater.

This program element criterion in Appendix A.1 of the SRP-LR requires that the program scope include the specific structures and components addressed with this program.

The project team confirmed that the specific components for which the heat exchanger monitoring program manages aging effects are identified in Section 3 of the CNP LRA, which satisfies the criterion defined in Appendix A.1 of the SRP-LR. On this basis, the project team finds that the applicant's proposed scope is acceptable.

7.1.8.1.2 Preventive Actions The applicant states in CNP AMP B.1.13 that the "preventive actions" program element is not applicable because the heat exchanger monitoring program is an inspection program and no actions will be taken as part of this program to prevent or mitigate aging degradation.

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D.C. Cook Audit & Review Report This program element criterion in Appendix A.1 of the SRP-LR is that condition monitoring programs do not rely on preventive actions, and thus, preventive actions need not be provided.

The project team confirmed that the preventive actions program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The project team did not identify the need for preventive actions for AMP B.1.13 because it is a condition monitoring program.

7.1.8.1.3 Parameters Monitored/Inspected The applicant states in CNP AMP B.1.13, for the "parameters monitored or inspected" program element, that non-destructive examinations will be performed. Eddy current testing will be used to identify wall thinning and cracking in shell-and-tube heat exchangers. Heat exchanger heads, covers, and tube sheets will be inspected using visual inspection methods. Where monitoring is impractical, replacement will be evaluated.

This program element criteria in Appendix A.1 of the SRP-LR are The parameters to be monitored or inspected should be identified and linked to the degradation of the particular structure and component intended function(s).

The parameter monitored or inspected should detect the presence and extent of aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A of the SRP-LR. The heat exchanger monitoring program is acceptable because the non-destructive examinations of the heat exchangers are intended to detect the presence and extent of aging effects. On this basis, the project team finds that the parameters monitored or inspected program element is acceptable.

7.1.8.1.4 Detection of Aging Effects The applicant states in CNP AMP B.1.13 for the "detection of aging effects" program element that The aging effects being managed by this program for the tubes are loss of material and cracking. An appropriate sample population of heat exchangers will be determined based on operating experience prior to the inspections. The extent and schedule of the inspections prescribed by the program are designed to maintain seismic qualification and ensure that aging effects will be discovered and repaired before the loss of intended function.

The eddy current inspection of the tubes will be every 10 years, or more frequently if inspection results indicate a need for more frequent inspections.

The visual inspections of the accessible heat exchangers will be performed on the same frequency as the eddy current inspections. Where inspection is impractical, replacement will be considered.

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D.C. Cook Audit & Review Report Inspection can reveal cracking and loss of material that could result in degradation in the seismic qualification of the heat exchangers. Fouling is not addressed by this program.

The criteria for this program element in Appendix A.1 of the SRP-LR are Provide information that links the parameters to be monitored or inspected to the aging effects being managed.

Describe when, where, and how program data are collected (i.e., all aspects of activities to collect data as part of the program).

Link the method or technique and frequency, if applicable, to plant-specific or industry-wide operating experience.

Provide the basis for the inspection population and sample size when sampling is used to inspect a group of SCs. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. Testing techniques will be developed, based on industry operating experience; sample population of heat exchangers will be determined based on operating experience prior to the inspections; and eddy current inspection of the tubes will be every 10 years, or more frequently if inspection results indicate a need for more frequent inspections. The applicant has committed to developing testing techniques, and this commitment is captured in Attachment 5 to this report. On this basis, the project team finds that the detection of aging effects program element is acceptable.

7.1.8.1.5 Monitoring and Trending The applicant states in CNP AMP B.1.13 for the "monitoring and trending" program element that Results will be evaluated against established acceptance criteria and an assessment will be made regarding the applicable degradation mechanism, degradation growth rate, and the allowable degradation level. This information will be used to develop future inspection scope and inspection intervals.

The criteria for this program element in Appendix A.1 of the SRP-LR are Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions.

This program element describes how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.

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D.C. Cook Audit & Review Report The project team confirms that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. Trending of inspection results will be performed and will enhance the applicant's ability to detect aging effects before there is a loss of intended function. On this basis, the project team also finds that the monitoring and trending program is acceptable.

7.1.8.1.6 Acceptance Criteria The applicant states in CNP AMP B.1.13 for the "acceptance criteria" program element that The tube plugging limit for each heat exchanger to be eddy-current inspected will be established based upon a component-specific engineering evaluation. This evaluation will determine conservative acceptance criteria that will identify when degraded tubes must be removed from service.

The acceptance criterion for visual inspections of heat exchanger heads, covers, and tube sheets will be no evidence of degradation that could lead to loss of function. If degradation that could lead to loss of intended function is detected, a condition report will be written and the issue resolved in accordance with the site corrective action program.

The criteria for this program element in Appendix A.1 of the SRP-LR are The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the structures and component (SC) intended function(s) are maintained under all CLB design conditions during the period of extended operation.

The program should include a methodology for analyzing the results against applicable acceptance criteria.

Qualitative inspections should be performed to same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site-specific programs.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. Any degradation that is identified from visual inspections and could lead to loss of intended function will be found unacceptable and corrective measures implemented, using the corrective action program. The applicant has committed to establish tube plugging limits based on a component-specific engineering evaluation, and this is identified in Attachment 5 to this report. On this basis, the project team finds that the acceptance criteria program element is acceptable.

7.1.8.1.7 Corrective Actions This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.8.1.8 Confirmation Process 36

D.C. Cook Audit & Review Report This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.8.1.9 Administrative Controls This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.8.1.10 Operating Experience The applicant states in CNP AMP B.1.13 that the heat exchanger monitoring program is a new program for which there is no operating experience. Eddy current inspections and heat exchanger internal visual inspections are standard industry methods to manage aging effects in heat exchangers. These methods are consistent with NRC-accepted industry practices.

Industry and plant-specific operating experience will be considered in the development of this program, as appropriate.

The "operating experience" program element criterion in Appendix A.1 of the SRP-LR states that operating experience should provide objective evidence to support the conclusion that the effects of aging will be managed adequately so that the SC intended function(s) will be maintained during the period of extended operation.

The project team reviewed the records associated with implementation of the GL 89-13 to confirm that plant-specific data, including the results of non-destructive evaluations, are being collected on heat exchangers and used in an appropriate manner.

The project team recognizes that the corrective action program, which captures internal and external plant operating experience issues, will provide reasonable assurance that operating experience is reviewed and incorporated in the future to provide objective evidence to support the conclusion that the effects of aging are adequately managed.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.13 will adequately manage the aging effects that have been observed at the applicant's plant.

7.1.8.2 UFSAR Supplement The applicant provides its UFSAR supplement for the heat exchanger monitoring program in the CNP LRA, Appendix A, Section A.2.1.16, and states that the program will manage loss of material and cracking, as applicable, on heat exchangers exposed to treated water in various systems. The program will inspect heat exchangers for degradation using non-destructive examinations, such as eddy-current inspections and visual inspections. If degradation is found, then an evaluation will be performed to determine its effects on the heat exchanger's design functions. The applicant states in Appendix A that the heat exchanger monitoring program will be initiated prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

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D.C. Cook Audit & Review Report 7.1.8.3 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.9 INSERVICE INSPECTION - ASME SECTION XI, SUBSECTIONS IWB, IWC, and IWD (AMP B.1.14)

In the CNP LRA, Appendix B, Section B.1.14, the applicant states that CNP AMP B.1.14, "Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD," is an existing plant program that is consistent with the GALL XI.M1, "Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD."

7.1.9.1 Program Description The applicant states, in the CNP LRA, that it has implemented the applicable requirements of the 1989 Edition of ASME Boiler and Pressure Vessel (B&PV) Code Section XI, approved NRC alternatives and relief requests, and other requirements specified in 10 CFR 50.55a for the third inservice inspection interval.

7.1.9.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.14 is consistent with GALL AMP XI.M1.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.14, including Engineering Report LRP-EAMP-01, Section 4.12.1, "ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program," which provides an assessment of the AMP elements' consistency with GALL AMP XI.M1.

The project team also reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documents against GALL AMP XI.M1 for consistency.

7.1.9.3 Exceptions to the GALL Report None 7.1.9.4 Enhancements None 7.1.9.5 Operating Experience 38

D.C. Cook Audit & Review Report The applicant states, in the CNP LRA, that it condition reports document the identification and resolution of program findings, which demonstrates that the program effectively monitors pressure-retaining components and prescribes appropriate actions when problems are found.

The project team reviewed the applicants self-assessment performed in 1999 for Subsection IWB, IWC and IWD inservice inspection program. This assessment concluded that this program provides the necessary administrative controls to ensure Code compliance, although programmatic elements relating to conflicting policy and procedures contributed to a lack of overall program cohesiveness. As a result of the self-assessment, the applicant revised the programs procedures to incorporate the changes as recommended. The project team confirmed that these changes have been implemented.

The project team also reviewed an internal study performed by the applicant that summarized documented analyses of flaws discovered during inservice inspections. The project team agrees with the applicant that this review identified no analytical flaws requiring further evaluation. The project team finds that this program effectively manages aging effect for the current operating term. However, in a letter dated June 30, 2004 (ML041840218), RAI 3.1-8, staff requested the applicant to propose a plan to monitor and evaluate detected and evaluated flaws in the RPV and control rod drive mechanism components identified in LRA Table 3.1.2-1 for the period of extended operation because disposition of these detected flaws has been previously based on the current operating term of 40 years. NRR DE will disposition this RAI in Section 3.0.3 of the SER related to the CNP LRA.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.14 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.9.6 UFSAR Supplement The applicant provides its UFSAR supplement for the inservice inspection-ASME Section XI, Subsections IWB, IWC, and IWD program in the CNP LRA, Appendix A, Section A.2.1.17. The applicant states that the ASME Section XI, Subsections IWB, IWC and IWD program implements the applicable requirements of ASME Section XI, approved NRC alternatives and relief requests, and other requirements specified in 10 CFR 50.55a. Every 10 years, the inservice inspection long-term plan is updated for each unit to the latest ASME Section XI code edition and addendum approved by the NRC in the current edition of 10 CFR Part 50. The long-term plan is a detailed listing and inspection schedule of components within the inservice inspection boundary.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.9.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistencies with the GALL Report are consistent with the GALL Report. Since the GALL Report is acceptable to the staff, the project 39

D.C. Cook Audit & Review Report team concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.10 INSERVICE INSPECTION - ASME SECTION XI, SUBSECTION IWE (AMP B.1.15)

In the CNP LRA, Appendix B, Section B.1.15, the applicant states that the CNP AMP B.1.15, "Inservice Inspection - ASME Section XI, Subsection IWE," is an existing plant program that is consistent with GALL AMP XI.S1, "ASME Section XI, Subsection IWE," with exceptions.

7.1.10.1 Program Description The applicant states, in the CNP LRA, that 10 CFR 50.55a specifies the examination requirements of the ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWE, for steel liners of concrete containments and other containment components. The applicant also states that it has implemented ASME Section XI, 1992 Edition with the 1992 Addenda, as approved in 10 CFR 50.55a. Subsection IWE and the additional requirements specified in 10 CFR 50.55a(b)(2) constitute an existing required program that is applicable to managing aging for license renewal.

The applicant states, in the CNP LRA, that the Subsection IWE program encompasses (1) concrete containment steel liners and their integral attachments; (2) containment hatches and airlocks; seals, (3) gaskets, and moisture barriers; and (4) pressure-retaining bolting. The primary inservice inspection method specified in Subsection IWE is visual examination (general visual, VT-3, or VT-1). Limited volumetric examination (ultrasonic thickness measurement) and surface examination (e.g., liquid penetrant) may also be necessary in some instances.

Subsection IWE specifies acceptance criteria, corrective actions, and expansion of the inspection scope when degradation exceeding the acceptance criteria is found.

7.1.10.2 Consistency with the GALL Report In the CNP LRA the applicant states that CNP AMP B.1.15 is consistent with GALL AMP XI.S1, with exceptions.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.15, including Engineering Report LRP-EAMP-01, Section 4.12.2, "ASME Section XI Inservice Inspection, Subsection IWE Program," which provides an assessment of how the GALL AMP elements are addressed by the CNP LRA ASME Section XI, Subsection IWE program.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documentation against GALL AMP XI.S1 for consistency.

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D.C. Cook Audit & Review Report 7.1.10.3 Exceptions to the GALL Report The applicant states, in the CNP LRA, that exceptions to the GALL Report elements as follows Element: 1: Scope 3: Parameters Monitored/Inspected Exception: (1) Category E-D seals and gaskets are not examined.

(2) Category E-G bolt torque or tension test is not included.

Element: 5: Monitoring and Trending Exception: Successive examinations required by IWE-2420(b) and IWE-2430©) are limited to Class MC components accepted by evaluation per IWE-3122.4, excluding successive examination of repaired components.

The GALL Report identifies the following criteria for the scope and parameters monitored or inspected program elements associated with the exceptions taken The components within the scope of Subsection IWE are Class MC pressure-retaining components and their integral attachments; metallic shell and penetration liners of Class CC containments and their integral attachments; containment seals and gaskets; containment pressure-retaining bolting; and metal containment surface areas.

Table IWE-2500-1 specifies that Category E-D seals and gaskets are to undergo visual (VT-3) examination; Category E-G pressure-retaining bolts are to undergo visual (VT-1) examination as well as bolt torque or tension tests.

The applicant cites approved relief requests that Allow for verifying the pressure-retaining capability of seals and gaskets by 10 CFR 50, Appendix J, Type B leakage testing. The applicant states that Appendix J Type B leakage testing is performed at least once each inspection interval.

Include the following alternate provisions to ensure the structural integrity and the leak-tightness of Class MC pressure-retaining bolting: (a) exposed surfaces of bolted connections shall be visually examined in accordance with requirements of Table IWE-2500-1, Examination Category E-G, Pressure Retaining Bolting, Item No. E8.10; and (b) bolted connections shall meet the pressure test requirements of Table IWE-2500-1 Examination Category E-P, All Pressure Retaining Components, Item No. E9.40.

The project team reviewed the relief requests and finds that these relief requests provide alternative methods for ensuring that the pressure boundary and structural integrity functions are maintained, negating the usefulness of performing additional tests in accordance with the GALL Report recommendations. On this basis, the project team finds these exceptions to be acceptable.

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D.C. Cook Audit & Review Report The GALL Report identifies the following criterion for the monitoring and trending program element associated with the exception taken:

When component examination results require evaluation of flaws, areas of degradation, or repairs, and the component is found to be acceptable for continued service, the areas containing such flaws, degradation, or repairs shall be reexamined during the next inspection period, in accordance with examination category E-C. When these reexaminations reveal that the flaws, areas of degradation, or repairs remain essentially unchanged for three consecutive inspection periods, these areas no longer require augmented examination in accordance with examination category E-C.

The applicant cites an approved relief request that limits the successive examinations required by IWE-2420(b) and IWE-2430©) to Class MC components accepted by evaluation per IWE-3122.4. This limitation excludes successive examination of repaired components.

The project team reviewed the relief request and, on that basis, finds the exception to be acceptable.

7.1.10.4 Enhancements None 7.1.10.5 Operating Experience The applicant states, in the CNP LRA, that a self-assessment of Subsection IWE and IWL programs was performed in the fall of 1999, when these programs and their respective implementing documents were under development. The review concluded that Subsection IWE and IWL programs would be effective structural monitoring programs.

The applicant also states that operating experience, as documented in condition reports and licensee event reports, indicates that the program effectively monitors containment liner condition and prescribes appropriate actions when problems are found. For example, a hole was found in the Unit 2 containment liner during the IWE general visual examination. This hole, which went undetected until the first IWE examination, was caused by an inadequate repair of a hole erroneously drilled through the liner during original construction. As another example, liner corrosion was identified when the concrete floor-to-liner joint seal was removed. This area of the liner plate is normally inaccessible and exempt from IWE examination requirements.

However, the IWE program was revised to add examinations of this area.

The project team reviewed the operating experience associated with this AMP, including the CNP SA-1999-ENP-015, a self-assessment performed by the applicant in 1999. Several condition reports and two licensee event reports were generated as a result of the self assessment and other inspections. The IWE program was revised as a result of the identified conditions and corrective actions. The project team confirmed that the IWE program was revised and on this basis, find this program to be acceptable.

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D.C. Cook Audit & Review Report On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.15 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.10.6 UFSAR Supplement The applicant provides its UFSAR supplement for the inservice inspection - ASME Section XI, Subsection IWE program in the CNP LRA, Appendix A, Section A.2.1.18, which states that ASME Code Section XI, Subsection IWE and the additional requirements specified in 10 CFR 50.55a(b)(2) constitute an existing required program applicable to managing aging of steel liners of concrete containments and other containment components. The program uses visual examination, limited volumetric examination, and surface examination, as required.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.10.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the exceptions to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.11 INSERVICE INSPECTION - ASME SECTION XI, SUBSECTION IWF (AMP B.1.16)

In the CNP LRA, Appendix B, Section B.1.16, the applicant states that CNP AMP B.1.16, "Inservice Inspection - ASME Section XI, Subsection IWF," is consistent with GALL AMP XI.S3, "ASME Section XI, Subsection IWF."

7.1.11.1 Program Description The applicant states, in the CNP LRA, that this program is an existing required program applicable to managing aging of ASME Class 1, 2, 3, and MC supports. The Subsection IWF scope of inspection includes a sample of the total support population. The applicant states that sample size varies depending on the ASME Class. The largest sample size is specified for the most critical supports such as ASME Class 1 and the sample size decreases for the less critical supports such as ASME Class 2 and 3.

The applicant further states that discovery of support deficiencies during regularly scheduled inspections would triggers an increase in the inspection scope to ensure that the full extent of deficiencies is identified. The primary inspection method is visual examination. During regular 43

D.C. Cook Audit & Review Report schedule inspection, any degradation that could potentially compromises support function or load capacity is identified for evaluation. The applicant also states that Subsection IWF program specifies acceptance criteria and corrective actions such that supports requiring corrective actions are re-examined during the next inspection period.

The applicant states that it applicant has implemented the applicable requirements of the 1989 Edition of ASME Section XI, approved NRC alternatives and relief requests, and other requirements specified in 10 CFR 50.55a for the third inservice inspection interval.

7.1.11.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.16 is consistent with GALL AMP XI.S3.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.16, including Engineering Report LRP-EAMP-01, Section 4.12.3, "ASME Section XI Inservice Inspection, Subsection IWF Program," which provides an assessment of the AMP elements' consistency with GALL AMP XI.S3.

The project team also reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documents against GALL AMP XI.S3 for consistency.

7.1.11.3 Exceptions to the GALL Report None 7.1.11.4 Enhancements None 7.1.11.5 Operating Experience The applicant states, in the CNP LRA, that self-assessment of the Subsection IWF program was performed in the fall of 1999 (SA-1999-ENP-015). This self-assessment concluded that the program provides the necessary administrative controls to ensure code compliance, but that elements relating to conflicting policy and procedures had contributed to a lack of overall program cohesiveness. The applicant states that Procedure PMI-5070, "Inservice Inspection and Testing," was revised and PMP-5070-ISI-002, "Inservice Inspection Program Implementation," was added to incorporate the changes recommended by this self-assessment.

The applicant also states that because of these improvements to its procedures, this program found and resolved only minor problems, such as missing fasteners on ductwork supports. The applicant concludes that this operating experience indicates that the program is effectively monitoring supports and taking appropriate actions when problems are found.

The project team reviewed these procedures and agrees with the applicant that the effects of aging will be effectively manage by this program and, therefore, is acceptable.

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D.C. Cook Audit & Review Report On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.16 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.11.6 UFSAR Supplement The applicant provides its UFSAR supplement for the inservice inspection - ASME Section XI, Subsection IWF program in the CNP LRA, Appendix A, Section A.2.1.19. The applicant states in Appendix A that the program includes inservice inspection of supports for ASME piping and components. The applicant states that this AMP is an existing required program applicable to managing aging of ASME Class 1, 2, 3, and MC supports. The program uses visual examinations of a sample of the total support population.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.11.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistencies with the GALL Report are consistent with the GALL Report. Since the GALL Report is acceptable to the staff, the project team concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.12 INSERVICE INSPECTION - ASME SECTION XI, SUBSECTION IWL (AMP B.1.17)

In the CNP LRA, Appendix B, Section B.1.17, the applicant states that the CNP AMP B.1.17, "Inservice Inspection - ASME Section XI, Subsection IWL," is an existing plant program that is consistent with GALL AMP XI.S2, "ASME Section XI, Subsection IWL," with exceptions.

7.1.12.1 Program Description 10 CFR 50.55a specifies the examination requirements of the ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWL, for reinforced concrete containments (Class CC).

The applicant has implemented ASME Section XI, 1992 Edition with the 1992 Addenda, as approved in 10 CFR 50.55a. Subsection IWL and the additional requirements specified in 10 CFR 50.55a(b)(2) constitute an existing required program that is applicable to managing aging for license renewal.

7.1.12.2 Consistency with the GALL Report 45

D.C. Cook Audit & Review Report In the CNP LRA the applicant states that CNP AMP B.1.17 is consistent with GALL AMP XI.S2, with exceptions.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.17, including Engineering Report LRP-EAMP-01, Section 4.12.4, "ASME Section XI Inservice Inspection, Subsection IWL Program" which provides an assessment of how the GALL AMP elements are addressed by the CNP LRA ASME Section XI, Subsection IWL program.

The applicant's basis document states that this program is credited for containment buildings.

The Class CC components subject to examination include the containment concrete walls and dome. The project team also reviewed the CNP Units 1 and 2, Containment Inservice Inspection Program Plan," Appendix E, "IWL Inspection Basis Document."

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documentation against GALL AMP XI.S2 for consistency.

7.1.12.3 Exceptions to the GALL Report The applicant states, in the CNP LRA, that exceptions to the GALL Report elements as follows:

Elements: 1: Scope 3: Parameters Monitored/Inspected 5: Monitoring and Trending 6: Acceptance Criteria Exception: Post-tensioning systems are not in the scope of this program.

Element: 4: Detection of Aging Effects Exception: The maximum direct examination distance specified for remote visual examinations may be extended and the minimum illumination requirements specified may be decreased provided the conditions or indications for which the visual examination is performed can be detected at the chosen distance and illumination.

The GALL Report identifies the following criteria for the scope, parameters monitored or inspected, monitoring and trending, and acceptance criteria program elements associated with the exceptions taken:

The components within the scope of Subsection IWL are reinforced concrete and unbonded post-tensioning systems of Class CC containments, as defined by CC-1000.

Table IWL-2500-1 requires visual examination of tendon anchorage and wires or strands for cracks, corrosion, and mechanical damage. Tendon wires or strands are also tested for yield strength, ultimate tensile strength, and elongation.

Tendon corrosion protection medium is tested by analysis for alkalinity, water content, and soluble ion concentrations.

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D.C. Cook Audit & Review Report For prestressed containments, trending of prestressing forces in tendons is required in accordance with paragraph (b)(2)(viii) of 10 CFR 50.55a.

Qualitative acceptance criteria are provided for the post-tensioning system tendon force and elongation, tendon wire or strand samples, and corrosion protection medium.

The applicant states that it does not have a post-tensioning system. The project team agrees with the applicant and on this basis, the project team finds this exception to be acceptable.

The GALL Report identifies the following criterion for the detection of aging effects program element associated with the exceptions taken The frequency and scope of examinations specified in 10 CFR 50.55a and Subsection IWL ensure that aging effects would be detected before they would compromise the design-basis requirements. The frequency of inspection is specified in IWL-2400. Concrete inspections are performed in accordance with Examination Category L-A. Under Subsection IWL, inservice inspections for concrete and unbonded post-tensioning systems are required at one, three, and five years following the structural integrity test. Regarding detection methods for aging effects, all concrete surfaces receive a visual VT-3C examination.

Selected areas, such as those that indicate suspect conditions and areas surrounding tendon anchorages, receive a more rigorous VT-1 or VT-1C examination. These visual examination methods and testing would identify the aging effects of accessible concrete components and prestressing systems in concrete containments.

The applicant states, in the CNP LRA, that an approved relief request that includes the alternate provisions that when performing the visual examinations required per IWL-2510 remotely, the maximum direct examination distance specified in Table IWA-2210-1 may be extended and the minimum illumination requirements specified in Table IWA-2210-1 may be decreased provided that the conditions or indications for which examination is performed can be detected at the chosen distance and illumination. On the basis of the approved relief request, the project team finds this exception to be acceptable.

7.1.12.4 Enhancements None 7.1.12.5 Operating Experience The applicant states, in the CNP LRA, that a self-assessment of the Subsection IWE and IWL programs was performed in the fall of 1999, when the programs and their respective implementing documents were under development. The review concluded that Subsection IWE and IWL programs would be effective structural monitoring programs.

The applicant also states that operating experience for the Subsection IWL program, although limited, indicates that this program effectively monitors containment concrete condition and prescribes appropriate actions when problems are found. Program inspections have identified 47

D.C. Cook Audit & Review Report only minor problems. A Subsection IWL inservice inspection conducted in 2001 revealed several surface discrepant conditions in the form of buried wood, exposed rebar, and plastic.

Based on the evaluation of the conditions, the applicant concluded that the containment structural integrity was unaffected. The applicant further states that the program will continue to trend these areas at inspection interval frequencies sufficient to discover degradation well in advance of impact on the structural integrity of the containment structure.

The project team reviewed the operating experience for the ASME Section XI Subsection IWL program, including the results of the inspection conducted in 2001 (NED-2001-034-REP and CR-01283012). The project team agrees with the applicant that the containment structural integrity is unaffected by the presence of foreign material or exposed reinforcing bar.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.17 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.12.6 UFSAR Supplement The applicant provides its UFSAR supplement for the inservice inspection - ASME Section XI Subsection IWL program in the CNP LRA, Appendix A, Section A.2.1.20, which states that 10 CFR 50.55a specifies the examination requirements of the ASME Boiler and Pressure Vessel Code,Section XI, Subsection IWL for reinforced concrete containments (Class CC).

ASME Code Section XI, Subsection IWL and the additional requirements specified in 10 CFR 50.55a(b)(2) constitute an existing required program applicable to managing aging of reinforced concrete containment systems. The ASME Section XI, Subsection IWL program uses visual examinations of accessible portions of the containment concrete walls and domes.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.12.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the exceptions to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.13 INSERVICE INSPECTION - ASME SECTION XI, AUGMENTED INSPECTIONS (AMP B.1.18)

In the CNP LRA, Appendix B, Section B.1.18, the applicant describes CNP AMP B.1.18, "Inservice Inspection - ASME Section XI, Augmented Inspections."

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D.C. Cook Audit & Review Report The applicant states that CNP AMP B.1.18 is a plant-specific program. The applicant credits this program with managing the effects of aging on selected components that are outside the jurisdiction of ASME Section XI. The existing program is used for other components that do not require an aging management in accordance with 10 CFR Part 54. Augmented inspections are consistent, to the extent practical, with the appropriate ASME Section XI requirements, specifically regarding (1) selection of inspection methods, (2) inspection frequency, (3) percentage of components examined within a population, and (4) acceptance criteria.

The applicant states that it has implemented the applicable requirements of the 1989 Edition of ASME Section XI, approved NRC alternatives and relief requests, and other requirements specified in 10 CFR 50.55a for the third inservice inspection interval.

The project team reviewed the documents listed in Attachment 4 of this audit and review report, in whole or in part, for the inservice inspection - ASME Section XI augmented inspections program and interviewed the applicant's technical staff.

7.1.13.1 Review of the AMP Against the Program Elements The project team reviewed CNP AMP B.1.18 against the AMP elements found in the SRP-LR, Appendix A, Section A.1.2.3 and SRP-LR Table A.1-1. The guidance described in the CNP audit and review plan was followed.

7.1.13.1.1 Scope of Program The applicant states in CNP AMP B.1.18 that the inservice inspection - ASME Section XI, augmented inspections program scope includes existing augmented inspections on selected components that are outside the jurisdiction of ASME Section XI, and nondestructive inspections that will be implemented prior to the period of extended operation to manage aging effects on portions of the containment spray system.

For license renewal, the applicant states that it will enhance the scope of this program to include volumetric inspections of the spray additive tanks (SATs) and the portions of the containment spray system that are wetted by sodium hydroxide (e.g., piping up to the first normally closed valve), and the portion of the discharge header in containment that may contain untreated water with concentrated contaminants.

By letter dated October 31, 2003 (ML033070177), the applicant committed to the enhancements applicable to this LRA AMP and the associated implementation dates.

This program element criterion in Appendix A.1 of the SRP-LR requires that the program scope include the specific SCs addressed with this program.

The project team confirmed that the program scope program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The proposed scope identifies the specific components for which the program manages aging. On this basis, the project team finds that the applicant's proposed program scope is acceptable.

7.1.13.1.2 Preventive Actions 49

D.C. Cook Audit & Review Report The applicant states in CNP AMP B.1.18 that the "preventive actions" program element is not applicable because the inservice inspection - ASME Section XI, augmented inspections program is a monitoring program and no actions will be taken as part of this program to prevent or mitigate aging degradation.

This program element criterion in Appendix A.1 of the SRP-LR is that condition monitoring programs do not rely on preventive actions and thus, preventive actions need not be provided.

The project team confirmed that the preventive actions program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The project team did not identify the need for preventive actions for AMP B.1.18 because it is a condition monitoring program.

7.1.13.1.3 Parameters Monitored/Inspected The applicant states in CNP AMP B.1.18, for the "parameters monitored or inspected" program element, that the program uses non-destructive inspections to monitor for cracking and loss of material (wall thinning).

This program element criteria in Appendix A.1 of the SRP-LR are The parameters to be monitored or inspected should be identified and linked to the degradation of the particular structure and component intended function(s).

The parameter monitored or inspected should detect the presence and extent of aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. Measurements of wall thickness are intended to detect the presence and extent of aging effects. On this basis, the project team finds that parameters monitored or inspected program element is acceptable.

7.1.13.1.4 Detection of Aging Effects The applicant states in CNP AMP B.1.18 for the "detection of aging effects" program element that nondestructive inspections are used, such as volumetric examination methods used for Section XI inspections on Class 1, 2, and 3 components. The frequency of inspections is specified in the Inservice Inspection (ISI) Long-Term Plan.

For license renewal, the applicant states that the program will be enhanced to include inspections to manage (1) loss of material and cracking of the spray additive tanks and the portions of the containment spray system that are wetted by sodium hydroxide (e.g., piping up to the first normally closed valve) and (2) loss of material and cracking of the portions of the discharge header in containment that may contain untreated water with concentrated contaminants.

By letter dated October 31, 2003 (ML033070177), the applicant committed to the enhancements applicable to this CNP LRA AMP and the associated implementation dates.

The detection of aging effects program element criteria in Appendix A.1 of the SRP-LR are 50

D.C. Cook Audit & Review Report Provide information that links the parameters to be monitored or inspected to the aging effects being managed.

Describe when, where, and how program data are collected (i.e., all aspects of activities to collect data as part of the program).

Link the method or technique and frequency, if applicable, to plant-specific or industry-wide operating experience.

Provide the basis for the inspection population and sample size when sampling is used to inspect a group of SCs. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The in-scope spray additive tanks are treated as Class 2 vessels and the in-scope containment spray piping components as Class 2 piping in accordance with ASME XI. Inspections associated with this AMP use a frequency and sample size based on existing codes and operating experience to detect the presence and extent of aging effects. On that basis, the project team finds that the detection of aging effects program element is acceptable.

7.1.13.1.5 Monitoring and Trending The applicant states in CNP AMP B.1.18 for the "monitoring and trending" program element that the new inspections will be implemented prior to the period of extended operation. This program does not perform trending. However, the Corrective Action Program is applicable to the augmented inspections program. This provides reasonable assurance that trends entailing repeat failures to meet acceptance criteria will be identified and addressed with appropriate corrective actions.

The criteria for this program element in Appendix A.1 of the SRP-LR are Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions.

This program element describes how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. Because of the slow-acting nature of aging mechanisms causing these aging effects, the frequencies specified in ASME Section XI will be adequate to manage the effects of aging. On this basis, the project team finds that the monitoring and trending program element is acceptable.

7.1.13.1.6 Acceptance Criteria 51

D.C. Cook Audit & Review Report The applicant states in CNP AMP B.1.18 for the "acceptance criteria" program element that flaws detected during examination are evaluated by comparing the examination results to the acceptance standards established in ASME Section XI.

The criteria for this program element in Appendix A.1 of the SRP-LR are The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the structure and component intended function(s) are maintained under all CLB design conditions during the period of extended operation.

The program should include a methodology for analyzing the results against applicable acceptance criteria.

Qualitative inspections should be performed to same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site-specific programs.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The project team reviewed the applicant's acceptance criteria program element and finds that any flaws discovered in the process of performing the inspections are deemed unacceptable and corrective measures are implemented. Acceptance criteria are based on existing codes. On this basis, the project team finds that the acceptance criteria program element is acceptable.

7.1.13.1.7 Corrective Actions This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.13.1.8 Confirmation Process This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.13.1.9 Administrative Controls This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.13.1.10 Operating Experience The applicant states in CNP AMP B.1.18 that the augmented inspections being added prior to the period of extended operation are new. However, the monitoring techniques used in this program are supported by extensive industry operating experience. Operating experience at CNP will provide input to adjust the program, as needed, and to develop new augmented inspections.

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D.C. Cook Audit & Review Report The project team reviewed the applicant's operating experience, including CNP LRP-TLEE-02, "Metal Fatigue Review," Revision 1, which is an inservice inspection summary review of flaws that were analyzed to the end of the service life of the component. The project team finds that the applicants ISI inspection results identified no analytical flaw evaluations performed in accordance with IWB-3600 for the service life of the component. Although the data were reported for the metal fatigue program, the project team finds that they are applicable to the inservice inspection - ASME Section XI, augmented inspections CNP LRA AMP.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team finds that AMP B.1.18 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.13.2 UFSAR Supplement The applicant provides its UFSAR supplement for the inservice inspection - ASME Section XI, augmented inspections program in the CNP LRA, Appendix A, Section A.2.1.21, and states that the program will manage the effects of aging on selected components outside the jurisdiction of ASME Section XI. To the extent practical, augmented inspections will be consistent with the applicable ASME requirements of ASME Section XI (i.e., selection of inspection methods, inspection frequency, percentage of components examined within a population, and acceptance criteria). This program requires enhancements that will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.13.3 Conclusion Since this is a new program, final determination of its acceptability will not be made until the details of the final AMP have been submitted to the NRC staff and reviewed, which shall occur prior to the period of extended operation. The commitment to submit the program for review is documented in Attachment 5 of this report for inclusion in the SER related to the CNP LRA. On the basis of its audit and review of the applicant's program, the project team finds that those portions of program for which the applicant has identified as meeting the criteria in Appendix A.1 of the SRP-LR will adequately manage the effects of aging so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.14 INSTRUMENT AIR QUALITY (AMP B.1.19)

In the CNP LRA, Appendix B, Section B.1.19, the applicant describes CNP AMP B.1.19, "Instrument Air Quality."

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D.C. Cook Audit & Review Report The applicant states that CNP AMP B.1.19 is an existing plant-specific program. The purpose of the program with respect to license renewal is to prevent and mitigate aging effects on control air system components by maintaining the system free of water and significant contaminants. The applicant also states that the control air system is part of the compressed air system.

The project team reviewed the documents listed in Attachment 4 of this audit and review report, in whole or in part, including Engineering Report LRP-EAMP-01, Section 4.13, "Instrument Air Quality Program," for the instrument air quality program and interviewed the applicant's technical staff.

7.1.14.1 Review of the AMP Against the Program Elements The project team reviewed CNP AMP B.1.19 against the AMP elements found in the SRP-LR, Appendix A, Section A.1.2.3 and SRP-LR Table A.1-1. The guidance described in the CNP audit and review plan was followed.

7.1.14.1.1 Scope of Program The applicant states in CNP AMP B.1.19 that the program applies to those components within the scope of license renewal and subject to an AMR that are supplied with control air where pressure boundary integrity is required for the component to perform its intended function.

This program element criterion in Appendix A.1 of the SRP-LR requires that the program scope include the specific SCs addressed with this program.

The project team confirmed that the program scope program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The proposed scope identifies the specific components for which the program manages aging. On this basis, the project team finds that the applicant's proposed program scope is acceptable.

7.1.14.1.2 Preventive Actions The applicant states in CNP AMP B.1.19 for the "preventive actions" program element that system air quality is monitored and maintained in accordance with CNP testing and inspection plans, which are designed to ensure that the control air system and equipment meet specified operating requirements. These requirements are derived from guidelines presented in American National Standards Institute (ANSI) Standard ISA-S7.3, -1975, Quality Standard for Instrument Air.

This program element criterion in Appendix A.1 of the SRP-LR is that the activities for prevention and mitigation programs should be described.

The project team reviewed procedures 01-OHP-4030-114-030, Rev. 1, Daily and Shiftly Surveillance Checks, and 02-OHP-4030-214-030, Rev. 0, "Daily and Shiftly Surveillance Checks." Based on its review of surveillance procedures and discussion with the applicants responsible engineer, the project team concluded that effective methods are employed to prevent degradation of instrument air quality.

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D.C. Cook Audit & Review Report The project team confirmed that the preventive actions program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The project team finds that the preventive actions program element is acceptable because maintenance of contaminant-free oil systems prevents and mitigates the identified aging effects.

7.1.14.1.3 Parameters Monitored/Inspected The applicant states in CNP AMP B.1.19, for the "parameters monitored or inspected" program element, that this program periodically monitors the control air system air quality pursuant to the following performance requirements from ANSI Standard ISA-S7.3-1975 Maximum dewpoint (monitored approximately weekly)

Particulate size (afterfilter differential pressure monitored daily)

Dryer condition inspection (monitored approximately monthly)

For license renewal, the applicant proposes to enhance plant procedures to more clearly specify frequencies for the dewpoint and dryer tours.

This program element criteria in Appendix A.1 of the SRP-LR are The parameters to be monitored or inspected should be identified and linked to the degradation of the particular SC intended functions.

The parameters monitored should be the specific parameters being controlled to achieve prevention or mitigation of aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The parameters monitored or inspected are linked to the aging effects pertinent to component intended function(s). The parameters monitored are not necessarily the specific parameters being controlled to achieve prevention or mitigation of aging effects, however the selection of parameters is appropriate. For example, the surveillance program monitors to confirm that air system temperatures remain above the dew point. In another instance, there is no direct measurement of particulates, but filter replacement that provides effective control is required. Maintenance and procurement documents were reviewed to confirm that the specified equipment is suitable for maintaining air quality within the required limits. On this basis, the project team finds that the parameters monitored or inspected program element is acceptable.

7.1.14.1.4 Detection of Aging Effects The applicant states in CNP AMP B.1.19, for the "detection of aging effects" program element, that ANSI Standard ISA-S7.3-1975 guidelines are followed to ensure timely detection of degradation of the control air system function. Degradation of the piping and equipment would become evident by observation of excessive corrosion, discovery of unacceptable leakage rates, or failure of the system or equipment to meet specified performance limits. This program is credited with managing the loss of material of the carbon steel, copper, and brass/bronze components in the control air systems.

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D.C. Cook Audit & Review Report The detection of aging effects program element criteria in Appendix A.1 of the SRP-LR are Provide information that links the parameters to be monitored or inspected to the aging effects being managed.

Describe when, where, and how program data are collected (i.e., all aspects of activities to collect data as part of the program).

Link the method or technique and frequency, if applicable, to plant-specific or industry-wide operating experience.

Provide the basis for the inspection population and sample size when sampling is used to inspect a group of SCs. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

The project team confirmed that with enhancement, this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The program is primarily preventive in approach, and emphasizes maintenance of air system quality rather than detection of degradation in the components it serves. On this basis, the project team finds that the detection of aging effects program element is acceptable.

7.1.14.1.5 Monitoring and Trending The applicant states in CNP AMP B.1.19 for the "monitoring and trending" program element that trends for dewpoint are maintained in a trending database. The control air afterfilter differential pressure is checked daily.

The criteria for this program element in Appendix A.1 of the SRP-LR are Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions.

This program element describes how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. Monitoring and trending activities are specified in the surveillance and maintenance procedures. On this basis, the project team finds that the monitoring and trending program element is acceptable.

7.1.14.1.6 Acceptance Criteria The applicant states in CNP AMP B.1.19 for the "acceptance criteria" program element that the dewpoint at line pressure shall be at least 18EF below the minimum temperature to which any part of the instrument air system is exposed at any season of the year. In no case should dewpoint at line pressure exceed 35EF.

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D.C. Cook Audit & Review Report The applicant states, in the CNP LRA, that plant procedures prescribe removal of the afterfilter from service based on a specified high differential pressure limit (commitment from GL 88-14, "Instrument Air Supply System Problems Affecting Safety-Related Equipment").

The criteria for this program element in Appendix A.1 of the SRP-LR are The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the structure and component intended function(s) are maintained under all CLB design conditions during the period of extended operation.

The program should include a methodology for analyzing the results against applicable acceptance criteria.

Qualitative inspections should be performed to same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site-specific programs.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. Appropriate acceptance criteria in the form of prescribed numerical limits are provided. On this basis, the project team finds the acceptance criteria program element acceptable.

7.1.14.1.7 Corrective Actions This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.14.1.8 Confirmation Process This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.14.1.9 Administrative Controls This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.14.1.10 Operating Experience The applicant states in CNP AMP B.1.19, for the operating experience program element, that GL 88-14 was issued based on industry operating experience with air systems. The applicant also states that the instrument air quality program is based on program elements specified in the generic letter. Instrument air quality that does not meet the administrative control criteria for sampling is documented through the Corrective Action Program, which includes trending for adverse conditions and repetitive failures of system components.

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D.C. Cook Audit & Review Report The applicant states, in the CNP LRA, that the lack of a significant number of condition reports regarding loss of material due to corrosion in the air systems indicates the program has been effective in preventing the effects of aging. As an example, a condition report was written documenting failure of the Unit 2 east control air dryer and if left uncorrected, this condition could have led to a failure to comply with the dewpoint requirements for air quality.

This program element criterion in Appendix A.1 of the SRP-LR states that operating experience should provide objective evidence to support the conclusion that the effects of aging will be adequately managed so that the SC intended function(s) will be maintained during the period of extended operation.

The project team reviewed the applicant's responses to concerns arising from industry experience with air systems. The project team finds that the applicant has had only a small number of condition reports related to air systems. This suggests that the preventive approach taken has been successful.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.19 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.14.2 UFSAR Supplement The applicant provides its UFSAR supplement for the instrument air quality program in the CNP LRA, Appendix A, Section A.2.1.22, and states that the program periodically documents the control air system air quality for maximum dewpoint, particulate size, and dryer condition, pursuant to the performance requirements of ANSI Standard ISA-S7.3-1975. This program ensures that the control air supplied to components within the scope of license renewal is maintained free of water and significant contaminants. This program requires an enhancement that will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.14.3 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.15 NON-EQ INSTRUMENTATION CIRCUITS TEST REVIEW (AMP B.1.21)

In the CNP LRA, Appendix B, Section B.1.21, the applicant states that the CNP AMP B.1.21, "Non-EQ Instrumentation Circuits Test Review," is a new program that will be initiated prior to 58

D.C. Cook Audit & Review Report the period of extended operation. The applicant states that the CNP AMP will be consistent with GALL AMP XI.E2, "Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits," with an exception.

7.1.15.1 Program Description This program provides reasonable assurance that the intended functions of specified non-EQ electrical cables will be maintained consistent with the current licensing basis through the period of extended operation. The electrical cables included in the scope of this program meet all of the following criteria:

(1) Not subject to the EQ requirements of 10 CFR 50.49; (2) Used in instrumentation circuits with sensitive, high voltage, low-level signals; and (3) Exposed to adverse localized environments caused by heat, radiation, or moisture.

An adverse localized environment is one that is significantly more severe than the specified service environment for the cable.

7.1.15.2 Consistency with the GALL Report In the CNP LRA the applicant states that CNP AMP B.1.21 will be consistent with GALL AMP XI.E2, with an exception.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.21, including Engineering Report LRP-EAMP-01, Section 3.7, "Non-EQ Instrumentation Circuits Test Review Program," which provides an assessment of how the GALL AMP elements are addressed by the non-EQ instrumentation circuits test review program.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documentation against GALL AMP XI.E2 for consistency.

7.1.15.3 Exceptions to the GALL Report The applicant states, in the CNP LRA, that exceptions to the GALL Report elements as follows Element: 4: Detection of Aging Effects Exceptions: Rather than perform the reviews at the normal calibration frequency specified in the Technical Specifications, the first reviews will be performed before the period of extended operation and every 10 years thereafter. Calibrations or surveillances that fail to meet the acceptance criteria will be reviewed at the time of the calibration or surveillance.

The GALL Report identifies the following criteria for the detection of aging effects program element associated with the exception taken 59

D.C. Cook Audit & Review Report The normal calibration frequency specified in the plant technical specifications provides reasonable assurance that severe aging degradation will be detected prior to loss of the cable intended function. The first tests for license renewal are to be completed before the period of extended operation.

Calibration provides sufficient indication of the need for corrective actions by monitoring key parameters and providing trending data based on acceptance criteria related to instrumentation loop performance.

In discussions with the project team during the audit, the applicant further clarified its position regarding inspection frequency by stating that it intends to closely match the guidance that will be provided in ISG-15, Revision to Generic Aging Lessons Learned Aging Management Program (AMP) XI.E2 when the guidance is released for final use.

By letter dated May 6, 2004, the staff submitted RAI 3.6-2 that asks for confirmation that the applicant intends to be consistent with the proposed ISG-15 in its management of non-EQ cables sensitive to a reduction in insulation resistance. NRR DE will disposition this RAI 3.6-2 in Section 3.0.3.2 of the SER related to the CNP LRA.

7.1.15.4 Enhancements None 7.1.15.5 Operating Experience The applicant states that the program will be initiated prior to the period of extended operation, and therefore, there is no operating experience. Industry and plant-specific operating experience will be considered in the development of this program, as appropriate.

The project team found this acceptable in that the normal inspection process provides reasonable assurance that operating experience will be reviewed in the future to provide objective evidence to support the conclusion that the effects of aging will be managed adequately.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.21 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.15.6 UFSAR Supplement The applicant provides its UFSAR supplement for the non-EQ instrumentation circuits test review program in the CNP LRA, Appendix A, Section A.2.1.24, which states that the program will manage aging effects for electrical cables that:

(1) Are not subject to the environmental qualification requirements of 10 CFR 50.49, and (2) Are used in instrumentation circuits with sensitive, high-voltage, low-level signals exposed to adverse localized environments caused by heat, radiation, or moisture.

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D.C. Cook Audit & Review Report An adverse localized environment is defined as being significantly more severe than the specified service environment for the cable. This program will detect aging effects by reviewing calibration or surveillance results for components within the program scope. The program will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.15.7 Conclusion Since this is a new program, final determination of its acceptability will not be made until the details of the final AMP have been submitted to the NRC staff and reviewed, which shall occur prior to the period of extended operation. The commitment to submit the program for review is documented in Attachment 5 of this report for inclusion in the SER related to the CNP LRA. On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the exception to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.16 NON-EQ INSULATED CABLES AND CONNECTIONS (AMP B.1.22)

In the CNP LRA, Appendix B, Section B.1.22, the applicant states that CNP AMP B.1.22, "Non-EQ Insulated Cables and Connections," is a new program that will be initiated prior to the period of extended operation. The applicant states that the CNP AMP will be consistent with GALL AMP XI.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification (EQ) Requirements."

7.1.16.1 Program Description The applicant states that CNP AMP B.1.22 will apply to accessible insulated cables and connections installed in structures within the scope of license renewal and prone to adverse localized environments. The program provides reasonable assurance that the intended functions of insulated cables and connections exposed to adverse localized environments caused by heat, radiation, and moisture can be maintained consistent with the CLB through the period of extended operation. An adverse localized environment is significantly more severe than the specified service condition for the insulated cable or connection.

7.1.16.2 Consistency with the GALL Report 61

D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that CNP AMP B.1.22 will be consistent with GALL AMP XI.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements."

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.22, including Engineering Report LRP-EAMP-01, Section 3.8, "Non-EQ Insulated Cables and Connections Programs," which provides an assessment of the AMP elements' consistency with GALL AMP XI.E1.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documents against GALL AMP XI.E1 for consistency.

The project team reviewed CNP LRP-EAMR-01, "Verification of License Renewal Report," and found reference to the need for the implementation of an action plan for inspection of the aluminum conductor cables that are installed in the plant. The non-EQ insulated cables and connections inspection program as defined in CNP LRP-EAMP-01 credits this program for management of aging effects of aluminum cables.

In response to project team questions concerning the method to be used for this aluminum cables inspection program, the applicant stated that the aluminum conductor connections were sealed with tape and/or no-ox grease to prevent corrosion of the connection, so the types of connections will not typically be accessible. The use of no-ox grease precludes oxidation of aluminum surfaces, so change in material properties is not an applicable aging effect for the aluminum conductors. The aging stressors have been removed by the use of common industry practices. Therefore, visual inspections for these cables is no different than for other insulated cables. Predictive maintenance such as CHAR and thermography are performed as part of routine maintenance.

CNP LRP-EAMR-01 also discusses condition report CR P-99-27605, "Water in junction box",

which describes the accumulation of water due to condensation. The affected cable was found in good condition, the junction box was cleaned, and a weep hole was installed to prevent future accumulation of water. The report also states that the immersion of low-voltage cables in water is considered acceptable on the basis that the circuits were rated at 250 VDC and that, therefore, no water-treeing would occur. The event was documented and corrected.

The project team asked the applicant to provide further details on how the AMP will detect degradation in non-accessible cables and how the insulation aging assessments for multi-conductor jacketed cables in accessible locations will be performed. Specifically, the project team's concern is how these assessments will be performed where the cable jacket and insulation are of different materials.

The applicant responded that not all cables will be accessible, however, the program will include a representative sample for each cable type and environment combination, so that the inspection sampling will include all cables in the scope of the aging program, consistent with the GALL Report. The applicant states that the samples will be chosen based upon the most limiting combination of cable insulation and environment. While any deterioration in the jacket 62

D.C. Cook Audit & Review Report may or may not be indicative of deterioration of insulation, evidence of jacket aging could be used to indicate the aging effect of adverse environmental conditions. On the basis that the applicant is committed to include a representative sample for each cable type/environment combination within the scope of the AMP and has addressed the process by which cable jacket anomalies will be used to identify potential degradation of the insulation, the project team finds this response to be acceptable.

7.1.16.3 Exceptions to the GALL Report None 7.1.16.4 Enhancements None 7.1.16.5 Operating Experience The applicant states, in the CNP LRA, that the non-EQ insulated cables and connections AMP is a new program for which there is no operating experience. Industry and plant-specific operating experience will be considered in the development of this program, as appropriate.

The project team recognizes that the corrective action program, which captures internal and external plant operating experience issues, will provide reasonable assurance that operating experience is reviewed and incorporated in the future to provide objective evidence to support the conclusion that the effects of aging are adequately managed.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.22 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.16.6 UFSAR Supplement The applicant provides its UFSAR supplement for the non-EQ cables and connections program in the CNP LRA, Appendix A, Section A.2.1.25. The applicant states in Appendix A that the program will apply to accessible insulated cables and connections installed in structures that are within the scope of license renewal and prone to adverse localized environments. An adverse localized equipment environment is designed as being significantly more severe than the specified service condition for the insulated cable or connection. The program will visually inspect a representative sample of accessible insulated cables and connections for cable and connection jacket surface anomalies. The program will be implemented prior to the period of extended operation.

By letter dated May 6, 2004, the staff forwarded to the applicant an RAI that states that the existing Section A.2.1.25 does not provide an adequate description of the program as required by 10 CFR 54.21(d), specifically that the description for aging management of electrical and I&C components should be consistent with Table 3.6-2 of the SRP-LR. The staff requested, in RAI 3.6-11, that the applicant submit a revised UFSAR supplement that is consistent with the 63

D.C. Cook Audit & Review Report SRP-LR. RAI 3.6-11 is reviewed by NRR DE staff and addressed in Section 3.0 of the SER related to the CNP LRA.

7.1.16.7 Conclusion Since this is a new program, final determination of its acceptability will not be made until the details of the final AMP have been submitted to the NRC staff and reviewed, which shall occur prior to the period of extended operation. The commitment to submit the program for review is documented in Attachment 5 of this report for inclusion in the SER related to the CNP LRA. On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistencies with the GALL Report are consistent with the GALL Report. Since the GALL Report is acceptable to the staff, the project team concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.17 OIL ANALYSIS (AMP B.1.23)

In the CNP LRA, Appendix B, Section B.1.23, the applicant describes CNP AMP B.1.23, "Oil Analysis."

The applicant states that CNP AMP B.1.23 is a plant-specific program. The applicant credits this program with maintaining oil systems free of contaminants (primarily water and particulates) thereby preserving an environment that is not conducive to loss of material, cracking, or fouling.

The project team reviewed the documents listed in Attachment 4 of this audit and review report, in whole or in part, including Engineering Report LRP-EAMP-01, Section 4.14, "Oil Analysis Program, for the oil analysis program and interviewed the applicant's technical staff.

7.1.17.1 Review of the AMP Against the Program Elements The project team reviewed CNP AMP B.1.23 against the AMP elements found in the SRP-LR, Appendix A, Section A.1.2.3 and SRP-LR Table A.1-1. The guidance described in the CNP audit and review plan was followed.

7.1.17.1.1 Scope of Program The applicant states in CNP AMP B.1.23 that the "scope of program" program element encompasses periodic sampling of the lubricating oil to which plant components subject to an AMR are exposed. The components are maintained in a list of plant equipment included in the program.

The applicant states that CNP AMP B.1.23 will manage aging effects on the following components: emergency core cooling system (ECCS) components wetted by lubricating oil; 64

D.C. Cook Audit & Review Report reactor coolant pump (RCP) bearing oil coolers; emergency diesel generator (EDG) lube oil system components; fire pump diesel engine lube oil system components; security diesel engine lube oil system components; and auxiliary feedwater pump turbine lube oil components.

The applicant used INPO 89-009, Good Practice MA-316, Plant Predictive Maintenance, as a basis for initial selection of equipment.

This program element criterion in Appendix A.1 of the SRP-LR requires that the program scope include the specific SCs addressed with this program.

The project team confirmed that the specific components for which the oil analysis program manages aging are identified. The lubricating oil to which these components are exposed is included in the oil analysis program. The program scope program element satisfies the criterion defined in Appendix A the SRP-LR. On this basis, the project team finds that the applicant's proposed scope is acceptable.

7.1.17.1.2 Preventive Actions The applicant states in CNP AMP B.1.23 for the "preventive actions" program element that the program maintains oil systems free of contaminants (including water and particulates) thereby preserving an environment that is not conducive to corrosion.

This program element criterion in Appendix A.1 of the SRP-LR is that the activities for prevention and mitigation programs should be described.

The project team confirmed that the preventive actions program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The project team finds that the preventive actions program element is acceptable because maintenance of contaminant-free oil systems prevents and mitigates the identified aging effects.

7.1.17.1.3 Parameters Monitored/Inspected The applicant states in CNP AMP B.1.23, for the "parameters monitored or inspected" program element, that the contaminants monitored are those that contribute to the aging effects of concern, such as particle contaminants and water content.

This program element criteria in Appendix A.1 of the SRP-LR are The parameters to be monitored or inspected should be identified and linked to the degradation of the particular SC intended functions.

The parameters monitored should be the specific parameters being controlled to achieve prevention or mitigation of aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The oil sampling program activities detect the conditions that potentiate degradation and also detect the presence and extent of aging effects. On this basis, the project team finds that the parameters monitored or inspected program element is acceptable.

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D.C. Cook Audit & Review Report 7.1.17.1.4 Detection of Aging Effects The applicant states in CNP AMP B.1.23, for the "detection of aging effects" program element, that periodic sampling and compliance with the acceptance criteria provide assurance that lube oil contaminants do not exceed acceptable levels. The applicant states that this program manages the following aging effects:

C loss of material (including that due to selective leaching) and fouling for the ECCS components wetted by lubricating oil C loss of material for RCP bearing oil coolers C loss of material (including that due to selective leaching), cracking and fouling for EDG lube oil system components C loss of material (including that due to selective leaching) and fouling for the fire pump diesel engine lube oil system components C loss of material (including that due to selective leaching) for security diesel engine lube oil system components C loss of material (including that due to selective leaching) and fouling for auxiliary feedwater pump turbine lube oil components Routine oil sampling is scheduled. Scheduled sampling dates and intervals may be adjusted according to recommendations from the analysis laboratory, plant management, and engineering personnel.

The detection of aging effects program element criteria in Appendix A.1 of the SRP-LR are Provide information that links the parameters to be monitored or inspected to the aging effects being managed.

Describe when, where, and how program data are collected (i.e., all aspects of activities to collect data as part of the program).

Link the method or technique and frequency, if applicable, to plant-specific or industry-wide operating experience.

Provide the basis for the inspection population and sample size when sampling is used to inspect a group of SCs. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. (Sampling from a population is not applicable to this AMP.)

Sampling is appropriately described and linked to the aging effects and compliance with the acceptance criteria allow for the timely detection of their presence and extent. Appropriate 66

D.C. Cook Audit & Review Report industry standards are used in the development of sampling methods and frequencies. On this basis, the project team finds that the detection of aging effects program element is acceptable.

7.1.17.1.5 Monitoring and Trending The applicant states in CNP AMP B.1.23 for the "monitoring and trending" program element that the oil trending database contains the data obtained through the implementation of this program.

The criteria for this program element in Appendix A.1 of the SRP-LR are Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions.

This program element describes how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. Trending of the analysis results is performed and enhances the applicant's ability to detect aging effects before there is a loss of intended function. On this basis, the project team finds that the monitoring and trending program element is acceptable.

7.1.17.1.6 Acceptance Criteria The applicant states in CNP AMP B.1.23 for the "acceptance criteria" program element that data received from the testing laboratories is reviewed. Evaluations of reports indicating an adverse trend or significant exception are documented. Alert levels to initiate corrective action have been set based on wear particle count, viscosity, and water content. Appropriate corrective actions are initiated when concerns regarding equipment or lubricant conditions are indicated.

The criteria for this program element in Appendix A.1 of the SRP-LR are The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the structure and component intended function(s) are maintained under all CLB design conditions during the period of extended operation.

The program should include a methodology for analyzing the results against applicable acceptance criteria.

Qualitative inspections should be performed to same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site-specific programs.

