ML051570082

Audit and Review Plan for Plant Aging Management Programs and Reviews

ML051570082
Person / Time
Site:	Palisades
Issue date:	06/03/2005
From:	Cozens K NRC/NRR/DRIP/RLEP
To:
Cozens K, RLEP/DRIP/NRR, 415-4104
References
Contract # DR-03-05-026
Download: ML051570082 (242)

Text

Audit and Review Plan for Plant Aging Management Programs and Reviews Palisades Nuclear Plant Docket No.: 50-255 June 3, 2005 Revision 0 Prepared by Information Systems Laboratories, Inc.

11140 Rockville Pike Rockville, MD 20852 Contract No. DR-03-05-026 Prepared for License Renewal and Environmental Impacts Program Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Palisades Nuclear Plant Audit and Review Plan Table of Contents

1. Introduction..1

2. Background.2

3. Objectives3

4. Summary of Information Provided in the License Renewal Application4

5. Overview of Audit, Review, and Documentation Procedure6

6. Planning, Audit, Review and Documentation Procedure...10 Appendix A - Project Team Membership..A-1 Appendix B - ScheduleB-1 Appendix C - Aging Management Program Assignments.C-1 Appendix D - Aging Management Review Assignments...D-1 Appendix E - Consistent with GALL Report AMP Audit/Review Worksheets... E-1 Appendix F - Plant-Specific AMP Audit/Review Worksheets... F-1 Appendix G - Aging Management Review Worksheets....G-1 Appendix H - Abbreviations, Acronyms, and InitialismsH-1 Tables Table 1 Aging Management Program Element Description 30 Table 2 Notes for License Renewal Application Tables 3.x.2-y.. 31 Figures Figure 1 Audit of AMPs That Are Consistent With the GALL Report.. 32 Figure 2 Audit of Plant-Specific AMPs..... 33 Figure 3 Review of AMRs That Are Consistent With the GALL Report.. 34 Figure 4 Review of AMRs Using NRC-Approved Precedents.. 35 i

Palisades Nuclear Plant Audit and Review Plan

1. Introduction By letter dated March 22, 2005 (ADAMS Accession Number ML050940434), Nuclear Management Company (NMC, the applicant) submitted to the U.S. Nuclear Regulatory Commission (NRC) its application for renewal of Operating License DPR-20 for Palisades Nuclear Plant (PNP) (ML050940446). The applicant requested renewal of the operating license for an additional 20 years beyond the 40-year current license term.

In support of the staff's safety review of the license renewal application (LRA) for the Palisades Nuclear Plant (PNP), the License Renewal and Environmental Impacts Program, Section B (RLEP-B), will lead a project team that will audit and review selected aging management reviews (AMRs) and associated aging management programs (AMPs) developed by the applicant to support its LRA for PNP. The project team will include both NRC staff and engineers provided by Information Systems Laboratories, Inc. (ISL), RLEP-Bs technical assistance contractor. Appendix A, Project Team Membership, lists the project team members. This document is the RLEP-B plan for auditing and reviewing plant aging management reviews and aging management programs for PNP.

The project team will audit and review its assigned AMPs and AMRs against the requirements of Title 10 of the Code of Federal Regulations, Part 54 (10 CFR Part 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 Application 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 this plan. For the scope of work defined in this audit plan, the project team will verify 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 PNP current licensing basis (CLB) for the period of extended operation.

The team will perform its work at NRC Headquarters, Rockville, Maryland; at ISLs offices in Rockville, Maryland; and at the PNP site in Covert, Michigan. The project team will perform its work in accordance with the schedule shown in Appendix B, Schedule. The team will conduct a public exit meeting at or near the applicants offices in Covert, Michigan, after it completes its on-site work.

This plan includes the following information:

• Introduction and Background. Summary of the license renewal requirements, as stated in the Code of Federal Regulations, and a summary of the documents that the project team will use to conduct the audit and review process described in this plan.

• Objectives. The objectives of the audit and review addressed by this plan.

• Summary of Information Provided in License Renewal Application. Description of the information contained in the license renewal application for PNP that is applicable to this plan.

• Overview of the Audit, Review and Documentation Procedure. Summary of the process the project team will follow to audit and review the LRA information that is within its scope of review.

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Palisades Nuclear Plant Audit and Review Plan

• Planning, Audit, Review and Documentation Procedure. The procedure that the project team will use to plan and schedule its work, to audit and review the LRA information that is within its scope of review, and to document the results of its work.

• Appendices. Supporting information. The project team membership is shown in Appendix A and the schedule is shown in Appendix B. The teams work assignments are shown in Appendix C, Aging Management Program Assignments, and Appendix D, Aging Management Review Assignments. Appendices E, F, and G contain the worksheets that the individual team members use to informally document the results of their review and audit work. The application of these worksheets is discussed in Section 6 of this plan. Appendix H is a list of the acronyms, abbreviations, and initialisms used in this plan.

2. Background

In 10 CFR 54.4, the scope of license renewal is defined as those structures, systems, and components (SSCs) (1) that are safety-related, (2) whose failure could affect safety-related functions, and (3) that are relied on to demonstrate compliance with the NRCs regulations for fire protection, environmental qualification, pressurized thermal shock, anticipated transients without scram, and station blackout. An applicant for a renewed license must review all SSCs within the scope of license renewal to identify those structures and components (SCs) subject to an AMR. SCs subject to an AMR are those that perform an intended function without moving parts or without a change in configuration or properties (passive), and that are not subject to replacement based on qualified life or specified time period (long-lived). 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 final safety analysis report (FSAR) that contains a summary description of the programs and activities that it credited to manage the effects of aging during the extended period of operation.

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 management of a large number of SCs that are subject to an AMR. It also summarizes the aging management evaluations, programs, and activities acceptable to the NRC staff for managing aging of most of the SCs used in 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 extended period of operation. If an applicant commits to implementing these staff-approved AMPs, the time, effort, and resources needed to review an applicants LRA will be greatly reduced, thereby improving the efficiency and effectiveness of the license renewal review process. The GALL Report identifies (1) systems, structures, and components, (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 to manage 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 2

Palisades Nuclear Plant Audit and Review Plan applicants facility, the staff will accept the applicants 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 re-review of the substance of the matters described in the GALL Report. Rather, the staff confirms that the applicant verified that the approvals set forth in the GALL Report apply to its programs.

If an applicant takes credit for a GALL AMP, it is incumbent on the applicant to ensure that the plant AMP contains all the program elements of the referenced GALL AMP.1 In addition, the conditions at the plant must be bounded by the conditions for which the GALL AMP was evaluated. The applicant must certify in its LRA that it completed the verifications and that they are documented on-site in an auditable form.

3. Objectives The overall objective of the audit and review described in this plan is to verify compliance with 10 CFR 54.21(a)(3). Therefore, the audit and review process helps ensure that for each structure and component within the scope of the project teams review, the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation.

The audit and review procedure for PNP is described in Sections 5 and 6 of this plan. It is intended to accomplish the following objectives:

• For plant AMPs that the applicant claims are consistent with GALL AMPs, verifying that the plant AMPs contain the program elements of the referenced GALL AMP (for the seven program elements that are within the scope of review of the project team) and that the conditions at the plant are bounded by the conditions for which the GALL AMPs were evaluated.

• For plant AMPs that the applicant claims are consistent with GALL AMPs with exceptions, verifying that the plant AMPs contain the program elements of the referenced GALL AMPs and that the conditions at the plant are bounded by the conditions for which the GALL AMPs were evaluated. In addition, verifying that the applicant has documented an acceptable technical basis for each exception.

• For plant AMPs that the applicant claims will be consistent with GALL AMPs after specified enhancements are implemented, verifying that the plant AMPs, with the enhancements, will be consistent with the referenced GALL AMPs, or are acceptable on the basis of a technical review. In addition, verifying that the applicant identified the enhancements as commitments in the Final Safety Analysis Report (FSAR) or other docketed correspondence.

1 Table 1 of this plan shows the 10 program elements that are used to evaluate the adequacy of each aging management program. These program elements are presented in Branch Technical Position (BTP)

RLSB-1, Aging Management Review - Generic, in Appendix A of the SRP-LR, and are summarized in the GALL Report. The project teams scope of review includes 7 of the 10 elements: 1 through 6, and

10. The Division of Inspection Program Management (DIPM), Office of Nuclear Reactor Regulation (NRR) will review program elements 7, corrective actions; 8, confirmation process; and 9, administrative controls. Therefore, the project team will not review these three elements. The DIPM review will be documented in Section 3 of the license renewal safety evaluation report for the plant.

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Palisades Nuclear Plant Audit and Review Plan

• For plant-specific AMPs that the applicant claims are consistent with AMPs that the staff has previously approved for another plant, verifying the AMPs are acceptable on the basis of a technical review.

• For AMRs that the applicant claims are consistent with the GALL Report, verifying that the plant AMRs are consistent with the criteria of the GALL Report or can be accepted on the basis of an NRC-approved precedent.

• For AMR line items for which the GALL Report recommends further evaluation, verifying that the applicant has addressed the further evaluation, and evaluating the AMRs in accordance with the SRP-LR.

4. Summary of Information Provided in the License Renewal Application The PNP LRA closely follows the standard LRA format presented in 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 LRA provides the results of the aging management review for structures and components that the applicant identified as being subject to an aging management review.

LRA Table 3.0-1 provides a description of the service environments used in the AMRs to determine the aging effects requiring management. Results of the AMRs are presented in two different types of tables. The applicant refers to the two types of tables as Table 1 and Table 2.

The first table type is a series of six tables labeled Table 3.X.1, where X is the system/component group number (see table below), and 1 indicates it is a Table 1 type. For example, in the reactor coolant system subsection of the LRA Section 3, this is Table 3.1.1, and in the engineered safety features subsection of LRA Section 3, this is Table 3.2.1.

X Definition 1 Reactor Coolant System 2 Engineered Safety Features 3 Auxiliary Systems 4 Steam and Power Conversion System 5 Containments, Structures, and Component Supports 6 Electrical and Instrumentation and Controls The second table type is a series of tables labeled Table 3.X.2-Y, where X is the system/component group number, 2 indicates it is a Table 2 type, and Y indicates the subgroup number within group X. For example, within the reactor coolant system (group 1),

the AMR results for the primary coolant system (subgroup 1) are presented in LRA Table 3.1.2-1, and the results for the reactor vessel (subgroup 2) are presented in LRA Table 3.1.2-2.

Under the engineered safety features (group 2), the engineering safeguards system (subgroup

1) results are presented in Table 3.2.2-1 of the LRA.

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Palisades Nuclear Plant Audit and Review Plan The applicant compared the PNP 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.

LRA Tables 3.1.1 through 3.6.1 (Table 1 types) provide a summary comparison of how the PNP AMR results align with Tables 1 through 6 of the GALL Report, Volume 1. These LRA tables are essentially the same as Tables 1 through 6 of the GALL Report, Volume 1, except that the Type column has been replaced by an Item Number column, the GALL Volume 2 Item Number column has been deleted, and a Discussion column has been added. The Item Number column provides a means to cross-reference between an LRA Table 3.X.2-Y (Table 2 type) and an LRA Table 3.X.1 (Table 1 type). The Discussion column includes further information. The following are examples of information that might be contained within the Discussion column:

• Any Further Evaluation Recommended information or reference to the location of that information.

• The name of a plant-specific program being used.

• Exceptions to the GALL Report assumptions.

• A discussion of how the line item is consistent with the corresponding line item in the GALL Report, when it may not be intuitively obvious.

• A discussion of how the line item differs from the corresponding line item in the GALL Report, when it may appear to be consistent.

LRA Table 2 types provide the detailed results of the AMRs for those SCs that are subject to an aging management review. There is a Table 2 for each subgroup within the six system/component groups. For example, the engineered safety features group contains a table specific to the engineering safeguards system. Table 2 of the LRA 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 2.1-1 in Section 2 of the LRA.

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

• 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 LRA Table 3.0-1.

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Palisades Nuclear Plant Audit and Review Plan

• 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.

• NUREG-1801 Volume 2 Line Item. Each combination of the following factors listed in LRA Table 2 is compared to the GALL Report to identify consistencies: component type, material, environment, aging effect requiring management, and aging management program. Column 7 documents identified consistencies by noting the appropriate GALL Report item number. If there is no corresponding item number in the GALL Report for a particular combination of factors, Column 7 is left blank.

• LRA Table 1 Item. 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 aging management program.

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).2 These standard notes are shown in Table 2 of this plan. Notes that use numeric designators are specific to PNP.

LRA Table 2 contains the aging management review results and indicates whether the results correspond to line items in Volume 2 of the GALL Report. Correlations between the combination in 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 plant-specific programs. In these cases, the applicant considers the PNP evaluation to be consistent with the GALL Report if the other elements are consistent. Any appropriate AMP is considered to be a match to the GALL program for line items referring to a plant-specific program.

5. Overview of Audit, Review, and Documentation Procedure The project team will follow the procedure specified in Section 6 of this plan to perform its audits and reviews and to document the results of its work. The process covered by the procedure is summarized below.

2 The staff concurred with the standardized format for license renewal applications by letter dated April 7, 2003, from P.T. Kuo, NRC, to A. Nelson, NEI (ML030990052).

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Palisades Nuclear Plant Audit and Review Plan 5.1 Aging Management Programs Table 1 of this plan summarizes the program elements that comprise an aging management program. Of these 10 elements, elements 1 through 6, and element 10 are within the project teams scope of review.3 For the PNP AMPs for which the applicant claimed consistency with the AMPs included in the GALL Report, the project team will review the PNP AMP descriptions and compare program elements 1 through 6, and program element 10 for the PNP AMPs to the corresponding program elements for the GALL AMPs. The project team will verify that the PNP AMPs contain the program elements of the referenced GALL program and that the conditions at the plant are bounded by the conditions for which the GALL program was evaluated.

For each PNP AMP that has an exception or an enhancement, the project team will determine whether it is acceptable, and whether the AMP, as modified by the applicant, will adequately manage the aging effects for which it is credited. If the project team identifies differences between a GALL AMP credited by the applicant and the PNP AMP, which the applicant did not address in the LRA, the project team will review the difference to determine whether the PNP AMP, as modified by the difference, will adequately manage the aging effects for which it is credited.

5.2 Aging Management Reviews The AMRs in the GALL Report fall into two broad categories: (1) those that the GALL Report concludes are adequate to manage aging of the components referenced in the GALL Report, and (2) 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 will determine (1) whether the AMRs reported by the applicant to be consistent with the GALL Report are indeed consistent with the GALL Report, and (2) whether the plant-specific AMRs reported by the applicant to be based on a previously-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 will review the applicants evaluation to determine if it adequately addressed the issues for which the GALL Report recommended further evaluation.

5.3 NRC-Approved Precedents To help facilitate the staff review of its LRA, the applicant referenced NRC-approved precedents to demonstrate that certain non-GALL AMPs correspond to programs that the staff had approved for other plants during its review of previous applications for license renewal. Using the precedent information, the project team will (1) determine whether the material presented in the precedent is applicable to the applicants facility; (2) determine whether the applicants AMP is bounded by the conditions for which the precedent was evaluated and approved; and (3) verify that the applicants AMP contains the program elements of the referenced precedent. In general, if the project team determines that these conditions are satisfied, it will use the precedent to frame and focus its review of the applicants AMP.

3 As noted in Section 2 of this plan, DIPM will review program elements 7, 8, and 9. The results of these reviews will be documented in Section 3 of the plant safety evaluation report.

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Palisades Nuclear Plant Audit and Review Plan It is important to note that precedent information is not a part of the license renewal application; 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 AMP.

Rather, the precedent facilitates the review of the substance of the matters described in the applicants AMP. As such, in the project teams documentation of its reviews of AMPs 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 AMP for which it is credited, then the project team reviews the AMP as a plant-specific AMP, without consideration of the precedent information.

5.4 FSAR Supplement Review Consistent with the SRP-LR, for the AMRs and associated AMPs that it will review, the project team will review the FSAR supplement that summarizes the applicants programs and activities for managing the effects of aging for the extended period of operation. The project team will also review any commitments associated with its programs and activities made by the applicant and verify that they are acceptable for the stated purpose.

5.5 Documents Reviewed by the Project Team In performing its work, the project team will rely heavily on the LRA, the audit and review plan, the SRP-LR, and the GALL Report. The project team will also examine the applicants precedent review documents, its AMP and AMR basis documents (catalogs of the documentation used by the applicant to develop or justify its AMPs and AMRs), and other applicant documents, including selected implementing procedures, to verify that the applicants activities and programs will adequately manage the effects of aging on structures and components.

5.6 Public Exit Meeting After it completes its audits and reviews, the project team will hold a public exit meeting to discuss the scope and results of its audits and reviews.

5.7 Documentation Prepared by the Project Team The project team will prepare an audit and review plan, worksheets, work packages, requests for additional information (RAIs), an audit and review report, and safety evaluation report (SER) input. The project team will also prepare questions during site visits and will track the applicants responses to the questions.

5.7.1 Audit and Review Plan The project team leader will prepare a plant-specific audit and review plan as described herein.

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Palisades Nuclear Plant Audit and Review Plan 5.7.2 Worksheets Each project team member will informally document the results of his or her work on a variety of worksheets. The worksheets are shown in Appendix E, Consistent with GALL Report AMP Audit/Review Worksheet and Appendix G, Aging Management Review Worksheets. The use of the worksheets is described in Section 6 of this plan.4 5.7.3 Questions As specified in Section 6 of this plan, the project team members will ask the applicant questions during on-site audits, as appropriate, to facilitate its audit and review activities. The team will also track the applicants answers to the questions.

5.7.4 Work Packages After each site visit, the project team leader will assemble work packages for any work that the team will refer to the NRR Division of Engineering (DE) for review. Each work package will include a work request and any applicable background information on the review item that was gathered by the project team.

5.7.5 Requests for Additional Information The review process described in this plan is structured to resolve as many questions as possible during the site visits. As examples, the site visits are used to obtain clarifications about the LRA and explanations as to where certain information may be found in the LRA or its associated documents. Nevertheless, there may be occasions where an RAI is appropriate to obtain information to support an SER finding. The need for RAIs will be determined by the project team leader during the site visits through discussions with the individual project team members. When the project team leader determines that an RAI is needed, the project team member who is responsible for the area of review will prepare the RAI. RAIs will include the technical and regulatory basis for requesting the information.

After the NRC receives a response to an RAI from the applicant, the team leader will provide the response to the team member who prepared the RAI. The team member will review the response and determine if it resolves the issue that was the reason for the RAI. The team member will document the disposition of the RAI in the audit and review report (unless the report was issued before the RAI response was received) and in the SER input. If the audit report was issued before the applicant submitted its response to an RAI, the review of the response will be documented in the SER.

5.7.6 Audit and Review Report The project team will document the results of its work in an audit and review report. The team will prepare its report as described in Section 6.4.1 of this plan.

4 Appendix F is reserved for plant-specific AMP audit/review worksheets. There are no plant-specific AMPs assigned to the project team for review.

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Palisades Nuclear Plant Audit and Review Plan 5.7.7 Safety Evaluation Report Input The project team leader will prepare SER input, based on the audit and review report, as described in Section 6.4.2 of this plan.

6. Planning, Audit, Review, and Documentation Procedure This section of the audit and review plan contains the detailed procedures that the project team will follow to plan, perform, and document its work.

6.1 Planning Activities 6.1.1 Schedule for Key Milestones and Activities The project team leader will establish the schedule for the key milestones and activities, consistent with the overall schedule for making the licensing decision. Key milestones and activities include, as a minimum:

A. receiving the LRA from the applicant B. receiving work split tables from the project manager C. making individual work assignments D. training project team members E. holding the project team kickoff meeting F. preparing the audit and review plan G. scheduling site visits H. scheduling in-office review periods I. preparing questions J. preparing RAIs K. preparing draft and final audit and review report L. preparing draft and final SER input Site visits will be scheduled on the basis of discussions between the project team leader, the NRC license renewal project manager, and the applicant.

Appendix B of this plan contains the target schedule for the key milestones and activities.

6.1.2 Work Assignments The technical assistance contractor will propose team member work assignments to the NRC project team leader. The NRC project team leader will approve all work assignments. After the audit plan is issued, the team leader may reassign work as necessary.

The contractor will develop assignment tables that show which project team member will review each AMP and AMR. Appendix A of this plan shows the project team membership. Appendix C shows the team member assignments for the AMPs. Appendix D of this plan shows the team member assignments for the AMRs.

6.1.3 Training and Preparation The training and preparation will include the following:

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Palisades Nuclear Plant Audit and Review Plan

1. A description of the audit and review process.

2. An overview of audit/review-related documentation and the documentation that the project team will audit and review.

A. GALL Report B. SRP-LR C. Interim Staff Guidance (ISG)

D. LRA AMPs E. LRA AMRs F. basis documents (catalogues of information assembled by the applicant to demonstrate the bases for its programs and activities)

G. implementing procedures H. operating experience reports I. RAIs, audit reports, and SERs for other plants J. applicants FSAR

3. The protocol for interfacing with the applicant.

4. Administrative issues such as travel, control of documentation, work hours, etc.

5. Process for preparing questions, RAIs, the audit and review report, and SER input.

6. Process for interfacing with DE technical reviewers.

6.2 Aging Management Program Audits and Reviews 6.2.1 Types of AMPs There are two types of AMPs: those that the applicant claims are consistent with AMPs contained in the GALL Report, and those that are plant-specific. The process for auditing and reviewing both types of AMPs is presented in the following sections of this plan.

6.2.2 Scope of AMP Elements to be Audited and Reviewed Table 1 of this plan shows the 10 program elements that are used to evaluate the adequacy of each aging management program. These program elements are presented in Branch Technical Position (BTP) RLSB-1, Aging Management Review - Generic, in Appendix A of the SRP-LR, and are summarized in the GALL Report. The project teams scope of review includes 7 of the 10 elements: 1 through 6, and 10.5 The program elements audited or reviewed is the same for both AMPs that are consistent with the GALL Report and for plant-specific AMPs.

5 DIPM will review program elements 7, 8, and 9. The DIPM review will be documented in Section 3 of the plant safety evaluation report.

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Palisades Nuclear Plant Audit and Review Plan 6.2.3 Plant AMPs That Are Consistent With the GALL Report Figure 1, Audit of AMPs That Are Consistent With the GALL Report, is the process flowchart that shows the activities and decisions used by the project team to review and audit each plant AMP that the applicant claims is consistent with the GALL Report.

Preparation A. For the plant AMP being reviewed, identify the corresponding GALL AMP.

B. Review the associated GALL AMP and identify those elements that will be audited.

C. Identify the documents needed to perform the audit. These may include, but are not limited to, the following:

(1) GALL Report (2) SRP-LR (3) ISGs (4) RAIs and SERs for similar plants (5) LRA (6) basis documents (7) implementation procedures (8) operating experience reports (plant-specific and industry)

(9) FSAR Audit/Review A. Confirm that the seven plant AMP elements are consistent with the corresponding elements of the GALL Report AMP by answering the following questions and then following the process shown in Figure 1.

(1) Did the applicant identify any exceptions to the GALL Report AMP?

(2) Are the elements consistent with the GALL Report AMP?

B. If either of the above questions results in the identification of an exception or a difference to the GALL AMP, determine whether it is acceptable on the basis of an adequate technical justification.

C. If an acceptable basis exists for an exception or difference, document the basis in the worksheet and later in the audit and review report and the SER input.

D. Review the industry and plant-specific operating experience associated with the AMP.

This is an area of review emphasis. They require review to identify aging effects requiring management that are not identified by the industry guidance documents (such as Electric Power Research Institute (EPRI) tools) and to confirm the effectiveness of aging management programs. The team members should consider the industry guidance when assessing operating experience and formulating questions for the applicant. The industry guidance (from NEI 95-10, Revision 3) is as follows:

(1) Operating Experience - Aging Effects Requiring Management. A plant-specific operating experience review should assess the operating and maintenance history.

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Palisades Nuclear Plant Audit and Review Plan A review of the prior five to 10 years of operating and maintenance history should be sufficient. The results of the review should confirm consistency with documented industry operating experience. Differences with previously documented industry experience such as new aging effects or lack of aging effects allow consideration of plant-specific aging management requirements.

(2) Operating Experience With Aging Management Programs. Plant-specific operating experience with existing programs should be considered. The operating experience of aging management programs, including past corrective actions resulting in program enhancements or additional programs, should be considered. The review should provide objective evidence to support the conclusion that the effects of aging will be managed so that the intended function(s) will be maintained during the extended period of operation. Guidance for reviewing industry operating experience is presented in BTP RLSB-1 in Appendix A.1 of the Branch Technical Positions in SRP-LR.

(3) Industry Operating Experience. Industry operating experience and its applicability should be assessed to determine whether it changes plant-specific determinations.

The GALL Report is based upon industry operating experience prior to its date of issue. Operating experience after the issue date of the GALL Report should be evaluated and documented as part of the aging management review. In particular, generic communications such as a bulleting or an information notice should be evaluated for impact upon the AMP. The evaluation should check for new aging effects or a new component or location experiencing an already identified aging effect.

E. If it is necessary to ask the applicant a question to clarify the basis for accepting a program element, or an exception or a difference to the GALL Report AMP, follow the logic process shown in Figure 1.

F. If it is necessary for the applicant to submit additional information to support the basis for accepting a program element, an exception, or a difference, the applicant may agree to voluntarily submit the required information as a supplement to the LRA. If not, the NRC may issue an RAI to obtain the information.

AMP Audit Worksheets Document the audits/reviews using the worksheet provided in Appendix E, Consistent with GALL Report AMP Audit/Review Worksheets.

6.2.4 Plant-Specific AMPs There are no plant-specific AMPs assigned to the project team.

6.3 AMR Audits and Reviews There are two types of AMRs: those that the applicant claims are consistent with the GALL Report, and those that are plant-specific. Audit and review of both types of AMRs are discussed below. In general, the project team will review AMRs that are consistent with the GALL Report and AMRs that are based on an NRC-approved precedent that the applicant has identified.

13

Palisades Nuclear Plant Audit and Review Plan 6.3.1 Plant AMRs That Are Consistent With the GALL Report Figure 3, Review of AMRs That Are Consistent With the GALL Report, is the process flowchart that shows the activities and decisions used to audit/review each AMR that the applicant claims is consistent with the GALL Report.

Preparation A. For the plant AMRs that the applicant claims are consistent with the GALL Report, identify the corresponding AMRs in Volume 2 of the GALL Report.

B. Review the associated GALL Report AMRs and identify those line items that will be audited/reviewed in conjunction with each of the plant AMRs.

C. Identify the documents needed to perform the review. These may include, but are not limited to, the following:

(1) GALL Report (2) SRP-LR (3) ISGs (4) RAIs and SERs for similar plants (5) LRA (6) basis documents (7) implementation procedures (8) operating experience reports (plant-specific and industry)

(9) FSAR Audit/Review A. Each AMR line item is coded with a letter which represents a standard note designation.6 The letter notes are described in Table 2 of this plan. Notes that use numeric designators are plant-specific. The note codes A though E are classified as consistent with the GALL Report, and will be reviewed in accordance with the guidance contained in this plan.

B. The AMR review involves verification that the applicant has satisfied the requirements of 10 CFR 54.21(a)(3). This requirement states that, for each structure and component

[within the scope of license renewal], demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the extended period of operation.

C. Verify compliance by following the process shown in Figure 3. The process is summarized below:

6 The AMR line item letter notes are based on a 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). 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).

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Palisades Nuclear Plant Audit and Review Plan (1) For each AMR line item, perform the review associated with the letter note (A through E) assigned to the AMR line item. Specifically, determine if the AMR is consistent with the GALL Report for the elements associated with its note.

(2) If Note A applies, and the applicant uses a plant-specific AMP7, determine if the component is within the scope of the cited plant AMP. If the component is within the scope of the plant AMP, the AMR line item is acceptable. If not acceptable, go to Step (7) below.

(3) If Note B applies, review the LRA exceptions and document the basis for acceptance in the worksheet, and later in the audit and review report. If not acceptable, go to Step (7) below.

(4) If Note C or D applies, determine if the component type is acceptable for the material, environment, and aging effect. If Note D applies, also review the LRA exceptions and document the basis for acceptance in the worksheet, and later in the audit and review report. If not acceptable, go to Step (7) below.

