ML063050504

Email: (PA-LR) FW: Word Document of NRC LRA Programs Audit of Pilgrim

ML063050504
Person / Time
Site:	Pilgrim
Issue date:	06/02/2006
From:	Ford B Entergy Corp
To:	Subbaratnam R NRC/NRR/ADRO
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.rd - FW: Word Document of NRC LRA Programs Audit of Pilgrim Page 1]

From: "Ford, Bryan" <BFord@entergy.com>

To: <rxs2 @nrc.gov>

Date: 6/2/2006 4:17:03 PM

Subject:

FW: Word Document of NRC LRA Programs Audit of Pilgrim FYI Bryan Ford 508-830-8403 From: Ellis, Douglas Sent: Thursday, June 01, 2006 3:20 PM To: 'jad@nrc.gov' Cc: Ford, Bryan; Lach, David J; Mogolesko, Fred; Ellis, Douglas

Subject:

Word Document of NRC LRA Programs Audit of Pilgrim Jim - as you requested, find attached the MS Word document of the database questions and responses from the NRC Programs Audit last week.

Douglas Ellis, Pilgrim Licensing, 508.830.8160.

MaTilmp\(

E o o i 4 7 "3.)MP Page 1l1 Mail Envelope Properties (44809CB7.41F: 19: 13343)

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NRC LRA ProgramsAudit of PNPS Number Status Request Response NRC Auditor PNPS Lead 137 Closed [B.1.1-W-01, Boraflex As stated in LRA Section B.1.1, the Boraflex Wen, Peter Potts, Lori Monitoring] Monitoring Program is consistent with NUREG-1801,Section XI.M22 with no

1. "The program relies on exceptions. Thus, the Boraflex Monitoring periodic inspection of the Program monitors all of these parameters.

Boraflex, monitoring of silica levels in the spent fuel pool water, and analysis of criticality to assure that the required 5% subcriticality margin is maintained."

For Boraflex Monitoring Program, the GALL Report identifies parameters to be monitored including: physical conditions of the Boraflex panels, such as gap formation and decreased boron area density, and the concentration of the silica in the spent fuel pool. Does applicant's Boraflex Monitoring Program monitor all of these parameters, especially, the areal density measurement?

Thursday, June 1, 2006 Page I of 82

Number Status Request Response NRC Audiitor PNPS Lead 138 Accepted [B.1.1-W-02, Boraflex LRA Section 8.1.1, Operating Experience, will be Wen, Peter James, Gary Monitoring] revised to the paragraphs below to clarify that reactivity calculations performed after direct

2. In the Operating Experience material surveillance (blackness testing) using Section, PNPS implies that the bounding assumptions with regard to neutron required 5% subcritically margin attenuation capability of the Boraflex was demonstrated through the demonstrated that the 5% subcriticality margin gap measurement. Please is maintained.

provide details how the results of gap measurement This requires an amendment to the LRA.

demonstrated that the 5%

subcritically margin is Blackness testing was performed on Boraflex maintained. panels inthe spent fuel storage racks during 1996 and 1998 to provide a baseline for development of the monitoring program.

Results of the 1996 testing showed shrinkage and gapping in the Boraflex. Analysis of the criticality design of the fuel pool based on the 1996 blackness test used bounding assumptions with regard to neutron attenuation capability of the Boraflex based on the observed gap sizes and locations and assumed levels of Boraflex erosion (thinning and edge loss). The analysis showed that the pool subcriticality margin was greater than 5%. Results of the 1998 testing showed about a 20% increase in average gap size, but overall shrinkage (gaps and end shortening) of the material was much less on a percentage change basis and was bounded by the criticality analysis assumptions. The report concluded that the Boraflex poison material in the spent fuel storage racks continues to perform its intended function.

The Boraflex Monitoring Program (with areal density measurement) at PNPS has been instituted recently. Therefore, there is no additional plant-specific operating experience.

Thursday, June 1, 2006 Page 2 of 82

Number Status Request Response NRC Auditor PNPS Lead 139 Closed [B.1.1-W-03, Boraflex The RACKLIFE predictive model is used at Wen, Peter Potts, Lori Monitoring] PNPS. However, as the model is under development, the projected useful life of the

3. The applicant states in the Boraflex racks has not yet been determined.

LRA that its Boraflex Monitoring Corrective actions would be initiated iftest Program is consistent with the results find that the 5% subcriticality margin program described in GALL cannot be maintained because of current or Report Section XI.M22, projected degradation. Corrective actions Boreflex Monitoring. In the consist of providing additional neutron-absorbing Detection of Aging Effects capacity by Boral or boron steel inserts, or program element, the GALL other options which are available to maintain a Report states that: subcriticality margin of 5%.

"The amount of boron carbides released from the Boraflex panel is determined through direct measurement of boron areal density and correlated with the levels of silica present with a predictive code. This is supplemented with detection of gaps through blackness testing and periodic verification of boron loss through areal density measurement techniques such as the BADGER device."

What predictive code is being used at PNPS? Based on the predictive code and trending of the SFP silica level what is the projected useful life of the 140 Accepted [B.1.1-W-04, Boraflex LRA Table 3.3.2-13 line items for neutron Wen, Peter Potts, Lori Monitoring] absorber aging effects "loss of material" and "cracking" will be changed to indicate that these

4. As indicated in Table aging effects are managed by the Water 3.3.2-13 of the LRA, PNPS Chemistry Control - BWR Program. The line identified that this AMP will be items will use note H, "Aging effect not in used in three line items (page NUREG-1 801 for this component, material and 3.3-131). These three line environment combination."

items include managing neutron absorber aging effects of "loss This requires an amendment to the LRA.

of material," "change in material properties," and "cracking." All these three line items reference GALL Report item VII.A2-2. However, the aging effect identified by the GALL Report (VII.A2-2) is only "reduction of neutron-absorbing capacity/ Boraflex degradation." Please explain the discrepancies.

Thursday, June 1, 2006 Page 3 of 82

Number Status Request Response NRC Auditor PNPS Lead 141 Accepted [B.1.3-D-01, BWR CRD Return The CRD Return Line weld overlay was Davis, Jim Harizi, Phil Line Nozzle Program] designed and installed in accordance with ASME Section XI Code Case N-504-2, "Alternate Rules

1. A structural weld overlay for Repair of Class 1, 2 and 3 Austenitic was applied over a through wall Stainless Steel Piping" and Code Case N-638, Crack in a 182/82 weld using "Similar and Dissimilar Metal Welding Using alloy 52 material without Ambient Temperature Machine GTAW Temper removing the flaw. What Bead Technique" and associated Relief Request regulatory basis was used to PRR-36 and PRR-38. Both code cases were install this overlay? How will approved for use in NRC Regulatory Guide this be handled during the 1.147, Revision 13. ASME Section Xl Code PEO? Case N-504-2 allows a repair to be performed by either removing the flaw or reducing it to an What is the regulatory basis for acceptable size. The weld overlay approach, by reducing the examination design, reduces the flaw to an acceptable size.

volume? The weld overlay assumes a flaw size through wall for 360 degrees around the component. The weld overlay is designed to structurally replace the cross-section of the underlying component such that no structural credit is taken for the remaining ligaments of the component.

Code Case N-504-2 is the basis for the design and implementation of the structural weld overlay repair method. Code Case N-638 is used for the application of the temper bead technique for repair welding of dissimilar metals using the GTAW process. Code Case N-638 provides the applicable procedure qualification requirements for welding with nickel-based alloys on a ferritic base metal, which in this case includes welding to both a P-No. 3 low alloy carbon steel nozzle and a P-No. 43 nickel-chrome alloy pipe cap.

It was necessary to take exceptions to the specific alloys described in the Code Case N-504-2 overlay repair method, which is based on the use of austenitic stainless steel alloys only. These specific exceptions are described in the Pilgrim Relief Request PRR-36.

Additionally, relief was requested, via Pilgrim Relief Request PRR-38, to use an alternative program for implementation of ASME XI Appendix VIII, Supplement 11 for ultrasonic examinations. The alternative program was implemented through the Performance Demonstration Initiative (PDI) program.

The CRD Return Line Nozzle N-10 weld overlay repair will continue to be inspected under the PNPS Inservice Inspection Program as a Category E weld in accordance with BWRVIP-75-A "Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedules" during PEO.

PNPS commits (Commitment #30) to perform a code repair of the CRD return nozzle to cap weld as needed if the installed overlay weld repair is not approved via accepted code cases, revised codes, or subsequent approval of relief requests.