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D.C. Cook Audit & Review Report The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. Any contaminant values that are projected to exceed limits (determined on the basis of the applicable standards and manufacturers' recommendations documented in the implementing procedures), result in the implementation of corrective measures. On this basis, the project team finds the acceptance criteria program element acceptable.

7.1.17.1.7 Corrective Actions This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.17.1.8 Confirmation Process This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.17.1.9 Administrative Controls This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.17.1.10 Operating Experience The applicant states in CNP AMP B.1.23, for the operating experience program element, that a review of operating experience pertaining to this AMP determined that program enhancements have been made based on industry and plant-specific operating experience. For example, the potential for possible incompatibility between emergency diesel generator fuel oil and lube oil identified at another nuclear power plant was evaluated and a program change was made to ensure the problem was addressed. The review of condition reports indicates that the program has detected conditions at levels below which aging degradation is expected to occur.

This program element criterion in Appendix A.1 of the SRP-LR states that operating experience should provide objective evidence to support the conclusion that the effects of aging will be adequately managed so that the SC intended function(s) will be maintained during the period of extended operation.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.23 adequately manages the aging effects that have been observed at the applicant's plant and can do so during the period of extended operation.

7.1.17.2 UFSAR Supplement The applicant provides its UFSAR supplement for the oil analysis program in the CNP LRA, Appendix A, Section A.2.1.26, and states that the program ensures that the lubricating oil environment in the mechanical systems in the scope of license renewal is maintained to the required quality. By monitoring oil quality, the oil analysis program maintains oil systems 68

D.C. Cook Audit & Review Report free of contaminants (primarily water and particulates), thereby preserving an environment that is not conducive to loss of material, cracking, or fouling.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.17.3 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.18 PRESSURIZER EXAMINATIONS (AMP B.1.24)

In the CNP LRA, Appendix B, Section B.1.24, the applicant describes CNP AMP B.1.24, "Pressurizer Examinations."

The applicant states that CNP AMP B.1.24 is a plant-specific program. As discussed in WCAP-14574-A, "License Renewal Evaluation: Aging Management for Pressurizers," cracking of the pressurizer cladding (and items attached to the cladding) may propagate into the underlying ferritic steel. In addition, the pressurizer spray head is susceptible to cracking and reduction of fracture toughness. The purpose of this program is to identify degradation that could potentially cause loss of intended function of these pressurizer components.

The project team reviewed the documents listed in Attachment 4 of this audit and review report, in whole or in part, including Engineering Report LRP-EAMP-01, Section 4.15, "Pressurizer Examinations Program," for the pressurizer examinations program and interviewed the applicant's technical staff.

7.1.18.1 Review of the AMP Against the Program Elements The project team reviewed CNP AMP B.1.24 against the AMP elements found in the SRP-LR, Appendix A, Section A.1.2.3 and SRP-LR Table A.1-1. The guidance described in the CNP audit and review plan was followed.

7.1.18.1.1 Scope of Program The applicant states in CNP AMP B.1.24 that the "scope of program" program element will be to assess the cladding and attachment welds to the cladding of the pressurizer to address the propagation of cracks. The applicant states that, for license renewal, the condition of the internal spray head, spray head locking bar, and coupling will be determined by a one-time 69

D.C. Cook Audit & Review Report visual examination (VT-3) of these components in one CNP unit. This examination will be performed prior to the period of extended operation to accepted ASME Section XI methods and standards. The spray head is susceptible to cracking and loss of toughness.

This program element criterion in Appendix A.1 of the SRP-LR requires that the program scope include the specific SCs addressed with this program.

The project team confirmed that the program scope program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. However, the staff requested, in RAI 3.0.3.3-4, that the applicant provide additional information regarding nickel-alloy bimetallic welds used to attach penetrations to the pressurizer. NRR DE will disposition this RAI in Section 3.0.3.3 of the SER related to the CNP LRA. Otherwise, the proposed scope identifies the specific components for which the program manages aging. On this basis, the project team finds that the applicant's proposed program scope is acceptable.

7.1.18.1.2 Preventive Actions The applicant states in CNP AMP B.1.24 that the "preventive actions" program element is not applicable because the pressurizer examinations program is an inspection program and no actions will be taken as part of this program to prevent aging effects or mitigate aging degradation.

This program element criterion in Appendix A.1 of the SRP-LR is that condition monitoring programs do not rely on preventive actions, and thus, preventive actions need not be provided.

The project team confirmed that the preventive actions program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The project team did not identify the need for preventive actions for AMP B.1.24 because it is a condition monitoring program.

7.1.18.1.3 Parameters Monitored/Inspected The applicant states in CNP AMP B.1.24, for the "parameters monitored or inspected" program element, that In order to provide assurance that cracking of the pressurizer cladding and attachment welds to the cladding has not propagated into the underlying base metal of the pressurizer, volumetric examination of pressurizer items that are susceptible to thermal fatigue will be performed. Cracking of the pressurizer stainless steel cladding would most likely result from thermal fatigue. The stainless steel clad item with the highest fatigue cumulative usage factor is the circumferential weld at the shell-to-head junction.

In accordance with ASME Section XI, Examination Category B-B, volumetric examination of essentially 100% of the circumferential shell-to-head weld will be performed at each inspection interval. In addition, the weld metal between the surge nozzle and the vessel lower head will be subjected to high stress cycles.

Periodic monitoring of this area provides monitoring for cracking of the cladding that may propagate to the underlying ferritic steel. The weld that connects the 70

D.C. Cook Audit & Review Report surge nozzle to the lower head will receive volumetric examination at each inspection interval in accordance with Examination Category B-D. These examinations will continue through the period of extended operation to manage cracking of cladding that may extend into the base metal at susceptible locations.

For license renewal, the applicant states that it will enhance the program to include a one-time condition assessment of the spray head, spray head locking bar, and coupling.

This program element criteria in Appendix A of the SRP-LR are The parameters to be monitored or inspected should be identified and linked to the degradation of the particular structure and component intended function(s).

The parameter monitored or inspected should detect the presence and extent of aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A of the SRP-LR. The evaluations of cladding and weld integrity are intended to detect the presence and extent of aging effects. On this basis, the project team finds that the parameters monitored or inspected program element is acceptable.

7.1.18.1.4 Detection of Aging Effects The applicant states in CNP AMP B.1.24 for the "detection of aging effects" program element that Detection of cracking in the pressurizer cladding will be achieved through periodic volumetric inspections as required by ASME Section XI. Inspection of these items constitutes an appropriate sample of the stainless steel clad items in the pressurizer.

For license renewal, the applicant states that it will enhance this program to assess the condition of the internal spray head, spray head locking bar, and coupling by performing a one-time visual examination (VT-3) of these components in one CNP unit. This examination will be performed prior to the period of extended operation to accepted ASME Section XI methods and standards.

The detection of aging effects program element criteria in Appendix A.1 of the SRP-LR are Provide information that links the parameters to be monitored or inspected to the aging effects being managed.

Describe when, where, and how program data are collected (i.e., all aspects of activities to collect data as part of the program).

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D.C. Cook Audit & Review Report Link the method or technique and frequency, if applicable, to plant-specific or industry-wide operating experience.

Provide the basis for the inspection population and sample size when sampling is used to inspect a group of SCs. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. However, the staff, in RAI 3.0.3.3-5, requested additional justification to demonstrate that a VT-3 examination is sufficient to detect a potential flaw in the spray head which could lead to failure of the component, and additional information to justify using the VT-3 examination instead of the VT-1 examination for the one-time inspection of these components in either CNP 1 or CNP 2. NRR DE will disposition this RAI in Section 3.0.3.3 of the SER related to the CNP LRA. Otherwise, for inspections, the applicant will use a frequency and sample size based on existing codes and operating experience, to detect the presence and extent of aging effects. On this basis, the project team finds that the detection of aging effects program element is acceptable.

7.1.18.1.5 Monitoring and Trending The applicant states in CNP AMP B.1.24 for the "monitoring and trending" program element that During the course of the inspections, the extent of surface or volumetric flaws will be characterized by non-destructive examinations. Anomalous indications that are signs of degradation will be recorded on non-destructive examination reports in accordance with plant procedures.

As the inspection of the pressurizer spray head, spray head locking bar, and coupling is a one-time inspection, no monitoring or trending will be completed for this activity. However, the need for subsequent inspections will be determined after the results of the inspection are evaluated. All other examinations are part of the ASME Section XI required inspections and will be monitored in accordance with ASME Section XI Code.

The criteria for this program element in Appendix A.1 of the SRP-LR are Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions.

This program element describes how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.

The project team confirmed that this program element satisfies the criteria defined in Appendix A of the SRP-LR. Trending of the inspection results will enhance the applicant's ability to detect 72

D.C. Cook Audit & Review Report aging effects before there is a loss of intended function. On this basis, the project team finds that the monitoring and trending program element is acceptable.

7.1.18.1.6 Acceptance Criteria The applicant states in CNP AMP B.1.24 for the "acceptance criteria" program element that for volumetric examinations the acceptance criteria will be in accordance with ASME Section XI, IWB-3510 and IWB-3512. The acceptance standards for the visual examinations will be in accordance with ASME Section XI examinations (VT-3).

The criteria for this program element in Appendix A.1 of the SRP-LR are The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the structure and component intended function(s) are maintained under all CLB design conditions during the period of extended operation.

The program should include a methodology for analyzing the results against applicable acceptance criteria.

Qualitative inspections should be performed to same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site-specific programs.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The project team finds that any volumetric examination results that fall below the minimum allowable, as determined by the applicable design code, will be found unacceptable and corrective measures implemented. On that basis, the project team finds that the acceptance criteria program element is acceptable.

7.1.18.1.7 Corrective Actions This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.18.1.8 Confirmation Process This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.18.1.9 Administrative Controls This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.18.1.10 Operating Experience 73

D.C. Cook Audit & Review Report The applicant states in CNP AMP B.1.24 that the pressurizer examinations program includes multiple volumetric examinations of pressurizer components having the highest fatigue usage factors. Any cracking of the cladding that extends into the base metal would be detected by ASME Section XI volumetric examinations at these locations. The volumetric inspections are performed with inservice inspection techniques that have been proven effective within the industry at detecting cracking before loss of function occurs. The operating experience reviewed for the inservice inspection program in Section 7.1.9.5 of this report applies to the pressurizer examinations program.

The project team found this acceptable in that the volumetric inspections performed by the applicant using industry-proven inservice inspection techniques provides reasonable assurance that aging effects of cracking of pressurizer cladding and spray head will be detected before a loss of function occurs and aging effects will be managed so that the pressurizer will continue to perform its intended functions consistent with the CLB for the period of extended operation.

However, the staff, in RAI 3.0.3.3.6, asked the applicant to provide plant-specific and industry operating experience regarding detection, sizing, and disposition of cracking in the pressurizer cladding using volumetric examinations and cracking and loss of arts in spray head components using visual examinations consistent with the inspection discussed in LRA B.1.24.

NRR DE will disposition this RAI in Section 3.0.3.3 of the SER related to the CNP LRA.

The "operating experience" program element criterion in Appendix A.1 of the SRP-LR states that operating experience should provide objective evidence to support the conclusion that the effects of aging will be adequately managed so that the SC intended function(s) will be maintained during the period of extended operation.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.24 will adequately manage the aging effects that have been observed at the applicant's plant, pending satisfactory response to RAI 3.0.3.3.6, as documented in SER Section 3.0.3.3 related to the CNP LRA.

7.1.18.2 UFSAR Supplement The applicant provided its UFSAR supplement for the pressurizer examinations program in the CNP LRA, Appendix A, Section A.2.1.27, and states that the program manages cracking of the pressurizer cladding (and items attached to the cladding) which may propagate into the underlying ferritic steel. This program will also determine the condition of the internal spray head, spray head locking bar, and coupling by a one-time visual examination of these components in one CNP unit. This program requires enhancements that will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.18.3 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the 74

D.C. Cook Audit & Review Report intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.19 PREVENTIVE MAINTENANCE (AMP B.1.25)

In the CNP LRA, Appendix B, Section B.1.25, the applicant describes CNP AMP B.1.25, "Preventive Maintenance."

The applicant states that CNP AMP B.1.25 is a plant-specific program. The applicant credits this program with maintaining plant structures, systems, and components at the quality level required for the safe and reliable operation of the plant. The program comprises those preventive maintenance tasks that are intended to sustain plant equipment within design parameters and maintain the equipment's intrinsic reliability.

The project team reviewed the documents listed in Attachment 4 of this audit and review report, in whole or in part, including Engineering Report LRP-EAMP-01, Section 4.16, Preventive maintenance program," for the preventive maintenance program and interviewed the applicant's technical staff.

7.1.19.1 Review of the AMP Against the Program Elements The project team reviewed CNP AMP B.1.25 against the AMP elements found in the SRP-LR, Appendix A, Section A.1.2.3 and SRP-LR Table A.1-1. The guidance described in the CNP audit and review plan was followed.

7.1.19.1.1 Scope of Program The applicant states in CNP AMP B.1.25 that the "scope of program" program element encompasses those tasks credited with managing the aging effects identified in the CNP LRA.

The applicant describes the SC-specific preventive maintenance activities credited for license renewal under the "detection of aging effects" program element.

This program element criterion in Appendix A.1 of the SRP-LR requires that the program scope include the specific SCs addressed with this program.

The project team confirmed that the program scope program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The proposed scope identifies the program element under which specific components for which the program manages aging are discussed. On this basis, the project team finds that the applicant's proposed program scope is acceptable.

7.1.19.1.2 Preventive Actions The applicant states in CNP AMP B.1.25 for the "preventive actions" program element that the inspection and testing activities used to identify component aging effects do not prevent aging 75

D.C. Cook Audit & Review Report effects. However, implementation of these activities enables the inspectors to detect aging effects and allow for corrective actions before loss of intended function.

This program element criterion in Appendix A.1 of the SRP-LR is that The activities for prevention and mitigation programs should be described.

The project team confirmed that the preventive actions program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The periodic surveillance and preventive maintenance program activities are intended to identify component aging effect and prevent failures of components that might be caused by aging effects. On this basis, the project team finds the preventive action program element is acceptable.

7.1.19.1.3 Parameters Monitored/Inspected The applicant states in CNP AMP B.1.25, for the "parameters monitored or inspected" program element, that the program documents and specific preventive maintenance procedures address parameters such as surface condition, cracking, and other indications of aging effects.

Inspection and testing activities monitor various parameters, including surface condition, presence of corrosion products, and signs of cracking.

This program element criteria in Appendix A.1 of the SRP-LR are The parameters to be monitored or inspected should be identified and linked to the degradation of the particular structure and component intended function(s).

The parameters monitored should be the specific parameters being controlled to achieve prevention or mitigation of aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A of the SRP-LR. On the basis of interviews with the applicant's technical staff, the project team finds the applicant's parameters monitored or inspected program element to be acceptable.

7.1.19.1.4 Detection of Aging Effects The applicant states in CNP AMP B.1.25 for the "detection of aging effects" program element that Preventive maintenance activities provide for periodic component inspections and testing to detect aging effects. Inspection intervals are established such that they provide for timely detection of degradation. Inspection intervals are dependent on the component material and environment and take into consideration industry and plant-specific operating experience and manufacturer's recommendations.

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D.C. Cook Audit & Review Report The extent and schedule of inspections and testing assure detection of component degradation prior to loss of intended functions. Established techniques such as visual inspections are used.

The program includes inspections of the centrifugal charging pump casing cladding, as identified in NRC Information Notice 80-38, "Cracking in Charging Pump Casing Cladding," to manage the component-specific aging effect of cladding cracking due to high localized stresses. After locations of rust or boric acid deposits are mapped, liquid penetrant examinations are used to identify indications. Damaged areas are excavated and re-clad with stainless steel.

Base metal is repaired if necessary.

Numerous EDG components are inspected in a general fashion, rather than component-by-component listings. This program currently ensures that loss of material, cracking, fouling, and change in material properties are managed for EDG subsystem components. For license renewal, the program will be enhanced to manage the aging effects of cracking and change of material properties for the emergency diesel engine elastomer flex hoses or tubing using visual inspection and replacement as needed.

The program currently performs inspections of control room ventilation air handler unit components. For license renewal, the tasks for the control room ventilation air handler packages will be enhanced to include inspection of the heat exchanger tubes and flex joints. These inspections will ensure that loss of material and fouling are managed for the stainless steel heat exchanger tubes, and that changes in material properties and cracking are managed for the elastomer flex joints. The program currently performs inspections of auxiliary feedwater pump room cooling unit components. For license renewal, these tasks will be enhanced to include inspection of the internal evaporator tubes, valves, and tubing. These inspections will ensure that loss of material and fouling are managed for the copper alloy components within these units. The tasks for the EDG ventilation system will be enhanced to include inspection of the flex joints.

For license renewal, the fire protection system preventive maintenance activities will be enhanced to perform inspections of reactor coolant pump lube oil leakage collection components. If damaged components are found, they will be replaced. This will ensure that loss of material is managed and that the intended function of pressure boundary is maintained for the period of extended operation.

For license renewal, the program will be enhanced to manage cracking and change in material properties for the rubber hoses in the compressed air system that require aging management review. This activity will include visual inspection and replacement as needed. The program will be enhanced to manage cracking and change of material properties for the rubber hoses for the post-accident containment hydrogen monitoring system reagent gas supply. This will include visual inspection and replacement as needed. The program will be enhanced to manage cracking and change of material properties for the security diesel engine 77

D.C. Cook Audit & Review Report elastomer flex hoses or tubing. This will include visual inspection and replacement as needed. The program will be enhanced to manage cracking and change in material properties of the auxiliary feedwater system elastomer condensate storage tank floating head seals. This activity will include visual inspection and replacement as needed.

Acceptance criteria and corrective actions will be specified as needed for the enhancements.

The detection of aging effects program element criteria in Appendix A.1 of the SRP-LR are Provide information that links the parameters to be monitored or inspected to the aging effects being managed.

Describe when, where, and how program data are collected (i.e., all aspects of activities to collect data as part of the program).

Link the method or technique and frequency, if applicable, to plant-specific or industry-wide operating experience.

Provide the basis for the inspection population and sample size when sampling is used to inspect a group of SCs. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The measurements and inspections use a frequency and sample size based on operating experience to detect the presence and extent of aging effects. On this basis, the project team finds that the detection of aging effects program element is acceptable.

7.1.19.1.5 Monitoring and Trending The applicant states in CNP AMP B.1.25 for the "monitoring and trending" program element that administrative controls reference activities for monitoring systems and components to permit early detection of degradation. These activities include visual examinations for corrosion, cracking, fouling, leaking and physical condition, mechanical damage, and loose or missing hardware, as appropriate.

The CNP corrective action program is applicable to this program. This provides reasonable assurance that trends entailing repeat failures to meet acceptance criteria will be identified and addressed with appropriate corrective actions.

The criteria for this program element in Appendix A.1 of the SRP-LR are Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions.

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D.C. Cook Audit & Review Report This program element describes how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. Trending of the inspection results will enhance the applicant's ability to detect aging effects before there is a loss of intended function. On the basis of its review of the monitoring and trending program element, the project team finds it acceptable.

7.1.19.1.6 Acceptance Criteria The applicant states in CNP AMP B.1.25 for the "acceptance criteria" program element that program acceptance criteria are defined in specific inspection and testing procedures. The acceptance criteria confirm component integrity by verifying the absence of aging effect or by comparing applicable parameters to limits based on applicable intended functions established by the plant design basis. Unacceptable indications of aging effects are addressed through the Corrective Action program.

The criteria for this program element in Appendix A.1 of the SRP-LR are The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the structure and component intended function(s) are maintained under all CLB design conditions during the period of extended operation.

The program should include a methodology for analyzing the results against applicable acceptance criteria.

Qualitative inspections should be performed to same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site-specific programs.

The project team confirmed that this program element satisfies the criteria defined in Appendix A of the SRP-LR. The project team reviewed a selection of the repetitive tasks and associated procedures. In all cases where an aging effect had been identified, appropriate acceptance criteria were provided. While this offers some confidence that additional aging effects will be appropriately monitored, the codes and/or standards to be applied (and methods of assessment) have yet to be specified for the full license renewal scope. On the basis of its review of the applicant's acceptance criteria program element, the project team finds that any degradation to component integrity below the minimum allowable is unacceptable and corrective measures are implemented. On this basis, the project team finds the acceptance criteria program element to be acceptable.

7.1.19.1.7 Corrective Actions This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

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D.C. Cook Audit & Review Report 7.1.19.1.8 Confirmation Process This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.19.1.9 Administrative Controls This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.19.1.10 Operating Experience The applicant states in CNP AMP B.1.25 that the review of operating experience included condition reports, program health reports, assessment reports, NRC inspection reports, and licensee event reports.

The applicant states, in the CNP LRA, that the program was overhauled as part of the 1997-2000 plant restart effort. Program improvements incorporated proven industry practices and addressed self-identified issues. In 1999, the preventive maintenance program was benchmarked using programs considered to be among the best in the industry. The NRC conducted a special inspection in 1999 and concluded that the preventive maintenance activities were adequate to support restart of the plant. The applicant also states that to maintain the program, the preventive maintenance group reviews industry operating experience via the Corrective Action program and factor into existing or new preventive maintenance tasks, when applicable.

The "operating experience" program element criterion in Appendix A.1 of the SRP-LR states that operating experience should provide objective evidence to support the conclusion that the effects of aging will be adequately managed so that the SC intended function(s) will be maintained during the period of extended operation.

The project team noted that plant operating experience with respect to the preventive maintenance program is extensive. The applicant's documentation of operating experience for this AMP was not specific to the aging effects of concern or the components addressed, however, the project team concluded that the use of corrective action programs and reviews of industry experience are a satisfactory method for ensuring that operating experience is factored into the program appropriately.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.25 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.19.2 UFSAR Supplement The applicant provides its UFSAR supplement for the preventive maintenance program in the CNP LRA, Appendix A, Section A.2.1.28, and states that the program comprises those preventive maintenance tasks which are intended to sustain plant equipment within design parameters and maintain the equipment's intrinsic reliability. Preventive maintenance activities 80

D.C. Cook Audit & Review Report will provide for periodic component inspections and testing to detect the various aging effects applicable to those components included in the scope of the AMP for license renewal. The applicant states that this program requires enhancements that will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.19.3 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.20 REACTOR VESSEL INTERNALS CAST AUSTENITIC STAINLESS STEEL (AMP B.1.28)

In the CNP LRA, Appendix B, Section B.1.28, the applicant states that CNP AMP B.1.28, "Reactor Vessel Internals Cast Austenitic Stainless Steel," is a new program that will be initiated prior to the period of extended operation. The applicant states that the CNP AMP will be consistent with GALL AMP XI.M13, "Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel."

7.1.20.1 Program Description The applicant states that the purpose of CNP AMP B.1.28 is to manage the effects of cracking, reduction of fracture toughness, and dimensional changes of CASS reactor vessel internals components.

By letter dated April 23, 2004 (ML041270484), the applicant provides clarification that management of cracking includes evaluation and disposition of identified cracks. The program will include identification of the most limiting susceptible components based on metallurgical characteristics and thermal and neutron environments. For each identified component, aging management will be accomplished through either a supplemental examination based on the neutron fluence to which the component has been exposed or a component-specific evaluation to determine its susceptibility to loss of fracture toughness. The applicant states that component-specific evaluations, including stress conditions, have not been reported and may eliminate components from inspection requirements.

The applicant states, in the CNP LRA, that this program will supplement the reactor vessel internals inspections required by ASME Section XI. Scheduling of inspections of CASS reactor internals components will be done according to ASME Section XI, Subsection IWB-2400.

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D.C. Cook Audit & Review Report However, the inspection of internals components in Unit 1 will be completed in the fifth inspection interval, whereas the internals components of Unit 2 will be inspected in the sixth interval. Both inspections will be completed prior to the period of license renewal.

The applicant also states, in the CNP LRA, that characterization of the internals aging effects through the activities of EPRI and other industry groups will ensure a better understanding of the identified aging effects. Further understanding of these aging effects will provide additional bases for the inspections under this program. For instance, pending results of industry progress with regard to validation of the significance of dimensional changes due to void swelling, visual examinations may be supplemented to incorporate requirements for dimensional verification of critical reactor vessel internals parts. The applicant states that its technical staff participate in industry-wide programs designed by the PWR Materials Reliability Project Issues Task Group for investigating the impacts of aging on pressurized water reactor (PWR) vessel internals components.

7.1.20.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.28 will be consistent with GALL AMP XI.M13.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report, including Engineering Report LRP-EAMP-01, Section 3.9.2, "Reactor Vessel Internals Cast Austenitic Stainless Steel Program," for reactor vessel internals cast austenitic stainless steel program.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documents against GALL AMP XI.M13 for consistency.

The project team requested that the applicant provide a justification for the determination of critical flaw size or specified required supplemental inspections. By letter dated October 31, 2003 (ML033070177), the applicant states that critical flaw size will be determined by engineering evaluation and subsequent examinations, consistent with GALL AMP XI.M13. The project team reviewed the applicants response and finds this acceptable.

7.1.20.3 Exceptions to the GALL Report None 7.1.20.4 Enhancements None 7.1.20.5 Operating Experience The applicant states, in the CNP LRA, that the reactor vessel internals CASS AMP is a new program for which there is no plant-specific operating experience. Visual examinations to be 82

D.C. Cook Audit & Review Report performed under this program are inspections with demonstrated capability and a proven industry record of detecting potential cracking.

The program operating experience is based on published industry operating experience and fracture toughness data. Additionally, the applicant monitors national research activities and plant experiences with CASS material through its participation in EPRI task groups and the Westinghouse Owners Group.

The project team recognizes that the corrective action program, which captures internal and external plant operating experience issues, will provide reasonable assurance that operating experience is reviewed and incorporated in the future to provide objective evidence to support the conclusion that the effects of aging are adequately managed.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.28 will adequately manage the aging effects that have been observed at the applicant's plant.

7.1.20.6 UFSAR Supplement The applicant provides its UFSAR supplement for the reactor vessel internals CASS program in the CNP LRA, Appendix A, Section A.2.1.31. The applicant states in Appendix A that the program will supplement the reactor vessel internals inspections required by the ASME Section XI inservice inspection program. The applicant states that CNP AMP B.1.28 will manage cracking, reduction of fracture toughness, and dimensional changes using inspections of applicable components, which will be determined based on the neutron fluence and thermal embrittlement susceptibility of the component. The applicant states that the program will manage aging effects of CASS reactor vessel internals components. In RAI B.1.28-2, the staff asked the applicant to clarify why the enhanced examination and/or component-specific flaw evaluation for the CASS components, which are specified in the SRP-LR, are not included in the UFSAR Supplement Section A.2.1.31.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, pending satisfactory response to RAI B.1.28-2, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d). NRR-DE will disposition the response to RAI B.1.28-2 in Section 3.0.3 of the SER related to the CNP LRA.

7.1.20.7 Conclusion Since this is a new program, final determination of its acceptability will not be made until the details of the final AMP have been submitted to the NRC staff and reviewed, which shall occur prior to the period of extended operation. The commitment to submit the program for review is documented in Attachment 5 of this report for inclusion in the SER related to the CNP LRA. On the basis of its audit and review, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are expected to be consistent with the GALL Report. In addition, on the basis of its review of the exception to the GALL Report, the project team finds that the applicant has described a program that will adequately manage 83

D.C. Cook Audit & Review Report the effects of aging so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.21 SERVICE WATER SYSTEM RELIABILITY (AMP B.1.29)

In the CNP LRA, Appendix B, Section B.1.29, the applicant states that the CNP AMP B.1.29, "Service Water System Reliability," is consistent with GALL AMP XI.M20, "Open-Cycle Cooling Water System," with exceptions and an enhancement.

7.1.21.1 Program Description The applicant states, in the CNP LRA, that this program relies on implementation of the recommendations of GL 89-13 to ensure that the effects of aging on the essential service water (ESW) system will be managed for the period of extended operation. The program includes surveillance and control techniques to manage aging effects caused by biofouling, corrosion, erosion, protective coating failures, and silting in the ESW system, or structures and components serviced by the ESW system.

7.1.21.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.29 will be consistent with GALL AMP XI.M20, with exceptions and an enhancement.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.29, including Engineering Report LRP-EAMP-01, Section 4.18, "Service Water System Reliability Program,"

which provides an assessment of how the GALL AMP elements are addressed by the CNP LRA service water system reliability program.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documentation against GALL AMP XI.M20 for consistency.

7.1.21.3 Exceptions to the GALL Report The applicant states, in the CNP LRA, that exceptions to the GALL Report elements as follows:

Element: 1: Scope Exception: Heat exchangers may receive a thorough visual inspection and cleaning in lieu of thermal performance testing.

Element: 2: Preventive Actions 84

D.C. Cook Audit & Review Report Exception: The service water system reliability program components are lined or coated only as deemed necessary to protect underlying surfaces, they are not all lined or coated.

Element: 5: Monitoring and Trending Exception: The frequency of inspections and testing is set to commence during refueling outages.

The GALL Report identifies the following criterion for the "scope" program element associated with the exception taken:

The guidelines of GL 89-13 include a test program to verify heat transfer capabilities.

The project team reviewed the applicant's response to GL 89-13 and determined that the applicants use of visual inspection and cleaning of the heat exchangers in lieu of heat transfer capability testing to ensure that the system can perform its intended function is consistent with that which was accepted by staff in the applicants GL 89-13 program to manage heat exchangers. On the basis that the GL 89-13 program was considered an acceptable basis for satisfying staffs expectations for GL 89-13, and it is consistent with the CLB, the project team finds this exception to be acceptable.

The GALL Report identifies the following criterion for the "preventive actions" program element associated with the exception taken The system components are constructed of appropriate materials and lined or coated to protect the underlying metal surfaces from being exposed to aggressive cooling water environments.

The project team finds this acceptable because the applicant has conducted various inspections of components over time and either upgraded the material of the component such that no coating is required, or coated the components requiring lining or coating.

The GALL Report identifies the following criterion for the "monitoring and trending" program element associated with the exception taken Inspection scope, method, and testing frequencies are in accordance with the utility commitments under GL 89-13. Testing and inspections are done annually and during refueling outages.

The project team determined that the applicants inspection frequencies are in accordance with the applicant's commitments under GL 89-13 and is, therefore, finds exception to be acceptable.

7.1.21.4 Enhancements The applicant states, in the CNP LRA, that the enhancements in meeting the GALL Report elements as follows 85

D.C. Cook Audit & Review Report Element: 4: Detection of Aging Effects Enhancements: (1) The program will check for evidence of selective leaching during visual inspections.

(2) A new preventive maintenance activity will be developed, or an existing activity revised, to ensure the eight-inch expansion joints in the ESW supply lines to the emergency diesel generator heat exchangers are inspected for evidence of loss of material, change in material properties, and cracking.

The GALL Report identifies the following criterion for the detection of aging effects program element associated with the enhancement:

Inspections for biofouling, damaged coatings, and degraded material condition are conducted.

The project team finds that visual inspections might not be an adequate preventive and control method for detection of selective leaching in all systems where it is likely to occur. GALL AMP XI.M33, "Selective Leaching of Material," recommends a visual inspection and a hardness measurement of selected components to determine whether loss of material due to selective leaching is occurring. By letter dated May 6, 2004, the staff forwarded to the applicant RAI 3.3.2-2 that asks the applicant to provide justification for excluding a hardness measurement from the service water system reliability program to detect selective leaching. Pending resolution of RAI 3.3.2-2, the project team finds the first portion of the enhancement to be acceptable. RAI 3.3.2-2 is reviewed by NRR DE staff and addressed in Section 3.0 of the SER related to the CNP LRA.

The project team determined that addition of the inspections of eight-inch expansion joints in the ESW supply lines to the emergency diesel generator heat exchangers is consistent with the GALL Report. On this basis, the project team finds the second portion of the enhancement to this program element to be acceptable.

7.1.21.5 Operating Experience The applicant states, in the CNP LRA, that its review of operating experience for this AMP included condition reports, program health reports, procedure revisions, and licensee event reports. This program was established to meet the requirements of GL 89-13, which included recommendations based on extensive industry operating experience. Examples of aging effects noted in the GL 89-13 Program Health Report in 2002 include minor galvanic or crevice corrosion of the CCW heat exchanger tube sheets, identified by inspection and cracking of tube seam welds; and MIC pitting of the containment spray heat exchangers, identified by eddy current testing. The identification of these effects demonstrates that program activities are effective at detecting minor degradation before it becomes significant.

The applicant further states that inspections and tests performed in accordance with the service water reliability program have been effective in identifying degradation such as aging effects 86

D.C. Cook Audit & Review Report that could impact the capabilities of the ESW system. When deficiencies are identified, appropriate corrective actions are performed. The combination of inspections and testing are adequate to ensure the aging effects from the exposure to ESW are adequately managed for this system.

The project team reviewed correspondence and reports dealing with the applicant's response to GL 89-13 and subsequent activities related to the ESW system. In addition to industry experience, the applicant has experienced significant challenges to the ESW system. The project team reviewed a condition report related to a fish kill, and observed that the applicant's actions went well beyond those components directly affected by the event, and led to both enhancement of its program to address GL 89-13 and discovery of numerous latent problems similar to those that are managed by this program. The project team reviewed Report No. 013002-08, GL 89-13 Program Health Report, Rev. 0, 3rd Quarter 2003. An appropriate level of attention to plant-specific operating experience is evident.

On the basis of the its review and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.29 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.21.6 UFSAR Supplement The applicant provides its UFSAR supplement for the service water system reliability program in the CNP LRA, Appendix A, Section A.2.1.32, which states that the service water system reliability program relies on implementation of the recommendations of GL 89-13 to ensure that the effects of aging on the ESW system will be managed. The program includes surveillance and control techniques to manage aging effects in the ESW system, or SCs serviced by the ESW system. This program requires enhancements that will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.21.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the exceptions and enhancements to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.22 SMALL BORE PIPING PROGRAM (AMP B.1.30) 87

D.C. Cook Audit & Review Report In the CNP LRA, Appendix B, Section B.1.30, the applicant states that CNP AMP B.1.30, "Small Bore Piping," is consistent with GALL AMP XI.M32, "One-Time Inspection."

The applicant states, in the CNP LRA, that this is a new program that will be implemented prior to the period of extend operation. The applicant states that GALL AMP XI.M32 encompasses a broader scope of activities than the small bore piping inspections addressed in LRA AMP B.1.30.

7.1.22.1 Program Description The applicant states, in the CNP LRA, that this program is credited for managing cracking of small bore Class 1 piping (less than 4 inch nominal pipe size [NPS-4]), including pipe, fittings, and branch connections, in the RCS. This piping does not receive volumetric inspection in accordance with ASME Section XI, Examination Category B-J or B-F. The applicant also states that cracking is an aging effect requiring management for RCS small bore piping for the period of extended operation. The small bore piping inspection will involve a one-time volumetric examination of susceptible items in selected locations of Class 1 small bore piping. These inspections will occur at or near the end of the initial operating period for CNP, Units 1 and 2.

7.1.22.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.30 is consistent with GALL AMP XI.M32.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.30, including Engineering Report LRP-EAMP-01, Section 3.10, "Small Bore Piping Program," which provides an assessment of the AMP elements' consistency with GALL AMP XI.M32.

GALL AMP XI.M32 defines a one-time inspection program to address concerns about the potential long incubation periods for certain aging effects on structures and components. CNP AMP B.1.30 addresses cracking of small bore piping, which does not undergo volumetric inspections in accordance with ASME Section XI. Since CNP AMP B.1.30 addresses one of the aging effects addressed by GALL AMP XI.M32, the project team finds that CNP AMP B.1.30 may be reviewed against all the attributes defined in GALL XI.M32.

The project team also reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documents against GALL AMP XI.M32 for consistency.

7.1.22.3 Exceptions to the GALL Report None 7.1.22.4 Enhancements None 88

D.C. Cook Audit & Review Report 7.1.22.5 Operating Experience The applicant states that this one-time inspection is a new activity that will use techniques with demonstrated capability and a proven industry record to detect piping weld and base material flaws.

Because the applicant adopts the equivalent criteria of ASME Section XI as its inspection methodology, the project team reviewed the industry's experience with Section XI as operating experience. ASME Section XI programs provide processes for identifying degradation that is attributable to applicable aging effects and are therefore acceptable for managing the effects of aging during the period of extended operation. Based on the applicant program's use of ASME type criteria, the project team finds that the small bore-piping program would be expected to identify the cracking aging effects defined in its scope.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.30 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.22.6 UFSAR Supplement The applicant provides its UFSAR supplement for the small bore piping program in the CNP LRA, Appendix A, Section A.2.1.33. The applicant states in Appendix A that the program will manage cracking of small bore Class 1 piping (less than 4 inch nominal pipe size), including pipe, fittings, and branch connections, in the reactor coolant system. The small bore piping inspection will be a one-time volumetric examination of susceptible items in selected locations of Class 1 small bore piping that will occur prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.22.7 Conclusion Since this is a new program, final determination of its acceptability will not be made until the details of the final AMP have been submitted to the NRC staff and reviewed, which shall occur prior to the period of extended operation. The commitment to submit the program for review is documented in Attachment 5 of this report for inclusion in the SER related to the CNP LRA. On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistencies with the GALL Report are consistent with the GALL Report. Since the GALL Report is acceptable to the staff, the project team concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

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D.C. Cook Audit & Review Report 7.1.23 STRUCTURES MONITORING - STRUCTURES MONITORING (AMP B.1.32)

In the CNP LRA, Appendix B, Section B.1.32, the applicant states that CNP AMP B.1.32, "Structures Monitoring - Structures Monitoring," is consistent with GALL AMP XI.S6, "Structures Monitoring Program," with enhancements.

7.1.23.1 Program Description The applicant states, in the CNP LRA, that implementation of structures monitoring under 10 CFR 50.65 (the Maintenance Rule) is addressed in NRC Regulatory Guide 1.160, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants," Rev. 2, and NEI, NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," Rev. 2, April 1996. These two documents provide guidance for the development of licensee-specific programs to monitor the condition of structures and structural components within the scope of the Maintenance Rule, such that there is no loss of structure or structural component intended function.

The applicant states that the following structures are within the scope of this program:

containment building, auxiliary building, turbine building and screen house, yard structures, bulk commodities, and non-safety-related systems and components affecting safety-related systems. The program will be expanded to encompass structures and structural components within the scope of license renewal.

7.1.23.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.32 is consistent with GALL AMP XI.S6, "Structures Monitoring Program."

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.32, including Engineering Report LRP-EAMP-01, Section 4.20.1, "Structures Monitoring Program," which provides an assessment of the AMP elements' consistency with GALL AMP XI.S6. The project team also reviewed report LRP-SAMR-04, "Aging Management Review of the Yard Structures."

This report documents evaluations related to the roadway (shoreline) as a structural component/commodity and credits AMP B.1.32 for managing aging effects for this structural component.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documents against GALL AMP XI.S6 for consistency.

During its audit, the project team asked the applicant to describe how the aging effects of loss of material on the ice condenser steel structural components and loss of material, cracking, and change in material properties for ice condenser concrete structural components exposed to borated ice will be adequately addressed for the period of extended operation. The applicant stated that the structures monitoring (CNP AMP B.1.32) and the boric acid corrosion (CNP AMP B.1.4) programs will ensure that the aging effects associated with the ice condenser will be managed during the period of extended operation. The ice baskets are addressed by CNP 90

D.C. Cook Audit & Review Report AMP B.1.35, "Structures Monitoring - Ice Basket Inspection." On the basis of its review of the seven program elements in the CNP AMP against GALL AMP XI.S6 and its review of the applicants response, the project team finds that the structures monitoring program adequately manages aging effects and is acceptable.

7.1.23.3 Exceptions to the GALL Report None 7.1.23.4 Enhancements The applicant states, in the CNP LRA, that the enhancements in meeting the GALL Report elements as follows Element: 1: Scope Enhancement: Include equipment, cable tray, conduit and pipe supports; instrument panels; racks; cable trays; conduits; elastomers; and pipe hangers. Include the fire protection pump house superstructure and walls, gas bottle storage tank rack and foundation, security diesel generator room, switchyard control house, fire protection water storage tank foundation, primary water storage tank foundation, and roadway west of the screenhouse.

Element: 4: Detection of Aging Effects Enhancement: The examination criteria for the roadway west of the screenhouse must detect degradation of the roadway due to weather-related damage.

The GALL Report identifies the following criterion for the scope program element associated with the enhancement The applicant specifies the structure/aging effect combinations that are managed by its structures monitoring program.

The GALL Report identifies the following criterion for the detection of aging effects program element associated with the enhancement:

For each structure/aging effect combination, the inspection methods, inspection schedule, and inspector qualifications are selected to ensure that the aging degradation will be detected and quantified before there is loss of intended functions.

By letter dated October 31, 2003 (ML033070177), the applicant committed to include the additional SCs to the program scope of its Structures Monitoring - Structures Monitoring program. The project team finds that the proposed scope identifies the specific components for which the program manages aging. Also, the project team finds that the additional SCs are consistent with GALL AMP XI.S6. The enhancement to revise procedure 91

D.C. Cook Audit & Review Report 12-EHP-5035-SMP-001 to include criteria that will detect degradation of the roadway also are consistent with GALL AMP XI.S6 and will ensure that the roadway structure can perform its intended function consistent with the CLB. On this basis, the project team finds these enhancements to be acceptable.

7.1.23.5 Operating Experience The applicant states, in the CNP LRA, that its operating experience review included condition reports, licensee event reports, NRC inspection reports, peer assessments, and self-assessments. The most recent NRC inspection was conducted in 2001 which identified no findings of significance for the specific areas inspected.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.32 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.23.6 UFSAR Supplement The applicant provides its UFSAR supplement for the structures monitoring - structures monitoring program in the CNP LRA, Appendix A, Section A.2.1.35. The applicant states in Appendix A that the program is based on the guidance in NRC Regulatory Guide 1.160, Rev. 2, and NUMARC 93-01, Rev. 2. These two documents provide guidance for development of facility-specific programs to monitor the condition of structures and SCs within the scope of the Maintenance Rule and the scope of license renewal, such that there is no loss of structure or structural component intended function. This program requires enhancements that will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.23.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the enhancements to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.24 STRUCTURES MONITORING - CRANE INSPECTION PROGRAM (AMP B.1.33) 92

D.C. Cook Audit & Review Report In the CNP LRA, Appendix B, Section B.1.33, the applicant states that CNP AMP B.1.33, "Structures Monitoring - Crane Inspection," is an existing program that is consistent with GALL AMP XI.M23, "Inspection of Overhead Heavy Load and Light Load (Related to Refueling)

Handling Systems," with exceptions and enhancements.

7.1.24.1 Program Description The applicant states, in the CNP LRA, that this program includes testing and monitoring to provide assurance that the structures, systems, and components of these cranes are capable of sustaining their rated loads. This program is primarily concerned with passive structural components that make up the bridge and trolley.

7.1.24.2 Consistency with the GALL Report In the CNP LRA the applicant states that CNP AMP B.1.33 is consistent with GALL AMP XI.M23, with exceptions and enhancements.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.33, including Engineering Report LRP-EAMP-01, Section 4.20.2, "Crane Inspection Program," which provides an assessment of how the GALL AMP elements are addressed by the CNP crane inspection program.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documentation against GALL AMP XI.M23 for consistency.

7.1.24.3 Exceptions to the GALL Report The applicant states, in the CNP LRA, that exceptions to the GALL Report elements as follows:

Element: 3: Parameters Monitored/Inspected Exception: The number and magnitude of the lifts are not reviewed.

Element: 4: Detection of Aging Effects Exception: Functional tests are not performed on all in-scope cranes.

The GALL Report identifies the following criterion for the parameters monitored/inspected program element associated with the exception taken:

The number and magnitude of lifts made by the crane are reviewed.

The project team found that review of the number and magnitude of lifts is not necessary since the allowable limits are expected to provide adequate margin for the period of extended operation. The number of lifts made by cranes is addressed as a TLAA in Section 4.7.6 of the CNP LRA. NRR DE evaluation of the TLAA is documented in Section 4 of the SER related to the CNP LRA.

93

D.C. Cook Audit & Review Report The GALL Report identifies the following criterion for the detection of aging effects program element associated with the exception taken:

Crane rails and structural components are visually inspected on a routine basis for degradation. Functional tests are also performed to assure their integrity.

During the audit, the project team found that the intended function of many cranes is maintaining structural integrity to prevent impacting safety-related systems, structures, and components. Therefore, functional tests involving the active components of these cranes are not subject to aging management. On this basis, the project team finds the exception to be acceptable.

7.1.24.4 Enhancements The applicant states, in the CNP LRA, that the enhancements in meeting the GALL Report elements are as follows Element: 1: Scope of Program Enhancement: Develop procedures or recurring tasks to manage loss of material on the crane, rails, and supports of in-scope cranes.

Element: 3: Parameters Monitored/Inspected Enhancement: Develop procedures or recurring tasks to evaluate the effectiveness of the maintenance monitoring program and the effects of past and future usage on the structural reliability of in-scope cranes.

Element: 4: Detection of Aging Effects Enhancement: Develop procedures or recurring tasks to verify that in-scope crane rails and structural components are visually inspected on a routine basis for loss of material.

Element: 6: Acceptance Criteria Enhancement: Develop procedures or recurring tasks to verify that significant visual indications of loss of material due to corrosion or wear are evaluated according to applicable industry standards and good industry practice.

The GALL Report identifies the following criterion for the scope of program element associated with the enhancement:

The program manages the effects of general corrosion on the crane and trolley structural components for those cranes that are within the scope of 10 CFR 54.4, and the effects of wear on the rails in the rail system.

94

D.C. Cook Audit & Review Report The project team finds that addition of procedures or recurring tasks to manage loss of material on in-scope components is consistent with the requirements for this program element in GALL AMP XI.M23. On this basis, the project team finds this enhancement to be acceptable.

The GALL Report identifies the following criterion for the parameters monitored/inspected program element associated with the enhancement:

The program evaluates the effectiveness of the maintenance monitoring program and the effects of past and future usage on the structural reliability of cranes.

The project team finds that addition of procedures or recurring tasks to evaluate the effectiveness of the maintenance monitoring program and the effects of past and future usage on the structural reliability of cranes is consistent with the requirements for this program element in GALL AMP XI.M23. On this basis, the project team finds this enhancement to be acceptable.

The GALL Report identifies the following criterion for the detection of aging effects program element associated with the enhancement:

Crane rails and structural components are visually inspected on a routine basis for degradation.

The project team finds that addition of procedures or recurring tasks to visually inspect crane rails and structural components for degradation on a routine basis is consistent with the requirements for this program element in GALL AMP XI.M23. On this basis, the project team finds this enhancement to be acceptable.

The GALL Report identifies the following criterion for the acceptance criteria program element associated with the enhancement:

Any significant visual indication of loss of material due to corrosion or wear are evaluated according to applicable industry standards and good industry practice.

If the crane was designed to a specific EOCI or CMAA service class, the specification that was applicable at the time the crane was manufactured is used.

The applicant committed to modify procedure 12-EHP-5035.SMP.001 ,"Plant Structure Performance Evaluation and Monitoring Program," to identify the earth underneath the roadway (shore line) within the procedure.

The project team finds that addition of procedures or recurring tasks to evaluate significant visual indications of degradation according to applicable industry standards and good practice is consistent with the requirements for this program element in GALL AMP XI.M23. On this basis, the project team finds this enhancement to be acceptable.

7.1.24.5 Operating Experience 95

D.C. Cook Audit & Review Report The applicant states, in the CNP LRA, that its operating experience review included a review of condition reports, licensee event reports, NRC inspection reports, and self-assessments.

The project team reviewed operating experience relative to the crane inspection program. No crane aging problems were identified. One industry OE identified had a crane rail stud failure due to fatigue (CR-98-00136). The corrective action performed by the applicant was to have the crane representative perform inspections of major cranes, and to modify the preventive maintenance task sheet to ensure inspections are performed prior to crane use.

The applicant, in condition report CR-99-17230, identified a small amount of peeling paint on the new and spent fuel handling crane. The limited extent of the condition did not constitute an FME concern. Nonetheless, action request A0186183 was generated to correct the situation.

This shows problems are being noticed and identified early, before significant equipment degradation occurs.

No crane aging problems were identified at CNP. This operating experience is consistent with the conclusion that the program is effectively monitoring cranes, and taking effective actions when problems are found.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.33 adequately manages the aging effects that have been observed at the applicant's plant or at other nuclear facilities.

7.1.24.6 UFSAR Supplement The applicant provides its UFSAR supplement for the structures monitoring - crane inspection program in the CNP LRA, Appendix A, Section A.2.1.36, which states that the program includes testing and monitoring to provide assurance that the structures and components of cranes in the scope of license renewal are capable of sustaining their rated loads. Crane rails and structural components will be visually inspected on a routine basis for degradation to manage loss of material. This program requires enhancements that will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.24.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the exceptions and the enhancements to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

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D.C. Cook Audit & Review Report On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.25 STRUCTURES MONITORING - DIVIDER BARRIER SEAL INSPECTION (AMP B.1.34)

In the CNP LRA, Appendix B, Section B.1.34, the applicant describes CNP AMP B.1.34, "Structures Monitoring - Divider Barrier Seal Inspection."

The applicant states that CNP AMP B.1.34 is a plant-specific program. The divider barrier in each containment is the physical boundary that separates upper containment from lower containment. Several containment internal structures constitute the divider barrier. Elastomeric seals are provided for penetrations and openings through the divider barrier where it is necessary to limit potential ice condenser bypass leakage subsequent to a postulated pipe rupture or loss of coolant accident. Cracking and change in material properties are aging effects requiring management for the pressure seals.

The project team reviewed the documents listed in Attachment 4 of this audit and review report, in whole or in part, including Engineering Report LRP-EAMP-01, Section 4.20.3, "Structures Monitoring Programs - Divider Barrier Seal Inspection," for the structures monitoring - divider barrier seal inspection program and interviewed the applicant's technical staff.

7.1.25.1 Review of the AMP Against the Program Elements The project team reviewed CNP AMP B.1.34 against the AMP elements found in the SRP-LR, Appendix A.1, Section A.1.2.3 and SRP-LR Table A.1-1. The guidance described in the CNP audit and review plan was followed.

7.1.25.1.1 Scope of Program The applicant states in CNP AMP B.1.34 that the "scope of program" program element for this program is the containment divider barrier elastomeric pressure seals around penetrations and openings through the divider barrier.

This program element criterion in Appendix A.1 of the SRP-LR requires that the program scope include the specific structures and components addressed with this program.

The project team confirmed that the specific components for which the program manages aging effects are identified, which satisfies the criterion defined in Appendix A.1 of the SRP-LR. On this basis, the project team finds that the applicant's proposed scope is acceptable.

7.1.25.1.2 Preventive Actions The applicant states in CNP AMP B.1.34 that the "preventive actions" program element is not applicable because the divider barrier seal inspection program is an inspection program and no actions will be taken as part of this program to prevent or mitigate aging degradation.

97

D.C. Cook Audit & Review Report This program element criterion in Appendix A.1 of the SRP-LR is that condition monitoring programs do not rely on preventive actions, and thus, preventive actions need not be provided.

The project team confirmed that the preventive actions program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The project team did not identify the need for preventive actions for AMP B.1.34 because it is an inspection program.

7.1.25.1.3 Parameters Monitored/Inspected The applicant states in CNP AMP B.1.34, for the "parameters monitored or inspected" program element, that this program monitors cracking and change in material properties of elastomeric pressure seals.

This program element criteria in Appendix A.1 of the SRP-LR are The parameters to be monitored or inspected should be identified and linked to the degradation of the particular structure and component intended function(s).

The parameter monitored or inspected should detect the presence and extent of aging effects.

The project team reviewed this program element against the criteria defined in Appendix A of the SRP-LR. The project team reviewed the applicants procedures which address inspection and testing and describe the parameters for cracking and other geometric discontinuities. No test or inspection was identified that would reveal a change in material properties.

The project team requested clarification on the method used to monitor a change in material properties of the elastomeric pressure seals. By letter dated April 23, 2004 (ML041270484),

the applicant responded that the phrase "change in material properties" was intended to convey a visual inspection to ensure the absence of apparent deterioration (i.e., cracks or defects in the sealing surfaces) as discussed in the implementing procedures. Changes in other material properties are neither monitored nor inspected.

Since cracking is addressed separately and because material properties that may affect the performance of seals (e.g., hardening, embrittlement) are not addressed, the project team does not consider this issue resolved. The project team asked the applicant to provide a basis for concluding that degradation (e.g., hardening, embrittlement) will be apparent before the intended function is challenged. Otherwise, the project team asked the applicant to provide a technical basis for the conclusion that the elastomers in question are not subject to these effects or that these effects will not interfere with the intended function of the component. This is followup item 7.1.25-1 and will be dispositioned in the SER related to the CNP LRA (RAI B.1.34-1).

7.1.25.1.4 Detection of Aging Effects The applicant states in CNP AMP B.1.34 for the "detection of aging effects" program element that 98

D.C. Cook Audit & Review Report The program detects cracking and change in material properties prior to loss of the pressure seals' intended functions. The seals around penetrations and openings (including the bulkhead gate) are visually inspected to ensure the absence of apparent deterioration (cracks or defects).

The frequency of inspection is at least once every 10 years.

The criteria for this program element in Appendix A.1 of the SRP-LR are Provide information that links the parameters to be monitored or inspected to the aging effects being managed.

Describe when, where, and how program data are collected (i.e., all aspects of activities to collect data as part of the program).

Link the method or technique and frequency, if applicable, to plant-specific or industry-wide operating experience.

Provide the basis for the inspection population and sample size when sampling is used to inspect a group of SCs. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The divider barrier seals will be inspected at least once every 10 years. Visual inspections will examine the pressure seals for signs of cracking or surface defects properties prior to loss intended function.

7.1.25.1.5 Monitoring and Trending The applicant states in CNP AMP B.1.34 for the "monitoring and trending" program element that this program monitors aging effects through visual examination of the seals. The corrective action program provides reasonable assurance that repeated failures to meet acceptance criteria will be identified and addressed with appropriate corrective actions.

The criteria for this program element in Appendix A.1 of the SRP-LR are Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions.

This program element describes how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.

The project team confirms that for visual inspection, this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The plant procedures describe the documentation and monitoring of visual inspection results.

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D.C. Cook Audit & Review Report 7.1.25.1.6 Acceptance Criteria The applicant states in CNP AMP B.1.34 for the "acceptance criteria" program element that seals must be free of unacceptable deterioration (excessive cracks or defects) and unacceptable misalignment.

The criteria for this program element in Appendix A.1 of the SRP-LR are The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the SC intended function(s) are maintained under all CLB design conditions during the period of extended operation.

The program should include a methodology for analyzing the results against applicable acceptance criteria.

Qualitative inspections should be performed to same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site-specific programs.

The project team reviewed this program element to determine whether or not it satisfies the criteria defined in Appendix A.1 of the SRP-LR. Any degradation that could lead to loss of function will be found unacceptable and corrective measures implemented.

The acceptance criteria described in implementing procedures include evidence of chemical attack, radiation damage, or changes in physical appearance. No guidance is provided as to how these are to be evaluated.

The project team requested clarification on the acceptance criteria for evaluating changes in material properties of elastomers, specifically, the pressure seals (divider barrier). The project team determined that implementing procedures mention evidence of chemical attack, radiation damage, or changes in physical appearance. The project team asked the applicant to clarify how these will be evaluated and confirm that visual evidence of degradation will precede loss of function. This is followup item 7.1.25-2 and will be dispositioned in the SER related to the CNP LRA (RAI B.1.34-2).

7.1.25.1.7 Corrective Actions This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.25.1.8 Confirmation Process This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.25.1.9 Administrative Controls 100

D.C. Cook Audit & Review Report This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.25.1.10 Operating Experience The applicant states, in the CNP LRA, that its operating experience relative to the divider barrier seal inspection program included condition reports and licensee event reports. The review revealed that the program is monitoring and detecting the aging of the elastomer seals prior to loss of intended function. The condition reports included all aspects of the divider barrier seal and indicated no pattern of repeat conditions. For example, a condition report documented adequacy of inspection and replacement criteria for seals covered by the program. Another condition report and associated licensee event reports documented correction of ice condenser bypass leakage in excess of the design basis through implementation of design changes.

The applicant also states that due to the limited number of ice condenser containments has resulted in minimal industry operating experience. No examples of industry experience relative to the CNP plants were identified.

The "operating experience" program element criterion in Appendix A.1 of the SRP-LR states that operating experience should provide objective evidence to support the conclusion that the effects of aging will be managed adequately so that the SC intended function(s) will be maintained during the period of extended operation.

The project team reviewed CR-00304040,"Various Problems with the Material of the Divider Barrier Seal," which describes operating experience from the existing barrier seal inspection and monitoring program. The project team recognizes that the corrective action program, which captures internal and external plant operating experience issues, will provide reasonable assurance that operating experience is reviewed and incorporated in the future to provide objective evidence to support the conclusion that the effects of aging are adequately managed.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.34 will adequately manage the aging effects that have been observed at the applicant's plant.

7.1.25.2 UFSAR Supplement The applicant provides its UFSAR supplement for the structures monitoring - divider barrier seal inspection program in the CNP LRA, Appendix A, Section A.2.1.37, and states that the program detects cracking and change in material properties of elastomeric pressure seals for penetrations and openings through the containment divider barrier. The program detects aging effects through visual examination of the seals.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.25.3 Conclusion 101

D.C. Cook Audit & Review Report On the basis of its audit and review of the applicant's program, pending satisfactory resolution of RAI B.1.34-2, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.26 STRUCTURES MONITORING - ICE BASKET INSPECTION (AMP B.1.35)

In the CNP LRA, Appendix B, Section B.1.35, the applicant describes CNP AMP B.1.35, "Structures Monitoring - Ice Basket Inspection."

The applicant states that CNP AMP B.1.35 is a plant-specific program. The applicant credits this program with providing instructions to verify that ice condenser baskets are free of detrimental structural wear, cracks, corrosion, or any other noticeable damage. The functional integrity of the ice condenser baskets ensures that the ice condenser can perform its intended safety function.

The project team reviewed the documents listed in Attachment 4 of this audit and review report, in whole or in part, including Engineering Report LRP-EAMP-01, Section 4.20.4, "Structures Monitoring Programs - Ice Basket Inspection," for the structures monitoring - ice basket inspection program and interviewed the applicant's technical staff.

7.1.26.1 Review of the AMP Against the Program Elements The project team reviewed CNP AMP B.1.35 against the AMP elements found in the SRP-LR, Appendix A, Section A.1.2.3 and SRP-LR Table A.1-1. The guidance described in the CNP audit and review plan was followed.