(5) If Note E applies, review the AMP audit report findings to determine if the scope of the alternate AMP envelopes the AMR line item being reviewed and satisfies 10 CFR 54.21(a)(3). If it does not, go to Step (7) below.

(6) Review the corresponding LRA Table 3.X.1 entry that is referenced in LRA Table 3.X.2.Y. If applicable, determine whether the applicants Further Evaluation Recommended response in LRA Section 3.X.2.2.Z is enveloped by Section 3.X.2.2.Z of the SRP-LR. If not, go to Step (7) below. If the LRA section does not meet the acceptance criteria of Appendix A of the SRP-LR, go to Step (7) below.

(7) If during the review a difference is identified, prepare a question to the applicant, in order to obtain clarification.

(a) Review the applicants response to the question. If it appears acceptable, re-start the audit/review for the AMR line item from Step (1) above.

(b) If the applicants response does not resolve the question or issue, prepare an additional question to obtain the information needed to achieve resolution.

Review the applicants response to the second question. If it appears acceptable, re-start the audit/review for the AMR line item from Step (1) above.

(c) If it is necessary for the applicant to submit additional information to resolve a question or an issue or to support a basis or conclusion, the applicant may submit the information as a supplement to the LRA or the NRC may issue an RAI to obtain the information. The team leader should be consulted if docketed information may be needed.

AMR Audit/Review Worksheets Document the audits/reviews of plant AMRs using the worksheet provided in Appendix G, Aging Management Review Worksheets.

7 Some GALL AMRs reference the use of a plant-specific AMP. In such cases the AMR audit requires the project team member to confirm that the plant-specific AMP is appropriate to manage the aging effects during the period of extended operation.

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Palisades Nuclear Plant Audit and Review Plan 6.3.2 AMRs Based on NRC-Approved Precedents Figure 4, AMR Review Using NRC-Approved Precedent, is the process flowchart that shows the activities and decisions used to review plant AMRs that the applicant has identified as being consistent with an NRC-approved precedent.8 Preparation Identify the documents needed to perform the audit/review. These may include, but are not limited to, the following:

(1) GALL Report (2) SRP-LR (3) ISGs (4) RAIs and SERs for similar plants (5) LRA (6) basis documents (7) implementation procedures (8) operating experience reports (plant-specific and industry)

(9) FSAR Audit/Review A. The AMR audit/review involves verification that the requirements of 10 CFR 54.21(a)(3) are satisfied. This criterion states that, For each structure and component [within the scope of license renewal], demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation.

B. For AMRs with an NRC-approved precedent, this may be achieved by answering the following questions while following the assessment process shown in Figure 4.

(1) Is the precedent appropriate for the LRA AMR being reviewed?

(2) Is the NRC-approved precedent sufficiently documented or understood to technically support the adequacy of the LRA AMR being reviewed?

(3) Is the LRA AMR within the bounds of the chosen NRC-approved precedent?

(4) If any of these questions results in a No answer, then additional information is required to make a determination that the AMR is acceptable.

(5) If it is necessary to ask the applicant a question to obtain clarification on the basis for accepting the AMR, the process shown in Figure 4 should be used.

(6) If it is necessary for the applicants response to be docketed as a basis for accepting the exception or difference, the applicant may voluntarily docket the response or the NRC may issue an RAI.

8 Applicant identified NRC-approved precedents are only to be used as an aid for performing AMR audits.

The audit conclusions will be based on the technical basis of the AMR and its applicability to the plant being reviewed. It is not acceptable to simply cite the NRC-approved precedent as its basis.

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Palisades Nuclear Plant Audit and Review Plan AMR Audit/Review Worksheets Document the audits/reviews using the worksheet provided in Appendix G, Aging Management Review Worksheets.

6.4 Audit and Safety Review Documentation As noted in Section 5.7 of this plan, the project team will prepare an audit and review plan, worksheets, work packages, requests for additional information, an audit and review report, and a SER input. This section of the plan addresses the preparation of the audit and review report and the SER input.

6.4.1 Audit and Review Report

1. Format and content of the audit and review report. The report should include the following:

A. Cover page B. Table of Contents C. Section 1, Introduction and General Information D. Section 2, Aging Management Programs Audit and Review Results E. Section 3, Aging Management Review Audit and Review Results F. Section 4, Time-Limited Aging Analyses G. Attachment 1, Abbreviations and Acronyms H. Attachment 2, Project Team and Applicant Personnel I. Attachment 3, Elements of an Aging Management Program for License Renewal J. Attachment 4, Disposition of Requests for Additional Information, LRA Supplements and Open Items K. Attachment 5, List of Documents Reviewed L. Attachment 6, List of Commitments

2. The following paragraphs describe, in general, the type of information and the level of detail necessary for each report section.

A. Cover page that identifies the following:

(1) Name of the plant and units (2) Docket number of the plants (3) Organization preparing the report (4) Contract number under which the work was performed (5) Acknowledgement that the report was prepared for the License Renewal and Environmental Impacts Program, Division of Regulatory Improvement Programs, Office of Nuclear Reactor Regulation (6) Date of the report B. Table of Contents.

C. Section 1, Introduction and General Information. The introduction and general information should include the following information.

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Palisades Nuclear Plant Audit and Review Plan (1) Section 1.1, Introduction. This section of the report should provide an overview of the audit and review conducted by the project team. It should also list key audit and review activities, including on-site visits, as well as the organizations supporting the audit and review. This information should be taken largely from the audit and review plan.

(2) Section 1.2, Background. This section of the report should include a summary of the license renewal requirements as stated in the Code of Federal Regulations and a summary of the documents that the project team used to carry out the audit and review. This information should be taken largely from the audit and review plan.

(3) Section 1.3, Summary of Information in the License Renewal Application. This section of the report should include a description of the information contained in the license renewal application that is applicable to the audit and review. This information should be taken largely from the audit and review plan.

(4) Section 1.4, Audit and Review Scope. This section of the report should indicate that the AMRs and associated AMPs that the project team reviewed are identified in the audit and review plan. It should also include a general statement of the types and numbers of AMRs and AMPs that the team audited and reviewed.

(5) Section 1.5, Audit and Review Process. This section of the report should state that the audit and review was performed in accordance with the processes defined in the audit and review plan and should summarize the audit and review process for AMPs, AMRs, and the Final Safety Analysis Report (FSAR) supplement. This section of the report should include the following subsections:

i. 1.5.1 PNP AMPs ii. 1.5.2 PNP AMR Results iii. 1.5.3 NRC-Approved Precedents iv. 1.5.4 Final Safety Analysis Report Supplement

v. 1.5.5 Documentation and Documents Reviewed vi. 1.5.6 Commitments to be included in the Safety Evaluation Report (6) Section 1.6, Exit Meeting. This section should include an acknowledgement of and a brief summary of the public exit meeting.

D. Section 2, Aging Management Programs Audit and Review Results.

NOTE: This section of the report contains the project teams review results and evaluation of the aging management programs. Numbering of these AMP writeups should be sequential based on the order presented in the applicants LRA (e.g., the section number for first plant AMP should be 2.1). Depending on the plant AMP, whether it is consistent with the Generic Aging Lessons Learned (GALL) Report or plant-specific, (1) or (2), respectively, as provided below, is to be used.

(1) For AMPs that are consistent with the GALL Report.

The project team's audit and review of each AMP that the applicant identified as consistent with the GALL Report should be documented in the report. Each AMP 18

Palisades Nuclear Plant Audit and Review Plan should have an individual subsection in the report, identified in the table of contents, that includes the following:

i. A subsection (e.g., 2.X, AMP NAME (AMP Number) that identifies the plant AMP name and number and the section of the LRA (number and title) that includes the AMP.

ii. A subsection (e.g., 2.X.1, Program Description) that describes the plant AMP.

iii. A subsection (e.g., 2.X.2, Consistency with the GALL Report) that describes the plant AMP consistency with respect to the GALL AMP. The inputs to this determination, including the key documents reviewed and the applicant staff interviewed are to be documented here, followed by an evaluation and basis for concluding that the plant AMP is (or is not) consistent with the GALL AMP.

If exceptions or enhancements were identified by the applicant, state so. If any differences were identified by the project team, describe them here. If the applicant chooses to treat the identified difference as an exception, evaluate it in Section 2.X.3 and refer to that discussion here. If the applicant chooses to address the difference as a required enhancement, evaluate it in Section 2.X.4 and refer to that discussion here. If the applicant addressed the difference with a formal response to an RAI or a supplement to the LRA, document the submittal (include the date and the ADAMS accession number), summarize the applicants position, identify the basis for resolution or rejection of the difference, and document it here.

For any unresolved items, the NRC staff should issue a request for additional information (RAI). If the applicant responds to the RAI prior to the issuance of the audit report, the project team should document the response (include the dated and the ADAMS accession number), summarize the applicants position, explain the issue that the response resolved, and discuss the basis for the resolution. Otherwise, the project team should document the issue and the associated RAI number, and indicate that the review of the RAI response will be documented in the safety evaluation report.

iv. A subsection (e.g., 2.X.3, Exceptions to the GALL Report) that lists any exceptions to the GALL AMP, a restatement of the GALL AMP program element criteria that apply to the exception, and an evaluation that clearly explains why any exceptions (identified by either the applicant or the project team) to the GALL AMP are acceptable.

The evaluation should address any supplements to the LRA. If the applicant submitted a supplement to its LRA to resolve a question or issue, document the submittal (include the date and the ADAMS accession number),

summarize the applicants position, explain the issue that the submittal resolved, and discuss the basis for the resolution.

For any unresolved items, the NRC staff should issue a request for additional information (RAI). If the applicant responds to the RAI prior to the issuance of the audit report, the project team should document the response (include the dated and the ADAMS accession number), summarize the applicants 19

Palisades Nuclear Plant Audit and Review Plan position, explain the issue that the response resolved, and discuss the basis for the resolution. Otherwise, the project team should document the issue and the associated RAI number, and indicate that the review of the RAI response will be documented in the safety evaluation report.

If there are no exceptions, enter None.

v. A subsection (e.g., 2.X.4, Enhancements) that lists any enhancements to the applicants AMP to meet the GALL Report, a restatement of the GALL AMP program element criteria that apply to the enhancement, and an evaluation that clearly explains why any enhancements to the applicants AMP are acceptable and that such changes to the applicants program will provide additional assurance that the effects of aging will be adequately managed.

The evaluation should address any supplements to the LRA. If the applicant submitted a supplement to its LRA to resolve a question or issue, document the submittal (include the date and the ADAMS accession number),

summarize the applicants position, explain the issue that the submittal resolved, and discuss the basis for the resolution.

For any unresolved items, the NRC staff should issue a request for additional information (RAI). If the applicant responds to the RAI prior to the issuance of the audit and review report, the project team should document the response (include the dated and the ADAMS accession number), summarize the applicants position, explain the issue that the response resolved, and discuss the basis for the resolution. Otherwise, the project team should document the issue and the associated RAI number, and indicate that the review of the RAI response will be documented in the safety evaluation report.

If there are no enhancements, enter None.

vi. A subsection (e.g., 2.X.5, Operating Experience) that documents the project team's review of the plant-specific and industry operating experience associated with the plant AMP.

vii. A subsection (e.g., 2.X.6, FSAR Supplement) that documents the project team's review of the adequacy of the applicant's commitment to revise the FSAR.

viii. A subsection (e.g., 2.X.7, Conclusions) that documents the project team's conclusions regarding the AMP. The conclusion should discuss the AMP consistency with the GALL AMP, the disposition status of any exceptions or enhancements, and state if the criteria of 10 CFR54.21(a)(3) will be satisfied.

Also, the conclusion should discuss the adequacy of the AMP and whether the criteria of 10 CFR54.21(d) will be satisfied.

(2) For AMPs that are Plant-Specific There are no plant-specific AMPs assigned to the project team.

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Palisades Nuclear Plant Audit and Review Plan E. Section 3, Aging Management Review Audit and Review Results This section of the report contains the project teams review results and evaluation of the aging management reviews.

(1) A summary of the documents that the project team reviewed to perform the audit and review, e.g., the LRA, the SRP-LR, and the applicant's basis documents.

(2) A summary review of the AMR notes used by the applicant to classify the AMR line-items used in the LRA Tables 3.X.2 Y if they are relevant to the audit and review (Notes A through E for AMRs that are consistent with the GALL Report; Notes A through J if the review is based on an NRC-approved precedent).

(3) The basis for accepting any exceptions to the GALL Report AMRs that were identified by the applicant or the project team reviewer.

(4) Information about any supplements submitted by the applicant. The evaluation should address any LRA supplements that the applicant submitted to resolve questions or issues. Document the submittal (include the date and the ADAMS accession number), summarize the applicants position, explain the issue that the submittal resolved, and discuss the basis for the resolution.

(5) Information about any RAIs. For any unresolved items, the NRC staff should issue a request for additional information (RAI). If the applicant responds to the RAI prior to the issuance of the audit report, the project team should document the response (include the dated and the ADAMS accession number), summarize the applicants position, explain the issue that the response resolved, and discuss the basis for the resolution. Otherwise, the project team should document the issue and the associated RAI number, and indicate that the review of the RAI response will be documented in the safety evaluation report.

NOTE: For each of the applicants LRA AMRs Sections, (i.e, Sections 3.1 through 3.6), a writeup is required for each section and is described below. Numbering of these AMRs writeup should be sequential based on the order presented in the applicants LRA (e.g., the section number for first section should be 3.1). Also, the title of the sections should be the same as the title of the applicants LRA for that section (i.e., the Aging Management of Reactor Vessel, Internals, and Reactor Coolant System).

(6) 3.X Applicants LRA Section 3.X - Aging Management of This section includes introductory information for the LRA Section 3.X and should contain the LRA section that the project team reviewed and a summary of the type of information provided in the section of the LRA reviewed, including a listing of component types associated with this LRA section. A discussion on the component type of AMRs reviewed (i.e., those components where further evaluation is recommended, those for which no further evaluation is required, and those that are not applicable together with the basis for their exclusion).

Also, identify the SRP-LR Section for which the review is performed against.

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Palisades Nuclear Plant Audit and Review Plan

i. (3.X.1) Aging Management Review Results That Are Consistent With the GALL Report This section of the audit and review report documents reviews of AMRs that are consistent with the GALL Report. It should include the following.

(a) A introductory paragraph that states the project teams determination of the applicants reference to the GALL Report is acceptable.

(b) A paragraph that identifies what the project team reviewed.

(c) Document information on AMRs consistent with the GALL Report for which no further information is required only if there was an audit finding that resulted in an RAI or an open item requiring a formal response from the applicant. Numbering of the subsection should be sequential based on the order presented in the applicants LRA (i.e., 3.X.1.1). The title of the subsection should be based on the subject of discussion. If there was no finding, skip the next three items and go to item (f).

(d) Information about any supplements submitted by the applicant. The evaluation should address any LRA supplements that the applicant submitted to resolve questions or issues. Document the submittal (include the date and the ADAMS accession number), summarize the applicants position, explain the issue that the submittal resolved, and discuss the basis for the resolution.

(e) Information about any RAIs. For any unresolved items, the NRC staff should issue a request for additional information (RAI). If the applicant responds to the RAI prior to the issuance of the audit report, the project team should document the response (include the dated and the ADAMS accession number), summarize the applicants position, explain the issue that the response resolved, and discuss the basis for the resolution. Otherwise, the project team should document the issue and the associated RAI number, and indicate that the review of the RAI response will be documented in the safety evaluation report.

(f) An evaluation determining that:

1. The applicant identified the applicable aging effects.

2. The applicant defined the appropriate combination of materials and environments.

3. The applicant specified acceptable AMPs.

4. A conclusion stating that, if appropriate, the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained for the period of extended operation, and that 10 CFR 54.21(a)(3) has been satisfied.

(g) A conclusion that documents the project team's overall conclusions regarding AMRs not requiring further evaluation. Specifically, the applicant's references to the GALL Report are acceptable and that no further project team review is required.

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Palisades Nuclear Plant Audit and Review Plan ii. (3.X.2) Aging Management Review Results For Which Further Evaluation Is Recommended By The GALL Report This section of the audit and review report documents reviews of AMR results for which the GALL Report recommends further evaluation. It should include the following:

(a) An introductory paragraph that states the project teams determination of the applicants reference to the GALL Report which require further evaluation. A summary of the type of information provided in the section of the LRA reviewed. Identify the LRA Tables 3.X.2.-Y through 3.X.2-Z listed in this section. Also, identify the SRP-LR Section for which the review is performed against.

(b) A subsection for each of the LRA sections (3.X.2.2.Y) containing the applicant's further evaluations of AMRs for which further evaluation is recommended.

(c) For each LRA Section 3.X.2.2.Y containing the applicant's further evaluations, the following should be included:

1. A statement that the project team audited the applicant's further evaluations against the criteria contained in Section 3.X.2.2.Y of the SRP-LR.

2. The SRP-LR Section 3.X.2.2.Y criteria.

3. The basis for concluding that it the applicant's evaluation of the aging effect satisfies the criteria contained in Section 3.X.2.2.Y of the SRP-LR.

4. Information about any supplements submitted by the applicant.

The evaluation should address any LRA supplements that the applicant submitted to resolve questions or issues. Document the submittal (include the date and the ADAMS accession number),

summarize the applicants position, explain the issue that the submittal resolved, and discuss the basis for the resolution.

(d) Information about any RAIs. For any unresolved items, the NRC staff should issue a request for additional information (RAI). If the applicant responds to the RAI prior to the issuance of the audit report, the project team should document the response (include the dated and the ADAMS accession number), summarize the applicants position, explain the issue that the response resolved, and discuss the basis for the resolution. Otherwise, the project team should document the issue and the associated RAI number, and indicate that the review of the RAI response will be documented in the safety evaluation report.

(e) A concluding paragraph summarizing the project team evaluation of the particular aging effect.

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Palisades Nuclear Plant Audit and Review Plan iii. (3.X.3) Aging Management Review Results That Are Not Consistent With GALL Report Or Are Not Addressed in the GALL Report This section of the audit and review report documents reviews of AMRs that are not consistent with the GALL Report or are not addressed in the GALL Report and should include the following:

(a) An introductory paragraph that states the project teams review of AMR results that are not consistent with the GALL Report or are not addressed in the GALL Report. A summary of the type of information provided in the section of the LRA reviewed. Identify the LRA Tables 3.X.2.-Y through 3.X.2-Z listed in this section.

(b) For each LRA Table 3.X.2-Y in LRA Section 3.X, the results and findings of previously approved positions of the NRC staff that were reviewed.

(c) An evaluation and finding that determines that:

1. the applicant identified the applicable aging effect and component,

2. the applicant listed the appropriate combination of materials and environments, and

3. the applicant identified acceptable AMPs.

(d) Information about any supplements submitted by the applicant. The evaluation should address any LRA supplements that the applicant submitted to resolve questions or issues. Document the submittal (include the date and the ADAMS accession number), summarize the applicants position, explain the issue that the submittal resolved, and discuss the basis for the resolution.

(e) For additional information (RAI). If the applicant responds to the RAI prior to the issuance of the audit report, the project team should document the response (include the dated and the ADAMS accession number), summarize the applicants position, explain the issue that the response resolved, and discuss the basis for the resolution. Otherwise, the project team should document the issue and the associated RAI number, and indicate that the review of the RAI response will be documented in the safety evaluation report.

(f) A conclusion stating, if appropriate, that the applicant has demonstrated that the effects of aging will be adequately managed so that the intended functions will be maintained during the period of extended operation, and 10 CFR 54.21(a)(3) has been satisfied.

F. Section 4, Time-Limited Aging Analyses This section documents the project team review of the applicants TLAA.

Reviewer to add TLAA discussion in this section. For guidance on developing this section, confer with some of the more recent SERs.

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Palisades Nuclear Plant Audit and Review Plan G. Attachment 1, Abbreviations and Acronyms. This attachment should identify the abbreviations and acronyms used in the audit and review report.

H. Attachment 2, Project Team and Applicant Personnel. This attachment should identify the project team members, the project team support personnel, the key applicant personnel who were consulted during the audit and review, and the individuals that attended the exit meeting.

I. Attachment 3, Elements of an Aging Management Program for License Renewal. This attachment is a standard table of the 10 program elements that are used to evaluate the adequacy of each AMP as presented in Branch Technical Position (BTP) RLSB 1, "Aging Management Review - Generic," in Appendix A of the SRP-LR.

J. Attachment 4, Disposition of Requests for Additional Information, LRA Supplements, and Open Items. This attachment should identify the following.

(1) A list of the formal RAIs that were issued as a result of the audit/review and a summary of the disposition of the applicant's responses to each RAI.

(2) A list of issues that the applicant agreed to formally address through a supplement to its LRA and a summary of the disposition of each issue.

(3) The applicable AMP or AMR for each RAI and LRA supplement.

(4) Possible dispositions which could include open, closed, or confirmatory items.

The initiation of each RAI and LRA supplement, as well as its dispositions, should be clearly documented in conjunction with the audit and review results in the applicable AMP or AMR sections of the report.

K. Attachment 5, List of Documents Reviewed. This attachment should list all of the documents reviewed by the project team to support its AMP and AMR audits and reviews and to support its evaluations and conclusions.

(1) Indicate which documents were reviewed for each AMP or AMR section.

(2) Include both docketed documents (e.g., the license renewal application) and non-docketed documents (e.g., basis documents, condition reports, and implementing procedures).

(3) Include both licensee-controlled documents (e.g., basis documents, condition reports, and implementing procedures) and other documents (e.g., topical reports and industry codes and standards).

L. Attachment 6, List of Commitments. This attachment should list and summarize all commitments made by the applicant that were reviewed by the project team, including any commitments that the applicant made in response to the project team's audit and review. This information can be subsequently excerpted for the safety evaluation report (SER).

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Palisades Nuclear Plant Audit and Review Plan 6.4.2 Safety Evaluation Report Input

1. General guidance A. Prepare the SER input for the AMP and AMR audits and reviews.

B. In general, the data and information needed to prepare the SER input should be available in the project teams audit and review report and the team members worksheets.

C. SER inputs are to be prepared for:

(1) Each AMP that was determined to be consistent with the GALL Report, which has no exceptions or enhancements.

(2) Each AMP that was determined to be consistent with the GALL Report, which has exceptions (identified by either the applicant or the project team) or enhancements.

(3) Each plant-specific AMP.

(4) AMRs that are consistent with the GALL Report.

(5) Project team AMR review results9.

D. The SER input should contain the following sections. (Note: The following section numbers (3. through 3.X.3) are based on the numbering system for the SER input.

They are not a continuation of the numbering convention used throughout this plan.)

3. Aging Management Review Results 3.0 Applicants Use of the Generic Aging Lessons Learned Report 3.0.1 Format of the LRA 3.0.2 Staffs Review Process 3.0.2.1 Review of AMPs 3.0.2.2 AMRs in the GALL Report 3.0.2.3 NRC-Approved Precedents 3.0.2.4 FSAR Supplement 3.0.2.5 Documentation and Documents Reviewed 3.0.3 Aging Management Programs 3.0.3.1 AMPs that are Consistent With the GALL Report 3.0.3.2 AMPs that are Consistent With GALL Report With Exceptions or Enhancements 3.0.3.3 AMPs that are Plant-Specific 3.0.4 Quality Assurance Program Attributes Integral to Aging Management Programs 3.X10 Aging Management of ______

3.X.1 Summary of Technical Information in the Application 3.X.2 Staff Evaluation 9

AMRs that are not consistent with the GALL Report.

10 The LRA AMR results are broken down into six sections and address the following system/structure groups: (1) Section 3.1, reactor vessel, internals and reactor coolant system, (2) Section 3.2, engineering safety features systems, (3) Section 3.3, auxiliary systems, (4) Section 3.4, steam power and conversion systems, (5) Section 3.5, structures and component supports, (6) Section 3.6, electrical and instrumentation and controls.

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Palisades Nuclear Plant Audit and Review Plan 3.X.2.1 Aging Management Evaluations that are Consistent with the GALL Report, for Which Further Evaluation is Not Required 3.X.2.2 Aging Management Evaluations that are Consistent with the GALL Report, for Which Further Evaluation is Recommended 3.X.2.3 AMR Results that are Not Consistent with or Not Addressed in the GALL Report 3.X.3 Conclusion E. For each AMP audited/reviewed by the project team, the SER shall include a discussion of the teams review of the operating experience program element.

F. If the applicant submitted an amendment or a supplement to its LRA that is associated with the project teams audit or review activities, document the submittal (include the date and ADAMS accession number) and explain the issue that the submittal resolved and discuss the basis for the resolution.

G. If an RAI was issued, identify the RAI number and briefly discuss the RAI. State if the RAI remains open or if the applicant response has been received and accepted.

If the response was acceptable, identify the submittal (including the date and the ADAMS accession number) that provided the response and document the basis for its acceptance.

H. Issues (e.g., RAIs) that have not been resolved by the applicant at the time the SER input is prepared should be identified as open items.

2. SER input A. For AMPs determined to be consistent with the GALL Report, without exceptions, include the AMP title, the plant AMP paragraph number, and a discussion of the basis for concluding that the FSAR supplement (Appendix A of the LRA) is acceptable. This SER input documents that the AMP is consistent with the GALL Report.

B. For AMPs determined to be consistent with the GALL Report, with exceptions or enhancements, the SER input should include a statement that the audit found the AMP consistent with the GALL Report and that any applicant-identified exceptions to the GALL Report were found technically acceptable to manage the aging effect during the period of extended operation. The SER input should identify the exceptions and provide the basis for acceptance. The SER input will also address the FSAR supplement, and document the basis for concluding that it is acceptable.

C. For plant-specific AMPs, the SER input should document the basis for accepting each of the seven elements reviewed by the project team. The SER input should also include a discussion concerning the adequacy of the FSAR supplement.

D. For aging management evaluations that are consistent with the GALL Report,11 the SER input should include the following:

11 The audit results documented in this section address the AMRs consistent with the GALL Report for which no further evaluation is recommended.

27

Palisades Nuclear Plant Audit and Review Plan (1) Identify the LRA section reviewed.

(2) A summary of the type of information provided in the section of the LRA reviewed, including a listing of the AMPs reviewed.

(3) Identify the LRA Tables 3.X.2-Y reviewed.

(4) A summary review of the AMR Notes A through E used to classify the AMR line items used in these tables.

(5) A brief summary of what the staff (project team) reviewed to perform the audit, i.e., LRA and applicant basis documents and other implementation documents.

Reference the appendix that lists the details of the documents reviewed.

(6) The bases for accepting any exceptions to GALL AMRs that were identified by the applicant or the project team member.

(7) A finding that verifies that:

i. The applicant identified the applicable aging effects.

ii. The applicant defined the appropriate combination of materials and environments.

iii. The applicant specified acceptable AMPs.

(8) A conclusion stating, if applicable, 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, and that 10 CFR 54.21(a)(3) has been satisfied.

E. For aging management evaluations that are consistent with the GALL Report, for which further evaluation is recommended, the SER input should include the following:

(1) The LRA section containing the applicants further evaluations of AMRs for which further evaluation is required.

(2) A list of the aging effects for which the further evaluation apply.

(3) For the applicants further evaluations, provide a summary of the basis for concluding that it satisfied the criteria of Section 3.1.3.2 of the SRP-LR.

(4) A statement that the staff audited the applicants further evaluations against the criteria contained in Section 3.1.3.2 of the SRP-LR.

(5) A statement that the audit and review report contains additional information. Also identify the issue date and the ADAMS accession number for the audit and review report.

F. Staff AMR Review Results.12 This section of the SER input documents the reviews of AMRs assigned to the project team that are not consistent with the GALL Report.

The audit report should document the following, based on a precedent identified by the applicant:

(1) The LRA section reviewed.

(2) A summary of the type of information provided in the section of the LRA, reviewed, including a listing of the AMPs reviewed for this LRA section.

(3) Identify the LRA Tables 3.X.2-Y documented by this audit writeup.

(4) A brief summary of what the staff (project team) reviewed, i.e., LRA and applicant basis documents and other implementation documents.

(5) A finding that verifies, if true, that:

12 This section documents reviews of AMRs assigned to the project team that are not consistent with the GALL Report.

28

Palisades Nuclear Plant Audit and Review Plan

i. The applicant identified the applicable aging effects.

ii. The applicant listed the appropriate combination of materials and environments.

iii. The applicant specified acceptable AMPs.