The N-10 nozzle weld overlay was inspected to the maximum extent physically possible based on the geometric limitations of the nozzle and examination equipment used. The examination Thursday, June 1, 2006 Page 4 of 82

volume is based on the component wall Number Status Request Response NRC Auditor PNPS Lead thickness; weld overlay thickness and structural length required. The N-10 Nozzle wall thickness is 0.578" and the required thickness for the N-10 weld overlay was 0.20" with a required structural axial length of 1" either side of the flaw. Based on these dimensions, the required length of the examination volume would be approximately 1-1/2". The length of the applied weld overlay on either side of the flaw was 1-3/4" and therefore provided sufficient length to allow full volumetric examination of the overlay.

The reduced examination volume for the CRD Return Line Nozzle to Vessel Weld is described in the LRA Appendix B.1.3. This reduction of the inspection volume for the adjacent base metal is now in accordance with ASME Code Case N-613-1, which has been approved for use by the NRC in Regulatory Guide 1.147 Rev.

14, "Inservice Inspjection Code Case Acceptability, ASME Section XI, Division 1".

This LRA information will be updated to reflect the current status of this Code Case approval.

142 Closed [B.1.3-D-02, BWR CRD Return A Relief Request to use Code Case N-504-2 Davis, Jim Harizi, Phil Line Nozzle Program] for the CRD Return Line weld overlay was applied for and approved prior to startup of the

2. Was relief requested to use N-10 Nozzle repair outage. The Pilgrim Relief Code Case N-504-2 to do the Request, PRR-36, Entergy letter number weld overlay? What 2.03.120 requested that Alloys 152/52 be exceptions have you taken to allowed for weld overlay repair material and an Code Case -504-2? Do you alternate inspection plan be allowed in lieu of a meet the requirements for hydrostatic pressure test.

ASME Section XI non-mandatory Appendix Q? The CRD Return Line Nozzle weld overlay repair How will this be handled during was designed and installed in October of 2003 the period of extended in accordance with the 1989 edition of ASME operation (PEO) ? Section XI. ASME Section XI Non-Mandatory Appendix 0, "Weld Overlay Repair of Class 1, 2 and 3 Austenitic Stainless Steel Piping Weldments", was first published as part of the 2004 edition of ASME Section XI and therefore was not considered for the CRD Return Line Nozzle weld overlay modification.

The CRD Return Line Nozzle N-10"weld overlay repair will continue to be inspected under the PNPS Inservice Inspection Program as a Category E weld in accordance with BWRVIP-75-A "Technical Basis for Revisions to Generic Letter 88-01 Inspection Schedules" 143 Closed [B.1.4-D-1, BWR Feedwater The reduced volume inspection is in accordance Davis, Jim Finnin, Ron Nozzle Program] with ASME Code Case N-613-1, which has been endorsed by the NRC in Regulatory Guide

1. For this program what is the 1.147, "Inservice Inspection Code Case regulatory basis for reducing Acceptability, ASME Section XI, Division 1.."

the examination volume?

Thursday, June 1, 2006 Page 5 of 82

Number Status Request Response NRC Auditor PNPS Lead 144 Closed [B.1.5-J-01, BWR Penetrations] RFO-1 1 was conducted in the February - April Jackson, Wilbur Finnin, Ron 1997 timeframe (2/15 - 4/14/97)

1. LRA Appendix B.1.5 (BWR GE SIL 571 recommends that surface Penetrations) in the Operating examinations be performed on small bore nozzle Experience states that in safe end extensions fabricated from 304 January 2005 three 2.5" piping stainless steel. The SIL recommends that the butt welds in SLC system entire safe end extension piece including the piping [shop welds RPV-N14-T1 nozzle to safe end weld receive a surface and RPV-N14-T2 and field weld examination. The fabrication of the nozzle and RPV-14-2] were found'to be safe end extension assembly includes line unidentified on inspection boring of the nozzle/safe end extension drawings and not included in the assembly inner surfaces and machining of the ISI weld population totals. It outside surface to a flush condition. The also states that weld RPV-1 4-2 extensive cold working during fabrication can was included in surface sensitize the austenitic stainless steel extension examinations of the N14 nozzle piece such that IGSCC could occur in the base safe end weld and safe end metal of the safe end extension as well as the extension piece performed in weld heat affected zones. This machining also RFO11. It also states that prevents the nozzle to safe end weld transition corrective actions included from being easily detected by an inspector. To adding the welds to the ISI weld ensure that the entire nozzle to safe end population totals and extension piece and the nozzle to safe end weld performing a nozzle surface were examined in RFO1 1, ISI NDE inspectors examination of weld RPV-N14-2 were instructed by PNPS to perform a surface during RFO15. examination of the entire nozzle and safe end extension piece from the RPV outside wall out to QUESTION: the adjacent tee. As a result of this conservative approach, the RPV-N 14-2 weld When was RFO1 1? was included by default in the surface examination boundary.

Explain the apparent inconsistency that weld RPV-N14-2 was not included in the ISI weld population until RFO15, yet it was included in the N14 surface examinations of N14 nozzle safe end weld and safe end extension piece during RFO11.

Thursday, June 1, 2006 Page 6 of 82

Number Status Request Response NRC Auditor PNPS Lead 145 Closed [B.1.5-J-02, BWR Penetrations] Regarding the N15A/B nozzles, the makeup Jackson, Wilbur Finnin, Ron capacity size exclusion provision in ASME XI IWB-1220(a) exempts these nozzles from code

2. LRAAppendixB.1.5 (BWR inservice surface examinations.

Penetrations) under Exceptions states that "surface The N15A/B and N16A/B nozzles are also examinations are not performed excluded from the recommendations of GE SIL on instrument penetration 571 due to the replacement of the 304SS safe nozzle weld6." It further states end extensions with Inconel extensions in that inspections to monitor the RFO#7.

effects of cracking on the intended function of instrument BWRVIP-49 recommends that surface penetration nozzles (N15A/B examinations be performed per ASME XI and N16A/B) include enhanced IWB-2500 Category B-F requirements; however, visual (VT-2 with insulation Class 1 Category B-F and B-J welds at PNPS removed) examinations during are inspected in accordance with the PNPS ISI system pressure testing. It Program. This program selects welds for also states that a UT exam of examination based on a combined risk ranking the N16B safe end-to-reducer that considers the risk of failure and the weld is performed every 10 consequences of such a failure. This program years. However, ASME selected one weld out of the four welds at the Section XI, Table IWB-2500-1 N16A and B nozzles, specifically weld and BWRVIP-49 also RPV-N16B-R-2, for inspection. This weld was recommend surface ultrasonically examined during RFO1 5 in 2005 examinations. with no indications detected.

QUESTION: Additionally, when the predominant damage mechanism is an I.D. initiated one such as A surface examination is IGSCC in this case, there is no benefit to capable of finding indications performing a surface examination since the with potential for failure before component would already be leaking if the flaw a through-wall leak can occur. propagates to the surface. A liquid penetrant However, a VT-2 examination examination will not detect a subsurface flaw.

looks for signs of leakage. In this case, a VT-2 examination is the preferred Provide a more detailed examination as it is equivalent to a surface discussion and justification of exam in this case, but is less time-consuming why PNPS's AMP B.1.5, with and results in reduced radiation exposure to this exception, is adequate to inspection personnel.

manage the aging of these instrument nozzles during the An "enhanced" VT-2 examination is performed extended period of operation. with insulation removed as discussed in BWRVIP-27A, "BWR SBLC/Core Plate delta-P What is meant by the phrase Inspection and Flaw Evaluation Guidelines".

"enhanced visual ... Periodic code system leakage tests do not examinations"? Exactly what is require the removal of pipe insulation to perform the enhancement? VT-2 examinations for leakage. For partial penetration small bore nozzles such as the N15A/B, N16A/B and N14 nozzles, an enhanced VT-2 examination is more effective as it is more likely to detect leakage from a degraded partial penetration weld on the reactor vessel inner wall.

PNPS will continue to follow BWRVIP-27 guidelines during the period of extended operation including examinations in excess of code requirements for the N15A/B, N16A/B, and N14 nozzles.

Thursday, June 1, 2006 Page 7 of 82

- I Number Status Request Response NRC Auditor PNPS Lead 146 Closed [B.1.5-J-03, BWR Penetrations] 1. The N15A/B nozzles are exempted from code Jackson, Wilbur Finnin, Ron inservice examination by the makeup capacity size exclusion provision as allowed by ASME XI

3. LRA Appendix B.1.5 (BWR paragraph IWB-1220(a). The N15A/B nozzles are Penetrations) includes an subjected to steam conditions while the N16A/B "Exception Note" stating that and N14 nozzles are exposed to water service PNPS has implemented conditions. The makeup size exclusion risk-informed ISI (RI-ISI) in calculation for PNPS excludes steam piping with accordance with ASME Section an inside diameter less than 2.2 inches and XI, Code Case N-578. water piping with an inside diameter of less than 1.1 inches. The PNPS makeup size exclusion QUESTIONS: calculation does not use ECCS systems as a basis for the calculation.