7.1.26.1.1 Scope of Program The applicant states in CNP AMP B.1.35 that the "scope of program" program element includes verification that the ice condenser baskets are operable as required by Technical Specification Surveillance Requirement 4.6.5.1.d. The requirement is to check a sample of ice baskets at least every 40 months to verify that they are free of detrimental structural wear, cracks, corrosion or other damage.

This program element criterion in Appendix A.1 of the SRP-LR requires that program scope include the specific SCs addressed with this program.

The project team confirmed that the program scope program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The proposed scope identifies the specific components for which the program manages aging. On this basis, the project team finds that the applicant's proposed program scope is acceptable.

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D.C. Cook Audit & Review Report 7.1.26.1.2 Preventive Actions The applicant states in CNP AMP B.1.35 that the "preventive actions" program element is not applicable because the structures monitoring - ice basket inspection program is an inspection program and no actions will be taken as part of this program to prevent or mitigate aging degradation.

This program element criterion in Appendix A.1 of the SRP-LR is that condition monitoring programs do not rely on preventive actions, and thus, preventive actions need not be provided.

The project team confirmed that the "preventive actions" program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The project team did not identify the need for preventive actions for CNP AMP B.1.35 because it is a condition monitoring program.

7.1.26.1.3 Parameters Monitored/Inspected The applicant states in CNP AMP B.1.35, for the "parameters monitored or inspected" program element, that visual checks are made for the ice basket bottom, top rim, coupling connections, stiffener rings, weld seams, and ligaments. Ligaments are checked for visible pitting or surface metal wastage caused by corrosion that is significant enough to dimensionally affect the ligament.

This program element criteria in Appendix A of the SRP-LR are The parameters to be monitored or inspected should be identified and linked to the degradation of the particular structure and component intended function(s).

The parameter monitored or inspected should detect the presence and extent of aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The structures monitoring - ice basket inspection activities are intended to detect the presence and extent of aging effects. On this basis, the project team finds that the parameters monitored or inspected program element is acceptable.

7.1.26.1.4 Detection of Aging Effects The applicant states in CNP AMP B.1.35 for the "detection of aging effects" program element that the program detects loss of material of the ice baskets prior to loss of structure or component intended function.

The detection of aging effects program element criteria in Appendix A.1 of the SRP-LR are Provide information that links the parameters to be monitored or inspected to the aging effects being managed.

Describe when, where, and how program data are collected (i.e., all aspects of activities to collect data as part of the program).

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D.C. Cook Audit & Review Report Link the method or technique and frequency, if applicable, to plant-specific or industry-wide operating experience.

Provide the basis for the inspection population and sample size when sampling is used to inspect a group of SCs. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The inspections are conducted, using a frequency and sample size required by plant technical specifications, to detect the presence and extent of aging effects. On that basis, the project team finds that the detection of aging effects program element is acceptable.

7.1.26.1.5 Monitoring and Trending The applicant states in CNP AMP B.1.35 for the "monitoring and trending" program element that results of the ice basket inspections are retained to permit confirmation of the inspection program effectiveness.

The criteria for this program element in Appendix A.1 of the SRP-LR are Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions.

This program element describes how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.

The project team confirmed that this program element satisfies the criteria defined in Appendix A of the SRP-LR. Trending of the inspection results will enhance the applicant's ability to detect aging effects before there is a loss of intended function. On this basis, the project team finds that the monitoring and trending program element is acceptable.

7.1.26.1.6 Acceptance Criteria The applicant states in CNP AMP B.1.35 for the "acceptance criteria" program element that acceptance criteria for the ice basket inspections are specified in plant procedures to ensure that the ice baskets are free of detrimental structural wear, cracks, corrosion, or other damage.

The criteria for this program element in Appendix A.1 of the SRP-LR are The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the structure and component intended function(s) are maintained under all CLB design conditions during the period of extended operation.

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D.C. Cook Audit & Review Report The program should include a methodology for analyzing the results against applicable acceptance criteria.

Qualitative inspections should be performed to same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site-specific programs.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. Any identified deficiencies will be found unacceptable and corrective measures implemented. On this basis, the project team finds that the acceptance criteria program element is acceptable.

7.1.26.1.7 Corrective Actions This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.26.1.8 Confirmation Process This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.26.1.9 Administrative Controls This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.26.1.10 Operating Experience The applicant states in CNP AMP B.1.35 for the "operating experience" program element that its review of relevant operating experience included condition reports, licensee event reports, and NRC inspection reports.

The applicant states, in the CNP LRA, that the condition reports related to this program identified ice basket damage, flow passage problems, etc. Damage to baskets was found to be the result of improper handling of the baskets during testing (weighing) and refilling, rather than aging effects. The applicant also states that enhancements were incorporated into the program under the corrective actions for these condition reports. The applicant further states that an NRC inspection of the ice condensers was performed in 1998. No aging effects were identified in the inspection report.

This program element criterion in Appendix A.1 of the SRP-LR states that operating experience should provide objective evidence to support the conclusion that the effects of aging will be adequately managed so that the SC intended function(s) will be maintained during the period of extended operation.

The project team reviewed CNP procedure 12-MHP-4030-010-007, "Ice Condenser Ice Basket Surveillance," which provides enhanced instructions for maintaining ice baskets. Additional program enhancements have been made under the corrective action program. Based on its 105

D.C. Cook Audit & Review Report review, the project team concludes that operating experience for the structures monitoring - ice basket inspection program has been identified, and corrective actions, where needed, have been performed as a result.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.35 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.26.2 UFSAR Supplement The applicant provides its UFSAR supplement for the structures monitoring - ice basket inspection program in the CNP LRA, Appendix A, Section A.2.1.38, and states that the program verifies that ice condenser baskets are free of detrimental structural wear, cracks, corrosion, or noticeable damage. The program detects loss of material of the ice baskets by visual inspections as required by Technical Specifications.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.26.3 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.27 STRUCTURES MONITORING - MASONRY WALL (AMP B.1.36)

In the CNP LRA, Appendix B, Section B.1.36, the applicant states that CNP AMP B.1.36, "Structures Monitoring - Masonry Wall," is consistent with GALL AMP XI.S5, "Masonry Wall Program," with an enhancement.

7.1.27.1 Program Description In the CNP LRA, the applicant states that the objective of the masonry wall program is to manage aging effects so that the evaluation basis established for each masonry wall within the scope of license renewal remains valid through the period of extended operation. The applicant states that masonry walls are inspected as part of the structures monitoring program conducted for the Maintenance Rule, 10 CFR 50.65.

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D.C. Cook Audit & Review Report 7.1.27.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.36 is consistent with GALL AMP XI.S5, with an enhancement.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.36, including Engineering Report LRP-EAMP-01, Section 4.20.5, "Masonry Wall Program," which provides an assessment of the AMP elements' consistency with GALL AMP XI.S5, and 12-EHP-5035-SMP-001, "Plant Structure Performance Evaluation and Monitoring Program,"

which provides additional information on the implementing activities/inspections.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documents against GALL AMP XI.S5 for consistency.

7.1.27.3 Exceptions to the GALL Report None 7.1.27.4 Enhancements The applicant states, in the CNP LRA, that the enhancement in meeting the GALL Report elements as follows Element: 1: Scope Enhancement: Include the four-hour fire rated masonry block in the turbine building and screenhouse, and the masonry block in the auxiliary building.

The GALL Report identifies the following criterion for the scope program element associated with the enhancement The scope includes all masonry walls identified as performing intended functions in accordance with 10 CFR 54.4.

The project team finds that the inclusion of the masonry block in the turbine building, screenhouse, and auxiliary building is consistent with the GALL Report. The applicant identifies these structural components as within the scope of license renewal, performing intended functions in accordance with 10 CFR 54.4. On this basis, the project team finds the enhancement to be acceptable.

7.1.27.5 Operating Experience The applicant states, in the CNP LRA, that operating experience review for this AMP included condition reports, NRC inspection reports, and documentation of the results of internal program assessments.

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D.C. Cook Audit & Review Report The applicant states, in the CNP LRA, that physical degradation was identified during a walkdown in 1999. Three block walls had mortar joints that were cracked and needed to be resealed. As a result of these findings, additional inspections were conducted for loss of function (none were found) and the walls were repaired. This demonstrates that activities performed under the program actively identify and manage aging effects prior to loss of function.

Based on a review of the applicants condition reports, the project team concludes that operating experience for the structures monitoring - masonry wall program has been identified, and corrective actions, where needed, have been performed as a result.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.36 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.27.6 UFSAR Supplement The applicant provides its UFSAR supplement for the structures monitoring - masonry wall program in the CNP LRA, Appendix A, Section A.2.1.39. The applicant states in Appendix A that the program manages cracking of masonry walls within the scope of license renewal.

Masonry walls are visually inspected as part of the structures monitoring program conducted for 10 CFR 50.65, the Maintenance Rule. The applicant states that this program requires an enhancement that will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.27.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistencies with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the enhancement to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.28 SYSTEM TESTING (AMP B.1.37)

In the CNP LRA, Appendix B, Section B.1.37, the applicant describes CNP AMP B.1.37, "System Testing."

The applicant states that CNP AMP B.1.37 is a plant-specific program. The applicant credits this program with encompassing a number of miscellaneous system and component testing 108

D.C. Cook Audit & Review Report activities credited for managing the effects of aging. These activities are typically surveillance activities required by the applicant technical specifications or normal monitoring of plant operation (for example, plant log readings or other normal monitoring techniques). In general, these activities are conducted on a periodic basis (surveillances) or routinely (logs) during plant operation. They are intended to verify the continuing capability of safety-related systems and components to meet established performance requirements.

The project team reviewed the documents listed in Attachment 4 of this audit and review report, in whole or in part, including Engineering Report LRP-EAMP-01, Section 4.21, "System Testing Program," for the system testing program and interviewed the applicant's technical staff.

7.1.28.1 Review of the AMP Against the Program Elements The project team reviewed CNP AMP B.1.37 against the AMP elements found in the SRP-LR, Appendix A, Section A.1.2.3 and SRP-LR Table A.1-1. The guidance described in the CNP audit and review plan was followed.

7.1.28.1.1 Scope of Program The applicant states in CNP AMP B.1.37 that the "scope of program" program element includes the following testing activities: (1) centrifugal charging pump test; (2) engineered safety features ventilation units testing; (3) control room ventilation units testing; (4) fuel handling area exhaust unit testing; (5) security diesel test; (6) letdown orifice test; (7) main steam flow meter monitoring; (8) blowdown system normal operation monitoring; and (9) spent fuel pool water level monitoring.

This program element criterion in Appendix A.1 of the SRP-LR requires that program scope include the specific SCs addressed with this program.

The project team confirmed that the program scope program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The proposed scope identifies the specific components for which the program manages aging. On this basis, the project team finds that the applicant's proposed program scope is acceptable.

7.1.28.1.2 Preventive Actions The applicant states in CNP AMP B.1.37 that the preventive actions program element is not applicable because the system testing program is an inspection program and no actions will be taken as part of this program to prevent or mitigate aging degradation.

This program element criterion in Appendix A.1 of the SRP-LR is that condition monitoring programs do not rely on preventive actions, and thus, preventive actions need not be provided.

The project team confirmed that the "preventive actions" program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The project team did not identify the need for preventive actions for AMP B.1.37 because it is a condition monitoring program.

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D.C. Cook Audit & Review Report 7.1.28.1.3 Parameters Monitored/Inspected The applicant states in CNP AMP B.1.37, for the "parameters monitored or inspected" program element, that the program monitors flow rates and pressure.

This program element criteria in Appendix A of the SRP-LR are The parameters to be monitored or inspected should be identified and linked to the degradation of the particular structure and component intended function(s).

The parameter monitored or inspected should detect the presence and extent of aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The program monitors such aging effects as loss of material in the centrifugal charging pump discharge orifice and aging effects on drains from various ventilation units. Fouling and loss of material in parts of the security diesel are addressed as well as loss of material in the buried fuel oil storage tank, pipe, tubing and associated fittings, starting air components, and (diesel) exhaust gas components. In addition, the condition of chemical and volume control system letdown orifices and main steam system flow restrictors are monitored in the course of plant operation, as is the level of the spent fuel pool.

Parameters are monitored at frequencies based on evaluation, and trended by the Site Surveillance Tracking Database. On this basis, the project team finds that the parameters monitored or inspected program element is acceptable.

7.1.28.1.4 Detection of Aging Effects The applicant states in CNP AMP B.1.37 for the "detection of aging effects" program element that For license renewal, centrifugal charging pumps system testing will be enhanced to manage loss of material for the centrifugal charging pumps minimum flow orifices and the Unit 1 centrifugal charging pumps discharge orifices. ASME Section XI pump testing will verify the orifices have not experienced loss of material to the extent of impacting the ability of a pump to provide the required flow.

For license renewal, engineered safety features ventilation units system testing will be enhanced to manage the effects of aging on the drain valves and drain piping from these units. During surveillance testing, a visual inspection of the drain valves and drain piping will be accomplished.

For license renewal, control room ventilation units system testing will be enhanced to manage the effects of aging on the drain valves and drain piping from these units. During surveillance testing, a visual inspection of the drain valves and drain piping will be accomplished.

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D.C. Cook Audit & Review Report For license renewal, fuel handling area exhaust unit system testing will be enhanced to manage the effects of aging on the drain valves and drain piping from this unit. During surveillance testing, a visual inspection of the drain valves and drain piping will be accomplished.

Testing requirements include periodically starting the security diesel and operating it in accordance with manufacturer's recommendations. System testing is credited for managing fouling and loss of material for the security diesel jacket water heat exchangers and lube oil heat exchanger tubes. Since periodic engine testing and inspections are performed on the security diesel, system testing is also credited for managing loss of material for the buried fuel oil storage tank, pipe, tubing and fittings, starting air components, and exhaust gas components. Fuel oil level indication and periodic pressure testing with use of the spectacle flange manage the aging effects on the buried fuel oil storage tank. During engine operation, monitoring engine parameters and performing visual inspections manage the aging effects by verifying the pressure boundary of engine components. Also, six-month and annual inspections are performed on the security diesel to manage the aging effects on security diesel passive mechanical components.

The letdown orifices reduce the pressure in the letdown line from RCS pressure to the lower pressure allowed for the demineralizers and other CVCS components. Normal plant operation will verify the ability of the letdown orifices to control flow. CVCS letdown flow is recorded hourly on the Unit 1 or Unit 2 Critical Parameters Log.

System testing includes monitoring the components during normal plant operation. For the main steam system, this monitoring manages the aging effect of loss of material from the main steam flow restrictors. A material loss from the internal surface of the flow restrictors significant enough to impact its flow control function would be detected by changes in the flow reading. For the blowdown system, this monitoring is credited with ensuring the restricting orifices are performing their flow control (pressure breakdown) function, and managing the aging effect of loss of material from erosion for the internal surfaces of the orifices.

The spent fuel pool water level is monitored and recorded once per shift.

Monitoring the spent fuel pool level allows early detection of leakage through the spent fuel pool liner. This program manages the aging effect of loss of material and cracking for the spent fuel pool liner.

The detection of aging effects program element criteria in Appendix A.1 of the SRP-LR are Provide information that links the parameters to be monitored or inspected to the aging effects being managed.

Describe when, where, and how program data are collected (i.e., all aspects of activities to collect data as part of the program).

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D.C. Cook Audit & Review Report Link the method or technique and frequency, if applicable, to plant-specific or industry-wide operating experience, to demonstrate that inspection frequency is adequate to detect the aging effect before a loss of intended function.

Provide the basis for the inspection population and sample size when sampling is used to inspect a group of SCs. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

By letter dated May 6, 2004, the staff forwarded to the applicant RAI 3.3.2.1.9-1. The staff, in RAI 3.3.2.1.9-1, stated that in CNP LRA Table 3.3.2-9, the applicant credited CNP AMP B.1.37 with managing loss of material for stainless steel fittings and stainless steel/carbon steel piping in a soil environment. However, CNP AMP B.1.37 does not define fitting or pipe condition or approximate rate of degradation as recommended in GALL AMPs XI.M28 and XI.M34 for buried fittings/piping. Therefore, the staff requested, in RAI 3.3.2.1.9-1, that the applicant either provide justification for exclusion of the buried piping/fittings condition assessment from AMP B.1.37 or to revise the CNP LRA accordingly. RAI 3.3.2.1.9-1 is reviewed by NRR DE staff and addressed in Section 3.0 of the SER related to the CNP LRA.

The project team confirmed that, pending resolution of the RAI, this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The selection of parameters monitored and the frequency with which they are evaluated are consistent with the goal of detecting aging effects before loss of function occurs. The applicant identified the need to enhance the system testing program to inspect centrifugal charging pump minimum flow orifices and to address the verification of pressure boundary integrity in various drain systems. Pending resolution of RAI 3.3.2.1.9-1, the project team finds that the detection of aging effects program element is acceptable.

7.1.28.1.5 Monitoring and Trending The applicant states in CNP AMP B.1.37 for the "monitoring and trending" program element that the surveillance and monitoring activities associated with this program are performed on a specific frequency as listed in the site surveillance tracking database and the results of these activities are documented. The program includes various frequencies, depending upon the specific component or system being tested.

The criteria for this program element in Appendix A.1 of the SRP-LR are Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions.

This program element describes how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.

The project team confirmed that this program element satisfies the criteria defined in Appendix A of the SRP-LR. Trending of the inspection results will enhance the applicant's 112

D.C. Cook Audit & Review Report ability to detect aging effects before there is a loss of intended function. On this basis, the project team finds that the monitoring and trending program element is acceptable.

7.1.28.1.6 Acceptance Criteria The applicant states in CNP AMP B.1.37 for the "acceptance criteria" program element that acceptance criteria and guidelines for the surveillances and normal log readings are provided in the governing procedures. Acceptance criteria are tailored for each individual system or component test.

The criteria for this program element in Appendix A.1 of the SRP-LR are The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the structure and component intended function(s) are maintained under all CLB design conditions during the period of extended operation.

The program should include a methodology for analyzing the results against applicable acceptance criteria.

Qualitative inspections should be performed to same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site-specific programs.

The project team reviewed a sample of plant testing procedures and confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The project team finds that, under the plant corrective action program, deficiencies, when discovered during inspections, will be found unacceptable and corrective measures implemented. On this basis, the project team finds that the acceptance criteria program element is acceptable.

7.1.28.1.7 Corrective Actions This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.28.1.8 Confirmation Process This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.28.1.9 Administrative Controls This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

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D.C. Cook Audit & Review Report 7.1.28.1.10 Operating Experience The applicant states in CNP AMP B.1.37 for the "operating experience" program element that a review of condition reports and interviews with the system managers, related to the various tests and inspections that constitute the system testing program, found that testing procedure issues have been identified and corrected. Although typical component problems have been identified, system testing has not identified aging-related problems for monitored components.

This program element criterion in Appendix A.1 of the SRP-LR states that operating experience should provide objective evidence to support the conclusion that the effects of aging will be adequately managed so that the SC intended function(s) will be maintained during the period of extended operation.

The project team noted that plant operating experience with respect to system testing is extensive. The project team reviewed the applicant's documentation of operating experience for this AMP and found that it was not specific to the aging effects of concern or the components addressed. However, comparable component problems have been identified and corrected, suggesting that the program will be effective if aging effects are observed.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.37 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.28.2 UFSAR Supplement The applicant provides its UFSAR supplement for the system testing program in the CNP LRA, Appendix A, Section A.2.1.40, and states that the program encompasses a number of miscellaneous system and component testing activities credited for managing the effects of aging. These activities are typically surveillance activities required by the Technical Specifications or normal monitoring of plant operation (for example, plant log readings or other normal monitoring techniques). In general, these activities are conducted on a periodic basis (surveillances) or routinely (logs) during plant operation. They are intended to verify the continuing capability of safety-related systems and components to meet established performance requirements. This program requires enhancements that will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.28.3 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

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D.C. Cook Audit & Review Report On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.29 SYSTEM WALKDOWN (AMP B.1.38)

In the CNP LRA, Appendix B, Section B.1.38, the applicant describes CNP AMP B.1.38, "System Walkdown."

The applicant states that CNP AMP B.1.38 is a plant-specific program. The applicant credits this program with managing aging effects on systems and components within the scope of license renewal and subject to an AMR.

The project team reviewed the documents listed in Attachment 4 of this audit and review report, in whole or in part, including Engineering Report LRP-EAMP-01, Section 4.22, "System Walkdown Program," for the system walkdown program and interviewed the applicant's technical staff.

7.1.29.1 Review of the AMP Against the Program Elements The project team reviewed CNP AMP B.1.38 against the AMP elements found in the SRP-LR, Appendix A, Section A.1.2.3 and SRP-LR Table A.1-1. The guidance described in the CNP audit and review plan was followed.

7.1.29.1.1 Scope of Program The applicant states in CNP AMP B.1.38 that the "scope of program" program element includes inspections of external surfaces of CNP components within the scope of license renewal and subject to an AMR. The program is credited with managing loss of material from internal surfaces for situations in which the external surface condition is representative of the internal surface condition and both have the same environment. The program is also credited with detecting leakage and spray from liquid-filled low-energy systems before such leakage can prevent satisfactory accomplishment of safety functions.

The applicant states, in the CNP LRA, that for license renewal this program element will be enhanced to include balance-of-plant systems such as fire protection and security diesel, and non-safety-related components affecting safety-related systems.

This program element criterion in Appendix A.1 of the SRP-LR requires that program scope include the specific SCs addressed with this program.

The project team confirmed that the program scope program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The proposed scope identifies the specific components for which the program manages aging. On this basis, the project team finds that the applicant's proposed program scope is acceptable.

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D.C. Cook Audit & Review Report 7.1.29.1.2 Preventive Actions The applicant states in CNP AMP B.1.38 that the preventive actions program element is not applicable because the system walkdown program is an inspection program and no actions will be taken as part of this program to prevent or mitigate aging degradation.

This program element criterion in Appendix A.1 of the SRP-LR is that condition monitoring programs do not rely on preventive actions, and thus, preventive actions need not be provided.

The project team confirmed that the "preventive actions" program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The project team did not identify the need for preventive actions for AMP B.1.38 because it is a condition monitoring program.

7.1.29.1.3 Parameters Monitored/Inspected The applicant states in CNP AMP B.1.38, for the "parameters monitored or inspected" program element, that during a walkdown, the engineer monitors for items which could affect system performance, safety, or reliability as well as general housekeeping, personnel safety hazards, and radiological concerns. Examples of parameters inspected during the system walkdowns are condition and placement of coatings, evidence of corrosion, and indications of leakage.

The applicant states that for license renewal this program element will be enhanced to ensure that evidence of corrosion is adequately monitored.

This program element criteria in Appendix A of the SRP-LR are C The parameters to be monitored or inspected should be identified and linked to the degradation of the particular structure and component intended function(s).

C The parameters monitored or inspected should detect the presence and extent of aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The system walkdown activities are intended to detect the presence and extent of aging effects. On this basis, the project team finds that the parameters monitored or inspected program element is acceptable.

7.1.29.1.4 Detection of Aging Effects The applicant states in CNP AMP B.1.38 for the "detection of aging effects" program element that A general visual inspection is conducted on readily accessible system and component surfaces during walkdowns.

The program is credited with managing loss of material for external and internal carbon steel surfaces, loss of mechanical closure integrity for bolted closures that may be exposed to borated water leakage, loss of material (including that 116

D.C. Cook Audit & Review Report due to selective leaching) for copper alloy and cast iron surfaces, and cracking of stainless steel surfaces.

The detection of aging effects program element criteria in Appendix A.1 of the SRP-LR are Provide information that links the parameters to be monitored or inspected to the aging effects being managed.

Describe when, where, and how program data are collected (i.e., all aspects of activities to collect data as part of the program).

Link the method or technique and frequency, if applicable, to plant-specific or industry-wide operating experience.

Provide the basis for the inspection population and sample size when sampling is used to inspect a group of SCs. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The walkdowns are conducted, using a frequency and sample size based on operating experience, to detect the presence and extent of aging effects. By letter dated May 26, 2004, in related RAI 3.3.2.1.11-3 from the staff, the applicant was asked to explain how the system walkdown program will detect loss of material on the internal surfaces of the components subject to an AMR that meet the criterion of 10 CFR 54.4(a)(2), or those non-safety-related components that affect the safety-related function of a system within the scope of license renewal. Pending the satisfactory resolution of RAI 3.3.2.1.11-3, the project team finds that the detection of aging effects program element is acceptable.

7.1.29.1.5 Monitoring and Trending The applicant states in CNP AMP B.1.38 for the "monitoring and trending" program element that observations are documented in quarterly walkdown reports.

The criteria for this program element in Appendix A.1 of the SRP-LR are Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions.

This program element describes how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.

During the audit, the project team asked whether the walkdowns are performed quarterly or merely documented quarterly. The applicant responded that the walkdowns are performed quarterly, and provided documentation of this requirement.

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D.C. Cook Audit & Review Report The project team confirmed that this program element satisfies the criteria defined in Appendix A of the SRP-LR. The scope of the walkdowns is defined by the respective plant system managers. The program requires written reports, and discrepancies are documented in the corrective action program. On this basis, the project team finds that the monitoring and trending program element is acceptable.

7.1.29.1.6 Acceptance Criteria The applicant states in CNP AMP B.1.38 for the "acceptance criteria" program element that walkdown reports document safety or operability concerns and provide an overall assessment of the system condition, based on observations. Specific needs for improvement and follow-up actions are summarized. Condition reports are generated, as required.

The applicant states that for license renewal this program element will be enhanced to ensure adequate detection of aging effects.

The criteria for this program element in Appendix A.1 of the SRP-LR are The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the structure and component intended function(s) are maintained under all CLB design conditions during the period of extended operation.

The program should include a methodology for analyzing the results against applicable acceptance criteria.

Qualitative inspections should be performed to same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site-specific programs.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The project team finds that any deficiencies will be found unacceptable and corrective measures implemented. On this basis, the project team finds that the acceptance criteria program element is acceptable.

7.1.29.1.7 Corrective Actions This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.29.1.8 Confirmation Process This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

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D.C. Cook Audit & Review Report 7.1.29.1.9 Administrative Controls This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.29.1.10 Operating Experience The applicant states in CNP AMP B.1.38 for the "operating experience" program element that condition reports document indications of component aging identified during system walkdowns.

Conditions such as boric acid leakage at a valve flange, corrosion on anchor bolts, and tank surface pitting have been identified.

The applicant states, in the CNP LRA, that the condition reports show that not only have aging effects like corrosion been noted and corrected, but aging management conditions that promote these aging effects have been noted and corrected as well. Among the conditions noted during a walkdown of the control room ventilation system in 1999 was corrosion of the inside of the ductwork believed to be caused by clogged drains, which was in turn caused by inadequate surveillance activities and insufficient housekeeping. The control room ventilation system was cleaned monthly for six months until the condition of the system was such that a return to normal housekeeping was considered adequate.

This program element criterion in Appendix A.1 of the SRP-LR states that operating experience should provide objective evidence to support the conclusion that the effects of aging will be adequately managed so that the SC intended function(s) will be maintained during the period of extended operation.

The project team reviewed the applicants documentation and concludes that operating experience for the system walkdown program has been identified, and corrective actions, where needed, have been performed as a result.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.38 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.29.2 UFSAR Supplement The applicant provides its UFSAR supplement for the system walkdown program in the CNP LRA, Appendix A, Section A.2.1.41, and states that the program conducts inspections to manage loss of material, loss of mechanical closure integrity, and cracking, as applicable, for SCs within the scope of license renewal. The program uses general visual inspections of readily accessible system and component surfaces during system walkdowns. The applicant states that this program requires enhancements that will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

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D.C. Cook Audit & Review Report 7.1.29.3 Conclusion On the basis of its audit and review of the applicant's program, the project team finds, pending satisfactory resolution of RAI 3.3.2.1.11-3, that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.30 WALL THINNING MONITORING (AMP B.1.39)

In the CNP LRA, Appendix B, Section B.1.39, the applicant describes CNP AMP B.1.39, "Wall Thinning Monitoring."

The applicant states that CNP AMP B.1.39 is a new, plant-specific program. The applicant credits this program with managing the aging effects for loss of material to ensure that wall thickness is above the minimum required in order to avoid failures under normal, transient, and accident conditions, including seismic events.

The project team reviewed the documents listed in Attachment 4 of this audit and review report, in whole or in part, including Engineering Report LRP-EAMP-01, Section 3.11, Wall Thinning Monitoring Program," for the wall thinning monitoring program and interviewed the applicant's technical staff.

7.1.30.1 Review of the AMP Against the Program Elements The project team reviewed CNP AMP B.1.39 against the AMP elements found in the SRP-LR, Appendix A, Section A.1.2.3 and SRP-LR Table A.1-1. The guidance described in the CNP audit and review plan was followed.

7.1.30.1.1 Scope of Program The applicant states in CNP AMP B.1.39 that the "scope of program" program element encompasses wall thinning monitoring inspections for carbon steel piping and valves in the containment isolation system and auxiliary feedwater system to ensure piping wall thickness is above the minimum required.

This program element criterion in Appendix A.1 of the SRP-LR requires that the program scope include the specific SCs addressed with this program.

The project team confirmed that the program scope program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The proposed scope identifies the specific components for which the program manages aging. On this basis, the project team finds that the applicant's proposed program scope is acceptable.

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D.C. Cook Audit & Review Report 7.1.30.1.2 Preventive Actions The applicant states in CNP AMP B.1.39 that the preventive actions program element is not applicable because the wall thinning monitoring program is an inspection program and no actions will be taken as part of this program to prevent or mitigate degradation due to aging.

This program element criterion in Appendix A.1 of the SRP-LR is that condition monitoring programs do not rely on preventive actions, and thus, preventive actions need not be provided.

The project team confirmed that the "preventive actions" program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The project team did not identify the need for preventive actions for AMP B.1.39 because it is a condition monitoring program.

7.1.30.1.3 Parameters Monitored/Inspected The applicant states in CNP AMP B.1.39, for the "parameters monitored or inspected" program element, that non-destructive examinations will be performed on susceptible components to determine wall thickness.

This program element criteria in Appendix A.1 of the SRP-LR are The parameters to be monitored or inspected should be identified and linked to the degradation of the particular SC intended function(s).

The parameter monitored or inspected should detect the presence and extent of aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A of the SRP-LR. The parameters monitored or inspected program element is acceptable because the measurements of wall thickness are intended to detect the presence and extent of aging effects. On this basis, the project team finds that the parameters monitored or inspected program element is acceptable.

7.1.30.1.4 Detection of Aging Effects The applicant states in CNP AMP B.1.39 for the detection of aging effects' program element that The aging effect being managed by this program is loss of material. An appropriate sample size will be determined based on operating experience prior to these inspection activities. The extent and schedule of the examinations prescribed by the program will be designed to ensure that aging effects will be discovered and repaired before loss of intended function.

Inspections will be performed periodically at a frequency to be determined prior to implementation. The frequency of inspections will depend upon results of previous inspections, calculated rate of material loss, and industry and plant operating experience.

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D.C. Cook Audit & Review Report The applicant credits this program with managing the aging effects of loss of material from the internal surfaces of containment penetrations carbon steel components and loss of material on the internal surfaces of the auxiliary feedwater system carbon steel components.

The detection of aging effects program element criteria in Appendix A.1 of the SRP-LR are Provide information that links the parameters to be monitored or inspected to the aging effects being managed.

Describe when, where, and how program data are collected (i.e., all aspects of activities to collect data as part of the program).

Link the method or technique and frequency, if applicable, to plant-specific or industry-wide operating experience.

Provide the basis for the inspection population and sample size when sampling is used to inspect a group of SCs. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

The project team confirmed that this program element satisfies the criteria defined in Appendix A of the SRP-LR. The applicant states that the inspections will be performed periodically at a frequency to be determined prior to the end of the initial 40-year license term and that the frequency of inspections will depend upon the results of previous inspections, the calculated rate of material loss, and industry and plant operating experience. On this basis, the project team finds the detection of aging effects program element to be acceptable.

7.1.30.1.5 Monitoring and Trending The applicant states in CNP AMP B.1.39 for the "monitoring and trending" program element that Wall thickness will be trended and projected to the next inspection. Corrective actions will be taken if the projections indicate that the acceptance criteria may not be met at the next inspection.

The criteria for this program element in Appendix A.1 of the SRP-LR are Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions.

This program element describes how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.

The project team confirmed that this program element satisfies the criteria defined in Appendix A of the SRP-LR. Trending of the inspection results will enhance the applicant's 122

D.C. Cook Audit & Review Report ability to detect aging effects before there is a loss of intended function. On this basis, the project team finds that the monitoring and trending program element is acceptable.

7.1.30.1.6 Acceptance Criteria The applicant states in CNP AMP B.1.39 for the "acceptance criteria" program element that wall thickness measurements greater than minimum wall thickness values for the components' design code of record will be acceptable.

The criteria for this program element in Appendix A.1 of the SRP-LR are The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the SC intended function(s) are maintained under all CLB design conditions during the period of extended operation.

The program should include a methodology for analyzing the results against applicable acceptance criteria.

Qualitative inspections should be performed to same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site-specific programs.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The project team finds that any wall thickness values that are projected to fall below the minimum allowable, as determined by the applicable design code, will be found unacceptable and corrective measures implemented. The project team concludes that this acceptance criterion is adequate to demonstrate that a loss of material due to wall thinning will be managed for the period of extended operation and that correction action program will be implemented for any wall thickness values projected to fall below the minimum allowable. On this basis, the project team finds that the acceptance criteria program element is acceptable.

7.1.30.1.7 Corrective Actions This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.30.1.8 Confirmation Process This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.30.1.9 Administrative Controls This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

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D.C. Cook Audit & Review Report 7.1.30.1.10 Operating Experience The applicant states in CNP AMP B.1.39 that the wall thinning monitoring program is a new program for which there is no operating experience. Industry and plant-operating experience will be considered in the development of this program.

The "operating experience" program element criterion in Appendix A.1 of the SRP-LR states that operating experience should provide objective evidence to support the conclusion that the effects of aging will be adequately managed so that the SC intended function(s) will be maintained during the period of extended operation.

The project team observed that ultrasonic wall thickness examinations are consistent with industry standards and the applicant had indicated that if initial or periodic examinations reveal the need to expand the sample size or increase the frequency of these activities, such actions would occur. The operating experience associated with this AMP will be accrued over the period of extended operation.

During the audit, the project team asked the applicant to clarify and/or provide the operating experience reviews for new programs. In its response, the applicant stated that the plant corrective action program, which captures internal and external plant operating experience issues, provides reasonable assurance that operating experience will be reviewed and incorporated in the future to provide objective evidence to support the conclusion that the effects of aging will be adequately managed.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.39 will adequately manage the aging effects that have been observed at the applicant's plant.

7.1.30.2 UFSAR Supplement The applicant provides its UFSAR supplement for the wall thinning monitoring program in the CNP LRA, Appendix A, Section A.2.1.42, and states that it will manage loss of material of carbon steel piping and valves in the containment isolation and auxiliary feedwater systems.

Inspections will be performed to ensure wall thickness is above the minimum required in order to avoid failures. The applicant states in Appendix A that the wall thinning monitoring program will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.30.3 Conclusion Since this is a new program, final determination of its acceptability will not be made until the details of the final AMP have been submitted to the NRC staff and reviewed, which shall occur prior to the period of extended operation. The commitment to submit the program for review is documented in Attachment 5 of this report for inclusion in the SER related to the CNP LRA. On the basis of its audit and review of the applicant's program, the project team finds that the 124

D.C. Cook Audit & Review Report applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.31 WATER CHEMISTRY CONTROL - PRIMARY AND SECONDARY WATER CHEMISTRY (AMP B.1.40.1)

In the CNP LRA, Appendix B, Section B.1.40.1, the applicant states that the CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry," is consistent with GALL AMP XI.M2, "Water Chemistry," with enhancements.

7.1.31.1 Program Description The applicant states, in the CNP LRA, that the purpose of this program is to mitigate damage caused by corrosion and stress corrosion cracking. The program relies on monitoring and control of water chemistry based on EPRI guidelines.

7.1.31.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.40.1 is consistent with GALL AMP XI.M2, with enhancements.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.1.40.1, including Engineering Report LRP-EAMP-01, Section 4.23.1, "Primary and Secondary Water Chemistry Control Program," which provides an assessment of how the GALL AMP elements are addressed by the CNP LRA primary and secondary water chemistry control program.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documentation against GALL AMP XI.M2 for consistency.

7.1.31.3 Exceptions to the GALL Report None.

7.1.31.4 Enhancements The applicant states, in the CNP LRA, that the enhancements in meeting the GALL Report elements as follows Element: 3: Parameters Monitored/Inspected Enhancement: Revise program controlling procedures to require individual implementing procedures to identify and 125

D.C. Cook Audit & Review Report prescribe any special collection and preservation needs of a sample.

Element: 6: Acceptance Criteria Enhancement: Include sulfate monitoring criteria for the refueling water storage tank that are consistent with the EPRI guidelines and the sulfate criteria for other systems impacted by refueling water storage tank chemistry (e.g., reactor coolant system and spent fuel pool).

Elements: 3: Parameters Monitored/Inspected 6: Acceptance Criteria Enhancement: Bring the parameters monitored/inspected and acceptance criteria into clear alignment with the EPRI water chemistry guidelines.

The GALL Report identifies the following criteria for the parameters monitored or inspected program element associated with the enhancements:

The chemistry integrity of the samples is maintained and verified to ensure that the method of sampling and storage will not cause a change in the concentration of the chemical species in the samples.

(1) EPRI TR-105714, PWR Primary Water Chemistry Guidelines, recommends that the concentration of chlorides, fluorides, sulfates, lithium, and dissolved oxygen and hydrogen are monitored and kept below the recommended levels to mitigate stress corrosion cracking (SCC) of austenitic stainless steel, alloy 600, and alloy 690 components.

(2) EPRI TR-102134, PWR Secondary Water Chemistry Guidelines, recommends monitoring and control of chemistry parameters (e.g., pH level, cation conductivity, sodium, chloride, sulfate, lead, dissolved oxygen, iron, copper, and hydrazine) to mitigate steam generator tube degradation caused by denting, intergranular attack, outer diameter SCC, or crevice and pitting corrosion.

Monitoring and control of these parameters also mitigates general (carbon steel components), crevice, and pitting corrosion of the steam generator shell and the balance-of-plant materials of construction (e.g., carbon steel, stainless steel, and copper).

The GALL Report identifies the following criterion for the acceptance criteria program element associated with the enhancements:

Maximum levels for various contaminants are maintained below the system-specific limits as indicated by the limits specified in the corresponding EPRI water chemistry guidelines.

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D.C. Cook Audit & Review Report The project team finds that the enhancements to this AMP, all of which are intended to ensure that the program complies with the applicable EPRI water chemistry guidelines and thus ensure consistency with the GALL AMP, will improve the ability of the systems to perform their intended functions consistent with the CLB during the extended operating term. On this basis, the project team finds the enhancements to be acceptable.

7.1.31.5 Operating Experience The applicant states, in the CNP LRA, that the program is based on the EPRI water chemistry guidelines, which reflect chemistry practices based on operating experience in the nuclear power industry. The guidelines are updated as appropriate based on continuing operating experience.

The applicant states, in the CNP LRA, that it performed an primary chemistry self-assessment in 2002 that focused on critical program attributes. Selected attributes established in EPRI PWR primary water guidelines were evaluated. The assessment team included an industry peer and obtained benchmarking information from two other plants. The assessment team concluded that the essential program attributes assessed are adequately described and effectively implemented.

The applicant states, in the CNP LRA, that it performed a self-assessment of the secondary chemistry program in 2002, including peer review with staff from another station, to identify program deficiencies and to establish corrective actions. Industry operating experience was examined by the assessment team in order to improve startup contaminant control. The team concluded that the essential program attributes assessed are adequately described and effectively implemented.

The project team review the applicants documentation and concludes that operating experience for the water chemistry control - primary and secondary water chemistry program has been identified, and corrective actions, where needed, have been performed as a result.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.40.1 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.31.6 UFSAR Supplement The applicant provides its UFSAR supplement for the water chemistry control - primary and secondary water chemistry control program in the CNP LRA, Appendix A, Section A.2.1.43, which states that the program mitigates damage caused by corrosion and SCC. The program relies on monitoring and control of water chemistry based on EPRI guidelines. This program requires enhancements that will be implemented prior to the period of extended operation.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

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D.C. Cook Audit & Review Report 7.1.31.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the enhancements to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.32 WATER CHEMISTRY CONTROL - CLOSED COOLING WATER CHEMISTRY CONTROL (AMP B.1.40.2)

In the CNP LRA, Appendix B, Section B.1.40.2, the applicant states that the CNP AMP B.1.40.2, "Water Chemistry Control - Closed Cooling Water Chemistry Control," is consistent with GALL AMP XI.M21, "Closed-Cycle Cooling Water System," with exceptions.

7.1.32.1 Program Description The applicant states, in the CNP LRA, that this program includes preventive measures that manage loss of material (including that due to selective leaching, where applicable), cracking, and fouling, as applicable, for closed cooling water system components. These chemistry activities provide for monitoring and controlling closed cooling water chemistry using procedures and processes that are based on EPRI TR-107396, "Closed Cooling Water Chemistry Guidelines."

7.1.32.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.1.40.2 is consistent with GALL AMP XI.M21, with exceptions.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for CNP AMP B.1.40.2, including Engineering Report LRP-EAMP-01, Section 4.23.2, "Closed Cooling Water Chemistry Control Program," which provides an assessment of how the GALL AMP elements are addressed by the CNP LRA closed cooling water chemistry control program.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documentation against GALL AMP XI.M21 for consistency.

7.1.32.3 Exceptions to the GALL Report The applicant states, in the CNP LRA, that exceptions to the GALL Report elements as follows 128

D.C. Cook Audit & Review Report Elements: 3: Parameters Monitored/Inspected 5: Monitoring and Trending 6: Acceptance Criteria Exception: The program only monitors chemistry parameters.

Element: 4: Detection of Aging Effects Exception: The program is a preventive program that claims no credit for the detection of aging effects through performance and functional testing.

Element: 6: Acceptance Criteria Exception: The nitrite corrosion inhibitor concentrations are maintained within specified limits, which allow for larger variance (1200 ppm - 4000 ppm) than recommended (500 ppm - 1000 ppm) in EPRI TR-107396.

The GALL Report identifies the following criteria for program elements: (1) parameters monitored/inspected, (2) monitoring and trending, and (3) acceptance criteria for the first exception taken:

The AMP monitors the effects of corrosion by surveillance testing and inspection in accordance with standards in EPRI TR-107396 to evaluate system and component performance. For pumps, the parameters monitored include flow and discharge and suction pressures. For heat exchangers, the parameters monitored include flow, inlet and outlet temperatures, and differential pressure.

Performance and functional tests are performed at least every 18 months to demonstrate system operability, and tests to evaluate heat removal capability of the system and degradation of system components are performed every five years.

System and component performance test results are evaluated in accordance with the guidelines of EPRI TR-107396. Acceptance criteria and tolerances are also based on system design parameters and functions.

During the audit, the project team asked the applicant to justify the acceptability of the exception to these program elements (parameters monitored/inspected, monitoring and trending, and acceptance criteria) in GALL XI.M21 that monitoring only the chemistry parameters is sufficient to protect system components from degradation without monitoring parameters of pumps and heat exchangers in the system.

In its response, the applicant states that EPRI TR-107386 does not provide specific recommendations for equipment performance and functional testing at a given frequency for monitoring the effectiveness of a water chemistry control program. Monitoring pump performance parameters is of little value in managing the effects of aging on long-lived, passive closed cooling water system components. EPRI TR-107396, Section 5.7, states that performance monitoring is typically part of an engineering program, which would not be part of water chemistry. EPRI TR-107386 further states that performance monitoring, "...can be used to confirm that conditions in the closed cooling water system are not degrading heat exchanger performance..."

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D.C. Cook Audit & Review Report The project team finds that this EPRI guidance neither requires nor negates performance monitoring. The project team reviewed industry guidelines, the applicants operating experience, and inspection procedures of plant systems and heat exchangers, and determined that there is reasonable assurance that monitoring chemistry parameters in conjunction with plant inspections will adequately manage aging effects on the closed cycle cooling water systems. On this basis, the project team finds this exception to be acceptable.

The GALL Report identifies the following criterion for the detection of aging effects program element associated with the second exception taken:

The extent and schedule of inspections and testing, in accordance with EPRI TR-107396, assure detection of corrosion before the loss of intended function of the component. Performance and functional testing, in accordance with EPRI TR-107396, ensures acceptable functioning of the closed cooling water system or components serviced by the closed cooling water system.

During the audit, the project team asked the applicant to justify the acceptability of the exception to the detection of aging effects program element in GALL XI.M21 as to why performance and functional testing is not required to effectively manage aging effects.

In its response, the applicant states that, in most cases, functional and performance testing verifies that component active functions are maintained and therefore would be managed by the Maintenance Rule (10CFR50.65). The applicant further responded that testing of closed cycle cooling water system heat exchangers was not required by GL 89-13 because of the effectiveness of the closed cooling water system chemistry program. The passive intended functions of pumps, heat exchangers and other components of the closed cycle cooling water system will be adequately managed by the closed cooling water chemistry program.

The project team reviewed the applicant's response and operating experience and finds that aging effects on passive mechanical components in the closed cooling water system are adequately managed without reliance on performance and functional testing. On this basis, the project team finds the second exception to the detection of aging effects program element to be acceptable.

The GALL Report identifies the following criterion for the "acceptance criteria" program element associated with the third exception taken:

Corrosion inhibitor concentrations are maintained within the limits specified in the EPRI water chemistry guidelines for closed cooling water systems.

During the audit, the project team asked the applicant to provide the technical basis for using different limits than EPRI TR-107396 on nitrite corrosion inhibitor concentrations and to justify that its concentration limits will not increase the probability of corrosion in system components.

In its response, the applicant states that EPRI TR-107396, Section 4.3.2, notes that "based on industry experience, lower ranges (200 to 500 ppm) have been successfully used in systems with demineralized water makeup. Higher levels (up to 4000 ppm) can be used, but increase the potential for microbiological growth." The applicant further states that procedural targets for 130

D.C. Cook Audit & Review Report nitrites are within these EPRI guidelines, and that CNP AMP B.1.41, "One Time Inspection," will confirm the effectiveness of the closed cooling water chemistry control program prior to the period of extended operation. Additionally, the applicant has converted water chemistry control for component cooling water systems to molybdate corrosion inhibitor control, and the limits for molybdate match the recommended limits in EPRI TR-107396. The applicant has stated that nitrate control remains a procedural option until sufficient operating experience with molybdate control is evaluated.

The project team reviewed the applicant's response and operating experience, industry guidelines and determined, pending acceptance of CNP AMP B.1.41, One Time Inspection, that there is reasonable assurance that monitoring these nitrite corrosion inhibitor concentrations within specified limits will adequately manage aging effects on closed cooling water systems. The evaluation of the water chemistry control - one time inspection program is in Section 3.0.3.3.17 of the SER related to the CNP LRA. On this basis, the project team finds the third exception to the acceptance criteria program element to be acceptable.

7.1.32.4 Enhancements None 7.1.32.5 Operating Experience The applicant states, in the CNP LRA, that its operating experience for this AMP reflects chemistry practices based on extensive operating experience in the nuclear industry. The guidelines are updated, as appropriate, based on continuing operating experience. An independent assessment, performed by the applicant in 1999, of the component cooling water system chemistry included a detailed review of the program chemical selection, control, monitoring, and record keeping; and provided an examination of the fidelity of the processes with industry guidance documents.

The applicant further states that the independent review provided evaluations of plant-specific operating experience and recommendations based on that experience. Documentation of the chemical treatment processes was found to be exemplary, while the overall program was found to be comparable to industry best practice.

The project team reviewed operating experience of representative condition reports relevant to the closed cooling water chemistry control program finds that the program monitors and corrects out-of-specification readings before they contribute to the aging of components.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that CNP AMP B.1.40.2 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.32.6 UFSAR Supplement The applicant provides its UFSAR supplement for the water chemistry control - closed cooling water chemistry control program in the CNP LRA, Appendix A, Section A.2.1.44, which states that the closed cooling water chemistry control program includes preventive measures that 131

D.C. Cook Audit & Review Report manage loss of material, cracking, and fouling, as applicable, for the component cooling water system and components cooled by the component cooling water system that are in the scope of license renewal. These chemistry activities provide for monitoring and controlling closed cooling water chemistry using procedures and processes based on EPRI guidelines.

In the SRP-LR, Table 3.3-2, page 3.3-17, with respect to the closed-cycle cooling water system, it is stated that "...The program relies on preventive measures to minimize corrosion by maintaining inhibitors and by performing non-chemistry monitoring consisting of inspection and nondestructive evaluations based on the guidelines of EPRI-TR-107396 for closed-cycle cooling water systems.." In CNP LRA Section A.2.1.44, the applicant did not refer to inspection and nondestructive evaluations.

During the second audit, the project team asked the applicant to justify the acceptability of the inconsistency between LRA Section A.2.1.44 and the SRP-LR, Table 3.3-2, or revise CNP LRA Section A.2.1.44 to be consistent with the SRP-LR, Table 3.3-2.

In its response, the applicant stated that the chemistry one-time inspection program, described in CNP LRA Section A.2.1.46, commits to inspections and nondestructive evaluations to verify the effectiveness of the closed cooling water chemistry control program.

On the basis of the applicant's response and the project team's review of the UFSAR supplement, the project team finds that the UFSAR supplement provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.32.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the exceptions to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.33 WATER CHEMISTRY CONTROL - AUXILIARY SYSTEMS WATER CHEMISTRY CONTROL PROGRAM (AMP B.1.40.3)

In the CNP LRA, Appendix B, Section B.1.40.3, the applicant describes CNP AMP B.1.40.3, "Water Chemistry Control - Auxiliary Systems Water Chemistry Control."

The applicant states that CNP AMP B.1.40.3 is a plant-specific program. The applicant credits this program with managing loss of material, cracking, and fouling of components exposed to treated water environments.

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D.C. Cook Audit & Review Report The project team reviewed the documents listed in Attachment 4 of this audit and review report, in whole or in part, including Engineering Report LRP-EAMP-01, Section 4.23.3, Water Chemistry Control - Auxiliary Systems Water Chemistry Control Program," for the auxiliary systems water chemistry control program and interviewed the applicant's technical staff.

7.1.33.1 Review of the AMP Against the Program Elements The project team reviewed CNP AMP B.1.40.3 against the AMP elements found in the SRP-LR, Appendix A, Section A.1.2.3 and SRP-LR Table A.1-1. The guidance described in the CNP audit and review plan was followed.

7.1.33.1.1 Scope of Program The applicant states in CNP AMP B.1.40.3 that the "scope of program" program element encompasses sampling activities and analyses on the demineralized water supply penetrations and non-safety-related components affecting safety-related systems; control room ventilation liquid chiller components; glycol/ice condenser penetrations; glycol/ice condenser non-safety-related components affecting safety-related systems; primary water supply to pressurizer relief tank penetrations; primary water system non-safety-related components affecting safety-related systems; emergency diesel generator jacket cooling water; and security diesel jacket cooling water.

This program element criterion in Appendix A.1 of the SRP-LR requires that the program scope include the specific SCs addressed with this program.

The project team confirmed that the program scope program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. The proposed scope identifies the specific components for which the program manages aging. On this basis, the project team finds that the applicant's proposed program scope is acceptable.

7.1.33.1.2 Preventive Actions The applicant states in CNP AMP B.1.40.3 for the "preventive actions" program element that this program monitors and controls relevant conditions such as dissolved oxygen, conductivity, and corrosion inhibitor concentrations to manage loss of material and fouling, as applicable.

These corrosive contaminants are either removed, their concentrations minimized, or treatments are provided to limit their corrosive effects.

This program element criterion in Appendix A.1 of the SRP-LR is that the activities for prevention and mitigation programs should be described.

During the audit, the applicant provided clarification on the parameters to be monitored and how these would prevent or mitigate the aging effects. The principles for chemical treatment and a typical (chemistry) monitoring program presented in EPRI TR-107396 are used in system chemistry monitoring, where applicable. Dissolved oxygen is included as a diagnostic parameter because it can increase corrosion. In the demineralized water application, it is included as a control treatment parameter. Conductivity is included as a diagnostic parameter because it is an indirect measurement of the concentration of chemical treatment (used to 133

D.C. Cook Audit & Review Report minimize corrosion or fouling). Corrosion inhibitor is monitored for direct measurement of the treatment control concentration being used for corrosion control. pH is included as a treatment control parameter because it has a direct impact on corrosion rate and might be an indicator of microbiological activity in the system. Iron and copper are included as diagnostic parameters because accumulation of corrosion products is an indirect indication of corrosion. Hardness is monitored to provide indication of formation of mineral scales. Nitrate is monitored and included as a diagnostic for indication of increase in microbiologic activity. Glycol weight percentage concentration is monitored to ensure that the range specified in Section 5.3.5.12.3 of the UFSAR is maintained.

The project team confirmed that the preventive actions program element satisfies the criterion defined in Appendix A.1 of the SRP-LR. On the basis of its audit of the implementation procedures and review of the program basis documents, the project team finds that preventive actions program element is acceptable because it identifies and describes the activities from managing aging effects.

7.1.33.1.3 Parameters Monitored/Inspected The applicant states in CNP AMP B.1.40.3, for the "parameters monitored or inspected" program element, that the program monitors specific parameters such as dissolved oxygen, conductivity, and corrosion inhibitor concentrations. Other typical parameters that are monitored include pH, iron, copper, hardness, and nitrite. The specific parameters monitored vary depending on the system.

This program element criteria in Appendix A of the SRP-LR are The parameters to be monitored or inspected should be identified and linked to the degradation of the particular SC intended function(s).

The parameters monitored should be the specific parameters being controlled to achieve prevention or mitigation of aging effects.

During the audit, the applicant stated that the basis for parameters monitored and established chemistry limits in the auxiliary cooling systems is based on a strategic plan that was developed based on systems materials of construction and currently approved chemical treatment chemicals. Corrosion inhibitor concentrations are monitored to ensure adequate protection of the system materials from corrosion. Other parameters are monitored to understand the rates of corrosion and stability of the system. In the case of primary makeup systems, parameters and limits are based on practices developed by the EPRI for primary water chemistry.

The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The component inspections and water chemistry monitoring activities are intended to detect the presence and extent of aging effects. On this basis, the project team finds that the parameters monitored or inspected program element is acceptable.

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D.C. Cook Audit & Review Report 7.1.33.1.4 Detection of Aging Effects The applicant states in CNP AMP 1.40.3 for the "detection of aging effects" program element that the AMP is a mitigation program and does not provide for detection of aging effects, such as loss of material and cracking. This program is credited with managing the following aging effects: loss of material for the demineralized water, glycol/ice condenser, and primary water containment penetrations; loss of material (including that due to selective leaching) and fouling in the emergency diesel generator cooling water system; loss of material (including that due to selective leaching) and fouling from the internal wetted surfaces of the control room ventilation liquid chiller components; loss of material (including that due to selective leaching) for the security diesel engine cooling water; loss of material (including that due to selective leaching) for the demineralized water, ice condenser, and primary water non-safety-related components affecting safety-related systems.

The detection of aging effects program element criteria in Appendix A.1 of the SRP-LR are Provide information that links the parameters to be monitored or inspected to the aging effects being managed.

This program element describes when, where, and how program data are collected (i.e., all aspects of activities to collect data as part of the program).

The method or technique and frequency may be linked to plant-specific or industry-wide operating experience.

When sampling is used to inspect a group of SCs, provide the basis for the inspection population and sample size. The inspection population should be based on such aspects of the SCs as a similarity of materials of construction, fabrication, procurement, design, installation, operating environment, or aging effects.

The project team agrees that this is a mitigation program and as such does not detect aging effects, such as loss of material and cracking. Therefore, the project team concluded that this element program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. On this basis, the project team finds that the detection of aging effects program element is acceptable.

7.1.33.1.5 Monitoring and Trending The applicant states in CNP AMP B.1.40.3 for the "monitoring and trending" program element that the program is implemented through various plant procedures. The applicable procedure identifies the sampling schedule, the critical parameters, and the location of the sample points.

Parameters are monitored and corrective actions are taken if the parameters are outside the acceptable range.

The criteria for this program element in Appendix A.1 of the SRP-LR are 135

D.C. Cook Audit & Review Report Monitoring and trending activities should be described, and they should provide predictability of the extent of degradation and thus effect timely corrective or mitigative actions.

This program element describes how the data collected are evaluated and may also include trending for a forward look. The parameter or indicator trended should be described.

The project team reviewed several implementing procedures and concluded that the sampling schedule, critical parameters, and location of the sample points are defined. The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. Trending of the inspection results will enhance the applicant's ability to detect aging effects before there is a loss of intended function. On this basis, the project team finds that the monitoring and trending program element is acceptable.

7.1.33.1.6 Acceptance Criteria The applicant states in CNP AMP B.1.40.3 for the "acceptance criteria" program element that the acceptance criteria for this program are in site procedures and are established based on the sampled parameter, the sample location, and the plant operating conditions. These criteria have been established based on equipment specification requirements, EPRI guidelines, or CNP specific experience.

The criteria for this program element in Appendix A.1 of the SRP-LR are The acceptance criteria of the program and its basis should be described. The acceptance criteria, against which the need for corrective actions will be evaluated, should ensure that the SC intended function(s) are maintained under all CLB design conditions during the period of extended operation.

The program should include a methodology for analyzing the results against applicable acceptance criteria.

Qualitative inspections should be performed to same predetermined criteria as quantitative inspections by personnel in accordance with ASME Code and through approved site-specific programs.

The project team reviewed several plant procedures and validated that the program includes a methodology for analyzing the results against specific acceptance numerical criteria. The project team confirmed that this program element satisfies the criteria defined in Appendix A.1 of the SRP-LR. The project team finds that any inspection results that indicate component degradation or any chemistry parameters that fall outside those contained in applicable industry and manufacturers' guidelines will be found unacceptable and corrective measures implemented. On this basis, the project team finds that the acceptance criteria program element is acceptable.

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D.C. Cook Audit & Review Report 7.1.33.1.7 Corrective Actions This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.33.1.8 Confirmation Process This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.33.1.9 Administrative Controls This program element is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.1.33.1.10 Operating Experience The applicant states in CNP AMP B.1.40.3 for the "operating experience" program element that a review of representative condition reports relevant to the program found that the program identifies out-of-specification values and corrects them before they lead to equipment degradation. Examples of conditions that were identified and corrected include excessive sodium in the borated water inventories, nitrites below the minimum limit for the diesel jacket cooling water, and low pH in the alternate heating boiler.