(6) Provide a conclusion stating, if applicable, 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, and that 10 CFR 54.21(a)(3) has been satisfied.

6.5 Documents Reviewed and Document Retention Any documents reviewed that were used to formulate the basis for resolution of an issue, such as the basis for a technical resolution, the basis for the acceptance of an exception or an enhancement, etc., should be documented as a reference in the audit and review report.

Upon issuance of the audit and review report, all worksheets that were completed by contractor and NRC personnel shall be given to the NRC project team leader.

After the NRC has made its licensing decision, all copies of documents collected and all documents generated to complete the audit and review report, such as audit worksheets, question and answer tracking documentation, etc., are to be discarded.

29

Palisades Nuclear Plant Audit and Review Plan Table 1. Aging Management Program Element Descriptions Element Description 1 Scope of the program The scope of the program should include the specific structures and components subject to an aging management review.

2 Preventive actions Preventive actions should mitigate or prevent the applicable aging effects.

3 Parameters monitored Parameters monitored or inspected should be linked to the or inspected effects of aging on the intended functions of the particular structure and component.

4 Detection of aging Detection of aging effects should occur before there is loss of effects any structure and component intended function. 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 and trending Monitoring and trending should provide prediction of the extent of the effects of aging and timely corrective or mitigative actions.

6 Acceptance criteria Acceptance criteria, against which the need for corrective action will be evaluated, should ensure that the particular structure and component intended functions are maintained under all current licensing basis design conditions during the period of extended operation.

7 Corrective actions Corrective actions, including root cause determination and prevention of recurrence, should be timely.

8 Confirmation process The confirmation process should ensure that preventive actions are adequate and appropriate corrective actions have been completed and are effective.

9 Administrative controls Administrative controls should provide a formal review and approval process.

10 Operating experience Operating experience involving the aging management program, including past corrective actions resulting in program enhancements or additional programs, should provide objective evidence to support a determination that the effects of aging will be adequately managed so that the structure and component intended functions will be maintained during the period of extended operation.

30

Palisades Nuclear Plant Audit and Review Plan Table 2. Notes for License Renewal Application Tables 3.X.2-Y13 Note Description A Consistent with the GALL Report item for component, material, environment, and aging effect. AMP is consistent with the GALL Report AMP.

B Consistent with the GALL Report item for component, material, environment, and aging effect. AMP takes some exceptions to the GALL Report AMP.

C Component is different, but consistent with the GALL Report item for material, environment, and aging effect. AMP is consistent with the GALL Report AMP.

D Component is different, but consistent with the GALL Report item for material, environment, and aging effect. AMP takes some exceptions to the GALL Report AMP.

E Consistent with the GALL Report for material, environment, and aging effect, but a different aging management program is credited.

F Material not in the GALL Report for this component.

G Environment not in the GALL Report for this component and material.

H Aging effect not in the GALL Report for this component, material and environment combination.

I Aging effect in the GALL Report for this component, material and environment combination is not applicable.

J Neither the component nor the material and environment combination is evaluated in the GALL Report.

13 Each AMR line item is coded with a letter which represents a standard note designation based on a 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). The staff concurred in the format of the standardized format for license renewal applications by letter dated April 7, 2003, from P.T. Kuo, NRC, to A. Nelson, NEI (ML030990052).

31

Palisades Nuclear Plant Audit and Review Plan Start Preparation Steps Identify GALL AMP(s) to which LRA AMP is being compared Note; Preparation steps may be performed as a single combined step for Identify elements of GALL each AMP audited.

AMP(s) attributes to be audited Identify LRA AMP support documents needed to Develop and perform audit provide question Obtain to Team Leader response from for PMs submittal applicant to applicant Did applicant identify Yes any exceptions to GALL AMP(s)?

Yes Notify NRC No Team Leader Ask applicant a clarifying that Audit of No question to continue audit?

AMR may not Compare each GALL AMP proceed.

No to the LRA auditable element AMP Is there a technical No basis to accept exception or difference? Draft RAI Is the attribute Note: If a prior NRC element consistent? No precedent exists, it may be used as an aid to Yes make the technical determination.

Documentation of the Document the basis for Yes acceptance must be acceptance of the attribute made on the technical element in worksheet merits not a citation to Terminate AMP the precedent. audit Have all attribute elements Write audit report input per No been audited? guidance in Section D.E.F Yes Provide audit report input No Have all 7 AMP attributes been audited? Write SE input per guidance in Section G.H.J Yes Provide audit SE input Conclusion of AMP audit Figure 1. Audit of AMPs That Are Consistent With the GALL Report 32

Palisades Nuclear Plant Audit and Review Plan Figure has been deleted (Note: There are no plant-specific AMPs to be reviewed by the project team.)

Figure 2. Audit of Plant-Specific AMPs 33

Palisades Nuclear Plant Audit and Review Plan AMR item Item is No Review corresponding LRA Table Review referenced LRA subsection and Further Yes assigned to 3.X.1"Further Evaluation Recommended" compare with SRP subsection for any Evaluation DE and "Discussion" columns differences Yes No No No No No No Footnote A Footnote B Footnote C Footnote D Footnote E Yes Yes Yes Yes Yes Compare item with Compare line item with Compare line item with Compare line item with Compare line item with GALL Vol. 2 System GALL Vol. 2 System GALL Vol. 2 System GALL Vol. 2 System GALL Vol. 2 System Table item for: Table line item for: Table line item for: Table line item for: Table line item for:

component type component type - - -

material material material material material environment environment environment environment environment aging effect aging effect aging effect aging effect aging effect AMP - AMP - -

Confirm AE still Confirm material, Confirm material, Confirm AMP can manage AMP Yes managed despite environment, AE, and environment and aging this AE is Plant- AMP exception method per AMP are effect are comparable and Specific comparable AE still managed despite No Confirm that AMP will AMP exception address AE for this component and environment No Acceptable in Document problem in Confirm question Mark for query Prepare question all aspects AMR Comparison Checklist is captured Yes Document basis for acceptance AMR line item Mark as Acceptable in AMR Comparison Checklist complete Out of RLEP Mark as Out of Scope Scope Figure 3. Review of AMRs That Are Consistent With the GALL Report 34

Palisades Nuclear Plant Audit and Review Plan Yes Applicant proposes precedent No Review cited SER Yes Review all relevant RAIs exist RAIs No Review cited LRA (may not be required in all cases)

Yes Document basis for acceptance Valid precedent Mark as Acceptable AMR complete in AMR Comparison Checklist No Yes Additional Document problem in Prepare Confirm question information Mark for query AMR Comparison question is captured needed Checklist No Identify or request alternative precedent Yes Alternative precedent identified No Document absence of Propose Out of RLEP Mark as Open Item precedent in AMR assignment Scope Comparison Checklist to DE Figure 4. Review of AMRs Using NRC-Approved Precedents 35

Palisades Nuclear Plant Audit and Review Plan Appendix A Project Team Membership

Palisades Nuclear Plant Audit and Review Plan Appendix A Project Team Membership Organization Name Function NRC/NRR/DRIP/RLEP-B Kurt Cozens Team leader NRC/NRR/DRIP/RLEP-B Robert Hsu Backup team leader NRC/NRR/DRIP/RLEP-B Amar Pal Reviewer - Electrical ISL Michael Kennedy Contractor lead, reviewer - Systems ISL Malcolm Patterson Reviewer - Materials/Systems/

Mechanical ISL Farideh Saba Reviewer - Mechanical ISL Jon Woodfield Reviewer - Structural A-1

Palisades Nuclear Plant Audit and Review Plan Appendix B RLEP-B Schedule for LRA Safety Review

Palisades Nuclear Plant Audit and Review Plan Appendix B RLEP-B Schedule for LRA Safety Review Plant: Palisades Nuclear Plant TAC Number: MC6433 Team Leader: Kurt Cozens Backup Team Leader: Robert Hsu Project Manager: Mike Morgan Contractor: ISL Activity/Milestone Scheduled Completion 1 Receive license renewal application 3/24/05 2 Train project team 5/18-19/05 3 Make review assignments (project manager) 5/7/05 4 Conduct team planning meeting 5/19/05 5 Issue audit plan to project manager 5/18/05 6 Complete pre-write of audit report 5/31/05 7 Conduct on site AMP audit & review 6/20-24/05 8 Draft AMP audit report input 7/13/05 9 Conduct in-office AMR reviews 7/18-22/05 10 Conduct on site AMR audit & review 8/1-5/05 11 Draft AMR audit report input 8/25/05 12 Cutoff for providing RAIs to PM 8/31/05 13 Conduct public exit meeting 9/2/05 14 Peer review of final draft audit and review report 9/21-26/05 15 Issue final audit and review report 10/17/05 16 Draft SER input for AMP reviews 11/9/05 17 Draft SER input for AMR reviews 11/9/05 18 Issue final draft SER input to PM with open items 11/21/05 19 ACRS Subcommittee meeting 6/2006 tentative 20 ACRS Full Committee meeting 11/2006 tentative B-1

Palisades Nuclear Plant Audit and Review Plan Appendix C Aging Management Program Assignments

Palisades Nuclear Plant Audit and Review Plan Appendix C Aging Management Program Assignments The following AMPs have been assigned to the project team for review.

Consistent GALL with GALL LRA Report Report AMP AMP Assigned Number Number AMP Title Yes No Reviewer B2.1.1 XI.M11 Alloy 600 Program Yes Hsu B2.1.2 XI.M1 ASME Section XI IWB, IWC, IWD, Yes Hsu XI.M3 IWF Inservice Inspection Program XI.S3 B2.1.3 XI.M18 Bolting Integrity Program Yes DE B2.1.4 XI.M10 Boric Acid Corrosion Program Yes DE B2.1.5 XI.M34 Buried Services Corrosion Monitoring Yes Saba Program B2.1.6 XI.M21 Closed Cycle Cooling Water Program X Kennedy B2.1.7 XI.S1 Containment Inservice Inspection Yes Woodfield XI.S2 Program X.S1 B2.1.8 XI.S4 Containment Leakage Testing Yes Woodfield Program B2.1.9 XI.M30 Diesel Fuel Monitoring and Storage X Kennedy Program B2.1.10 XI.M26 Fire Protection Program X Saba XI.M27 B2.1.11 XI.M17 Flow Accelerated Corrosion Program Yes Patterson B2.1.12 XI.E1 Non-EQ Electrical Commodities Yes Pal (XI.EI, XI.E2 Condition Monitoring Program XI.E2)

XI.E3 DE (XI.E3)

B2.1.13 XI.M29 One-Time Inspection Program X Patterson XI.M32 XI.M33 C-1

Palisades Nuclear Plant Audit and Review Plan Consistent GALL with GALL LRA Report Report AMP AMP Assigned Number Number AMP Title Yes No Reviewer B2.1.14 XI.M20 Open Cycle Cooling Water Program Yes Kennedy B2.1.15 XI.M23 Overhead Load Handling Systems X Woodfield Inspection Program B2.1.16 XI.M31 Reactor Vessel Integrity Surveillance Yes DE Program B2.1.17 XI.M16 Reactor Vessel Internals Inspection Yes Patterson Program B2.1.18 XI.M19 Steam Generator Tube Integrity Yes Saba Program B2.1.19 XI.S5 Structural Monitoring Program Yes Woodfield XI.S6 XI.S7 B2.1.20 XI.M29 System Monitoring Program PS DE B2.1.21 XI.M2 Water Chemistry Program Yes Saba B3.1* X.E1 Electrical Equipment Qualification Yes Pal Program B3.2 X.M1 Fatigue Monitoring Program Yes Patterson/Hsu DE = Division of Engineering PS = plant specific X = with exceptions

• Note: This LRA AMP is a Time-Limited Aging Analysis (TLAA) which has been assigned to the project team. Refer to Section 4 of some recent SERs for guidance on documenting the review of this AMP.

C-2

Palisades Nuclear Plant Audit and Review Plan Appendix D Aging Management Review Assignments

Palisades Nuclear Plant Audit and Review Plan Appendix D Aging Management Review Assignments Aging Management Reviews Reviewer 3.1 Aging Management of Reactor Coolant System Patterson 3.2 Aging Management of Engineered Safety Features Patterson 3.3 Aging Management of Auxiliary Systems Saba 3.4 Aging Management of Steam and Power Conversion System Kennedy 3.5 Aging Management of Containments, Structures, and Component Woodfield Supports 3.6 Aging Management of Electrical and Instrumentation and Controls Pal The specific AMRs to be reviewed by the project team are shown in the work-split tables which are available on ADAMS (ML051380078). The project team will review all the AMRs identified in the table except those that are highlighted on the work-split tables. The results of those evaluations will be reported in Section 3 of the PNP SER.

D-1

Palisades Nuclear Plant Audit and Review Plan Appendix E Consistent with GALL Report AMP Audit/Review Worksheets

Palisades Nuclear Plant Audit and Review Plan Table of Contents for Worksheets B2.1.1 Alloy 600 Program ......................................................................................... 1 B2.1.2 ASME Section XI IWB, IWC, IWD, IWF Inservice Inspection Program........... 7 B2.1.5 Buried Services Corrosion Monitoring Program ........................................... 25 B2.1.6 Closed Cycle Cooling Water Program.......................................................... 31 B2.1.7 Containment Inservice Inspection Program.................................................. 39 B2.1.8 Containment Leakage Testing Program....................................................... 58 B2.1.9 Diesel Fuel Monitoring and Storage Program .............................................. 64 B2.1.10 Fire Protection Program............................................................................... 71 B2.1.11 Flow Accelerated Corrosion Program .......................................................... 87 B2.1.12 Non-EQ Electrical Commodities Condition Monitoring Program................... 93 B2.1.13 One-Time Inspection Program................................................................... 103 B2.1.14 Open Cycle Cooling Water Program.......................................................... 121 B2.1.15 Overhead Load Handling Systems Inspection Program............................. 128 B2.1.17 Reactor Vessel Internals Inspection Program ............................................ 134 B2.1.18 Steam Generator Tube Integrity Program .................................................. 138 B2.1.19 Structural Monitoring Program ................................................................... 146 B2.1.21 Water Chemistry Program ......................................................................... 166 B3.1 Electrical Equipment Qualification Program ............................................... 174 B3.2 Fatigue Monitoring Program ...................................................................... 182 E-1

Palisades Nuclear Plant Audit and Review Plan Appendix E Consistent with GALL Report AMP Audit/Review Worksheets The worksheets provided in this appendix provide, as an aid for the reviewer, a process for documenting the basis for the assessment of the elements and sub-elements contained in the GALL Report AMPs (Chapter XI of NUREG-1801, Volume 2). The worksheets are organized into packages with a package for each AMP reviewed by the project team. Some packages have multiple worksheets. One worksheet is provided for each GALL Report AMP referenced by the LRA AMP. The worksheets provide a systematic method for recording the basis for assessments or to identify when the applicant needs to provide clarification or additional information. Information recorded in the worksheets will also be used to prepare the audit and review report and the safety evaluation report input.

E-2

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.1 Alloy 600 Program This AMP requires auditing against the following criteria:

XI.M11-A NICKEL-ALLOY PENETRATION NOZZLES WELDED TO THE UPPER REACTOR VESSEL CLOSURE HEADS OF PRESSURIZED WATER REACTORS (PWRS Only)

XI.M11 Nickel-Alloy Nozzles and Penetrations 1

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.1 Alloy 600 Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M11-A NICKEL-ALLOY PENETRATION NOZZLES WELDED TO THE UPPER REACTOR VESSEL CLOSURE HEADS OF PRESSURIZED WATER REACTORS (PWRS Only)

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A This program is established to ensure that augmented Consistent with GALL AMP: Yes No inservice inspections (ISI) of all nickel-alloy vessel head Document(s) used to confirm Criteria:

Program Description penetration (VHP) nozzles welded to the upper reactor vessel (RV) head of a PWR-designed light-water reactor will continue to be performed as mandated by the interim requirements in Order EA-03-009, Issuance of Order Establishing Interim Comment:

Inspection Requirements for Reactor Pressure Vessel Heads at Pressurized Water Reactors, as amended by the First Revision of the Order, or by any subsequent NRC requirements that may be established to supercede the requirements of Order EA-03-009.

XI.M11 Nickel-Alloy Nozzles and Penetrations 2

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B The Order, as amended, established a mandated augmented inspection process for upper VHP nozzles and upper RV heads that supplements the leakage tests and visual VT-2 examinations requirements established in Section XI of the ASME Boiler and Pressure Vessel Code, Table IWB-2500-1, Examination Category B-P. The interim requirements of the Order, as amended, also established the NRCs required technical method for calculating the susceptibility ranking of a plants upper VHP nozzles to PWSCC and a required process for establishing the inspection methods and inspection frequencies for a plants VHP nozzles in accordance with its susceptibility ranking.

1. Scope of Program A The program is focused on managing the effects of crack Consistent with GALL AMP: Yes No initiation and growth due to PWSCC of the nickel-alloy used in Document(s) used to confirm Criteria:

the fabrication of the upper VHP nozzles at PWR-designed nuclear facilities.

Comment B The scope of this AMP is limited to upper VHP nozzles, Consistent with GALL AMP: Yes No including control rod drive mechanism (CRDM) nozzles, Document(s) used to confirm Criteria:

control element drive mechanism (CEDM) nozzles, thermocouples (TC) nozzles, in-core instrumentation (ICI) nozzles, and vent line nozzles; associated J-groove welds; and adjoining upper RV closure heads.. Comment

2. Preventive Actions: A Preventive measures to mitigate PWSCC are in accordance Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

with PWR water chemistry guidelines for primary coolant systems, as established in EPRI Topical Report TR-105714 (applicants for license renewal may credit the version of the report on record at the facility at the time of submittal of its application). Comment:

XI.M11 Nickel-Alloy Nozzles and Penetrations 3

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

3. Parameters A The program monitors for cracking/PWSCC and loss of Consistent with GALL AMP: Yes No Monitored/Inspected: material/wastage in the upper VHP nozzles to ensure the Document(s) used to confirm Criteria:

structural integrity of the VHP nozzles prior to a loss of their intended safety function. The program also monitors for evidence of reactor coolant leakage as a result of through-wall cracks that may exist in the upper VHP nozzles or their Comment:

associated partial penetration J-groove welds. Evidence of reactor coolant leakage may manifest itself in the form of boric acid residues on the upper RV head or adjacent components or in the form of corrosion products that result from rusting of the low-alloy steel materials used to fabricate the RVs.

4. Detection of Aging A Implementation of inspections required by the Order, as Consistent with GALL AMP: Yes No Effects: amended, or any subsequent NRC requirements, as Document(s) used to confirm Criteria:

applicable, assures detection of cracks in the upper VHP nozzles and any loss of material/wastage of the upper RV head prior to a loss of intended function of the components.

Comment:

5. Monitoring and A As required by the Order, as amended, inspection Consistent with GALL AMP: Yes No Trending: schedules and frequencies for the applicant's VHP nozzles are Document(s) used to confirm Criteria:

implemented in accordance with required frequencies for the plant's susceptibility category (i.e., in accordance with the specific inspection frequencies required for "Low", "Moderate",

"High", or "Replaced" susceptibility categories, as based on Comment:

the "total effective degradation years" ). Any deviations from implementing the required inspection frequencies mandated by the Order, as amended, will be submitted for NRC review and approval in accordance with the Order, as amended.

Disposition of flaw indications detected during required examinations is implemented in accordance with the Acceptance Criteria and Corrective Actions program attributes of this AMP.

XI.M11 Nickel-Alloy Nozzles and Penetrations 4

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

6. Acceptance Criteria: A Relevant flaw indications detected as a result of the Consistent with GALL AMP: Yes No augmented inspections of the upper VHP nozzles are to be Document(s) used to confirm Criteria:

evaluated in accordance with acceptable flaw evaluation criteria provided in a letter from Mr. Richard Barrett, NRC, Office of Nuclear Reactor Regulation (NRR), Division of Engineering to Alex Marion, Nuclear Energy Institute (NEI), Comment:

dated April 11, 2003, or in accordance with NRC-approved Code Cases that incorporate the flaw evaluation procedures and criteria of the NRC=s April 11, 2003, letter to NEI.

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating Experience: A There is documentation of PWSCC occurring in the VHP Consistent with GALL AMP: Yes No nozzles of U.S. PWRs, as described in the program Document(s) used to confirm Criteria:

description above. In addition to these generic communications, applicants for license renewal should reference plant-specific operating experience that is applicable to PWSCC of its VHP nozzles. Comment:

XI.M11 Nickel-Alloy Nozzles and Penetrations 5

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M11 Nickel-Alloy Nozzles and Penetrations 6

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.2 ASME Section XI IWB, IWC, IWD, IWF Inservice Inspection Program This AMP requires auditing against the following three (3) GALL AMPs:

XI.M1 ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD XI.M3 Reactor Head Closure Studs XI.S3 ASME Section XI, Subsection IWF XI.M1 ASME Section XI Inservice Inspection, Subsections IWD, IWC, And IWD 7

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.2 ASME Section XI IWB, IWC, IWD, IWF Inservice REVIEWER: ______________________

Inspection Program DATE: __________________________

GALL AMP: XI.M1 ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The Code of Federal Regulations, 10 CFR 50.55a, imposes Consistent with GALL AMP: Yes No the inservice inspection (ISI) requirements of the American Document(s) used to confirm Criteria:

Program Description Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, for Class 1, 2, and 3 pressure-retaining components and their integral attachments in light-water cooled power plants. Inspection, repair, and Comment:

replacement of these components are covered in Subsections IWB, IWC, and IWD, respectively, in the 1995 edition through the 1996 addenda. The program generally includes periodic visual, surface, and/or volumetric examination and leakage test of all Class 1, 2, and 3 pressure-retaining components and their integral attachments. The ASME Section XI inservice inspection program in accordance with Subsections IWB, IWC, or IWD has been shown to be generally effective in managing aging effects in Class 1, 2, or 3 components and their integral attachments in light-water cooled power plants. However, in certain cases, the ASME inservice inspection program is to be augmented to manage effects of aging for license renewal and is so identified in the GALL Report.

XI.M1 ASME Section XI Inservice Inspection, Subsections IWD, IWC, And IWD 8

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

1. Scope of Program A The ASME Section XI program provides the requirements Consistent with GALL AMP: Yes No for ISI, repair, and replacement. The components within the Document(s) used to confirm Criteria:

scope of the program are specified in Subsections IWB-1100, IWC-1100, and IWD-1100 for Class 1, 2, and 3 components, respectively, and include all pressure-retaining components and their integral attachments in light-water cooled power Comment plants.

B The components described in Subsections IWB-1220, IWC- Consistent with GALL AMP: Yes No 1220, and IWD-1220 are exempt from the examination Document(s) used to confirm Criteria:

requirements of Subsections IWB-2500, IWC-2500, and IWD-2500.

Comment

2. Preventive Actions: A The ASME Section XI does not provide guidance on Consistent with GALL AMP: Yes No methods to mitigate degradation. Document(s) used to confirm Criteria:

Comment:

3. Parameters A The ASME Section XI ISI program detects degradation of Consistent with GALL AMP: Yes No Monitored/Inspected: components by using the examination and inspection Document(s) used to confirm Criteria:

requirements specified in ASME Section XI Tables IWB-2500-1, IWC-2500-1, or IWD-2500-1, respectively, for Class 1, 2, or 3 components.

Comment:

XI.M1 ASME Section XI Inservice Inspection, Subsections IWD, IWC, And IWD 9

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

4. Detection of Aging A The extent and schedule of the inspection and test Consistent with GALL AMP: Yes No Effects: techniques prescribed by the program are designed to Document(s) used to confirm Criteria:

maintain structural integrity and ensure that aging effects will be discovered and repaired before the loss of intended function of the component.

Comment:

B Components are examined and tested as specified in Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

Tables IWB-2500-1, IWC-2500-1, and IWD-2500-1, respectively, for Class 1, 2, and 3 components. The tables specify the extent and schedule of the inspection and examination methods for the components of the pressure-retaining boundaries. Alternative approved methods that meet Comment:

the requirements of IWA-2240 are also specified in these tables.

C The program uses three types of examination visual, Consistent with GALL AMP: Yes No surface, and volumetric in accordance with the general Document(s) used to confirm Criteria:

requirements of Subsection IWA-2000.

Comment:

D For BWRs, the nondestructive examination (NDE) Consistent with GALL AMP: Yes No techniques appropriate for inspection of vessel internals and Document(s) used to confirm Criteria:

their implementation needs, including the uncertainties inherent in delivering and executing and NDE technique in a boiling water reactor (BWR), are included in the approved boiling water reactor vessel and internals project Comment:

(BWRVIP)-03. Also, an applicant may use the guidelines of the approved BWRVIP-62 for inspection relief for vessel internal components with hydrogen water chemistry.

XI.M1 ASME Section XI Inservice Inspection, Subsections IWD, IWC, And IWD 10

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

5. Monitoring and A For Class 1, 2, or 3 components, the inspection schedule of Consistent with GALL AMP: Yes No Trending: IWB-2400, IWC-2400, or IWD-2400, respectively, and the Document(s) used to confirm Criteria:

extent and frequency of IWB-2500-1, IWC-2500-1, or IWD-2500-1, respectively, provides for timely detection of degradation.

Comment:

B If flaw indications or relevant conditions of degradation are Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

evaluated in accordance with IWB-3100 or IWC-3100, and the component is qualified as acceptable for continued service, the areas containing such flaw indications and relevant conditions are reexamined during the next three inspection periods of IWB-2410 for Class 1 components and for the next inspection Comment:

period of IWC-2410 for Class 2 components.

C Examinations that reveal indications that exceed the Consistent with GALL AMP: Yes No acceptance standards described below are extended to Document(s) used to confirm Criteria:

include additional examinations in accordance with IWB-2430, IWC-2430, or IWD-2430 (1995 edition) for Class 1, 2, or, 3 Components, respectively.

Comment

6. Acceptance Criteria: A Any indication or relevant conditions of degradation Consistent with GALL AMP: Yes No detected are evaluated in accordance with IWB-3000, IWC- Document(s) used to confirm Criteria:

3000, or IWD-3000, for Class 1, 2, or 3 components, respectively.

Comment:

B Examination results are evaluated in accordance with IWB- Consistent with GALL AMP: Yes No 3100 or IWC-3100 by comparing the results with the Document(s) used to confirm Criteria:

acceptance standards of IWB-3400 and IWB-3500 or IWC-3400 and IWC-3500, respectively, for Class 1 or Class 2 and 3 components.

Comment:

XI.M1 ASME Section XI Inservice Inspection, Subsections IWD, IWC, And IWD 11

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C Flaws that exceed the size of allowable flaws, as defined in Consistent with GALL AMP: Yes No IWB-3500 or IWC-3500, are evaluated by using the analytical Document(s) used to confirm Criteria:

procedures of IWB-3600 or IWC-3600, respectively, for Class 1 or Class 2 and 3 components.

Comment:

D Approved BWRVIP-14, BWRVIP-59, and BWRVIP-60 documents provide guidelines for evaluation of crack growth steels, nickel alloys, and low-alloy steels, respectively.

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A Because the ASME Code is a consensus document that Consistent with GALL AMP: Yes No Experience: has been widely used over a long period, it has been shown to Document(s) used to confirm Criteria:

be generally effective in managing aging effects in Class 1, 2, and 3 components and their integral attachments in light-water cooled power plants (see Chapter I of the GALL Report, Vol.

2). Comment:

XI.M1 ASME Section XI Inservice Inspection, Subsections IWD, IWC, And IWD 12

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M1 ASME Section XI Inservice Inspection, Subsections IWD, IWC, And IWD 13

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)_______________

LRA AMP: B2.1.2 ASME Section XI IWB, IWC, IWD, IWF Inservice REVIEWER: ______________________

Inspection Program DATE: __________________________

GALL AMP: XI.M3 Reactor Head Closure Studs PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A This program includes inservice inspection (ISI) in Consistent with GALL AMP: Yes No conformance with the requirements of the American Society of Document(s) used to confirm Criteria:

Program Description Mechanical Engineers (ASME), Code,Section XI, Subsection IWB (1995 edition through the 1996 addenda),

Table IWB 2500-1.