1. Compare the number, type, frequency and extent of As stated in Table 3.1.2-1 of the LRA, cracking inspections required for of the instrumentation nozzles is managed by a instrument penetration nozzles combination of the BWR Water Chemistry N15A/B and N16A/B before Program and the BWR Penetrations Program.

implementation of RI-ISI and (Loss of material is managed by a combination after implementation of RI-ISI. of the BWR Water Chemistry and the Inservice Inspection Program). PNPS believes the existing combination of mitigation and

2. Are N15A/B and N16A/B the inspections, with the ASME Code exclusions only Pilgrim RPV instrument taken, provide acceptable aging management penetrations? for the period of extended operation for the following reasons.

3. Please make available at the audit a copy of ASME Section a. ASME Section XI IWB-2500, without XI, Code Case N-587. exclusion, requires a surface examination of these components. As the aging effects of interest originate on the ID wall (exposed to treated water >140 F), these surface examinations would only detect a flaw once the flaw propagated thru-wall. The surface examinations would not detect any flaws that were not thru-wall.

b. The ISI program includes inspection of welds of the same material/environment combinations as the welds within the BWR Penetrations Program. These inspections will provide information on the aging of the subject components. If any indications are found on the similar component inspections, sample expansion will lead to inspection of more similar locations and if appropriate to the actual components in question. Inspection of representative sample locations is acceptable to confirm the aging of the component/environment combination.

c. As discussed in Question 145, PNPS performs an enhanced VT-2 of these penetrations. The enhancement is that the insulation is removed from the penetrations so that the penetration and welds are viewed directly and specifically during the leak test, insuring the detection of even very small amounts of leakage from this penetration.

PNPS believes this is the most effective way to monitor the condition of these specific components. Given the code surface exams will only detect thru-wall failures from the ID, these inspections will find the same thru-wall flaws that the surface exams would find.

Separate table was provided to the inspector which shows N15 and N16 nozzle inspection history.

Thursday, June 1, 2006 Page 8 of 82

Number Status Request, Response NRC Auditor PNPS Lead

2. The only instrument partial-penetration weld nozzles at Pilgrim are the N15A/B, N16A/B and N14 (SBLC/Core dP) nozzles.

147 Closed [B.1.5-J-04, BWR Penetrations] Pilgrim is on Hydrogen Water Chemistry. Jackson, Wilbur Finnin, Ron Pilgrim has not used or requested relief for

4. GALL Program Description vessel internal components. The industry is XI.M8 (BWR Penetrations) currently waiting for the NRC SER on this states that an applicant may BWRVIP report which is being finalized by the use the guidelines of NRC BWRVIP-62 for inspection relief for vessel internal components with hydrogen water chemistry, provided that such relief is submitted under the provisions of 10 CFR 50.55a and approved by the staff.

QUESTIONS Has Pilgrim implemented hydrogen water chemistry?

Has Pilgrim requested and/or obtained inspection relief for vessel internal components using the guidelines of BWRVIP-62? If so, describe the details of the inspection relief requested and/or granted.

Thursday, June 1, 2006 Page 9 of 82

Number Status Request Response NRC Auditor PNPS Lead 148 Closed [B.1.5-J-05, BWR Penetrations] 1. The N16B nozzle safe end to reducer weld Jackson, Wilbur Finnin, Ron RPV-N16B-R-2 was ultrasonically examined in RFO15 per the 3rd Interval ISI Program Plan

5. For PNPS AMP B.1.5 (BWR and the PNPS Risk-Informed ISI Program.

Penetrations), the description Access was provided by the removal of the of the exception states that a N16B concrete shielding blocks which were UT exam of N16B safe replaced after the examination was completed.

end-to-reducer weld is The Inconel to 316 stainless steel weld was performed every 10 years. examined using Appendix VIII methods for For this same AMP, the dissimilar metal welds with full code coverage Operating Experience provides achieved during the exam. No recordable relatively recent (RFO15) indications were identified.

examination results for weld RPV-N14-2 (SLC nozzle) and 2. A summary table of inspections performed on for instrument penetration the N15 and N16 nozzles is included in the nozzles. The Operating response to Question B.1.5.3 above.

Experience also states that liquid penetranant examination Leakage was discovered during power operations of instrument penetration nozzle in 1986 at the socket weld on the 2 inch side of N15A in 1990 resulted in no the N16A nozzle safe end extension to reducer recordable indications. The (2xl) weld. A temporary sleeve repair was Operating Experience does not installed and all N15 and N16 safe end discuss results of the 10-year extensions were subsequently replaced with UT examinations of N16B safe Inconel extensions during the next outage in end-to-reducer weld. 1987.

QUESTIONS: The SBLC N14 nozzle to safe end weld RPV-N14-1 was included in the Class 1 weld

1. Discuss results of the inspection sample and received a PT 10-year UT examination of examination during the 3rd 10-year ISI interval N16B safe end-to-reducer weld. until the Risk-Informed ISI Program was implemented in 2001. This weld was not included in the risk-informed weld sample

2. For RPV-N14-2 and for population for examination. The weld received a instrument penetration nozzles, surface examination in both RFO1 1 and RFO15 discuss the history of with no indications detected. Since an adequate examination results that is ultrasonic procedure that allows depth sizing of earlier than RFO15. indications is not currently available, weld RPV-N1 4-1 is scheduled for a surface examination every two outages starting with RFO15 in accordance with BWRVIP-27A recommendations. Enhanced VT-2 examinations for leakage were performed on this weld in both RFO14 and RFO15. This schedule of an enhanced VT-2 every outage and surface examination every other outage will continue going forward at least until an adequate UT procedure is available.

SBLC nozzle safe end extension to tee weld RPV-N14-2 is examined for leakage with VT-2 methods during the Class 1 system pressure test during every outage as required by code at

• the close of each refueling outage.

Thursday, June 1, 2006 Page 10 of 82

Number Status Request Response NRC Auditor PNPS Lead 149 Closed [B.1.6-J.-01, BWR Stress 1. If cracking is detected in GL 88-01 Category Jackson, Wilbur Finnin, Ron Corrosion Cracking] A welds, the scope expansion rules of the PNPS Risk-Informed ISI Program in accordance with

1. The PNPS LRA states that EPRI Topical Report TR-1 12657 will be used to the implementing procedure for determine scope expansion size and content.

ASME Section XI inservice Scope expansion caused by cracking detected inspection and testing will be in any other GL 88-01 category (B through G) enhanced to specify that the will be determined by the scope expansion guidelines of Generic Letter criteria of BWRVIP-75A used in conjunction with 88-01 or approved BWRVIP-75 GL 88-01.

'shall be considered" in determining sample expansions 2. PNPS plans to use the scope expansion rules if indications are found in outlined in BWRVIP-75A and GL 88-01 for Generic Letter 88-01 welds: Category B through G welds. Ifcracking is detected in GL 88-01 Category A welds, the QUESTIONS: scope expansion rules of the PNPS Risk-Informed ISI Program in accordance with What is PNPS's current basis EPRI Topical Report TR-112657 will be used to for determining sample determine scope expansion size and content.

expansion if indications are found in GL 88-01 welds? Sample expansion addressed in section 2.5 of IGSCC report PNPS-RPT-05-008.

In addition the guidelines in Generic Letter 88-01 or approved BWRVIP-75, what other considerations, if any, will PNPS use in determining sample expansion if indications are found in Generic Letter 88-01 welds?

150 Closed [B.1.6-J-02, BWR Stress This information is available in LRPD-02 which Jackson, Wilbur Finnin, Ron Corrosion Cracking] was provided to the NRC at the beginning of the audit.

2. Make available at the audit, in both hard copy and electronic format, the documents that compare the ten elements of PNPS AMP B13.6 (BWR Stress Corrosion Cracking) to the ten elements of GALL AMP XI.M7 (BWR Stress Corrosion Cracking).

Thursday, June 1, 2006 Page I I of 82

Number Status Request Response NRC Auditor PNPS Lead 151 Closed [B.1.6-J-03, BWR Stress Copies were made available during the audit. Jackson, Wilbur Woods, Steve Corrosion Cracking]

Differences between paragraph IWB-3600 in the

3. LRA Appendix B.1.6 (BWR 1986 edition and the 1998 through 2000 addenda Stress Corrosion Cracking) are listed below:

identifies an Exception to NUREG-1801. The exception IWB-361 0 - The '98-2000 code has expanded is described as PNPS' use of this paragraph to include requirements for the 1998 edition with 2000 evaluating flaws in clad components.

addenda of ASME Section XI, Otherwise, no changes.

Subsection IWB-3600 for flaw evaluation, while NUREG-1801 IWB-3641.2 - The '98-2000 code differs slightly specifies the 1986 edition of from the '86 edition.

ASME Section XI, Subsection IWB-3600 for flaw evaluation. IWB3641.3 - The '98-2000 code differs slightly from the '86 edition.