This program element criterion in Appendix A.1 of the SRP-LR states that operating experience should provide objective evidence to support the conclusion that the effects of aging will be adequately managed so that the SC intended function(s) will be maintained during the period of extended operation.

The project team interviewed applicant personnel concerning the operating experience of this existing program to validate the AMP statements. The plant records confirmed that the program has been effective in identifying water chemistry parameters and the corrective actions have been taken. Based on its review, the project team concluded that the operating experience of this program demonstrates that it is an effective tool for mitigating the aging effects of loss of material and cracking.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.1.40.3 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.33.2 UFSAR Supplement The applicant provides its UFSAR supplement for the water chemistry control - auxiliary systems water chemistry control program in the CNP LRA, Appendix A, Section A.2.1.45, and states the program manages loss of material and fouling, as applicable, of components in the scope of license renewal that are exposed to treated water environments. The program implements sampling activities and analyses to monitor and control relevant chemistry conditions of these environments.

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D.C. Cook Audit & Review Report The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.33.3 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.34 ENVIRONMENTAL QUALIFICATION OF ELECTRICAL COMPONENTS (AMP B.2.1)

In the CNP LRA, Appendix B, Section B.2.1, the applicant states that AMP B.2.1, "Environmental Qualification (EQ) of Electrical Components," is consistent with GALL AMP X.E1, "Environmental Qualification (EQ) of Electric Components."

7.1.34.1 Program Description The applicant states, in the CNP LRA, that NRC established nuclear station EQ requirements in 10 CFR 50.49. The requirements are that each licensed facility establish an EQ program to demonstrate that electrical components located in harsh plant environments are qualified to perform their safety function in those harsh environments while withstanding the effects of inservice aging. The effects of significant aging mechanisms must be addressed as part of EQ.

The applicant states, in the CNP LRA, that the EQ program manages component thermal, radiation, and cyclical aging effects through the use of aging evaluations based on 10 CFR 50.49(f) qualification methods. As required by 10 CFR 50.49, EQ components not qualified for the current license term are to be refurbished, replaced, or have their qualification extended prior to reaching the aging limits established in the evaluation. Aging evaluations for EQ components are considered time-limited aging analyses (TLAA) for license renewal. This TLAA is addressed in CNP LRA, Section 4.4 (Generic Safety Issue 168) and is reviewed by the NRR DE staff and addressed in Section 4 of the SER related to the CNP LRA.

7.1.34.2 Consistency with the GALL Report In the CNP LRA, the applicant states that CNP AMP B.2.1 is consistent with GALL AMP X.E1.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report, including Engineering Report LRP-EAMP-01, Section 4.8, "Environmental Qualification (EQ) of Electrical Components Program," for the environmental qualification (EQ) of electrical components program and interviewed the applicant's technical staff.

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D.C. Cook Audit & Review Report The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documents against GALL AMP X.E1 for consistency.

7.1.34.3 Exceptions to the GALL Report None 7.1.34.4 Enhancements None 7.1.34.5 Operating Experience The applicant states, in the CNP LRA, that this program has been effective at managing aging effects and has identified no aging effects that the AMP is intended to prevent. The applicant states that the program is continuing to be improved as a result of ongoing program assessments. In accordance with the GALL Report, the EQ program operating experience is used to modify qualification bases and conclusions, including qualified life.

The project team review the applicants documentation and concludes that operating experience for the environmental qualification (EQ) of electrical components program has been identified, and corrective actions, where needed, have been performed as a result.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that AMP B.2.1 adequately manages the aging effects that have been observed at the applicant's plant.

7.1.34.6 UFSAR Supplement The applicant provides its UFSAR supplement for the EQ of electrical components program in the CNP LRA, Appendix A, Section A.2.2.3. The applicant states in Appendix A that the EQ program manages component thermal, radiation, and cyclical aging, as applicable, through the use of aging evaluations based on the applicable qualification methods:

(1) 10 CFR 50.49(f),

(2) NUREG-0588, "Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," or (3) Enclosure 4 to IE Bulletin 79-01B, "Guidelines for Evaluating Environmental Qualification of Class 1 Electrical Equipment in Operating Reactors."

The applicant states that aging evaluations for EQ components that specify a qualification of at least 40 years are considered TLAAs for license renewal. The EQ of electrical components program ensures that these EQ components will be maintained within the bounds of their qualification bases. The effects of aging will thus be managed in accordance with 10 CFR 54.21(c)(1)(iii).

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D.C. Cook Audit & Review Report The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.34.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistencies with the GALL Report are consistent with the GALL Report. Since the GALL Report is acceptable to the staff, the project team concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.1.35 FATIGUE MONITORING (AMP B.2.2)

In the CNP LRA, Appendix B, Section B.2.2, the applicant states that the CNP AMP B.2.2, "Fatigue Monitoring," will be consistent with GALL AMP X.M1, "Metal Fatigue of Reactor Coolant Pressure Boundary," with an exception.

7.1.35.1 Program Description The applicant states, in the CNP LRA, that In order to remain within fatigue usage design limits, the fatigue monitoring program monitors and tracks the number of critical thermal and pressure transients for selected RCS components. The program ensures the validity of analyses that explicitly assume a specified number of thermal and pressure fatigue transients. Components managed by this program are those shown to be acceptable by analyses explicitly based on a limiting number of thermal or pressure fatigue transient cycles.

In addition, the applicant states, in the CNP LRA, that the fatigue monitoring program for aging management is a continuation of an existing program. The projections from the plant operating experience to 60 years of operation show that the fatigue transients will be within bounds for the extended license of the plant. The applicant also states that continued implementation of the fatigue monitoring program will assure that the applicable components and structures will be monitored for fatigue damage and will perform their intended functions within the design basis in the extended period of operation.

7.1.35.2 Consistency with the GALL Report In the CNP LRA the applicant states that CNP AMP B.2.2 will be consistent with GALL AMP X.M1, with an exception.

The project team interviewed the applicant's technical staff and reviewed, in whole or in part, the documents listed in Attachment 4 of this audit and review report for AMP B.2.2, including Engineering Report LRP-EAMP-01, Section 4.9, "Fatigue Monitoring Program," which provides 140

D.C. Cook Audit & Review Report an assessment of how the GALL AMP elements are addressed by the fatigue monitoring program.

The project team reviewed seven program elements (see Section 5.1 of this audit and review report) contained in the CNP AMP and associated bases documentation against GALL AMP X.M1 for consistency.

7.1.35.3 Exceptions to the GALL Report The applicant states, in the CNP LRA, that an exception to the GALL Report elements as follows Element: 4: Detection of Aging Effects Exception: The program does not provide for periodic update of fatigue usage calculations. Corrective actions are initiated only when the number of accumulated cycles approaches 80% of the number of component design cycles.

The GALL Report identifies the following criterion for the detection of aging effects program element associated with the exception taken:

The program provides for periodic update of the fatigue usage calculations.

The applicant states, in the CNP LRA, that updates of fatigue usage calculations, as recommended in the GALL Report, are not necessary unless the number of accumulated fatigue cycles approaches the number of assumed design cycles, and commits to implement corrective actions at that time. This is an alternative method for ensuring that the design code limit is not exceeded and for that reason the project team finds it to be acceptable.

7.1.35.4 Enhancements None 7.1.35.5 Operating Experience The applicant states, in the CNP LRA, that it performed a self-assessment of the fatigue monitoring program in 1999. This self-assessment identified deficiencies and provided recommendations that were addressed with condition reports. These condition reports led to enhancements of the implementing procedure, even though the procedure met the intent of the program requirements. The applicant also states that it performed, in 2002, a follow-up self-assessment to review the program improvements. This follow-up self-assessment concluded the program will adequately and accurately track design basis plant transients. This assessment also identified deficiencies and provided recommendations that were addressed by corrective actions, which demonstrates that the program continues to be monitored and improved.

In addition, the applicant states, in the CNP LRA, that thermal fatigue transients have been tracked since the initial hydrostatic tests and commercial operation of both CNP units. The 141

D.C. Cook Audit & Review Report applicant states that it performed a review of the number of design transients documented to date. Based on the rate of occurrence, the numbers of the various transients were projected to 60 years of operation. It was demonstrated that the numbers of design transients projected for the period of extended operation associated with license renewal are less than the numbers of transients considered in the applicants fatigue analyses.

The project team review the applicants documentation and concludes that operating experience for the fatigue monitoring program has been identified, and corrective actions, where needed, have been performed as a result.

On the basis of its review of the above operating experience and on discussions with the applicant's technical staff, the project team concludes that CNP AMP B.2.2 is sufficient to support the management of the aging effects of fatigue that has been monitored and predicted at the applicant's plant.

7.1.35.6 UFSAR Supplement The applicant provides its UFSAR supplement for the fatigue monitoring program in the CNP LRA, Appendix A, Section A.2.1.12, which states that the fatigue monitoring program monitors and tracks the number of critical thermal and pressure transients for selected RCS components in order not to exceed the design limit on fatigue usage. The program ensures the validity of analyses containing explicit cycle count assumptions. The components managed by this program are those shown to be acceptable by analyses that explicitly address thermal and pressure fatigue transient limits.

The project team reviewed the UFSAR supplement and confirms that it provides an adequate summary description of the program, as identified in the SRP-LR UFSAR supplement table and as required by 10 CFR 54.21(d).

7.1.35.7 Conclusion On the basis of its audit and review of the applicant's program, the project team finds that those portions of the program for which the applicant claims consistency with the GALL Report are consistent with the GALL Report. In addition, on the basis of its review of the exception to the GALL Report, the project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its review of the UFSAR supplement for this AMP, the project team also finds that it provides an adequate summary description of the program, as required by 10 CFR 54.21(d).

7.2 Aging Management Reviews The project team's audit and review activities for the CNP AMRs and its conclusions regarding these reviews are documented below.

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D.C. Cook Audit & Review Report For its AMR reviews, the project team determined that the AMRs reported by the applicant to be consistent with the GALL Report are consistent with the GALL Report and concluded that the plant-specific AMRs reported to be justified on the basis of an NRC-approved precedent are technically acceptable and applicable. For component groups evaluated in the GALL Report for which the applicant claimed consistency with the GALL Report, and for which the GALL Report recommends further evaluation, the project team reviewed the applicant's evaluation to determine whether or not it adequately addressed the issues for which the GALL Report recommends further evaluation.

The AMRs reviewed by the project team in LRA Tables 3.X.2-Y in Chapter 3 of the LRA were either consistent with the GALL Report, or justified by the applicant on the basis of a previously approved position of the NRC staff. In LRA Tables 3.X.2-Y, in addition to the notes, the applicant provided a summary of AMRs for the applicable systems which included SCs, associated materials, environment, aging effect requiring management, and an AMP for each line item. The notes describe the alignment of information in the tables with the aging management approach described in the GALL Report. Those alignments that are defined in the GALL Report are assigned letters and the meaning of those letters is described below.

Those defined by the applicant are assigned numbers and defined in the LRA.

Note A indicates that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP is consistent with the AMP identified in the GALL Report.

Note B indicates that the AMR line item is consistent with the GALL Report for component, material, environment, and aging effect. In addition, the AMP takes some exceptions to the AMP identified in the GALL Report. The project team concluded that the identified exceptions to the GALL AMPs are acceptable.

Note C indicates that the component for the AMR line item is different, but consistent with the GALL Report for material, environment, and aging effect.

This note indicates that the applicant was unable to find a listing of some system components in the GALL Report. However, the applicant identified a different component in the GALL Report that had the same material, environment, aging effect, and AMP as the component that was under review. The project team concluded that the AMR line item of the different component was applicable to the component under review.

Note D indicates that the component for the AMR line item is different, but consistent with the GALL Report for material, environment, and aging effect. In addition, the AMP takes some exceptions to the AMP identified in the GALL Report. The project team reviewed these line items to verify consistency with the GALL Report. The project team concluded that the AMR line item of the different component was applicable to the component under review. The project team concluded that the identified exceptions to the GALL AMPs are acceptable.

Note E indicates that the AMR line item is consistent with the GALL Report for material, environment, and aging effect, but a different AMP is credited. The 143

D.C. Cook Audit & Review Report project team reviewed these line items to verify consistency with the GALL Report.

Note F indicates that the material is not in the GALL Report for the identified component.

Note G indicates that the environment is not in the GALL Report for the identified component and material.

Note H indicates that the aging effect is not in the GALL Report for component, material, and environment combination.

Note I indicates that the aging effect in the GALL Report for the identified component, material, and environment combination is not applicable.

Note J indicates that neither the identified component nor the material and environment combination is evaluated in the GALL Report.

Discrepancies or issues discovered by the project team during the audit and review that required a response are documented in this audit and review report. If resolution of an issue was not docketed prior to issuing this audit and review report, a request for additional information (RAI) was prepared by the project team to solicit the information needed to disposition the issue. The RAI will be included and dispositioned in the SER related to the CNP LRA. The list of RAIs associated with the audit and review is provided in Attachment 3 to this audit and review report.

The project team conducted an audit and review of the information provided in the LRA as well as program bases documents that were made available at the applicant's engineering office.

On the basis of its audit and review, the project team found that the applicable aging effects were identified, the appropriate combination of materials and environments were listed, and acceptable AMPs were specified for their management.

On the basis of its audit and review, the project team concludes that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

The reviews of LRA Sections 3.1 through 3.6 that were performed by the project team are documented below.

7.2.1 CNP LRA Section 3.1 - Aging Management of Reactor Vessel, Internals, and Reactor Coolant System In CNP LRA Section 3.1, the applicant provides the results of its AMRs for the reactor vessel, internals, and RCS components.

In CNP LRA Tables 3.1.2-1 through 3.1.2-5 (Table 2s), the applicant provides a summary of the AMRs for component types associated with the (1) reactor vessel and control element drive 144

D.C. Cook Audit & Review Report mechanism (CEDM) pressure boundary; (2) reactor vessel internals; (3) Class 1 piping, valves, and RCPs; (4) pressurizer; and (5) steam generators. The summary information for each component type includes: intended function, material, environment, aging effect requiring management, AMPs, the GALL Report Volume 2 item, cross reference to LRA Table 3.1.1 (Table 1), and generic and plant-specific notes related to consistency with the GALL Report.

Also, the applicant identifies for each component type in CNP LRA Table 3.1.1 (Table 1) those components where further evaluation is recommended, those for which no further evaluation is required, and those that are not applicable to CNP together with the basis for their exclusion.

Additionally, in CNP LRA Tables 3.1.2-1 through 3.1.2-5, the applicant identifies which AMR results it considers to be consistent with the GALL Report (table column Notes A through E) and which results it justifies on a different basis.

The AMRs that are within the scope of the project team audit and review are identified on copies of LRA Tables 3.1.2-1 through 3.1.2-5 included as an appendix to the CNP audit and review plan.

The project team conducted its audit and review in accordance with SRP-LR Section 3.1.3 and the CNP audit and review plan.

7.2.1.1 Aging Management Evaluations That Are Consistent With the GALL Report, for Which No Further Evaluation Is Required For aging management evaluations that the applicant states are consistent with the GALL Report and for which further evaluation is not recommended, the project team conducted its audit and review to determine if the applicant's reference to the GALL Report in the CNP LRA is acceptable.

The project team reviewed the CNP LRA to confirm that the applicant (1) provides a brief description of the system, components, materials, and environment; (2) states that the applicable aging effects have been reviewed and are evaluated in the GALL Report; and (3) identifies those aging effects for the reactor vessel, internals, and RCS system components that are subject to an AMR.

7.2.1.1.1 Thermal Aging Embrittlement of CASS To manage loss of fracture toughness due to thermal aging embrittlement of the CASS pressurizer spray head, the GALL Report recommends no further evaluation if this aging effect is managed using a program consistent with GALL AMP XI.M12, "Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)." In the CNP LRA, the applicant describes CNP AMP B.1.7, "Cast Austenitic Stainless Steel Evaluation" as consistent with GALL AMP XI.M12, however, the pressurizer spray head is not within its scope. In the CNP LRA, the applicant proposes instead to use CNP AMP B.1.24, "Pressurizer Examinations," to manage this aging effect. The evaluation of this plant-specific program is documented in Section 7.1.18 of this audit and review report.

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D.C. Cook Audit & Review Report The project team finds that the pressurizer examinations program specifies one-time inspection using VT-3 to manage reduction of fracture toughness. This is not consistent with the CASS AMP in the GALL Report, which provides for volumetric examination or, alternatively, a plant- or component-specific flaw tolerance evaluation to demonstrate that the thermally embrittled material has adequate toughness.

By letter dated June 30, 2004 (ML041840218) the staff asked, in RAI B.1.24-2, that the applicant provide justification for using the VT-3 examination instead of VT-1 examination for the one-time inspection of the spray head and its associated components in either Unit 1 or Unit

2. Additionally, the staff asked the applicant to provide information regarding acceptance criteria; the evaluation methodology for disposition of indications; and the need for successive examinations for the one-time inspection of spray head, spray head locking bar, and coupling.

This is followup item 7.2.1.1-1 and will be dispositioned in the SER related to the CNP LRA (RAI B.1.24-2).

7.2.1.1.2 Core Exit Thermocouple Nozzle Assembly During the audit and review, the project team noted that the core exit thermocouple nozzle assembly, including holddown nut, compression collar and lockwasher are not components listed in the GALL Report. By letter dated April 23, 2004 (ML041270484) the applicant provided the following explanation for their inclusion:

The thermocouple nozzle assembly pressure-retaining items include the head port adapter (pressure housing), holddown nut, compression collar, Grafoil seals, seal carrier assembly, and lockwasher. The head port adapter, holddown nut, and compression collar are fabricated from stainless steel and are subject to aging management review. The short-lived Grafoil seals, seal carrier assembly, and lockwasher are replaced each refueling outage and are not subject to an AMR.

The AMR determined that the compression collar and holddown nut are part of the bolted connection used to connect the head port adapter to the core exit thermocouple column, which is part of the reactor vessel internals. The stainless steel holddown nut and compression collar are exposed to an external-ambient environment in which there are no aging effects that require management.

The stainless steel thermocouple nozzle assembly head port adapter is exposed to an internal environment of borated water and an external-ambient environment. The applicable aging effects include cracking and loss of material, which will be managed by the inservice inspection program and water chemistry control program throughout the period of extended operation. The thermocouple nozzle assembly head port adapter is attached to a CRDM head nozzle adapter by means of a threaded connection and a canopy seal weld. The canopy seal weld is exposed to an external-ambient environment. The applicable aging effect of the canopy seal weld is cracking, which is managed by the boric acid corrosion prevention program.

The staff's evaluation of CNP AMP B.1.4, "Boric Acid Corrosion Prevention," is documented in Section 3 of the SER related to the CNP LRA. CNP AMPs B.1.40.1, "Water Chemistry Control

- Primary and Secondary Water Chemistry Control Program," and B.1.14, "Inservice Inspection 146

D.C. Cook Audit & Review Report

- ASME Section XI, Subsection IWB, IWC, and IWD," were evaluated by the project team as documented in Sections 7.1.31 and 7.1.9 of this report.

With respect to the water chemistry control program and inservice inspection programs, aging of this component type is managed in a manner consistent with the recommendations of the GALL Report. The BAC prevention program is reviewed by NRR DE staff and addressed in Section 3.0 of the SER related to the CNP LRA.

The project team finds that for the water chemistry control program and inservice inspection programs the applicant has demonstrated that, given an acceptable BAC prevention program, the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.1.1.3 Loss of Mechanical Closure Integrity The GALL Report recommends the management of loss of mechanical closure integrity of stainless steel and nickel-based alloy bolted fasteners by stress relaxation in borated water using a loose part monitoring program (GALL AMP XI.M14) or neutron noise monitoring program (GALL AMP XI.M15) in addition to inservice inspection.

In the CNP LRA, the applicant proposes to manage this aging effect using CNP AMPs B.1.27, "Reactor Vessel Internals Plates, Forgings, Welds, and Bolting," and B.1.14, "Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD." The staff's evaluation of the plant-specific reactor vessel internals program is documented in Section 3.0 of the SER related to the CNP LRA. The project teams evaluation of these inservice inspection programs are documented in Section 7.1.9 of this report.

In the CNP LRA, the applicant states that the proposed new reactor vessel internals program is intended as an alternative to the loose parts monitoring program. The plant program includes managing the aging effects of loss of preload and loss of mechanical closure integrity, and is to be implemented prior to the period of extended operation. The project team finds that this would provide adequate management of this aging mechanism, however, the AMR for the core support holddown spring does not identify the inservice inspection program as applicable to this aging effect. By letter dated April 23, 2004 (ML041270484), the applicant provided clarification.

In its response, the applicant states that this included the commitment that the holddown spring is included in the inservice inspection program (already documented in the CNP LRA for the aging effect of cracking) and that the reactor vessel internals program will augment the inservice inspection to include acceptable inspection methods for bolted joints including those necessary to demonstrate that loss of closure integrity due to stress relaxation (i.e., loss of preload) will be managed. NRR DE review of the reactor vessel internals - plates, forgings, welds, and bolting program is addressed in Section 3.0 of the SER related to the CNP LRA.

7.2.1.1.4 Flow-Accelerated Corrosion In the CNP LRA, the main steam nozzles and the Unit 2 feedwater elbow thermal liners are included in this grouping. Management of loss of material from the feedwater nozzles due to FAC is recommended in the GALL Report, but the applicant does not manage FAC for these 147

D.C. Cook Audit & Review Report components, which are protected from flow-accelerated corrosion by nickel-based alloy thermal sleeves (Unit 1) and carbon steel thermal liners (Unit 2). The sleeves are not subject to FAC and no program is required for management of this aging effect. The liners are managed using CNP AMP B.1.12, "Flow-Accelerated Corrosion," supplemented by CNP AMP B.1.40.1, "Water Chemistry Control Program - Primary and Secondary Water Chemistry Control." This is consistent with the GALL Report and therefore acceptable to the project team.

The project team finds that, based on the programs identified above, the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

On the basis of its audit and review, the project team determined that for all other AMRs not requiring further evaluation, as identified in LRA Table 3.1.1 (Table 1), the applicant's references to the GALL Report are acceptable and no further project team review is required.

7.2.1.2 Aging Management Evaluations That Are Consistent With the GALL Report, for Which Further Evaluation Is Recommended For some line items consistent with the GALL Report in CNP LRA Tables 3.1.2-1 through 3.1.2-5, the GALL Report recommends further evaluation. When further evaluation is recommended, the project team reviewed these further evaluations provided in CNP LRA Section 3.1.2.2 against the criteria provided in the SRP-LR Section 3.1.2.2. The following provides the project team's assessments of these evaluations. These project team assessments are applicable to each Table 2 line item in Section 3.1 citing the item in Table 1.

The LRA sections identified in CNP LRA Table 3.1.1 where further evaluation is recommended are discussed below.

7.2.1.2.1 Cumulative Fatigue Damage (CNP LRA Section 3.1.2.2.1)

CNP LRA Section 3.1.2.2.1 is reviewed by the NRR DE staff and addressed in Section 4 of the SER related to the CNP LRA.

7.2.1.2.2 Loss of Material Due to Pitting and Crevice Corrosion (CNP LRA Section 3.1.2.2.2)

In CNP LRA Section 3.1.2.2.2, the applicant addresses loss of material of steam generator assemblies due to pitting and crevice corrosion.

SRP-LR Section 3.1.2.2.2 states that loss of material due to pitting and crevice corrosion could occur in the steam generator shell assembly. The existing program relies on control of water chemistry to mitigate corrosion and inservice inspection to detect loss of material. NRC IN 90-04, "Cracking of the Upper Shell-to-Transition Cone Girth Welds in Steam Generators,"

states that if general corrosion pitting of the shell exists, the existing program may not be sufficient. In that case, the GALL Report recommends augmented inspections to manage the aging effect.

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D.C. Cook Audit & Review Report The AMPs recommended by the GALL Report for managing the aging of steam generator assemblies due to pitting and crevice corrosion are GALL AMP XI.M1, "ASME Section XI, Inservice Inspection, Subsections IWB, IWC, and IWD" program to detect loss of material and GALL AMP XI.M2, "Water Chemistry" program to mitigate corrosion. The GALL Report recommends a plant-specific program to conduct augmented inspections.

In the CNP LRA, the applicant states that for the management of loss of material due to pitting and crevice corrosion, the applicant credits CNP AMP B.1.40.1, "Water Chemistry Control -

Primary and Secondary Water Chemistry Control Program." This water chemistry control AMP evaluation is documented in Section 7.1.31 of this report. The program is supplemented by CNP AMP B.1.14, "Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD" for secondary-side external components of the steam generator within the scope of that program. Evaluation of this inservice inspection AMP is documented in Section 7.1.9 of this report.

In the CNP LRA, Section 3.1.2.2, the applicant did not discuss secondary-side internal components of the steam generator that are not within the scope of the inservice inspection program. In Table 3.1.2-1, the applicant states that management of general, pitting, and crevice corrosion for the steam generator shell assembly and attached components, and components of the secondary side internals are supplemented using CNP AMP B.1.31, "Steam Generator Integrity Program," which is evaluated by the DE staff and documented in Section 3 of the SER related to the CNP LRA.

CNP AMP B.1.14, "Inservice Inspection - Inservice Inspection" which is evaluated in Section 7.1.12 of this report, and CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control," which is evaluated in Section 7.1.26 of this report for managing loss of material due to pitting and crevice corrosion on the internal surfaces of the steam generator shell.

The project team reviewed IN 90-04, which identifies the need to augment inspections beyond the requirements of ASME Section XI if general corrosion pitting of the steam generator shell is known to exist in order to differentiate isolated cracks for inherent geometric conditions. The applicant maintains that these concerns are not applicable to CNP, since CNP has not experienced significant pitting corrosion of the steam generator shell. Unit 1 steam generators were replaced in 2000 and Unit 2 steam generators were replaced in 1988.

The project team reviewed operating experience which indicated that no pitting corrosion of the steam generator shell has been detected to date, and that water chemistry has been maintained for these new steam generators per EPRI guidelines. The project team finds that the augmented inspections recommended by NRC IN 90-04, as referenced in the SRP-LR, do not currently apply to the CNP steam generators.

In the CNP LRA, the applicant states that the steam generator tubesheet is made of low alloy steel, clad on the primary side with nickel-based alloy. Using only the primary and secondary water chemistry control program to manage loss of material from the primary side (in treated, borated water) is consistent with the GALL Report and acceptable to the project team.

However, the project team does not consider the water chemistry control program to be sufficient for managing this loss of material from the secondary side of the tubesheet. During 149

D.C. Cook Audit & Review Report the audit, the applicant was asked to justify this position. By letter dated April 23, 2004 (ML041270484), the applicant documented a commitment to use the steam generator integrity program in addition to water chemistry control to manage loss of material from the secondary side of the tube sheet. This is consistent with the GALL Report and therefore acceptable to the project team.

Also, since pitting corrosion has not been detected on the steam generator shell since installation, the project team finds that augmented inspections are not required and that the current water chemistry control and inservice inspection programs, supplemented by the steam generator integrity program, are consistent with the recommendations of the GALL Report and therefore adequate for managing this aging effect.

The project team finds that, based on the programs identified above, the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.1.2.3 Loss of Fracture Toughness Due to Neutron Irradiation Embrittlement (CNP LRA Section 3.1.2.2.3)

CNP LRA Section 3.1.2.2.1 is reviewed by the NRR DE staff and addressed in Section 4 of the SER related to the CNP LRA.

7.2.1.2.4 Crack Initiation and Growth Due to Thermal and Mechanical Loading or Stress Corrosion Cracking (CNP LRA Section 3.1.2.2.4)

In CNP LRA Section 3.1.2.2.4, the applicant addresses the potential crack initiation and growth due to thermal and mechanical loading or SCC (including intergranular stress corrosion cracking) that could occur in small-bore RCS and connected system piping less than 4-inch nominal pipe size (NPS 4).

SRP-LR Section 3.1.2.2.4 states that the GALL Report recommends that a plant-specific destructive examination or a nondestructive examination (NDE) that permits inspection of the inside surfaces of the piping be conducted to ensure that cracking has not occurred and the component intended function will be maintained during the period of extended operation. The applicant should verify that service-induced weld cracking is not occurring in small-bore piping less than NPS 4. A one-time inspection of a sample of locations is an acceptable method to ensure that the aging effect is not occurring and the component's intended function will be maintained during the period of extended operation. Per ASME Section XI, 1995 Edition, Examination Category B-J or B-F, small bore piping, defined as piping less than NPS 4, does not receive volumetric inspection.

The GALL Report recommended GALL AMP XI.M1, "ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD" to detect loss of material and GALL AMP XI.M2, "Water Chemistry" to mitigate SCC.

The project team reviewed CNP LRA Section 3.1.2.2.4. The applicant uses CNP AMP B.1.14, "Inservice Inspection-ASME Section XI, Subsection IWB, IWC, and IWD Program," evaluated in 150

D.C. Cook Audit & Review Report Section 7.1.9 of this report, and AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control" evaluated in Section 7.1.31 of this report, to manage cracking due to stress corrosion cracking. The small bore piping program will include a one-time inspection to confirm that significant cracking is not occurring. The project team finds this to be consistent with the recommendations of the GALL Report and therefore acceptable.

The project team finds that the applicant's AMR results are consistent with the GALL Report, and that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.1.2.5 Crack Growth Due to Cyclic Loading (CNP LRA Section 3.1.2.2.5)

CNP LRA Section 3.1.2.2.1 is reviewed by the NRR DE staff and addressed in Section 4 of the SER related to the CNP LRA.

7.2.1.2.6 Changes in Dimension Due to Void Swelling (CNP LRA Section 3.1.2.2.6)

In CNP LRA Section 3.1.2.2.6, the applicant addresses changes in dimension due to void swelling that could occur in reactor internal components.

SRP-LR Section 3.1.2.2.6 states that the GALL Report recommends that changes in dimension due to void swelling in reactor internal components be evaluated to ensure that this aging effect is adequately managed. The GALL Report recommends that a plant-specific AMP be evaluated to manage the effects of changes in dimension due to void swelling and the loss of fracture toughness associated with swelling.

In CNP LRA Section 3.1.2.2.6 and Table 3.1.1-11, the applicant credits CNP AMP B.1.27, Reactor Vessel Internals Plates, Forgings, Welds, and Bolting Program, to manage changes in dimension due to void swelling of reactor vessel internals.

In CNP LRA Table 3.1.2-2, page 3.1-51, the applicant credits the reactor vessel internals (CASS) program to manage distortion of the lower support plate and lower core plate support column cap in a treated water environment. Additionally, in LRA Appendix B, Sections B.1.27, Reactor Vessel Internals Plates, Forgings, Welds, and Bolting, and B.1.28, Reactor Vessel Internals Cast Austenitic Stainless Steel, the applicant describes the program description for each as managing the aging effect of distortion due to void swelling.

The staff requested, in RAI 3.1.2-4, that applicant updates CNP LRA Section 3.1.2.2.6 and Table 3.1.1 -11 to include the reactor vessel internals (CASS) program with managing this aging effect or justify why it should not be credited with managing this aging effect. This is followup item 7.2.1.2-1 and will be dispositioned in the SER related to the CNP LRA (RAI 3.1.2-4).

7.2.1.2.7 Crack Initiation and Growth Due to Stress Corrosion Cracking or Primary Water Stress Corrosion Cracking (CNP LRA 3.1.2.2.7) 151

D.C. Cook Audit & Review Report In the CNP LRA Section 3.1.2.2.7, the applicant proposes to manage cracking of nickel-based alloy components due to primary water stress corrosion cracking (PWSCC) using the plant-specific CNP AMP B.1.1, "Alloy 600 Aging Management." The staff's evaluation of this program is documented in Section 3.0 of the SER related to the CNP LRA.

The applicant also states, in the CNP LRA, that the Alloy 600 aging management program is supplemented by CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control" and B.1.14, "Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD." The project teams evaluations of these aging management programs are documented in Sections 7.1.31 and 7.1.9, of this report, respectively.

In the CNP LRA, the applicant further states that cracking of the pressurizer spray head assembly is to be managed using CNP AMP B.1.24, "Pressurizer Examinations." The project team evaluation of this program is documented in Section 7.1.18 of this report. Crack initiation and growth due to SCC in reactor coolant piping and fittings is to be managed by the water chemistry control program and the inservice inspection program.

In addition to the plant-specific aging management program recommended by the GALL Report, the applicant committed to augment inservice inspection where industry programs identify specific locations or appropriate inspections for management of this aging effect.

The project team finds the applicant's approach for managing crack initiation and growth due to SCC and PWSCC to be consistent with the GALL Report and therefore acceptable, pending review of the program prior to the period of extended operation. The project team finds that the applicant appropriately evaluated AMR results which address these aging mechanisms, as recommended in the GALL Report.

7.2.1.2.8 Crack Initiation and Growth Due to Stress Corrosion Cracking or Irradiation-Assisted Stress Corrosion Cracking (CNP LRA 3.1.2.2.8)

In the CNP LRA Section 3.1.2.2.8, the applicant addresses crack initiation and growth due to SCC or irradiation assisted stress corrosion cracking (IASCC) that could occur in baffle/former bolts in the reactor.

SRP-LR Section 3.1.2.2.8 states that crack initiation and growth due to SCC or IASCC could occur in baffle/former bolts in the reactors. The GALL Report recommends further evaluation to ensure that these aging effects are adequately managed.

The applicant proposes, in the CNP LRA, to use CNP AMP B.1.27, "Reactor Vessel Internals Plates, Forgings, Welds, and Bolting" in conjunction with CNP AMP B.1.14, "Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD." The staff's evaluation of the reactor vessel internals program is documented in Section 3.0 of the SER related to the CNP LRA. The project teams evaluation of the inservice inspection program documented in Section 7.1.9 of this report. The applicant also credits CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control" for mitigating damage caused by stress corrosion cracking.

In the CNP LRA, the applicant states that volumetric inspections of baffle/former bolt critical locations will be used to assess cracking. No detectable crack will be considered acceptable 152

D.C. Cook Audit & Review Report for a baffle bolt, and the critical number (and location) of baffle bolts that must remain intact will be determined by analysis as part of this program. The industry is addressing the issue of baffle bolt cracking through the activities of the PWR Materials Reliability Project, Issues Task Group (ITG). Those activities are to determine, develop, and implement the necessary steps and plans to manage the applicable aging effects on a plant-specific basis. In the CNP LRA, the applicant has committed to follow these efforts and to apply further understanding of these aging effects to provide additional bases for the inspections under this program. This is acceptable to the project team.

7.2.1.2.9 Loss of Preload Due to Stress Relaxation (CNP LRA 3.1.2.2.9)

In the CNP LRA Section 3.1.2.2.9, the applicant addresses loss of preload due to stress relaxation that could occur in baffle/former bolts in the reactor.

SRP-LR Section 3.1.2.2.9 states that loss of preload due to stress relaxation could occur in baffle/former bolts in the reactor. The GALL Report recommends further evaluation to ensure that these aging effects are adequately managed.

In the CNP LRA, the applicant proposes to use CNP AMP B.1.27, "Reactor Vessel Internals Plates, Forgings, Welds, and Bolting" in conjunction with CNP AMP B.1.14 "Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD." The staff's evaluation of the plant-specific reactor vessel internals program is documented in Section 3.0 of the SER related to the CNP LRA. The project teams evaluation of these inservice inspection programs are documented in Section 7.1.9 of this report. As recommended by the GALL Report, the inservice inspections are augmented by volumetric examination to detect and manage this aging effect.

On the basis that the applicant's program reactor vessel internals program will be consistent with GALL AMP XI.M16, the project team finds the applicant's approach for managing loss of preload due to stress relaxation to be consistent with the GALL report and therefore acceptable.

7.2.1.2.10 Loss of Section Thickness Due to Erosion (CNP LRA Section 3.1.2.2.10)

In CNP LRA Section 3.1.2.2.10, the applicant addresses loss of section thickness due to erosion that could occur in steam generator feedwater impingement plates and supports.

SRP-LR Section 3.1.2.2.10 states that loss of section thickness due to erosion could occur in steam generator feedwater impingement plates and supports. The GALL Report recommends further evaluation of a plant-specific AMP to ensure that this aging effect is adequately managed.

The applicant states, in the CNP LRA, that its steam generator design does not include impingement plates. Since impingement plates are not part of the CNP steam generator design, the project team finds that this aging effect does not require management at CNP.

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D.C. Cook Audit & Review Report 7.2.1.2.11 Crack Initiation and Growth Due to Primary Water Stress Corrosion Cracking, Outside Diameter Stress Corrosion Cracking, or Intergranular Attack or Loss of Material Due to Wastage and Pitting Corrosion or Loss of Section Thickness Due to Fretting and Wear or Denting Due to Corrosion of Carbon Steel Tube Support Plate (CNP LRA Section 3.1.2.2.11)

In CNP LRA Section 3.1.2.2.11, the applicant addresses crack initiation and growth due to PWSCC, SCC, or intergranular attack (IGA) or loss of material due to wastage and pitting corrosion or deformation due to corrosion that could occur in nickel-based alloy components of the steam generator tubes and plugs.

SRP-LR Section 3.1.2.11 states that crack initiation and growth due to PWSCC, outside diameter stress corrosion cracking, or IGA or loss of material due to wastage and pitting corrosion or deformation due to corrosion could occur in Alloy 600 components of the steam generator tubes, repair sleeves and plugs. The applicant committed to a steam generator (SG) degradation management program described in NEI 97-06; these guidelines are currently under NRC staff review. The GALL Report recommends that an AMP based on the recommendations of staff-approved NEI 97-06 guidelines, or other alternate regulatory basis for SG degradation management, should be developed to ensure that this aging effect is adequately managed.

To manage several of the effects of aging, the applicant, in the CNP LRA, credits CNP AMP B.1.31, "Steam Generator Integrity." Aging effects using the steam generator integrity program include crack initiation and growth due to PWSCC, SCC or IGA or loss of material due to wastage and pitting corrosion or deformation due to corrosion, which could occur in nickel-based alloy components of the SG tubes and plugs. The NRR DE staff's evaluation of the steam generator integrity program is documented in Section 3.0 of the SER related to the CNP LRA. In addition, the applicant states that this program is supplemented by CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control," and CNP AMP B.1.14, "Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD."

The project team evaluations of these programs are documented in Sections 7.1.31 and 7.1.9 of this report, respectively. For general and pitting corrosion as well as for the assessment of tube integrity and plugging or repair criteria of flawed tubes, the steam generator integrity program acceptance criteria conform to NEI 97-06 guidelines.

On the basis of its review of the water chemistry control and inservice inspection programs, the project team finds that the applicant appropriately evaluated AMR results involving plant-specific programs to address these aging mechanisms, as recommended in the GALL Report.

7.2.1.2.12 Loss of Section Thickness Due to Flow-Accelerated Corrosion (CNP LRA Section 3.1.2.2.12)

In CNP LRA Section 3.1.2.2.12, the applicant addresses loss of section thickness due to FAC that could occur in tube support lattice bars made of carbon steel.

SRP-LR Section 3.1.2.2.12 states the loss of section thickness due to FAC could occur in tube support lattice bars made of carbon steel. The GALL Report recommends that a plant-specific AMP be evaluated and, on the basis of the guidelines of NRC Generic Letter 97-06, an 154

D.C. Cook Audit & Review Report inspection program for SG internals be developed to ensure that this aging effect is adequately managed.

In the CNP LRA, the applicant states that its SG design does not include carbon steel tube support lattice bars.

On the basis that carbon steel tube support lattice bars are not part of the CNP SG design, the project team finds that this aging effect is does not require management at CNP.

7.2.1.2.13 Ligament Cracking Due to Corrosion (CNP LRA Section 3.1.2.2.13)

In CNP LRA Section 3.1.2.2.13, the applicant addresses ligament cracking due to corrosion that could occur in carbon steel components in the SG tube support plate.

SRP-LR Section 3.1.2.2.13 states that ligament cracking due to corrosion could occur in carbon steel components in the SG tube support plate. All PWR licensees have committed voluntarily to a steam generator degradation management program described in NEI 97-06; these guidelines are currently under NRC staff review. The GALL Report recommends that an AMP based on the recommendations of staff-approved NEI 97-06 guidelines, or other alternate regulatory basis for SG degradation management, be developed to ensure that this aging effect is adequately managed.

The applicant states that the CNP Unit 1 SGs do not have support plates and the SGs in Unit 2 have tube support plates made of stainless steel, not carbon steel.

On the basis that there is no tube support plate at CNP Unit 1 and that carbon steel components are not part of the CNP Unit 2 SG tube support plate design, the project team finds that this aging effect does not require management at CNP.

7.2.1.2.14 Loss of Material Due to Flow-Accelerated Corrosion (CNP LRA Section 3.1.2.2.14)

In CNP LRA Section 3.1.2.2.14, the applicant addresses loss of material due to FAC that could occur in the feedwater inlet ring and supports.

SRP-LR Section 3.1.2.2.14 states that loss of material due to FAC could occur in the feedwater inlet ring and supports. As noted in Combustion Engineering (CE) IN 90-04, NRC IN 91-19 and LER 50-362/90-05-01, this form of degradation has been detected only in certain CE System 80 SGs. The GALL Report recommends further evaluation to ensure that this aging effect is adequately managed. The GALL Report recommends that a plant-specific AMP be evaluated because existing programs may not be capable of mitigating or detecting loss of material due to FAC.

In the CNP LRA, the applicant states that this subsection of the SRP-LR applies only to CE System 80 steam generators and notes that CNP has Babcock and Wilcox Type 51R and Westinghouse Model 51 SGs which this form of degradation has not been detected.

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D.C. Cook Audit & Review Report On the basis that B&W Type 51R and Westinghouse Model 51 SGs are not subject to FAC in the feedwater inlet ring supports, the project team finds that it requires no aging management program at CNP.

7.2.1.2.15 Quality Assurance for Aging Management of Non-safety-related Components (CNP LRA Section 3.1.2.2.15)

CNP LRA Section 3.1.2.2.15 is reviewed by NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.2.1.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report In CNP LRA Tables 3.1.2-1 through 3.1.2-5, the project team reviewed additional details of the results of the AMRs for material, environment, aging effect requiring management, and AMP combinations that are not different from or not addressed in the GALL Report.

7.2.1.3.1 Reactor Vessel and CEDM Pressure Boundaries Summary of Aging Management ( CNP LRA Table 3.1.2-1)

The project team reviewed Table 3.1.2-1 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the reactor vessel and control element drive mechanism (CEDM) pressure boundary component groups.

In the CNP LRA, the applicant states that loss of material from components with stainless steel and nickel based alloy cladding in borated water is not addressed in the GALL Report for bottom and upper head, shell rings (including the nozzle course), vessel and closure head flanges, as well as inlet and outlet nozzles. The applicant proposes to control this aging mechanism using CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control." The project team evaluation of this program is documented in Section 7.1.31 of this report.

In CNP LRA Table 3.1.2-1, for each of these same component and material combinations, the applicant is also managing cracking using the water chemistry control program, CNP AMP B.1.14, Inservice Inspection - ASME Section XI, Subsections IWB, IWC, and IWD, and a plant-specific program such as CNP AMP B.1.1, Alloy 600 Aging Management. The project team accepted the inservice inspection - IWB, IWC, and IWD program and evaluation of this AMP is documented in Section 7.1.9. The alloy 600 aging management program is reviewed by NRR DE and is evaluated in Section 3.0 of the SER related to the CNP LRA. The applicant manages cracking in a manner consistent with the GALL Report.

On the basis that management of cracking of stainless steel and nickel-based alloy components is being managed by the water chemistry control and inservice inspection programs, and on the basis of industry experience that the effects of general and crevice corrosion, as well as pitting on stainless steel components in chemically treated, borated water are not significant, the project team finds that management of loss of material aging effect using water chemistry control is sufficient for stainless steel cladding. This conclusion also applies to loss of material from nickel-alloy cladding in chemically treated, borated water.

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D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that cracking of stainless steel cladding of the weld buildup support pads due to external-ambient conditions is an aging effect managed under CNP AMP B.1.14, "Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD." The project teams evaluation of this AMP is documented in Section 7.1.9 of this report. This aging effect is not identified in the GALL Report for this material, environment and component. The applicant's identification of cracking as an applicable effect for these components is acceptable and the Section XI, Subsection IWB, inservice inspection is appropriate for management of this aging effect. The project team finds this to be acceptable.

In the CNP LRA, the applicant states that loss of material from components in treated, borated water is not an aging effect addressed in the GALL Report for nickel-based alloy and stainless steel. The applicant proposes to use the water chemistry control program to manage this aging effect for nickel-based alloy CRDM nozzles, incore instrumentation nozzles, the vent line nozzle and elbow, and Unit 1 flange leak tubes. The same program is to be used for stainless steel inlet and outlet nozzle safe ends (Unit 1) CRDM housing adapters, incore instrumentation nozzle safe ends, and housing cap, in-core instrumentation nozzle safe ends, the BMI thimble guide tubes and bullet plugs, the thimble seal table, the vent line safe end, CRDM housing, core exit thermocouple nozzle assembly, holddown nut, compression collar, and lockwasher, CRDM housing cap, and flange leak tubes (Unit 2).

In CNP LRA Table 3.1.2-1, for each of these same component and material combinations, the applicant is also managing cracking using the water chemistry control program, CNP AMP B.1.14, Inservice Inspection - IWB, IWC, and IWD, and a plant-specific program such as CNP AMP B.1.1, Alloy 600 Aging Management or CNP AMP B.1.9, Control Rod Drive Mechanism and Other Vessel Head Penetration Inspection. The project team accepted the inservice inspection - IWB, IWC, and IWD program and evaluation of this AMP is documented in Section 7.1.9. The alloy 600 aging management and control rod drive mechanism and other vessel head penetration inspection programs are reviewed by NRR DE and are evaluated in Section 3.0 of the SER related to the CNP LRA. The applicant manages cracking in a manner consistent with the GALL Report.

On the basis that management of cracking of nickel-based alloy and stainless steel components in treated, borated water is consistent with the GALL Report and on the basis of industry experience that the effects of general and crevice corrosion as well as pitting on stainless steel components in chemically treated, borated water are not significant, the project team finds that management of this aging effect using water chemistry control is sufficient. A similar conclusion has been reached for loss of material from nickel-alloy components in chemically treated, borated water.

In the CNP LRA, the applicant states that loss of material for nickel-based alloy in borated water for core support lugs is managed by a water chemistry control program, in addition to the inservice inspection specified in the GALL Report. The project team finds the combination of this preventive/mitigative program with an inspection program to be an acceptable way to manage this aging effect.

During the audit and review, the project team noted that cracking of stainless steel alloy in treated, borated water is handled in a manner consistent with the GALL Report for the core exit thermocouple nozzle assembly, but the head port adapter (holddown nut, compression collar, 157

D.C. Cook Audit & Review Report and lockwasher) is not exposed to the same environment. By letter dated April 23, 2004 (ML041270484), the applicant states the following in its response:

The stainless steel thermocouple nozzle assembly head port adapter is exposed to an internal environment of borated water and an external-ambient environment. The applicable aging effects include cracking and loss of material, which will be managed by the Inservice Inspection Program and the Water Chemistry Control Program throughout the period of extended operation.

The thermocouple nozzle assembly head port adapter is attached to a CRDM head nozzle adapter by means of a threaded connection and a canopy seal weld. The canopy seal weld is exposed to an external-ambient environment.

The applicable aging effect of the canopy seal weld is cracking, which is managed by the Boric Acid Corrosion Prevention Program.

The project team finds that this is consistent with the GALL Report and therefore it is acceptable.

7.2.1.3.2 Reactor Vessel Internals Summary of Aging Management (CNP LRA Table 3.1.2-2)

The project team reviewed CNP LRA Table 3.1.2-2, which summarizes the results of AMR evaluations in the SRP-LR for the reactor vessel internals component groups.

In the CNP LRA, the applicant states that loss of material for stainless steel (including CASS) in treated, borated water is not addressed in the GALL Report. This aging effect is considered for the core barrel, flange, outlet nozzle, and fasteners, core former plates, baffle plates, baffle bolts, former bolts, and lower plate, lower support columns, diffuser plate, lower support plate, lower core plate support column cap, secondary core support assembly, thermal shield, upper support plate (Unit 1), deep beam sections, upper support columns, support column bolts, upper core support column mixing device, upper core support column orifice base, upper support plate (Unit 2), upper core plate and plate alignment pins, lower support radial keys, holddown spring, guide tube assemblies, upper system thermocouples, and lower system flux thimbles. Loss of material for nickel-based alloy clevis insert fasteners. The applicant proposes to manage loss of material for this material-environment combination using only CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control."

The project teams evaluation of this program is documented in Section 7.1.31 of this report.

In CNP LRA Table 3.1.2-2, for each of these same component and material combinations, the applicant is also managing cracking using the water chemistry control program, CNP AMP B.1.14, Inservice Inspection - ASME Section XI, Subsections IWB, IWC, and IWD, and a plant-specific program such as CNP AMP B.1.28, Reactor Vessel Internals Cast Austenitic Stainless Steel, or CNP AMP B.1.27, Reactor Vessel Internals Plates, Forgings, Welds, and Bolting. The project team accepted the inservice inspection - IWB, IWC, and IWD program and evaluation of this AMP is documented in Section 7.1.9. The project team reviewed CNP AMP B.1.28, Reactor Vessel Internals Cast Austenitic Stainless Steel, and evaluation of this AMP is documented in Section 7.1.20. The reactor vessel internals plates, forgings, welds, and bolting is reviewed by NRR-DE and is evaluated in Section 3.0 of the SER related to the CNP 158

D.C. Cook Audit & Review Report LRA. The project team finds that the applicant manages cracking in a manner consistent with the GALL Report.

On the basis that cracking of stainless steel (including CASS) and nickel-based alloy components in treated borated water is managed in a manner consistent with the Gall Report and on the basis of industry experience that the effects of general and crevice corrosion as well as pitting on components made of stainless steel (including CASS) in chemically treated, borated water are not significant, the project team finds that management of this aging effect using water chemistry control is sufficient. A similar conclusion has been reached for loss of material from nickel-alloy components in chemically treated, borated water.

In the CNP LRA, the applicant states nickel-based alloy clevis insert block, control rod guide tube pin, and fuel assembly guide pin are managed using the inservice inspection program and water chemistry control program. On the basis that the GALL Report suggests management of this aging effect for these components using inservice inspection, the project team finds this to be acceptable.

7.2.1.3.3 Class 1 Piping, Valves, and Reactor Coolant Pumps Summary of Aging Management (CNP LRA Table 3.1.2-3)

The project team reviewed CNP LRA Table 3.1.2-3, which summarizes the results of AMR evaluations in the SRP-LR for the Class 1 piping, valves, and RCPs component groups. For the items assigned to the project team, the team finds that the programs proposed for management of aging effects for the component types in this system are consistent with the GALL Report.

In the CNP LRA, the applicant states that loss of material for CASS in treated, borated water is addressed using CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control" and CNP AMP B.1.14, "Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD" for the following components: hot and cold leg pipe and fittings, crossover leg pipe and fittings, Class 1 valve bodies and bonnets (NPS 2-1/2" and NPS <2"), reactor coolant pump casing, main closure flange, pressurizer surge line, piping and fitting (including blind flanges) (NPS 4" and NPS <4"), branch nozzles (NPS 4" and NPS <4"),

thermal sleeves, orifices, and Class 1 valve bodies and bonnets (NPS 2-1/2" and NPS <2").

The project team evaluation of these two programs is documented in Sections 7.1.31 and 7.1.14 of this report, respectively. This is consistent with the recommendations in the GALL Report for management of other components of the same material in a similar environment.

On that basis, the project team finds this to be acceptable.

In the CNP LRA, the applicant states that loss of material from the stainless steel thermal barrier heat exchanger in treated water is to be managed using the water chemistry control program. On the basis of industry experience that the effects of general and crevice corrosion as well as pitting on components made of stainless steel in chemically treated water and treated, borated water are not significant, the project team finds that management of this aging effect using water chemistry control is sufficient.

In the CNP LRA, the applicant states that cracking of low alloy and stainless steel bolting material is to be managed using CNP AMP B.1.14, "Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD." The project team evaluation of this program is documented 159

D.C. Cook Audit & Review Report in Section 7.1.9 of this report. To manage cracking of the bolting material for valves and blind flanges as well as main flange bolts, the applicant proposes to use the inservice inspection program. Although a precedent was cited, the project team was not able to confirm its applicability. For the component referenced, the GALL Report recommends a program consistent with "Bolting Integrity" (GALL AMP XI.M18) which invokes the guidelines of NUREG-1339 to prevent and mitigate bolting degradation.

The project team asked the applicant to explain the rationale for excluding this bolting material from the scope of CNP LRA AMP B.1.2, Bolting and Torquing Activities, or confirm that it is managed using this program. By letter dated August 20, 2004, the staff asked, in RAI 3.1.3-1, that the applicant explain the rationale for excluding bolting material for valves and blind flanges, and main flange bolts from the scope of CNP AMP B.1.2, Bolting and Torquing Activities, or confirm that it is managed using this program. This is followup item 7.2.1.3-1 and will be dispositioned in the SER related to the CNP LRA (RAI 3.1.3-1).

7.2.1.3.4 Pressurizer Summary of Aging Management (CNP LRA Table 3.1.2-4)

The project team reviewed CNP LRA Table 3.1.2-4, which summarizes the results of AMR evaluations in the SRP-LR for the pressurizer component groups.

In the CNP LRA, the applicant states that loss of material for low alloy steel clad with stainless steel in treated, borated water is to be managed using CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control" only. The project teams evaluation of this program is documented in Section 7.1.31 of this report. This applies to the lower head, shell, upper head, surge, spray, relief, and safety nozzles (with nickel-alloy weld buttering), as well as the manway forging.

On the basis of industry experience that the effects of general and crevice corrosion, as well as pitting on cladding made of stainless steel in chemically treated, borated water are not significant, the project team finds that management of this aging effect using water chemistry control is sufficient.

In the CNP LRA, the applicant states that loss of material from stainless steel components in treated, borated water is to be managed using the water chemistry control program only. This includes the surge, spray, relief, and safety nozzle safe ends; surge and spray nozzle thermal sleeves; heater well nozzles and couplings; immersion heater sheaths; heater support plates, plate brackets, and plate bracket bolts; spray head locking bar and couplings; instrument nozzles and couplings; as well as the manway insert. Loss of material from the CASS spray head in this environment is managed in the same way.

On the basis of industry experience that the effects of general and crevice corrosion as well as pitting on components made of stainless steel (including CASS) in chemically treated, borated water are not significant, the project team finds that management of this aging effect using water chemistry control is sufficient.

In the CNP LRA, the applicant states that cracking of the heater support plates, their brackets, and the bracket bolts are to be managed using the water chemistry control program. Although a precedent was cited, the project team was not able to confirm that it is applicable. For the 160

D.C. Cook Audit & Review Report component referenced, the GALL Report recommends the use of inservice inspection in addition to the water chemistry control program.

The project team asked the applicant to justify the absence of an inspection or monitoring program to manage cracking of these components, or identify the program used. By letter dated August 20, 2004, the staff asked, in RAI 3.1.3-2, that the applicant explain the rationale for excluding cracking of heater support plates, their brackets, and the bracket bolts from the scope of an inspection or monitoring program, or identify the program used to supplement water chemistry control. This is followup item 7.2.1.3-2 and will be dispositioned in the SER related to the CNP LRA (RAI 3.1.3-2).

In the CNP LRA, the applicant states that cracking of low-alloy steel and carbon steel components exposed to ambient air is managed using the inservice inspection program for the support skirt and flange, seismic lugs, valve support bracket lugs. The project team found this to be consistent with the GALL Report and therefore acceptable.

In the CNP LRA, the applicant states that cracking of the low-alloy steel manway cover bolts/studs in ambient air is managed using the inservice inspection program. Although a precedent was cited, the project team was not able to determine its applicability. For the component referenced, the GALL Report recommends the use of a program consistent with the bolting integrity program (GALL AMP XI.M18).

The project team asked the applicant to explain the rationale for excluding this bolting material from the scope of CNP LRA AMP B.1.2, Bolting and Torquing Activities, or confirm that it is managed using this program. By letter dated August 20, 2004, the staff asked, in RAI 3.1.3-1, that the applicant explain the rationale for excluding low-alloy steel manway cover bolts/studs in ambient air from the scope of CNP AMP B.1.2, Bolting and Torquing Activities, or confirm that it is managed using this program. This is followup item 7.2.1.3-3 and will be dispositioned in the SER related to the CNP LRA (RAI 3.1.3-1).

7.2.1.3.5 Steam Generators Summary of Aging Management (CNP LRA Table 3.1.2-5)

The project team reviewed Table 3.1.2-5 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the SG component groups.

In the CNP LRA, the applicant states that the primary head and primary nozzles of the steam generator are fabricated with low alloy steel clad with stainless steel. All are exposed to treated, borated water. For these components, the applicant proposes to manage loss of material using only CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control." The project team evaluation of this program is documented in Section 7.1.31. This is consistent with the GALL Report and acceptable to the project team.

In the CNP LRA, the applicant states that the primary nozzle safe end and the primary manway insert plate (Unit 2) are made of stainless steel and are exposed to treated, borated water. For these components, the applicant proposes to manage loss of material using only the water chemistry control program. This is consistent with the GALL Report and acceptable to the project team.

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D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that the partition plates, nozzle dam retention rings, primary manway insert plate (Unit 1), and tube plugs are made of nickel-based alloy or low-alloy steel clad with nickel-based alloy. The tube sheet (primary side) is low-alloy steel clad with nickel-based alloy. All are exposed to treated, borated water. For these components, the applicant proposes to manage loss of material using only the water chemistry control program.

This is consistent with the GALL Report and acceptable to the project team.

In the CNP LRA, the applicant states that the feedwater nozzle thermal sleeve, feedwater safe ends (Unit 1) and feedwater liner piston rings (Unit 2) are made of nickel-based alloy. All are exposed to treated water. For these components, the applicant proposes to manage loss of material using only the water chemistry control program. This is consistent with the GALL Report and acceptable to the project team.

In the CNP LRA, the applicant states that cracking of the low-alloy steel lower shell, upper shell, transition cone, steam drum, elliptical upper head, feedwater nozzle and main steam nozzle, secondary blowdown and instrumentation connections, recirculation connections (Unit 1), and secondary shell drain connections, secondary handhole and inspection ports in treated water is managed by CNP AMP B.1.14, "Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD." The project team evaluation of this program is documented in Section 7.1.9 of this report.