Comment:

B The program includes preventive measures to mitigate Consistent with GALL AMP: Yes No cracking. Document(s) used to confirm Criteria:

Comment:

1. Scope of Program A ISI to detect crack initiation and growth due to stress Consistent with GALL AMP: Yes No corrosion cracking (SCC) or intergranular stress corrosion Document(s) used to confirm Criteria:

cracking (IGSCC); loss of material due to wear; and coolant leakage from reactor vessel closure stud bolting for both boiling water reactors (BWRs) and pressurized water reactors (PWRs). Comment:

XI.M3 Reactor Head Closure Studs 14

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B preventive measures of NRC Regulatory Guide 1.65 to Consistent with GALL AMP: Yes No mitigate cracking. Document(s) used to confirm Criteria:

Comment:

C The program is applicable to closure studs and nuts Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

constructed from materials with a maximum tensile strength limited to less than 1,172 MPa (170 ksi) (Nuclear Regulatory Commission [NRC] Regulatory Guide [RG] 1.65).

Comment:

2. Preventive Actions: A preventive measures include avoiding the use of metal- Consistent with GALL AMP: Yes No plated stud bolting to prevent degradation due to corrosion or Document(s) used to confirm Criteria:

hydrogen embrittlement.

Comment:

B to use manganese phosphate or other acceptable surface Consistent with GALL AMP: Yes No treatments and stable lubricants (RG 1.65). Document(s) used to confirm Criteria:

Comment:

XI.M3 Reactor Head Closure Studs 15

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

3. Parameters A The ASME Section XI ISI program detects and sizes Consistent with GALL AMP: Yes No Monitored/Inspected: cracks, detects loss of material, and detects coolant leakage Document(s) used to confirm Criteria:

by following the examination and inspection requirements specified in Table IWB-2500-1.

Comment:

4. Detection of Aging A The extent and schedule of the inspection and test Consistent with GALL AMP: Yes No Effects: Document(s) used to confirm Criteria:

techniques prescribed by the program are designed to maintain structural integrity and ensure that aging effects will be discovered and repaired before the loss of intended function of the component. Inspection can reveal crack initiation and growth, loss of material due to corrosion or wear, Comment:

and leakage of coolant.

B The program uses visual, surface, and volumetric Consistent with GALL AMP: Yes No examinations in accordance with the general requirements of Document(s) used to confirm Criteria:

Subsection IWA-2000.

Comment:

C Components are examined and tested as specified in Table Consistent with GALL AMP: Yes No IWB-2500-1. Document(s) used to confirm Criteria:

Comment:

XI.M3 Reactor Head Closure Studs 16

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING D Examination category B-G-1, for pressure-retaining bolting Consistent with GALL AMP: Yes No greater than 2 in. in diameter in reactor vessels specifies Document(s) used to confirm Criteria:

volumetric examination of studs in place, from the top of the nut to the bottom of the flange hole, and surface and volumetric examination of studs when removed.

Comment:

E Also specified are volumetric examination of flange threads Consistent with GALL AMP: Yes No and visual VT-1 examination of surfaces of nuts, washers, and Document(s) used to confirm Criteria:

bushings.

Comment:

F Examination category B-P for all pressure-retaining Consistent with GALL AMP: Yes No components, specifies visual VT-2 examination of all pressure- Document(s) used to confirm Criteria:

retaining boundary components during the system leakage test and the system hydrostatic test.

Comment:

5. Monitoring and A The Inspection schedule of IWB-2400, and the extent and Consistent with GALL AMP: Yes No Trending: Document(s) used to confirm Criteria:

frequency of IWB-2500-1 provide timely detection of cracks, loss of material, and leakage.

Comment:

XI.M3 Reactor Head Closure Studs 17

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

6. Acceptance Criteria: A Any indication or relevant condition of degradation in Consistent with GALL AMP: Yes No closure stud bolting is evaluated in accordance with IWB-3100 Document(s) used to confirm Criteria:

by comparing ISI results with the acceptance standards of IWB-3400 and IWB-3500.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A The SCC has occurred in BWR pressure vessel head studs Consistent with GALL AMP: Yes No Experience: (Stoller 1991). The aging management program (AMP) has Document(s) used to confirm Criteria:

provisions regarding inspection techniques and evaluation, material specifications, corrosion prevention, and other aspects of reactor pressure vessel head stud cracking.

Implementation of the program provides reasonable assurance Comment:

that the effects of cracking due to SCC or IGSCC and loss of material due to wear will be adequately managed so that the intended functions of the reactor head closure studs and bolts will be maintained consistent with the current licensing basis.

XI.M3 Reactor Head Closure Studs 18

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M3 Reactor Head Closure Studs 19

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.2 ASME Section XI IWB, IWC, IWD, IWF Inservice REVIEWER: ______________________

Inspection Program DATE: __________________________

GALL AMP: XI.S3 ASME Section XI, Subsection IWF PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The10 CFR 50.55a imposes the inservice inspection (ISI) Consistent with GALL AMP: Yes No requirements of the American Society of Mechanical Document(s) used to confirm Criteria:

Program Description Engineers (ASME) Boiler and Pressure Vessel Code,Section XI, for Class 1, 2, 3, and MC piping and components and their associated supports. Inservice inspection of supports for ASME piping and components is addressed in Section XI, Comment:

Subsection IWF. This evaluation covers the 1989 Edition through the 1995 Edition and addenda through the 1996 Addenda, as approved in 10 CFR 50.55a. ASME Code Section XI, Subsection IWF constitutes an existing mandated program applicable to managing aging of ASME Class 1, 2, 3, and MC supports for license renewal.

XI.S3 ASME Section XI, Subsection IWF 20

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B The IWF scope of inspection for supports is based on Consistent with GALL AMP: Yes No sampling of the total support population. Document(s) used to confirm Criteria:

• The sample size varies depending on the ASME Class.

The largest sample size is specified for the most critical supports (ASME Class 1).

• The sample size decreases for the less critical supports Comment:

(ASME Class 2 and 3).

• Discovery of support deficiencies during regularly scheduled inspections triggers an increase of the inspection scope, in order to ensure that the full extent of deficiencies is identified.

• The primary inspection method employed is visual examination.

• Degradation that potentially compromises support function or load capacity is identified for evaluation.

• IWF specifies acceptance criteria and corrective actions.

• Supports requiring corrective actions are re-examined during the next inspection period.

1. Scope of Program A For Class 1 piping and component supports, Subsection Consistent with GALL AMP: Yes No IWF (1989 edition) refers to Subsection IWB for the inspection Document(s) used to confirm Criteria:

scope and schedule.

• According to Table IWB-2500-1, only 25% of nonexempt supports are subject to examination. Supports exempt from examination are the supports for piping systems that Comment:

are exempt from examination, according to pipe diameter or service.

• The same supports are inspected in each 10-year inspection interval.

B For Class 2, 3, and MC piping and component supports, Consistent with GALL AMP: Yes No Subsection IWF (1989 edition) refers to Subsections IWC, Document(s) used to confirm Criteria:

IWD, and IWE for the inspection scope and schedule.

• According to Table IWC-2500-1, 7.5% of nonexempt supports are subject to examination for Class 2 systems.

• The same supports are inspected in each 10-year Comment:

inspection interval.

XI.S3 ASME Section XI, Subsection IWF 21

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C No specific numerical percentages are identified in Consistent with GALL AMP: Yes No Subsections IWD and IWE for Class 3 and Class MC, Document(s) used to confirm Criteria:

respectively.

Comment:

2. Preventive Actions: A No preventive actions are specified; Subsection IWF is a Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

inspection program.

Comment:

3. Parameters A IWF specifies visual examination (VT-3) of supports. Consistent with GALL AMP: Yes No Monitored/Inspected: Document(s) used to confirm Criteria:

• The parameters monitored or inspected include corrosion; deformation; misalignment; improper clearances; improper spring settings; damage to close tolerance machined or sliding surfaces; and missing, detached, or loosened support items. Comment:

• The visual inspection would be expected to identify relatively large cracks.

4. Detection of Aging A VT-3 visual examination is specified in Table IWF-2500-1. Consistent with GALL AMP: Yes No Effects: Document(s) used to confirm Criteria:

• The complete inspection scope is repeated every 10-year inspection interval.

• The qualified VT-3 inspector uses judgment in assessing general corrosion; observed degradation is documented if loss of structural capacity is suspected. Comment:

XI.S3 ASME Section XI, Subsection IWF 22

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

5. Monitoring and A There is no requirement to monitor or report progressive, Consistent with GALL AMP: Yes No Trending: time-dependent degradation. Unacceptable conditions, Document(s) used to confirm Criteria:

according to IWF-3400, are noted for correction or further evaluation.

Comment:

6. Acceptance Criteria: A The acceptance standards for visual examination are Consistent with GALL AMP: Yes No specified in IWF-3400. Document(s) used to confirm Criteria:

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A To date, IWF sampling inspections have been effective in Consistent with GALL AMP: Yes No Experience: Document(s) used to confirm Criteria:

managing aging effects for ASME Class 1, 2, 3, and MC supports. There is reasonable assurance that the Subsection IWF inspection program will be effective through the period of extended operation.

Comment:

XI.S3 ASME Section XI, Subsection IWF 23

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.S3 ASME Section XI, Subsection IWF 24

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.5 Buried Services Corrosion Monitoring Program This AMP requires auditing against the following GALL AMP:

XI.M34 Buried Piping and Tanks Inspection XI.M34 Buried Piping And Tanks Inspection 25

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.5 Buried Services Corrosion Monitoring Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M34 Buried Piping and Tanks Inspection PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The program includes preventive measures to mitigate Consistent with GALL AMP: Yes No corrosion. Document(s) used to confirm Criteria:

Program Description Comment:

B periodic inspection to manage the effects of corrosion on Consistent with GALL AMP: Yes No the pressure-retaining capacity of buried carbon steel piping Document(s) used to confirm Criteria:

and tanks.

Comment:

C Preventive measures are in accordance with standard Consistent with GALL AMP: Yes No industry practice for maintaining external coatings and Document(s) used to confirm Criteria:

wrappings.

Comment:

XI.M34 Buried Piping And Tanks Inspection 26

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING D Buried piping and tanks are inspected when they are Consistent with GALL AMP: Yes No excavated during maintenance and when a pipe is dug up and Document(s) used to confirm Criteria:

inspected for any reason.

Comment:

E this is an acceptable option to manage buried components, Consistent with GALL AMP: Yes No except for the program element/attributes of detection of aging Document(s) used to confirm Criteria:

effects (regarding inspection frequency) and operating experience. Thus, the staff further evaluates an applicants inspection frequency and operating experience with buried components. Comment:

1. Scope of Program A The program relies on preventive measures such as Consistent with GALL AMP: Yes No coating and wrapping and periodic inspection for loss of Document(s) used to confirm Criteria:

material caused by corrosion of the external surface of buried carbon steel piping and tanks . Loss of material in these components, which may be exposed to aggressive soil environment, is caused by general, pitting, and crevice Comment corrosion, and microbiologically influenced corrosion (MIC).

B Periodic inspections are performed when the components Consistent with GALL AMP: Yes No are excavated for maintenance or for any other reason. Document(s) used to confirm Criteria:

Comment

2. Preventive Actions: A In accordance with industry practice, underground piping Consistent with GALL AMP: Yes No and tanks are coated during installation with a protective Document(s) used to confirm Criteria:

coating system to protect the piping from contacting the aggressive soil environment.

Comment:

XI.M34 Buried Piping And Tanks Inspection 27

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

3. Parameters A The program monitors parameters such as coating and Consistent with GALL AMP: Yes No Monitored/Inspected: wrapping integrity that are directly related to corrosion damage Document(s) used to confirm Criteria:

of the external surface of buried carbon steel piping and tanks.

Coatings and wrappings are inspected by visual techniques.

Comment:

B Any evidence of damaged wrapping or coating defects is an indicator of possible corrosion damage to the external surface of piping and tanks.

4. Detection of Aging A Periodic inspection of susceptible locations to confirm that Consistent with GALL AMP: Yes No Effects: coating and wrapping are intact. Document(s) used to confirm Criteria:

Comment:

B The inspections are performed in areas with the highest Consistent with GALL AMP: Yes No likelihood of corrosion problems, and in areas with a history of Document(s) used to confirm Criteria:

corrosion problems.

Comment:

XI.M34 Buried Piping And Tanks Inspection 28

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C Because the inspection frequency is plant specific Consistent with GALL AMP: Yes No and also depends on the plant operating experience, the Document(s) used to confirm Criteria:

applicants proposed inspection frequency is to be further evaluated for the extended period of operation.

Comment:

5. Monitoring and A Results of previous inspections are used to identify Consistent with GALL AMP: Yes No Trending: Document(s) used to confirm Criteria:

susceptible locations.

Comment:

6. Acceptance Criteria: A Any coating and wrapping degradations are reported and Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

evaluated according to site corrective actions procedures.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A Operating experience shows that the program described Consistent with GALL AMP: Yes No Experience: Document(s) used to confirm Criteria:

here is effective in managing corrosion of external surfaces of buried carbon steel components. However, because the inspection frequency is plant specific and also depends on the plant operating experience, the applicants plant-specific operating experience is further evaluated for the extended Comment:

period of operation.

XI.M34 Buried Piping And Tanks Inspection 29

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M34 Buried Piping And Tanks Inspection 30

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.6 Closed Cycle Cooling Water Program This AMP requires auditing against the following GALL AMP:

XI.M21 Closed-Cycle Cooling Water System XI.M21 Closed-Cycle Cooling Water System 31

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.6 Closed Cycle Cooling Water Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M21 Closed-Cycle Cooling Water System PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The program includes (a) preventive measures to minimize Consistent with GALL AMP: Yes No corrosion and (b) surveillance testing and inspection to monitor Document(s) used to confirm Criteria:

Program Description the effects of corrosion on the intended function of the component.

Comment:

B The program relies on maintenance of system corrosion Consistent with GALL AMP: Yes No inhibitor concentrations within specified limits of Electric Power Document(s) used to confirm Criteria:

Research Institute [EPRI] TR-107396 to minimize corrosion.

Comment:

C Surveillance testing and inspection in accordance with Consistent with GALL AMP: Yes No standards in EPRI TR-107396 for closed-cycle cooling water Document(s) used to confirm Criteria:

(CCCW) systems is performed to evaluate system and component performance.

Comment:

XI.M21 Closed-Cycle Cooling Water System 32

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

1. Scope of Program A A CCCW system is defined as part of the service water Consistent with GALL AMP: Yes No system that is not subject to significant sources of Document(s) used to confirm Criteria:

contamination, in which water chemistry is controlled and in which heat is not directly rejected to a heat sink. The program described in this section applies only to such a system. If one or more of these conditions are not satisfied, the system is to Comment:

be considered an open-cycle cooling water system. The staff notes that If the adequacy of cooling water chemistry control can not be confirmed, the system is treated as an open-cycle system as indicated in Action III of Generic Letter (GL) 89-13.

2. Preventive Actions: A The program relies on the maintenance of system corrosion Consistent with GALL AMP: Yes No inhibitor concentrations within specified limits of EPRI TR- Document(s) used to confirm Criteria:

107396.

Comment:

B The program includes monitoring and control of cooling Consistent with GALL AMP: Yes No water chemistry to minimize exposure to aggressive Document(s) used to confirm Criteria:

environments.

Comment:

C application of corrosion inhibitor in the CCCW system to Consistent with GALL AMP: Yes No mitigate general, crevice, and pitting corrosion. Document(s) used to confirm Criteria:

Comment:

XI.M21 Closed-Cycle Cooling Water System 33

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

3. Parameters A surveillance testing and inspection in accordance with Consistent with GALL AMP: Yes No Monitored/Inspected: standards in EPRI TR-107396 to evaluate system and Document(s) used to confirm Criteria:

component performance.

Comment:

B For pumps, the parameters monitored include flow and Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

discharge and suction pressures.

Comment:

C For heat exchangers, the parameters monitored include Consistent with GALL AMP: Yes No flow, inlet and outlet temperatures, and differential pressure. Document(s) used to confirm Criteria:

Comment:

4. Detection of Aging A The extent and schedule of inspections and testing in Consistent with GALL AMP: Yes No Effects: accordance with EPRI TR-107396. Document(s) used to confirm Criteria:

Comment:

XI.M21 Closed-Cycle Cooling Water System 34

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B Performance and functional testing in accordance with Consistent with GALL AMP: Yes No EPRI TR-107396. Document(s) used to confirm Criteria:

Comment:

C For systems and components in continuous operation, Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

performance adequacy is determined by monitoring data trends for evaluation of heat transfer fouling, pump wear characteristics, and branch flow changes.

Comment:

D Components not in operation are periodically tested to Consistent with GALL AMP: Yes No ensure operability. Document(s) used to confirm Criteria:

Comment:

5. Monitoring and A Frequency of sampling water chemistry varies and can Consistent with GALL AMP: Yes No Trending: occur on a continuous, daily, weekly, or as needed basic, as Document(s) used to confirm Criteria:

indicated by plant operating conditions.

Comment:

XI.M21 Closed-Cycle Cooling Water System 35

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B Per EPRI TR-107396, performance and functional tests are Consistent with GALL AMP: Yes No performed at least every 18 months to demonstrate system Document(s) used to confirm Criteria:

operability.

Comment:

C tests to evaluate heat removal capability of the system and Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

degradation of system components are performed every five years . The testing intervals may be adjusted on the basis of the results of the reliability analysis, type of service, frequency of operation, or age of components and systems.

Comment:

D The testing intervals may be adjusted on the basis of Consistent with GALL AMP: Yes No the results of the reliability analysis, type of service, frequency Document(s) used to confirm Criteria:

of operation, or age of components and systems.

Comment:

6. Acceptance Criteria: A Corrosion inhibitor concentrations are maintained within Consistent with GALL AMP: Yes No the limits specified in the EPRI water chemistry guidelines for Document(s) used to confirm Criteria:

CCCW.

Comment:

XI.M21 Closed-Cycle Cooling Water System 36

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B System and component performance test results are Consistent with GALL AMP: Yes No evaluated in accordance with the guidelines of EPRI TR- Document(s) used to confirm Criteria:

107396.

Comment:

C Acceptance criteria and tolerances are also based on Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

system design parameters and functions.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A Degradation of closed-cycle cooling water systems due to Consistent with GALL AMP: Yes No Experience: Document(s) used to confirm Criteria:

corrosion product buildup (NRC Licensee Event Report [LER]

93-029-00) or through-wall cracks in supply lines (NRC LER 91-019-00) has been observed in operating plants.

Accordingly, operating experience demonstrates the need for this program. Comment:

XI.M21 Closed-Cycle Cooling Water System 37

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M21 Closed-Cycle Cooling Water System 38

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.7 Containment Inservice Inspection Program This AMP requires auditing against the following three (3) GALL AMPs:

X.S1 Concrete Containment Tendon Prestress XI.S1 ASME Section XI, Subsection IWE XI.S2 ASME Section XI, Subsection IWL X.S1 Concrete Containment Tendon Prestress 39

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.7 Containment Inservice Inspection Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: X.S1 Concrete Containment Tendon Prestress PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A In order to ensure the adequacy of prestressing forces in Consistent with GALL AMP: Yes No prestressed concrete containments during the extended period Document(s) used to confirm Criteria:

Program Description of operation, an applicant shall develop an aging management program (AMP) under 10 CFR 54.21(c)(1)(iii).

Comment:

X.S1 Concrete Containment Tendon Prestress 40

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B The AMP consists of an assessment of the results of inspections performed in accordance with the requirements of Subsection IWL of the ASME Section XI Code, as supplemented by the requirements of 10 CFR 50.55a(b)(2)(ix) or (viii) in the later amendment of the regulation. The assessment related to the adequacy of the prestressing force will consist of the establishment of (1) acceptance criteria and (2) trend lines. The acceptance criteria will normally consist of predicted lower limit (PLL) and the minimum required prestressing force, also called minimum required value (MRV).

NRC Regulatory Guide 1.35.1 provides guidance for calculating PLL and MRV. The trend line represents the trend of prestressing forces based on the actual measured forces.

NRC Information Notice IN 99-10 provides guidance for constructing the trend line. The goal is to keep the trend line above the PLL because, as a result of any inspection performed in accordance with ASME Section XI, Subsection IWL, if the trend line crosses the PLL, the existing prestress in the containment could go below the MRV soon after the inspection and would not meet the requirements of 10 CFR 50.55a(b)(2)(ix)(B) or 10 CFR 50.55a(b)(2)(viii)(B).

C As evaluated below, this is an acceptable option to manage containment tendon prestress force, except for the program element/attribute regarding operating experience. Thus, it is recommended that the staff should further evaluate an applicant's operating experience related to the containment prestress force.

D The AMP related to the adequacy of prestressing force for containments with grouted tendons will be reviewed on a case-by-case basis.

X.S1 Concrete Containment Tendon Prestress 41

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

1. Scope of Program The program addresses the assessment of containment Consistent with GALL AMP: Yes No prestressing force when an applicant chooses to perform the Document(s) used to confirm Criteria:

containment prestress force TLAA using 10 CFR 54.21(c)(1)(iii).

Comment:

2. Preventive Actions: Maintaining the prestress above the MRV, as described under Consistent with GALL AMP: Yes No program description above, will ensure that the structural and Document(s) used to confirm Criteria:

functional adequacy of the containment are maintained.

Comment:

3. Parameters The parameters to be monitored are the containment Consistent with GALL AMP: Yes No Monitored/Inspected: prestressing forces in accordance with requirements specified Document(s) used to confirm Criteria:

in Subsection IWL of Section XI of the ASME Code, as incorporated by reference in 10 CFR 50.55a.

Comment:

4. Detection of Aging The loss of containment prestressing forces is detected by the Consistent with GALL AMP: Yes No Effects: program. Document(s) used to confirm Criteria:

Comment:

X.S1 Concrete Containment Tendon Prestress 42

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

5. Monitoring and The estimated and measured prestressing forces are plotted Consistent with GALL AMP: Yes No Trending: against time and the PLL, MRV, and trending lines developed Document(s) used to confirm Criteria:

for the period of extended operation.

Comment:

6. Acceptance Criteria: The prestressing force trend lines indicate that existing Consistent with GALL AMP: Yes No prestressing forces in the containment would not be below the Document(s) used to confirm Criteria:

MRVs prior to the next scheduled inspection, as required by 10 CFR 50.55a(b)(2)(ix)(B) or 10 CFR 50.55a(b)(2)(viii)(B).

Comment:

7. Corrective Actions: If acceptance criteria are not met, then either systematic N/A retensioning of tendons or a reanalysis of the containment is warranted to ensure the design adequacy of the containment.

As discussed in the appendix to this report, the staff finds the requirements of 10 CFR Part 50, Appendix B, acceptable to address corrective actions.

8. Confirmation Process: As discussed in the appendix to this report, the staff finds the N/A requirements of 10 CFR Part 50, Appendix B, acceptable to address the confirmation process.

9. Administrative As discussed in the appendix to this report, the staff finds the N/A Controls: requirements of 10 CFR Part 50, Appendix B, acceptable to address administrative controls.

10. Operating The program incorporates the relevant operating experience Consistent with GALL AMP: Yes No Experience: that has occurred at the applicant's plant as well as at other Document(s) used to confirm Criteria:

plants. The applicable portions of the experience with prestressing systems described in NRC Information Notice 99-10 could be useful for the purpose. However, tendon operating experience could be different at plants with prestressed concrete containments. The difference could be due to the Comment:

prestressing system design (e.g., button-headed, wedge, or swaged anchorages), environment, and type of reactor (i.e.,

PWR and BWR). Thus, the applicant's plant-specific operating experience should be further evaluated for license renewal.

X.S1 Concrete Containment Tendon Prestress 43

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

X.S1 Concrete Containment Tendon Prestress 44

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.7 Containment Inservice Inspection Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.S1 ASME Section XI, Subsection IWE PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The evaluation of 10 CFR 50.55a and Subsection IWE as Consistent with GALL AMP: Yes No an aging management program (AMP) for license renewal is Document(s) used to confirm Criteria:

Program Description provided below.

10 CFR 50.55a imposes the inservice inspection (ISI) requirements of the American Society of Mechanical Comment:

Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, Subsection IWE for steel containments (Class MC) and steel liners for concrete containments (Class CC). The full scope of IWE includes steel containment shells and their integral attachments; steel liners for concrete containments and their integral attachments; containment hatches and airlocks; seals, gaskets and moisture barriers; and pressure-retaining bolting. This evaluation covers both the 1992 Edition with the 1992 Addenda and the 1995 Edition with the 1996 Addenda, as approved in 10 CFR 50.55a. ASME Code Section XI, Subsection IWE and the additional requirements specified in 10 CFR 50.55a(b)(2) constitute an existing mandated program applicable to managing aging of steel containments, steel liners of concrete containments, and other containment components for license renewal.

XI.S1 ASME Section XI, Subsection IWE 45

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

1. Scope of Program A Subsection IWE-1000 specifies the components of steel Consistent with GALL AMP: Yes No containments and steel liners of concrete containments within Document(s) used to confirm Criteria:

its scope.

• The components within the scope of Subsection IWE are Class MC pressure-retaining components (steel containments) and their integral attachments; metallic shell Comment:

and penetration liners of Class CC containments and their integral attachments; containment seals and gaskets; containment pressure-retaining bolting; and metal containment surface areas, including welds and base metal.

B Subsection IWE exempts the following from examination: Consistent with GALL AMP: Yes No (1) Components that are outside the boundaries of the Document(s) used to confirm Criteria:

containment as defined in the plant-specific design specification; (2) Embedded or inaccessible portions of containment components that met the requirements of the original Comment:

construction code of record; (3) Components that become embedded or inaccessible as a result of vessel repair or replacement, provided IWE-1232 and IWE-5220 are met; and (4) Piping, pumps, and valves that are part of the containment system or that penetrate or are attached to the containment vessel (governed by IWB or IWC).

C The 10 CFR 50.55a(b)(2)(ix) specifies additional Consistent with GALL AMP: Yes No requirements for inaccessible areas. It states that the licensee Document(s) used to confirm Criteria:

is to evaluate the acceptability of inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas. Comment:

• Examination requirements for containment supports are not within the scope of Subsection IWE.

XI.S1 ASME Section XI, Subsection IWE 46

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

2. Preventive Actions: A No preventive actions are specified; Subsection IWE is a Consistent with GALL AMP: Yes No monitoring program. Document(s) used to confirm Criteria:

Comment:

3. Parameters A Table IWE-2500-1 specifies seven categories for Consistent with GALL AMP: Yes No Monitored/Inspected: Document(s) used to confirm Criteria:

examination. Table IWE-2500-1 references the applicable section in IWE-3500 that identifies the aging effects that are evaluated. The parameters monitored or inspected depend on the particular examination category.

Comment:

4. Detection of Aging A The frequency and scope of examination specified in Consistent with GALL AMP: Yes No Effects: 10 CFR 50.55a and Subsection IWE ensure that aging effects Document(s) used to confirm Criteria:

would be detected before they would compromise the design-basis requirements.

Comment:

5. Monitoring and A With the exception of inaccessible areas, all surfaces are Consistent with GALL AMP: Yes No Trending: monitored by virtue of the examination requirements on a Document(s) used to confirm Criteria:

scheduled basis.

Comment:

XI.S1 ASME Section XI, Subsection IWE 47

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B When component examination results require evaluation of Consistent with GALL AMP: Yes No flaws, evaluation of areas of degradation, or repairs, and the Document(s) used to confirm Criteria:

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. Comment:

• 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.

C IWE-2430 specifies that (a) examinations performed during Consistent with GALL AMP: Yes No any one inspection that reveal flaws or areas of degradation Document(s) used to confirm Criteria:

exceeding the acceptance standards are to be extended to include an additional number of examinations within the same category approximately equal to the initial number of examinations, and (b) when additional flaws or areas of Comment:

degradation that exceed the acceptance standards are revealed, all of the remaining examinations within the same category are to be performed to the extent specified in Table IWE-2500-1 for the inspection interval.