QUESTIONS:

IWB-3650 - This is a new paragraph in the later Make available at the audit a code for evaluation procedures and acceptance copies of ASME Section XI, criteria for flaws in ferritic piping.

Subsection IWB-3600, the 1986 edition, and the 1998 edition Table IWB-3641 Notes under the table with 2000 addenda. have been expanded in the '98-2000 code.

Table data is the same.

Identify which specific subsections of IWB-3600 are Table IWB-3641 Notes under the table different between the 1986 have been expanded in the '98-2000 code.

edition and 1998 edition with Table data-is the same.

2000 addenda of ASME Section Xl. Table IWB-3641-5 - Table is deleted from

'98-2000 code.

Table IWB-3641-6 - Table is deleted from

'98-2000 code.

Thursday, June 1, 2006 Page 12 of 82

Number Status Request Response NRC Auditor PNPS Lead 152 Accepted [B.1.6-J-04, BWR Stress The enhancement, as stated in LRA Appendix B Jackson, Wilbur Finnin, Ron Corrosion Cracking] is 'The implementing procedure for ASME Section XI inservice inspection and testing will

4. The Standard Review Plan be enhanced to specify that the guidelines in for License Renewal Generic Letter 88-01 or approved BWRVIP-75 (NUREG-1800, Rev. 1), shall be considered in determining sample Section 3.1.2.4, FSAR expansion if indications are found in Generic Supplement, states that "The Letter 88-01 welds."

[summary] description [of the program in the FSAR See Item # 320 for resolution.

supplement] should ... contain any future aging management activities, including enhancements and commitments, to be completed before the period of extended operation."

PNPS LRA Appendix B.1.6 (BWR Stress Corrosion Cracking) identifies an enhancement to be initiated prior to the period of extended operation. The LRA states that

'The implementing procedure for ASME Section XI inservice inspection and testing will be enhanced to specify that the guidelines in Generic Letter 88-01 or Approved BWRVIP-75.

shall be considered in determining sample expansion if indications are found in Generic Letter 88-01 welds.

PNPS LRA UFSAR Supplement A.2.1.6 (BWR Stress Corrosion Cracking Program) does not include a description of the enhancement to PNPS' implementing procedure for ASME Section Xl inservice inspection.

QUESTION:

Include a description of the enhancement to PNPS' implementing procedure for ASME Section X1 inservice inspection in the UFSAR Supplement's description, A.2.1.6 (BWR Stress Corrosion Cracking Program).

Thursday, June 1, 2006 Page 13 of 82

Number Status Request Response NRC Auditor PNPS Lead 153 Closed [B.1.7-J-01, BWR Vessel ID PNPS follows the requirement of BWRVIP-48 Jackson, Wilbur Finnin, Ron Attachment Welds] (now BWRVIP-48-A) as approved by the NRC for inspections. These are:

1. For examination category B-N-2, ASME Section XI, Table - Jet pump riser brace - primary brace IWB 2500-1, specifies VT-1 attachments examinations for interior - Core Spray piping - primary bracket attachment welds within the attachments beltline region. It specifies - Steam dryer support brackets VT-3 examinations for interior attachment welds beyond the beltline region and for core support structure welds. The guidelines of BWRVIP-48 recommend more stringent inspections for certain attachments. Specifically, the guidelines recommend enhanced visual VT-1 examination of all safety-related attachments and those nonsafety-related attachments identified as being susceptible to IGSCC.

QUESTION:

Confirm that PNPS performs the more stringent inspections of applicable vessel ID attachment welds as recommended in BWRVIP-48.

Provide a descriptive list of the category B-N-2 vessel ID attachment welds that are inspected using the more stringent enhanced VT-1 examination techniques.

154 Closed [B.1.7-J-02, BWR Vessel ID PNPS plant procedures require that flaws be Jackson, Wilbur Finnin, Ron Attachment Welds] evaluated in accordance with BWRVIP Inspection and Flaw Evaluation Guidelines for

2. Confirm PNPS AMP B.1.7 components that perform a safety function.

(BWR Vessel ID Attachment Subsequent BWRVIP correspondence that has Welds) implements the been approved by the BWRVIP Executive evaluation guidelines of Committee must also be considered when BWRVIP-14, BWRVIP-59 and evaluating flaws. For components that do not BW RVI P-60 for evaluation of perform a safety function, flaw evaluation shall crack growth in stainless steel, be established by Design Engineering using the nickel alloys and low alloy Condition Report process. Any flaw evaluation steels, respectively. done by PNPS would consider all pertinent information available at that time, including the three BWRVIP documents identified in the question (and in NUREG-1801 Section XI.M4).

Thursday, June 1, 2006 Page 14 of 82

Number Status Request Response NRC Auditor PNPS Lead 155 Accepted [B.1.8-J-01, BWR Vessel As indicated in LRA Section B.1.8 under Jackson, Wilbur Finnin, Ron Internals] Enhancements, ten (10) percent of the top guide locations will be inspected using enhanced

1. The PNPS LRA states that visual inspection technique, EVT-1, within the top guide fluence is projected first 12 years of the period of extended to exceed the threshold for operation, with one-half of the inspections (50 IASCC prior to the period of percent of locations) to be completed within the extended period of operation. first 6 years of the period of extended The LRA states that PNPS operation. This enhancement will be revised to AMP B.1.8 (BWR Vessel require inspection of an additional 5% of the top Internals) will be enhanced to guide locations during the third 6 years of the inspect ten (10) percent of the period of extended operation.

top guide locations using enhanced visual inspection This enhancement is Item 3 of the PNPS technique, EVT-1, within the the commitments for license renewal.

first 12 years of the period of extended operation, with This requires an amendment to the LRA.

one-half of the inspections (50 percent of the locations) to be completed within the first 6 years of the period of extended operation.

QUESTIONS:

Describe PNPS's plans for inspection of top guide locations during the final 8 years of the twenty-year period of extended operation.

If no inspections are planned for the final 8 years of operation, provide a technical basis for not continuing inspection of top guide locations during this part of the period of extended operation.

Thursday, June 1, 2006 Page 15 of 82

Number Status Request Response NRC Auditor PNPS Lead 156 Accepted [B.1.8-J-02, BWR Vessel As stated in the letter submitting the license Jackson, Wilbur Finnin, Ron Internals] renewal application (letter number 2.06.003, dated 1/25/06), PNPS is committed to the

2. The Standard Review Plan programs listed in Appendix B, Section B.1 of for License Renewal the license renewal application. Enhancements (NUREG-1800, Rev. 1), to programs that are described in Appendix B of Section 3.1.2.4, FSAR the LRA are, therefore, commitments. To Supplement, states that "The facilitate tracking of the enhancements through

[summary] description [of the the NRC review process and facilitate program in the FSAR implementation once the renewed license is supplement] should ... contain received, a list of specific commitments for any future aging management license renewal has been developed. This list activities, including will be sent to the Staff under oath and enhancements and affirmation and will be supplemented as commitments, to be completed necessary during the NRC review process.

before the period of extended Both Appendix B of the LRA and the list of operation." commitments for license renewal include commitments to implement new programs and PNPS LRA Appendix B.1.8 commitments to enhance existing programs (BWR Vessel Internals before the period of extended operation.

Program) identifies an enhancement to be initiated Item 3 on the list of commitments for license prior to the period of extended renewal is the commitment to implement the operation. PNPS LRA UFSAR enhancement to PNPS AMP B.1.8.

supplement A.2.1.8 (BWR Vessel Internals Program) does See Item #320 for resolution.

not describe this enhancement.

QUESTION:

Include a description of the enhancement to PNPS' AMP B.1.8 in the UFSAR Supplement's description of of this program.

Thursday, June 1, 2006 Page 16 of 82

Number Status Request Response NRC Auditor PNPS Lead 157 Closed [B.1.8-J-03, BWR Vessel A copy of BWRVIP-26 including table 3.2 was Jackson, Wilbur Okas, Pete Internals] made available during the audit.

3. PNPS LRA Appendix B.1.8 (BWR Vessel Internals) identifies the following described exception to Scope of Program and Detection of Aging Effects: "Inspection of the four top guide hold-down assemblies and four top guide aligner assemblies is not performed at PNPS." An Exception Note states, "PNPS has a plant-specific analysis to account for plant-specific dynamic loading of the top guide hold-down and aligner assemblies, which concludes that less than 20% of the weld area on the top guide hold-down and aligner assemblies is needed to resist load.

Therefore, in accordance with Table 3.2 of BWRVIP-26, inspection of the four top guide hold-down assemblies and four top guide aligner assemblies is not performed at PNPS.

Questions:

Provide a staff-approved copy of BWRVIP-26, including Table 3.2, stating that inspection of the four top guide hold-down assemblies and four top aligners is not required if 20%

or less of the weld area is sufficient to resist vertical loads from the top guide during faulted events.