The applicant made reference to a previously approved staff position, however, in the case cited, a water chemistry control program had been credited as well. The applicant did not identify the water chemistry control program for managing of this aging effect. The project team asked the applicant to provide the basis for concluding that water chemistry control is not required or identify the water chemistry control program that will be used. By letter dated August 20, 2004, the staff asked, in RAI 3.1.3-4, that the applicant explain the rationale for excluding a water chemistry control program for managing of cracking of the above components in treated water, or identify the water chemistry control program that will be used.

This is followup item 7.2.1.3-4 and will be dispositioned in the SER related to the CNP LRA (RAI 3.1.3-4).

In the CNP LRA, the applicant states that cracking of nickel-based alloy in treated water for the feedwater nozzle thermal sleeve, feedwater safe end (Unit 1), feedwater liner piston rings (Unit 2) are to be managed using the water chemistry control and inservice inspection programs. The project team finds this to be acceptable.

In the CNP LRA, the applicant states that cracking of carbon steel in treated water for the secondary manway and the feedwater elbow thermal liner (Unit 2) is managed using the inservice inspection program. The applicant made reference to a previously approved staff position, however, in the case cited, a water chemistry control program had been credited as well. No water chemistry control program was identified for managing of this aging effect.

The project team asked the applicant to provide the basis for concluding that water chemistry control is not required or identify the water chemistry control program that will be used. By letter dated August 20, 2004, the staff asked, in RAI 3.1.3-4, that the applicant explain the rationale for excluding a water chemistry control program for managing of cracking of the above components in treated water, or identify the water chemistry control program that will be used.

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D.C. Cook Audit & Review Report This is followup item 7.2.1.3-5 and will be dispositioned in the SER related to the CNP LRA (RAI 3.1.3-4).

In the CNP LRA, the applicant states that cracking of carbon steel bolting of the secondary manway, handhole, recirculation port (Unit 1), and inspection port closure in ambient air is managed using the inservice inspection program. Although a precedent was cited, the project team was not able to confirm its applicability. For the component referenced, the GALL Report recommends the use of a program consistent with the bolting integrity program (GALL AMP XI.M18).

The project team asked the applicant to explain the rationale for excluding this bolting material from the scope of CNP LRA AMP B.1.2, Bolting and Torquing Activities, or confirm that it is managed using this program. By letter dated August 20, 2004, the staff asked, in RAI 3.1.3-1, that the applicant explain the rationale for excluding carbon steel bolting of the secondary manway, handhole, recirculation port (Unit 1), and inspection port closure in ambient air from the scope of CNP AMP B.1.2, Bolting and Torquing Activities, or confirm that it is managed using this program. This is followup item 7.2.1.3-6 and will be dispositioned in the SER related to the CNP LRA (RAI 3.1.3-1).

In the CNP LRA, the applicant states that loss of material from the stainless steel steam flow restrictors (Unit 1) in treated water is to be managed using the water chemistry control program.

In the CNP LRA, the applicant states that cracking of the stainless steel steam flow restrictors (Unit 1) in treated water will be managed using water chemistry control and in-service inspection programs. During the audit, the project team asked the applicant how the inspection would be performed. By letter dated April 23, 2004 (ML041270484), the applicant stated that ISI should not be credited for the steam flow restrictors. On the basis of industry and plant-specific operating experience, the project team concludes that the water chemistry control program will be acceptable for the management cracking of the steam flow limiter.

All other AMRs assigned to the project team in Tables 3.1.2-1 through 3.1.2-5 were evaluated.

Those that were not accepted, as evaluated and documented above, were evaluated by the DE staff and are discussed in Section 3.0 of the SER related to the CNP LRA.

7.2.2 CNP LRA Section 3.2 - Aging Management of Engineered Safety Features Systems In CNP LRA Section 3.2, the applicant provides the results of its AMRs for components of the engineered safety features systems.

In CNP LRA Tables 3.2.2-1 through 3.2.2-5 (Table 2s), the applicant provides a summary of the AMRs for component types associated with the following systems: (1) emergency core cooling, (2) containment spray, (3) containment cooling, (4) containment penetrations, and (5) containment equalization/hydrogen skimmer. The summary information for each component type includes: intended function, material, environment, aging effect requiring management, AMPs, the GALL Report Volume 2 item, cross reference to CNP LRA Table 3.2.1 (Table 1),

and generic and plant-specific notes related to consistency with the GALL Report.

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D.C. Cook Audit & Review Report Also, the applicant identifies for each component type in CNP LRA Table 3.2.1 (Table 1) those components where further evaluation is recommended, those for which no further evaluation is required, and those that are not applicable to CNP together with the basis for their exclusion.

Additionally, the applicant identifies in CNP LRA Tables 3.2.2-1 through 3.2.2-5, which AMR results it considers to be consistent with the GALL Report (table column Notes A through E) and which it justifies on a different basis.

The AMRs that are within the scope of the project team audit and review are identified on copies of CNP LRA Tables 3.2.2-1 through 3.2.2-5 included as an appendix to the CNP audit and review plan.

The project team conducted its audit and review in accordance with SRP-LR Section 3.2.3 and the CNP audit and review plan.

7.2.2.1 Aging Management Evaluations That Are Consistent With the GALL Report, for Which No Further Evaluation Is Required For aging management evaluations that the applicant states are consistent with the GALL Report and for which further evaluation is not recommended, the project team conducted its audit and review to determine if the applicant's reference to the GALL Report in the CNP LRA is acceptable.

The project team reviewed the CNP LRA to confirm that the applicant (1) provides a brief description of the system, components, materials, and environment; (2) states that the applicable aging effects have been reviewed and are evaluated in the GALL Report; and (3) identifies those aging effects for the engineered safety features system components that are subject to an AMR.

On the basis of its audit and review, the project team determined that for AMRs not requiring further evaluation, as identified in CNP LRA Table 3.2.1 (Table 1), the applicant's references to the GALL Report are acceptable and no further project team review is required.

The project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.2.2 Aging Management Evaluations That Are Consistent With the GALL Report, for Which Further Evaluation Is Recommended For some line items consistent with the GALL Report in CNP LRA Tables 3.2.2-1 through 3.2.2-5, the GALL Report recommends further evaluation. When further evaluation is recommended, the project team reviewed these further evaluations provided in CNP LRA Section 3.2.2.2 against the criteria provided in SRP-LR Section 3.2.2.2. The following provides the project team's assessments of these evaluations. These project team assessments are applicable to each Table 2 line item in Section 3.2 citing the item in Table 1.

The CNP LRA sections identified in CNP LRA Table 3.2.1 for which further evaluation is recommended are discussed below.

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D.C. Cook Audit & Review Report 7.2.2.2.1 Cumulative Fatigue Damage (CNP LRA Section 3.2.2.2.1)

CNP LRA Section 3.2.2.2.1 is reviewed by the NRR DE staff and addressed in Section 4 of the SER related to the CNP LRA.

7.2.2.2.2 Loss of Material Due to General Corrosion (CNP LRA Section 3.2.2.2.2)

In CNP LRA Section 3.2.2.2.2, the applicant addresses loss of material due to general corrosion that could occur in the containment spray, containment isolation valves and associated piping, and the external surfaces of carbon steel components.

SRP-LR Section 3.2.2.2.2 states that loss of material due to general corrosion could occur in the containment spray, containment isolation valves and associated piping, and the external surfaces of carbon steel components. The GALL Report recommends further evaluation on a plant-specific basis to ensure that the aging effect is adequately managed.

The applicant states, in CNP LRA, that the plant-specific program CNP AMP B.1.38, "System Walkdown," is credited with managing the aging effect of loss of material due to general corrosion on external surfaces of carbon steel components in the containment penetrations system. The applicant also states that there are no carbon steel components in the containment spray system and the ECCS. In CNP LRA Table 3.2.1, Item Number 3.2.1-10, the applicant also states that loss of material due to general corrosion on external surfaces of carbon steel components is managed by the system walkdown program. The project team evaluation of this program is documented in Section 7.1.29 of this report.

On the basis of its review of the system walkdown program, the project team finds that the applicant has appropriately evaluated AMR results involving management of the loss of material due to general corrosion, as recommended in the GALL Report.

7.2.2.2.3 Local Loss of Material Due to Pitting and Crevice Corrosion (CNP LRA Section 3.2.2.2.3)

In CNP LRA Section 3.2.2.2.3, the applicant addresses local loss of material from pitting and crevice corrosion that could occur in the containment spray components, containment isolation valves and associated piping, and ECCS.

SRP-LR Section 3.2.2.2.3 states that local loss of material from pitting and crevice corrosion could occur in the containment spray components, containment isolation valves and associated piping, and ECCS. The GALL Report recommends further evaluation to ensure that the aging effect is adequately managed.

The applicant, in the CNP LRA, credits CNP AMP B.1.40.1, "Water Chemistry Control -

Primary and Secondary Water Chemistry Control"; CNP AMP B.1.39, "Wall Thinning Monitoring"; and CNP AMP B.1.13, "Containment Leak Rate" with managing the aging effect of loss of material due to pitting and crevice corrosion. The project teams evaluation of these AMPs is documented in Sections 7.1.31, 7.1.30, and 7.1.3 of this report, respectively.

SRP-LR Subsection 3.2.2.2.3.2 requires verification of the programs' effectiveness and identifies one-time inspections as an acceptable method. The wall thinning monitoring program 165

D.C. Cook Audit & Review Report includes periodic (rather than one-time) inspection of appropriately selected sample components, which is acceptable to the project team.

On the basis of its review of the water chemistry, wall thinning monitoring, and containment leak rate programs, the project team finds that the applicant has appropriately evaluated AMR results involving management of the loss of material due to pitting and crevice corrosion, as recommended in the GALL Report.

7.2.2.2.4 Local Loss of Material Due to Microbiologically Influenced Corrosion (CNP LRA Section 3.2.2.2.4)

In CNP LRA Section 3.2.2.2.4, the applicant addresses local loss of material due to MIC.

SRP-LR Section 3.2.2.2.4 states that local loss of material due to MIC could occur in containment isolation valves and associated piping in systems that are not addressed in other chapters of the GALL Report. The GALL Report recommends further evaluation to ensure that the aging effect is adequately managed.

The applicant, in CNP LRA, credits CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control"; CNP AMP B.1.39, "Wall Thinning Monitoring"; and CNP AMP B.1.13, "Containment Leak Rate" with managing the aging effect of loss of material due to MIC. The project team evaluation of these programs are documented in Sections 7.1.31, 7.1.30, and 7.1.3 of this report, respectively.

On the basis of its review of the water chemistry, wall thinning monitoring, and containment leak rate programs, the project team finds that the applicant has appropriately evaluated AMR results involving management of the loss of material due to MIC, as recommended in the GALL Report.

7.2.2.2.5 Changes in Material Properties Due to Elastomer Degradation (CNP LRA Section 3.2.2.2.5)

In CNP LRA Section 3.2.2.2.5, the applicant addresses the changes in properties due to elastomer degradation that could occur in seals associated with the standby gas treatment system ductwork and filters.

The applicant states, in the CNP LRA, that this aging effect is applicable to boiling water reactors (BWRs) only and does not require management at CNP.

On the basis that this issue applies BWRs only, the project team finds that this aging effect is not applicable to CNP.

7.2.2.2.6 Local Loss of Material Due to Erosion (CNP LRA Section 3.2.2.2.6)

In CNP LRA Section 3.2.2.2.6, the applicant addresses local loss of material due to erosion that could occur in the HPSI miniflow orifice.

SRP-LR Section 3.2.2.2.6 states that local loss of material due to erosion could occur in the HPSI pump miniflow orifice. This aging mechanism and its effect will apply only to pumps that 166

D.C. Cook Audit & Review Report are normally used as charging pumps in the chemical and volume control systems. The GALL Report recommends further evaluation to ensure that the aging effect is adequately managed.

The applicant states, in the CNP LRA, that the chemical and volume control charging pumps are used for RCS makeup at CNP and not the HPSI pumps. The applicant credits CNP AMP B.1.37, "System Testing," for managing this aging effect for the charging pump miniflow orifice.

The project teams evaluation of this program is documented in Section 7.1.28 of this report.

On the basis of its review of the system testing program, the project team finds that the applicant has appropriately evaluated AMR results involving management of the loss of material due to erosion, as recommended in the GALL Report.

7.2.2.2.7 Buildup of Deposits Due to Corrosion (CNP LRA Section 3.2.2.2.7)

In CNP LRA Section 3.2.2.2.7, the applicant addresses the plugging of components due to general corrosion that could occur in the spray nozzles and flow orifices of the drywell and suppression chamber spray system.

The applicant states, in the CNP LRA, that this aging effect is applicable to BWRs only and does not require management at CNP.

On the basis that this issue applies BWRs only, the project team finds that this aging effect is not applicable to CNP.

7.2.2.2.8 Quality Assurance for Aging Management of Non-safety-related Components (CNP LRA Section 3.2.2.2.8)

CNP LRA Section 3.2.2.2.8 is reviewed by NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.2.2.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report In CNP LRA Tables 3.2.2-1 through 3.1.2-5, the project team reviewed additional details of the results of the AMRs for material, environment, aging effect requiring management, and AMP combinations that are not consistent with the GALL Report.

7.2.2.3.1 Containment Spray System Summary of Aging Management (CNP LRA Table 3.2.2-1)

The project team reviewed Table 3.2.2-1 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the containment spray system component groups.

For carbon steel bolting exposed to air, loss of mechanical closure integrity is not addressed in the GALL Report. In the CNP LRA, for loss of mechanical closure integrity in carbon steel bolting exposed to ambient air, the applicant proposes to use CNP AMP B.1.4, "Boric Acid Corrosion Prevention" and CNP AMP B.1.38, "System Walkdown." The DE staff's evaluation of the boric acid corrosion prevention program is documented in Section 3 of the SER related to 167

D.C. Cook Audit & Review Report the CNP LRA. The project teams evaluation of the system walkdown program is documented in Section 7.1.29 of this report.

The project team reviewed existing procedures as well as the proposed enhancements related to evaluating the extent of degradation and criteria for initiating corrective actions. On the basis that the program is to include detailed guidance for inspecting and evaluating the material condition of SCs within the scope of this program, and that the guidance includes specific parameters to be monitored and criteria to be used for evaluating their condition, the project team finds that it can be an acceptable way to manage this aging effect when supplemented by an acceptable BAC prevention program.

In the CNP LRA the applicant states that no aging management program is needed to address aging effects on stainless steel in an environment of air. The applicant did not identify an aging effect for stainless steel components exposed to air (either internal or external). Component types identified included bolting, eductor, heater housing (RWST electric heater), manifold (piping), orifice, piping, pump casing, spray nozzle, tank, thermowell, tubing (instrument piping),

and valves. Stainless steel is not identified in the GALL Report as a material associated with some of these components, and air is not a defined environment for the others.

Loss of material may be an applicable aging effect where stainless steel components under wet conditions if the components have creviced areas that may be exposed to fluids or have areas where stagnant fluid may be present. The ambient environment for containment spray components does not contain contaminants of sufficient concentration to cause aging effects that require management. Based on industry experience for this combination of material and environment, the project team finds that no aging management program is required to manage loss of material from stainless steel components exposed to air at CNP.

In the CNP LRA the applicant states that loss of material from stainless steel components in treated, borated water is to be managed using the water chemistry control program.

Component types identified include eductor, heater housing (RWST electric heater), heat exchanger tubes, manifold (piping), orifice, piping, pump casing, tank, thermowell, tubing (instrument piping), and valves. On the basis of industry experience that loss of material from stainless steel components in chemically treated, borated water are not significant, the project team finds that management of this aging effect using a water chemistry control program that is consistent with the GALL Report is sufficient.

In the CNP LRA, the applicant states that fouling of stainless steel heater exchanger tubes in treated water will be managed using water chemistry control. The applicant cites a precedent that implies that CNP AMP B.1.40.3, "Water Chemistry Control - Auxiliary Systems Water Chemistry Control" applies. The project teams evaluation of this program is documented in Section 7.1.33 of this report. The GALL Report recommends managing loss of material using a program consistent with GALL AMP XI.M21, "Closed-Cycle Cooling Water System," which more closely corresponds to CNP AMP B.1.40.2, "Water Chemistry Control - Closed Cooling Water Chemistry Control." The project teams evaluation of this program is documented in Section 7.1.32 of this report. On the basis that these water chemistry control programs are consistent with the recommendations of the GALL Report and that each one has been determined to allow management of fouling, the project team finds that fouling will be adequately managed by the water chemistry control programs.

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D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that fouling from stainless steel containment spray heat exchanger tubes (internal) in treated, borated water is managed using the water chemistry control program. On the basis that the water chemistry control program is consistent with the recommendations of the GALL Report and allows management of fouling, the project team finds that fouling will be adequately managed by the water chemistry control program.

In the CNP LRA, the applicant states that stainless steel piping and valve component types in a nitrogen gas environment are not subject to effects requiring aging management. Based on industry experience with this combination of material and environment the project team finds it to be acceptable.

7.2.2.3.2 Containment Isolation System Summary of Aging Management (CNP LRA Table 3.2.2-2)

The project team reviewed Table 3.2.2-2 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the containment isolation system component groups.

In the CNP LRA, for loss of mechanical closure integrity in carbon steel bolting exposed to ambient air, the applicant proposes to use CNP AMP B.1.3, "Bolting and Torquing Activities,"

CNP AMP B.1.4, "Boric Acid Corrosion Prevention," and CNP AMP B.1.38, "System Walkdown." The DE staff's evaluation of the bolting and torquing activities and boric acid corrosion prevention programs is documented in Section 3 of the SER related to the CNP LRA.

The project teams evaluation of the system walkdown program is documented in Section 7.1.29 of this report.

The project team reviewed existing procedures as well as the proposed enhancements related to evaluating the extent of degradation and criteria for initiating corrective actions. On the basis that the program is to include detailed guidance for inspecting and evaluating the material condition of SCs within the scope of this program, and that the guidance includes specific parameters to be monitored and criteria to be used for evaluating their condition, the project team finds that it can be an acceptable way to manage this aging effect when supplemented by acceptable bolting and torquing activities and BAC prevention programs.

In the CNP LRA, the applicant states that no aging management program is needed to address aging effects on stainless steel in air (including condensation). This includes bolting, piping, and valve component types. Loss of material may be an applicable aging effect where stainless steel components under wet conditions if the components have creviced areas that may be exposed to fluids or have areas where stagnant fluid may be present. The environment for containment isolation components does not contain contaminants of sufficient concentration to cause aging effects in stainless steel that require management. Based on industry experience for this combination of material and environment, the project team finds that no program is required to manage loss of material from stainless steel components exposed to air at CNP.

The applicant, in the CNP LRA, states that loss of material exposed to lube oil is managed using CNP AMP B.1.23, "Oil Analysis," which is a plant-specific program. This applies to brass, carbon steel, cast iron, copper alloy, and stainless steel. (Glass is also exposed to lube oil, but no effect subject to aging management was identified for this material.)

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D.C. Cook Audit & Review Report The oil analysis program analyzes for contaminants, anomalous particulate, and moisture. In addition, beneficial additives are maintained in lubricating oils. On the basis of operating experience at CNP, the project team concluded that this preventive program is effective in the management of aging effects in this environment and finds the associated AMRs to be acceptable.

In the CNP LRA, the applicant states that cracking of stainless steel components in treated, borated water >270EF will be managed using water chemistry control. This is proposed for piping and valve component types. The GALL Report suggests a plant-specific program.

While the water chemistry control program is expected to prevent and mitigate aging effects, the project team finds that this may not be sufficient.

The project team asked the applicant to justify the absence of an inspection or monitoring program to confirm the effectiveness of water chemistry control in managing this aging effect or identify the program that will be used to do so. In related RAI B.1.41-2, the staff asked the applicant to provide a list of components, material types, environments, and aging effects that will be inspected using CNP AMP B.1.41, Water Chemistry Control - Chemistry One-time Inspection, and to justify that the components selected are an adequate sample size to verify the effective of the water chemistry program for each aging effect to be managed. This is followup item 7.2.2.3-1 and will be dispositioned in the SER Section 3 related to the CNP LRA (RAI B.1.41-2).

Loss of material from components of stainless steel in treated, borated water was not addressed in the GALL Report for the piping and valve component types. The applicant proposes to manage this aging effect using the water chemistry control program. On the basis of industry experience that loss of material from stainless steel components in chemically treated, borated water are not significant, the project team finds that management of this aging effect using a water chemistry control program that is consistent with the GALL Report is sufficient.

7.2.2.3.3 Emergency Core Cooling System Summary of Aging Management (CNP LRA Table 3.2.2-3)

The project team reviewed Table 3.2.2-3 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the emergency core cooling system component groups.

In the CNP LRA, the applicant states that loss of mechanical closure integrity in high-temperature or high-pressure systems, carbon steel bolting exposed to ambient air will be managed using CNP AMP B.1.2, "Bolting and Torquing Activities," CNP AMP B.1.4, "Boric Acid Corrosion Prevention," and CNP AMP B.1.38, "System Walkdown." The DE staff's evaluation of bolting and torquing activities and the boric acid corrosion prevention program is documented in Section 3 of the SER related to the CNP LRA. The project team evaluation of the system walkdown program is documented in Section 7.1.29 of this report.

The project team reviewed existing procedures as well as the proposed enhancements related to evaluating the extent of degradation and criteria for initiating corrective actions. On the basis that the program is to include detailed guidance for inspecting and evaluating the material condition of SCs within the scope of this program, and that the guidance includes specific parameters to be monitored and criteria to be used for evaluating their condition, the project 170

D.C. Cook Audit & Review Report team finds that it can be an acceptable way to manage this aging effect when supplemented by an acceptable BAC prevention program.

For stainless steel exposed to ambient air, the applicant identifies no aging effects requiring management. The component types affected are bolting, flex hose, heater housing, orifice, manifold, piping, pump casing strainer housing, tank, thermowell, tubing, and valves. No aging effects are identified for piping and valves exposed to nitrogen (gas). On the basis that no aging effects requiring management are identified and this is consistent with industry experience, the project team finds the absence of an AMP for stainless steel components exposed to ambient air and nitrogen to be acceptable.

In the CNP LRA, the applicant states that loss of material from carbon steel filter housing, heat exchanger shell, piping, pump casing, and tank; copper-alloy heat exchanger shell and tubes, piping, and valves; stainless steel piping; and cast iron pump casing component types are managed using CNP AMP.1.23, "Oil Analysis." The project team evaluation of this program is documented in Section 7.1.17. On the basis that the oil analysis program maintains oil systems free of contaminants (primarily water and particles), the project team finds that this program adequately manages loss of material for components exposed to lubricating oil.

In the CNP LRA, the applicant states that loss of material from components of stainless steel in treated, borated water was not addressed in the GALL Report for the flex hose, heat exchanger tubes, heater housing, manifold, orifice, piping, pump casing, strainer housing, tank, thermowell, tubing, or valve component types; nor for pump casing, and tanks clad with stainless steel. The applicant proposes to manage this aging effect using the water chemistry control program. On the basis of industry experience that loss of material from stainless steel components in chemically treated, borated water are not significant, the project team finds that management of this aging effect using a water chemistry control program that is consistent with the GALL Report is sufficient.

The applicant did not identify any aging effect requiring aging management for copper alloy heat exchanger, piping, and valve component types exposed to ambient air in the CNP LRA.

Based on industry experience for this combination of material and environment, the project team finds this to be acceptable.

In the CNP LRA, the applicant states that cracking of stainless steel components in treated, borated water >270EF will be managed using water chemistry control. This is proposed for heat exchanger tubes, manifold, piping, pump casing, strainer housing, thermowell, tubing, and valve component types. The GALL Report suggests a plant-specific program. While the water chemistry control program is expected to prevent and mitigate aging effects, the project team finds that this may not be sufficient.

The project team asked the applicant to justify the absence of an inspection or monitoring program to confirm the effectiveness of water chemistry control in managing this aging effect or identify the program that will be used to do so. In related RAI B.1.41-2, the staff asked the applicant to provide a list of components, material types, environments, and aging effects that will be inspected using CNP AMP B.1.41, Water Chemistry Control - Chemistry One-time Inspection, and to justify that the components selected are an adequate sample size to verify the effective of the water chemistry program for each aging effect to be managed. This is 171

D.C. Cook Audit & Review Report followup item 7.2.2.3-2 and will be dispositioned in the SER Section 3 related to the CNP LRA (RAI B.1.41-2).

7.2.2.3.4 Containment Equalization/Hydrogen Skimmer System Summary of Aging Management (CNP LRA Table 3.2.2-4)

Table 3.2.2-4 of the CNP LRA summarizes the results of AMR evaluations in the SRP-LR for the containment equalization/hydrogen skimmer system component groups. The issue that the project team identified during its line item review is presented below.

In the CNP LRA, the applicant states that loss of mechanical closure integrity carbon steel bolting exposed to ambient air will be managed using CNP AMP B.1.4, "Boric Acid Corrosion Prevention," and CNP AMP B.1.38, "System Walkdown." The DE staff's evaluation of the boric acid corrosion prevention program is documented in Section 3 of the SER related to the CNP LRA. The project team evaluation of the system walkdown program is documented in Section 7.1.29 of this report.

The project team reviewed existing procedures as well as the proposed enhancements related to evaluating the extent of degradation and criteria for initiating corrective actions. On the basis that the program is to include detailed guidance for inspecting and evaluating the material condition of SCs within the scope of this program, and that the guidance includes specific parameters to be monitored and criteria to be used for evaluating their condition, the project team finds that it can be an acceptable way to manage this aging effect when supplemented by an acceptable BAC prevention program.

In the CNP LRA, the applicant identifies no aging effects requiring management for stainless steel bolting or copper-alloy heat exchanger component types exposed to ambient air. On the basis that no aging effects requiring management are identified and this is consistent with industry experience, the project team finds that the absence of an AMP for stainless steel components exposed to ambient air and nitrogen to be acceptable.

7.2.3 CNP LRA Section 3.3 - Aging Management of Auxiliary Systems In CNP LRA Section 3.3, the applicant provides the results of its AMRs for components for the auxiliary systems.

In CNP LRA Tables 3.3.2-1 through 3.3.2-11 (Table 2s), the applicant provides a summary of the AMRs for component types associated with the following systems: (1) spent fuel pool systems; (2) essential service water system; (3) component cooling water system; (4) compressed air system; (5) chemical and volume control system; (6) heating, ventilation and air conditioning systems; (7) fire protection system; (8) emergency diesel generator; (9) security diesel; (10) post-accident containment hydrogen monitoring system; and (11) miscellaneous systems in scope for 10 CFR 54.4(a)(2). The summary information for each component type includes: intended function, material, environment, aging effect requiring management, AMPs, the GALL Report Volume 2 item, cross reference to CNP LRA Table 3.3.1 (Table 1), and generic and plant-specific notes related to consistency with the GALL Report.

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D.C. Cook Audit & Review Report Also, the applicant identifies for each component type in CNP LRA Table 3.3.1 (Table 1) those components where further evaluation is recommended, those for which no further evaluation is required, and those that are not applicable to CNP, together with the basis for their exclusion.

Additionally, the applicant identifies in CNP LRA Tables 3.3.2-1 through 3.3.2-11, which AMR results it considers to be consistent with the GALL Report (table column Notes A through E) and which it justifies on a different basis.

The AMRs that are within the scope of the project team audit and review are identified on copies of CNP LRA Tables 3.3.2-1 through 3.3.2-11 included as an appendix to the CNP audit and review plan.

The project team conducted its audit and review in accordance with SRP-LR Section 3.3.3 and the CNP audit and review plan.

7.2.3.1 Aging Management Evaluations That Are Consistent with the GALL Report, for Which No Further Evaluation Is Required For aging management evaluations that the applicant states are consistent with the GALL Report and for which further evaluation is not recommended, the project team conducted its audit and review to determine if the applicant's reference to the GALL Report in the CNP LRA is acceptable.

The project team reviewed the CNP LRA to confirm that the applicant (1) provides a brief description of the system, components, materials, and environment; (2) states that the applicable aging effects have been reviewed and are evaluated in the GALL Report; and (3) identifies those aging effects for the auxiliary system components that are subject to an AMR.

7.2.3.1.1 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced Corrosion In the CNP LRA, the applicant states that loss of material and cracking for stainless steel, carbon steel, and copper alloy exposed to treated water in the component cooling water system will be managed with CNP AMP B.1.40.2, "Water Chemistry Control - Closed Cooling Water Chemistry Control." The applicant states that this program is consistent with GALL AMP XI.M21, "Closed-Cycle Cooling Water System," with exceptions. The project team evaluation of this program is documented in Section 7.1.32 of this report.

The GALL Report recommends, in addition to water chemistry control, performance monitoring and functional testing of components managed with this program. The project team asked the applicant to provide justification or a commitment to apply an appropriate testing and/or monitoring program to manage these aging effects. In related RAI B.1.41-2, the staff asked the applicant to provide a list of components, material types, environments, and aging effects that will be inspected using CNP AMP B.1.41, Water Chemistry Control - Chemistry One-time Inspection, and to justify that the components selected are an adequate sample size to verify the effective of the water chemistry program for each aging effect to be managed. This is followup item 7.2.3.1-1 and will be dispositioned in the SER Section 3 related to the CNP LRA (RAI B.1.41-2).

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D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that loss of material from copper alloy components exposed to raw water in the HVAC systems will be managed using CNP AMP B.1.29, "Service Water System Reliability." The project team evaluation of this program is documented in Section 7.1.21 of this report. The GALL Report suggests the use of programs consistent with GALL AMP XI.M20, "Open-Cycle Cooling Water System and GALL AMP XI.M33, "Selective Leaching of Materials. The latter program recommends both visual inspection and hardness testing to monitor this aging effect. The applicant has not identified how the service water system reliability program will adequately monitor this aging effect.

By letter dated May 6, 2004 (ML0041280528), the staff asked the applicant, in RAI 3.3.2-2, to provide justification for excluding a hardness measurement from the service water system reliability program to detect selective leaching. This is followup item 7.2.3.1-2 and will be dispositioned in the SER for the CNP LRA as RAI 3.3.2-2.

7.2.3.1.2 Loss of Material Due to General, Pitting, Crevice, and Galvanic Corrosion, Microbiologically Influenced Corrosion and Biofouling; Buildup of Deposits Due to Biofouling The applicant credits the service water system reliability program with managing loss of material in stainless steel, elastomer, carbon steel, copper alloy, and cast iron exposed to fresh, raw water (internal) in the essential service water system. The CNP AMP takes exception to the GALL AMP requirements concerning the lining or coating of components. The applicant states that components are lined or coated only when necessary to protect underlying metal surfaces. The project team found this acceptable. However, in Section B.1.29 of the CNP LRA (Ref. 2), loss of material is indicated only for the enhancement of the program for the 8-inch expansion joints in the ESW supply lines to the emergency diesel generator heat exchangers, and not for any other component or material.

On the basis of its audit and review, the project team determined that for all other AMRs not requiring further evaluation, as identified in the CNP LRA Table 3.3.1 (Table 1), the applicant's references to the GALL Report are acceptable and no further project team review is required.

The project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.3.2 Aging Management Evaluations That Are Consistent with the GALL Report, for Which Further Evaluation Is Recommended For some line items consistent with the GALL Report in the CNP LRA Tables 3.3.2-1 through 3.3.2-11, the GALL Report recommends further evaluation. When further evaluation is recommended, the project team reviewed these further evaluations provided in CNP LRA Section 3.3.2.2 against the criteria provided in the SRP-LR Section 3.3.2.2. The following provides the project team assessments of these evaluations. These project team assessments are applicable to each Table 2 line item in Section 3.3, citing the item in Table 1.

The CNP LRA sections identified in CNP LRA Table 3.3.1, for which further evaluation is recommended, are discussed below.

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D.C. Cook Audit & Review Report 7.2.3.2.1 Loss of Material Due to General, Pitting, and Crevice Corrosion (CNP LRA Section 3.3.2.2.1)

In CNP LRA Section 3.3.2.2.1, the applicant addresses loss of material in components of the spent fuel pool and cleanup system.

The applicant states that the spent fuel pool cooling components do not provide any intended function within the scope of license renewal. Pool inventory, which assures cooling, is assured by aging management of the fuel pool. This is evaluated as part of the auxiliary building in Section 7.2.5.2 of this report.

Because the spent fuel cooling components do provide any intended function that requires aging management, the project team finds this to be acceptable.

The project team finds that the applicant has demonstrated that the effects of aging for components of the spent fuel pool system subject to loss of material will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.3.2.2 Hardening and Cracking or Loss of Strength Due to Elastomer Degradation or Loss of Material Due to Wear (CNP LRA Section 3.3.2.2.2)

In CNP LRA Section 3.3.2.2.2, the applicant addresses the potential for degradation of elastomers in collars and seals in spent fuel cooling systems and ventilation systems.

SRP-LR Section 3.3.2.2.2 states that hardening and cracking due to elastomer degradation could occur in elastomer linings of the filter, valve, and ion exchangers in spent fuel pool cooling and cleanup systems. Hardening and loss of strength due to elastomer degradation could occur in the collars and seals of the duct and in the elastomer seals of the filters in the control room area, auxiliary and radwaste area, and primary containment heating ventilation systems and in the collars and seals of the duct in the diesel generator building ventilation system. Loss of material due to wear could occur in the collars and seals of the duct in the ventilation systems. The GALL Report recommends further evaluation to ensure that these aging effects are adequately managed.

The applicant states that the spent fuel pool system contains no components with elastomers that are subject to an AMR. For the ventilation systems, the plant-specific CNP AMP B.1.25, "Preventive Maintenance" is used to manage degradation of elastomers. The project team evaluation of this program is documented in Section 7.1.19. For other systems, management of elastomer degradation is provided by the one of three programs: the PM program; CNP AMP B.1.29, "Service Water System Reliability"; or CNP AMP B.1.11, "Fire Protection." The project team evaluation of these programs is documented in Sections 7.1.5 and 7.1.6 (for fire protection) and Section 7.1.21 (for service water system reliability).

The project team requested clarification on the method(s) used to monitor a change in material properties of elastomers in the ventilation systems. Material properties that could affect the performance of elastomers (e.g., hardness, flexibility) are not directly measured. By letter dated August 20, 2004 (ML042330355), in RAI 3.3.2-3, the project team asked the applicant to provide a technical basis for the conclusion that degradation of elastomers will be detected 175

D.C. Cook Audit & Review Report before a loss of intended function of the component or justify why the elastomers are not subject to hardening and flexibility aging effects. This followup item 7.2.3.2-1 will be dispositioned in the SER related to the CNP LRA as RAI 3.3.2-3.

7.2.3.2.3 Cumulative Fatigue Damage (CNP LRA Section 3.3.2.2.3)

CNP LRA Section 3.3.2.2.3 is reviewed by the NRR DE staff and addressed in Section 4 of the SER related to the CNP LRA.

7.2.3.2.4 Crack Initiation and Growth Due to Cracking or Stress Corrosion Cracking (CNP LRA Section 3.3.2.2.4)

The project team reviewed CNP LRA Section 3.3.2.2.4 against the criteria in SRP-LR Section 3.3.2.2.4.

In CNP LRA Section 3.3.2.2.4, the applicant addresses the potential for cracking in the high-pressure pumps of the chemical and volume control system.

SRP-LR Section 3.3.2.2.4 addresses crack initiation and growth due to cracking in the high-pressure pump in the chemical and volume control system. The GALL Report recommends further evaluation to ensure that these aging effects are adequately managed.

The applicant uses the plant-specific CNP AMP B.1.25, "Preventive Maintenance" to manage cracking of the charging pump casings. The project team evaluation of this program is documented in Section 7.1.19 of this report. This program was evaluated as an acceptable response to NRC Information Notice 80-38 for monitoring this aging effect and on that basis, it is acceptable to the project team.

The project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.3.2.5 Loss of Material Due to General, Microbiologically Influenced, Pitting, and Crevice Corrosion (CNP LRA Section 3.3.2.2.5)

In CNP LRA Section 3.3.2.2.5, the applicant addresses the loss of material from corrosion that could occur on internal and external surfaces of components exposed to air and the associated range of atmospheric conditions.

SRP-LR Section 3.3.2.2.5 states that loss of material due to general, pitting, and crevice corrosion could occur in the piping and filter housing and supports in the control room area, the auxiliary and radwaste area, the primary containment heating and ventilation systems, in the piping of the diesel generator building ventilation system, in the above ground piping and fittings, valves, and pumps in the diesel fuel oil system and in the diesel engine starting air, combustion air intake, and combustion air exhaust subsystems in the EDG system. Loss of material due to general, pitting, crevice, and MIC could occur in the duct fittings, access doors, and closure bolts, equipment frames and housing of the duct; loss of material due to pitting and crevice corrosion could occur in the heating/cooling coils of the air handler heating/cooling; and loss of material due to general corrosion could occur on the external surfaces of all carbon steel 176

D.C. Cook Audit & Review Report SCs, including bolting exposed to operating temperatures less than 212EF in the ventilation systems. The GALL Report recommends further evaluation to ensure that these aging effects are adequately managed.

The applicant credits CNP AMP B.1.38, "System Walkdown," evaluated in Section 7.1.29 of this report; CNP AMP B.1.37, "System Testing," evaluated in Section 7.1.28; CNP AMP B.1.29, "Service Water System Reliability," evaluated in Section 7.1.21; and CNP AMP B.1.25, "Preventive Maintenance," evaluated in Section 7.1.19 for managing loss of material from surfaces exposed to air and outdoor air. CNP AMP B.1.11, "Fire Protection," is used to manage loss of material for internal surfaces of the fire protection system. The project team evaluation of fire protection programs is documented in Sections 7.1.5 and 7.1.6 of this report.

The project team reviewed CNP operating experience and confirmed that sufficient opportunities for inspection had been exploited by the applicant. On the basis that inspection guidance provided confidence that the presence and extent of these aging effects would be identified, the project team finds management of this aging effect to be acceptable.

The project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.3.2.6 Loss of Material Due to General, Galvanic, Pitting, and Crevice Corrosion (CNP LRA Section 3.3.2.2.6)

In CNP LRA Section 3.3.2.2.6, the applicant addresses further evaluation of programs to manage loss of material in the RCP oil collection system to verify the effectiveness of the fire protection program.

SRP-LR Section 3.3.2.2.6 states that loss of material due to general, galvanic, pitting, and crevice corrosion could occur in tanks, piping, valve bodies, and tubing in the RCP oil collection system in fire protection. The fire protection program relies on a combination of visual and volumetric examinations in accordance with the guidelines of 10 CFR Part 50, Appendix R and Branch Technical Position 9.5-1 to manage loss of material from corrosion. However, corrosion may occur at locations where water from washdowns may accumulate. Therefore, verification of the effectiveness of the program should be performed to ensure that corrosion is not occurring.

The GALL Report recommends further evaluation of programs to manage loss of material due to general, galvanic, pitting, and crevice corrosion to verify the effectiveness of the program. A one-time inspection of the bottom half of the interior surface of the tank of the RCP oil collection system is an acceptable method to ensure that corrosion is not occurring and that the component's intended function will be maintained during the period of extended operation. This would be provided by a program consistent with GALL AMP XI.M32, "One-Time Inspection."

In the CNP LRA, the applicant states that the plant-specific CNP AMP B.1.25, "Preventive Maintenance," consistent with GALL Report with enhancements and AMP B.1.4, Boric Acid Corrosion Prevention, will be used to manage loss of material in lieu of the one-time inspection program. The project team evaluation of the preventive maintenance program is documented in Sections 7.1.19 of this report. The NRR DE staff's evaluation of the boric acid corrosion 177

D.C. Cook Audit & Review Report program is documented in Section 3.0 of the SER related to the CNP LRA. On the basis that the preventive maintenance and boric acid corrosion prevention programs will afford an opportunity to inspect similar material in this environment, the project team finds that these programs will allow adequate verification of the effectiveness of the management of loss of material due to general, pitting, galvanic, and crevice corrosion.

The project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.3.2.7 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced Corrosion and Biofouling (CNP LRA Section 3.3.2.2.7)

In CNP LRA Section 3.3.2.2.7, the applicant addresses further evaluation of programs to manage loss of material in the diesel fuel oil system to verify the effectiveness of the diesel fuel monitoring program.

SRP-LR Section 3.3.2.2.7 states that loss of material due to general, pitting, and crevice corrosion, microbiologically influenced corrosion (MIC), and biofouling could occur in the internal surface of tanks in the diesel fuel oil system and that loss of material due to general, pitting, and crevice corrosion and MIC could occur in the tanks of the diesel fuel oil system in the EDG system. The existing AMP relies on the fuel oil chemistry program for monitoring and control of fuel oil contamination in accordance with the guidelines of ASTM Standards D4057, D1796, D2709 and D2276 to manage loss of material due to corrosion or biofouling. Corrosion or biofouling may occur at locations where contaminants accumulate. Verification of the effectiveness of the chemistry control program should be performed to ensure that corrosion is not occurring. The GALL Report recommends further evaluation of programs to manage corrosion/biofouling to verify the effectiveness of the program. A one-time inspection of selected components at susceptible locations is an acceptable method to ensure that corrosion is not occurring and that the component's intended function will be maintained during the period of extended operation.

The GALL Report recommends programs consistent with "Fuel Oil Chemistry" (XI.M30) and "One Time Inspection" (XI.M32) for management of this aging effect.

The applicant uses CNP AMP B.1.10, "Diesel Fuel Monitoring," evaluated in Section 7.1.4 of this report, to manage loss of material for the diesel fuel oil system. This program also provides for the periodic inspection of the fuel oil tanks. The applicant takes exception to ultrasonic testing of the diesel fuel oil tank, which addresses the one-time inspection recommendation in the GALL Report.

The project team requested a basis for the exception to ultrasonic testing. An engineer on the applicant's technical staff provided the results of ultrasonic testing that had already been performed and his basis for concluding that the aging effect is being managed so as to maintain the intended function beyond the period of extended operation. After review of the data and basis, the project team finds that the applicant has already demonstrated the effectiveness of the program credited, which is an acceptable basis for the exception.

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D.C. Cook Audit & Review Report The project team finds that the diesel fuel monitoring program adequately manages the loss of material for carbon steel components in a fuel oil environment. The project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.3.2.8 Quality Assurance for Aging Management of Non-safety-related Components (CNP LRA Section 3.3.2.2.8)

CNP LRA Section 3.3.2.2.8 is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.2.3.2.9 Crack Initiation and Growth Due to Stress Corrosion Cracking and Cyclic Loading (CNP LRA Section 3.3.2.2.9)

In CNP LRA Section 3.3.2.2.9, the applicant addresses further evaluation of programs to manage cracking in the chemical and volume control system to verify the effectiveness of the water chemistry control program.

SRP-LR Section 3.3.2.2.9 states that crack initiation and growth due to SCC and cyclic loading could occur in the channel head and access cover, tubesheet, tubes, shell and access cover, and closure bolting of the regenerative heat exchanger and in the channel head and access cover, tubesheet, and tubes of the letdown heat exchanger in the chemical and volume control system. The water chemistry program relies on monitoring and control of water chemistry based on the guidelines of EPRI TR-105714, PWR Primary Water Chemistry Guidelines:

Revision 4, to manage the effects of crack initiation and growth due to SCC and cyclic loading.

Verification of the effectiveness of the chemistry control program should be performed to ensure that crack initiation and growth are not occurring. The GALL Report recommends further evaluation to manage crack initiation and growth from SCC and cyclic loading for these systems to verify the effectiveness of the water chemistry program. A one-time inspection of select components and susceptible locations is an acceptable method to ensure that crack initiation and growth are not occurring and that the component's intended function will be maintained during the period of extended operation.

The AMPs recommended by the GALL Report are "Water Chemistry" (X1.M2) and a plant-specific verification program for management of this aging effect.

The GALL Report recommends that the water chemistry program be augmented by verifying the absence of cracking due to SCC and cyclic loading, or loss of material due to pitting and crevice corrosion. The GALL Report states that an acceptable verification program is to include temperature and radioactivity monitoring of the shell side water, and eddy current testing of tubes.

In the CNP LRA, the applicant states that this aging effect will be managed using the CNP AMP B.1.40.2, "Water Chemistry Control - Closed-Cycle Cooling Water Chemistry Control,"

supplemented with CNP AMP B.1.13, "Heat Exchanger Monitoring." The project team evaluation of these programs is documented in Sections 7.1.32 and 7.1.8 of this report, respectively. The applicant also uses CNP AMP B.1.41, "Water Chemistry Control - Chemistry 179

D.C. Cook Audit & Review Report One-Time Inspection." The NRR DE staff's evaluation of the chemistry one-time inspection program is documented in Section 3.0 of the SER related to the CNP LRA.

The project team finds that the heat exchanger monitoring program provides an acceptable way to monitor the effectiveness of the water chemistry control program and therefore the management of this aging effect is acceptable.

7.2.3.2.10 Reduction of Neutron-Absorbing Capacity and Loss of Material Due to General Corrosion (CNP LRA Section 3.3.2.2.10)

In CNP LRA Section 3.3.2.2.10, the applicant addresses reduction of neutron-absorbing capacity and loss of material due to general corrosion, which could occur in the neutron absorbing sheets of the spent fuel storage rack in the spent fuel storage.

SRP-LR Section 3.3.2.2.10 states that reduction of neutron-absorbing capacity and loss of material due to general corrosion could occur in the neutron-absorbing sheets of the spent fuel storage rack in the spent fuel storage. The GALL Report recommends further evaluation to ensure that these aging effects are adequately managed.

The applicant uses CNP AMP B.1.3, "Boral Surveillance" and AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control" to manage neutron absorbing capacity and loss of material. The NRR DE staff's evaluation of the boral surveillance program is documented in Section 3.0 of the SER related to the CNP LRA and the project team evaluation of the water chemistry control program is documented in Section 7.1.31 of this report.

The project team finds that the water chemistry control program is consistent with the recommendation of the GALL Report and therefore acceptable for mitigating this aging effect.

7.2.3.2.11 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced Corrosion (CNP LRA Section 3.3.2.2.11)

In CNP LRA Section 3.3.2.2.11, the applicant addresses the potential for loss of material in buried piping of the SW and diesel fuel oil systems.

SRP-LR Section 3.3.2.2.11 states that loss of material due to general, pitting, and crevice corrosion and MIC could occur in the underground piping and fittings in the open-cycle cooling water system (SW system) and in the diesel fuel oil system. The buried piping and tanks inspection program relies on industry practice, frequency of pipe excavation, and operating experience to manage the effects of loss of material from general, pitting, and crevice corrosion and MIC. The effectiveness of the buried piping and tanks inspection program should be verified to evaluate an applicant's inspection frequency and operating experience with buried components, ensuring that loss of material is not occurring.

The AMP recommended by the GALL Report is GALL AMP XI.M34, "Buried Piping and Tanks Inspection," for management of this aging effect.

There are no buried components in the CNP essential service water system. To manage loss of material for buried components of the diesel fuel oil system, the applicant credits the CNP 180

D.C. Cook Audit & Review Report AMP B.1.6, "Buried Piping Inspection," which was evaluated by the project team as documented in Section 7.1.1 of this report. The program calls for the opportunistic inspection of buried pipe when excavated. The project team reviewed the applicant's operating history and found that the frequency of pipe excavation was sufficient to allow the applicant to manage the effects of loss of material in this manner.

The project team finds that the applicant has demonstrated that the effects of aging for loss of material will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.3.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report In CNP LRA Tables 3.3.2-1 through 3.3.2-11, the project team reviewed additional details of the results of the AMRs for material, environment, aging effect requiring management, and AMP combinations that are not consistent with the GALL Report.

7.2.3.3.1 Spent Fuel Pool System Summary of Aging Management (CNP LRA Table 3.3.2-1)

The project team reviewed Table 3.3.2-1 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the spent fuel pool system component groups.

No issues were identified during the project team's AMR line item review of Table 3.3.2-1.

7.2.3.3.2 Essential Service Water System Summary of Aging Management (CNP LRA Table 3.3.2-2)

The project team reviewed Table 3.3.2-2 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the essential service water system component groups.

For stainless steel exposed to external condensation, the applicant identifies no aging effects requiring management. The component types affected are bolting, detector wells, fittings, flex hose, orifice, piping, thermowell, tubing, and valve. On the basis of the conclusion that no aging effects requiring management are identified, the project team finds that the absence of an AMP for stainless steel components exposed to condensation is acceptable.

For copper alloy manifold (piping), piping, tubing, and valves exposed to condensation, the applicant identified no aging effect requiring management. No aging effects are considered to require management for copper components in condensation. On the basis of the conclusion that no aging effects requiring management are identified, the project team finds that the absence of an AMP for copper components exposed to condensation is acceptable.

For the cast iron strainer housing exposed to condensation, the applicant proposes to use CNP AMP B.1.38, "System Walkdown," to manage loss of material. The project team evaluation of this program is documented in Section 7.1.29 of this report.

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D.C. Cook Audit & Review Report The GALL Report identifies carbon steel as the material for this component. The project team considers the aging effects on cast iron in this environment to be the same as those for carbon steel. On this basis, the project team agrees that use of an AMP considered acceptable for carbon steel is also acceptable for management of this cast iron component.

7.2.3.3.3 Component Cooling Water System Summary of Aging Management (CNP LRA Table 3.3.2-3)

The project team reviewed Table 3.3.2-3 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the CCW system component groups.

For stainless steel exposed to external condensation, the applicant identifies no aging effects requiring management. The component types affected are bolting, detector well, fittings, heat exchanger (bonnet), heat exchanger (shell), manifold (piping), piping, thermowell, tubing, and valves. On the basis of the conclusion that no aging effects requiring management are identified, the project team finds that the absence of an AMP for stainless steel components exposed to condensation is acceptable.

No aging effects are considered to require management for copper alloy fittings, manifold, piping, tubing, and valves exposed to condensation. On the basis of the conclusion that no aging effects requiring management are identified, the project team finds that the absence of an AMP for copper components exposed to condensation is acceptable.

In the CNP LRA, the applicant states that loss of material from copper alloy fittings, manifold, piping, tubing, and valves exposed to treated water is managed using closed cooling water chemistry control. On the basis of industry operating experience with copper alloy in a treated water environment, the project team finds this acceptable.

In the CNP LRA, the applicant states that loss of material for stainless steel exposed to treated water in the component cooling water system will be managed with CNP AMP B.1.40.2, "Water Chemistry Control - Closed Cooling Water Chemistry Control." This applies to detector well, fittings, heat exchanger tubes, manifold, piping, thermowell, tubing and valve component types.

The applicant states that this program is consistent with GALL AMP XI.M21 "Closed-Cycle Cooling Water System", with exceptions. The project team evaluation of this program is documented in Section 7.1.32 of this report.

The project team reviewed stainless steel components exposed to treated water and concludes that the effects of general, pitting, and crevice corrosion on stainless steel components are not significant in chemically treated water and on the basis that the water chemistry control program is consistent with the GALL Report, the project team finds this acceptable.

In the CNP LRA, the applicant states that cracking for stainless steel exposed to treated water in the component cooling water system will be managed with the closed cooling water chemistry control. This applies to fittings, manifold, piping, thermowell, tubing, and valve component types. The project team identified that this material and environment combination was not in the GALL Report for component cooling water component types, however, it has been considered acceptable to manage cracking of stainless steel using water chemistry control supplemented by inspection or monitoring programs. The project team asked the applicant to identify the program or programs that will be used to confirm the effectiveness of water 182

D.C. Cook Audit & Review Report chemistry control for managing this aging effect, or clarify the rationale for relying on water chemistry control alone. In related RAI B.1.41-2, the staff asked the applicant to provide a list of components, material types, environments, and aging effects that will be inspected using CNP AMP B.1.41, Water Chemistry Control - Chemistry One-time Inspection, and to justify that the components selected are an adequate sample size to verify the effective of the water chemistry program for each aging effect to be managed. This is followup item 7.2.3.3-1 and will be dispositioned in the SER Section 3 related to the CNP LRA (RAI B.1.41-2).

In the CNP LRA, the applicant states that loss of material from stainless steel heat exchanger component types (including shell and tubes) is managed using CNP AMP.1.23, "Oil Analysis."

The project team evaluation of this program is documented in Section 7.1.17 of this report.

On the basis that the oil analysis program maintains oil systems free of contaminants (primarily water and particles), the project team finds that this program adequately manages loss of material for components exposed to lubricating oil, including stainless steel.

7.2.3.3.4 Compressed Air System Summary of Aging Management (CNP LRA Table 3.3.2-4)

The project team reviewed Table 3.3.2-4 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the compressed air system component groups.

For stainless steel exposed to ambient air, the applicant identifies no aging effects requiring management. The component types affected are bolting, flex hose, piping, tubing, and valves.

On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds the absence of an AMP for stainless steel components exposed to ambient air to be acceptable.

For brass fittings and valve component types exposed to ambient air (external) or nitrogen (internal), the applicant identifies no aging effects requiring management. On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds the absence of an AMP for brass components exposed to ambient air or nitrogen to be acceptable.

In the CNP LRA, the applicant states that cracking and change of material properties of elastomers of the flex hose component type in ambient air is managed using CNP AMP B.1.25, "Preventive Maintenance." The project team evaluation of this program is documented in Section 7.1.19 of this report. The project team found documentation of only visual inspection, which is an acceptable method for the detection of cracking. The project team asked the applicant to clarify the method(s) used to monitor a change in material properties of elastomers in the flex hose associated with the compressed air system. Material properties that could affect the performance of elastomers (e.g., hardness, flexibility) are not directly measured. By letter dated August 20, 2004, in RAI 3.3.3-2, the project team asked the applicant to provide a basis for concluding that degradation of the elastomers will be identified before the intended function is compromised, or to provide a technical basis for the conclusion that the elastomers in question are not subject to these aging effects. This followup item 7.2.3.3-2 will be dispositioned in the SER related to the CNP LRA as RAI 3.3.3-2.

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D.C. Cook Audit & Review Report For steel components exposed to nitrogen, the applicant identifies no aging effects requiring management. The component types affected are carbon steel piping, tank, tubing, and valves as well as stainless steel piping, tubing, and valves. On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds the absence of an AMP for steel components exposed to nitrogen to be acceptable.

In the CNP LRA, the applicant states that loss of material from carbon steel piping, tank tubing, and valve component types, when exposed to treated air, is managed using CNP AMP B.1.19, "Instrument Air Quality." The project team evaluation of this program is documented in Section 7.1.14 of this report. On the basis of plant operating experience demonstrating that the instrument air quality program is adequate to satisfy the requirements of GL 88-14, it is acceptable to the project team.

For copper alloy piping, tubing, and valves exposed to ambient air, the applicant identified no aging effect. On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds the absence of an AMP for copper alloy components exposed to ambient air to be acceptable.

For stainless steel exposed to nitrogen the applicant identifies no aging effects requiring management. The component types affected are piping, tubing, and valves. On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds the absence of an AMP for stainless steel components exposed to treated air to be acceptable.

7.2.3.3.5 Chemical and Volume Control System Summary of Aging Management (CNP LRA Table 3.3.2-5)

The project team reviewed Table 3.3.2-5 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the chemical and volume control system component groups.

In the CNP LRA, the applicant states that for stainless steel bolting, filter housing, flow element body, heat exchanger (bonnet), heat exchanger (shell), heater housing, manifold (piping),

orifice, piping, piping spool assembly, pulsation damper, pump casing, strainer (tee), tank, thermowell, tubing, and valve component types exposed to air, the applicant identified no aging effect. On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds the absence of an AMP for stainless steel components exposed to ambient air to be acceptable.

In the CNP LRA, the applicant states that loss of material for stainless steel in treated, borated water is managed using CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry Control." This applies to the filter housing, flow element body, heat exchanger (bonnet, shell, and tubes), heater housing, manifold (piping), orifice, piping, piping spool assembly, pulsation dampener, pump casing, strainer - tee, tank, thermowell, tubing, and valve component types in the CVCS. The project team evaluation of this program is documented in Section 7.1.31 of this report.

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D.C. Cook Audit & Review Report This material-environment combination was not identified in the GALL Report for this system.

On the basis that stainless steel components are not subject to significant general, pitting, and crevice corrosion in treated, borated water, this is acceptable to the project team.

In the CNP LRA, the applicant states that fouling of stainless steel heat exchanger tubes in treated, borated water is managed using the water chemistry control program. This aging effect is not identified in the GALL Report for this component, material, and environment combination. The project team finds the use of the water chemistry control program to be acceptable.

In the CNP LRA, the applicant states that cracking of stainless steel in treated, borated water is managed using the water chemistry control program. This affects orifice, piping, thermowell, tubing, and valve component types in the CVCS. On the basis that it is similar to the management of cracking of stainless steel in this environment in other non-Class 1 systems, the project team finds the use of the water chemistry control program to be acceptable for these components.

In the CNP LRA, the applicant states that for stainless steel piping and valves exposed to an environment of hydrogen or nitrogen gas, the applicant identified no aging effects. On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds the absence of an AMP for stainless steel components exposed to ambient air to be acceptable.

7.2.3.3.6 Heating, Ventilation and Air Conditioning Systems Summary of Aging Management (CNP LRA Table 3.3.2-6)

The project team reviewed Table 3.3.2-6 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the HVAC systems component groups.

For stainless steel components exposed to air (external or internal surface), condensation (external surface), or outdoor air (external surface), the applicant identified no aging effects.

Component types addressed included bolting, piping, sight glass housing, tank, thermowell, valves, and the ventilation unit housing. The project team found this acceptable.

On the basis of the conclusion that no aging effects requiring management are identified, the project team finds the absence of an AMP for stainless steel components exposed to condensation to be acceptable.

No aging effects were identified for copper-alloy component types exposed to freon, including the dryer, heat exchanger tubes, piping, sight glass housing, tubing, and valves. On the basis that no aging effects require management for these components, the project team finds the absence of an AMP for copper-alloy components exposed to freon to be acceptable.

In the CNP LRA, the applicant states that fouling of copper alloy and stainless steel heat exchanger tubes in treated water is managed using CNP AMP B.1.40.3, "Water Chemistry Control - Auxiliary Systems Water Chemistry Control." This applies to the heat exchanger (tubes) component types in the HVAC systems. The project team evaluation of this program is documented in Section 7.1.33 of this report.

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D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that loss of material for stainless steel in treated water is managed using CNP AMP B.1.40.3, "Water Chemistry Control - Auxiliary Systems Water Chemistry Control." This applies to the heat exchanger (tubes), piping, sight glass housing, tank, thermowell, and valve component types in the HVAC systems. The project team evaluation of this program is documented in Section 7.1.33 of this report.