D Alternatives to these examinations are provided in Consistent with GALL AMP: Yes No 10 CFR 50.55a(b)(2)(ix)(D). Document(s) used to confirm Criteria:

Comment:

6. Acceptance Criteria: A IWE-3000 provides acceptance standards for components Consistent with GALL AMP: Yes No of steel containments and liners of concrete containments. Document(s) used to confirm Criteria:

Comment:

XI.S1 ASME Section XI, Subsection IWE 48

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B Table IWE-3410-1 presents criteria to evaluate the Consistent with GALL AMP: Yes No acceptability of the containment components for service Document(s) used to confirm Criteria:

following the preservice examination and each inservice examination. This table specifies the acceptance standard for each examination category.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A ASME Section XI, Subsection IWE was incorporated into Consistent with GALL AMP: Yes No Experience: 10 CFR 50.55a in 1996. Prior to this time, operating Document(s) used to confirm Criteria:

experience pertaining to degradation of steel components of containment was gained through the inspections required by 10 CFR Part 50, Appendix J and ad hoc inspections conducted by licensees and the Nuclear Regulatory Commission (NRC). Comment:

NRC Information Notice (INs) 86-99, 88-82 and 89-79 described occurrences of corrosion in steel containment shells. NRC Generic Letter (GL) 87-05 addressed the potential for corrosion of boiling water reactor (BWR) Mark I steel drywells in the sand pocket region. More recently, NRC IN 97-10 identified specific locations where concrete containments are susceptible to liner plate corrosion. The program is to consider the liner plate and containment shell corrosion concerns described in these generic communications. Implementation of the ISI requirements of Subsection IWE, in accordance with 10 CFR 50.55a, is a necessary element of aging management for steel components of steel and concrete containments through the period of extended operation.

XI.S1 ASME Section XI, Subsection IWE 49

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.S1 ASME Section XI, Subsection IWE 50

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.7 Containment Inservice Inspection Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.S2 ASME Section XI, Subsection IWL PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The evaluation of 10 CFR 50.55a and Subsection IWL as Consistent with GALL AMP: Yes No an aging management program (AMP) for license renewal is Document(s) used to confirm Criteria:

Program Description provided below. 10 CFR 50.55a imposes the examination requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI, Subsection IWL for reinforced and prestressed Comment:

concrete containments (Class CC). The scope of IWL includes reinforced concrete and unbonded post-tensioning systems.

This evaluation covers both the 1992 Edition with the 1992 Addenda and the 1995 Edition with the 1996 Addenda, as approved in 10 CFR 50.55a. ASME Code Section XI, Subsection IWL and the additional requirements specified in 10 CFR 50.55a(b)(2) constitute an existing mandated program applicable to managing aging of containment reinforced concrete and unbonded post-tensioning systems for license renewal. IWL specifies acceptance criteria, corrective actions, and expansion of the inspection scope when degradation exceeding the acceptance criteria is found.

XI.S2 ASME Section XI, Subsection IWL 51

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

1. Scope of Program A Subsection IWL-1000 specifies the components of concrete Consistent with GALL AMP: Yes No containments within its scope. The components within the Document(s) used to confirm Criteria:

scope of Subsection IWL are reinforced concrete and containments, as defined by CC-1000. Subsection IWL exempts from examination portions of the concrete containment that are inaccessible (e.g., concrete covered by Comment:

liner, foundation material, or backfill, or obstructed by adjacent structures or other components). 10 CFR 50.55a(b)(2)(viii) specifies additional requirements for inaccessible areas. It states that the licensee is to evaluate the acceptability of concrete in inaccessible areas when conditions exist in accessible areas that could indicate the presence of or result in degradation to such inaccessible areas. Steel liners for concrete containments and their integral attachments are not within the scope of Subsection IWL, but are included within the scope of Subsection IWE.

2. Preventive Actions: A No preventive actions are specified; Subsection IWL is a Consistent with GALL AMP: Yes No monitoring program. Document(s) used to confirm Criteria:

Comment:

3. Parameters A Table IWL-2500-1 specifies seven categories for Consistent with GALL AMP: Yes No Monitored/Inspected: Examination of concrete surfaces: Category L-A for all Document(s) used to confirm Criteria:

concrete surfaces and Category L-B for concrete surfaces surrounding tendon anchorages. Both of these categories rely on visual examination methods.

Comment:

XI.S2 ASME Section XI, Subsection IWL 52

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B Concrete surfaces are examined for evidence of damage or Consistent with GALL AMP: Yes No degradation, such as concrete cracks. IWL-2510 specifies that Document(s) used to confirm Criteria:

concrete surfaces are examined for conditions indicative of degradation, such as those defined in ACI 201.1R-77.

Comment:

C Table IWL-2500-1 also specifies Category L-B for test and Consistent with GALL AMP: Yes No examination requirements for unbonded post tensioning Document(s) used to confirm Criteria:

systems. Tendon anchorage and wires or strands are visually examined for cracks, corrosion, and mechanical damage.

Tendon wires or strands are also tested for yield strength, ultimate tensile strength, and elongation. Tendon corrosion Comment:

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

4. Detection of Aging A The frequency and scope of examination specified in Consistent with GALL AMP: Yes No Effects: Document(s) used to confirm Criteria:

10 CFR 50.55a and Subsection IWL ensure that aging effects would be detected before they would compromise the design-basis requirements.

Comment:

B Concrete inspections are performed in accordance with Consistent with GALL AMP: Yes No Examination Category L-A. Under Subsection IWL, inservice Document(s) used to confirm Criteria:

inspections for concrete and unbonded post-tensioning systems are required at one, three, and five years following the structural integrity test.

• Thereafter, inspections are performed at five-year Comment:

intervals.

• For sites with two plants, the schedule for inservice inspection is provided in IWL-2421.

XI.S2 ASME Section XI, Subsection IWL 53

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C In the case of tendons, only a sample of the tendons of Consistent with GALL AMP: Yes No each tendon type requires examination at each inspection. Document(s) used to confirm Criteria:

• The tendons to be examined during an inspection are selected on a random basis.

• Table IWL-2521-1 specifies the number of tendons to be selected for each type (e.g., hoop, vertical, dome, helical, Comment:

and inverted U) for each inspection period.

• The minimum number of each tendon type selected for inspection varies from 2 to 4%.

D Regarding detection methods for aging effects, all concrete Consistent with GALL AMP: Yes No surfaces receive a visual VT-3C examination. Document(s) used to confirm Criteria:

• Selected areas, such as those that indicate suspect conditions and areas surrounding tendon anchorages, receive a more rigorous VT-1 or VT-1C examination.

Comment:

E Prestressing forces in sample tendons are measured. Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

• In addition, one sample tendon of each type is detensioned. A single wire or strand is removed from each detensioned tendon for examination and testing.

• These visual examination methods and testing would identify the aging effects of accessible concrete Comment:

components and prestressing systems in concrete containments.

5. Monitoring and A Except in inaccessible areas, all concrete surfaces are Consistent with GALL AMP: Yes No Trending: monitored on a regular basis by virtue of the examination Document(s) used to confirm Criteria:

requirements. B For prestressed containments, trending of prestressing forces in tendons is required in accordance with paragraph (b)(2)(viii) of 10 CFR 50.55a.

Comment:

XI.S2 ASME Section XI, Subsection IWL 54

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B For prestressed containments, trending of Consistent with GALL AMP: Yes No prestressing forces in tendons is required in accordance with Document(s) used to confirm Criteria:

paragraph (b)(2)(viii) of 10 CFR 50.55a.

• In addition to the random sampling used for tendon examination, one tendon of each type is selected from the first-year inspection sample and designated as a common Comment:

tendon.

• Each common tendon is then examined during each inspection.

C 10 CFR 50.55a and Subsection IWL also require that Consistent with GALL AMP: Yes No prestressing forces in all inspection sample tendons be Document(s) used to confirm Criteria:

measured by lift-off tests and compared with acceptance standards based on the predicted force for that type of tendon over its life.

Comment:

6. Acceptance Criteria: A IWL-3000 provides acceptance criteria for concrete Consistent with GALL AMP: Yes No containments. For concrete surfaces, the acceptance criteria Document(s) used to confirm Criteria:

rely on the determination of the "Responsible Engineer" (as defined by the ASME Code) regarding whether there is any evidence of damage or degradation sufficient to warrant further evaluation or repair. Comment:

• The acceptance criteria are qualitative; guidance is provided in IWL-2510, which references ACI 201.1R-77 for identification of concrete degradation.

• Quantitative acceptance criteria based on the "Evaluation Criteria" provided in Chapter 5 of ACI 349.3R may also be used to augment the qualitative assessment of the responsible engineer.

XI.S2 ASME Section XI, Subsection IWL 55

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B The acceptance standards for the unbonded post- Consistent with GALL AMP: Yes No tensioning system are quantitative in nature. For the post Document(s) used to confirm Criteria:

tensioning system, quantitative acceptance criteria are given for tendon force and elongation, tendon wire or strand samples, and corrosion protection medium.

• 10 CFR 50.55a and Subsection IWL do not define the Comment:

method for calculating predicted tendon prestressing forces for comparison to the measured tendon lift-off forces.

• The predicted tendon forces are to be calculated in accordance with Regulatory Guide 1.35.1, which provides an acceptable methodology for use through the period of extended operation.

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A ASME Section XI, Subsection IWL was incorporated into Consistent with GALL AMP: Yes No Experience: 10 CFR 50.55a in 1996. Prior to this time, operating Document(s) used to confirm Criteria:

experience pertaining to degradation of reinforced concrete and prestressing systems in concrete containments was gained through the inspections required by 10 CFR Part 50, Appendix J and ad hoc inspections conducted by licensees Comment:

and the Nuclear Regulatory Commission (NRC). Recently, NRC Information Notice (IN) 99-10 described occurrences of degradation in prestressing systems. The program is to consider the degradation concerns described in this generic communication. Implementation of Subsection IWL, in accordance with 10 CFR 50.55a, is a necessary element of aging management for concrete containments through the period of extended operation.

XI.S2 ASME Section XI, Subsection IWL 56

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.S2 ASME Section XI, Subsection IWL 57

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.8 Containment Leakage Testing Program This AMP requires auditing against the following GALL AMP:

XI.S4 10 CFR Part 50, Appendix J XI.S4 10 CFR Part 50, Appendix J 58

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.8 Containment Leakage Testing Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.S4 10 CFR Part 50, Appendix J PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A As described in 10 CFR Part 50, Appendix J, containment Consistent with GALL AMP: Yes No leak rate tests are required "to assure that (a) leakage through Document(s) used to confirm Criteria:

Program Description the primary reactor containment and systems and components penetrating primary containment shall not exceed allowable leakage rate values as specified in the technical specifications or associated bases and (b) periodic surveillance of reactor Comment:

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. "Appendix J provides two options, A and B, either of which can be chosen to meet the requirements of a containment LRT program. Under Option A, all of the testing must be performed on a periodic interval.

Option B is a performance-based approach. Some of the differences between these options are discussed below, and more detailed information for Option B is provided in the Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 1.163 and NEI 94-01, Rev. 0.

1. Scope of Program A The scope of the containment LRT program includes all Consistent with GALL AMP: Yes No pressure-retaining components. Document(s) used to confirm Criteria:

Comment XI.S4 10 CFR Part 50, Appendix J 59

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B Type A and B tests described in 10 CFR Part 50, Appendix Consistent with GALL AMP: Yes No J, are acceptable methods for performing these LRTs. Document(s) used to confirm Criteria:

Comment C Leakage testing for containment isolation valves (normally Consistent with GALL AMP: Yes No performed under Type C tests), if not included under this Document(s) used to confirm Criteria:

program, is included under LRT programs for systems containing the isolation valves.

Comment

2. Preventive Actions: A No preventive actions are specified; the containment LRT Consistent with GALL AMP: Yes No program is a monitoring program. Document(s) used to confirm Criteria:

Comment:

3. Parameters A The parameters to be monitored are leakage rates through Consistent with GALL AMP: Yes No Monitored/Inspected: containment shells; containment liners; and associated welds, Document(s) used to confirm Criteria:

penetrations, fittings, and other access openings.

Comment:

XI.S4 10 CFR Part 50, Appendix J 60

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

4. Detection of Aging A A containment LRT program is effective in detecting Consistent with GALL AMP: Yes No Effects: degradation of containment shells, liners, and components that Document(s) used to confirm Criteria:

compromise the containment pressure boundary, including seals and gaskets. While the calculation of leakage rates demonstrates the leak-tightness and structural integrity of the containment, it does not by itself provide information that Comment:

would indicate that aging degradation has initiated or that the capacity of the containment may have been reduced for other types of loads, such as seismic loading. This would be achieved with the additional implementation of an acceptable containment inservice inspection program as described in XI.S1 and XI.S2.

5. Monitoring and A With Option A, testing is performed on a regular fixed time Consistent with GALL AMP: Yes No Trending: interval as defined in 10 CFR Part 50, Appendix J. Document(s) used to confirm Criteria:

Comment:

B In the case of Option B, the interval for testing may be Consistent with GALL AMP: Yes No increased on the basis of acceptable performance in Document(s) used to confirm Criteria:

meeting leakage limits in prior tests. Additional details for implementing Option B are provided in NRC Regulatory Guide 1.163 and NEI 94-01, Rev.0.

Comment:

6. Acceptance Criteria: A Acceptance criteria for leakage rates are defined in Consistent with GALL AMP: Yes No plant technical specifications. Document(s) used to confirm Criteria:

Comment:

XI.S4 10 CFR Part 50, Appendix J 61

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B These acceptance criteria meet the requirements in Consistent with GALL AMP: Yes No 10 CFR Part 50, Appendix J, and are part of each plant's Document(s) used to confirm Criteria:

current licensing basis.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A To date, the 10 CFR Part 50, Appendix J, LRT program has Consistent with GALL AMP: Yes No Experience: been effective in preventing unacceptable leakage through the Document(s) used to confirm Criteria:

containment pressure boundary. Implementation of Option B for testing frequency must be consistent with plant-specific operating experience.

Comment:

XI.S4 10 CFR Part 50, Appendix J 62

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.S4 10 CFR Part 50, Appendix J 63

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.9 Diesel Fuel Monitoring and Storage Program This AMP requires auditing against the following GALL AMP:

XI.M30 Fuel Oil Chemistry XI.M30 Fuel Oil Chemistry 64

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.9 Diesel Fuel Monitoring and Storage Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M30 Fuel Oil Chemistry PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The program includes (a) surveillance and maintenance Consistent with GALL AMP: Yes No procedures to mitigate corrosion and (b) measures to verify the Document(s) used to confirm Criteria:

Program Description effectiveness of an aging management program (AMP) and confirm the absence of an aging affect.

Comment:

B Fuel oil quality is maintained by monitoring and controlling Consistent with GALL AMP: Yes No fuel oil contamination in accordance with the guidelines of the Document(s) used to confirm Criteria:

American Society for Testing Materials (ASTM) Standards D 1796, D2276, D2709, and D4057.

Comment:

C Exposure to fuel oil contaminants, such as water and Consistent with GALL AMP: Yes No microbiological organisms, is minimized by periodic draining or Document(s) used to confirm Criteria:

cleaning of tanks and by verifying the quality of new oil before its introduction into the storage tanks.

Comment:

XI.M30 Fuel Oil Chemistry 65

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING D The effectiveness of the program is verified to ensure that Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

significant degradation is not occurring and the component intended function will be maintained during the extended period of operation. Thickness measurement of tank bottom surfaces is an acceptable verification program.

Comment:

1. Scope of Program A The program is focused on managing the conditions that Consistent with GALL AMP: Yes No cause general, pitting, and microbiologically influence Document(s) used to confirm Criteria:

corrosion (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 Comment:

water and microbiological organisms.

2. Preventive Actions: A The quality of fuel oil is maintained by additions of biocides Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

to minimize biological activity, stabilizers to prevent biological breakdown of the diesel fuel, and corrosion inhibitors to mitigate corrosion. One-time inspection is an inspection activity independent of methods to mitigate or prevent degradation. Comment:

B Periodic cleaning of a tank allows removal of sediments. Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

Comment:

C Periodic draining of water collected at the bottom of a tank Consistent with GALL AMP: Yes No minimizes the amount of water and the length of contact time. Document(s) used to confirm Criteria:

Comment:

XI.M30 Fuel Oil Chemistry 66

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

3. Parameters A The AMP monitors fuel oil quality and the levels of water Consistent with GALL AMP: Yes No Monitored/Inspected: Document(s) used to confirm Criteria:

and microbiological organisms in the fuel oil.

Comment:

B The ASTM Standard D 4057 is used for guidance on oil Consistent with GALL AMP: Yes No sampling. Document(s) used to confirm Criteria:

Comment:

C The ASTM Standards D 1796 and D 2709 are used for Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

determination of water and sediment contamination in diesel fuel.

Comment:

D For determination of particulates, modified ASTM D 2276, Consistent with GALL AMP: Yes No Method A, is used. Document(s) used to confirm Criteria:

Comment:

4. Detection of Aging A Internal surfaces of tanks that are drained for cleaning are Consistent with GALL AMP: Yes No Effects: visually inspected to detect potential degradation. Document(s) used to confirm Criteria:

Comment:

XI.M30 Fuel Oil Chemistry 67

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B However, corrosion may occur at locations in which Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

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.

Comment:

5. Monitoring and A Water and biological activity or particulate contamination Consistent with GALL AMP: Yes No Trending: concentrations are monitored and trended at least quarterly. Document(s) used to confirm Criteria:

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 Comment:

function.

6. Acceptance Criteria: A The ASTM Standard D 4057 is used for guidance on oil Consistent with GALL AMP: Yes No sampling. Document(s) used to confirm Criteria:

Comment:

B The ASTM Standards D 1796 and D 2079 are used for Consistent with GALL AMP: Yes No guidance on the determination of water and sediment Document(s) used to confirm Criteria:

contamination in diesel fuel.

Comment:

C Modified ASTM D 2276, Method A is used for determination Consistent with GALL AMP: Yes No of particulates. The modification consists of using a filter with Document(s) used to confirm Criteria:

a pore size of 3.0 µm, instead of 0.8 µm.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A XI.M30 Fuel Oil Chemistry 68

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A The operating experience at some plants has included Consistent with GALL AMP: Yes No Experience: identification of water in the fuel, particulate contamination, Document(s) used to confirm Criteria:

and biological fouling. However, no instances of fuel oil system component failures attributed to contamination have been identified.

Comment:

XI.M30 Fuel Oil Chemistry 69

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M30 Fuel Oil Chemistry 70

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.10 Fire Protection Program This AMP requires auditing against the following two (2) GALL AMPs:

XI.M26 Fire Protection XI.M27 Fire Water System XI.M26 Fire Protection 71

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.10 Fire Protection Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M26 Fire Protection PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A For operating plants, the fire protection aging management Consistent with GALL AMP: Yes No program (AMP) includes a fire barrier inspection program and Document(s) used to confirm Criteria:

Program Description a diesel-driven fire pump inspection program. The fire barrier inspection program requires periodic visual inspection of fire barrier penetration seals, fire barrier walls, ceilings, and floors, and periodic visual inspection and functional tests of fire rated Comment:

doors to ensure that their operability is maintained. The diesel-driven fire pump inspection program requires that the pump be periodically tested to ensure that the fuel supply line can perform the intended function. The AMP also includes periodic inspection and test of halon/carbon dioxide fire suppression system.

1. Scope of Program A the AMP manages the aging effects on the intended Consistent with GALL AMP: Yes No function of the penetration seals, fire barrier walls, ceilings, Document(s) used to confirm Criteria:

and floors, and all fire rated doors (automatic or manual) that perform a fire barrier function. It also manages the aging effects on the intended function of the fuel supply line. The AMP also includes management of the aging effects on the Comment intended function of the halon/carbon dioxide fire suppression system.

XI.M26 Fire Protection 72

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

2. Preventive Actions: A the fire hazard analysis assesses the fire potential and fire Consistent with GALL AMP: Yes No hazard in all plant areas. Document(s) used to confirm Criteria:

Comment:

B It also specifies measures for fire prevention, fire detection, Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

fire suppression, and fire containment and alternative shutdown capability for each fire area containing structures, systems, and components important to safety.

Comment:

3. Parameters A Visual inspection of 10% of each type of penetration seal is Consistent with GALL AMP: Yes No Monitored/Inspected: performed during walkdowns carried out at least once every Document(s) used to confirm Criteria:

refueling outage.

Comment:

B These inspections examine any sign of degradation such Consistent with GALL AMP: Yes No as cracking, seal separation from walls and components, Document(s) used to confirm Criteria:

separation of layers of material, rupture and puncture of seals which are directly caused by increased hardness and shrinkage of seal material due to weathering. Visual inspection of the fire barrier walls, ceilings, and floors Comment:

examines any sign of degradation such as cracking, spalling, and loss of material caused by freeze-thaw, chemical attack, and reaction with aggregates.

XI.M26 Fire Protection 73

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C Hollow metal fire doors are visually inspected at least once Consistent with GALL AMP: Yes No bi-monthly for holes in the skin of the door. Document(s) used to confirm Criteria:

Comment:

D Fire door clearances are also checked at least once Consistent with GALL AMP: Yes No bi-monthly as part of an inspection program. Document(s) used to confirm Criteria:

Comment:

E Function tests of fire doors are performed daily, weekly, or Consistent with GALL AMP: Yes No monthly (which maybe plant specific) to verify the operability of Document(s) used to confirm Criteria:

automatic hold-open, release, closing mechanisms, and latches.

Comment:

F The diesel-driven fire pump is under observation during Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

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.

Comment:

XI.M26 Fire Protection 74

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING G Periodic visual inspection and function test at least once Consistent with GALL AMP: Yes No every six months examines the signs of degradation of the Document(s) used to confirm Criteria:

halon/carbon dioxide fire suppression system. The suppression agent charge pressure is monitored in the test.

Material conditions that may affect the performance of the system, such as corrosion, mechanical damage, or damage to Comment:

dampers, are observed during these tests. H Inspections performed at least once every month verify that the extinguishing agent supply valves are open and the system in automatic mode.

H Inspections performed at least once every month verify that Consistent with GALL AMP: Yes No the extinguishing agent supply valves are open and the system Document(s) used to confirm Criteria:

in automatic mode.

Comment:

4. Detection of Aging A If any sign of degradation is detected within that 10%, the Consistent with GALL AMP: Yes No Effects: scope of the inspection and frequency is expanded to ensure Document(s) used to confirm Criteria:

timely detection of increased hardness and shrinkage of the penetration seal before the loss of the component intended function.

Comment:

B Inspection (VT-1 or equivalent) of the fire barrier walls, Consistent with GALL AMP: Yes No ceilings, and floors performed in walkdown at least once every Document(s) used to confirm Criteria:

refueling outage ensures timely detection for concrete cracking, spalling, and loss of material.

Comment:

XI.M26 Fire Protection 75

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C Visual inspection (VT-3 or equivalent) detects any sign of Consistent with GALL AMP: Yes No degradation of the fire door such as wear and missing parts. Document(s) used to confirm Criteria:

Comment:

D Function tests promptly detect deficiencies in operational Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

conditions.

Comment:

E Periodic tests performed at least once every refueling Consistent with GALL AMP: Yes No outage, such as flow and discharge tests, sequential starting Document(s) used to confirm Criteria:

capability tests, and controller function tests performed on diesel-driven fire pump ensure fuel supply line performance.

Comment:

F The performance tests detect degradation of the fuel supply Consistent with GALL AMP: Yes No lines before the loss of the component intended function. Document(s) used to confirm Criteria:

Comment:

XI.M26 Fire Protection 76

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING G In the test of the halon/carbon dioxide fire suppression Consistent with GALL AMP: Yes No system, the suppression agent charge pressure is verified to Document(s) used to confirm Criteria:

be within in the normal band.

Comment:

5. Monitoring and A The aging effects of weathering on fire barrier penetration Consistent with GALL AMP: Yes No Trending: Document(s) used to confirm Criteria:

seals are detectable by visual inspection and, based on operating experience, visual inspections performed at least once every refueling outage to detect any sign of degradation of fire barrier penetration seals prior to loss of the intended function. Comment:

B Concrete cracking, spalling, and loss of material are Consistent with GALL AMP: Yes No detectable by visual inspection and, based on operating Document(s) used to confirm Criteria:

experience, visual inspection performed at least once every refueling outage detects any sign of degradation of the fire barrier walls, ceilings, and floors before there is a loss of the intended function. Comment:

C Wear, missing parts, or holes in the fire door are detectable Consistent with GALL AMP: Yes No by visual inspection and, based on operating experience, the Document(s) used to confirm Criteria:

visual inspection and function test performed bi-monthly which detects degradation of the fire doors prior to loss of the intended function.

Comment:

XI.M26 Fire Protection 77

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING D The performance of the fire pump is monitored during the Consistent with GALL AMP: Yes No periodic test to detect any degradation in the fuel supply lines. Document(s) used to confirm Criteria:

Periodic testing provides data (e.g., pressure) for trending necessary.

Comment:

E The performance of the halon/carbon dioxide fire Consistent with GALL AMP: Yes No suppression system is monitored during the periodic test to Document(s) used to confirm Criteria:

detect any degradation in the system. These periodic tests provide data necessary for trending.

Comment:

6. Acceptance Criteria: A Inspection results are acceptable if there are no visual Consistent with GALL AMP: Yes No Indications of cracking, separation of seals from walls and Document(s) used to confirm Criteria:

components, separation of layers of material, or ruptures or punctures of seals, no visual indications of concrete cracking, spalling and loss of material of fire barrier walls, ceilings, and floors, no visual indications of missing parts, Comment:

holes, and wear and no deficiencies in the functional tests of fire doors.

B No corrosion is acceptable in the fuel supply line for diesel- Consistent with GALL AMP: Yes No driven fire pump. Document(s) used to confirm Criteria:

Comment:

XI.M26 Fire Protection 78

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C any signs of corrosion and mechanical damage of the Consistent with GALL AMP: Yes No halon/carbon dioxide fire suppression system are not Document(s) used to confirm Criteria:

acceptable.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A Silicone foam fire barrier penetration seals have Consistent with GALL AMP: Yes No Experience: experienced splits, shrinkage, voids, lack of fill, and other Document(s) used to confirm Criteria:

failure modes (IN 88-56, IN 94-28, and IN 97-70). Degradation of electrical racing way fire barrier such as small holes, cracking, and unfilled seals are found on routine walkdown (IN 91-47 and GL 92-08). Fire doors have experienced wear of the Comment:

hinges and handles. Operating experience with the use of this AMP has shown that no corrosion-related problem has been reported for the fuel supply line, pump casing of the diesel-driven fire pump, and the halon/carbon dioxide suppression system.

XI.M26 Fire Protection 79

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M26 Fire Protection 80

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.10 Fire Protection Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M27 Water System PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The aging management program applies to water-based fire Consistent with GALL AMP: Yes No protection systems that consist of sprinklers, nozzles, fittings, Document(s) used to confirm Criteria:

Program Description valves, hydrants, hose stations, standpipes, water storage tanks, and aboveground and underground piping and components that are tested in accordance with the applicable National Fire Protection Association (NFPA) codes and Comment:

standards. In addition to NFPA codes and standards, which do not currently contain programs to manage aging, portions of the fire protection sprinkler system, which are not routinely subjected to flow, are to be subjected to full flow tests at the maximum design flow and pressure before the period of extended operation (and at not more than 5-year intervals thereafter). In addition, a sample of sprinkler heads is to be inspected by using the guidance of NFPA 25, Section 2.3.3.1.

This NFPA section states 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. It also contains guidance to perform this sampling every 10 years after the initial field service testing. Finally, portions of fire protection suppression piping located aboveground and exposed to water are disassembled and visually inspected internally once every refueling outage. The purpose of the full flow testing and internal visual inspections is to ensure that corrosion, microbiological influenced corrosion (MIC), or biofouling aging effects are managed such that the system function is maintained.

XI.M27 Fire Water System 81

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

1. Scope of Program A The aging management program focuses on managing Consistent with GALL AMP: Yes No loss of material due to corrosion, MIC, or biofouling of carbon Document(s) used to confirm Criteria:

steel and cast-iron components in fire protection systems exposed to water.

Comment B Hose station and standpipe are considered as piping in the Consistent with GALL AMP: Yes No AMP. Document(s) used to confirm Criteria:

Comment:

2. Preventive Actions: A To ensure no significant corrosion, MIC, or biofouling has Consistent with GALL AMP: Yes No occurred in water-based fire protection systems, periodic Document(s) used to confirm Criteria:

flushing, system performance testing, and inspections are conducted.

Comment:

3. Parameters A The parameters monitored are the systems ability to Consistent with GALL AMP: Yes No Monitored/Inspected: maintain pressure and internal system corrosion conditions. Document(s) used to confirm Criteria:

Comment:

XI.M27 Fire Water System 82

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

4. Detection of Aging A Fire protection system testing is performed to assure Consistent with GALL AMP: Yes No Effects: required pressures. Document(s) used to confirm Criteria:

Comment:

B Internal inspections of aboveground fire protection Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

piping and the smaller diameter fire suppression piping are performed on system components (when they are due to corrosion.