158 Closed [B.1.8-J-04, BWR Vessel The BWRVIP/ EPRI NDE center recently Jackson, Wilbur Okas, Pete Internals] acquired blade probes to demonstrate UT capability. Plans for 2007 are to develop a white

4. Provide a status summary paper to document the inspection capability to of current industry activities to examine the thermal sleeve welds. This project develop a delivery system for excludes tooling development as it is left to ultrasonic testing of the hidden inspection vendors.

welds in PNPS' core spray system.

159 Closed [B.1.8-J-05, BWR Vessel The BWRVIP/ EPRI NDE center recently Jackson, Wilbur Okas, Pete Internals] acquired blade probes to demonstrate UT capability. Plans for 2007 are to develop a white

5. Provide a status summary paper to document the inspection capability to of current industry activities to examine the thermal sleeve welds. This project develop a delivery system for excludes tooling development as it is left to ultrasonic testing of the hidden inspection vendors.

welds in PNPS' jet pump assemblies.

Thursday, June 1, 2006 Page 17 of 82

Number Status Request Response NRC Auditor PNPS Lead 160 Closed [B.1.8-J-06, BWR Vessel Core spray piping welds 1P5 and 3P5 in RF01 1, Jackson, Wilbur Okas, Pete Internals] and Steam dryer level screw tack welds in RFO7.

6. LRA Appendix B.1.8 (BWR Vessel Internals, Operating Corrective action for the Core Spray piping 1P5 Experience, states that and 3P5 UT weld UT indications that were found "Previous visual and enhanced in 1997 (RFO11) and re-examined in 1999 visual examinations of vessel consisted of the performance of flaw internals revealed indications evaluations that accounted for both crack on core spray piping welds, and growth and leakage considerations. The flaw steam dryer leveling screw evaluations found the 1P5 weld acceptable for tack welds." continued operation for five cycles (RFO17) and the 3P5 weld acceptable for another six cycles QUESTIONS: (RFO18).

When were the earlier Corrective action taken in 1987 (RFO7) for the indications on core spray piping cracked steam dryer leveling screw tack welds welds and steam dryer level consisted of a weld repair to the 35 and 215 screw tack welds found? degree azimuth screws. The two leveling screws were re-tacked in two places each per the What corrective actions were disposition detailed in Nonconformance Report taken?

161 Closed [B.1.8-J-07, BWR Vessel The PNPS BWR Vessel Internals program will Jackson, Wilbur Okas, Pete Internals] perform the more stringent inspections in the BWRVIP Inspection and Evaluation Guidelines

7. GALL Section XI.M9 (BWR approved by the NRC for referencing for Vessel Internals), Element 4 license renewal. Any exceptions to the (Detection of Aging Effects) approved BWRVIPs are discussed as states: 'The applicable and exceptions to NUREG-1801.

approved BWRVIP guidelines recommend more stringent Note that some of the specific BWRVIPs are inspections, such as enhanced considered part of sub-programs such as BWR VT-1 examinations or ultrasonic Penetrations, BWR Vessel ID attachment welds, methods of volumetric etc.; but all are implemented via the BWR inspection for certain selected Vessel Internals Program (NE 21.01) at the components and locations:" PNPS site.

QUESTION:

Confirm that PNPS AMP B.1.8 (BWR Vessel Internals) performs the more stringent inspections recommended in the applicable and approved BWRVIP guidelines, except as documented in PNPS LRA under the discussion of "Exceptions to NUREG-1801."

Thursday, June 1, 2006 Page 18 of 82

L. l Number Status Request Response NRC Auditor PNPS Lead 162 Closed [B.1.9-H-01, 10 CFR 50 The PNPS program utilizes Option B and the Hoang, Dan Ahrabli, Reza Appendix J (XI.S4)] guidance in NRC Regulatory Guide 1.163 and NEI 94-01. (Ref. Aging Management Program

1. The applicant is requested Evaluation Report LRPD-02, Section 4.8.B.5.b).

to address and discussion the During the most recent integrated leakage test Option related to this testing of primary containment performed in program. What and when was 1995, as-found and as-left test data met all the most significant experience applicable test acceptance criteria. QA audits in related to this program do you 2000 and 2005 revealed no issues or findings have? What was your that could impact effectiveness of the program.

corrective and preventive (Ref. LRA B.1.9) actions did you take? When will be your next "periodic During as-found local leak ratetesting in the late interval"? 1990s, the main steam isolation valves and feedwater check valves experienced test failures. The MSIVs were modified and refurbished to improve seat leakage performance. Preventive maintenance to replace the soft seats on the feedwater check valves each refueling outage has improved the seat leakage performance.

The current ILRT periodic interval is fifteen years (no later than May 25, 2010) based on License Amendment 213 to the PNPS Facility Operating License which allowed a five year 163 Accepted [B.1.10-P-01, Diesel Fuel As stated in LRA Section B.1.10, the security Pavinich, Wayne Potts, Lori Monitoring] diesel generator fuel storage tank is not periodically cleaned and inspected because the

1. Provide justification for not internals are inaccessible. The tank does not cleaning and visually inspecting have manways. This is acceptable because the the security diesel generator program enhancements described below will fuel storage tank on a periodic ensure that significant degradation is not basis. occurring.

One enhancement listed in LRA Section B.1.20 is for periodic sampling of the security diesel generator fuel storage tank, near the bottom, to determine water content.

The other enhancement listed in LRA Section B.1.10 is to include periodic UT measurement on the bottom surface of the security diesel generator fuel storage tank. However, engineering evaluation after submittal of the LRA determined that UT is not feasible for this tank due to geometry. Therefore, this enhancement will be revised to add instrumentation to monitor for leakage between the two walls of the tank. This modification will be installed prior to the period of extended operation.

Item # 5 on the list of commitments for license renewal is the commitment to install instrumentation to monitor for leakage between the two walls of the security diesel generator fuel storage tank.

Thursday, June 1, 2006 Page 19 of 82

Number Status Request Response NRC Auditor PNPS Lead 164 Closed [B.1.10-P-02, Diesel Fuel The Diesel Fuel Monitoring Program makes use Pavinich, Wayne Potts, Lori Monitoring] of the guidelines of ASTM D-2276 for determination of particulates in lieu of ASTM D-6217. ASTM D-2276 provides guidance

2. Provide justification for not on determining particulate contamination using a using all ASTM specifications. field monitor. It provides for rapid assessment of changes in contamination level without the time delay required for rigorous laboratory procedures. It also provides a laboratory filtration method using a 0.8 micron filter. ASTM D-6217 provides guidance on determining particulate contamination by sample filtration at an off-site laboratory. The acceptance criterion of D-2276 is 10 mg/liter while that of D-6217 is 24 mg/liter. Therefore, D-2276 criterion is more stringent than that of D-6217. Since ASTM D-2276 is an accepted method of determining particulates and is a method recommended by ASTM D-975, the D-2276 method'is used at PNPS.

165 Accepted [B.1.10-P-03, Diesel Fuel The enhancement is being revised to, "Enhance Pavinich, Wayne Potts, Lori Monitoring] the Diesel Fuel Monitoring Program to specify acceptance criterion for UT measurements of

3. Provide justification of the emergency diesel generator fuel storage tanks

"<= 60% of nominal thickness" (T-126A&B)." This enhancement is item # 6 on acceptance criterion. the list of commitments for license renewal and will be completed prior to the period of extended operation.

This requires an amendment to the LRA.

166 Closed [B.1.10-P-04, Diesel Fuel No, as described in the Aging Management Pavinich, Wayne Potts, Lori Monitoring] Program Evaluation Report, a periodic ultrasonic thickness (UT) measurement is performed on

4. Will all tank bottoms be the bottom surface of the underground subjected to 100% UT emergency diesel fuel oil storage tanks. During inspection? these inspections, UT measurements are made at several random locations on the bottom of these tanks.

167 Closed [B.1.10-P-05, Diesel Fuel In accordance with the corrective action Pavinich, Wayne Potts, Lori Monitoring] program, an engineering evaluation into the cause will be performed if test acceptance

5. If reduction of thickness is criteria are not met and corrective actions will be discovered during UT, will implemented, to ensure that the intended microbiological activity be function of the tanks can be maintained monitored and biocide added in consistent with the current licensing basis for the future? If not, provide a the period of extended operation. If appropriate justification for not doing so. to address the cause, biocide addition may be an element of the corrective action.