No aging effects were identified for copper-alloy components exposed to air, including the heater housing, piping, sight glass housing, test canister housing, and valves. On the basis that no aging effects requiring management are identified, the project team finds the absence of an AMP for copper components exposed to condensation to be acceptable.

In the CNP LRA, the applicant identified no aging effects for copper-alloy piping and valve component types exposed to condensate. For the valve component type, for copper-alloy material exposed to condensate, loss of material is also identified as an aging effect requiring management. The project team asked the applicant to clarify the inconsistency between identical material and environment combinations. By letter dated June 8, 2004 (ML041680255),

in response to a related RAI 3.3.2-1 from the staff, the applicant stated that copper alloy valves associated with the auxiliary feed pump ventilation may be wetted by condensation that could contain sulfates, chlorides, or fluorides. In those cases, loss of material was identified as an aging effect requiring management. In other cases, the applicant stated that copper alloy valves within the control room liquid chiller packages may be wetted by condensation that does not contain sulfates, chlorides, or fluorides, and these specific valves do not have an aging effect requiring management that is identified.

On the basis of its review of the response to RAI 3.3.2-1, the project team finds the issue resolved because the applicant appropriately identified and distinguished between the aging effects requiring management for the condensate environment containing sulfates, chlorides, or fluorides and the condensate environment not containing them.

In the CNP LRA, the applicant states that loss of material from a carbon steel valve exposed to air internally is to be managed using CNP AMP B.1.38, "System Walkdown." The project team evaluation of this program is documented in Section 7.1.29 of this report.

The project team asked the applicant to justify the use of the system walkdown program to manage loss of material for the internals of these carbon steel valves prior to failure of the component.

In a related staff RAI 3.3.2.1.11-3, by letter dated May 26, 2004 (ML041480115), the staff asked the applicant to explain how the system walkdown program will detect loss of material on the internal surfaces of the several components. This is followup item 7.2.3.3-4 and will be dispositioned in the SER for the CNP LRA (RAI 3.3.2.1.11-3).

7.2.3.3.7 Fire Protection System Summary of Aging Management (CNP LRA Table 3.3.2-7)

The project team reviewed Table 3.3.2-7 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the fire protection system component groups.

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D.C. Cook Audit & Review Report For stainless steel exposed to air, the applicant identifies no aging effects requiring management. The component types affected are bolting (ambient air) and flex hose (ambient and internal). On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds the absence of an AMP for stainless steel components exposed to ambient air to be acceptable.

For copper alloy fittings, piping, spray nozzles, tubing, and valve component types exposed to ambient air, as well as filter housing, fittings, spray nozzles, and valve component types internally exposed to air, the applicant identified no aging effect. On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds the absence of an AMP for copper alloy components exposed to ambient air to be acceptable.

In the CNP LRA, the applicant states that loss of material from carbon steel fire protection components exposed to treated water is managed using the CNP AMP B.1.11, "Fire Protection." The project team evaluation of this program is documented in Sections 7.1.5 and 7.1.6 of this report, respectively. The program addresses fittings, flange, heat exchanger bonnet and shell, heater housing, orifice, piping, pump casing, spray nozzles, tank, and tubing component types. This is acceptable to the project team.

In the CNP LRA, the applicant states that loss of material from copper-alloy fittings, piping, tubing, and valve component types is managed using CNP AMP B.1.10, "Diesel Fuel Monitoring." The project team evaluation of this program is documented in Section 7.1.4 of this report. On the basis that the diesel fuel program maintains oil systems free of contaminants (primarily water and particles), and provides additives to mitigate aging effects, the project team finds that this program adequately manages fouling and loss of material for components exposed to fuel oil.

In the CNP LRA, the applicant states that loss of material from copper alloy fire protection components exposed to treated water is managed using the CNP AMP B.1.11, "Fire Protection," which is subdivided into CNP AMP B.1.11.1, "Fire Protection," and CNP AMP B.1.11.2, "Fire Water System." The project team evaluation of the fire protection program is documented in Sections 7.1.5 and 7.1.6 of this report, respectively. The program addresses fittings, heat exchanger tubes, spray nozzles, tubing, and valve component types. On the basis that the program includes the SCs that credit this plant-specific program, the project team finds this to be acceptable.

In the CNP LRA, the applicant states that loss of material from cast iron heat exchanger shell, copper alloy heat exchanger tubes, carbon steel piping, and pump casing component types exposed to lubricating oil is managed using CNP AMP.1.23, "Oil Analysis." The project team evaluation of this program is documented in Section 7.1.17 of this report. On the basis that the oil analysis program maintains oil systems free of contaminants (primarily water and particles),

the project team finds that this program adequately manages fouling and loss of material for components exposed to lubricating oil.

In the CNP LRA, the applicant states that loss of material due to wear of copper-alloy heat exchanger tubes exposed to both lube oil and treated water using the fire protection program.

On the basis that the program includes the SCs that credit this plant-specific program, the project team finds this to be acceptable.

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D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that loss of material from a carbon steel spray nozzle exposed to air internally is to be managed using CNP AMP B.1.38, "System Walkdown." The project team evaluation of this program is documented in Section 7.1.29 of this report. During the AMP audit at the applicant's offices, the project team asked how internal loss of material would be detected. The applicant's technical staff explained that loss of carbon steel material sufficient to challenge the intended function of the spray nozzle would be expected to produce indications that would be evident on inspection without disassembly. On the basis that this plant-specific program provides for the management of loss of material for this component, and that evidence of significant internal loss of material will be visible to those conducting system walkdowns, and that they are guided by training and procedure to monitor this aging effect, this is acceptable to the project team.

7.2.3.3.8 Emergency Diesel Generator Summary of Aging Management (CNP LRA Table 3.3.2-8)

The project team reviewed Table 3.3.2-8 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the EDG component groups.

For stainless steel exposed to air, the applicant identifies no aging effects requiring management. The component types exposed to ambient air are bolting, fittings, flex hose, piping, strainer, thermowell, tubing, and valves, and those exposed to air internally are fittings, flex hose, piping, strainer, tubing, and valves. On the basis that no aging effects requiring management are identified and this is consistent with industry experience, the project team finds the absence of a program for stainless steel components exposed to ambient air to be acceptable.

In the CNP LRA, the applicant states that loss of material from carbon steel filter housing, fittings, heat exchanger shell, heater housing, piping, pump casing, strainer, tank, and valve is managed using CNP AMP.1.23, "Oil Analysis." The project team evaluation of this program is documented in Section 7.1.17 of this report. On the basis that the oil analysis program maintains oil systems free of contaminants (primarily water and particles), the project team finds that this program adequately manages loss of material for components exposed to lubricating oil.

For copper alloy filter housings, fittings, manifold, pneumatic cylinder, tubing, and valve component types exposed to ambient air, as well as for filter housings, fittings, pneumatic cylinder, tubing, and valve component types exposed to internal air, the applicant identified no aging effect. On the basis that no aging effects requiring management are identified and this is consistent with industry experience, the project team finds the absence of a program for copper alloy components exposed to ambient air to be acceptable.

In the CNP LRA, the applicant states that loss of material from carbon steel fittings, heat exchanger shell, heater housing, manifold, orifice, piping, pump casing, strainer, tank, thermowell, and tubing component types in treated water is managed using CNP AMP B.1.40, "Water Chemistry Control." The project team evaluation of this program is documented in Sections 7.1.31 through 7.1.33 of this report. On the basis that this is consistent with the management of similar items identified in the GALL Report, the project team finds this to be acceptable.

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D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that loss of material from carbon steel valve component types is managed using both the water chemistry control program and the plant-specific CNP AMP B.1.25, "Preventive Maintenance." The project team evaluation of this program is documented in Section 7.1.19. On the basis that use of the water chemistry control program is consistent with the management of similar items identified in the GALL Report, the project team finds its use to supplement the preventive maintenance program to be acceptable.

In the CNP LRA, the applicant states that loss of material from copper-alloy fittings, manifold, tubing, and valve component types is managed using CNP AMP B.1.10, "Diesel Fuel Monitoring." The project team evaluation of this program is documented in Section 7.1.4 of this report. On the basis that the diesel fuel program maintains oil systems free of contaminants (primarily water and particles), and provides additives to mitigate aging effects, the project team finds that this program adequately manages fouling and loss of material for components exposed to fuel oil.

In the CNP LRA, the applicant states that loss of material from copper-alloy fittings, heat exchanger tubes, tubing, and valve component types exposed to lube oil is managed using the oil analysis program. On the basis that the oil analysis program maintains oil systems free of contaminants (primarily water and particles), the project team finds that this program adequately manages cracking and loss of material for components exposed to lubricating oil.

In the CNP LRA, the applicant states that loss of material from copper-alloy fittings and heat exchanger tubes in raw water is managed using CNP AMP B.1.29, "Service Water System Reliability." Fouling of heat exchanger tubes is also managed using this program. The project team evaluation of the service water system reliability program is documented in Section 7.1.21 of this report. On the basis that use of service water system reliability is consistent with the management of similar items identified in the GALL Report, the project team finds its use to supplement the preventive maintenance program to be acceptable.

In the CNP LRA, the applicant states that loss of material from copper-alloy fittings, heat exchanger tubes, tubing, and valve component types in treated water is managed using the water chemistry control program. On the basis that this is consistent with the management of similar material-environment combinations identified in the GALL Report, the project team finds this to be acceptable.

In the CNP LRA, the applicant states that loss of material from stainless steel fittings, piping, strainer, tubing, and valve component types is managed using the diesel fuel monitoring program. The project team evaluation of this program is documented in Section 7.1.4 of this report. On the basis that the diesel fuel program maintains oil systems free of contaminants (primarily water and particles), and provides additives to mitigate aging effects, the project team finds that this program adequately manages fouling and loss of material for components exposed to fuel oil.

In the CNP LRA, the applicant states that cracking of stainless steel fittings, piping, strainer, thermowell, and tubing component types exposed to lube oil is managed using the oil analysis program. On the basis that the oil analysis program maintains oil systems free of contaminants (primarily water and particles), the project team finds that this program adequately manages loss of material for components exposed to lubricating oil.

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D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that loss of material from stainless steel fittings, piping, strainer, thermowell, tubing, and valve component types in lube oil is managed using the oil analysis program. On the basis that the oil analysis program maintains oil systems free of contaminants (primarily water and particles), the project team finds that this program adequately manages loss of material for components exposed to lubricating oil.

In the CNP LRA, the applicant states that loss of material from stainless steel fittings, piping, strainer, thermowell, tubing and valve component types in treated water is managed using the water chemistry control program. The project team evaluation of this program is documented in Sections 7.1.31 through 7.1.33 of this report. On the basis that this is consistent with the management of similar items identified in the GALL Report, the project team finds it to be acceptable.

In the CNP LRA, the applicant states that cracking and changes in material properties for elastomers in flex hose are managed using CNP AMP B.1.25, "Preventive Maintenance." The project team evaluation of this program is documented in Section 7.1.19 of this report.

The project team was unable to identify how changes in material properties would be monitored. The project team requested the applicant to clarify the method(s) used to monitor change in material properties of elastomers in the flex hose associated with the EDG. Material properties that could affect the performance of elastomers (e.g., hardness, flexibility) are not directly measured. By letter dated August 20, 2004, in RAI 3.3.3-2, the project team asked the applicant to provide a basis for concluding that degradation of the elastomers will be identified before the intended function is compromised, or to provide a technical basis for the conclusion that the elastomers in question are not subject to these aging effects. This followup item 7.2.3.3-5 will be dispositioned in the SER related to the CNP LRA as RAI 3.3.3-2.

In the CNP LRA, the applicant states that fouling of copper-alloy heat exchanger tubes in treated water is managed using the water chemistry control program. On the basis that this is consistent with the management of similar items identified in the GALL Report, the project team finds it to be acceptable.

7.2.3.3.9 Security Diesel Summary of Aging Management (CNP LRA Table 3.3.2-9)

The project team reviewed Table 3.3.2-9 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the security component groups.

In the CNP LRA, the applicant states that loss of material in a carbon steel filter housing, fittings, heat exchanger shell, piping, pump casing, strainer, strainer housing, tubing, and valve component types is managed using CNP AMP B.1.23, "Oil Analysis." The project team evaluation of this program is documented in Section 7.1.17 of this report. On the basis that the oil analysis program maintains oil systems free of contaminants (primarily water and particulates), the project team finds that this program adequately manages cracking and loss of material for components exposed to lubricating oil.

For copper alloy filter housing, fittings, heat exchanger (shell), pump casing, strainer housing, and tubing component types exposed to ambient air, the applicant identified no aging effect.

On the basis that no aging effects requiring management are identified, and this is consistent 190

D.C. Cook Audit & Review Report with industry experience, the project team finds the absence of an AMP for copper-alloy components exposed to ambient air to be acceptable.

In the CNP LRA, the applicant states that loss of material from copper-alloy filter housing, fittings, pump casing, strainer housing, and tubing component types is managed using CNP AMP B.1.10, "Diesel Fuel Monitoring." The project team evaluation of this program is documented in Section 7.1.4 of this report. On the basis that the diesel fuel program maintains oil systems free of contaminants (primarily water and particles), and provides additives to mitigate aging effects, the project team finds that this program adequately manages fouling and loss of material for components exposed to fuel oil.

In the CNP LRA, the applicant states that loss of material from carbon steel fittings, heater housing, piping, pump casing, tank, thermowell, and tubing component types in treated water is managed using CNP AMP B.1.40, "Water Chemistry Control." The project team evaluation of this program is documented in Sections 7.1.31 through 7.1.33 of this report. On the basis that this is consistent with the management of similar items identified in the GALL Report, the project team finds it to be acceptable.

In the CNP LRA, the applicant states that loss of material from copper-alloy fittings in contact with the soil is to be managed using the plant-specific CNP AMP B.1.37, "System Testing." The project team evaluation of this program is documented in Section 7.1.28 of this report. On the basis that similar aging effects occur for copper alloy materials in a soil environment and copper alloy materials in an internal fuel oil environment, and the system testing program scope includes the components of the security diesel system for this aging effect, the project team finds this to be acceptable.

In the CNP LRA, the applicant states that loss of material from copper-alloy fittings, heat exchanger tubes, and tubing component types in treated water is also managed using the water chemistry control program. On the basis that this is consistent with the management of similar items identified in the GALL Report, the project team finds it to be acceptable.

For stainless steel exposed to ambient air, the applicant identifies no aging effects requiring management. The component types affected are fittings, flange, flex hose, piping, tubing, and valves. On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds the absence of an AMP for stainless steel components exposed to ambient air to be acceptable.

In the CNP LRA, the applicant states that loss of material from stainless steel fittings, flange, flex hose, piping, strainer, tubing, and valve component types is managed using the diesel fuel monitoring program. The project team evaluation of this program is documented in Section 7.1.4. On the basis that the diesel fuel program maintains oil systems free of contaminants (primarily water and particles), and provides additives to mitigate aging effects, the project team finds that this program adequately manages fouling and loss of material for components exposed to fuel oil.

In the CNP LRA, the applicant states that cracking and changes in material properties for elastomers in flexible hose and tubing exposed to the air are managed using CNP AMP B.1.25, "Preventive Maintenance." The project team evaluation of this program is documented in Section 7.1.19 of this report.

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D.C. Cook Audit & Review Report The project team was unable to identify how changes in material properties would be monitored. The project team requested clarification on the method(s) used to monitor a change in material properties of elastomers in the flex hose associated with the security diesel.

Material properties that could affect the performance of elastomers (e.g., hardness, flexibility) are not directly measured. By letter dated August 20, 2004, in RAI 3.3.3-2, the project team asked the applicant to provide a basis for concluding that degradation of the elastomers will be identified before the intended function is compromised, or to provide a technical basis for the conclusion that the elastomers in question are not subject to these aging effects. This followup item 7.2.3.3-6 will be dispositioned in the SER related to the CNP LRA as RAI 3.3.3-2.

In the CNP LRA, the applicant states that loss of material in copper alloy heat exchanger tubes is managed using the oil analysis program. The project team evaluation of this program is documented in Section 7.1.17 of this report. On the basis that the oil analysis program maintains oil systems free of contaminants (primarily water and particulates), the project team finds that this program adequately manages cracking and loss of material for components exposed to lubricating oil.

7.2.3.3.10 Post-Accident Containment Hydrogen Monitoring System Summary of Aging Management (CNP LRA Table 3.3.2-10)

The project team reviewed Table 3.3.2-10 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the post-accident containment hydrogen monitoring system component groups.

For stainless steel component types exposed to air, both ambient and internal, the applicant identifies no aging effects requiring management. The component types affected are analyzer body, bolting, filter, heat exchanger, moisture separator, orifice, piping, pump casing, and valve.

On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds the absence of a program for stainless steel components exposed to ambient air to be acceptable.

In the CNP LRA, the applicant states that cracking and changes in material properties for elastomers in flexible hose are managed using CNP AMP B.1.25, "Preventive Maintenance."

The project team evaluation of this program is documented in Section 7.1.19 of this report.

The project team was unable to identify how changes in material properties would be monitored. The project team requested clarification on the method(s) used to monitor a change in material properties of elastomers in the flex hose associated with the containment hydrogen monitoring system. Material properties that could affect the performance of elastomers (e.g.,

hardness, flexibility) are not directly measured. By letter dated August 20, 2004, in RAI 3.3.3-2, the project team asked the applicant to provide a basis for concluding that degradation of the elastomers will be identified before the intended function is compromised, or to provide a technical basis for the conclusion that the elastomers in question are not subject to these aging effects. This followup item 7.2.3.3-7 will be dispositioned in the SER related to the CNP LRA as RAI 3.3.3-2.

In the CNP LRA, the applicant states that for stainless steel piping and valves exposed to an environment of hydrogen or nitrogen gas, the applicant identified no aging effects. On the basis that no aging effects requiring management are identified, and this is consistent with 192

D.C. Cook Audit & Review Report industry experience, the project team finds that the absence of an AMP for stainless steel components exposed to ambient air to be acceptable.

For brass valves exposed to ambient air, the applicant identifies no aging effects requiring management. On the basis that no aging effects requiring management are identified and this is consistent with industry experience, the project team finds that the absence of an AMP for stainless steel components exposed to ambient air to be acceptable.

7.2.3.3.11 Miscellaneous Systems in Scope for 10 CFR 54.4(a)(2) Summary of Aging Management (CNP LRA Table 3.3.2-11)

The project team reviewed Table 3.3.2-11 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the miscellaneous systems in scope for 10 CFR 54.4(a)(2) component groups.

In the CNP LRA, the applicant states that loss of material for carbon steel bolting exposed to ambient air is managed using CNP AMP B.1.4, "Boric Acid Corrosion Prevention," and CNP AMP B.1.38, "System Walkdown." The NRR DE staff's evaluation of the BAC prevention program is documented in Section 3.0 of the SER related to the CNP LRA. The project team evaluation of the system walkdown program is documented in Section 7.1.29 of this report. On the basis that it is similar to the management recommended by the GALL Report for this material-environment combination in other auxiliary systems, the project team finds the use of the system walkdown program to be acceptable for these components.

In the CNP LRA, the applicant states that loss of material for carbon steel component types exposed to ambient air is managed using the system walkdown program. This is used for condenser shell, evaporator housing, heater housing, orifice, piping, pump casing, strainer housing, tank (including coated carbon steel), thermowell, trap, valve, and ventilation unit housing component types. Loss of material for the internal surfaces of the ventilation unit housing made of carbon steel is also managed using the system walkdown program. The project team finds this to be acceptable.

For stainless steel exposed to ambient air, the applicant identifies no aging effects requiring management. The component types affected are bolting, filter housing, flex hose, manifold, orifice, piping, pump casing, strainer housing, tank, thermowell, tubing, and valve. On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds that the absence of an AMP for stainless steel components exposed to ambient air to be acceptable.

In the CNP LRA, the applicant states that loss of material for carbon steel component types exposed to treated water (internal) is managed using the system walkdown program and CNP AMP B.1.40, "Water Chemistry Control." The project team evaluation of the water chemistry control program is documented in Section 7.1.31 through 7.1.33. This is used for condenser shell, evaporator housing, heater housing, orifice, piping, pump casing, strainer housing, tank (including coated carbon steel), thermowell, and valve component types. The project team finds the use of water chemistry control to be acceptable; review by NRR DE staff of the use of the system walkdown program for these components is documented in Section 3 of the SER related to the CNP LRA.

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D.C. Cook Audit & Review Report For copper alloy heat exchanger (shell), heater coil, manifold, piping, tubing, and valve component types exposed to ambient air, the applicant identified no aging effect. On the basis that no aging effects requiring management are identified, and this is consistent with industry experience, the project team finds that the absence of an AMP for copper alloy components exposed to ambient air to be acceptable.

In the CNP LRA, the applicant states that loss of material for copper alloy heat exchanger shell, manifold, piping, tubing, and valve component types in treated water is managed using the system walkdown and water chemistry control programs. The project team finds the use of water chemistry control program to be acceptable; review by NRR DE staff of the use of the system walkdown program for these components is documented in Section 3 of the SER related to the CNP LRA.

In the CNP LRA, the applicant states that loss of material for copper alloy heater coil exposed to steam greater than 270EF is managed using the system walkdown program. Although a precedent was cited, the project team was not able to confirm its applicability in this case. It is not clear to the project team how the system walkdown program would offer any way to detect this aging effect prior to failure of the component.

In a related staff RAI 3.3.2.1.11-3, by letter dated May 26, 2004 (ML041480115), the staff asked the applicant to explain how the system walkdown program will detect loss of material on the internal surfaces of the several components. This is followup item 7.2.3.3-8 and will be dispositioned in the SER for the CNP LRA (RAI 3.3.2.1.11-3).

In the CNP LRA, the applicant states that loss of material for stainless steel in treated water is managed using system walkdown and water chemistry control programs. This applies to the manifold (piping), orifice, piping, pump casing, tank, thermowell, tubing, and valve component types. On the basis that it is similar to the management recommended by the GALL Report for this material-environment combination in other auxiliary systems, the project team finds the use of the water chemistry program to be acceptable for these components; review by NRR DE staff of the use of the system walkdown program for these components is documented in Section 3 of the SER related to the CNP LRA.

In the CNP LRA, the applicant states that cracking and loss of material for stainless steel manifold, piping, pump casing, thermowell, tubing and valves exposed to treated, borated water is managed using the water chemistry control program with the system walkdown program. On the basis that it is similar to the management recommended by the GALL Report for this material-environment combination in other auxiliary systems, the project team finds the use of the water chemistry program to be acceptable for these components; review by NRR DE staff of the use of the system walkdown program for these components is documented in Section 3 of the SER related to the CNP LRA.

In the CNP LRA, the applicant states that loss of material for cast iron pump casing and strainer housing component types in air is managed using the system walkdown program. On the basis that the aging effects of this material are similar to carbon steel in this environment and that the program is acceptable for management of this aging effect in carbon steel, the project team finds this acceptable.

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D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that loss of material and cracking in stainless steel tubing and valves exposed to treated water greater than 270EF and treated, borated water greater than 270EF, is to be managed using a water chemistry control program consistent with the GALL Report. On the basis that it is similar to the management of cracking of stainless steel in this environment in other non-Class 1 systems, the project team finds the use of the water chemistry control program to be acceptable for these components; review by NRR DE staff of the use of the system walkdown program for these components is documented in Section 3 of the SER related to the CNP LRA.

7.2.4 CNP LRA Section 3.4 - Aging Management of Steam and Power Conversion Systems In CNP LRA Section 3.4, the applicant provides the results of its AMRs for components for the steam and power conversion systems.

In CNP LRA Tables 3.4.2-1 through 3.4.2-4 (LRA Table 2s), the applicant provides a summary of the AMRs for component types associated with the following systems: (1) main feedwater; (2) main steam; (3) auxiliary feedwater; and (4) blowdown. The summary information for each component type includes: intended function, material, environment, aging effect requiring management, AMPs, the GALL Report Volume 2 item, cross reference to the CNP LRA Table 3.4.1 (Table 1), and generic and plant-specific notes related to consistency with the GALL Report.

Also, the applicant identifies for each component type in the CNP LRA Table 3.4.1 (Table 1) those components where further evaluation is recommended, those for which no further evaluation is required, and those that are not applicable to CNP together with the basis for their exclusion.

Additionally, the applicant identifies in the CNP LRA Tables 3.4.2-1 through 3.4.2-4, which AMR results it considers to be consistent with the GALL Report (table column Notes A through E) and which it justifies on a different basis.

The AMRs that are within the scope of the project team audit and review are identified on copies of the CNP LRA Tables 3.4.2-1 through 3.4.2-4 included as an appendix to the CNP audit and review plan.

The project team conducted its audit and review in accordance with SRP-LR Section 3.4.3 and the CNP audit and review plan.

7.2.4.1 Aging Management Evaluations That Are Consistent With the GALL Report, for Which No Further Evaluation Is Required For aging management evaluations that the applicant states are consistent with the GALL Report and for which further evaluation is not recommended, the project team conducted its audit and review to determine if the applicant's reference to the GALL Report in the CNP LRA is acceptable.

The project team reviewed the CNP LRA to confirm that the applicant (1) provides a brief description of the system, components, materials, and environment; (2) states that the 195

D.C. Cook Audit & Review Report applicable aging effects have been reviewed and are evaluated in the GALL Report; and (3) identifies those aging effects for the steam and power conversion system components that are subject to an AMR.

On the basis of its audit and review, the project team determined that for AMRs not requiring further evaluation, as identified in the CNP LRA Table 3.4.1 (Table 1), the applicant's references to the GALL Report are acceptable and no further project team review is required.

7.2.4.2 Aging Management Evaluations That Are Consistent With the GALL Report, for Which Further Evaluation Is Recommended For some line items consistent with the GALL Report in CNP LRA Tables 3.4.2-1 through 3.4.2-4, the GALL Report recommends further evaluation. When further evaluation is recommended, the project team reviewed these further evaluations provided in CNP LRA Section 3.4.2.2 against the criteria provided in the SRP-LR Section 3.4.2.2. The following provides the project team's assessments of these evaluations. These project team assessments are applicable to each Table 2 line item in Section 3.4 citing the item in Table 1.

The CNP LRA sections, identified in CNP LRA Table 3.4.1, for which further evaluation is recommended are discussed below.

7.2.4.2.1 Cumulative Fatigue Damage (CNP LRA Section 3.4.2.2.1)

CNP LRA Section 3.4.2.2.1 is reviewed by the NRR DE staff and addressed in Section 4 of the SER related to the CNP LRA.

7.2.4.2.2 Loss of Material Due to General, Pitting, and Crevice Corrosion (CNP LRA Section 3.4.2.2.2)

In CNP LRA Section 3.4.2.2.2, the applicant addresses loss of material due to general, pitting, and crevice corrosion that could occur on the internal surfaces of piping and fittings, valve bodies and bonnets, piping manifolds, orifices, pump casings, strainer housings, tanks, tubes, tubesheets, the channel head, and shell (excluding the main steam system). General corrosion applies only to carbon steel components; pitting and crevice corrosion apply to both carbon and stainless steel components and to the cast iron strainer housings. In CNP LRA Section 3.4.2.2.2, the applicant also addresses the GALL Report recommendation for further evaluation to verify the effectiveness of the water chemistry control program in managing loss of material due to general, pitting, and crevice corrosion.

SRP-LR Section 3.4.2.2.2 states that the management of loss of material due to general, pitting, and crevice corrosion should be evaluated further for carbon steel piping and fittings, valve bodies and bonnets, pump casings, pump suction and discharge lines, tanks, tubesheets, channel heads, and shells except for main steam system components and for loss of material due to pitting and crevice corrosion for stainless steel tanks and heat exchanger/cooler tubes.

The water chemistry program relies on monitoring and control of water chemistry based on the EPRI guidelines of TR-102134, PWR Secondary Water Chemistry Guideline-Revision 3, for secondary water chemistry to manage the effects of loss of material due to general, pitting, or crevice corrosion. However, corrosion may occur at locations of stagnant flow conditions.

Therefore, the effectiveness of the chemistry control program should be verified to ensure that 196

D.C. Cook Audit & Review Report corrosion is not occurring. The GALL Report recommends further evaluation of programs to manage loss of material due to general, pitting, and crevice corrosion to verify the effectiveness of the water chemistry program. A one-time inspection of select components and susceptible locations is an acceptable method to ensure that corrosion is not occurring and that the component's intended function will be maintained during the period of extended operation.

The AMP recommended by the GALL Report is GALL AMP XI.M32, "One Time Inspection," for management of this aging effect.

For the components for which this evaluation is required, the applicant credits CNP AMP B.1.40.1, "Primary and Secondary Water Chemistry Control," with enhancements, to manage loss of material by mitigating damage caused by corrosion. CNP AMP B.1.40.1 is evaluated in Section 7.1.31 of this report. Consistent with the GALL Report, the CNP primary and secondary water chemistry control program is supplemented with CNP AMP B.1.39, "Wall Thinning Monitoring," (auxiliary feedwater system components only) and CNP AMP B.1.41, "Water Chemistry Control - Chemistry One-Time Inspection," as the verification programs that will supplement CNP AMP B.1.40.1 for steam and power conversion system components.

The project team's evaluation of CNP AMP B.1.39, which is a plant-specific program, is documented in Section 7.1.30 of this report. The Water chemistry control - chemistry one-time inspection is a new program that the applicant states is consistent with GALL AMP XI.M32, "One-Time Inspection," but of a more limited scope. The NRR DE staff evaluation of CNP AMP B.1.41 is documented in Section 3 of the SER related to the CNP LRA.

7.2.4.2.3 Loss of Material Due to General, Pitting, and Crevice Corrosion, Microbiologically Influenced Corrosion, and Biofouling (CNP LRA Section 3.4.2.2.3)

The project team reviewed CNP LRA Section 3.4.2.2.3 against the criteria in SRP-LR Section 3.4.2.2.3.

In CNP LRA Section 3.4.2.2.3, the applicant addresses loss of material in carbon steel piping and fittings for untreated water from the backup water supply in the auxiliary feedwater system.

SRP-LR Section 3.4.2.2.3 states that loss of material due to general, pitting, and crevice corrosion, MIC, and biofouling could occur in carbon steel piping and fittings for untreated water from the backup water supply in the auxiliary feedwater system. The GALL Report recommends further evaluation to ensure that these aging effects are adequately managed.

In the CNP LRA, the applicant states that the portion of the lines from the essential service water (ESW) system to the auxiliary feedwater system that are exposed to untreated water are addressed as part of the ESW system (Item Number 3.3.1-17 of CNP LRA Table 3.3.1). The project team finds that, with exceptions and enhancement, the CNP AMP B.1.29, "Service Water System Reliability," is consistent with GALL AMP XI.M20, "Open-Cycle Cooling Water System," as discussed in Section 7.1.21 of this report.

CNP AMP B.1.29 is supplemented by CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry," and CNP AMP B.1.37, "System Testing," programs which manage loss of material and fouling. The project team's evaluations of these CNP AMPs are provided in Sections 7.1.31 and 7.1.28 of this report, respectively. The project team finds that, 197

D.C. Cook Audit & Review Report although biofouling is not, in itself, an aging effect, the programs manage the effects that may result from biofouling in carbon steel piping and fittings exposed to an internal environment of untreated water from the backup water supply in the essential service water system, and is therefore, acceptable.

The project team finds that the applicant has demonstrated that the effects of aging for loss of material due to general, pitting, and crevice corrosion, microbiologically influenced corrosion, and biofouling will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.4.2.4 General Corrosion (CNP LRA Section 3.4.2.2.4)

In CNP LRA Section 3.4.2.2.4, the applicant states that loss of material due to general corrosion that could occur on external surfaces of carbon steel SCs, including closure bolting, and the cast iron strainer housing in the auxiliary feedwater system. The basis for including the strainer housing is that industry experience has demonstrated that cast iron is subject to the same aging effects as carbon steel in this environment.

SRP-LR Section 3.4.2.2.4 states that loss of material due to general corrosion could occur on the external surfaces of all carbon steel SCs, including closure boltings, exposed to operating temperatures less than 212°F. The GALL Report recommends further evaluation to ensure that this aging effect is adequately managed.

In the CNP LRA, the applicant credits CNP AMP B.1.38, "System Walkdown," with enhancements, for managing loss of material for the external surfaces of carbon steel SCs, including bolting indoors and outdoors, and the cast iron strainer housing. This is consistent with the GALL Report. The project team reviewed the applicants system walkdown program, with enhancements, and concludes that the program is acceptable. The project teams evaluation of this program is documented in Section 7.1.29 of this report.

The project team finds that the applicant has demonstrated that the effects of aging for loss of material due to general corrosion will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.4.2.5 Loss of Material Due to General, Pitting, Crevice, and Microbiologically Influenced Corrosion (CNP LRA Section 3.4.2.2.5)

The project team reviewed CNP LRA Section 3.4.2.2.5 against the criteria in SRP-LR Section 3.4.2.2.5.

In the CNP LRA Section 3.4.2.2.5, the applicant addresses (1) loss of material due to general corrosion, pitting and crevice corrosion, and MIC in carbon steel components exposed to lubricating oil in the auxiliary feedwater system and (2) loss of material in underground piping and fittings and storage tanks for steam and power conversion systems. The components exposed to an internal environment of lubricating oil and subject to this aging effect are the auxiliary feedwater system carbon steel piping, pump casings, governor housing, heat exchanger shell, and sight glass housing.

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D.C. Cook Audit & Review Report SRP-LR Section 3.4.2.2.5 addresses loss of material due to general corrosion (carbon steel only), pitting and crevice corrosion, and MIC which could occur in stainless steel and carbon steel shells, tubes, and tubesheets within the bearing oil coolers (for steam turbine pumps) in the auxiliary feedwater system. The GALL Report recommends further evaluation to ensure that these aging effects are adequately managed.

SRP-LR Section 3.4.2.2.5 also addresses loss of material due to general corrosion, pitting and crevice corrosion, and MIC, which could occur in underground piping and fittings and emergency condensate storage tank in the auxiliary feedwater system and the underground condensate storage tank in the condensate system. The buried piping and tanks inspection program relies on industry practice, frequency of pipe excavation, and operating experience to manage the effects of loss of material from general corrosion, pitting and crevice corrosion, and MIC. The effectiveness of the buried piping and tanks inspection program should be verified to evaluate an applicant's inspection frequency and operating experience with buried components, ensuring that loss of material is not occurring.

The applicant states that CNP AMP B.1.23, "Oil Analysis," manages the loss of material aging effect for carbon steel components exposed to an internal environment of lubricating oil in the auxiliary feedwater system. The project team finds that the applicants oil analysis program, adequately manages the effects of aging of loss of material for carbon steel components exposed to lubricating oil. The project team's evaluation of this AMP is documented in Section 7.1.17 of this report.

The project team confirmed that there are no buried components subject to an AMR in steam and power conversion systems at CNP.

The project team finds that the applicant has demonstrated that the effects of aging for loss of material due to general, pitting, crevice, and microbiologically influenced corrosion will be adequately managed so that the intended functions will be maintained consistent with the CLB during the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.4.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report In CNP LRA Tables 3.4.2-1 through 3.4.2-4, the project team reviewed additional details of the results of the AMRs for material, environment, aging effect requiring management, and AMP combinations that are not consistent with the GALL Report.

7.2.4.3.1 Main Feedwater System Summary of Aging Management (CNP LRA Table 3.4.2-1)

The project team reviewed Table 3.4.2-1 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the main feedwater system component groups.

In the CNP LRA, the applicant states that it has identified no aging effects for stainless steel components exposed to air, including piping and valve component types. Air is not identified in the GALL Report as an environment for these components and materials.

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D.C. Cook Audit & Review Report On the basis of current industry research and operating experience, dry air on metal will not result in aging that will be of concern during the period of extended operation. The external environments being referred to are typical of ambient air, e.g., under a shelter, indoor, or air-conditioned enclosure or room. Wrought austenitic stainless steels and CASS are not susceptible to significant general corrosion that would affect the intended function of components. Therefore, the project team concludes that there are no aging effects requiring management for metal in a dry air environment.

In the CNP LRA, the applicant states that cracking and loss of material for stainless steel components exposed to an internal environment of treated water greater than 270EF are managed using CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry," with enhancements. The project team's evaluation of this AMP is documented in Section 7.1.31 of this report. The GALL Report,Section VIII.D.1.1-c, recommends that the AMP be augmented by verifying the effectiveness of the water chemistry control program. CNP LRA Table 3.4.1, Item Number 3.4.1-2, and CNP LRA Section 3.4.2.2.2 both identify CNP AMP B.1.41, "Water Chemistry Control - Chemistry One-Time Inspection," as the verification program that will supplement CNP AMP B.1.40.1 for main feedwater system components.

In the CNP LRA, the applicant states that CNP AMP B.1.41 is a new program that is consistent with GALL AMP XI.M32, "One-Time Inspection," but of a more limited scope. NRR DE staff evaluation of CNP AMP B.1.41 is documented in Section 3 of the SER related to the CNP LRA.

7.2.4.3.2 Main Steam System Summary of Aging Management (CNP LRA Table 3.4.2-2)

The project team reviewed Table 3.4.2-2 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the main steam system component groups.

The applicant states, in the CNP LRA, that it has identified no aging effects for stainless steel components exposed to air, including manifold (piping), piping, tubing, and valve component types. Air is not identified in the GALL Report as an environment for these components and materials.

On the basis of current industry research and operating experience, dry air on metal will not result in aging that will be of concern during the period of extended operation. The external environments being referred to are typical of ambient air, e.g., under a shelter, indoor, or air-conditioned enclosure or room. Wrought austenitic stainless steels and CASS are not susceptible to significant general corrosion that would affect the intended function of components. Therefore, the project team concludes that there are no aging effects requiring management for metal in a dry air environment.

In the CNP LRA, the applicant states that cracking and loss of material for stainless steel manifold, piping, tubing, and valves exposed to internal environments of treated water greater than 270EF and steam greater than 270EF are managed using CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry," with enhancements. The project team's evaluation of this AMP is documented in Section 7.1.31 of this report. The project team noted that similar component, material, environment combinations are not discussed in the GALL Report. However, the aging effects of cracking and loss of material for the main steam system stainless steel components exposed to internal environments of treated water greater than 270EF and steam greater than 270EF are consistent with industry operating 200

D.C. Cook Audit & Review Report experience. The project team finds that the appropriate aging effects were identified and are adequately managed, and therefore are acceptable.

7.2.4.3.3 Auxiliary Feedwater System Summary of Aging Management (CNP LRA Table 3.4.2-3)

The project team reviewed Table 3.4.2-3 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the auxiliary feedwater system component groups.

The applicant states, in the CNP LRA that it has identified no aging effects for the copper alloy fittings, manifold, tubing, and valves exposed to air; as well as fittings, tubing, and valves in outdoor air. No aging effects were identified for stainless steel fittings, manifold, orifice, tubing, and valves exposed to air, as well as fittings, piping, tank, tubing, and valves in outdoor air. Air is not identified in the GALL Report as an environment for these components and materials.

On the basis of current industry research and operating experience, dry air on metal will not result in aging that will be of concern during the period of extended operation. The external environments being referred to are typical of ambient air, e.g., under a shelter, indoors, or air-conditioned enclosure or room. Wrought austenitic stainless steels are not susceptible to significant general corrosion that would affect the intended function of components. Therefore, the project team concludes that there are no aging effects requiring management for metal in a dry air environment.

In the CNP LRA, the applicant states that cracking and loss of material for stainless steel fittings, tubing, and valves exposed to an internal environment of steam greater than 270EF are managed using CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry," with enhancements. The project team's evaluation of this AMP is documented in Section 7.1.31 of this report. The similar component, material, environment combinations are not discussed in the GALL Report. The aging effects of cracking and loss of material for the auxiliary feedwater system stainless steel components exposed to an internal environment of steam greater than 270EF are consistent with industry operating experience. The project team finds that the appropriate aging effects were identified and are adequately managed. The project team finds this to be acceptable.

In the CNP LRA, the applicant states that fouling and loss of material for copper-alloy heat exchanger tubes exposed to an external environment of lubricating oil is managed using CNP AMP.1.23, "Oil Analysis." The project team's evaluation of this program is documented in Section 7.1.17. The similar component, material, environment combination is not discussed in the GALL Report. On the basis that the applicants oil analysis program maintains oil systems free of contaminants (primarily water and particulates), the project team finds that this program adequately manages cracking and loss of material for components exposed to lubricating oil.

In the CNP LRA, the applicant states that there are no aging effects for the sight glass component type (glass) in an external environment of air or an internal environment of lubricating oil. Similar component, material, environment combinations are not discussed in the GALL Report. On the basis that no aging effects require management for these components, the project team finds that the absence of an AMP for glass to be acceptable.

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D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that cracking and change in material properties of tank elastomer exposed to an external environment of air and an internal environment of treated water are managed using CNP AMP B.1.25, "Preventive Maintenance," with enhancement.

The applicant states that the program enhancement will rely upon visual inspection to detect cracking and change in material properties of the auxiliary feedwater system elastomer condensate storage tank floating head seals. The project team's evaluation of this AMP is documented in Section 7.1.19 of this report.

The similar component, material, environment combination is not discussed in the GALL Report. The project team found documentation of only visual inspection, which is an acceptable method for the detection of cracking. The project team requested clarification as to how the applicant intends to detect changes in material properties. By letter dated May 26, 2004 (ML041480115), the staff asked the applicant, in RAI 3.4-9, to describe how they will manage the change in material properties and cracking of elastomeric materials in tanks, including inspection methods for inaccessible locations, frequency of inspections, acceptance criteria, and the basis thereof. This is followup item 7.2.4.3-1 and will be dispositioned in the SER for the CNP LRA (RAI 3.4-9).

In the CNP LRA, the applicant states that loss of material from copper-alloy valves in treated water is managed using the water chemistry control program. On the basis that this is consistent with the management of similar items identified in the GALL Report, the project team finds it to be acceptable.

7.2.4.3.4 Blowdown System Summary of Aging Management (CNP LRA Table 3.4.2-4)

The project team reviewed Table 3.4.2-4 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the blowdown system component groups.

The applicant states that it has identified no aging effects for stainless steel components exposed to air, including orifice, piping, tubing, and valve component types. Air is not identified in the GALL Report as an environment for these components and materials.

On the basis of current industry research and operating experience, dry air on metal will not result in aging that will be of concern during the period of extended operation. The external environments being referred to are typical of ambient air, e.g., under a shelter, indoor, or air-conditioned enclosure or room. Therefore, the project team concludes that there are no aging effects requiring management for metal in a dry air environment.

In the CNP LRA, the applicant states that cracking and loss of material for stainless steel orifice, piping, tubing, and valves exposed to an internal environment of treated water greater than 270EF are managed using CNP AMP B.1.40.1, "Water Chemistry Control - Primary and Secondary Water Chemistry," with enhancements. The project team's evaluation of this AMP is documented in Section 7.1.31 of this report. The similar component, material, environment combinations are not discussed in the GALL Report. The aging effects of cracking and loss of material for the blowdown system stainless steel components exposed to internal environments of treated water greater than 270EF are consistent with industry operating experience. The project team finds that the appropriate aging effects were identified and are adequately managed. The project team finds this to be acceptable.

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D.C. Cook Audit & Review Report 7.2.5 CNP LRA Section 3.5 - Aging Management of Structures and Component Supports In LRA Section 3.5, the applicant provides the results of its AMRs for SCs.

In LRA Tables 3.5.2-1 through 3.5.2-5 (Table 2s), the applicant provides a summary of the AMRs for component types associated with the following structures and commodities: (1) containment; (2) auxiliary building; (3) turbine building and screenhouse; (4) yard structures; and (5) structural commodities. The summary information for each component type includes:

intended function, material, environment, aging effect requiring management, AMPs, the GALL Report Volume 2 item, cross reference to LRA Table 3.5.1 (Table 1), and generic and plant-specific notes related to consistency with the GALL Report.

Also, the applicant identifies for each component type in LRA Table 3.5.1 (Table 1) those components where further evaluation is recommended, those for which no further evaluation is required, and those that are not applicable to CNP together with the basis for their exclusion.

Additionally, the applicant identifies in LRA Tables 3.5.2-1 through 3.5.2-5 which AMR results it considers to be consistent with the GALL Report (table column Notes A through E) and which it justifies on a different basis.

The AMRs that are within the scope of the project team audit and review are identified on copies of LRA Tables 3.5.2-1 through 3.5.2-5 included as an appendix to the CNP audit and review plan.

The project team conducted its audit and review in accordance with SRP-LR Section 3.5.3 and the CNP audit and review plan.

7.2.5.1 Aging Management Evaluations That Are Consistent With the GALL Report, for Which No Further Evaluation Is Required For aging management evaluations that the applicant states are consistent with the GALL Report and for which further evaluation is not recommended, the project team conducted its review and audit to determine if the applicant's reference to the GALL Report in the LRA is acceptable.

The project team concluded that the applicant: (1) provides a brief description of the system, components, materials, and environment; (2) states that the applicable aging effects have been reviewed and are evaluated in the GALL Report; and (3) identifies those aging effects for the SCs that are subject to an AMR. The project team also concluded that the LRA line item is consistent with the GALL Report Volume 2 system tables line item for component type, material, environment, aging effect, and AMP.

7.2.5.1.1 Loss of Material Due to Corrosion in Accessible Areas Only In CNP LRA Table 3.5.1, Item Number 3.5.1-14, the applicant states that loss of material due to corrosion in accessible areas only is not applicable. Protective coatings are not relied upon to manage the effects of aging at CNP.

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D.C. Cook Audit & Review Report The project team noted that although protective coatings are not credited, they have the potential to exacerbate an aging effect in that damage to protective coatings may accelerate corrosion. During the audit, the project team asked the applicant to address how damage to protective coatings is addressed. The applicant discussed the use of external coatings and wrappings, the measures taken during excavation of buried pipes, and inspections performed when buried pipe is exposed. These were acceptable to the project team.

On the basis of its audit and review, the project team determined that for AMRs not requiring further evaluation, as identified in LRA Table 3.5.1 (Table 1), the applicant's references to the GALL Report are acceptable, that the line items are consistent with GALL, and no further project team review is required.

7.2.5.2 Aging Management Evaluations That Are Consistent With the GALL Report, for Which Further Evaluation Is Recommended For some line items consistent with the GALL Report in LRA Tables 3.5.2-1 through 3.5.2-5, the GALL Report recommends further evaluation. When further evaluation is recommended, the project team reviewed these evaluations provided in LRA Section 3.5.2.2 against the criteria provided in SRP-LR Section 3.5.2.2. The following provides the project team's assessments of these evaluations. These project team assessments are applicable to each Table 2 line item in Section 3.5 citing the particular item in Table 1.

The LRA sections identified in LRA Table 3.5.1 where further evaluation is recommended are discussed below.

7.2.5.2.1 PWR Containments (CNP LRA Section 3.5.2.2.1)

The project team reviewed LRA Section 3.5.2.2.1 against the criteria in SRP-LR Section 3.5.2.2.1, which addresses several areas discussed below.

7.2.5.2.1.1 Aging of Inaccessible Concrete Areas (CNP LRA Section 3.5.2.2.1.1)

The project team reviewed LRA Section 3.5.2.2.1.1 against the criteria in SRP-LR Section 3.5.2.2.1.1.

In LRA Section 3.5.2.2.1.1, the applicant addresses aging of inaccessible concrete areas for the containment.

For inaccessible portions of the containment structure, 10 CFR 50.55a(b)(2)(ix) requires that the licensee evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of, or result in, degradation to inaccessible areas.

The AMP recommended by the GALL Report for managing the aging of the accessible portions of the containment structures is GALL AMP XI.S2, "ASME Section XI, Subsection IWL." The applicant addresses this with CNP AMP B.1.17, "Inservice Inspection - ASME Section XI, Subsection IWL (AMP B.1.17)" which is evaluated in Section 7.1.12. Subsection IWL exempts from examination those portions of the concrete containment that are inaccessible (e.g.,

foundation, below-grade exterior walls, or concrete covered by liner).

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D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that it also uses CNP AMP B.1.32, "Structures Monitoring

- Structures Monitoring," where accessible areas are monitored for evidence of aging effects that may be applicable to containment structures. The project team reviewed this program and concludes that this program is consistent with GALL AMP XI.S6, "Structures Monitoring Program." Its evaluation is documented in Section 7.1.23. The applicant also credits the CNP AMP B.1.32 for the examination of below-grade concrete when it is exposed by excavation.

In the GALL Report, Volume 2, Chapter II, Table A1 (as modified by ISG-3, Concrete Aging Management Program), further evaluation is recommended to manage the aging effects for containment concrete components located in inaccessible areas if the aging mechanisms of (1) freeze-thaw; (2) leaching of calcium hydroxide; (3) aggressive chemical attack; (4) reaction with aggregates; or (5) corrosion of embedded steel are significant. Possible aging effects for containment concrete structural components due to these five aging mechanisms are cracking, change in material properties, and loss of material.

(1) Freeze-thaw SRP-LR Section 3.5.2.2.1.1 does not address freeze-thaw as an aging mechanism for concrete containments because no further evaluation is recommended in the GALL Report. However, ISG-3 clarifies the staff position that further evaluation is appropriate if the applicant's facility is subject to moderate to severe weathering conditions unless the concrete meets certain specifications and subsequent inspections have confirmed that the aging mechanism has not caused degradation of the concrete.

CNP is located in a region considered to be subject to moderate weathering conditions. In the CNP LRA, the applicant states that its concrete structures are designed in accordance with American Concrete Institute (ACI) specification ACI 318-63, Building Code Requirements for Reinforced Concrete, which results in low permeability and resistance to aggressive chemical solutions by requiring the following:

(1) high cement content, (2) low water-to-cement ratio, (3) proper curing, and (4) adequate air entrainment.

In the CNP LRA, the applicant states that CNP concrete also meets requirements of the guideline ACI 201.2R-77, "Guide to Durable Concrete." ACI 318-63 and ACI 201.2R-77 use the same ASTM standards for selection, application and testing of concrete.

The project team interviewed members of the applicant's technical staff and reviewed relevant operating experience to confirm that loss of material from freeze-thaw has not been observed, either through the inservice inspection - IWL program or the structures monitoring program.

On the basis that concrete that satisfies the requirements of ACI 318-63 will meet the requirements of ISG-3, and on the basis of an audit of operating experience evaluated under the inservice inspection - IWL and structures monitoring programs, the project team finds that loss of material and cracking due to freeze-thaw will be adequately managed by the containment inservice inspection program.

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D.C. Cook Audit & Review Report (2) Leaching of calcium hydroxide SRP-LR Section 3.5.2.2.1.1 states that cracking, spalling, and increases in porosity and permeability due to leaching of calcium hydroxide could occur in inaccessible areas of PWR concrete and steel containments. The GALL Report, as updated by ISG-3, recommends further evaluation of plant-specific programs to manage the aging effects for inaccessible areas if specific criteria cannot be satisfied.

The GALL Report states that leaching of calcium hydroxide becomes significant only if the concrete is exposed to flowing water. Even if reinforced concrete is exposed to flowing water, such leaching is not significant if the concrete is constructed to ensure that it is dense, well-cured, has low permeability, and that cracking is well controlled.

In the CNP LRA, the applicant states that CNP concrete structures are designed in accordance with specification ACI 318-63 and meets the requirements of guideline ACI 201.2R-77.

The project team finds that because ACI 318 provides assurance that the criteria of the GALL Report and ISG-3 are met, leaching of calcium hydroxide is not significant at CNP, and therefore concludes that the inservice inspection - IWL program will be sufficient for management of increases in porosity and permeability from this aging mechanism. A plant-specific aging management program is not required to address this aging effect.

(3) Aggressive chemical attack SRP-LR Section 3.5.2.2.1.1 states that cracking, spalling, and increases in porosity and permeability due to aggressive chemical attack could occur in inaccessible areas of PWR concrete and steel containments. The GALL Report recommends further evaluation of plant-specific programs to manage the aging effects for inaccessible areas if specific criteria defined in the GALL Report and updated in ISG-3 cannot be satisfied.

The GALL Report, as updated by ISG-3, states that aggressive chemical attack is not significant unless pH is less than 5.5, chlorides are greater than 500 ppm, or sulfates are greater than1500 ppm. ISG-3 also states that a plant specific program is required to examine representative samples of below-grade concrete when excavated for any reason.

In the CNP LRA, the applicant states that the below-grade environment is not aggressive (pH greater than 5.5, chlorides less than 500 ppm, and sulfates less than 1,500 ppm). In addition, the project team noted that the applicant uses the structures monitoring program for the examination of below-grade concrete when it is exposed by excavation.

On the basis of the information provided in the CNP LRA, and the guidelines provided in the SRP-LR, the GALL Report, and ISG-3, the project team finds that increases in porosity and permeability, loss of material (spalling, scaling) and cracking due to aggressive chemical attack are not significant for concrete in inaccessible areas. The project team finds that an appropriate plant-specific program for examination of below-grade concrete has been identified.

(4) Reaction with aggregates 206

D.C. Cook Audit & Review Report SRP-LR Section 3.5.2.2.1.1 does not address reaction with aggregates as an aging mechanism for concrete containments because no further evaluation is recommended in the GALL Report.

However, ISG-3 clarifies the staff position that further evaluation is appropriate if investigations, tests, or examinations have demonstrated that the aggregates are reactive.

In the CNP LRA, the applicant states that CNP concrete structures are designed in accordance with specification ACI 318-63 and meets the requirements of guideline ACI 201.2R-77. The ACI standards call for the testing of aggregates at the time of construction.

On the basis of interviews with the applicant's technical staff, the project team confirmed that the results of those tests show that the aggregates used for concrete containment at CNP are not reactive. The project team finds that this aging effect does not require management at CNP.

(5) Corrosion of embedded steel SRP-LR Section 3.5.2.2.1.1 states that loss of material due to corrosion of embedded steel could occur in inaccessible areas of PWR concrete and steel containments. The GALL Report (updated in ISG-3) recommends further evaluation of plant-specific programs to manage the aging effects for inaccessible areas if specific criteria defined in the GALL Report cannot be satisfied.

For cracking, loss of bond, and loss of material (spalling, scaling) due to corrosion of embedded steel, the GALL Report states that a plant-specific program is only required if the below-grade environment is aggressive. ISG-3 also states that a plant specific program is required to examine representative samples of below-grade concrete when excavated for any reason.

In the CNP LRA, the applicant credits, for corrosion of embedded steel in accessible areas, CNP AMP B.1.17, Inservice Inspection - ASME Section XI, Subsection IWL, and CNP AMP B.1.32, Structures Monitoring - Structures Monitoring. In LRA Section 3.5.2.2.1.1, the applicant states, for aging of inaccessible concrete areas, that the below-grade environment is not aggressive (pH greater than 5.5, chlorides less than 500 ppm, and sulfates less than 1,500 ppm). In addition, the project team noted that the applicant uses the structures monitoring program for the examination of below-grade concrete when it is exposed by excavation.

On the basis of interviews with the applicant's technical staff, the project team determined that the environment at the time of construction was not aggressive and on the basis of subsequent testing it has remained within the limits identified in the GALL Report. The project team finds that in accordance with the criteria of the GALL Report this aging effect is not significant and is adequately managed.

The project team reviewed the results of the applicant's AMR for inaccessible concrete areas.

On the basis of its review, the project team finds that the applicant appropriately evaluated AMR results involving management of aging of inaccessible concrete areas for containment, as recommended in the GALL Report and ISG-3.

The project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

207

D.C. Cook Audit & Review Report 7.2.5.2.1.2 Cracking, Distortion, and Increase in Component Stress Level Due to Settlement; Reduction of Foundation Strength Due to Erosion of Porous Concrete Subfoundations, if Not Covered by Structures Monitoring Program (CNP LRA Section 3.5.2.2.1.2)

The project team reviewed LRA Section 3.5.2.2.1.2 against the criteria in SRP-LR Section 3.5.2.2.1.2.

In CNP LRA Section 3.5.2.2.1.2, the applicant addresses (1) cracking, distortion and increase in component stress level due to settlement and (2) reduction of foundation strength due to erosion of porous concrete subfoundations in the containment. The applicant uses CNP AMP B.1.32, "Structures Monitoring - Structures Monitoring" where accessible areas are monitored for evidence of aging effects that may be applicable to containment structures. This program, which is consistent with GALL AMP XI.S6, "Structures Monitoring Program," is evaluated in Section 7.1.23.

SRP-LR Section 3.5.2.2.1.2 states that cracking, distortion, and increase in component stress level due to settlement could occur in PWR concrete and steel containments. A recent staff survey has found that there are 12 nuclear reactor structures which have porous concrete foundations with high alumina content, and CNP structures are not in this group. These foundations are susceptible to reduction in strength and settlement potential due to erosion of cement from porous concrete. Some plants may rely on a de-watering system to lower the site ground water level. If the plant's CLB credits a de-watering system, the GALL Report recommends verification of the continued functionality of the de-watering system during the period of extended operation. The GALL Report recommends no further evaluation if this activity is included in the scope of the applicant's structures monitoring program.

The applicant states, in the CNP LRA, that it does not credit a de-watering system for control of settlement because settlement was monitored at CNP and it was confirmed that significant settlement was not occurring. Concrete within five feet of the highest known groundwater level is protected by membrane waterproofing, which protects the containment building concrete against exposure to groundwater. Consequently, the applicant was not identified in NRC IN 97-11, Cement Erosion From Containment Subfoundations at Nuclear Power Plants, as a plant susceptible to erosion of porous concrete subfoundations. Groundwater was not aggressive during plant construction and no changes in groundwater chemistry conditions have been observed. The applicant has included these components within the plant-specific structures monitoring program, which will confirm that these aging effects are adequately managed.

The project team reviewed the AMR results involving management of aging effects resulting from settling and erosion of porous concrete subfoundations and confirmed that the structures monitoring program addresses each of the affected SCs. On the basis of this review, the project team finds that the applicant has appropriately evaluated AMR results involving cracking, distortion, and increase in component stress level from settlement and reduction of foundation strength from erosion, as recommended in the GALL Report.

The project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

208

D.C. Cook Audit & Review Report 7.2.5.2.1.3 Reduction of Strength and Modulus of Concrete Structures Due to Elevated Temperature (CNP LRA Section 3.5.2.2.1.3)

The project team reviewed LRA Section 3.5.2.2.1.3 against the criteria in SRP-LR Section 3.5.2.2.1.3.