Comment:

C Repair and replacement actions are initiated as necessary. Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

Comment:

D general requirements of existing fire protection programs Consistent with GALL AMP: Yes No include testing and maintenance of fire detection and Document(s) used to confirm Criteria:

suppression systems and surveillance procedures to ensure that fire detectors, as well as fire suppression systems and components, are operable.

Comment:

XI.M27 Fire Water System 83

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING E Visual inspection of yard fire hydrants performed once every Consistent with GALL AMP: Yes No six months ensures timely detection of signs of degradation, Document(s) used to confirm Criteria:

such as corrosion.

Comment:

F Fire hydrant hose hydrostatic tests, gasket inspections, and Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

fire hydrant flow tests, performed annually, ensure that fire hydrants can perform their intended function and provide of intended function can occur.

Comment:

G Sprinkler systems are inspected once every refueling Consistent with GALL AMP: Yes No outage to ensure that signs of degradation, such as corrosion, Document(s) used to confirm Criteria:

are detected in a timely manner.

Comment:

5. Monitoring and A System discharge pressure is monitored continuously. Consistent with GALL AMP: Yes No Trending: Document(s) used to confirm Criteria:

Comment:

XI.M27 Fire Water System 84

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B Results of system performance testing are monitored and Consistent with GALL AMP: Yes No trended as specified by the NFPA codes and standards. Document(s) used to confirm Criteria:

Comment:

C Degradation identified by internal inspection is evaluated. Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

Comment:

6. Acceptance Criteria: A The acceptance criteria are the ability of a fire protection Consistent with GALL AMP: Yes No system to maintain required pressure, no unacceptable signs Document(s) used to confirm Criteria:

of degradation observed during visual assessment of internal system conditions, and that no biofouling exists in the sprinkler systems that could cause corrosion in the sprinkler heads.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A Water-based fire protection systems designed, inspected, Consistent with GALL AMP: Yes No Experience: tested and maintained in accordance with the NFPA minimum Document(s) used to confirm Criteria:

standards have demonstrated reliable performance.

Comment:

XI.M27 Fire Water System 85

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M27 Fire Water System 86

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.11 Flow Accelerated Corrosion Program This AMP requires auditing against the following GALL AMP:

XI.M17 Flow-Accelerated Corrosion XI.M17 Flow-Accelerated Corrosion 87

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.11 Flow Accelerated Corrosion Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M17 Flow-Accelerated Corrosion PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The program relies on implementation of the Electric Power Consistent with GALL AMP: Yes No Research Institute (EPRI) guidelines in the Nuclear Safety Document(s) used to confirm Criteria:

Program Description Analysis Center (NSAC)-202L-R2 for an effective flow-accelerated corrosion (FAC) program. The program includes performing (a) an analysis to determine critical locations, (b) limited baseline inspections to determine the extent of thinning Comment:

at these locations, and (c) follow-up inspections to confirm the predictions, or repairing or replacing components as necessary.

1. Scope of Program A The FAC program, described by the EPRI guidelines in Consistent with GALL AMP: Yes No NSAC-202L-R2, includes procedures or administrative controls Document(s) used to confirm Criteria:

to assure that the structural integrity of all carbon steel lines containing high-energy fluids (two phase as well as single phase) is maintained.

Comment B Valve bodies retaining pressure in these high-energy systems are also covered by the program.

XI.M17 Flow-Accelerated Corrosion 88

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C A program implemented in accordance with the EPRI guidelines predicts, detects, and monitors FAC in plant piping and other components, such as valve bodies, elbows and expanders. Such a program includes the following recommendations: (a) conducting an analysis to determine critical locations; (b) performing limited baseline inspections to determine the extent of thinning at these locations; and (c) performing follow-up inspections to confirm the predictions, or repairing or replacing components as necessary.

2. Preventive Actions: A The FAC program is an analysis, inspection, and Consistent with GALL AMP: Yes No verification program; thus, there is no preventive action. Document(s) used to confirm Criteria:

Comment:

3. Parameters A The aging management program (AMP) monitors the Consistent with GALL AMP: Yes No Monitored/Inspected: effects of FAC on the intended function of piping and Document(s) used to confirm Criteria:

components by measuring wall thickness.

Comment:

4. Detection of Aging A Degradation of piping and components occurs by wall Consistent with GALL AMP: Yes No Effects: thinning. The inspection program delineated in NSAC-202L Document(s) used to confirm Criteria:

consists of identification of susceptible locations as indicated by operating conditions or special considerations.

Comment:

B Ultrasonic and radiographic testing is used to detect wall thinning. The extent and schedule of the inspections assure detection of wall thinning before the loss of intended function.

XI.M17 Flow-Accelerated Corrosion 89

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

5. Monitoring and A CHECWORKS or a similar predictive code is used to Consistent with GALL AMP: Yes No Trending: predict component degradation in the systems conducive to Document(s) used to confirm Criteria:

FAC, as indicated by specific plant data, including material, hydrodynamic, and operating conditions.

Comment:

B The inspection schedule developed by the licensee on the basis of the results of such a predictive code provides reasonable assurance that structural integrity will be maintained between inspections.

C If degradation is detected such that the wall thickness is less than the minimum predicted thickness, additional examinations are performed in adjacent areas to bound the thinning.

6. Acceptance Criteria: A Inspection results are used as input to a predictive Consistent with GALL AMP: Yes No computer code, such as CHECWORKS, to calculate the Document(s) used to confirm Criteria:

number of refueling or operating cycles remaining before the component reaches the minimum allowable wall thickness.

Comment:

B If calculations indicate that an area will reach the minimum allowed thickness before the next scheduled outage, the component is to be repaired, replaced, or reevaluated.

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

XI.M17 Flow-Accelerated Corrosion 90

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

10. Operating A Wall-thinning problems in single-phase systems have Consistent with GALL AMP: Yes No Experience: occurred in feedwater and condensate systems (NRC IE Document(s) used to confirm Criteria:

Bulletin No. 87-01; NRC Information Notices [INs] 81-28, 92-35, 95-11) and in two-phase piping in extraction steam lines (NRC INs 89-53, 97-84) and moisture separation reheater and feedwater heater drains (NRC INs 89-53, 91-18, 93-21, 97-84). Comment:

Operating experience shows that the present program, when properly implemented, is effective in managing FAC in high-energy carbon steel piping and components.

XI.M17 Flow-Accelerated Corrosion 91

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M17 Flow-Accelerated Corrosion 92

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.12 Non-EQ Electrical Commodities Condition Monitoring Program This AMP requires auditing against the following three (3) GALL AMPs:

XI.E1 Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements XI.E2 Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits XI.E3 Inaccessible Medium-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements [Assigned to DE. Worksheet not included.]

XI.E1 Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 93

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.12 Non-EQ Electrical Commodities Condition REVIEWER: ______________________

Monitoring Program DATE: __________________________

GALL AMP: XI.E1 Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The purpose of the aging management program described Consistent with GALL AMP: Yes No herein is to provide reasonable assurance that the intended Document(s) used to confirm Criteria:

Program Description functions of electrical cables and connections that are not subject to the environmental qualification requirements of 10 CFR 50.49 and are exposed to adverse localized environments caused by heat, radiation, or moisture will be Comment:

maintained consistent with the current licensing basis through the period of extended operation. This program considers the technical information and guidance provided in NUREG/CR-5643, IEEE Std. P1205, SAND96-0344, and EPRI TR-109619.

B The program described herein is written specifically to Consistent with GALL AMP: Yes No address cables and connections at plants whose configuration Document(s) used to confirm Criteria:

is such that most (if not all) cables and connections installed in adverse localized environments are accessible.

Comment:

XI.E1 Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 94

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C Since they are not subject to the environmental qualification Consistent with GALL AMP: Yes No requirements of 10 CFR 50.49, the electrical cables and Document(s) used to confirm Criteria:

connections covered by this aging management program are either not exposed to harsh accident conditions or are not required to remain functional during or following an accident to which they are exposed. Comment

1. Scope of Program A This inspection program applies to accessible electrical Consistent with GALL AMP: Yes No cables and connections within the scope of license renewal Document(s) used to confirm Criteria:

that are installed in adverse localized environments caused by heat or radiation in the presence of oxygen Comment:

2. Preventive Actions: A This is an inspection program and no actions are taken as Consistent with GALL AMP: Yes No part of this program to prevent or mitigate aging degradation. Document(s) used to confirm Criteria:

Comment:

3. Parameters A A representative sample of accessible electrical cables and Consistent with GALL AMP: Yes No Monitored/Inspected: connections installed in adverse localized environments are Document(s) used to confirm Criteria:

visually inspected for cable and connection jacket surface anomalies, such as embrittlement, discoloration, cracking, or surface contamination. The technical basis for the sample selected is to be provided. Comment:

4. Detection of Aging A Accessible electrical cables and connections installed in Consistent with GALL AMP: Yes No Effects: adverse localized environments are visually inspected at least Document(s) used to confirm Criteria:

once every 10 years.

Comment:

XI.E1 Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 95

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B The first inspection for license renewal is to be completed Consistent with GALL AMP: Yes No before the period of extended operation. Document(s) used to confirm Criteria:

Comment:

5. Monitoring and A Trending actions are not included as part of this program Consistent with GALL AMP: Yes No Trending: because the ability to trend inspection results is limited. Document(s) used to confirm Criteria:

Comment:

6. Acceptance Criteria: A the accessible cables and connections are to be free Consistent with GALL AMP: Yes No from unacceptable, visual indications of surface Document(s) used to confirm Criteria:

anomalies, which suggest that conductor insulation or connection degradation exists. An unacceptable indication is defined as a noted condition or situation that, if left unmanaged, could lead to a loss of the intended Comment:

function.

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

XI.E1 Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 96

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

10. Operating Experience: A Operating experience has shown that adverse localized Consistent with GALL AMP: Yes No environments caused by heat or radiation for electrical cables Document(s) used to confirm Criteria:

and connections may exist next to or above (within three feet of) steam generators, pressurizers or hot process pipes, such as feedwater lines. These adverse localized environments have been found to cause degradation of the insulating Comment:

materials on electrical cables and connections that is visually observable, such as color changes or surface cracking.

These visual indications can be used as indicators of degradation.

XI.E1 Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 97

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.E1 Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements 98

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.12 Non-EQ Electrical Commodities Condition REVIEWER: ______________________

Monitoring Program DATE: __________________________

GALL AMP: XI.E2 Electrical Cables And Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used In Instrumentation Circuits PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The purpose the aging management program described Consistent with GALL AMP: Yes No herein is to provide reasonable assurance that the intended Document(s) used to confirm Criteria:

Program Description functions of electrical cables that are not subject to the environmental qualification requirements of 10 CFR 50.49 and are used in circuits with sensitive, low-level signals exposed to adverse localized environments caused by heat, radiation or Comment:

moisture will be maintained consistent with the current licensing basis through the period of extended operation.

This program considers the technical information and guidance provided in NUREG/CR-5643, IEEE Std. P1205, SAND96-0344, and EPRI TR-109619.

In this aging management program, routine calibration tests performed as part of the plant surveillance test program are used to identify the potential existence of aging degradation When an instrumentation loop is found to be out of calibration during routine surveillance testing, trouble shooting is performed on the loop, including the instrumentation cable.

XI.E2 Electrical Cables and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements used in Instrumentation Circuits

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B Since they are not subject to the environmental qualification Consistent with GALL AMP: Yes No requirements of 10 CFR 50.49, the electrical cables covered Document(s) used to confirm Criteria:

by this aging management program are either not exposed to harsh accident conditions or are not required to remain functional during or following an accident to which they are exposed. Comment

1. Scope of Program A This program applies to electrical cables used in circuits Consistent with GALL AMP: Yes No with sensitive, low-level signals such as radiation monitoring Document(s) used to confirm Criteria:

and nuclear instrumentation that are within the scope of license renewal.

Comment

2. Preventive Actions: A This is a surveillance testing program and no actions are Consistent with GALL AMP: Yes No taken as part of this program to prevent or mitigate aging Document(s) used to confirm Criteria:

degradation.

Comment:

3. Parameters A The parameters monitored are determined from the Consistent with GALL AMP: Yes No Monitored/Inspected: plant technical specifications and are specific to the Document(s) used to confirm Criteria:

instrumentation loop being calibrated, as documented in the surveillance test procedure.

Comment:

4. Detection of Aging A Calibration provides sufficient indication of the need for Consistent with GALL AMP: Yes No Effects: corrective actions by monitoring key parameters and providing Document(s) used to confirm Criteria:

trending data based on acceptance criteria related to instrumentation loop performance.

Comment:

XI.E2 Electrical Cables and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements used in Instrumentation Circuits

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B The normal calibration frequency specified in the plant Consistent with GALL AMP: Yes No technical specifications provides reasonable assurance that Document(s) used to confirm Criteria:

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.

Comment:

5. Monitoring and A Trending actions are not included as part of this program Consistent with GALL AMP: Yes No Trending: because the ability to trend test results is dependent on the Document(s) used to confirm Criteria:

specific type of test chosen.

Comment:

6. Acceptance Criteria: A Calibration readings are to be within the loop-specific Consistent with GALL AMP: Yes No acceptance criteria, as set out in the plant technical Document(s) used to confirm Criteria:

specifications surveillance test procedures.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating Experience: A Operating experience has shown that a significant number Consistent with GALL AMP: Yes No of cable failures are identified through routine calibration Document(s) used to confirm Criteria:

testing. Changes in instrument calibration can be caused by degradation of the circuit cable and are one indication of potential electrical cable degradation.

Comment:

XI.E2 Electrical Cables and Not Subject to 10 CFR 50.49 Environmental Qualification Requirements used in Instrumentation Circuits

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.E2 Electrical Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits 102

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.13 One-Time Inspection Program This AMP requires auditing against the following three (3) GALL AMPs:

XI.M29 Aboveground Carbon Steel Tanks XI.M32 One-Time Inspection XI.M33 Selective Leaching Of Materials XI.M29 Aboveground Carbon Steel Tanks 103

Audit Worksheet GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.13 One-Time Inspection Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M29 Aboveground Carbon Steel Tanks PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The program includes preventive measures to mitigate Consistent with GALL AMP: Yes No corrosion by protecting the external surface of carbon steel Document(s) used to confirm Criteria:

Program Description tanks with paint or coatings in accordance with standard industry practice. The program also relies on periodic system walkdowns to monitor degradation of the protective paint or coating. Comment:

B for storage tanks supported on earthen or concrete Consistent with GALL AMP: Yes No foundations, corrosion may occur at inaccessible locations, Document(s) used to confirm Criteria:

such as the tank bottom. Accordingly, verification of the effectiveness of the program is to be performed to ensure that significant degradation in inaccessible locations is not occurring and the component intended function will be Comment:

maintained during the extended period of operation. For reasons set forth below, an acceptable verification program consists of thickness measurement of the tank bottom surface.

1. Scope of Program A The program consists of preventive measures to mitigate Consistent with GALL AMP: Yes No corrosion by protecting the external surfaces of carbon steel Document(s) used to confirm Criteria:

tanks protected with paint or coatings and periodic system walkdowns to manage the effects of corrosion on the intended function of these tanks. Plant walkdowns cover the entire outer surface of the tank up to its surface in contact with soil or Comment concrete.

XI.M29 Aboveground Carbon Steel Tanks 104

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

2. Preventive Actions: A In accordance with industry practice, tanks are coated with Consistent with GALL AMP: Yes No protective paint or coating to mitigate corrosion by protecting Document(s) used to confirm Criteria:

the external surface of the tank from environmental exposure.

Comment:

B Sealant or caulking at the interface edge between the tank Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

and concrete or earthen foundation mitigates corrosion of the bottom surface of the tank by preventing water and moisture from penetrating the interface, which would lead to corrosion of the bottom surface.

Comment:

3. Parameters A The aging management program (AMP)utilizes periodic Consistent with GALL AMP: Yes No Monitored/Inspected: plant system walkdowns to monitor degradation because it is a Document(s) used to confirm Criteria:

condition directly related to the potential loss of materials.

Comment:

4. Detection of Aging A Periodic system walkdowns to confirm that the paint, Consistent with GALL AMP: Yes No Effects: coating, sealant, and caulking are intact is an effective method Document(s) used to confirm Criteria:

to manage the effects of corrosion on the external surface of the component.

Comment:

XI.M29 Aboveground Carbon Steel Tanks 105

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B corrosion may occur at inaccessible locations, such as the Consistent with GALL AMP: Yes No tank bottom surface, and thickness measurement of the tank Document(s) used to confirm Criteria:

bottom is to be taken to ensure that significant degradation is not occurring and the component intended function will be maintained during the extended period of operation.

Comment:

5. Monitoring and A The effects of corrosion of the aboveground external Consistent with GALL AMP: Yes No Trending: Document(s) used to confirm Criteria:

surface are detectable by visual techniques. Based on operating experience, plant system walkdowns during each outage provide for timely detection of aging effects.

Comment:

B The effects of corrosion of the underground external Consistent with GALL AMP: Yes No surface are detectable by thickness measurement of the tank Document(s) used to confirm Criteria:

bottom and are monitored and trended if significant material loss is detected.

Comment:

6. Acceptance Criteria: A Any degradation of paint, coating, sealant, and caulking is Consistent with GALL AMP: Yes No reported and will require further evaluation. Degradation Document(s) used to confirm Criteria:

consists of cracking, flaking, or peeling of paint or coatings, and drying, cracking or missing sealant and caulking.

Comment:

XI.M29 Aboveground Carbon Steel Tanks 106

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B Thickness measurements of the tank bottom are evaluated Consistent with GALL AMP: Yes No against the design thickness and corrosion allowance. Document(s) used to confirm Criteria:

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A Coating degradation has occurred in safety-related systems Consistent with GALL AMP: Yes No Experience: and structures (Nuclear Regulatory Commission [NRC]Generic Document(s) used to confirm Criteria:

Letter [GL] 98-04). Corrosion damage near the concrete-metal interface and sand-metal interface has been reported in metal containments (NRC Information Notice [IN] 89-79, Supplement 1, and NRC IN 86-99, Supplement 1). Comment:

XI.M29 Aboveground Carbon Steel Tanks 107

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M29 Aboveground Carbon Steel Tanks 108

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.13 One-Time Inspection Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M32 One-Time Inspection PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The program includes measures to verify the effectiveness Consistent with GALL AMP: Yes No of an aging management program (AMP) and confirm the Document(s) used to confirm Criteria:

Program Description absence of an aging effect.

There are cases where either (a) an aging effect is not expected to occur but there is insufficient data to completely Comment:

rule it out, or (b) an aging effect is expected to progress very slowly.

The elements of the program include (a) determination of the sample size based on an assessment of materials of fabrication, environment, plausible aging effects, and operating experience; (b) identification of the inspection locations in the system or component based on the aging effect; (c) determination of the examination technique, including acceptance criteria that would be effective in managing the aging effect for which the component is examined; and (d) evaluation of the need for follow-up examinations to monitor the progression of any aging degradation.

When evidence of an aging effect is revealed by a one-time inspection, the routine evaluation of the inspection results would identify appropriate corrective actions.

An acceptable verification program may consist of a one-time inspection of selected components and susceptible locations in the system.

XI.M32 One-Time Inspection 109

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING An alternative acceptable program may include routine maintenance or a review of repair records to confirm that these components have been inspected for aging degradation and significant aging degradation has not occurred and thereby verify the effectiveness of existing AMPs.

1. Scope of Program A The program includes measures to verify that unacceptable Consistent with GALL AMP: Yes No degradation is not occurring, thereby validating the Document(s) used to confirm Criteria:

effectiveness of existing AMPs or confirming that there is no need to manage aging-related degradation for the period of extended operation.

Comment:

B The structures and components for which one-time Consistent with GALL AMP: Yes No inspection is to verify the effectiveness of the AMPs (e.g., Document(s) used to confirm Criteria:

water chemistry control, etc.) have been identified in the Generic Aging Lessons Learned (GALL) Report.

Comment:

2. Preventive Actions: A One-time inspection is an inspection activity independent of Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

methods to mitigate or prevent degradation.

Comment:

3. Parameters A The program monitors parameters directly related to the Consistent with GALL AMP: Yes No Monitored/Inspected: degradation of a component. Document(s) used to confirm Criteria:

Comment:

XI.M32 One-Time Inspection 110

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B Inspection is performed in accordance with the Consistent with GALL AMP: Yes No requirements of the American Society of Mechanical Document(s) used to confirm Criteria:

Engineers (ASME) Code and 10 CFR 50, Appendix B, by using a variety of nondestructive examination (NDE) methods, including visual, volumetric, and surface techniques. Comment:

4. Detection of Aging A The inspection includes a representative sample of the Consistent with GALL AMP: Yes No Effects: system population, and, where practical, focus on the Document(s) used to confirm Criteria:

bounding or lead components most susceptible to aging due to time in service, severity of operating conditions, and lowest design margin.

Comment:

B For small-bore piping, actual inspection locations are based Consistent with GALL AMP: Yes No on physical accessibility, exposure levels, NDE techniques, Document(s) used to confirm Criteria:

and locations identified in Nuclear Regulatory Commission (NRC) Information Notice (IN) 97-46.

Comment:

C Combinations of NDE, including visual, ultrasonic, and Consistent with GALL AMP: Yes No surface techniques, are performed by qualified personnel Document(s) used to confirm Criteria:

following procedures consistent with the ASME Code and 10 CFR 50, Appendix B.

Comment:

D For small-bore piping less than NPS 4 in., including pipe, Consistent with GALL AMP: Yes No fittings, and branch connections, a plant-specific destructive Document(s) used to confirm Criteria:

examination of replaced piping due to plant modifications or NDE that permits inspection of the inside surfaces of the piping is to be conducted to ensure that cracking has not occurred.

Comment:

XI.M32 One-Time Inspection 111

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING E Follow-up of unacceptable inspection findings includes Consistent with GALL AMP: Yes No expansion of the inspection sample size and locations. Document(s) used to confirm Criteria:

Comment:

F With respect to inspection timing, the one-time inspection is Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

to be completed before the end of the current operating license.

Comment:

G the inspection is not to be scheduled too early in the current Consistent with GALL AMP: Yes No operating term, which could raise questions regarding Document(s) used to confirm Criteria:

continued absence of aging effects prior to and near the extended period of operation.

Comment:

5. Monitoring and A One-time inspection does not provide specific guidance on Consistent with GALL AMP: Yes No Trending: monitoring and trending. Document(s) used to confirm Criteria:

Comment:

B evaluation of the appropriateness of the techniques and Consistent with GALL AMP: Yes No timing of the one-time inspection improve with the Document(s) used to confirm Criteria:

accumulation of plant-specific and industry-wide experience.

Comment:

XI.M32 One-Time Inspection 112

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

6. Acceptance Criteria: A Any indication or relevant conditions of degradation Consistent with GALL AMP: Yes No detected are evaluated. Document(s) used to confirm Criteria:

Comment:

B The ultrasonic thickness measurements are to be compared Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

to predetermined limits, such as design minimum wall thickness.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A The elements that comprise these inspections (e.g., the Consistent with GALL AMP: Yes No Experience: scope of the inspections and inspection techniques) are Document(s) used to confirm Criteria:

consistent with years of industry practice and staff expectations.

Comment:

XI.M32 One-Time Inspection 113

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M32 One-Time Inspection 114

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.13 One-Time Inspection Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M33 Selective Leaching Of Materials PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The program for selective leaching of materials ensures Consistent with GALL AMP: Yes No the integrity of the components made of cast iron, bronze, Document(s) used to confirm Criteria:

Program Description brass, and other alloys exposed to a raw water, brackish water, treated water, or groundwater environment that may lead to selective leaching of one of the metal components.

Comment:

B The aging management program (AMP) a one-time visual Consistent with GALL AMP: Yes No inspection and hardness measurement of selected Document(s) used to confirm Criteria:

components that may be susceptible to selective leaching to determine whether loss of materials due to selective leaching is occurring, and whether the process will affect the ability of the components to perform their intended function for the Comment:

period of extended operation.

1. Scope of Program A This AMP determines the acceptability of the components Consistent with GALL AMP: Yes No that may be susceptible to selective leaching and assess their Document(s) used to confirm Criteria:

ability to perform the intended function during the period of extended operation.

Comment:

XI.M33 Selective Leaching of Materials 115

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B These components include piping, valve bodies, and Consistent with GALL AMP: Yes No bonnets, pump casing, and heat exchanger components. Document(s) used to confirm Criteria:

Comment:

C The materials of construction for these components may Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

include cast iron, brass, bronze, or aluminum-bronze.

Comment:

D These components may be exposed to a raw water, treated Consistent with GALL AMP: Yes No water, or groundwater environment. Document(s) used to confirm Criteria:

Comment:

E The AMP includes a one-time hardness measurement of a Consistent with GALL AMP: Yes No selected set of components to determine whether loss of Document(s) used to confirm Criteria:

material due to selective leaching is not occurring for the period of extended operation.

Comment:

XI.M33 Selective Leaching of Materials 116

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

2. Preventive Actions: A The one-time visual inspection and hardness measurement Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

is an inspection/verification program; thus, there is no preventive action.

Comment:

3. Parameters A The visual inspection and hardness measurement is to be Consistent with GALL AMP: Yes No Monitored/Inspected: Document(s) used to confirm Criteria:

a one-time inspection.

Comment:

B Because selective leaching is a slow acting corrosion Consistent with GALL AMP: Yes No process, this measurement is performed just before the Document(s) used to confirm Criteria:

beginning of the license renewal period. Follow-up of unacceptable inspection findings includes expansion of the inspection sample size and location.

Comment:

4. Detection of Aging A The one-time visual inspection and hardness measurement Consistent with GALL AMP: Yes No Effects: includes close examination of a select set of components to Document(s) used to confirm Criteria:

determine whether selective leaching has occurred and whether the resulting loss of strength and/or material will affect the intended functions of these components during the period of extended operation. Comment:

XI.M33 Selective Leaching of Materials 117

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B One acceptable procedure is to visually inspect the Consistent with GALL AMP: Yes No susceptible components closely and conduct Brinell Hardness Document(s) used to confirm Criteria:

testing on the inside surfaces of the selected set of components to determine if selective leaching has occurred.

Comment:

C If it is occurring, an engineering evaluation is initiated to Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

determine acceptability of the affected components for further service.

Comment:

5. Monitoring and A There is no monitoring and trending inspection and Consistent with GALL AMP: Yes No Trending: hardness measurement. Document(s) used to confirm Criteria:

Comment:

6. Acceptance Criteria: A Identification of selective leaching will define the need for Consistent with GALL AMP: Yes No further engineering evaluation before the affected components Document(s) used to confirm Criteria:

can be qualified for further service. If necessary, the evaluation will include a root cause analysis.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

XI.M33 Selective Leaching of Materials 118

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

10. Operating A One-time inspection is a new program to be applied by Consistent with GALL AMP: Yes No Experience: the applicant. The elements that comprise these Document(s) used to confirm Criteria:

inspections (e.g., the scope of the inspections and inspection techniques) are consistent with years of industry practice and staff expectations.

Comment:

XI.M33 Selective Leaching of Materials 119

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M33 Selective Leaching of Materials 120

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.14 Open Cycle Cooling Water Program This AMP requires auditing against the following GALL AMP:

XI.M20 Open-Cycle Cooling Water System XI.M20 Open-Cycle Cooling Water System 121

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.14 Open Cycle Cooling Water Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M20 Open-Cycle Cooling Water System PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The program relies on implementation of the Consistent with GALL AMP: Yes No recommendations of the Nuclear Regulatory Commission Document(s) used to confirm Criteria:

Program Description (NRC) Generic Letter (GL) 89-13 to ensure that the effects of aging on the open-cycle cooling water (OCCW) (or service water) system will be managed for the extended period of operation. Comment:

B The program includes surveillance and control techniques Consistent with GALL AMP: Yes No to manage aging effects caused by biofouling, corrosion, Document(s) used to confirm Criteria:

erosion, protective coating failures, and silting in the OCCW system or structures and components serviced by the OCCW system.

Comment:

1. Scope of Program A The program addresses the aging effects of material loss Consistent with GALL AMP: Yes No and fouling due to micro- or macro-organisms and various Document(s) used to confirm Criteria:

corrosion mechanisms.