Thursday, June 1, 2006 Page 20 of 82

Number Status Request Response NRC Auditor PNPS Lead 168 Accepted [B.1.10-P-06, Diesel Fuel As stated in the letter submitting the license Pavinich, Wayne Potts, Lori Monitoring] renewal application (letter number 2.06.003, dated 1/25/06), PNPS is committed to the

6. NUREG-1800, SRP for programs listed in Appendix B, Section B.1 of license renewal, section the license renewal application. Enhancements 3.X.3.4, FSAR Supplement, to programs that are described in Appendix B of states the following: the LRA are, therefore, commitments. To facilitate tracking of the enhancements through As noted in Table 3.X-2, an the NRC review process and facilitate applicant need not incorporate implementation once the renewed license is the implementation schedule received, a list of specific commitments for into its FSAR. However, the license renewal has been developed. This list reviewer should confirm that will be sent to the Staff under oath and the applicant has identified and affirmation and will be supplemented as committed in the license necessary during the NRC review process.

renewal application to any Both Appendix B of the LRA and the list of future aging management commitments for license renewal include activities, including commitments to implement new programs and enhancements and commitments to enhance existing programs commitments to be completed before the period of extended operation.

before entering the period of extended operation. The staff Items 4, 5, and 6 on the list of commitments for expects to impose a license license renewal are the commitments to condition on any renewed implement the enhancements described in LRA license to ensure that the Section B.1.10 applicant will complete these activities no later than the Close to item #320.

committed date.

The enhancements identified in the B.1.10 write-up are not included in the FSAR Supplement Appendix A.2.1.10.

They should be in the UFSAR Supplement in order to address these commitments.

Thursday, June 1, 2006 Page 21 of 82

Number Status Request Response NRC Auditor PNPS Lead 169 Accepted [B.1.11-N-01, Environment PNPS may perform reanalysis of an aging Nguyen, Duc Stroud, Mike Qualification (EQ) of Electrical evaluation in order to extend the qualification of Components Program] electrical components under 10 CFR 50.49(e) on a routine basis as part of the plant's EQ

1. The results of the program.

environmental qualification of electrical equipment in LRA As described in NUREG-1801, rev. 1, important Section 4.4. indicate that the attributes for the reanalysis of an aging aging effects of the EQ of evaluation include analytical methods, data electrical equipment identified collection and reduction methods, underlying in the TLAA will be managed assumptions, acceptance criteria, and corrective during the extended period of actions.

operation under 10 CFR 54.21(c)(1)(iii). However, no LRA Appendix B.1.11 will be revised to include information is provided on the the following:

attribute of a reanalysis of an aging evaluation to extend the EQ Component Reanalysis Attributes qualification life of electrical The reanalysis of an aging evaluation is equipment identified in the normally performed to extend the qualification TLAA. The important attributes by reducing excess conservatism incorporated of a reanalysis are the in the prior evaluation. Reanalysis of an aging analytical methods, the data evaluation to extend the qualification of a collection and reduction component is performed on a routine basis methods, the underlying pursuant to 10 CFR 50.49(e) aspart of an EQ assumptions, the acceptance program. While a component life limiting criteria, and corrective actions. condition may be due to thermal, radiation, or Provide detail description on cyclical aging, the vast majority of component the important attributes of aging limits are based on thermal conditions.

reanalysis of an aging Conservatism may exist in aging evaluation evaluation of electrical parameters, such as the assumed ambient equipment identified in the temperature of the component, an unrealistically TLAA in the LRA or plant's low activation energy, or in the application of a basis document (under program component (de-energized versus energized). The description) to extend the reanalysis of an aging evaluation is qualification under .10 CFR documented according to the station's quality 50.49(e). assurance program requirements, which requires the verification of assumptions and conclusions. As already noted, important attributes of a reanalysis include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met). These attributes are discussed below.

Analytical Methods:

The analytical models used in the reanalysis of' an aging evaluation are the same as those previously applied during the prior evaluation.

The Arrhenius methodology is an acceptable thermal model for performing a thermal aging evaluation. The analytical method used for a radiation aging evaluation is to demonstrate qualification for the total integrated dose (that is, normal radiation dose for the projected installed life plus accident radiation dose). For license renewal, one acceptable method of establishing 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. For cyclical aging, a similar approach may be used. Other models may be justified on a case-by-case basis.

Data Collection and Reduction Methods:

Reducing excess conservatism in the component service conditions (for example, temperature, radiation, cycles) used in the prior Thursday, June 1, 2006 Page 22 of 82

Number Status Request Response NRC Auditor PNPS Lead aging evaluation is the chief method used for a reanalysis. Temperature data used in an aging evaluation is to be conservative and based on plant design temperatures or on actual plant temperature data. When used, plant temperature data can be obtained in several ways, including monitors used for technical specification compliance, other installed monitors, measurements made by plant operators during rounds, and temperature sensors on large motors (while the motor is not running). A representative number of temperature measurements are conservatively evaluated to establish the temperatures used in an aging evaluation. Plant temperature data may be used in an aging evaluation in different ways, such as (a) directly applying the plant temperature data in the evaluation, or (b) using the plant temperature data to demonstrate conservatism when using plant design temperatures for an evaluation. Any changes to material activation energy values as part of a reanalysis are to be justified on a plant-specific basis. Similar methods of reducing excess conservatism in the component service conditions used in prior aging evaluations can be used for radiation and cyclical aging.

Underlying Assumptions:

EQ component aging evaluations contain sufficient conservatism to account for most environmental changes occurring due to plant modifications and events. When unexpected adverse conditions are identified during operational or maintenance activities that affect the normal 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.

Acceptance Criteria and Corrective Actions:

The reanalysis of an aging evaluation could extend the qualification of the component. If the qualification cannot be extended by reanalysis, the component is to be refurbished, replaced, or re-qualified prior to 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 re-qualify the component if the reanalysis is unsuccessful.

Pilgrim utilizes a reanalysis methodology in accordance with 10 CFR 50.49(e) that applies the important attributes in the GALL Report as appropriate. Reanalysis of aging evaluations in accordance with 10 CFR 50.49(e) is an acceptable AMP for license renewal under option 10 CFR 54.21 (c)(1)(iii).

Thursday, June 1, 2006 Page 23 of 82

Number Status Request Response NRC Auditor PNPS Lead 170 Closed [B.1.11-N-02, Environment Under the EQ program, surveillance and Nguyen, Duc Das, Swapan Qualification (EQ) of Electrical maintenance activities are used to assure that Components Program] equipment is maintained within its qualification basis and qualified life. The program provides

2. PNPS B.1.11 under that equipment shall be replaced, refurbished or operating experience, you have re-qualified prior to exceeding its qualified life.

stated that the overall effectiveness of the EQ of The overall effectiveness of the Environmental electric components program is Qualification (EQ) of Electric Components demonstrated by the excellent Program is demonstrated by the excellent*

operating experience for operating experience for systems, structures, systems, structures, and and components in the program. The program components in the program. has been subject to periodic internal and external Discuss operating experience assessments that have resulted in program of the existing EQ program. improvement.

Show where an existing program has succeeded and The Environmental Qualification (EQ) of Electric where it has failed in identifying Components Program has been effective at aging degradation in a timely managing aging effects. The Environmental manner. Qualification (EQ) of Electric Components Program provides reasonable assurance that the effects of aging will be managed such that the applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

References:

ENN Engineering Assessment Report dated 3/1/01, and EQ Program Self-Assessment January 28, 2002 - February 01, 2002 171 Closed [B.1.12-P-01, Fatigue The referenced 4.2.6 is FSAR Section 4.2.6 not Patel, Erach Potts, Lori Monitoring] LRA.

1. FSAR Supplement section A.2.1.12 references section 4.2.6 for location of the transient cycles that are tracked by this program.

However, section 4.2.6 addresses RPV Axial Weld Failure Probability. Should section 4.3.1, Table 4.3-2 be referenced instead?

172 Closed [B.1.13.1-P-01, Fire Protection] The carbon dioxide fire protection system is Patel, Erach Potts, Lori required for insurance purposes but is not required to protect safety-related systems.

1. Provide justification why Therefore the carbon dioxide fire protection carbon dioxide fire suppression system has no intended functions for 10 CFR system is not subject to aging 54.4(a)(1) or 10 CFR 54.4(a)(3). Also, since the system does not contain liquid that could leak and cause physical interaction with safety-related components that could prevent satisfactory accomplishment of a safety function, it also has no intended functions for 10 CFR 54.4(a)(2).

173 Closed [B.1.13.1-P-02, Fire Protection] NUREG-1800, SRP for license renewal, Section Patel, Erach Potts, Lori A.1.2.3.4 states that Detection of Aging Effects (element 4) describes "when," "where," and

2. The exception taken for "how" program data are collected. Therefore, the element 4 about the inspection exception to inspection frequency for frequency for penetration seals penetration seals was applied to element 4.

should also apply to element 3 PNPS does not take exception to the for the same reason that it parameters to be monitored or inspected for applies to element 4. Justify penetration seals. Therefore, the exception why this exception doe not apply does not apply to element 3.

to element 3.