In LRA Section 3.5.2.2.1.3, the applicant addresses reduction of strength and modulus of concrete structures due to elevated temperature in containments.

SRP-LR Section 3.5.2.2.1.3 states that reduction of strength and modulus of elasticity due to elevated temperatures could occur in PWR concrete and steel containments. The GALL Report calls for a plant-specific aging management program and recommends further evaluation if any portion of the concrete containment components exceeds specified temperature limits, i.e., general area temperature 66EC (150EF) and local area temperature 93EC (200EF).

In CNP LRA Section 3.5.2.2.1.3, the applicant states that during normal operation, all areas within the containment building are below 150EF ambient temperature except for the Unit 1 pressurizer enclosure, which is at 160EF. Several penetrations have been exposed to temperatures greater than 200EF; however, this was temporary and the effect was negligible.

Therefore, the applicant concluded that change in material properties due to elevated temperature is an aging effect requiring management for the containment concrete only for the pressurizer enclosure area for Unit 1, where ambient temperature exceeds 150EF.

The applicant concludes that CNP containment concrete structures are not subject to change in material properties due to elevated temperature. The applicant has included these components within the scope of CNP AMP B.1.32, "Structures Monitoring - Structures Monitoring," evaluated in Section 7.1.23 of this report, and AMP B.1.17, "Inservice Inspection - ASME Section XI, Subsection IWL," evaluated in Section 7.1.12 of this report, to monitor for indications of change in material properties for containment concrete aging effects.

The project team reviewed the AMR results involving management of aging effects resulting from elevated temperature and confirmed that the inservice inspection - IWL and structures monitoring programs address each of the affected SCs. On the basis of this audit and review, the project team finds that the applicant has appropriately evaluated AMR results involving reduction of strength and modulus due to elevated temperature, as recommended in the GALL Report.

On the basis that the concrete is not exposed to elevated temperatures with the exceptions noted above, the project team finds that for all other locations, the structures monitoring and inservice inspection - IWL programs appropriately manage this aging effect, and no further evaluation is required.

The project team finds that the applicant has demonstrated that the effects of aging of the concrete due to elevated temperature will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

209

D.C. Cook Audit & Review Report 7.2.5.2.1.4 Loss of Material Due to Corrosion in Inaccessible Areas of Steel Containment Shell or Liner Plate (CNP LRA Section 3.5.2.2.1.4)

The project team reviewed LRA Section 3.5.2.2.1.4 against the criteria in SRP-LR Section 3.5.2.2.1.4.

In CPN LRA Section 3.5.2.2.1.4, the applicant addresses loss of material due to corrosion in inaccessible areas of the steel containment shell or the steel liner plate for the containment.

SRP-LR Section 3.5.2.2.1.4 states that loss of material due to corrosion could occur in inaccessible areas of the steel containment shell or the steel liner plate for all types of PWR containments. The GALL Report recommends further evaluation of plant-specific programs to manage this aging effect for inaccessible areas if the following specific criteria defined in the GALL Report cannot be satisfied: (1) concrete meeting the requirements of ACI 318 or 349 and the guidance of 201.2R was used for the containment concrete in contact with the embedded containment shell or liner; (2) the accessible concrete is monitored to ensure that it is free of penetrating cracks that provide a path for water seepage to the surface of the containment shell or liner; (3) the accessible portion of the moisture barrier, at the junction where the shell or liner becomes embedded, is subject to aging management activities in accordance with IWE requirements; and (4) borated water spills and water ponding on the containment concrete floor are not common and when detected are cleaned up in a timely manner.

In the CNP LRA, the applicant states that the containment concrete in contact with the steel liner plate is designed in accordance with ACI 318-63, and meets the requirements of guideline ACI 201.2R-77. Accessible concrete is monitored for cracks under the structures monitoring program. The accessible portions of the steel liner plate and moisture barrier where the liner becomes embedded are inspected in accordance with the inservice inspection - ASME Section XI, Subsection IWE program. Spills (e.g., borated water spill) are cleaned up in a timely manner. The applicant also states that the aging effect of loss of material due to corrosion has not been significant for this liner plate.

The project team reviewed the structures monitoring program and the inservice inspection -

ASME Section XI, Subsection IWE program and its evaluation is documented in Section 7.1.23 and Section 7.1.10 of this report, respectively. Based on its review and on the basis that all of the criteria identified in the GALL Report are satisfied, the project team finds that no additional, plant-specific aging management program is required to manage inaccessible areas of the steel containment liner plate.

On the basis of its audit and review, the staff finds that the applicant has appropriately evaluated AMR results involving loss of material due to corrosion that could affect inaccessible areas of the steel liner plate, the containment liner plate. The project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.5.2.1.5 Loss of Prestress Due to Relaxation, Shrinkage, Creep, and Elevated Temperature (CNP LRA Section 3.5.2.2.1.5) 210

D.C. Cook Audit & Review Report CNP LRA Section 3.5.2.2.1.5 is reviewed by the NRR DE staff and addressed in Section 4 of the SER related to the CNP LRA.

7.2.5.2.1.6 Cumulative Fatigue Damage (CNP LRA Section 3.5.2.2.1.6)

CNP LRA Section 3.5.2.2.1.6 is reviewed by the NRR DE staff and addressed in Section 4 of the SER related to the CNP LRA.

7.2.5.2.1.7 Cracking Due to Cyclic Loading and Stress Corrosion Cracking (CNP LRA Section 3.5.2.2.1.7)

The project team reviewed CNP LRA Section 3.5.2.2.1.7 against the criteria in SRP-LR Section 3.5.2.2.1.7.

In CNP LRA Section 3.5.2.2.1.7, the applicant addresses aging mechanisms that can lead to cracking of penetration sleeves and penetration bellows such as cyclic loads and SCC.

SRP-LR Section 3.5.2.2.1.7 states that cracking of containment penetrations (including penetration sleeves, penetration bellows, and dissimilar metal welds) due to cyclic loading or SCC could occur in containments. Further evaluation of inspection methods is recommended to detect cracking due to cyclic loading and SCC since visual examinations (VT-3) may be unable to detect this aging effect.

GALL AMP XI.S1, "ASME Section XI, Subsection IWE" covers inspection of these items under examination categories E-B, E-F, and E-P (10 CFR Part 50, Appendix J pressure tests).

10 CFR 50.55a identifies examination categories E-B and E-F as optional during the current term of operation. For the period of extended operation, examination categories E-B and E-F, and additional appropriate examinations to detect SCC in bellows assemblies and dissimilar metal welds are warranted to address this issue.

To manage this aging effect, the applicant uses CNP AMP B.1.8, "Containment Leakage Rate Testing," evaluated in Section 7.1.3, and CNP AMP B.1.15, "Inservice Inspection - ASME Section XI, Subsection IWE," evaluated in Section 7.1.10. In SRP-LR Section 3.5.2.2.1.7, further evaluation of this aging effect is recommended for stainless steel penetration bellows and dissimilar metal welds. In LRA Tables 3.5.2-1 through 3.5.2-5, the applicant did not identify penetration bellows and dissimilar metal welds as subject to aging management review.

The project team finds that cracking due to SCC is not an applicable aging effect for CNP, and augmented inspection to detect cracking is not necessary.

On the basis of its review, the project team finds that the applicant has appropriately evaluated AMR results involving management of cracking due to SCC for containment components, as recommended in the GALL Report. Since the applicant's AMR results are otherwise consistent with the GALL Report, the staff finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

Cracking due to cyclic loading of the liner plate and penetrations is a TLAA which is evaluated by the NRR DE staff and addressed in Section 4 of the SER related to the CNP LRA.

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D.C. Cook Audit & Review Report 7.2.5.2.2 Class 1 Structures (CNP LRA Section 3.5.2.2.2)

The project team reviewed CNP LRA Section 3.5.2.2.2 against the criteria in SRP-LR Section 3.5.2.2.2, which addresses several areas discussed below.

7.2.5.2.2.1 Aging of Structures Not Covered by Structures Monitoring Program (CNP LRA Section 3.5.2.2.2.1)

The project team reviewed CNP LRA Section 3.5.2.2.2.1 against the criteria in SRP-LR Section 3.5.2.2.2.1.

In CNP LRA Section 3.5.2.2.2.1, the applicant addresses aging of Class 1 structures not covered by the structures monitoring program.

SRP-LR Section 3.5.2.2.2.1 states that the GALL Report recommends further evaluation of certain structure/aging effect combinations if they are not covered by the structures monitoring program. This is described in GALL Report Chapter III and includes (1) scaling, cracking, and spalling due to repeated freeze-thaw for Groups 1-3, 5, 7-9 structures; (2) scaling, cracking, spalling and increase in porosity and permeability due to leaching of calcium hydroxide and aggressive chemical attack for Groups 1-5, 7-9 structures; (3) expansion and cracking due to reaction with aggregates for Groups 1-5, 7-9 structures; (4) cracking, spalling, loss of bond, and loss of material due to corrosion of embedded steel for Groups 1-5, 7-9 structures; (5) cracks, distortion, and increase in component stress level due to settlement for Groups 1-3, 5, 7-9 structures; (6) reduction of foundation strength due to erosion of porous concrete subfoundations for Groups 1-3, 5-9 structures; (7) loss of material due to corrosion of structural steel components for Groups 1-5, 7-8 structures; (8) loss of strength and modulus of concrete structures due to elevated temperatures for Groups 1-5; and (9) crack initiation and growth due to SCC and loss of material due to crevice corrosion of stainless steel liner for Groups 7 and 8 structures. Further evaluation is necessary only for structure/aging effect combinations not covered by the structures monitoring program.

Technical details of the aging management issue are presented in SRP-LR Subsection 3.5.2.2.1.2 for structure/aging effect combinations Items (5) and (6) and SRP-LR Subsection 3.5.2.2.1.3 for Item (8).

In CNP LRA Table 3.5.1, Item Number 20, the applicant credits its structures monitoring program for all types of aging effects and all component groups except Group 6 of accessible interior and exterior concrete and steel components of Class 1 structures. The project team reviewed this program and its evaluation is documented in Section 7.1.23 of this report.

Additional discussion of specific structure/aging effect combinations follows.

(1) Freeze-thaw SRP-LR Section 3.5.2.2.1.2 does not address freeze-thaw as an aging mechanism for concrete containments because no further evaluation is recommended in the GALL Report. However, ISG-3 clarifies the staff position that further evaluation is appropriate if the applicant's facility is subject to moderate to severe weathering conditions unless the concrete meets certain specifications and subsequent inspections have confirmed that the aging mechanism has not caused degradation of the concrete.

212

D.C. Cook Audit & Review Report CNP is located in a region considered to be subject to moderate weathering conditions. In the CNP LRA, the applicant states that CNP structures are designed in accordance with specification ACI 318-63, which results in low permeability and resistance to aggressive chemical solutions by requiring the following:

(1) high cement content, (2) low water-to-cement ratio, (3) proper curing, and (4) adequate air entrainment.

In addition to ACI 318-63, the applicant states, in the CNP LRA, that it concrete also meets requirements of the guideline of ACI 201.2R-77. ACI 318-63 and ACI 201.2R-77 use the same ASTM standards for selection, application and testing of concrete.

The project team interviewed members of the applicant's technical staff and reviewed relevant operating experience to confirm that loss of material from freeze-thaw has not been observed, either through the inservice inspection - IWL program or the structures monitoring program.

On the basis that concrete that satisfies the requirements of ACI 318-63 will meet the requirements of ISG-3, and on the basis of an audit of operating experience evaluated under the structures monitoring program, the project team finds that loss of material and cracking due to freeze-thaw will be adequately managed by the structures monitoring program.

(2)(a) Leaching of calcium hydroxide SRP-LR Section 3.5.2.2.2.1 states that cracking, spalling, and increases in porosity and permeability due to leaching of calcium hydroxide could occur in inaccessible areas of PWR concrete and steel containments. The GALL Report, as updated by ISG-3, recommends further evaluation of plant-specific programs to manage the aging effects for inaccessible areas exposed to flowing water, unless the requirements of ACI 201.2R are met.

The GALL Report states that leaching of calcium hydroxide becomes significant only if the concrete is exposed to flowing water. Even if reinforced concrete is exposed to flowing water, such leaching is not significant if the concrete is constructed to ensure that it is dense, well-cured, has low permeability, and that cracking is well controlled.

In the CNP LRA, the applicant states that its concrete structures are designed in accordance with specification ACI 318-63 and meet the requirements of guideline ACI 201.2R-77. The applicant also states that its concrete is not exposed to flowing water.

The project team reviewed relevant operating experience, interviewed members of the applicants technical staff, and reviewed ISG-3. The project team finds that, because ACI 318-63 provides assurance that the criteria of the GALL Report and ISG-3 are met, and the applicants concrete is not exposed to flowing water, leaching of calcium hydroxide is not significant at CNP, and therefore concludes that the structures monitoring program will be sufficient for management of increases in porosity and permeability from this aging mechanism.

A plant-specific aging management program is not required to address this aging effect.

(2)(b) Aggressive chemical attack 213

D.C. Cook Audit & Review Report SRP-LR Section 3.5.2.2.2.1 states that cracking, spalling, and increases in porosity and permeability due to aggressive chemical attack could occur in inaccessible areas of Class 1 structures. The GALL Report recommends further evaluation of plant-specific programs to manage the aging effects for inaccessible areas if specific criteria defined in the GALL Report and updated in ISG-3 cannot be satisfied.

The GALL Report as updated by ISG-3 states that aggressive chemical attack is not significant unless pH is less than 5.5, chlorides are greater than 500 ppm, or sulfates are greater than1500 ppm. ISG-3 also states that a plant specific program is required to examine representative samples of below-grade concrete when excavated for any reason.

In the CNP LRA, the applicant states that the below-grade environment is not aggressive (pH greater than 5.5, chlorides less than 500 ppm, and sulfates less than 1,500 ppm). In addition, the project team noted that the applicant uses the structures monitoring program for the examination of below-grade concrete when it is exposed by excavation.

The project team reviewed the information provided in the CNP LRA, the basis documents, and the guidelines provided in the SRP-LR, the GALL Report, and ISG-3. On the basis of its review, the project team finds that increases in porosity and permeability, loss of material (spalling, scaling) and cracking due to aggressive chemical attack are not significant for concrete in inaccessible areas. The project team finds that an appropriate plant-specific program for examination of below-grade concrete (specifically, an enhancement to the structures monitoring program) has been identified.

(3) Reaction with aggregates SRP-LR Section 3.5.2.2.2.1 does not address reaction with aggregates as an aging mechanism for concrete containments because no further evaluation is recommended in the GALL Report.

However, ISG-3 clarifies the staff's position that further evaluation is appropriate if investigations, tests, or examinations have demonstrated that the aggregates are reactive.

In the CNP LRA, the applicant states that its concrete structures are designed in accordance with specification ACI 318-63 and meets the requirements of guideline ACI 201.2R-77. The ACI standards call for the testing of aggregates at the time of construction.

On the basis of interviews with the applicant's technical staff, the project team confirmed that the results of those tests showed that the aggregates used for concrete Class 1 structures at CNP are not reactive.

(4) Corrosion of embedded steel SRP-LR Section 3.5.2.2.2.1 states that loss of material due to corrosion of embedded steel could occur in inaccessible areas of Class 1 structures. The GALL Report (updated in ISG-3) recommends further evaluation of plant-specific programs to manage the aging effects for inaccessible areas if specific criteria defined in the GALL Report cannot be satisfied.

For cracking, loss of bond, and loss of material (spalling, scaling) due to corrosion of embedded steel, the GALL Report states that a plant-specific program is only required if the below-grade 214

D.C. Cook Audit & Review Report environment is aggressive. ISG-3 also states that a plant-specific program is required to examine representative samples of below-grade concrete when excavated for any reason.

In the CNP LRA, the applicant states that the below-grade environment is not aggressive because the environment at the time of construction had a measured pH greater than 5.5, chlorides less than 500 ppm, and sulfates less than 1,500 ppm and subsequent testing has shown the environment has remained within these limits.

The project team reviewed the guidelines in the GALL Report and the AMR results involving management of corrosion of embedded steel. On the basis of its review, the project team finds that the aging effect of corrosion of embedded steel is adequately managed by the enhanced structures monitoring program, which is evaluated in Section 7.1.23 of this report.

(5) Settlement SRP-LR Section 3.5.2.2.2.1 refers to Section 3.5.2.2.1.2 for discussion of settlement. SRP-LR Section 3.5.2.2.1.2 states that cracking, distortion, and increase in component stress level due to settlement could occur in Class 1 structures. Some plants may rely on a de-watering system to lower the site ground water level. If the plant's CLB credits a de-watering system, the GALL Report recommends verification of the continued functionality of the de-watering system during the period of extended operation. The GALL Report recommends no further evaluation if this activity is included in the scope of the applicant's structures monitoring program.

The applicant states, in the CNP LRA, that it does not credit a de-watering system for control of settlement because settlement was monitored and it was confirmed that significant settlement was not occurring. Concrete within five feet of the highest known groundwater level is protected by membrane waterproofing, which protects the Class 1 concrete structures against exposure to groundwater. Consequently, CNP was not identified in IN 97-11 as a plant susceptible to erosion of porous concrete sub-foundations. Groundwater was not aggressive during plant construction and no changes in groundwater chemistry conditions have been observed. The applicant has included these components within the plant-specific structures monitoring program, which will confirm that these aging effects are adequately managed.

The project team reviewed the AMR results involving management of aging effects resulting from settling and erosion of porous concrete subfoundations and confirmed that the structures monitoring program addresses each of the affected SCs. On the basis of this review, the project team finds that the applicant has appropriately evaluated AMR results involving cracking, distortion, and increase in component stress level from settlement and reduction of foundation strength from erosion, as recommended in the GALL Report.

(6) Erosion of porous concrete subfoundation SRP-LR Section 3.5.2.2.2.1 refers to Section 3.5.2.2.1.2 for discussion of erosion of porous concrete subfoundation. SRP-LR Section 3.5.2.2.1.2 states that reduction of foundation strength due to erosion of porous concrete subfoundations could occur in all types of Class 1 structures. Some plants may rely on a de-watering system to lower the site ground water level.

If the plant's CLB credits a de-watering system, the GALL Report recommends verification of the continued functionality of the de-watering system during the period of extended operation.

215

D.C. Cook Audit & Review Report The GALL Report recommends no further evaluation if this activity is included in the scope of the applicant's structures monitoring program.

The applicant states that it was not identified in IN 97-11 as a plant susceptible to erosion of porous concrete subfoundations. Groundwater was not aggressive during plant construction and there is no indication that groundwater chemistry has significantly changed. No changes in groundwater conditions have been observed at CNP. The project team finds that cracking, distortion, and increase in component stress level due to settlement and reduction of foundation strength due to erosion of porous concrete subfoundation are adequately managed by the structures monitoring program.

(7) Corrosion of structural steel components SRP-LR Section 3.5.2.2.2.1 states that corrosion of structural steel components could occur and that further evaluation is necessary only for structure/aging effect combinations not covered by the structures monitoring program.

In LRA Section 3.5.2.2.1, the applicant states that corrosion of structural steel components is an aging effect being managed by the structures monitoring program.

The project team reviewed the AMR results involving management of aging effects resulting from corrosion of structural steel components and confirmed that the structures monitoring program, evaluated in Section 7.1.23, addresses each of the affected SCs. On the basis of this audit and review, the project team finds that the applicant has appropriately evaluated AMR results involving this aging effect and that corrosion of structural steel components is adequately managed by the structures monitoring program.

(8) Elevated temperatures SRP-LR Section 3.5.2.2.2.1 refers to Section 3.5.2.2.1.3 for discussion of elevated temperatures. SRP-LR Section 3.5.2.2.1.3 states that reduction of strength and modulus of elasticity due to elevated temperatures could occur in Class 1 structures in Groups 1-5. The GALL Report calls for a plant-specific aging management program and recommends further evaluation if any portion of the concrete components exceeds specified temperature limits, i.e.,

general area temperature 66°C (150°F) and local area temperature 93°C (200°F).

In CNP LRA Section 3.5.2.2.2.1, the applicant states that during normal operation, all concrete areas in Class 1 structures are below 150EF ambient temperature except for the Unit 1 pressurizer enclosure, which is discussed in CNP LRA Section 3.5.2.2.1.3. The project teams evaluation of the Unit 1 pressurizer enclosure elevated temperature is contained in Section 7.2.5.2.1.3 of this report.

The project team reviewed the AMR results involving management of aging effects resulting from elevated temperature and confirmed that the structures monitoring program, evaluated in Section 7.1.23, addresses each of the affected SCs. On the basis of this review, the project team finds that the applicant has appropriately evaluated AMR results involving reduction of strength and modulus due to elevated temperature, as recommended in the GALL Report, and that it is adequately managed by the structures monitoring program.

216

D.C. Cook Audit & Review Report (9) Aging effects for stainless steel liners for tanks In CNP LRA Section 3.5.2.2.2.1, the applicant states that no tanks with stainless steel liners are included in the structural AMRs. Tanks that are subject to an AMR are evaluated with their respective mechanical systems AMRs.

On the basis of its review, the staff finds that the applicant has appropriately evaluated AMR results involving management of aging of accessible interior and exterior concrete and steel components of Class 1 structures (except Group 6, water-control structures, discussed in Section 7.2.5.3.3) and all are covered by the structures monitoring program. This is consistent with the recommendations of the GALL Report. The project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.5.2.2.2 Aging Management of Inaccessible Areas (CNP LRA Section 3.5.2.2.2.2)

The project team reviewed LRA Section 3.5.2.2.2.2 against the criteria in SRP-LR Section 3.5.2.2.2.2.

In CNP LRA Section 3.5.2.2.2.2, the applicant addresses aging of inaccessible areas of Class 1 structures.

SRP-LR Section 3.5.2.2.2.2 states that cracking, spalling, and increases in porosity and permeability due to aggressive chemical attack and cracking, spalling, loss of bond, and loss of material due to corrosion of embedded steel could occur in below-grade inaccessible concrete areas. The GALL Report recommends further evaluation to manage these aging effects in inaccessible areas of Groups 1-3, 5, 7-9 structures, if an aggressive below-grade environment exists. ISG-3 identifies additional requirements.

The GALL Report as updated by ISG-3 states that aggressive chemical attack and corrosion of embedded steel is not significant unless pH is less than 5.5, chlorides are greater than 500 ppm, or sulfates are greater than 1500 ppm. ISG-3 also states that a plant specific program is required to examine representative samples of below-grade concrete when excavated for any reason.

In the CNP LRA Section 3.5.2.2.2.2, the applicant states that the below-grade environment is not aggressive (pH greater than 5.5, chlorides less than 500 ppm, and sulfates less than 1,500 ppm). The project team reviewed the structures monitoring program, evaluated in Section 7.1.23, which is used to examine below-grade concrete when it is exposed by excavation. Inspections of accessible concrete have not revealed degradation from aggressive chemical attack or corrosion of embedded steel.

On the basis that the below-grade environment is not aggressive and that excavated concrete has been and will continue to be monitored, the project team finds that increases in porosity and permeability, loss of material (spalling, scaling) and cracking due to aggressive chemical attack and cracking, spalling, loss of bond, and loss of material due to corrosion of embedded steel are adequately managed for concrete in inaccessible areas.

217

D.C. Cook Audit & Review Report 7.2.5.2.3 Component Supports (CNP LRA Section 3.5.2.2.3)

The project team reviewed LRA Section 3.5.2.2.3 against the criteria in SRP-LR Section 3.5.2.2.3, which addresses several areas discussed below.

7.2.5.2.3.1 Aging of Supports not Covered by Structures Monitoring Program (CNP LRA Section 3.5.2.2.3.1)

The project team reviewed CNP LRA Section 3.5.2.2.3.1 against the criteria in SRP-LR Section 3.5.2.2.3.1.

In the CNP LRA Section 3.5.2.2.3.1, the applicant addresses aging of component supports that are not managed by the structures monitoring program.

SRP-LR Section 3.5.2.2.3.1 states that the GALL Report recommends further evaluation of certain component support/aging effect combinations if they are not covered by the structures monitoring program. This includes (1) reduction in concrete anchor capacity due to degradation of the surrounding concrete, for Groups B1-B5 supports; (2) loss of material due to environmental corrosion, for Groups B2-B5 supports; and (3) reduction/loss of isolation function due to degradation of vibration isolation elements, for Group B4 supports. Further evaluation is necessary only for structure/aging effect combinations not covered by the structures monitoring program.

(1) Reduction in concrete anchor capacity due to surrounding concrete for Groups B1 through B5 supports.

The applicant states, in CNP LRA Section 3.5.2.2.3.1, that its component supports for Groups B2-B5 are included in the structures monitoring program and component supports for Group B1 are managed using the inservice inspection program - IWF. The project team reviewed these programs and its evaluation is documented in Section 7.1.23 and Section 7.1.11 of this report, respectively.

On the basis of its review of the AMR results involving aging effects of reduction in concrete anchor capacity due to surrounding concrete, and its review of the AMPs that manage the aging effects, the project team finds that this aging effect is adequately managed for component supports.

(2) Loss of material due to environmental corrosion, for Groups B2-B5 supports.

The applicant states, in CNP LRA Section 3.5.2.2.3.1, that loss of material due to corrosion of steel support components is an aging effect requiring management at CNP. This aging effect is managed by the structures monitoring program.

(3) Reduction/loss of isolation function due to degradation of vibration isolation elements for Group B4 supports.

The applicant states, in CNP LRA Section 3.5.2.2.3.1, that no vibration isolation elements for Group B4 supports are subject to aging management review.

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D.C. Cook Audit & Review Report The project team finds that the applicant has appropriately evaluated AMR results involving management of aging of component supports, as recommended in the GALL Report. The project team finds that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21(a)(3).

7.2.5.2.3.2 Cumulative Fatigue Damage Due to Cyclic Loading (CNP LRA Section 3.5.2.2.3.2)

Cumulative fatigue damage is a TLAA that is reviewed by the NRR DE staff and addressed in Section 4 of the SER related to the CNP LRA.

7.2.5.2.4 Quality Assurance for Aging Management of Non-safety-related Components (CNP LRA Section 3.5.2.2.4)

CNP LRA Section 3.5.2.2.4 is reviewed by the NRR DIPM staff and addressed in Section 3 of the SER related to the CNP LRA.

7.2.5.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report In CNP LRA Tables 3.5.2-1 through 3.5.2-4, the project team reviewed additional details of the results of the AMRs for material, environment, aging effect requiring management, and AMP combinations that are not consistent with the GALL Report.

7.2.5.3.1 Containment Summary of Aging Management (CNP LRA Table 3.5.2-1)

The project team reviewed Table 3.5.2-1 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the containment structures component groups.

In the CNP LRA, the applicant states that loss of material for stainless steel fuel transfer tube penetration component type exposed to borated water is managed using CNP AMP B.1.15, "Inservice Inspection - ASME Section XI, Subsection IWE," and CNP AMP B.1.8, "Containment Leak Rate Testing." The project team reviewed these program and its evaluation is documented in Sections 7.1.10 and 7.1.3 of this report, respectively. Because this is consistent with the GALL Report recommendation for components with the same material, environment, and aging effect, the project team finds this to be acceptable.

In the CNP LRA, the applicant states that loss of material for galvanized steel ice baskets exposed to borated ice is managed using CNP AMP B.1.35, "Structures Monitoring - Ice Basket Inspection." The project team reviewed this program and its evaluation is documented in Section 7.1.26 of this report. On the basis of the operating experience and root causes identified for corrective work, the project team concludes that this is acceptable.

In the CNP LRA, the applicant states that loss of material for galvanized steel component types (ice condenser lattice frame, and carbon steel ice condenser lower support structure, and ice condenser turning vanes) exposed to borated ice is managed using CNP AMP B.1.32, "Structures Monitoring - Structures Monitoring." The project team evaluation of this program is documented in Section 7.1.23. The applicant manages loss of material of stainless steel ice 219

D.C. Cook Audit & Review Report condenser wall duct panels component type exposed to borated ice using the same program.

On the basis that the structures monitoring program is consistent with GALL AMP XI.S6, "Structures Monitoring Program," and adequately manages loss of material for these components, the project team finds this acceptable.

In the CNP LRA, the applicant states that loss of material for carbon steel reactor vessel supports (water cooled) exposed to treated water is managed using CNP AMP B.1.40.2, "Closed Cooling Water Chemistry Control," and CNP AMP B.1.16, "Inservice Inspection -

ASME Section XI Subsection IWF." The project team reviewed these program and its evaluation is documented in Sections 7.1.32 and 7.1.11 of this report, respectively. Because these programs are consistent with the GALL Report recommendation for other components with the same material, environment, and aging effect, the project team finds this to be acceptable.

The applicant states, in the CNP LRA, that the applicant has identified no aging effects for stainless steel components exposed to air (protected from weather), including removable gate (bulkhead), seal table, and sump screens component types. The applicant has identified no aging effects for galvanized steel sump screens and associated framing exposed to air (protected from weather). Air is not identified in the GALL Report as an environment for these components and materials.

On the basis of current industry research and operating experience, dry air on metal will not result in aging that will be of concern during the period of extended operation. The external environments being referred to are typical of ambient air, e.g., under a shelter, indoor, or air-conditioned enclosure or room. Significant corrosion of carbon and low-alloy steel requires an electrolytic environment, and a simultaneous presence of oxygen and moisture. Without the presence of the aggressive environment, low-alloy steel components will experience insignificant amounts of corrosion, and no aging effects are applicable to this component/commodity group. Therefore, the project team concludes that there are no aging effects requiring management for metal in a dry air environment.

In the CNP LRA, the applicant states that loss of material for cadmium-plated steel threaded fasteners (ice basket) exposed to borated ice is managed using the ice basket inspection program. On the basis of the operating experience and root causes identified for corrective work, the project team concludes that this is acceptable.

In the CNP LRA, the applicant states that reinforced concrete protected from the weather is managed using the structures monitoring program and the inservice inspection - IWL program for the containment base slab foundation component type. The applicant also states that reinforced concrete exposed to weather is managed using the structures monitoring program and the inservice inspection - IWL program for the containment dome and wall, as well as the exhaust dome and duct component types. On the basis that the programs that manage the aging of these components (same materials and environments) are consistent with the GALL Report, the project team finds this to be acceptable.

In the CNP LRA, the applicant states that reinforced concrete protected from the weather is managed using the structures monitoring program for the containment operating deck, crane wall (upper) and ice condenser end walls, fuel transfer canal walls and flood-up overflow structure, lower containment concrete walls and floor slabs, reactor cavity missile blocks, 220

D.C. Cook Audit & Review Report regenerative heat exchanger room wall, and steam generator enclosures. On the basis that the program that manages the aging of these components (same materials and environments) is consistent with the GALL Report, the project team finds this to be acceptable.

In the CNP LRA, the applicant states that loss of material, cracking, and change of material properties of concrete exposed to borated ice for ice condenser support slab and ice condenser wear slab is managed using the structures monitoring program. The project team was unable to confirm the applicability of the precedent cited. By letter dated August 20, 2004 (ML042330355), in RAI 3.5.3-1, the project team asked the applicant to clarify whether the ice condenser support slab and ice condenser wear slab are accessible for direct monitoring. If not, the project team asked the applicant to describe specifically how the associated aging effects will be monitored. This followup item 7.2.5.3-1 will be dispositioned in the SER related to the CNP LRA as RAI 3.5.3-1.

In the CNP LRA, the applicant states that cracking and change in material properties of elastomers protected from weather for removable gate bulkhead seals is managed by CNP AMP B.1.34, "Structures Monitoring - Divider Barrier Seal Inspection." The project team reviewed this program and its evaluation is documented in Section 7.1.25 of this report. The project team finds that this program adequately manages cracking aging effect through visual examination of the seal. However, the project team asked the applicant to identify how changes in material properties are detected. During the audit, the applicant responded that the phrase "change in material properties" was meant to convey a visual inspection which ensures the absence of apparent deterioration (cracks or defects). By letter dated April 23, 2004 (ML041270484), in its clarification to the CNP AMP B.1.34 question, the applicant reiterated this position.

Since cracking is addressed separately and because material properties that may affect the performance of seals (e.g., hardening, embrittlement) are not addressed, the project team does not consider this issue resolved. By letter dated August 20, 2004, in RAI B.1.34-1, the project team asked the applicant to provide a basis for concluding that degradation (e.g.,

hardening, embrittlement) will be apparent before the intended function is challenged.

Otherwise, the project team asked the applicant to provide a technical basis for the conclusion that the elastomers in question are not subject to these effects or that these effects will not interfere with the intended function of the component. This is followup item 7.2.5.3-2 and will be dispositioned in the SER related to the CNP LRA as RAI B.1.34-1.

7.2.5.3.2 Auxiliary Building Summary of Aging Management (CNP LRA Table 3.5.2-2)

The project team reviewed Table 3.5.2-2 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the auxiliary building component groups.

In the CNP LRA, the applicant proposes to manage loss of material of galvanized steel emergency diesel generator air intake missile shield grating exposed to weather using the structures monitoring program. The project team finds that the structures monitoring program is acceptable for managing loss of material since visual inspection will be performed on surfaces for any sign of aging degradation. On the basis of its review, the project team finds that the applicant has identified the appropriate aging effect for galvanized steel components in an exposed to weather environment and is adequately managing this aging effect.

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D.C. Cook Audit & Review Report The applicant states, in the CNP LRA, that it has identified no aging effects for stainless steel structures exposed to air, including the new fuel storage racks. Air is not identified in the GALL Report as an environment for this structure and material.

On the basis of current industry research and operating experience, dry air on metal will not result in aging that will be of concern during the period of extended operation. The external environments being referred to are typical of ambient air, e.g., under a shelter, indoor, or air-conditioned enclosure or room. Wrought austenitic stainless steels and CASS are not susceptible to significant general corrosion that would affect the intended function of components. Therefore, the project team concludes that there are no aging effects requiring management for stainless steel in a protected from weather air environment.

In the CNP LRA, the applicant identifies no aging effect for Transite exposed to weather, but uses the structures monitoring program to manage aging. The GALL Report identifies no aging effect for this material and environment. This is consistent with industry experience. On that basis the project team finds the use of the structures monitoring program to be acceptable.

In the CNP LRA, the applicant states that reinforced concrete is managed using the structures monitoring program evaluated in Section 7.1.2.3 of this report. This applies to reinforced concrete protected from weather and exposed to weather (above and below grade) for the electrical tunnel, exterior walls above grade and below grade, floor slabs, fuel transfer canal, foundation, interior walls, internal flood curbs, main steam line enclosure, roof, spent fuel pit walls and slab, and sump. On the basis that the program that manages the aging of these components (same materials and environments) is consistent with the GALL Report, the project team finds this to be acceptable.

7.2.5.3.3 Turbine Building Summary of Aging Management (CNP LRA Table 3.5.2-3)

The project team reviewed Table 3.5.2-3 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the turbine building component groups.

In the CNP LRA, the applicant states that loss of material for galvanized steel components, including intake corrugated piping and screenhouse forebay bar grille and base, exposed to raw water, is managed using the structures monitoring program. The project team finds that galvanized steel components in raw water outdoor environment are susceptible to loss of material. On the basis of industry operating experience of galvanized steel components exposed to a raw water outdoor environment, the project team finds that loss of material is an applicable aging effect and is adequately managed by the structures monitoring program.

In the CNP LRA, the applicant states that reinforced concrete protected from the weather and exposed to weather (above and below grade) is managed using the structures monitoring program for the 12" concrete wall, essential MCC room walls, the ESW pump room, the auxiliary feedwater pump room (walls, floor, and ceiling), foundation mat (turbine building) screenhouse exterior walls (above grade), and superstructure steel column concrete encasing.

On the basis that the program that manages the aging of these components (same materials and environments) is consistent with the GALL Report, the project team finds this to be acceptable.

7.2.5.3.4 Yard Structures Summary of Aging Management (CNP LRA Table 3.5.2-4) 222

D.C. Cook Audit & Review Report The project team reviewed Table 3.5.2-4 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the yard structures groups.

In the CNP LRA, the applicant states that loss of material for the galvanized steel tower, Unit 2 power delivery structure, exposed to weather, is managed using the structures monitoring program. The project team finds that galvanized steel structures in outdoor environments are susceptible to loss of material. On the basis of industry operating experience of galvanized steel structures exposed to an outdoor environment, the project team finds that loss of material is an applicable aging effect and is adequately managed by the structures monitoring program.

In the CNP LRA, the applicant states that reinforced concrete exposed to weather (above and below grade) is managed using the structures monitoring program for the fire protection pump house walls and foundation, gas bottle storage tank foundation, security diesel generator room, switchyard control house, tank area pipe tunnel (condensate storage, refueling water storage, and emergency diesel generator piping tunnel), refueling water storage tank foundation, condensate storage tank foundation, fire protection water storage tank foundation, primary water storage tank foundation, transformer pedestals (Unit 1 power delivery to switchyard and start-up), and the trench from switchyard to start-up transformers (duct bank). On the basis that the program that manages the aging of these structures (same material and environments) is consistent with the GALL Report, the project team finds this to be acceptable.

7.2.5.3.5 Structural Commodities Summary of Aging Management (CNP LRA Table 3.5.2-5)

The project team reviewed Table 3.5.2-4 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the structural commodities groups.

All other AMRs assigned to the project team in CNP LRA Tables 3.5.2-1 through 3.5.2-5 were evaluated. The project team finds them to be acceptable.

In the CNP LRA, the applicant states that loss of material for galvanized steel components, including base plates, embedded unistrut, cable trays and conduits, exposed to weather, is managed using the structures monitoring program. The project team finds that galvanized steel components in an outdoor environment are susceptible to loss of material. On the basis of industry operating experience of galvanized steel components exposed to an outdoor environment, the project team finds that loss of material is an applicable aging effect and is adequately managed by the structures monitoring program.

In the CNP LRA, the applicant states that loss of material for aluminum roof flashing, exposed to weather, is managed using the structures monitoring program. On the basis of its review, the staff finds that the applicant has identified the appropriate aging effect aluminum roof flashing exposed to weather and it is included in the scope of CNP AMP B.1.32, Structures Monitoring Program.

In the CNP LRA, the applicant states that loss of material for carbon steel equipment hatch and personnel access openings threaded fasteners, protected from weather, is managed using inservice inspection - IWE and containment leakage rate testing programs. On the basis that the programs that manage this aging effect are consistent with the GALL Report for the same material and environment, the project team finds this component type is adequately managed.

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D.C. Cook Audit & Review Report In the CNP LRA, the applicant states that cracking and loss of material for stainless steel spent fuel pool fasteners, exposed to borated water, are managed by CNP AMP B.1.40.3, "Water Chemistry Control - Auxiliary Systems Water Chemistry." The project team reviewed this program and its evaluation is documented in Section 7.1.33 of this report. Based on its review and on the basis of industry operating experience, the project team finds the aging effects to be acceptable and the program adequate to manage them.

In the CNP LRA, the applicant identifies no aging effect for transite exposed to weather, but uses the structures monitoring program to manage aging. On the basis of industry experience with this material, the project team finds it acceptable to use the structures monitoring program.

In the CNP LRA, the applicant states that reinforced concrete protected from weather or exposed to weather is managed using the structures monitoring program for flood curbs, hatches, support pedestals, and trenches (for pipe and cable). On the basis that the program that manages the aging of these SCs (same materials and environments) is consistent with the GALL Report, the project team finds this to be acceptable.

In the CNP LRA, the applicant states that pyrocrete protected from weather is managed by CNP AMP B.1.11, "Fire Protection." The project team review this program and its evaluation is documented Section 7.1.5 of this report. During the audit, the project team noted that separation, cracking, and loss of material are applicable aging effects for pyrocrete. By letter dated August 20, 2004, in RAI 3.5.3-2, the project team asked the applicant to identify how the aging effects of separation, cracking, and loss of material are managed by the fire protection program or justify why these aging effects are not applicable. This is followup item 7.2.5.3-3 and will be dispositioned in the SER related to the CNP LRA as RAI 3.5.3-2.

In the CNP LRA, the applicant states that cracking and change of material properties for elastomers of the building pressure boundary sealant, floor plugs, and penetration seals protected from weather, is managed using the structures monitoring program. The project team finds that the applicant's approach for evaluating the applicable aging effects for elastomers in structures outside the containment to be reasonable and acceptable. The project team concludes that the applicant has properly identified the aging effects for elastomers in these structures.

In the CNP LRA, the applicant states that cracking and change in material properties of divider barrier penetration seals' elastomers, protected from weather, is managed using CNP AMP B.1.34, "Structures Monitoring - Divider Barriers Seals Inspection." The project team reviewed this program and its evaluation is documented in Section 7.1.25 of this report. In addition, the applicant proposes, in the CNP LRA, to manage change in material properties using visual examination. The project team asked the applicant to further justify how a visual examination can detect change in material properties. This is followup item 7.2.5.3-2, which will be dispositioned in the SER related to the CNP LRA as RAI B.1.34-1.

In the CNP LRA, the applicant states that joint elastomer at seismic gaps protected from weather is managed using the structures monitoring program. During the audit, the project team asked the applicant to justify the basis for its conclusion that the elastomer will not harden. The applicant responded that the function of this elastomer is to prevent debris from entering the gap. Degradation by hardening of joint elastomer at seismic gaps would not prevent the seismic gap from performing its intended function. On the basis that the structures 224

D.C. Cook Audit & Review Report monitoring program would detect the absence of elastomer material, the project team finds that the structures monitoring program adequately manages aging of the joint elastomer at seismic gaps.

In the CNP LRA, the applicant states that cracking and change of material properties for roof elastomers exposed to the weather, is managed using the structures monitoring program. The project team finds that the applicant's approach for evaluating the applicable aging effects for elastomers in structures outside the containment to be reasonable and acceptable. The project team concludes that the applicant has properly identified the aging effects for elastomers in these structures.

7.2.6 CNP LRA Section 3.6 - Aging Management of Electrical and Instrumentation and Controls In CNP LRA Section 3.6, the applicant provides the results of its AMRs for electrical and instrumentation and controls (I&C) components.

In CNP LRA Table 3.6.2-1, the applicant provides a summary of the AMRs for component types associated with electrical and I&C components. The summary information for each component type includes: intended function, material, environment, aging effect requiring management; AMPs; the GALL Report Volume 2 item; cross reference to CNP LRA Table 3.6.1 ("Table 1");

and generic and plant-specific notes related to consistency with the GALL Report.

The applicant identifies for each component type in CNP LRA Table 1 those components where further evaluation is recommended, those for which no further evaluation is required, and those that are not applicable to CNP together with the basis for their exclusion.

Additionally, the applicant identifies in CNP LRA Table 3.6.2-1 (Table 2), which AMR results it considers to be consistent with the GALL Report (table column Notes A through E) and which are justifies on a different basis.

The AMRs that are within the scope of the project team audit and review are identified on copies of CNP LRA Table 3.6.2-1 included as an appendix to the CNP audit and review plan.

The project team conducted its audit and review in accordance with SRP-LR Section 3.6.3 and the CNP audit and review plan.

7.2.6.1 Aging Management Evaluations That Are Consistent With the GALL Report, for Which No Further Evaluation Is Required For aging management evaluations that the applicant states are consistent with the GALL Report and for which further evaluation is not recommended, the project team conducted its audit and review to determine if the applicant's reference to the GALL Report in the CNP LRA is acceptable.

The project team reviewed the CNP LRA to confirm that the applicant (1) provides a brief description of the system, components, materials, and environment; (2) states that the applicable aging effects have been reviewed and are evaluated in the GALL Report; and (3) identifies those aging effects for the electrical and I&C components that are subject to an AMR.

225

D.C. Cook Audit & Review Report On the basis of its audit and review, the project team finds that for AMRs not requiring further evaluation, as identified in CNP LRA Table 3.6.1, the applicant's references to the GALL Report are acceptable and no further project team review is required.

7.2.6.2 Aging Management Evaluations That Are Consistent With the GALL Report, for Which Further Evaluation Is Recommended For some line items consistent with the GALL Report in CNP LRA Table 3.6.2-1, the GALL Report recommends further evaluation. When further evaluation is recommended, the project team reviewed these further evaluations provided in CNP LRA Section 3.6.2.2 against the criteria provided in SRP-LR Section 3.6.2.2. No line items for which further evaluation is required are within the scope of the project team.

The only CNP LRA section identified in CNP LRA Table 3.6.1 where further evaluation is recommended is discussed below.

7.2.6.2.1 Electrical Equipment Subject to Environmental Qualification (CNP LRA Section 3.6.2.2.1)

CNP LRA Section 3.6.2.2.1 is reviewed by the NRR DE staff and addressed in Section 4 of the SER related to the CNP LRA.

7.2.6.3 AMR Results that are Not Consistent with the GALL Report or Not Addressed in the GALL Report In CNP LRA Table 3.6.2-1, the project team reviewed additional details of the results of the AMRs for material, environment, aging effect requiring management, and AMP combinations that are not consistent with the GALL Report.

7.2.6.3.1 Electrical Components Summary of Aging Management (CNP LRA Table 3.6.2-1)

The project team reviewed Table 3.6.2-1 of the CNP LRA, which summarizes the results of AMR evaluations in the SRP-LR for the electrical component groups. All items within the project team scope were consistent with the GALL Report.

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D.C. Cook Audit & Review Report Attachment 1 Project Team and Applicant Personnel CNP LRA Audit and Review Project Team G. Cranston, NRC, Team Leader*

K. Cozens, NRC, Backup Team Leader and Materials Engineer O. Chopra, NRC S. Pope, ISL, ISL Lead O. Mazzoni, ISL M. Patterson, ISL S. Traiforos, ISL R. Pond, ISL Project Team Support S. West, Chief, NRC RLEP Section B*

J. Eads, NRC RLEP Project Manager*

Applicant Personnel Contacted R. Grumbir* M. Hager R. Kalinowski* R. Rucker A. Cox H. Heidarisafa R. Hall J. Eaton R. Schlichter* N. Haggerty*

Applicant Personnel Who Attended the Public Exit Meeting on April 15, 2004 J. Eads, NRC N. Haggerty, AEP S. West, NRC R. Kalinowski, AEP G. Cranston, NRC R. Schlichter, AEP L. Kozak. NRC J. Zwolinski, AEP R. Grumbir, AEP H. Torberg, AEP N. Nazar, AEP D. Fadel, AEP

• Attended the Public Exit Meeting on April 15, 2004 NOTE: There were no members of the public at the Public Exit Meeting.

DC Cook Audit and Review Report Final Revision 1 A1 - 1

D.C. Cook Audit & Review Report Attachment 2 Elements of an Aging Management Program for License Renewal 1 Scope of Scope of program should include the specific structures and program components subject to an AMR for license renewal.

2 Preventive Preventive actions should prevent or mitigate aging degradation.

actions 3 Parameters Parameters monitored or inspected should be linked to the monitored or degradation of the particular structure or component intended inspected function(s).

4 Detection of Detection of aging effects should occur before there is a loss of aging effects structure or component intended function(s). This includes aspects such as method or technique (i.e., visual, volumetric, surface inspection), frequency, sample size, data collection and timing of new/one-time inspections to ensure timely detection of aging effects.

5 Monitoring Monitoring and trending should provide predictability of the extent of and trending degradation, and timely corrective or mitigative actions.

6 Acceptance Acceptance criteria, against which the need for corrective action will criteria be evaluated, should ensure that the structure or component intended function(s) are maintained under all CLB design conditions during the period of extended operation.

7 Corrective Corrective actions, including root cause determination and prevention actions of recurrence, should be timely.

(Audited by DIPM)*

8 Confirmation Confirmation process should ensure that preventive actions are process adequate and that appropriate corrective actions have been (Audited by completed and are effective.

DIPM) 9 Administrativ Administrative controls should provide a formal review and approval e controls process.

(Audited by DIPM) 10 Operating Operating experience of the aging management program, including experience past corrective actions resulting in program enhancements or additional programs, should provide objective evidence to support the conclusion that the effects of aging will be managed adequately so that the structure and component intended function(s) will be maintained during the period of extended operation.

• DIPM, NRR Division of Inspection Program Management DC Cook Audit and Review Report Final Revision 1 A2 - 1

D.C. Cook Audit & Review Report Attachment 3 Audit and Review Followup Items Any followup items that could not be closed out at the time this audit and review report was conducted are identified below. A RAI was issued to the applicant for each of the identified followup items. Each RAI and the disposition by the applicant will be included and closed out in the SER related to the CNP LRA.

Followup Item Description Closed to RAI No. (RAI Issue) 7.1.25-1 The project team requested clarification on the RAI B.1.34-1 method used to monitor a change in material properties of the elastomeric pressure seals (divider (Elastomer barrier). By letter dated April 23, 2004 properties)

(ML041270484), the applicant responded that the phrase change in material properties was intended to convey a visual inspection to ensure the absence of apparent deterioration (i.e., cracks or defects in the sealing surfaces) as discussed in the implementing procedures. Changes in other material properties are neither monitored nor inspected. Cracking is addressed separately and material properties that could affect the performance of barrier seals (e.g., hardening, embrittlement) are not addressed.

7.1.25-2 The acceptance criteria are described in part in RAI B.1.34-2 Procedure,12 MHP-4030-046-002, REV 0, CS-1.

These include visual evidence of chemical attack, (Elastomer radiation damage, or changes in physical properties) appearance. While it may be inferred that any such evidence would be considered unacceptable, no guidance is provided as to how these are to be evaluated.

7.2.1.1-1 The pressurizer examinations program specifies RAI B.1.24-2 one-time inspection using VT-3 to manage reduction of fracture toughness. This is not (Pressurizer consistent with the CASS AMP in the GALL Report, examinations) which provides for volumetric examination or, alternatively, a plant- or component-specific flaw tolerance evaluation to demonstrate that the thermally embrittled material has adequate toughness.

DC Cook Audit and Review Report Final Revision 1 A3 - 1

D.C. Cook Audit & Review Report Attachment 3 (Continued)

Audit and Review Followup Items Followup Item Description Closed to RAI No. (RAI Issue) 7.2.1.2-1 The staff requested, in RAI 3.1.2-4, the applicant to RAI 3.1.2-4 update CNP LRA Section 3.1.2.2.6 and Table 3.1.1

-11 to include the Reactor Vessel Internals (CASS) program with managing this aging effect or justify why it should not be credited with managing this aging effect.

7.2.1.3-1 Cracking of low alloy and stainless steel bolting RAI 3.1.3-1 material is to be managed using CNP AMP B.1.14, Inservice Inspection - ASME Section XI, (ISI is not Bolting Subsection IWB, IWC, and IWD. The project Integrity) team evaluation of this program is documented in Section 7.1.9. To manage cracking of the bolting material for valves and blind flanges as well as main flange bolts, the applicant proposes to use the inservice inspection program. Although a precedent was cited, the project team was not able to confirm its applicability. For the component referenced, the GALL Report recommends a program consistent with Bolting Integrity (AMP XI.M18) which invokes the guidelines of NUREG-1339 to prevent and mitigate bolting degradation.

7.2.1.3-2 To manage cracking of the heater support plates, RAI 3.1.3-2 their brackets, and the bracket bolts are to be managed using the water chemistry control (Inspect/Monitor program. Although a precedent was cited, the in Addition to project team was not able to confirm that it is Prevent/Mitigate) applicable. For the component referenced, the GALL Report recommends the use of inservice inspection in addition to the water chemistry control program.

DC Cook Audit and Review Report Final Revision 1 A3 - 2

D.C. Cook Audit & Review Report Attachment 3 (Continued)

Audit and Review Followup Items Followup Item Description Closed to RAI No. (RAI Issue) 7.2.1.3-3 The primary manway closure bolting is made of low RAI 3.1.3-1 alloy steel exposed to ambient air. Cracking is managed by CNP AMP B.1.14, Inservice (ISI is not Bolting Inspection - ASME Section XI, Subsection IWB, Integrity)

IWC, and IWD. To manage cracking of the SG primary manway closure bolting, the applicant proposes to use the inservice inspection program.

Although a precedent was cited, the project team was not able to determine its applicability. For the component referenced, the GALL Report recommends the use of a program consistent with the bolting integrity program (AMP XI.M18).

7.2.1.3-4 To manage cracking of the low-alloy steel lower RAI 3.1.3-4 shell, upper shell, transition cone, steam drum, elliptical upper head; feedwater nozzle and main (Supplement with steam nozzle; secondary blowdown and water chemistry instrumentation connections, recirculation control program) connections (Unit 1), and secondary shell drain connections; secondary handhole and inspection ports in treated water CNP is using AMP B.1.14, Inservice Inspection - ASME Section XI, Subsection IWB, IWC, and IWD. The applicant made reference to a previously approved staff position, however, in the case cited, a water chemistry control program had been credited as well. No water chemistry control program was identified for managing of this aging effect.

7.2.1.3-5 To manage cracking of carbon steel in treated water RAI 3.1.3-4 for the secondary manway and the feedwater elbow thermal liner (Unit 2) CNP is using the inservice (Supplement with inspection program. A previously approved staff water chemistry position was identified by the applicant, however, in control program) the case cited, a water chemistry control program had been credited as well. No water chemistry control program was identified for managing of this aging effect.

DC Cook Audit and Review Report Final Revision 1 A3 - 3

D.C. Cook Audit & Review Report Attachment 3 (Continued)

Audit and Review Followup Items Followup Item Description Closed to RAI No. (RAI Issue) 7.2.1.3-6 To manage cracking of carbon steel bolting of the RAI 3.1.3-1 secondary manway, handhole, recirculation port (Unit 1), and inspection port closure in ambient air is (ISI is not Bolting managed using the inservice inspection program. Integrity)

Although a precedent was cited, the project team was not able to confirm its applicability. For the component referenced, the GALL Report recommends the use of a program consistent with the bolting integrity program (AMP XI.M18).

7.2.2.3-1 To manage cracking of CIS stainless steel RAI B.1.41-2 components in treated, borated water >270EF CNP will use water chemistry control. This is proposed for (Inspect/Monitor piping and valve component types. Justify the in Addition to absence of an inspection or monitoring program to Prevent/Mitigate) confirm the absence of an inspection or monitoring program to confirm the effectiveness of water chemistry control in managing this aging effect.

7.2.2.3-2 To manage cracking of stainless steel components RAI B.1.41-2 in treated, borated water >270EF CNP is using water chemistry control. This is proposed for heat (Inspect/Monitor exchanger tubes, manifold, piping, pump casing, in Addition to strainer housing, thermowell, tubing, and valve Prevent/Mitigate) component types. Justify the absence of an inspection or monitoring program to confirm the absence of an inspection or monitoring program to confirm the effectiveness of water chemistry control in managing this aging effect.

7.2.3.1-1 For loss of material from stainless steel, carbon RAI B.1.41-2 steel, and copper alloy exposed to treated water in the component cooling water system CNP will use (Inspect/Monitor WCC. The GALL Report recommends performance in Addition to monitoring and functional testing of components Prevent/Mitigate) managed with this program. Justify the absence of an inspection or monitoring program to confirm the absence of an inspection or monitoring program to confirm the effectiveness of water chemistry control in managing this aging effect.

DC Cook Audit and Review Report Final Revision 1 A3 - 4

D.C. Cook Audit & Review Report Attachment 3 (Continued)

Audit and Review Followup Items Followup Item Description Closed to RAI No. (RAI Issue) 7.2.3.1-2 To manage loss of material from copper alloy RAI 3.3.2-2 components exposed to raw water in the HVAC (ML0041280528) systems CNP uses the SWS reliability program.

The GALL Report recommends both visual inspection and hardness testing.

7.2.3.2-1 The project team requested clarification on the RAI 3.3.2-3 method(s) used to monitor a change in material (ML042330355) properties of elastomers in the ventilation systems.

Material properties that could affect the (Elastomer performance of elastomers (e.g., hardness, properties) flexibility) are not directly measured. Please provide a basis for concluding that degradation will be identified before the intended function is compromised. Otherwise, provide a technical basis for the conclusion that the elastomers in question are not subject to these effects or that these effects will not interfere with the intended function of the component. Hardening of elastomers in the SFP system 7.2.3.3-1 Cracking for stainless steel exposed to treated RAI B.1.41-2 water in the component cooling water system will be managed with the closed cooling water chemistry (Inspect/Monitor control. This applies to fittings, manifold, piping, in Addition to thermowell, tubing, and valve component types in Prevent/Mitigate) auxiliary systems. Please identify the program or programs that will be used to confirm the effectiveness of water chemistry control for managing this aging effect, or clarify the rationale for relying on water chemistry control alone.

7.2.3.3-2 Hardening of flex hose. The project team asked the RAI 3.3.3-2 applicant to provide a basis for concluding that degradation of the elastomers will be identified (Elastomer before the intended function is compromised, or to properties) provide a technical basis for the conclusion that the elastomers in question are not subject to these aging effects.

DC Cook Audit and Review Report Final Revision 1 A3 - 5

D.C. Cook Audit & Review Report Attachment 3 (Continued)

Audit and Review Followup Items Followup Item Description Closed to RAI No. (RAI Issue) 7.2.3.3-4 In the LRA, the applicant states that loss of material RAI 3.3.2.1.11-3 from a carbon steel valve exposed to air internally (ML041480115) is to be managed using system walkdown.

(Detection prior to It is not clear to the project team how the system failure) walkdown program would offer any way to detect this aging effect prior to failure of the component.

7.2.3.3-5 Cracking and changes in material properties for RAI 3.3.3-2 elastomers in EDG flex hose are managed using preventive maintenance. The project team was (Elastomer unable to identify how changes in material properties) properties would be monitored. The project team asked the applicant to provide a basis for concluding that degradation of the elastomers will be identified before the intended function is compromised, or to provide a technical basis for the conclusion that the elastomers in question are not subject to these aging effects.

7.2.3.3-6 Cracking and changes in material properties for RAI 3.3.3-2 elastomers in the security system (generator) flex hose are managed using preventive maintenance. (Elastomer The project team was unable to identify how properties) changes in material properties would be monitored.

The project team asked the applicant to provide a basis for concluding that degradation of the elastomers will be identified before the intended function is compromised, or to provide a technical basis for the conclusion that the elastomers in question are not subject to these aging effects.

DC Cook Audit and Review Report Final Revision 1 A3 - 6

D.C. Cook Audit & Review Report Attachment 3 (Continued)

Audit and Review Followup Items Followup Item Description Closed to RAI No. (RAI Issue) 7.2.3.3-7 Cracking and changes in material properties for RAI 3.3.3-2 elastomers in the post-accident containment hydrogen monitoring system flex hose are managed (Elastomer using preventive maintenance. The project team properties) was unable to identify how changes in material properties would be monitored. The project team asked the applicant to provide a basis for concluding that degradation of the elastomers will be identified before the intended function is compromised, or to provide a technical basis for the conclusion that the elastomers in question are not subject to these aging effects.