Comment:

XI.M20 Open-Cycle Cooling Water System 122

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B Because the characteristics of the service water system Consistent with GALL AMP: Yes No may be specific to each facility, the OCCW system is defined Document(s) used to confirm Criteria:

as a system or systems that transfer heat from safety-related systems, structures, and components (SSC) to the ultimate heat sink (UHS). If an intermediate system is used between the safety-related SSCs and the system rejecting heat to the Comment:

UHS, that intermediate system performs the function of a service water system and is thus included in the scope of recommendations of NRC GL 89-13.

C The guidelines of NRC GL 89-13 include (a) surveillance Consistent with GALL AMP: Yes No and control of biofouling;(b) a test program to verify heat Document(s) used to confirm Criteria:

transfer capabilities; (c) routine inspection and a maintenance program to ensure that corrosion, erosion, protective coating failure, silting, and biofouling cannot degrade the performance of safety-related systems serviced by OCCW; (d) a system Comment:

walkdown inspection to ensure compliance with the licensing basis; and (e) a review of maintenance, operating, and training practices and procedures.

2. Preventive Actions: A Implementation of NRC GL 89-13 includes a condition and Consistent with GALL AMP: Yes No performance monitoring program; control or preventive Document(s) used to confirm Criteria:

measures, such as chemical treatment, whenever the potential for biological fouling species exists; or flushing of infrequently used systems.

Comment:

3. Parameters A Cleanliness and material integrity of piping, components, Consistent with GALL AMP: Yes No Monitored/Inspected: heat exchangers, and their internal linings or coatings (when Document(s) used to confirm Criteria:

applicable) that are part of the OCCW system or that are cooled by the OCCW system are periodically inspected, monitored, or tested to ensure heat transfer capabilities.

Comment:

XI.M20 Open-Cycle Cooling Water System 123

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B The program ensures (a) removal of accumulations of Consistent with GALL AMP: Yes No biofouling agents, corrosion products, and silt, and Document(s) used to confirm Criteria:

(b) detection of defective protective coatings and corroded OCCW system piping and components that could adversely affect performance of their intended safety functions.

Comment:

4. Detection of Aging A Inspections for biofouling, damaged coatings, and Consistent with GALL AMP: Yes No Effects: Document(s) used to confirm Criteria:

degraded material condition are conducted. Visual inspections are typically performed; however, nondestructive testing, such as ultrasonic testing, eddy current testing, and heat transfer capability testing, are effective methods to measure surface condition and the Comment:

extent of wall thinning associated with the service water system piping and components, when determined necessary.

5. Monitoring and A Inspection scope, method (e.g., visual or nondestructive Consistent with GALL AMP: Yes No Trending: examination [NDE]), and testing frequencies are in Document(s) used to confirm Criteria:

accordance with the utility commitments under NRC GL 89-13.

Comment:

B Testing and inspections are done annually and during Consistent with GALL AMP: Yes No refueling outages. Document(s) used to confirm Criteria:

Comment:

XI.M20 Open-Cycle Cooling Water System 124

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C Inspections or nondestructive testing will determine the Consistent with GALL AMP: Yes No extent of biofouling, the condition of the surface coating, the Document(s) used to confirm Criteria:

magnitude of localized pitting, and the amount of MIC, if applicable.

Comment:

D Heat transfer testing results are documented in plant test (s) used to confirm Criteria:

procedures and are trended and reviewed by the appropriate group.

Comment:

6. Acceptance Criteria: A Biofouling is removed or reduced as part of the Consistent with GALL AMP: Yes No surveillance and control process. Document(s) used to confirm Criteria:

Comment:

B Acceptance criteria are based on effective cleaning of Consistent with GALL AMP: Yes No biological fouling organisms and maintenance of protective Document(s) used to confirm Criteria:

coating or linings are emphasized.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

XI.M20 Open-Cycle Cooling Water System 125

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

10. Operating A Significant microbiologically influenced corrosion (NRC Consistent with GALL AMP: Yes No Experience: Information Notice [IN] 85-30), failure of protective coatings Document(s) used to confirm Criteria:

(NRC IN 85-24), and fouling (NRC IN 81-21, IN 86-96) have been observed in a number of heat exchangers. The guidance of NRC GL 89-13 has been implemented for approximately 10 years and has been effective in managing aging effects due to Comment:

biofouling, corrosion, erosion, protective coating failures, and sitting in structures and components serviced by OCCW systems.

XI.M20 Open-Cycle Cooling Water System 126

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M20 Open-Cycle Cooling Water System 127

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.15 Overhead Load Handling Systems Inspection Program This AMP requires auditing against the following GALL AMP:

XI.M23 Inspection Of Overhead Heavy Load And Light Load (Related To Refueling) Handling Systems XI.M23 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems 128

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.15 Overhead Load Handling Systems Inspection REVIEWER: ______________________

Program DATE: __________________________

GALL AMP: XI.M23 Inspection Of Overhead Heavy Load And Light Load (Related To Refueling) Handling Systems PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The program demonstrates that testing and monitoring Consistent with GALL AMP: Yes No programs have been implemented and have ensured that the Document(s) used to confirm Criteria:

Program Description structures, systems, and components of these cranes are capable of sustaining their rated loads. This is their intended function during the period of extended operation. It is noted that many of the systems and components of these cranes Comment:

perform an intended function with moving parts or with a change in configuration, or subject to replacement based on qualified life. In these instances, these types of crane systems and components are not within the scope of this aging management program (AMP).

• This program is primarily concerned with structural components that make up the bridge and trolley.

• NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, provides specific guidance on the control of overhead heavy load cranes.

XI.M23 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems 129

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

1. Scope of Program A The program manages the effects of general corrosion Consistent with GALL AMP: Yes No on the crane and trolley structural components for those Document(s) used to confirm Criteria:

cranes that are within the scope of 10 CFR 54.4, and the effects of wear on the rails in the rail system.

Comment:

2. Preventive Actions: A No preventive actions are identified. The crane program Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

is an inspection program.

Comment:

3. Parameters A The program evaluates the effectiveness of the Consistent with GALL AMP: Yes No Monitored/Inspected: maintenance monitoring program and the effects of past and Document(s) used to confirm Criteria:

future usage on the structural reliability of cranes.

Comment:

B The number and magnitude of lifts made by the crane are Consistent with GALL AMP: Yes No also reviewed. Document(s) used to confirm Criteria:

Comment:

XI.M23 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems 130

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

4. Detection of Aging A Crane rails and structural components are visually Consistent with GALL AMP: Yes No Effects: inspected on a routine basis for degradation. Document(s) used to confirm Criteria:

Comment:

B Functional tests are also performed to assure their Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

integrity.

Comment:

5. Monitoring and A Monitoring and trending are not required as part of the Consistent with GALL AMP: Yes No Trending: crane inspection program. Document(s) used to confirm Criteria:

Comment:

6. Acceptance Criteria: A Any significant visual indication of loss of material due to Consistent with GALL AMP: Yes No corrosion or wear are evaluated according to applicable Document(s) used to confirm Criteria:

industry standards and good industry practice.

Comment:

XI.M23 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems 131

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B The crane may also have been designed to a specific Consistent with GALL AMP: Yes No Service Class as defined in the EOCI Specification #61 (or Document(s) used to confirm Criteria:

later revisions), or CMAA Specification #70 (or later revisions), or CMAA Specification #74 (or later revisions).

The specification that was applicable at the time the crane was manufactured is used. Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Controls: Not reviewed by RLEP-B project team N/A

10. Operating Experience: A Because of the requirements for monitoring the Consistent with GALL AMP: Yes No effectiveness of maintenance at nuclear power plants Document(s) used to confirm Criteria:

provided in 10 CFR 50.65, there has been no history of corrosion-related degradation that has impaired cranes.

Likewise, because cranes have not been operated beyond their design lifetime, there have been no significant fatigue- Comment:

related structural failures.

XI.M23 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems 132

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M23 Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems 133

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.17 Reactor Vessel Internals Inspection Program This AMP should be discussed with the Project Team Leader to obtain guidance on how to proceed.

XI.M16 PWR Vessel Internals 134

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.17 Reactor Vessel Internals Inspection Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M16 PWR Vessel Internals PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

Program Description Comment:

1. Scope of Program Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

Comment

2. Preventive Actions: Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

Comment:

XI.M16 PWR Vessel Internals 135

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

3. Parameters Consistent with GALL AMP: Yes No Monitored/Inspected: Document(s) used to confirm Criteria:

Comment:

4. Detection of Aging Consistent with GALL AMP: Yes No Effects: Document(s) used to confirm Criteria:

Comment:

5. Monitoring and Consistent with GALL AMP: Yes No Trending: Document(s) used to confirm Criteria:

Comment:

6. Acceptance Criteria: Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

Comment:

7. Corrective Actions: N/A

8. Confirmation Process: N/A

9. Administrative N/A Controls:

10. Operating Consistent with GALL AMP: Yes No Experience: Document(s) used to confirm Criteria:

Comment:

XI.M16 PWR Vessel Internals 136

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M16 PWR Vessel Internals 137

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.18 Steam Generator Tube Integrity Program This AMP requires auditing against the following GALL AMP:

XI.M19 Steam Generator Tube Integrity XI.M19 Steam Generator Tube Integrity 138

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.18 Steam Generator Tube Integrity Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M19 Steam Generator Tube Integrity PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A Nondestructive examination (NDE) techniques are used to Consistent with GALL AMP: Yes No identify tubes that are defective and need to be removed from Document(s) used to confirm Criteria:

Program Description service or repaired in accordance with the guidelines of the plant technical specifications.

• In addition, operational leakage limits are included to ensure that, should substantial tube leakage develop, Comment:

prompt action is taken to avoid rupture of the leaking tubes.

• These limits are included in plant technical specifications, such as standard technical specifications of NUREG-1430, Rev. 1, for Babcock & Wilcox pressurized water reactors (PWRs); NUREG-1431, Rev. 1, for Westinghouse PWRs; and NUREG-1432, Rev. 1, for Combustion Engineering PWRs.

B The technical specifications specify SG inspection scope and frequency, and acceptance criteria for the plugging and repair of flawed tubes.

• The Nuclear Regulatory Commission (NRC) Regulatory Guide (RG) 1.121, Bases for Plugging Degraded Steam Generator Tubes, provides guidelines for determining the tube repair criteria and operational leakage limits.

• Acceptance criteria for the plugging and repair of flawed tubes are incorporated in the plant technical specifications.

XI.M19 Steam Generator Tube Integrity 139

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C plants may apply for changes in their technical specifications to provide an alternate regulatory basis for SG degradation management.

D the plant technical specifications, incorporating NEI 97-06 as approved by the staff and any other alternate regulatory bases for SG degradation management that have been previously approved by the staff for that plant, are adequate to manage the effects of aging on the SG tubes. However, because NEI 97-06 is still under staff review, until the staff has approved NEI 97-06, the applicants program should be reviewed on a plant-specific basis.

1. Scope of Program A The scope of the program is specific to SG tubes. Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

Comment B The program includes preventive measures to mitigate degradation related to corrosion phenomena; assessment of degradation mechanisms; inservice inspection (ISI) of steam generator tubes to detect degradation; evaluation and plugging or repair, as needed; and leakage monitoring to maintain the structural and leakage integrity of the pressure boundary.

C Tube inspection scope and frequency, plugging or repair, and leakage monitoring are in accordance with the plant technical specifications.

XI.M19 Steam Generator Tube Integrity 140

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

2. Preventive Actions: A The program includes preventive measures to mitigate Consistent with GALL AMP: Yes No degradation related to corrosion phenomena. Document(s) used to confirm Criteria:

• The guidelines in NEI 97-06 include foreign material exclusion as a means to inhibit fretting and wear degradation.

• The water chemistry program for PWRs relies on Comment:

monitoring and control of reactor water chemistry based on the EPRI guidelines in TR-105714 for primary water chemistry and TR-102134 for secondary water chemistry.

The program description and the evaluation and technical basis of monitoring and maintaining reactor water chemistry are presented in Chapter XI.M2, Water Chemistry, of this report.

3. Parameters A The inspection activities in the program detect flaws in Consistent with GALL AMP: Yes No Monitored/Inspected: tubing or degradation of secondary side internals needed to Document(s) used to confirm Criteria:

maintain tubing integrity.

Comment:

B Flaws are removed based on technical specification repair criteria.

C Degradation of steam generator internals is evaluated for corrective actions.

4. Detection of Aging A The inspection requirements in the technical specifications Consistent with GALL AMP: Yes No Effects: are intended to detect tube degradation (i.e., aging effects), if it Document(s) used to confirm Criteria:

should occur.

Comment:

XI.M19 Steam Generator Tube Integrity 141

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B The NEI 97-06 document, which is currently under NRC staff review, provides additional guidance on inspection programs to detect degradation.

C The intent of the inspection and repair criteria is to provide assurance of continued tube integrity between inspections.

5. Monitoring and A Condition monitoring assessments are performed to Consistent with GALL AMP: Yes No Trending: determine whether structural and accident leakage criteria Document(s) used to confirm Criteria:

have been satisfied.

Comment:

B Operational assessments are performed after inspections to verify that structural and leakage integrity are maintained during the operating interval until the next required inspection, which is selected in accordance with the technical specifications and staff approved NEI 97-06 guidelines.

C Comparison of the results of the condition monitoring assessment with the predictions of the previous operational assessment provides feedback for evaluation of the adequacy of the operational assessment and additional insights that can be incorporated into the next operational assessment.

6. Acceptance Criteria: A Assessment of tube integrity and plugging or repair criteria Consistent with GALL AMP: Yes No of flawed tubes is in accordance with the plant technical Document(s) used to confirm Criteria:

specifications.

Comment:

XI.M19 Steam Generator Tube Integrity 142

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B The criteria for plugging or repairing SG tubes are based on NRC RG 1.121 or other criteria previously reviewed and approved by the staff and incorporated into the plant technical specifications. Some examples that are applicable under certain circumstances include P*, F*, L*, or NRC GL 95-05.

C For general and pitting corrosion, the acceptance criteria are in accordance with staff approved NEI 97-06 guidelines.

D Also, loose parts or foreign objects that are found are removed from the SGs unless it can be shown by evaluation that these objects do not cause unacceptable tube damage.

The evaluation is to define an acceptable operating interval.

E For Westinghouse steam generator tube plugs, limits for the life of the plug and correlations for estimating their life are contained in WCAP-12244 and WCAP-12245.

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

XI.M19 Steam Generator Tube Integrity 143

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

10. Operating A Failures to detect some flaws, uncertainties in flaw sizing, Consistent with GALL AMP: Yes No Experience: inaccuracies in flaw locations, and the inability to detect some Document(s) used to confirm Criteria:

cracks at locations with dents have been reviewed in NRC Information Notice (IN) 97-88. Recent experience indicates the importance of performing a complete inspection by using appropriate techniques and equipment for the reliable Comment:

detection of tube degradation and to provide assurance that new forms of degradation are detected. Implementation of the program provides reasonable assurance that SG tube integrity is maintained consistent with the plants licensing basis for the period of extended operation. Experience with the condition and operational assessments required for plants that have implemented the alternate repair criteria in NRC GL 95-05 has shown that the predictions of the operational assessments have generally been consistent with the results of the subsequent condition monitoring assessments. In cases where discrepancies have been noted, adjustments have been made in the operational assessment models to improve agreement in subsequent assessments. In addition, NEI has prepared NEI 97-06 to incorporate lessons learned from plant operation experience and SG inspections and is under staff review.

XI.M19 Steam Generator Tube Integrity 144

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M19 Steam Generator Tube Integrity 145

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.19 Structural Monitoring Program This AMP requires auditing against the following three (3) GALL AMPs:

XI.S5 Masonry Wall Program XI.S6 Structures Monitoring Program XI.S7 RG 1.127, Inspection Of Water-Control Structures Associated With Nuclear Power Plants XI.S5 Masonry Wall Program 146

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.19 Structural Monitoring Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.S5 Masonry Wall Program PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A Nuclear Regulatory Commission (NRC) IE Bulletin (IEB) 80- Consistent with GALL AMP: Yes No 11, "Masonry Wall Design," and NRC Information Notice (IN) Document(s) used to confirm Criteria:

Program Description 87-67, "Lessons Learned from Regional Inspections of Licensee Actions in Response to IE Bulletin 80-11," constitute an acceptable basis for a masonry wall aging management program (AMP). Comment:

B The objective of the masonry wall program is to manage Consistent with GALL AMP: Yes No aging effects so that the evaluation basis established for each Document(s) used to confirm Criteria:

masonry wall within the scope of license renewal remains valid through the period of extended operation. Since the issuance of NRC IEB 80-11 and NRC IN 87-67, the NRC promulgated 10 CFR 50.65, the Maintenance Rule. Comment:

Note to reviewer: Since the issuance of NRC IEB 80-11 and NRC IN 87-67, the NRC promulgated 10 CFR 50.65, the Maintenance Rule. Masonry walls may be inspected as part of the Structures Monitoring Program (XI.S6) conducted for the Maintenance Rule, provided the ten attributes described below are incorporated.

XI.S5 Masonry Wall Program 147

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C Important elements in the evaluation of many masonry Consistent with GALL AMP: Yes No walls during the NRC IEB 80-11 program included (1) Document(s) used to confirm Criteria:

installation of steel edge supports to provide a sound technical basis for boundary conditions used in seismic analysis and (2) installation of steel bracing to ensure containment of unreinforced masonry walls during a seismic event. Comment Consequently, in addition to the development of cracks in the masonry walls, loss of function of the structural steel supports and bracing would also invalidate the evaluation basis.

Note to reviewer: See GALL Vol. 2, III.B5. Steel supports for masonry walls are included in the category of miscellaneous structural steel supports. The Structures Monitoring Program is the identified AMP. Reviewer should confirm that the applicant has credited an appropriate AMP to manage aging of steel supports/bracing for masonry walls.

How can this be audit?

1. Scope of Program A The scope includes all masonry walls identified as Consistent with GALL AMP: Yes No performing intended functions in accordance with 10 CFR Document(s) used to confirm Criteria:

54.4.

Comment

2. Preventive Actions: A No specific preventive actions are required. Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

Comment:

XI.S5 Masonry Wall Program 148

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

3. Parameters A The primary parameter monitored is wall cracking that could Consistent with GALL AMP: Yes No Monitored/Inspected: potentially invalidate the evaluation basis. Document(s) used to confirm Criteria:

Comment:

4. Detection of Aging A Visual examination of the masonry walls by qualified Consistent with GALL AMP: Yes No Effects: Document(s) used to confirm Criteria:

inspection personnel is sufficient. The frequency of inspection is selected to ensure there is no loss of intended function between inspections.

Comment:

B The inspection frequency may vary from wall to wall, Consistent with GALL AMP: Yes No depending on the significance of cracking in the evaluation Document(s) used to confirm Criteria:

basis.

Comment:

C Unreinforced masonry walls that have not been contained Consistent with GALL AMP: Yes No by bracing warrant the most frequent inspection, because the Document(s) used to confirm Criteria:

development of cracks may invalidate the existing evaluation basis.

Comment:

XI.S5 Masonry Wall Program 149

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

5. Monitoring and A Trending is not required. Monitoring is achieved by periodic Consistent with GALL AMP: Yes No Trending: examination for cracking. Document(s) used to confirm Criteria:

Comment:

6. Acceptance Criteria: A For each masonry wall, the extent of observed cracking of Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

masonry and degradation of steel edge supports and bracing is not to invalidate the evaluation basis.

Comment:

B Corrective actions are taken if the extent of cracking and Consistent with GALL AMP: Yes No steel degradation is sufficient to invalidate the evaluation Document(s) used to confirm Criteria:

basis.

Comment:

C An option is to develop a new evaluation basis that Consistent with GALL AMP: Yes No accounts for the degraded condition of the wall (i.e., Document(s) used to confirm Criteria:

acceptance by further evaluation).

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

XI.S5 Masonry Wall Program 150

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

10. Operating A Since 1980, masonry walls that perform an intended Consistent with GALL AMP: Yes No Experience: function have been systematically identified through licensee Document(s) used to confirm Criteria:

programs in response to NRC IEB 80-11, USI A-46, and 10 CFR 50.48. NRC IN 87-67 documented lessons learned from the NRC IEB 80-11 program, and provided recommendations for administrative controls and periodic Comment:

inspection to ensure that the evaluation basis for each safety-significant masonry wall is maintained. Whether conducted as a stand-alone program or as part of structures monitoring for MR, a masonry wall AMP that incorporates the recommendations delineated in NRC IN 87-67 should ensure that the intended functions of all masonry walls within the scope of license renewal are maintained for the period of extended operation.

XI.S5 Masonry Wall Program 151

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.S5 Masonry Wall Program 152

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.19 Structural Monitoring Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.S6 Structures Monitoring Program PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A Implementation of structures monitoring under Consistent with GALL AMP: Yes No 10 CFR 50.65 (the Maintenance Rule) is addressed in Nuclear Document(s) used to confirm Criteria:

Program Description Regulatory Commission (NRC) Regulatory Guide (RG) 1.160, Rev. 2, and NUMARC 93-01, Rev. 2. These two documents provide guidance for development of licensee-specific programs to monitor the condition of structures and structural Comment:

components within the scope of the Maintenance Rule, such that there is no loss of structure or structural component intended function. Because structures monitoring programs are licensee-specific, the Evaluation and Technical Basis for this aging management program (AMP) is based on the implementation guidance provided in Regulatory Guide 1.160, Rev. 2, and NUMARC 93-01, Rev. 2. Existing licensee-specific programs developed for the implementation of structures monitoring under 10 CFR 50.65 are acceptable for license renewal provided these programs satisfy the 10 attributes described below.

B If protective coatings are relied upon to manage the effects Consistent with GALL AMP: Yes No of aging for any structures included in the scope of this AMP, Document(s) used to confirm Criteria:

the structures monitoring program is to address protective coating monitoring and maintenance.

Comment:

XI.S6 Structures Monitoring Program 153

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

1. Scope of Program A The applicant specifies the structure/aging effect Consistent with GALL AMP: Yes No combinations that are managed by its structures monitoring Document(s) used to confirm Criteria:

program.

Comment

2. Preventive Actions: A No preventive actions are specified. Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

Comment:

3. Parameters A For each structure/aging effect combination, the specific Consistent with GALL AMP: Yes No Monitored/Inspected: parameters monitored or inspected are selected to ensure that Document(s) used to confirm Criteria:

aging degradation leading to loss of intended functions will be detected and the extent of degradation can be determined.

Comment:

B Parameters monitored or inspected are to be Consistent with GALL AMP: Yes No commensurate with industry codes, standards and guidelines, Document(s) used to confirm Criteria:

and are to also consider industry and plant-specific operating experience.

Comment:

C Although not required, ACI 349.3R-96 and ANSI/ASCE Consistent with GALL AMP: Yes No 11-90 provide an acceptable basis for selection of parameters Document(s) used to confirm Criteria:

to be monitored or inspected for concrete and steel structural elements and for steel liners, joints, coatings, and waterproofing membranes (if applicable).

Comment:

XI.S6 Structures Monitoring Program 154

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING D If necessary for managing settlement and erosion of porous Consistent with GALL AMP: Yes No concrete subfoundations, the continued functionality of a site Document(s) used to confirm Criteria:

de-watering system is to be monitored.

Comment:

E The plant-specific structures monitoring program is to contain sufficient detail on parameters monitored or inspected to conclude that this program attribute is satisfied.

4. Detection of Aging A For each structure/aging effect combination, the inspection Consistent with GALL AMP: Yes No Effects: methods, inspection schedule, and inspector qualifications are Document(s) used to confirm Criteria:

selected to ensure that aging degradation will be detected and quantified before there is loss of intended functions.

Comment:

B Inspection methods, inspection schedule, and inspector Consistent with GALL AMP: Yes No qualifications are to be commensurate with industry codes, Document(s) used to confirm Criteria:

standards and guidelines, and are to also consider industry and plant-specific operating experience.

Comment:

XI.S6 Structures Monitoring Program 155

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C Although not required, ACI 349.3R-96 and ANSI/ASCE Consistent with GALL AMP: Yes No 11-90 provide an acceptable basis for addressing detection of Document(s) used to confirm Criteria:

aging effects.

Comment:

D The plant-specific structures monitoring program is to Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

contain sufficient detail on detection to conclude that this program attribute is satisfied.

Comment:

5. Monitoring and A Regulatory Position 1.5, "Monitoring of Structures," in Consistent with GALL AMP: Yes No Trending: RG 1.160, Rev. 2, provides an acceptable basis for meeting Document(s) used to confirm Criteria:

the attribute.

Comment:

B A structure is monitored in accordance with 10 CFR 50.65 Consistent with GALL AMP: Yes No (a)(2) provided there is no significant degradation of the Document(s) used to confirm Criteria:

structure.

Comment:

XI.S6 Structures Monitoring Program 156

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C A structure is monitored in accordance with 10 CFR 50.65 Consistent with GALL AMP: Yes No (a)(1) if the extent of degradation is such that the structure Document(s) used to confirm Criteria:

may not meet its design basis or, if allowed to continue uncorrected until the next normally scheduled assessment, may not meet its design basis.

Comment:

6. Acceptance Criteria: A For each structure/aging effect combination, the Consistent with GALL AMP: Yes No acceptance criteria are selected to ensure that the need for Document(s) used to confirm Criteria:

corrective actions will be identified before loss of intended functions.

Comment:

B Acceptance criteria are to be commensurate with industry Consistent with GALL AMP: Yes No codes, standards and guidelines, and are to also consider Document(s) used to confirm Criteria:

industry and plant-specific operating experience.

Comment:

C Although not required, ACI 349.3R-96 provides an Consistent with GALL AMP: Yes No acceptable basis for developing acceptance criteria for Document(s) used to confirm Criteria:

concrete structural elements, steel liners, joints, coatings, and waterproofing membranes.

Comment:

XI.S6 Structures Monitoring Program 157

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING D The plant-specific structures monitoring program is to Consistent with GALL AMP: Yes No contain sufficient detail on acceptance criteria to conclude that Document(s) used to confirm Criteria:

this program attribute is satisfied.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A Although in many plants structures monitoring programs Consistent with GALL AMP: Yes No Experience: have only recently been implemented, plant maintenance has Document(s) used to confirm Criteria:

been ongoing since initial plant operation. A plant-specific program that includes the attributes described above will be an effective AMP for license renewal.

Comment:

XI.S6 Structures Monitoring Program 158

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.S6 Structures Monitoring Program 159

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.19 Structural Monitoring Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.S7 RG 1.127, Inspection Of Water-Control Structures Associated With Nuclear Power Plants PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A Nuclear Regulatory Commission (NRC) Regulatory Guide Consistent with GALL AMP: Yes No (RG) 1.127, Revision 1, "Inspection of Water-Control Document(s) used to confirm Criteria:

Program Description Structures Associated with Nuclear Power Plants," describes an acceptable basis for developing an inservice inspection and surveillance program for dams, slopes, canals, and other water-control structures associated with emergency cooling Comment:

water systems or flood protection of nuclear power plants.

B Water-control structures covered by the RG 1.127 program Consistent with GALL AMP: Yes No include concrete structures; embankment structures; spillway Document(s) used to confirm Criteria:

structures and outlet works; reservoirs; cooling water channels and canals, and intake and discharge structures; and safety and performance instrumentation.

Comment:

C For plants not committed to RG 1.127, Revision 1, aging Consistent with GALL AMP: Yes No management of water-control structures may be included in Document(s) used to confirm Criteria:

the Structures Monitoring Program (XI.S6). However, details pertaining to water-control structures are to incorporate the attributes described in XI.S7.

Comment:

XI.S7 RG 1.127 Inspection of Water-Control Structures Associated With Nuclear Power Plants 160

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

1. Scope of Program A RG 1.127 applies to water-control structures associated Consistent with GALL AMP: Yes No with emergency cooling water systems or flood protection of Document(s) used to confirm Criteria:

nuclear power plants.

Comment B The water-control structures included in the RG 1.127 Consistent with GALL AMP: Yes No program are concrete structures; embankment structures; Document(s) used to confirm Criteria:

spillway structures and outlet works; reservoirs; cooling water channels and canals, and intake and discharge structures; and safety and performance instrumentation.