Thursday, June 1, 2006 Page 24 of 82

Number Status Request Response NRC Auditor PNPS Lead 174 Accepted [B. 1.13.1 -P-03, Fire Protection] As stated in the letter submitting the license Patel, Erach Potts, Lori renewal application (letter number 2.06.003, dated 1/25/06), PNPS is committed to the

3. The two enhancements - programs listed in Appendix B, Section B.1 of identified in B.1.13.1 write-up the license renewal application. Enhancements are not included in the FSAR to programs that are described in Appendix B of Supplement Appendix A.1.13. the LRA are, therefore, commitments. To NUREG-1800, SRP for license facilitate tracking of the enhancements through renewal, section 3.X.3.4, FSAR the NRC review process and facilitate Supplement, states the implementation once the renewed license is following: received, a list of specific commitments for license renewal has been developed. This list As noted in Table 3.X 2, an will be sent to the Staff under oath and applicant need not incorporate affirmation and will be supplemented as the implementation schedule necessary during the NRC review process.

into its FSAR. However, the Both Appendix B of the LRA and the list of reviewer should confirm that commitments for license renewal include the applicant has identified and commitments to implement new programs and committed in the license commitments to enhance existing programs renewal application to any before the period of extended operation.

future aging management activities, including Items 7 and 8 on the list of commitments for enhancements and license renewal are the commitments to commitments to be completed implement the enhancements described in LRA before entering the period of Section B.1.13.1.

extended operation. The staff expects to impose a license See Item #320 for closure for this Item.

condition on any renewed license to ensure that the applicant will complete these activities no later than the committed date.

The enhancements should be included in the Appendix A writeup.

Thursday, June 1, 2006 Page 25 of 82

Number Status Request Response NRC Auditor PNPS Lead 176 Accepted [B.1.13.2-P-la, Fire Water As stated in the letter submitting the license Patel, Erach Potts, Lori Systerii] renewal application (letter number 2.06.003, dated 1/25/06), PNPS is committed to the

1. NUREG-1800, SRP for programs listed in Appendix B, Section B.1 of license renewal, section the license renewal application. Enhancements 3.X.3.4, FSAR Supplement, to programs that are described in Appendix B of states the following: the LRA are, therefore, commitments. To facilitate tracking of the enhancements through As noted in Table 3.X 2, an the NRC review process and facilitate applicant need not incorporate implementation once the renewed license is the implementation schedule received, a list of specific commitments for into its FSAR. However, the license renewal has been developed. This list reviewer should confirm that will be sent to the Staff under oath and the applicant has identified and affirmation and will be supplemented as committed in the license necessary during the NRC review process.

renewal application to any Both Appendix B of the LRA and the list of future aging management commitments for license renewal include activities, including commitments to implement new programs and enhancements and commitments to enhance existing programs commitments to be completed before the period of extended operation.

before entering the period of extended operation. The staff Item 11 on the list of commitments for license expects to impose a license renewal is the commitment to implement the condition on any renewed enhancement for fire water system wall license to ensure that the thickness evaluations described in LRA Section applicant will complete these B.1.13.

activities no later than the committed date.

a) The enhancement for wall thickness evaluation of fire protection piping is identified in the Appendix A write-up in the present tense, meaning the inspections are being performed. However, the enhancement is addressed in the Appendix B write-up is in the future tense, meaning the inspections will be performed in the future (before the end of the current operating term).

The Appendix A write-up should be revised to address this future commitment.

Thursday, June 1, 2006 Page 26 of 82

Number Status Request Response NRC Auditor PNPS Lead 177 Accepted [B.1.13.2-P-lb, FireWater As stated in the letter submitting the license Patel, Erach Potts, Lori System] renewal application (letter number 2.06.003, dated 1/25/06), PNPS is committed to the NUREG-1800, SRP for license programs listed in Appendix B, Section B.1 of renewal, section 3.X.3.4, FSAR the license renewal application. Enhancements Supplement, states the to programs that are described in Appendix B of following: the LRA are, therefore, commitments. To facilitate tracking of the enhancements through As noted in Table 3.X 2, an the NRC review process and facilitate applicant need not incorporate implementation once the renewed license is the implementation schedule received, a list of specific commitments for into its FSAR. However, the license renewal has been developed. This list reviewer should confirm that will be sent to the Staff under oath and the applicant has identified and affirmation and will be supplemented as committed in the license necessary during the NRC review process.

renewal application to any Both Appendix B of the LRA and the list of future aging management commitments for license renewal include activities, including commitments to implement new programs and enhancements and commitments to enhance existing programs commitments to be completed before the period of extended operation.

before entering the period of extended operation. The staff Item 9 on the list of commitments for license expects to impose a license renewal is the commitment to implement the condition on any renewed enhancement to inspect hose reels for corrosion license to ensure that the described in LRA Section B.1.13.2.

applicant will complete these activities no later than the See Item #320 for closure for this Item.

committed date.

b) The enhancement for revising procedures to include inspections of hose reels for corrosion is not addressed in the Appendix A write-up. The Appendix A write-up should be revised to address this future commitment.

178 Closed [B.1.14-W-01, FAC] For the initial evaluation of data at PNPS a Wen, Peter Ivy, Ted screening of criteria of 0.875 of Tnominal is

1. How is the minimum used to determine whether locations require allowable wall thickness defined further evaluation. If below this screening in PNPS FAC program? criteria the wear, wear rate and remaining service life are calculated in accordance with ENN-DC-315 section 5.6. PNPS uses the term minimum acceptable wall thickness (Taccept) in the FAC program. The term minimum acceptable wall thickness is defined as the maximum value of Tmin or Tcrit where Tmin is the minimum required global wall thickness based on hoop stress and Tcrit is the minimum required wall thickness per code of construction required to meet all design loading conditions.

Taccept is used in the calculation of the remaining service life which determines whether the component may be returned to service.

These definitions can be found in ENN-DC-315 in section 3.0.

179 Closed [B.1.14-W-02, FAC] As described in LRPD-02 section B.5.b Wen, Peter Ivy, Ted CHECWORKS version 1.0F is being used at

2. The FAC program includes PNPS and PNPS is a member of the the use of a predictive code. CHECWORKS Users Group.

Does PNPS belong to EPRI's CHECWORKS Users Group (CHUG), and CHECWORKS is being used?

Thursday, June 1, 2006 Page 27 of 82

Number Status Request Response NRC Auditor PNPS Lead 180 Closed [B.1.14-W-03, FAC] From ENN-DC-315 rev. 1: Wen, Peter Ivy, Ted

3. If degradation is detected 5.9 DISPOSITION OF INSPECTION such that the measured wall RESULTS thickness is less than the [1] ...

predicted thickness, explain [2]

how the sample size is [3] If Tpred is = 0.875 Tnom Evaluate increased to bound the thinning for sample expansion (Reference section 5.12).

for the same inspection period.

5.12 SAMPLE EXPANSION (1] If a component is discovered that has a current or projected wall thickness less than the minimum acceptable wall thickness (Taccpt),

then additional inspections of identical or similar piping components in a parallel or alternate train shall be performed to bound the extent of thinning except as provided below. Reference section 5.12.2

[2] When inspections of components detects significant wall thinning and it is determined that sample expansion is required, the sample size for that line should be increased to include the following:

(a) Components within two diameters downstream of the component displaying significant wear or within two diameters upstream ifthe component is an expander or expanding elbow.

(b) A minimum of the next two most susceptible components from the relative wear ranking in the same train as the piping component displaying significant wall thinning.

(c) Corresponding components in each other train of a multi-train line with a configuration similar to that of the piping component 181 Closed [B.1.14-W-04, FAC] Portions of the Main Steam system (Plant Wen, Peter Bechen, Gerry Heating; Reactor Vessel Vent Lines; portions of

4. In the Program Description, the Feedwater System (Recirculation lines to the the applicant states that Condenser - Feedwater clean-up line to the condenser); Feedwater Heater Start-up vent "This program applies to lines; portions of RCIC; and Portions of HPCI safety-related and have been excluded. Inspections have been nonsafety-related carbon steel performed on some of these lines typically in components in systems response to operational issues such as valve containing high-energy fluids leakage or orifice degradation occurring such carrying two-phase or that there is flow in the line during normal single-phase high-energy fluid > operation.

2% of plant operating time."

In RFO14 and RFO15 the Feedwater recycle Which piping systems are line (FAC pt# 366) was inspected to verify that excluded from the FAC a leaking valve had not caused damage. The program scoping as a result of piping wall thickness was found to not have low operating time (i.e., < 2% of appreciably changed during the two inspections plant operating time)? Has any which provided evidence that significant wear of inspection ever been the piping had not and was not occurring. In performed to make sure that RFO15 the RCIC minimum flow bypass line there is no wear on these lines? (FAC pt# 376) was inspected due to suspected valve leak by and the downstream piping was found to show no significant wear based on wall thickness.