7.2.3.3-8 In the LRA, the applicant states that loss of material RAI 3.3.2.1.11-3 for copper alloy heater coil exposed to steam (ML041480115)

>270°F is managed using the system walkdown program. Although a precedent was cited, the (Detection prior to project team was not able to confirm its applicability failure) in this case. It is not clear to the project team how the system walkdown program would offer any way to detect this aging effect prior to failure of the component.

7.2.4.3-1 Cracking and change in material properties of tank RAI 3.4-9 elastomer exposed to an external environment of air ML041480115 and an internal environment of treated water are managed using the preventive maintenance (Elastomer program. The project team found documentation of properties) only visual inspection, which is an acceptable method for the detection of cracking. It is not clear to the project team how the applicant intends to detect changes in material properties, which are not generally amenable to visual detection.

7.2.5.3-1 Loss of material, cracking, and change of material RAI 3.5.3-1 properties of concrete exposed to borated ice for ice condenser support slab and ice condenser wear (Inaccessible slab is managed using the structures monitoring concrete) program. Please clarify whether these are accessible for direct monitoring and if not, describe specifically how the associated aging effects will be monitored.

DC Cook Audit and Review Report Final Revision 1 A3 - 7

D.C. Cook Audit & Review Report Attachment 3 (Continued)

Audit and Review Followup Items Followup Item Description Closed to RAI No. (RAI Issue) 7.2.5.3-2 How are separation, cracking, and loss of material RAI 3.5.3-2 managed for pyrocrete using the fire protection program? (Acceptance criteria) 7.2.5.3-3 The applicant proposes to manage change in RAI B.1.34-1 material properties using visual examination. The Same as followup project team asked the applicant to further justify item 7.1.25-1 how a visual examination can detect change in material properties. (Elastomer properties)

DC Cook Audit and Review Report Final Revision 1 A3 - 8

D.C. Cook Audit & Review Report Attachment 4 Documents Reviewed by the Project Team The following is a list of applicant documents reviewed by the project team, including documents prepared by others for the applicant. Inclusion of a document on this list does not imply that the project team reviewed the entire document, but, rather that selected sections or portions of the documents were reviewed as part of the overall effort documented in this audit and review report. In addition, inclusion of a document in this list does not imply NRC acceptance of the document.

Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Buried Piping X1.M34 CNP LRP-EAMP-01, Evaluation of Aging Management Inspection Programs, Rev. 2, Section 3.2. Buried Piping Inspection (A.2.1.6 and Program, 10/10/03 B.1.6)

CNP LRA Section A.2.1.6, Buried Piping Inspection Program and CNP LRA Section B.1.6, Buried Piping Inspection Program CNP Commitment No. 8246, Implement Buried Piping Inspection Program, dated 11/19/03 LRA for Robinson Nuclear Plant, Section B.3.8, Buried Piping and Tanks Surveillance Program Indiana Michigan Power letter AEP:NRC:3034 10 CFR 54, dated Oct 31, 2003 (Commitments)

CNP FSAR Chapter 5, Section 5.2.2.6 Corrosion Protection Southwest Research Institute, Report 7307, Oct-Nov 1995 AEP letter dated March 1, 1996, UT Results and Recommendations A4 - 1

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program CASS XI.M12 CNP LRP-EAMP-01, Evaluation of Aging Management Evaluation Programs, Rev. 2, Section 3.3, Cast Austenitic Stainless (A.2.1.7 and Steel Evaluation Program, 10/10/03 B.1.7)

EPRI TR 1000976, Evaluation of Thermal Aging Embrittlement for Cast Austenitic Stainless Steel Components, January, 2001 WCAP-15131, Technical Justification for Eliminating Large Primary Loop Pipe Rupture as the Structural Design Basis for the D.C. Cook Units 1 and 2 Nuclear Power Plants CNP LRA Section A.2.1.7, Cast Austenitic Stainless Steel Evaluation Program, CNP LRA Section B.1.7, Cast Austenitic Stainless Steel Evaluation CNP Commitment Management System Commitment No. 8247, "Implement Cast Austenitic Stainless Steel Evaluation Program," dated 10/31/03 Staff Evaluation of License Renewal Issue No. 98-0030, Thermal Aging Embrittlement of Cast Austenitic Steel Components, May 19, 2000 A4 - 2

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Containment X1.S4 CNP LRP-EAMP-01, Evaluation of Aging Management Leakage Rate Programs, Rev. 2, Section 4.5, Containment Leak Rate Testing Program, 10/10/03 (A.2.1.8 and B.1.8)

CNP LRA Sections A.2.1.8, Containment Leakage Rate Testing Program CNP LRA and B.1.8, Containment Leakage Rate Testing Program 10CFR Part 50, Appendix J, Primary Reactor Leakage Testing for Water-Cooled Power Reactors CNP EHI-5300, Rev. 1, D.C. Cook Nuclear Plant Containment Leakage Rate Testing Program (Appendix J)

A4 - 3

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Diesel Fuel X1.M30 CNP LRP-EAMP-01, Evaluation of Aging Management Monitoring Programs, Rev. 2, Section 4.7. Diesel Fuel Monitoring (A.2.1.10 and Program, 10/10/03 B.1.10)

CNP LRA Sections A.2.1.10, Diesel Fuel Monitoring Program CNP LRA Section B.1.10, Diesel Fuel Monitoring Program CNP Program Comparison Document, Diesel Fuel Monitoring Program LRA for R.E. Ginna Nuclear Power Plant, Section B.2.1.16, Fuel Oil Chemistry Letter from P. T. Kuo, NRC, to R. C. Mecredy, RG&E, License Renewal Safety Evaluation Report for the R. E.

Ginna Nuclear Power Plant, dated October 9, 2003 (SER Section 3.3.2.3.4)

NUREG-1801, Generic Aging Lessons Learned (GALL)

Report,Section XI.M30, Fuel Oil Chemistry, April 2001 ASTM D 2276-00, Standard Test Method for Particulate Contaminant in Aviation Fuel by Line Sampling, American Society for Testing Materials ASTM D 4057-95, Standard Practice for Manual Sampling of Petroleum and Petroleum Products, American Society for Testing Materials CNP 12-EHP-4030-STP-251-001, Rev. 1, AB Emergency Diesel Fuel Oil Storage Tank Leakage Testing CNP 12-THP-6020-CHM-307, Rev 7c, Emergency Diesel Fuel Oil A4 - 4

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Fire XI.M26 CNP LRP-EAMP-01, Evaluation of Aging Management Protection Programs, Rev. 2, Section 4.10.1, Fire Protection (A.2.1.13 and Program, 10/10/03 B.1.11.1)

CNP 12-PPP-4030-066-017, Rev. 0a, Inspection of Fire Barrier Penetration Seals CNP 12-PPP-4030-066-022, Rev. 1a, Inspection of Fire Doors, Frames and Their Hardware Protecting Safety-Related Areas NRC Inspection Report 50-315/03 & 50-316/03-05, dated July 21, 2003 CNP SA-2002-DCC-003, DC Cook Fire Protection Program Self Assessment, August 30, 2002 Fire Water XI.M27 CNP LRP-EAMP-01, Evaluation of Aging Management System Programs, Rev. 2, Section 4.10.2. Fire Water System (A.2.1.14 and Program, 10/10/03 B.1.11.2)

Interim Staff Guidance (ISG)-04, Aging Management of Fire Protection Systems for License Renewal, December 3, 2002 D.C. Cook Nuclear Power Plant, Units 1 and 2, NRC Inspection Report 50-315/03-05 & 50-316/03-05 dated July 21, 2003 CNP SA-2002-DCC-003, D.C. Cook Fire Protection Program Self Assessment, August 30, 2002 A4 - 5

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Flow X1.M17 CNP LRP-EAMP-01, Evaluation of Aging Management Accelerated Programs, Rev. 2, Section 4.11, Flow-Accelerated Corrosion Corrosion Program, 10/10/03 (A.2.1.15 and B.1.12) D. C. Cook Condition Report: 02022070 (1/22/02)

D. C. Cook Condition Report: 02029055 (1/29/02)

EPRI Report NSAC-202L-R2, Recommendations for an Effective Flow-Accelerated Corrosion Program, Final Report, April 1999 CNP 1st, 2nd and 3rd quarter condition reports, Flow Accelerated Corrosion (FAC) Program, 2003 CNP LRA Section A.2.1.15, Flow-Accelerated Corrosion Program CNP LRA Section B.1.12, Flow-Accelerated Corrosion Program CNP PMI-5022, Rev. 2, Flow-Accelerated Corrosion Inspection Program CNP 12-EHP-5022-001-001, Rev. 1, Program for Implementing FAC Inspection Program NUREG-1801 XI.M17 Flow-Accelerated Corrosion NUREG-1801, Generic Aging Lessons Learned (Gall)

Report,Section XI.M17 Flow-Accelerated Corrosion A4 - 6

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Heat Plant-Specific CNP LRP-EAMP-01, Evaluation of Aging Management Exchanger Programs, Rev. 2, Section 4.18, Service Water System Monitoring Reliability Program, 10/10/03 (A.2.1.16 and B.1.13) CNP LRP-NGPR-01, Non-GALL Precedent Review for the LRA, Draft Rev. 0, Attachment B-5, Heat Exchanger Monitoring Program, 12/18/03 CNP LRP-MAMR-02, Containment Spray System, Rev 1, 05/02/03 CNP LRP-MAMR-10, Component Cooling Water System, Rev. 2, 11/21/03 CNP LRP-MAMR-11, Emergency Diesel Generator System, Rev. 1, 11/21/03 A4 - 7

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program ASME X1.M1 CNP LRP-EAMP-01, Evaluation of Aging Management Section XI Programs, Rev. 2, Section 4.12.1, ASME Section XI Inservice Inservice Inspection, Subsections IWB, IWC, and IWD Inspection, Program, 10/10/03 Subsections IWB, IWC CNP LRP-MAMR-01, Donald C. Cook License Renewal and IWD. Project Aging Management Review of the Reactor Coolant (A.2.1.17 and System, Sections 4.1.4.2, 4.2.4.5, 4.3.4.4, 4.4.4.2, and B.1.14) 4.5.4.4 ASME Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection, 1989 Edition Donald C. Cook Nuclear Power Plant, License Renewal Application Dated October 31, 2003 (ML033070179)

CNP LRA Section A.2.1.17, Inservice Inspection - ASME Section XI, Subsection IWB, IWC, IWD CNP LRA Section B.1.14, Inservice Inspection-ASME Section XI, Subsection IWB, IWC, IWD 10 CFR 50.55a, Codes and Standards.

CNP PMI-5070, Inservice Inspection, Revision 16.

CNP ISI Program Basis Document, Third Ten-Year Inservice Inspection Interval, D.C. Cook, Units 1 and 2, Revision 1 A4 - 8

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Inservice XI.S1 CNP LRP-EAMP-01, Evaluation of Aging Management Inspection- Programs, Rev. 2, Section 4.12.2, ASME Section XI ASME Inservice Inspection, Subsection IWE Program, 10/10/03 Section XI, Inservice CNP LRA Sections A.2.1.18, Inservice Inspection-ASME Inspection Section XI Section XI, Subsection IWE Program Program IWE (A.2.1.18 Comparison Document, Inservice Inspection-ASME and B.1.15)

Section XI, Subsection IWE Program CNP LRA Sections B.1.15, Inservice Inspection-ASME Section XI Section XI, Subsection IWE Program Program Comparison Document, Inservice Inspection-ASME Section XI, Subsection IWE Program LRA for McGuire Nuclear Station, Units 1 & 2 and Catawba Nuclear Station, Units 1 & 2, Section B.3.7, Containment Inservice Inspection Plan-IWE NUREG-1772, Safety Evaluation Report Related to the License Renewal of McGuire Nuclear Station, Units 1 and 2, and Catawba Nuclear Station, Units 1 and 2, Section 3.0.3.3, Containment Inservice Inspection Plan-IWE Letter from M.S. Tuckman, Duke Power, to NRC Document Control Desk, Response to Requests for Additional Information in Support of the Staff Review of the Application to Renew the Facility Operating Licenses of McGuire Nuclear Station, Units 1 & 2 and Catawba Nuclear Station, Units 1 & 2, dated March 11, 2002 (RAIs B.3.7-1, B.3.7-2 and B.3.8-1)

NUREG-1801, Generic Aging Lessons Learned (Gall)

Report,Section XI.S1, ASME Section X1, Subsection IWE April 2001 10 CFR 50.55a, Codes and Standards A4 - 9

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Inservice XI.S1 CNP Units 1 and 3 Containment Inservice Inspection Inspection- Program Plan ASME Section XI, Letter from C.M. Craig, NRC to R.P. Powers, I&M, Donald Inservice C. Cook Nuclear Power Plant, Units 1 and 2-Safety Inspection Evaluation for Proposed Alternative in Accordance with 10 IWE (A.2.1.18 CFR 50.55a(a)(3)(ii) for Containment Inspections (TAC No.

and B.1.15)

MB1249 and MB1250), dated July 13, 2001 (Continued)

CNP PMP-5070-ISI002, Rev. 0, Inservice Inspection Program Implementation Inservice XI.S3 CNP LRP-EAMP-01, Evaluation of Aging Management Inspection- Programs, Rev. 2, Section 4.12.3, ASME XI Inservice ASME Inspection, Subsection IWF Program, 10/10/03 Section XI, Inservice CNP LRA Section A.2.1.19, Inservice Inspection-ASME Inspection Section XI, Subsection IWF Program IWF (A.2.1.19 and B.1.16)

CNP LRA Section B.1.16, Inservice Inspection-ASME Section XI, Subsection IWF NUREG-1801, Generic Aging Lessons Learned (GALL)

Report, Section XI-S2, ASME Section XI, Subsection IWF April 2001 10 CFR 50.55a, Codes and Standards CNP PMP-5070-ISI-002, Rev. 0, Inservice Inspection Program Implementation A4 - 10

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Inservice XI.S2 CNP LRP-EAMP-01, Evaluation of Aging Management Inspection- Programs, Rev. 2, Section 4.12.4, ASME Section XI ASME Inservice Inspection, Subsection IWL Program, 10/10/03 Section XI, Inservice CNP LRA Section A.2.1.20, Inservice Inspection-ASME Inspection Section XI Inservice Inspection, Subsection IWL Program IWL (A.2.1.20 and B.1.17)

CNP LRA Section B.1.17, Inservice Inspection-ASME Section XI, Subsection IWL CNP Program Comparison Document, Inservice Inspection-ASME Section XI, Subsection IWL Program LRA for McGuire Nuclear Station, Units 1 & 2 and Catawba Nuclear Station, Units 1 & 2, Section B.3.7, Containment Inservice Inspection Plan-IWE NUREG-1801, Generic Aging Lessons Learned (GALL)

Report, Section CI.S3, ASME Section XI, Subsection IWL April 2001 10 CFR 50.55a Codes and Standards CNP Units 1 and 2 Containment Inservice Inspection Program Plan CNP NED -2001-034-REP, RPE Report IWL Inspection 2001 A4 - 11

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Inservice XI.S2 CNP 12-QHP-5070-NDE-006, Rev. 1, Visual Inspection- Examinations: Concrete Containment ASME Section XI, CNP PMI-5075, Rev. 5-CS1, ASME Section XI Inservice Repair/Replacement Program Inspection IWL (A.2.1.20 and B.1.17) PMP-5070-ISI-002, Rev. 0, Inservice Inspection Program (Contiuned) Implementation ASME Plant-Specific CNP LRP-TLEE-02 , Metal Fatigue Review, Revision 1 Section XI, (page 28 of 49) Section B.1.18, Inservice Inspection -

Augmented ASME Section XI, Augmented Inspection of Donald C.

Inspection Cook Nuclear Plant License Renewal Application (A.2.1.21 and B.1.18) CNP LRP-NGPG -01, Draft Revision 0, Attachment B-6, Inservice Inspection - Augmented Inspection Program NUREG-1800 - Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, July 2001 CNP LRP-EAMP-01, Revision 2, Donald C. Cook License Renewal Project, Evaluation of Aging Management Programs CNP SA-1999-015-ENP, Inservice Inspection Program Assessment Donald C. Cook Nuclear Power Plant, License Renewal Application Dated October 31, 2003 (ML033070179)

CNP LRP-TLEE-02, Revision 1, Donald C. Cook License Renewal Project, Metal Fatigue Review CNP Commitment No. 8251, Implement ISI-Augmented Inspections Program Enhancements A4 - 12

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Instrument Air Plant-Specific CNP Response to NRC Generic Letter 88-14, Instrument Quality Air Supply Problems Affecting Safety-Related Equipment, (A.2.1.22 and To T.E. Murley from M.P. Alexich dated 02/24/89 B.1.19)

CNP PMP-7100-CMP-001, Rev. 03, NRC Commitment Management Program, 09/21/01 CNP PMP-2010-PRC-001, Rev. 2, Procedure Writing, 09/12/03 CNP LRP-EAMP-01, Evaluation of Aging Management Programs, Rev. 2, Section 4.13, Instrument Air Quality Program, 10/10/03 CNP Commitment No. 8252, Implement Instrument Air Quality Program Enhancements NUREG-1743, Safety Evaluation Report Related to the License Renewal of Arkansas Nuclear One, Unit 1, Section 3.3.4.2.2, Aging Management Programs, May 2001 ANSI / ISA S7.3-1975, Quality Standard for Instrument Air NRC Generic Letter 88-14, Instrument Air Supply Problems Affecting Safety-Related Equipment, U.S. Nuclear Regulatory Commission, August 8, 1988.

CNP 01-OHP-4030-114-030, Rev. 1, Daily Shiftly Surveillance Checks.

CNP 02-OHP-4030-214-030, Rev. 0, Daily and Shiftly Surveillance Checks CNP 12-THP-6040-PER-005, Rev. 6-CS2, Control Air Performance Monitoring CNP Recurring Task Job Order 00023370, Planned 03/24/03, J/O Description; 1-QR-12-1, Replace Control Air Filter Elements A4 - 13

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Non-EQ X1.E2 CNP LRP-EAMP-01, Evaluation of Aging Management Insulated Programs, Rev. 2, Section 3.7, Non-EQ Instrumentation Cables and Circuits Test Review Program, 10/10/03 Connections (A.2.1.24 and CNP LRA Section A.2.1.24, Non-EQ Instrumentation B.1.21) Circuits Test Review Program and Section B.1.21, Non-EQ Instrumentation Circuits Test Review Program CNP Commitment No. 8254, Implement Non-EQ Instrumentation Circuits Test Review Program, dated 11/20/03 EPRI TR-109619, Guideline for the Management of Adverse Localized Equipment Environments, Electric Power Research Institute, Palo Alto, CA, June 1999 CNP Verification of License Renewal Report LRP-EAMR-01, Revision 2, Aging Management Review for Electrical Systems Indiana Michigan Power letter AEP:NRC:3034 10 CFR 54, dated Oct 31, 2003 (Commitments)

A4 - 14

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Non-EQ X1.E1 CNP LRP-EAMP-01, Evaluation of Aging Management Insulated Programs, Rev. 2, Section 3.8, Non-EQ Insulated Cables Cables and and Connections Program, 10/10/03 Connections (A.2.1.25 and CNP LRA Section A.2.1.25, Non-EQ Insulated Cables and B.1.22) Connections Program CNP LRA Section B.1.22, Non-EQ Insulated Cables and Connections Program CNP Commitment No. 8255, Implement Non-EQ Insulated Cables and Connections Program, dated 11/20/03 EPRI TR-109619, Guideline for the Management of Adverse Localized Equipment Environments, Electric Power Research Institute, Palo Alto, CA, June 1999 CNP Verification of License Renewal Report LRP-EAMR-01, Revision 2, Aging Management Review for Electrical Systems CNP CR P-99-27605, Water in junction box Indiana Michigan Power letter AEP:NRC:3034 10 CFR 54, dated Oct 31, 2003 (Commitments)

A4 - 15

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Oil Analysis Plant-Specific CNP LRP-EAMP-01 Evaluation of Aging Programs, Rev. 2, (A.2.1.2 and Section 4.14, Oil Analysis Program 09/18/03 B.1.23)

CNP LRP-NGPR-01 Draft Rev. 0, Att. B-8 Oil Analysis Program Comparison Document LRA for Arkansas Nuclear One, Unit 1, Section B.4.14, Oil Analysis NUREG-1743, Safety Evaluation Report Related to the License Renewal Arkansas Nuclear One, Unit 1, Section 3.3.1.4.7, Oil Analysis Program, May 2001 INPO 89-009 (Good Practice MA-316), Plant Predictive Maintenance September 1989.

Letter from G.E. Grant, NRC, to E.E. Fitzpatrick, I&M, System Operational Performance Inspection (SOPI) Report 50-315/96013 (DRS): 50-316/96013 (DRS), Notice of Deviation and Notice of Violation, dated February 4, 1997 CNP 12-EHP-5030-OIL-001, Rev. 1, Oil Analysis Program CNP 12-THP-6020-CHM-302, Rev. 4b-CS1, Oil and EHC Sampling, 10/16/03.

CNP Recuring Task Nbr: 00010280, Obtain 1-AB Diesel Gen Crankcase Oil Sample, Procedure 12-THP-6020-CHM-302, 11/30/03 CNP 1-OME-150-AB, Unit 1 AB Emergency Diesel Engine Oil Sample Results 12/05/03 A4 - 16

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Pressurizer Plant-Specific CNP LRP-EAMP-01 Evaluation of Aging Management Examinations Programs, Rev. 2, Section 4.15, Pressurizer Examinations (A.2.1.27 and Program, 10/10/03 B.1.24)

CNP Commitment No. 8256, Implement Pressurizer Examinations Program Enhancements CNP LRP-NGPR-01 Comparison Document, Pressurizer Examinations Program CNP PMP-5070-ISI-002, Rev. 0, Inservice Inspection Program Implementation 03/22/2000 CNP Inservice Inspection Program Assessment:

Assessment Number: SA-1999-015-ENP, Assessment Dates: 10/14/99 to 10/30/99, Assessment Topic: Inservice Inspection Program Approval date 12/05/1999 CNP PMI-5070, Rev. 00, Inservice Inspection, 01/25/02 CNP Condition Report: P98-06681, Inspection of RCP Flywheel, approval date 09/10/1999 ISI Program Basis Document Third Ten-Year Inservice Inspection Interval D.C. Cook, Units 1 & 2, Revision 1, 10/01/03 A4 - 17

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Preventive Plant-Specific CNP LRP-EAMP-01, Evaluation of Aging Management Maintenance Programs, Rev. 2, Section 4.16, Preventive Maintenance (A.2.1.28 and Program 09/18/03 B.1.25)

CNP Commitment No. 8257, Implement Preventive Maintenance Program Enhancements CNP LRP-NGPR-01, Draft Rev. 0, 12/18/03 Letter from J.A. Grobe, NRC, to R.P. Powers, I&M, NRC Inspection Report 50-315/99034 (DRS) and 50-316/99034 (DRS), dated February 8, 2000 CNP PMI-5030, Rev. 13, Preventive Maintenance, 12/10/01 CNP PMP-5030-001-003, Rev. 10, Preventive Maintenance, 11/30/01 CNP Repetitive Task 19125, 1-OME-150-AB Perform 18 month Diesel Surveillance, 10/29/03 CNP Preventative Maintenance Program Health Report, 3rd Quarter 2003 A4 - 18

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Reactor Vessel X1.M31 CNP-LRP-EAMP-01, Evaluation of Aging Management Integrity Programs, Rev. 2, Section 4.17, "Reactor Vessel Integrity Program Program," 10/10/03 (A.2.1.29 and B.1.26) CNP-LRA Section A.2.1.29, "Reactor Vessel Integrity Program" CNP LRA Section B.1.26, "Reactor Vessel Integrity" CNP- Commitment No. 8258, "Implement Reactor Vessel Integrity Program Enhancements" NUREG-1801,Section XI.M31, Reactor Vessel Integrity Reactor Vessel X1.M13 CNP LRP-EAMP-01, Evaluation of Aging Management Internals Cast Programs, Rev. 2, Section 3.9.2, "Reactor Vessel Internals Austenitic Cast Austenitic Stainless Steel Program," 10/10/03 Stainless Steel Components CNP LRA Section A.2.1.31 Reactor Vessel Internals Cast (A.2.1.31 and Austenitic Stainless Steel Program of Appendix A UFSAR B.1.28) Supplement and Section B.1.28 Reactor Vessel Internals Cast Austenitic Stainless Steel Program Letter from C. I. Grimes, NRC, to D. J. Walters, Nuclear Energy Institute, "License Renewal Issue No. 98-0030, Thermal Aging Embrittlement of Cast Stainless Steel Components," May 19, 2000 CNP Commitment No. 8259, "Implement Reactor Vessel Internals: Cast Austenitic Stainless Steel Program"(10/31/03)

NUREG-1801,Section XI.M13, Reactor Vessel Internals Cast Austenitic Stainless Steel A4 - 19

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Service Water X1.M20 CNP LRP-EAMP-01, Evaluation of Aging Management System Programs, Rev. 2, Section 4.18. Service Water System Reliability Reliability Program 10/10/03 (A.2.1.32 and B.1.29) CNP Commitment No. 8261, Implement Service Water System Reliability Program Enhancements Letter from P.T. Kuo, NRC, to R.C. Mecredy, RG&E, License Renewal Safety Evaluation for the R.E. Ginna Nuclear Power Plant, Section 3.3.2.3.6, Open-Cycle Cooling Water System Program, October 9, 2003 CNP 12-PMP-5030-001-005, Rev. 0, Essential Service Water System Inspection Program CNP EHI-8913, Rev. 1, Program for Implementing Generic Letter 89-13 (Service Water System Reliability)

CNP ENVI-8913, Rev. 3, Zebra Mussel Monitoring and Control Program Letter from M.P. Alexich, I&M, to A.B. Davis, NRC, Generic Letter 89-13 (Service Water System Problems Responses, AEP:NRC:1104, dated January 25, 1990 CNP LRP-MAMR-02, Containment Spray System, Rev 1, 05/02/03 CNP LRP-MAMR-10, Component Cooling Water System, Rev. 2, 11/21/03 CNP LRP-MAMR-11, Emergency Diesel Generator System, Rev. 1, 11/21/03 CNP LRP-MAMR-12, Heating, Ventilation and Air Conditioning Systems, Rev. 2, 11/21/03 A4 - 20

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Small Bore XI.M32 CNP LRP-EAMP-01, Evaluation of Aging Management Piping Programs, Rev. 2, Section 3.10, Small Bore Piping (A.2.1.33 and Program, 10/10/03 B.1.30)

NUREG-1801, Generic Action Lessons Learned (GALL)

Report,Section XI.M32, One Time Inspection, April 2001 CNP LRA Section B.1.30, Small Bore Piping CNP Commitment Number 8262, Implementation of Small Bore Piping Program A4 - 21

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Structures X1.S6 CNP LRP-EAMP-01, Evaluation of Aging Management Monitoring - Programs, Rev. 2, Section 4.20, Structures Monitoring Masonry Walls Program, 10/10/03 (A.2.1.35 and B.1.32)

CNP LRA Section A.2.1.35, Structures Monitoring-Structures Monitoring Program CNP LRA Section B.1.32, Structures Monitoring-Structures Monitoring CNP Commitment No. 8263, implement Structures Monitoring Program Enhancements NUREG-1801, Generic Aging Lessons Learned (GALL)

Report,Section XI.S6, Structures Monitoring Program April 2001 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants CNP 12-EHP-5035-SMP-001, Rev. 2, Plant Structure Performance Evaluation and Monitoring Program NRC Regulatory Guide 1.160, Rev 2, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, U.S.

Nuclear Regulatory Commission, March 1997 A4 - 22

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Structures XI.M23 CNP LRP-EAMP-01, Evaluation of Aging Management Monitoring- Programs, Rev. 2, Section 4.20.2, Crane Inspection Crane Program, 10/10/03 Inspection Program CNP LRA Section A.2.1.36, Structures Monitoring-Crane (A.2.1.36 and Inspection B.1.33)

CNP LRA Section B.1.33, Structures Monitoring-Crane Inspection CNP Commitment No. 8264, Implement Crane Inspection Program Enhancements CNP Program Comparison Document, Structures Monitoring-Crane Inspection Program LRA for VC Summer Nuclear Station (VCSNS), Section B.1.19, Material Handling System Inspection Program Letter from P.T. Kuo, NRC, to S.A. Byrne, SCE&G, License Renewal safety Evaluation Report for the Virgil C.

Summer Nuclear Station, Section 3.3.2.3.2, Material Handling System Inspection Program, dated October 9, 2003 CNP 12-EHP-5035_smp-001, Rev 2, Plant Structure Performance Evaluation and Monitoring Program A4 - 23

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Structures Plant-Specific CNP LRP-EAMP-01, Evaluation of Aging Management Monitoring- Programs, Rev. 2, Section 4.20.3, Structures Monitoring Divider Barrier Programs - Divider Barrier Seal Inspection, 10/10/03 Seal Inspection CNP LRA Section A.2.1.37, Structures Monitoring-Divider (A.2.1.37 and Barrier Seal Inspection Program B.1.34)

CNP LRA Section B.1.34, Structures Monitoring-Divider Barrier Seal Inspection CNP Program Comparison Document, Structures Monitoring-Divider Barrier Seal Inspection Program LRA for McGuire Nuclear Station, Units 1 & 2 and Catawba Nuclear Station, Units 1 & 2, Section B.3.11, Divider Barrier Seal Inspection and Testing Program.

NUREG-1722, Safety Evaluation Report Related to the License Renewal of McGuire Nuclear Station, Units 1 and Unit 2, and Catawba Nuclear Station, Units 1 and 2, Section 3.5.1.2.2, Divider Barrier Seal Inspection and Testing Program CNP 12-EHP-6040-PER-154, Rev. 1, Containment Divider Barrier Survey CNP 12-EHP-4030-STP-249 CNP 12-MHP-5021-010-001 CNP 12-MHP-4030-046-002, Rev. 0-CS1, Upper and Lower Containment Compartments Seal Material Inspection CNP Technical Specification 4.6.5.9 A4 - 24

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Structures Plant-Specific CNP LRP-EAMP-01, Evaluation of Aging Management Monitoring-Ice Programs, Rev. 2, Section 4.20.4, Structures Monitoring Basket Programs - Ice Basket Inspection Program, 10/10/03 Inspection (A.2.1.38 CNP LRA Section A.2.1.38, Structures Monitoring-Ice B.1.35)

Basket Inspection Program CNP LRA Section B.1.35, Structures Monitoring-Ice Basket Inspection Program CNP Program Comparison Document, Structures Monitoring-Ice Basket Inspection Program LRA for McGuire Nuclear Station, Units 1 & 2 and Catawba Nuclear Station, Units 1 & 2, Section B.3.18.1, Ice Basket Inspection NUREG-1772, Safety Evaluation Report Related to the License Renewal of McGuire Nuclear Station Units 1 and 2, and Catawba Nuclear Station, Units 1 and 2, Section 3.5.1.2.2, Ice Condenser Inspections CNP 12-MHP-4030-010-007, Rev.0a, Ice Condenser Ice Basket Surveillance Letter from J.A. Grobe, NRC, to E.E. Fitzpatrick, I&M, NRC Inspection Report No. 50-315-98005 (DRP);50-316-98005 (DRP), dated April 10, 1998 A4 - 25

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Masonry Walls X1.S5 CNP LRP-EAMP-01, Evaluation of Aging Management (A.2.1.39 and Programs, Rev. 2, Section 4.20.5, Masonry Wall Program B.1.36)

CNP LRA Section A.2.1.39, Structures Monitoring-Masonry Wall Program and Section B.1.36, Structures Monitoring-Masonry Wall CNP Commitment No. 8265, Implement Masonry Wall Program Enhancements CNP 12-EHP-5035-SMP-001, Rev. 2, Plant Structure Performance Evaluation and Monitoring Program CNP Condition Report CR-99-26595, Approved 11/03/99 CNP Baseline Structural Inspection Walkdown, Reports NED-2001-007/008-REP System Plant-Specific CNP LRP-EAMP-01, Evaluation of Aging Management Testing Programs, Rev. 2, Section 4.21 System Testing Program (A.2.1.40 and 9/18/03 B.1.37)

CNP LRP-NGPR-01. Non-GALL Precedent Review for the LRA, Draft Rev. 0, Attachment B-13, System Testing Program 12/18/03 CNP LRP-MAMR-11, Emergency Diesel Generator System, Rev. 1, 11/21/03 CNP 1-OME-150-AB, Perform 18-Month Diesel Surveillance 10/29/03 CNP Commitment No. 8266, Implement System Testing Program Enhancements A4 - 26

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program System Plant-Specific CNP LRP-EAMP-01, Evaluation of Aging Management Walkdown Programs, Rev. 2, Section 4.22, System Walkdown (A.2.1.41 and Program, 10/10/03 B.1.38)

CNP LRA Section A.2.1.41, System Walkdown Program and Section B.1.38, System Walkdown Program CNP Commitment No. 8267 Implement System Walkdown Program Indiana Michigan Power letter AEP:NRC:3034 10 CFR 54, dated Oct 31, 2003 (Commitments)

CNP System Engineering Handbook, Revision 11 A4 - 27

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Wall Thinning Plant-Specific CNP LRP-EAMP-01, Evaluation of Aging Management Monitoring Programs, Rev. 2, Section 3.11, Wall Thinning Monitoring (A.2.1.42 and Program, 10/10/03 B.1.39)

NUREG-1743, Safety Evaluation Report related to the License Renewal of Arkansas Nuclear One, Unit 1, Section 3.3.1.4.3 Wall Thinning Inspection Program, May 2001 CNP LRA Section B.1.39, Wall Thinning Monitoring Program DC Cook License Renewal Project Evaluation of Aging Management Programs, LRP-EAMP-01, Revision 2, Section 3.11 NSAC-202L-R2, April 1999, Recommendations for an Effective Flow-Accelerated Corrosion Program.

Letter from AEP (M.W. Rencheck) to NRC, October 31, 2003, Application for Renewed Licenses, Attachment 1 (List of Regulatory Commitments)

CNP LRA Section A.2.1.42, Wall Thinning Monitoring Program CNP LRA Section B.1.39, Wall Thinning Monitoring CNP Commitment No. 8268, Implement Wall Thinning Monitoring Program CNP Program Comparison Document, Wall Thinning Monitoring Program LRA for Arkansas Nuclear One, Unit 1, Section B.3.7, Wall Thinning Inspection A4 - 28

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Primary and XI.M2 CNP LRP-EAMP-01, Evaluation of Aging Management Secondary Programs, Rev. 2, Section 4.23.1, Primary and Secondary Water Water Chemistry Control Program, 10/10/03 Chemistry Program CNP LRA Section A.2.1.43, Water Chemistry Control-(A2.1.43 and Primary and Secondary Water Chemistry Control Program B.1.40.1)

CNP LRA Section B.1.40.1 Water Chemistry Control-Primary and Secondary Water Chemistry Control CNP Commitment No. 8269, Implement Primary and Secondary Water Chemistry Control Program Enhancements EPRI TR-102134, PWR Secondary Water Chemistry Guidelines: Revision 5, Electric Power Research Institute, Palo Alto, CA, May 1993 EPRI TR-105714, PWR Primary Water Chemistry Guidelines: Revision 4, Electrical Power Research Institute, Palo Alto, CA, November 1995 A4 - 29

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Closed Cooling XI.M21 CNP LRP-EAMP-01, Evaluation of Aging Management Water Programs, Rev. 2, Section 4.23.2, Closed Cooling Water Chemistry Chemistry Control Program, 10/10/03 Control (A.2.1.44 and CNP LRA Section A.2.1.44, Water Chemistry Control-B.1.40.2)

Closed Water Chemistry Control Program CNP LRA Section B.1.40.2, Water Chemistry Control-Closed Cooling Water Chemistry Control LRA for St. Lucie Nuclear Plant, Units 1 & 2, Section 3.2.5.2, Chemistry Control Program-Closed Cycle Cooling Water System Chemistry Subprogram NUREG-1779, Safety Evaluation Report Related to the License Renewal St. Lucie Nuclear Plant, Units 1 & 2, Section 3.0.5.6, Chemistry Control Program-Closed Cycle Cooling Water System Chemistry Subprogram, September 2003 Letter from D.E. Jernigan, St. Lucie Plant, to NRC Document Control Desk Response to NRC Request for Additional Information for Review of the St. Lucie Units 1 &

2 License Renewal Application dated September 26, 2002 (RAI B.3.2.5 and RAI 3.3.2-1)

CNP 12-THP-6020-CHM-305, Rev. 9, Component Cooling Water EPRI TR-107396, Closed Cooling Water Chemistry Guidelines, Electric Power Research Institute, Palo Alto, CA, November 1997 A4 - 30

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Auxiliary X1.M2 CNP LRP-EAMP-01, Evaluation of Aging Management Systems Programs, Rev. 2, Section 4.23.3, Auxiliary Systems Water Water Chemistry Control Program, 10/10/03 Chemistry (A.2.1.45 and CNP LRA Section A.2.1.45, Water Chemistry Control-B.1.40.3) Auxiliary Systems Water Chemistry Control Program CNP LRA Section B.1.40.3, Water Chemistry Control-Auxiliary Systems Water Chemistry Control CNP Program Comparison Document, Water Chemistry Control-Auxiliary Systems Water Chemistry Control Program LRA for Arkansas Nuclear One, Unit 1, Section B.4.6.3, Auxiliary Systems Chemistry Monitoring NUREG-1743, Safety Evaluation Report Related to the License Renewal Arkansas Nuclear One, Unit 1, Section 3.3.1.1, Chemistry Control Program, May 2001 Letter from J.D. Vandergrift, Entergy, to NRC Document Control Desk, Arkansas Nuclear One-Unit 1, Docket No.50-313, License No. DPR-51, License Renewal Application RAIs (TAC No. MA8054), ICAN090004, dated September 12, 2000 (Response to RAI 3.3.1.1-1)

A4 - 31

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Environmental X.E1 CNP LRP-EAMP-01, Evaluation of Aging Management Qualification of Programs, Rev. 2, Section 4.8, Environmental Qualification Electrical of Electrical Components Program, 10/10/03 Components (A.2.1.11 and CNP PMI-5025, Environmental Qualification Program, B.2.1) Revision 06, dated 4-13-00 CNP PMP-5025.EQE.001, Procedure for Environmental Qualification of Electrical Equipment, Revision 00, dated 6/29/01 CNP LRA Section A.2.2.3, Environmental Qualification (EQ) of Electric Components Program, page A-29 A4 - 32

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program Fatigue XI.MI CNP LRP-EAMP-01, Evaluation of Aging Management Monitoring Programs, Rev. 2, Section 4.9, Fatigue Monitoring (A.2.1.1B and Program, 10/10/03 B.2.2)

CNP LRA Section A.2.2.2, Fatigue Monitoring Program CNP LRA Section B.2.2, Fatigue Monitoring Program CNP Commitment No. 8271, Implement Fatigue Monitoring Program LRA for McGuire Nuclear Station, Units 1 & 2 and Catawba Nuclear Station, Units 1 & 2, Section 4.2, Metal Fatigue NUREG-1722, Safety Evaluation Report Related to the License Renewal of McGuire Nuclear Station, Units 1 & 2, and Catawba Nuclear Station, Units 1 & 2, Section 4.3, Metal Fatigue CNP 12-EHP-5040-TCM-001, Rev. 0, Transient and Thermal Cycle Monitoring Program NUREG/CR-6260, Application of NUREG/CR-5999 Interim Fatigue Curves to Selected Nuclear Power Plant Components, March 1995 CNP-LRP-TLEE-02 Metal Fatigue Review (7/11/03)

CNP UFSAR, Section 4.1.4 NUREG-1801 XI.M1 Fatigue Monitoring A4 - 33

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program References N/A Letter from Indiana Michigan Power Company to US Reviewed by Nuclear Regulatory Commission, Dated October 31, 2003 Project Team (ML033070179),

Subject:

License Renewal Application for Members for Operating Licenses DPR-58 and DPR-74 for Donald C.

AMR Review Cook Nuclear Plant, Units 1 and 2 CNP LRP-NGPR-01. Non-GALL Precedent Review for the LRA, Draft Rev. 0, 12/18/03 NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, April 2001 NUREG-1801, Generic Aging Lessons Learned (GALL)

Report, Volume 1 and Volume 2, April 2001 NUREG-1743, Safety Evaluation Report Related to License Renewal of Arkansas One, Unit 1 NUREG-1782, Safety Evaluation Report Related to the License Renewal of Ft. Calhoun Station, Unit 1 NUREG-1772, Safety Evaluation Report Related to License Renewal of McGuire Nuclear Station, Units 1 and 2, and Catawba Nuclear Station, Units 1 and 2 NUREG-1779, Safety Evaluation Report Related to the License Renewal of St. Lucie Nuclear Plant, Units 1 and 2 Safety Evaluation Report - Related to the License Renewal of H.B. Robinson Steam Electric Plant, Unit 2 (ML040200981)

Safety Evaluation Report - Related to the License Renewal of the R. E. Ginna Nuclear Power Plant (ML040640687)

Safety Evaluation Report - Related to the License Renewal of the Virgil C. Summer Nuclear Station (ML040300170)

A4 - 34

D.C. Cook Audit & Review Report Attachment 4 (Continued)

Documents Reviewed by the Project Team Applicants GALL Aging CNP LRA - AMP Basis Document and Other Aging Management Documents Reviewed Management Program Program References N/A Letter from US Nuclear Regulatory Commission to Indiana Reviewed by Michigan Power Company, Dated June 30, 2004 Project Team (ML041840218) ,

Subject:

Request for Additional Members for Information for the Review of Donald C. Cook Nuclear AMR Review Plant, Units 1 and 2, License Renewal Application (continued)

Letter from Indiana Michigan Power Company to US Nuclear Regulatory Commission, Dated April 23, 2004 (ML041270484),

Subject:

Supplemental Information for the Donald C. Cook Nuclear Plant License Renewal Application

- Aging Management Program Audit Letter from US Nuclear Regulatory Commission to Indiana Michigan Power Company, Dated August 20, 2004 (ML042330355) ,

Subject:

Request for Additional Information for the Review of Donald C. Cook Nuclear Plant, Units 1 and 2, License Renewal Application Letter from US Nuclear Regulatory Commission to Indiana Michigan Power Company, Dated May 6, 2004 (ML0041280528),

Subject:

Request for Additional Information for the Review of Donald C. Cook Nuclear Plant, Units 1 and 2, License Renewal Application Letter from Indiana Michigan Power Company to US Nuclear Regulatory Commission, Dated June 8, 2004 (ML041680255),

Subject:

License Renewal Application -

Respponse to Requests for Additional Information on Electrical and Auxiliary Systems Letter from US Nuclear Regulatory Commission to Indiana Michigan Power Company, Dated May 26, 2004 (ML0041480115),

Subject:

Request for Additional Information for the Review of Donald C. Cook Nuclear Plant, Units 1 and 2, License Renewal Application A4 - 35

D.C. Cook Audit & Review Report Attachment 5 Commitments to be Included in the Safety Evaluation Report No. Audit and Review Commitment Report Section 1 NA The Alloy 600 Aging Management Program will be implemented prior to the period of extended operation. This program will manage aging effects of Alloy 600/690 components and Alloy 52/152 and 82/1 82 welds in the reactor coolant system that are not addressed by other aging management programs. This program will detect cracking from primary water stress corrosion cracking prior to the loss of component intended function by using the examination and inspection requirements specified in American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI 2 NA The following enhancements to the Boric Acid Corrosion Prevention Program will be implemented prior to the period of extended operation:

! (1) The program scope will be revised to address electrical components in addition to ferrite steel.

! (2) The program acceptance criteria will be revised to address electrical components in addition to ferrite steel.

3 7.1.1 The Buried Piping Inspection Program will be implemented prior to the period of extended operation. The program will include (a) preventive measures to mitigate corrosion and (b) periodic inspections to manage the effects of corrosion on the pressure-retaining capability of buried carbon steel piping and tanks.

Preventive measures will be in accordance with standard industry practice for maintaining external coatings and wrappings. Buried piping and tanks will be inspected when they are excavated during maintenance. The applicant will submit to the staff for review and approval the buried piping inspection program prior to the period of extended operation.

A5 - 1

D.C. Cook Audit & Review Report Attachment 5 (Continued)

Commitments to be Included in the Safety Evaluation Report No. Audit and Review Commitment Report Section 4 7.1.2 The Cast Austenitic Stainless Steel (CASS) Evaluation Program will be implemented prior to the period of extended operation.

The program will include a determination of the susceptibility of the CASS components to thermal aging embrittlement based on casting method, molybdenum content, and percent ferrite. Prior to the period of extended operation, CNP will develop aging management program details (for example, plans for additional volumetric inspections or flaw tolerance evaluations) for the reactor coolant system piping beats of material that are susceptible to reduction of fracture toughness. The program will be submitted to the staff for review and approval prior to the period of extended operation.

5 7.1.5.4 The following enhancements to the Fire Protection Program will be implemented prior to the period of extended operation:

! (1) In the CO2 and halon procedures, ensure that conditions that may affect the performance of the system (such as corrosion, mechanical damage, or damage to dampers) are observed and degraded conditions are addressed via the Corrective Action Program.

(2) Enhance procedures to ensure the diesel fuel supply line is monitored for degradation. during performance testing.

6 7.1.6.4 The following enhancements to the Fire Water System Program will be implemented prior to the period of extended operation:

(1) A sample of sprinkler heads will be inspected using the guidance of National Fire Protection Association 25, Section 2.3.3.1.

! (2) The Fire Water System Program will be enhanced to implement the requirements of the NRC interim staff guidance pertaining to non-intrusive measurement of pipe wall thickness.

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D.C. Cook Audit & Review Report Attachment 5 (Continued)

Commitments to be Included in the Safety Evaluation Report No. Audit and Review Commitment Report Section 7 7.1.8 The Heat Exchanger Monitoring Program will be implemented prior to the period of extended operation. The program will inspect heat exchangers for degradation using non-destructive examinations, such as eddy-current inspections or visual inspections, or if appropriate, the heat exchanger will be replaced. If degradation is found, an evaluation will be performed to determine its effects on the heat exchanger design functions.

The tube plugging limit for each heat exchanger to be eddy-current inspected will be established based upon a component-specific engineering evaluation. This evaluation will determine conservative acceptance criteria that will identify when degraded tubes must be removed from service.

8 7.1.13 The following enhancements to the Inservice Inspection (ISI)

ASME Section XI, Augmented Inspections Program will be implemented prior to the period of extended operation:

(1) An augmented ISI volumetric inspection of the spray additive tanks and the portions of the containment spray system that are wetted by sodium hydroxide.

(2) An augmented ISI volumetric inspection of the portions of the discharge header in containment that may contain water with concentrated contaminants.

The program will be submitted to the staff for review and approval prior to the period of extended operation.

9 7.1.14.1.4 The following enhancement to the Instrument Air Quality Program will be implemented prior to the period of extended operation:

Enhance the CNP Program procedure prior to the period of extended operation to clearly specify frequencies for the dewpoint and dryer tours.

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D.C. Cook Audit & Review Report Attachment 5 (Continued)

Commitments to be Included in the Safety Evaluation Report No. Audit and Review Commitment Report Section 10 NA The Non-EQ Inaccessible Medium-Voltage Cable Program is a new program that will be implemented prior to the period of extended operation. This program applies to inaccessible (e.g.,

in conduit or direct-buried) medium-voltage cables within the scope of license renewal that are exposed to significant moisture simultaneously with applied voltage. This program will test these cables to provide an indication of the condition of the conductor insulation. The specific type of test performed will be determined prior to the initial test.

11 7.1.15 The Non-EQ Instrumentation Circuits Test Review Program will be implemented prior to the period of extended operation. The electrical cables included in the scope of this program meet all of the following criteria:

(1) Not subject to the EQ requirements of 10 CER 50.49; (2) Used in instrumentation circuits with sensitive, high voltage, low-level signals; and (3) Exposed to adverse localized environments caused by heat, radiation, or moisture.

This program will be consistent with the method discussed with the NRC staff during the March 13, 2003, meeting regarding NUREG-l 801,Section XI.E2.

12 7.1.16 The Non-EQ Insulated Cables and Connections Program will be implemented prior to the period of extended operation. The Non-EQ Insulated Cables and Connections Program will apply to accessible insulated cables and connections installed in structures within the scope of license renewal and prone to adverse localized environments.

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D.C. Cook Audit & Review Report Attachment 5 (Continued)

Commitments to be Included in the Safety Evaluation Report No. Audit and Review Commitment Report Section 13 7.1.18.1.1 The following enhancements to the Pressurizer Examinations Program will be implemented prior to the period of extended operation:

! The condition of the internal spray head, spray head locking bar, and coupling will be determined by a one-time visual examination (VT-3) of these components in one CNP unit. This examination will be performed to accepted ASME Section XI methods and standards to ensure that degradation of these items has not occurred.

! If flaws are detected in the spray head, spray head locking bar, or coupling, engineering analysis will be completed to determine corrective actions which could include replacement of the spray head. The need for subsequent inspections will be determined after the results of the initial inspection are evaluated.

14 7.1.19.1.4 The following enhancements to the Preventive Maintenance (PM)

Program will be implemented prior to the period of extended operation:

! Revise PM tasks for the emergency diesel generator (EDG) ventilation system to include inspection of the flex joints; for the control room ventilation air handler packages to include inspection of the heat exchanger tubes and flex joints; and for the auxiliary feedwater pump room cooling units to include inspection of the internal evaporator tubes, valves and tubing.

! The PM program will manage the aging effects for the emergency diesel engine elastomer flex hoses or tubing, reactor coolant pump lube oil leakage collection components, rubber hoses in the compressed air system, rubber hoses in the Post-Accident Containment Hydrogen Monitoring System reagent gas supply, security diesel engine elastomer flex hoses or tubing, and elastomer condensate storage tanks floating head seals.

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D.C. Cook Audit & Review Report Attachment 5 (Continued)

Commitments to be Included in the Safety Evaluation Report No. Audit and Review Commitment Report Section 15 NA The following enhancements to the Reactor Vessel Integrity Program will be implemented prior to the period of extended operation:

(1) I&M will pull and test one additional standby capsule for each unit between 32 effective full-power years (EFPY) and 48 EPPY to cover the peak fluence expected at 60 years. A fluence update will be performed at approximately 32 EFPY when Capsules W (Unit 1) and S (Unit 2) are pulled and tested. A subsequent fluence update will be performed when the standby capsules are pulled and tested between 32 EFPY and 48 EFPY.

(2) Modifications to design and operation that result in changes to the neutron energy spectrum or operating temperatures will be compared to the original environment in which the capsules were irradiated.

16 7.1.20 The Reactor Vessel Internals CASS Program will be implemented prior to the period of extended operation. This program will provide visual inspections and non-destructive examinations of the reactor vessel internals during the period of extended operation. The program will monitor propagation of cracks from existing flaws. In addition to the features of the program described in NUREG-l 801,Section XI.M13, the program will manage the aging effect of distortion due to void swelling of the reactor vessel internals. Applicable components will be determined based on the neutron fluence and thermal embrittlement susceptibility of the component.

I&M will participate in industry-wide programs designed by the PWR Materials Reliability Project Issues Task Group for investigating the impacts of aging on PWR vessel internal components.

The program will be submitted to the staff for review and approval prior to the period of extended operation.

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D.C. Cook Audit & Review Report Attachment 5 (Continued)

Commitments to be Included in the Safety Evaluation Report No. Audit and Review Commitment Report Section 17 NA The Reactor Vessel Internals Plates, Forgings, Welds, and Bolting Program is a new program that will be implemented prior to the period of extended operation. This program will include visual inspections and non-destructive examinations of the reactor vessel internals during the period of extended operation.

A visual inspection will be performed on plates, forgings, and welds to detect and monitor cracking caused by Irradiation Assisted Stress Corrosion Cracking enhanced by reduction of fracture toughness by irradiation embrittlement and distortion due to swelling. For baffle bolts, a volumetric inspection of critical locations will be performed to assess cracking.

I&M will participate in industry-wide programs designed by the PWR Materials Reliability Project Issues Task Group for investigating the impacts of aging on PWR vessel internal components.

18 7.1.22 The Small Bore Piping Program will be implemented prior to the period of extended operation. The small bore piping inspection will involve a one-time volumetric examination of susceptible items in selected locations of Class 1 small bore piping. These inspections will occur at or near the end of the initial operating period for CNP Units 1 and 2.

The program will be submitted to the staff for review and approval prior to the period of extended operation.

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D.C. Cook Audit & Review Report Attachment 5 (Continued)

Commitments to be Included in the Safety Evaluation Report No. Audit and Review Commitment Report Section 19 7.1.23.4 The following enhancements to the Structures Monitoring Program will be implemented prior to the period of extended operation:

Include the following in the Structures Monitoring Program:

equipment supports, instrument panels, racks, cable trays, conduits, cable tray supports, conduit supports, elastomers, pipe hangers/supports, fire protection pump house superstructure and walls, gas bottle storage tank rack and foundation, security diesel generator room, switchyard control house, fire protection water storage tank foundation, primary water storage tank foundation, and the roadway west of the screenhouse.

20 7.1.24 The following enhancements to the Service Water System Reliability Program will be implemented prior to the period of extended operation:

(1) The Service Water System Reliability Program will be enhanced to check for selective leaching during visual inspections.

(2) Develop new PM activity or revise existing PM activity to ensure the 8-inch expansion joints in the essential service water supply lines to the EDG heat exchangers are inspected for evidence of loss of material, change in material properties and cracking.

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D.C. Cook Audit & Review Report Attachment 5 (Continued)

Commitments to be Included in the Safety Evaluation Report No. Audit and Review Commitment Report Section 21 7.1.24.4 The following enhancements to the Structures Monitoring Crane Inspection Program will be implemented prior to the period of extended operation:

Develop procedures or recurring tasks to: evaluate the effectiveness of the maintenance monitoring program and the effects of past and future usage on the structural reliability of in-scope cranes, verify that in-scope crane rails and structural components are visually inspected on a routine basis for loss of material, and verify that significant visual indications of loss of material due to corrosion or wear are evaluated according to applicable industry standards and good industry practice.

22 7.1.25 Changes in material properties are not monitored or inspected 7.2.3.2 directly. Cracking is addressed separately and material 7.2.3.3 properties that could affect the performance of barrier seals (e.g.,

7.2.4.3 hardening, embrittlement) are not addressed. A commitment to 7.2.5.3 manage changes in material properties or an acceptable basis for taking exception to it is required.

23 7.1.27.4 The following enhancement to the Structures Monitoring Masonry Wall Program will be implemented prior to the period of extended operation:

Include the following in the Masonry Wall Program: 4-hour fire-rated masonry block in the turbine building and screenhouse; and masonry block in the auxiliary building.

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D.C. Cook Audit & Review Report Attachment 5 (Continued)

Commitments to be Included in the Safety Evaluation Report No. Audit and Review Commitment Report Section 24 7.1.28.1.4 The following enhancements to the System Testing Program will be implemented prior to the period of extended operation:

(1) Develop a PM procedure to inspect the centrifugal charging pumps minimum flow orifices and the Unit 1 centrifugal charging pumps discharge orifices.

(2) Ensure procedures for engineered safety features ventilation unit, the fuel handling area exhaust unit, and control room ventilation unit surveillance testing include visual verification that the drain valves and drain piping have not experienced loss of material to the extent that their pressure boundary function is compromised.

25 7.1.29 The following enhancements to the system walkdown program will be implemented prior to the period of extended operation:

(1) Enhance the System Walkdown Program to ensure that balance of plant systems are adequately addressed with regard to license renewal considerations.

(2) Enhance the System Walkdown Program to ensure that evidence of corrosion is monitored adequately.

(3) Enhance the System Walkdown Program acceptance criteria to ensure adequate detection of aging effects.

(4) Develop and implement enhanced administrative controls for the System Walkdown Program.

26 7.1.30 The Wall Thinning Monitoring Program is a new program that will be implemented prior to the period of extended operation. The Wall Thinning Monitoring Program inspections will be performed to ensure piping wall thickness is above the minimum required in order to avoid failures under normal conditions and postulated transient and accident conditions, including seismic events.

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D.C. Cook Audit & Review Report Attachment 5 (Continued)

Commitments to be Included in the Safety Evaluation Report No. Audit and Review Commitment Report Section 27 7.1.31.4 The following enhancements to the Primary and Secondary Water Chemistry Control Program will be implemented prior to the period of extended operation:

(1) Revise the program controlling procedures to require individual implementing procedures to identify and prescribe any special collection and preservation needs of a sample.

(2) Bring the parameters monitored/inspected and acceptance criteria into clear alignment with the Electric Power Research Institution (EPRI) water chemistry guidelines.

(3) Include sulfate monitoring criteria for the refueling water storage tank (RWST) that are consistent with the EPRI guidelines, and the sulfate criteria for other systems impacted by RWST chemistry.

28 NA The Chemistry One-Time Inspection Program will be implemented and completed prior to the period of extended operation. Combinations of nondestructive examinations (including visual, ultrasonic, and surface techniques) will be performed by qualified personnel following procedures that are consistent with the Section XI of the ASME B&PV Code and 10 CFR 50, Appendix B. Follow-up of unacceptable inspection findings may include expansion of the inspection sample size and locations.

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D.C. Cook Audit & Review Report Attachment 5 (Continued)

Commitments to be Included in the Safety Evaluation Report No. Audit and Review Commitment Report Section 29 NA The applicant will perform one or more of the following prior to the period of extended operation for the pressurizer surge line:

(1) Further refine the fatigue analysis to lower the pressurizer surge line cumulative usage factors to below 1.0; (2) Repair the affected locations; (3) Replace the affected locations; (4) Manage the effects of fatigue of the pressurizer surge line by an NRC-approved inspection program; and/or (5) Review changes to ASME B&PV Code actions relating to environmental fatigue. Any refined analysis will use the methodology approved by the ASME Committee and NRC.

30 NA Interim staff guidance (ISG) document ISG-5 addresses fuse holders that are not part of a larger assembly, but support safety-related and nonsafety-related functions in which a failure of a fuse precludes a safety function from being accomplished.

Fuse holders that meet these requirements will be evaluated before the beginning of the period of extended operation for possible aging effects. The fuses will either be replaced, modified to remove the aging effects, or a program will be implemented to manage the aging effects. The aging management program (if needed) for fuse holders will consider the aging stressors for the metallic clips.

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