Comment

2. Preventive Actions: A No preventive actions are specified; RG 1.127 is a Consistent with GALL AMP: Yes No monitoring program. Document(s) used to confirm Criteria:

Comment:

3. Parameters A RG 1.127 identifies the parameters to be monitored and Consistent with GALL AMP: Yes No Monitored/Inspected: inspected for water-control structures. The parameters vary Document(s) used to confirm Criteria:

depending on the particular structure. Parameters to be monitored and inspected for concrete structures include cracking., movements (e.g., settlement, heaving, deflection),

conditions at junctions with abutments and embankments, Comment:

erosion, cavitation, seepage, and leakage.

B Parameters to be monitored and inspected for earthen Consistent with GALL AMP: Yes No embankment structures include settlement, depressions, sink Document(s) used to confirm Criteria:

holes, slope stability (e.g., irregularities in alignment and variances from originally constructed slopes), seepage, proper functioning of drainage systems, and degradation of slope protection features. Comment:

XI.S7 RG 1.127 Inspection of Water-Control Structures Associated With Nuclear Power Plants 161

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING C Further details of parameters to be monitored and inspected Consistent with GALL AMP: Yes No for these and other water-control structures are specified in Document(s) used to confirm Criteria:

Section C.2 of RG 1.127.

Comment:

4. Detection of Aging A Visual inspections are primarily used to detect degradation Consistent with GALL AMP: Yes No Effects: of water-control structures. Document(s) used to confirm Criteria:

Comment:

B RG 1.127 indicates that the available records and readings Consistent with GALL AMP: Yes No of installed instruments are to be reviewed to detect any Document(s) used to confirm Criteria:

unusual performance or distress that may be indicative of degradation.

Comment:

C RG 1.127 describes periodic inspections, to be performed Consistent with GALL AMP: Yes No at least once every five years. Document(s) used to confirm Criteria:

Comment:

XI.S7 RG 1.127 Inspection of Water-Control Structures Associated With Nuclear Power Plants 162

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING D RG 1.127 also describes special inspections immediately Consistent with GALL AMP: Yes No following the occurrence of significant natural phenomena, Document(s) used to confirm Criteria:

such as large floods, earthquakes, hurricanes, tornadoes, and intense local rainfalls.

Comment:

5. Monitoring and A Water-control structures are monitored by periodic Consistent with GALL AMP: Yes No Trending: Document(s) used to confirm Criteria:

inspection as described in RG 1.127.

Comment:

B In addition to monitoring the aging effects identified in Attribute (3) above, inspections also monitor the adequacy and quality of maintenance and operating procedures. RG 1.127 does not discuss trending.

6. Acceptance Criteria: A Although not required, plant-specific acceptance criteria Consistent with GALL AMP: Yes No based on Chapter 5 of ACI 349.3R-96 are acceptable Document(s) used to confirm Criteria:

Comment:

XI.S7 RG 1.127 Inspection of Water-Control Structures Associated With Nuclear Power Plants 163

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B Acceptance criteria for earthen structures such as dams, Consistent with GALL AMP: Yes No canals, and embankments are to be consistent with programs Document(s) used to confirm Criteria:

falling within the regulatory jurisdiction of the Federal Energy Regulatory Commission (FERC) or the U.S. Army Corps of Engineers.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A Degradation of water-control structures has been detected, Consistent with GALL AMP: Yes No Experience: through RG 1.127 programs, at a number of nuclear power Document(s) used to confirm Criteria:

plants, and in some cases, it has required remedial action.

NOTE: For dam inspection and maintenance, programs under the regulatory jurisdiction of FERC or the U.S. Army Corps of Comment:

Engineers, continued through the period of extended operation, will be adequate for the purpose of aging management. For programs not falling under the regulatory jurisdiction of FERC or the U.S. Army Corps of Engineers, the staff will evaluate the effectiveness of the aging management program based on compatibility to the common practices of the FERC and Corps programs.

XI.S7 RG 1.127 Inspection of Water-Control Structures Associated With Nuclear Power Plants 164

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.S7 RG 1.127 Inspection of Water-Control Structures Associated With Nuclear Power Plants 165

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.21 Water Chemistry Program This AMP requires auditing against the following GALL AMP:

XI.M2 Water Chemistry XI.M2 Water Chemistry 166

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B2.1.21 Water Chemistry Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: XI.M2 Water Chemistry PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The main objective of this program is to mitigate damage Consistent with GALL AMP: Yes No caused by corrosion and stress corrosion cracking (SCC). The Document(s) used to confirm Criteria:

Program Description water chemistry program for boiling water reactors (BWRs) relies on monitoring and control of reactor water chemistry based on guidelines in the boiling water reactor vessel and internals project (BWRVIP)-29 (Electric Power Research Comment:

Institute [EPRI] TR-103515). The BWRVIP-29 has three sets of guidelines: one for primary water, one for condensate and feedwater, and one for control rod drive (CRD) mechanism cooling water. The water chemistry program for pressurized water reactors (PWRs) relies on monitoring and control of reactor water chemistry based on the EPRI guidelines in TR-105714 for primary water chemistry and TR-102134 for secondary water chemistry. The water chemistry programs are generally effective in removing impurities from intermediate and high flow areas. The Generic Aging Lessons Learned (GALL) report identifies those circumstances in which the water chemistry program is to be augmented to manage the effects of aging for license renewal Accordingly, in certain cases as identified in the GALL Report, verification of the effectiveness of the chemistry control program is undertaken to ensure that significant degradation is not occurring and the component intended function will be maintained during the extended period of operation. As discussed in the GALL Report for these specific cases, an acceptable verification program is a one-time inspection of selected components at susceptible locations in the system.

XI.M2 Water Chemistry 167

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

1. Scope of Program A The program includes periodic monitoring and control of Consistent with GALL AMP: Yes No known detrimental contaminants such as chlorides, fluorides Document(s) used to confirm Criteria:

(PWRs only), dissolved oxygen, and sulfate concentrations below the levels known to result in loss of material or crack initiation and growth. Water chemistry control is in accordance with the guidelines in BWRVIP-29 (EPRI TR-103515) for water Comment:

chemistry in BWRs; EPRI TR-105714, Rev. 3 and PWRs; EPRI TR102134, Rev. 3, for primary water chemistry in PWRs; EPRI TR-102134, Rev. 3, for secondary water chemistry in PWRs; or later revisions or updates of these reports as approved by the staff.

2. Preventive Actions: A The program includes specifications for chemical species , Consistent with GALL AMP: Yes No sampling and analysis frequencies, and corrective actions for Document(s) used to confirm Criteria:

control of reactor water chemistry.

Comment:

B System water chemistry is controlled to minimize Consistent with GALL AMP: Yes No contaminant concentration and mitigate loss of material due to Document(s) used to confirm Criteria:

general, crevice and pitting corrosion and crack initiation and growth caused by SCC.

Comment:

3. Parameters A The concentration of corrosive impurities listed in the EPRI Consistent with GALL AMP: Yes No Monitored/Inspected: guidelines discussed above, which include chlorides, fluorides Document(s) used to confirm Criteria:

(PWRs only), sulfates, dissolved oxygen, and hydrogen peroxide, are monitored to mitigate degradation of structural materials. Water quality (pH and conductivity) is also maintained in accordance with the guidance. Chemical species Comment:

and water quality are monitored by in process methods or through sampling. 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.

XI.M2 Water Chemistry 168

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B BWR Water Chemistry: The guidelines in BWRVIP-29 Consistent with GALL AMP: Yes No (EPRI TR-103515) for BWR reactor water recommend that the Document(s) used to confirm Criteria:

concentration of chlorides, sulfates, and dissolved oxygen are monitored and kept below the recommended levels to mitigate corrosion. The two impurities, chlorides and sulfates, determine the coolant conductivity; dissolved oxygen, hydrogen peroxide, and hydrogen determine electrochemical Comment:

potential (ECP). The EPRI guidelines recommend that the coolant conductivity and ECP are also monitored and kept below the recommended levels to mitigate SCC and corrosion in BWR plants. The EPRI guidelines in BWRVIP-29 (TR-103515) for BWR feedwater, condensate, and control rod drive water recommends that conductivity, dissolved oxygen level, and concentrations of iron and copper (feedwater only) are monitored and kept below the recommended levels to mitigate SCC. The EPRI guidelines in BWRVIP-29 (TR-103515) also include recommendations for controlling water chemistry in auxiliary systems: torus/pressure suppression chamber, condensate storage tank, and spent fuel pool.

C PWR Primary Water Chemistry: The EPRI guidelines (EPRI Consistent with GALL AMP: Yes No TR-105714) for PWR primary water chemistry recommend that Document(s) used to confirm Criteria:

the concentration of chlorides, fluorides, sulfates, lithium, and dissolved oxygen and hydrogen are monitored and kept below the recommended levels to mitigate SCC of austenitic stainless steel, Alloy 600, and Alloy 690 components. Comment:

TR-105714 provides guidelines for chemistry control in PWR auxiliary systems such as boric acid storage tank, refueling water storage tank, spent fuel pool, letdown purification systems, and volume control tank.

XI.M2 Water Chemistry 169

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING D PWR Secondary Water Chemistry: The EPRI guidelines Consistent with GALL AMP: Yes No (EPRI TR-102134) for PWR secondary water chemistry Document(s) used to confirm Criteria:

recommend 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 (IGA), outer diameter stress corrosion Comment:

cracking (ODSCC), or crevice and pitting corrosion. The monitoring and control of these parameters, especially the pH level, 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).

4. Detection of Aging A This is a mitigation program and does not provide for Consistent with GALL AMP: Yes No Effects: detection of any aging effects, such as loss of material and Document(s) used to confirm Criteria:

crack initiation and growth.

Comment:

5. Monitoring and A The frequency of sampling water chemistry varies (e.g., Consistent with GALL AMP: Yes No Trending: continuous, daily, weekly, or as needed) based on plant Document(s) used to confirm Criteria:

operating conditions and the EPRI water chemistry guidelines.

Comment:

6. Acceptance Criteria: A Maximum levels for various contaminants are maintained Consistent with GALL AMP: Yes No below the system specific limits as indicated by the limits Document(s) used to confirm Criteria:

specified in the corresponding EPRI water chemistry guidelines. Any evidence of the presence of aging effects or unacceptable water chemistry results is evaluated, the root cause identified, and the condition corrected. Comment:

XI.M2 Water Chemistry 170

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B Any evidence of the presence of aging effects or Consistent with GALL AMP: Yes No unacceptable water chemistry results is evaluated, the root Document(s) used to confirm Criteria:

cause identified, and the condition corrected.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A BWR: Intergranular stress corrosion cracking (IGSCC) has Consistent with GALL AMP: Yes No Experience: occurred in small- and large-diameter BWR piping made of Document(s) used to confirm Criteria:

austenitic stainless steels and nickel-base alloys. Significant cracking has occurred in recirculation, core spray, residual heat removal (RHR) systems, and reactor water cleanup (RWCU) system piping welds. IGSCC has also occurred in a Comment:

number of vessel internal components, including core shroud, access hole cover, top guide, and core spray spargers (Nuclear Regulatory Commission [NRC] Information Bulletin 80-13, NRC Information Notice [IN] 95-17, NRC General Letter [GL] 94-03, and NUREG-1544). No occurrence control systems exposed to sodium pentaborate solution has ever been reported (NUREG/CR-6001).

XI.M2 Water Chemistry 171

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B PWR Primary System: The primary pressure boundary Consistent with GALL AMP: Yes No piping of PWRs has generally not been found to be affected by Document(s) used to confirm Criteria:

SCC because of low dissolved oxygen levels and control of primary water chemistry. However, the potential for SCC exists due to inadvertent introduction of contaminants into the primary coolant system from unacceptable levels of Comment:

contaminants in the boric acid; introduction through the free surface of the spent fuel pool, which can be a natural collector of airborne contaminants; or introduction of oxygen during cooldown (NRC IN 84-18). Ingress of demineralizer resins into the primary system has caused IGSCC of Alloy 600 vessel head penetrations (NRC IN 96-11, NRC GL 97-01).

Inadvertent introduction of sodium thiosulfate into the primary system has caused IGSCC of steam generator tubes. The SCC has occurred in safety injection lines (NRC INs 97-19 and 84-18), charging pump casing cladding (NRC INs 80-38 and 94-63), instrument nozzles in safety injection tanks (NRC IN 91-05), and safety-related SS piping systems that contain oxygenated, stagnant, or essentially stagnant borated coolant (NRC IN 97-19). Steam generator tubes and plugs and Alloy 600 penetrations have experienced primary water stress corrosion cracking (PWSCC) (NRC INs 89-33, 94-87, 97-88, 90-10, and 96-11; NRC Bulletin 89-01 and its two supplements).

C PWR Secondary System: Steam generator tubes have Consistent with GALL AMP: Yes No experienced ODSCC, IGA, wastage, and pitting (NRC I Document(s) used to confirm Criteria:

N 97-88, NRC GL 95-05). Carbon steel support plates in steam generators have experienced general corrosion. The steam generator shell has experienced pitting and stress corrosion cracking (NRC INs 82-37, 85-65, and 90-04). Comment:

XI.M2 Water Chemistry 172

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

XI.M2 Water Chemistry 173

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B3.1 Electrical Equipment Qualification Program This AMP requires auditing against the following GALL AMP:

X.E1 Environmental Qualification (EQ) Of Electric Components X.E1 Environmental Qualification (EQ) of Electric Components 174

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B3.1 Electrical Equipment Qualification Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: X.E1 Environmental Qualification (EQ) Of Electric Components PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A The 10 CFR 50.49 defines the scope of components to be Consistent with GALL AMP: Yes No included requires the preparation and maintenance of a list of Document(s) used to confirm Criteria:

Program Description in-scope components Comment:

B Requires the preparation and maintenance of a qualification Consistent with GALL AMP: Yes No file that includes component performance specifications, Document(s) used to confirm Criteria:

electrical characteristics, and the environmental conditions to which the components could be subjected Comment:

C The 10 CFR 50.49(e)(5) contains provisions for aging that Consistent with GALL AMP: Yes No require, in part, consideration of all significant types of aging Document(s) used to confirm Criteria:

degradation that can affect component functional capability Comment X.E1 Environmental Qualification (EQ) of Electric Components 175

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING D The 10 CFR 50.49(e) also requires replacement or Consistent with GALL AMP: Yes No refurbishment of components not qualified for the current Document(s) used to confirm Criteria:

license term prior to the end of designated life, unless additional life is established through ongoing qualification Comment E The 10 CFR 50.49(k) and (l) permit different qualification Consistent with GALL AMP: Yes No criteria to apply based on plant and component vintage. Document(s) used to confirm Criteria:

Supplemental EQ regulatory guidance for compliance with these different qualification criteria is provided in the DOR Guidelines, Guidelines for Evaluating Environmental Qualification of Class 1E Electrical Equipment in Operating Comment Reactors; NUREG-0588, Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment; and Regulatory Guide 1.89, Rev. 1, Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants.

F Important attributes for the reanalysis of an aging evaluation Consistent with GALL AMP: Yes No include analytical methods, data collection and reduction Document(s) used to confirm Criteria:

methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met).

Comment G Generic Safety Issue (GSI) 168, which is related to low- Consistent with GALL AMP: Yes No voltage EQ instrumentation and control cables, is currently an Document(s) used to confirm Criteria:

open generic issue. NRC research is ongoing to provide information to resolve it. An applicant is to address GSI-168 in its application for staff review.

Comment A Reanalysis of an aging evaluation to extend the qualification Consistent with GALL AMP: Yes No of a component is performed on a routine basis pursuant to 10 Document(s) used to confirm Criteria:

EQ Component CFR 50.49(e) as part of an EQ program.

Reanalysis Attributes Comment X.E1 Environmental Qualification (EQ) of Electric Components 176

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING B The analytical models used in the reanalysis of an aging Consistent with GALL AMP: Yes No evaluation are the same as those previously applied during the Document(s) used to confirm Criteria:

prior evaluation.

Comment:

C For license renewal, one acceptable method of establishing Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

the 60-year normal radiation dose is to multiply the 40-year normal radiation dose by 1.5 (that is, 60 years/40 years). The result is added to the accident radiation dose to obtain the total integrated dose for the component.

Comment D Temperature data used in an aging evaluation is to be Consistent with GALL AMP: Yes No conservative and based on plant design temperatures or on Document(s) used to confirm Criteria:

actual plant temperature data.

Comment E plant temperature data can be obtained in several ways, Consistent with GALL AMP: Yes No including monitors used for technical specification compliance, Document(s) used to confirm Criteria:

other installed monitors, measurements made by plant operators during rounds, and temperature sensors on large motors (while the motor is not running).

Comment F A representative number of temperature measurements are Consistent with GALL AMP: Yes No conservatively evaluated to establish the temperatures used in Document(s) used to confirm Criteria:

an aging evaluation.

Comment X.E1 Environmental Qualification (EQ) of Electric Components 177

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING G Plant temperature data may be used in an aging evaluation Consistent with GALL AMP: Yes No in different ways, such as (a) directly applying the plant Document(s) used to confirm Criteria:

temperature data in the evaluation, or (b) using the plant temperature data to demonstrate conservatism when using plant design temperatures for an evaluation.

Comment H Any changes to material activation energy values as part of Consistent with GALL AMP: Yes No a reanalysis are to be justified on a plant-specific basis. Document(s) used to confirm Criteria:

Comment I Similar methods of reducing excess conservatism in the Consistent with GALL AMP: Yes No component service conditions used in prior aging evaluations Document(s) used to confirm Criteria:

can be used for radiation and cyclical aging.

Comment J When unexpected adverse conditions are identified during Consistent with GALL AMP: Yes No operational or maintenance activities that affect the normal Document(s) used to confirm Criteria:

operating environment of a qualified component, the affected EQ component is evaluated and appropriate corrective actions are taken, which may include changes to the qualification bases and conclusions. Comment K If the qualification cannot be extended by reanalysis, the Consistent with GALL AMP: Yes No component is to be refurbished, replaced, or requalified prior to Document(s) used to confirm Criteria:

exceeding the period for which the current qualification remains valid. A reanalysis is to be performed in a timely manner (that is, sufficient time is available to refurbish, replace, or requalify the component if the reanalysis is Comment unsuccessful).

X.E1 Environmental Qualification (EQ) of Electric Components 178

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

1. Scope of Program A EQ programs apply to certain electrical components that Consistent with GALL AMP: Yes No are important to safety and could be exposed to harsh Document(s) used to confirm Criteria:

environment accident conditions, as defined in 10 CFR 50.49.

Comment

2. Preventive Actions: A The 10 CFR 50.49 does not require actions that prevent Consistent with GALL AMP: Yes No aging effects. Document(s) used to confirm Criteria:

Comment:

3. Parameters A EQ component qualified life is not based on condition or Consistent with GALL AMP: Yes No Monitored/Inspected: performance monitoring. Document(s) used to confirm Criteria:

Comment:

4. Detection of Aging A The 10 CFR 50.49 does not require the detection of aging Consistent with GALL AMP: Yes No Effects: effects for in-service components. Document(s) used to confirm Criteria:

Comment:

5. Monitoring and A The 10 CFR 50.49 does not require monitoring and trending Consistent with GALL AMP: Yes No Trending: of component condition or performance parameters of in- Document(s) used to confirm Criteria:

service components to manage the effects of aging.

Comment:

X.E1 Environmental Qualification (EQ) of Electric Components 179

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

6. Acceptance Criteria: A 10 CFR 50.49 acceptance criteria are that an inservice EQ Consistent with GALL AMP: Yes No component is maintained within the bounds of its qualification Document(s) used to confirm Criteria:

basis, including (a) its established qualified life and (b) continued qualification for the projected accident conditions.

Comment:

B When monitoring is used to modify a component qualified Consistent with GALL AMP: Yes No Document(s) used to confirm Criteria:

life, plant-specific acceptance criteria are established based on applicable 10 CFR 50.49(f) qualification methods.

Comment:

7. Corrective Actions: Not reviewed by RLEP-B project team N/A

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

10. Operating A EQ programs include consideration of operating experience Consistent with GALL AMP: Yes No Experience: Document(s) used to confirm Criteria:

to modify qualification bases and conclusions, including qualified life. Compliance with 10 CFR 50.49 provides reasonable assurance that components can perform their intended functions during accident conditions after experiencing the effects of inservice aging. Comment:

X.E1 Environmental Qualification (EQ) of Electric Components 180

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

X.E1 Environmental Qualification (EQ) of Electric Components 181

PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B3.2 Fatigue Monitoring Program This AMP requires auditing against the following GALL AMP:

X.M1 Metal Fatigue of Reactor Coolant Pressure Boundary X.M1 Metal Fatigue of Reactor Coolant Pressure Boundary 182

AUDIT WORKSHEET GALL REPORT AMP PLANT: Palisades Nuclear Plant (PNP)

LRA AMP: B3.2 Fatigue Monitoring Program REVIEWER: ______________________

DATE: __________________________

GALL AMP: X.M1 Metal Fatigue of Reactor Coolant Pressure Boundary PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING A In order not to exceed the design limit on fatigue usage, the Consistent with GALL AMP: Yes No Program Description aging management program (AMP) monitors and tracks the Document(s) used to confirm Criteria:

number of critical thermal and pressure transients for the selected reactor coolant system components.

Comment:

B AMP addresses the effects of the coolant environment on Consistent with GALL AMP: Yes No component fatigue life by assessing the impact of the reactor Document(s) used to confirm Criteria:

coolant environment on a sample of critical components that includes, as a minimum, those components selected in NUREG/CR-6260.

Comment:

C The sample of critical components can be evaluated by Consistent with GALL AMP: Yes No applying environmental correction factors to the existing ASME Document(s) used to confirm Criteria:

Code fatigue analyses. Formulas for calculating the environmental life correction factors are contained in NUREG/CR-6583 for carbon and low-alloy steels and in NUREG/CR-5704 for austenitic stainless steels. Comment:

X.M1 Metal Fatigue of Reactor Coolant Pressure Boundary 183

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING D As evaluated below, this is an acceptable option for Consistent with GALL AMP: Yes No managing metal fatigue for the reactor coolant pressure Document(s) used to confirm Criteria:

boundary, considering environmental effects. Thus, no further evaluation is recommended for license renewal if the applicant selects this option under 10 CFR 54.21(c)(1)(iii) to evaluate metal fatigue for the reactor coolant pressure boundary. Comment:

1. Scope of Program: A The program includes preventive measures to mitigate Consistent with GALL AMP: Yes No fatigue cracking of metal components of the reactor coolant Document(s) used to confirm Criteria:

pressure boundary caused by anticipated cyclic strains in the material.

Comment

2. Preventive Actions: A Maintaining the fatigue usage factor below the design code Consistent with GALL AMP: Yes No limit and considering the effect of the reactor water Document(s) used to confirm Criteria:

environment, as described under the program description, will provide adequate margin against fatigue cracking of reactor coolant system components due to anticipated cyclic strains.

Comment:

3. Parameters A The program monitors all plant transients that cause cyclic Consistent with GALL AMP: Yes No Monitored/Inspected: strains, which are significant contributions to the fatigue usage Document(s) used to confirm Criteria:

factor. The number of plant transients that cause significant fatigue usage for each reactor coolant pressure boundary component is to be monitored.

Comment:

B Alternatively, more detailed local monitoring of the plant Consistent with GALL AMP: Yes No transient may be used to compute the actual fatigue usage for Document(s) used to confirm Criteria:

each transient.

Comment:

X.M1 Metal Fatigue of Reactor Coolant Pressure Boundary 184

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

4. Detection of Aging A The program provides for periodic update of the fatigue Consistent with GALL AMP: Yes No Effects: usage calculations. Document(s) used to confirm Criteria:

Comment:

5. Monitoring and A The program monitors a sample of high fatigue usage Consistent with GALL AMP: Yes No Trending: Document(s) used to confirm Criteria:

locations. As a minimum, this sample is to include the locations identified in NUREG/CR-6260.

Comment:

6. Acceptance Criteria: A Maintain the fatigue usage below the design code limit Consistent with GALL AMP: Yes No considering environmental fatigue effects. Document(s) used to confirm Criteria:

Comment:

7. Corrective Actions: A Acceptable corrective actions include a more rigorous Consistent with GALL AMP: Yes No analysis of the component to demonstrate that the design code Document(s) used to confirm Criteria:

limit will not be exceeded, repair, or replacement of the component. For programs that monitor a sample of high fatigue usage locations, corrective actions include a review of additional affected reactor coolant pressure boundary Comment:

locations.

8. Confirmation Process: Not reviewed by RLEP-B project team N/A

9. Administrative Not reviewed by RLEP-B project team N/A Controls:

X.M1 Metal Fatigue of Reactor Coolant Pressure Boundary 185

PROGRAM ELEMENT AUDITABLE GALL CRITERIA DOCUMENTATION OF AUDIT FINDING

10. Operating A The program reviews industry experience regarding fatigue Consistent with GALL AMP: Yes No Experience: cracking. Applicable experience with fatigue cracking is to be Document(s) used to confirm Criteria:

considered in selecting the monitored locations.

Comment:

X.M1 Metal Fatigue of Reactor Coolant Pressure Boundary 186

EXCEPTIONS Item Program Elements LRA Exception Description Basis for Accepting Exception Documents Reviewed Number (Identifier, Para.# and/or Page #)

1.

2.

ENHANCEMENTS Item Program Elements LRA Enhancement Basis for Accepting Documents Reviewed Number Description Enhancement (Identifier, Para.# and/or Page #)

1.

2.

Document Reviewed During Audit:

DOCUMENT NUMBER IDENTIFIER (NUMBER) TITLE REVISION AND/OR DATE 1.

2.

3.

4.

X.M1 Metal Fatigue of Reactor Coolant Pressure Boundary 187

Palisades Nuclear Plant Audit and Review Plan - DRAFT Appendix F Plant-Specific AMP Audit/Review Worksheets

Palisades Nuclear Plant Audit and Review Plan - DRAFT Appendix F Plant-Specific AMP Audit/Review Worksheets There are no plant-specific AMPs assigned to the project team, therefore, no worksheets are provided.

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Palisades Nuclear Plant Audit and Review Plan - DRAFT Appendix G AMR Comparison Worksheets

PNP AMR Component (Table 1) Worksheet Audit Date:

Unit: Table No.: Chapter:

Auditor Name(s) :

The audit team verified that items in Table 3.x.1 (Table 1) correspond to items in the GALL Volume 1, Table X. All items applicable to PWRs in Table 1 were reviewed and are addressed in the following table.

Item Further Evaluation Discussion No. Recommended Audit Remarks (Document all questions for the applicant here):

No. Question for applicant (draft per RAI guidance) Response (with date)

References/Documents Used:

1.

2.

3.

4.

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PNP AMR MEAP Comparison (Table 2) Worksheet Audit Date:

Unit: Table No.: Chapter:

Auditor Name(s) :

Line items to which Notes A, B, C, D, and E are applied or for which a precedent was cited (except for those assigned to DE) were reviewed for: 1) consistency with NUREG-1801, Volume 2 tables, and 2) adequacy of the aging managing programs. All items in the Table 2 of the system named above are acceptable with the exception of items in boldface type. (Reviewers need not duplicate information in the 2nd-5th columns that are reflected in the discussion/draft audit report.)

LRA Page Component Aging No. Type Material Environment Effect Note Discussion (draft as Audit Report input)

Audit Remarks (Document all questions for the applicant here):

No. Question for applicant (draft per RAI guidance) Response (with date)

References/Documents Used:

5.

6.

7.

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Palisades Nuclear Plant Audit and Review Plan - DRAFT Appendix H Acronyms, Abbreviations, and Initialisms

Palisades Nuclear Plant Audit and Review Plan - DRAFT Appendix H Acronyms, Abbreviations, and Initialisms ADAMS Agencywide Documents Access and Management System AMP aging management program AMR aging management review ASME American Society of Mechanical Engineers BTP Branch Technical Position CLB current licensing basis DE Division of Engineering DIPM Division of Inspection Program Management EPRI Electric Power Research Institute FSAR final safety analysis report GALL Generic Aging Lessons Learned ISG interim staff guidance ISL Information Systems Laboratories, Inc.

LRA license renewal application NEI Nuclear Energy Institute NMC Nuclear Management Company NRC U.S. Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation PNP Palisades Nuclear Plant RAI request for additional information RLEP-B License Renewal and Environmental Impacts Program, Section B RLSB License Renewal and Standardization Branch SC structures and components SER safety evaluation report SRP-LR Standard Review Plan-License Renewal SSC structures, systems, and components H-1