Thursday, June 1, 2006 Page 28 of 82

Number Status Request Response NRC Auditor PNPS Lead 182 Closed [B.1.14-W-05, FAC] 1. For example, in RFO14, FAC pt #319 and Wen, Peter Ivy, Ted pt# 371 (1st point "B" operating vent line) were Describe the experience of inspected and found below Taccept. This piping FAC program at PNPS and the was upgraded with chrome-moly. FAC pt# 128.2 ability of the inspection was inspected in RFO14 (Tscreen was less programs to detect wall thinning than required) and again in RFO15 to verify in a timely manner before the Tmin was not met. The issue is apparently due a intended function of piping low point on a socket weld and not FAC wear.

components has been lost: The affected piping is scheduled for replacement in RFO16.

1 Have components been identified that did not meet the Additionally, one of the 30" extraction steam minimum allowable wall lines to the 5th point heater was inspected in thickness prior to replacement RFO13 and found to have a hole in it and was or loss of pressure retaining repaired. This piping is inside the condenser.

capacity? Additional inspections were performed and general FAC degradation was noted on most of

2. What corrective actions the lines. The decision was made replace all of have been taken, and to what this piping with chrome-moly piping. The last of extent have these measures it is scheduled for replacement in RFO16.

been effective in eliminating or reducing the wall thinning? In RFO14 FAC pt# 307 was inspected and found to have a wall thickness less than Tscreen.

3. What changes to the Re-evaluation concluded the location was program have occurred to acceptable for operation thru RFO1 6. The ensure that aging effects due component is currently scheduled for to FAC have been re-inspection in RFO16 successfully managed?

2. Piping upgrade to FAC resistant material.

4. Provide evidence that the such as A335 Gr. P11 piping has been current aging management extremely effective in eliminating or reducing program has been effective to the loss of wall thickness. Additionally, in some successfully mitigate and cases, the degraded components have been detect wall thinning during the replaced in-kind. Measures also include:

time period addressed by the changing out leaking valves, changing out degraded restriction orifices, etc.

3. As documented in LRPD-05 section 4.1.14, a fleet wide procedure for the Entergy northeast plants has been developed that includes improvements based on industry and other Entergy Nuclear Northeast plant OE. For example, skid mounted piping is now included in the enhanced system susceptibility evaluation.

In addition, during RFO15, several FAC points were added to inspections, or re-inspected, in response to industry OE and the MIHAMA Japan failure.

4. As documented in LRPD-05 section 4.1.14, examinations between RFO13 and RFO14 and during RFO14 (April, 2003) and examinations between RFO14 and RFO15) and during RFO15 (April, 2005) detected 8 locations with decreased wall thickness. Of these 8 locations four were either replaced or repaired and the remainder were determined to be acceptable after reevaluation.

Thursday, June 1, 2006 Page 29 of 82

Number Status Request Response NRC Auditor PNPS Lead 183 Closed [B.1.15-P-01, Heat Exchanger This is a new program and the details have not Pavinich, Wayne Ivy, Ted Monitoring] yet been developed. In accordance with LRPD-02 sections 3.2.B.3 and 3.2.B.4, where

1. What method(s) will be used practical, eddy current inspections of to detect localized corrosion? shell-and-tube heat exchanger tubes will be Identify areas to be inspected performed to determine tube wall thickness.

and frequency of inspections Visual inspections will be performed on heat for localized corrosion. exchanger heads, covers and tube sheets where accessible to monitor surface condition for indications of loss of material such as areas where localized corrosion could occur (i.e.

stagnant/low flow areas). A potential approach for determining the inspection frequency would be that once the initial inspections are completed, the results would be used to determine the frequency to ensure that effects of aging are identified prior to loss of intended function. Inspection frequency will be dependent on the specific component operating parameters (process fluid, cooling medium, pressures, materials), maintenance history, licensing commitments, NEIL Loss Control Standards and OE.

184 Closed [B.1.15-P-02, Heat Exchanger A review of the specific component's Pavinich, Wayne Ivy, Ted Monitoring] mechanical design, environments, operating conditions and flow paths combined with its

2. Provide additional details maintenance history, and internal and external describing the methods that will OE will be used to determine the sample size be used establish sample size and frequency. The sample size will most likely and frequency. include peripheral tubes and areas within a particular heat exchanger that are more susceptible to wear, corrosion or damage, i.e.

adjacent to inlet/outlet nozzles and changes in flow direction and will consider industry best practices and EPRI recommendations. Once the initial inspections are completed, the results will be used to determine the frequency to ensure that effects of aging are identified prior to loss of intended function. Visual inspections of accessible heat exchangers will be performed on the same frequency as eddy current inspections.

185 Closed [B.1.15-P-03, Heat Exchanger Since this is a new program the details of data Pavinich, Wayne Ivy, Ted Monitoring] collection are not available. However, inspections will be performed either online or

3. Provide details on data during refueling outages (dependent on the collection. particular component). The data will be collected, analyzed and required actions taken at that time. The data will also be utilized for longer term trending and developing future action plans and will be maintained in accordance with site QA program requirements.

186 Closed [B.1.15-P-04, Heat Exchanger Because this is a new program exact details are Pavinich, Wayne Ivy, Ted Monitoring] not yet available. Wall thickness will be trended and projected to the next inspection.

4. Provide details describing Corrective actions will be taken if projections the methods to assess indicate that the acceptance criteria may not be remaining component life for met at the next inspection. Reference LRPD-02 loss of material using section 3.2.B.6. Trend information along with OE inspection results such that will be utilized to determine the remaining timely mitigative action can be component life.

made.

Thursday, June 1, 2006 Page 30 of 82

Number Status Request Response NRC Auditor PNPS Lead 187 Closed [B.1.15-P-05, Heat Exchanger The minimum acceptable tube wall thickness for Pavinich, Wayne Ivy, Ted Monitoring] each heat exchanger to be eddy current inspected will be established based upon a

5. Provide more details on how component specific engineering evaluation acceptance criteria will be based on code requirements, EPRI guidelines, established. and internal calculations. Wall thickness will be acceptable if greater than the minimum wall thickness for the component. The acceptance criterion for visual inspections of heat exchanger heads, covers and tubesheets will be no evidence of degradation that could lead to loss of function. If degradation is detected such that if not corrected it would lead to loss of intended function, a condition report will be written and the issue resolved in accordance with the. site corrective action program.

Reference LRPD-02 section 3.2.B.6 188 Closed [B.1.15-P-06, Heat Exchanger GL 89-13 requires inspection of one RBCCW Pavinich, Wayne Lane, Ken Monitoring] heat exchanger each refuel outage. Service water side inspections have resulted in some

6. Although this is a new minimal tube plugging and weld or belzona repair program, provide operating to washed out areas on the pass partition plate experience with respect to heat or tube sheet. Past inspections have also exchanger wall thinning and identified degraded gasket seating surfaces and other degradation resulting tube inlet sleeve erosion that have required from adherence to GL 89-13. repairs. The copper nickel tube degradation is typically due to internal erosion caused by material wedged in the tube and is random in location. There has also been external tube damage in the area impacted by the shell side inlet flow due to vibration. This particular OE is included in the Service Water Integrity Program (SWIP) B.1.28 since it is a heat exchanger in the scope of the SWIP and the OE confirms the effectiveness of the SWIP. In accordance with NEI 95-10 the review of operating experience is used to either confirm the effectiveness of an existing program or identify new site specific aging effects. For new programs such as the Heat Exchanger Monitoring Program B.1.15, applying this as OE is not required.

Thursday, June 1, 2006 Page 31 of 82

Number Status Request Response NRC Auditor PNPS Lead 189 Closed [B.1.16.1-H-01, COi] a. Torus supports and RPV stabilizer supports. Hoang, Dan Pardee, Rich The program document is PNPS-RPT--05-001.

1. Pilgrim AMP B.1.16.1 identifies that the Containment All torus supports, earthquake ties and upper Inservice Inspection (CII) drywell stabilizer supports are scheduled for program is a plant-specific examination during the PNPS 4th ten-year program encompassing the inspection interval.

requirements for the inspection of class MC. The applicant is b.Torus supports and RPV stabilizer supports.

requested to identify the The program document is PNPS-RPT-05-001.

document(s) that includes the evaluation of Pilgrim AMP All torus supports, earthquake ties and upper B.1.16.1 to include additional drywell stabilizer supports are currently MC supports. Please provide scheduled for examination during the PNPS 4th the following information related ten-year inspection interval. There are no other to: supports to add.

(a) Identify the MC supports c. These are under the ASME Section XI program that are currently included in and require VT-3 inspection.

the existing inspection program.

The Class MC supports at PNPS consist of 16 torus saddle supports, 4 torus earthquake ties (b) Identify the MC supports and 8 upper drywell stabilizers. The original [WE that will be added to the scope program at PNPS was developed in accordance of this inspection program for with the requirements ASME XI 1992 edition with the license renewal period. 1992 addenda after the IWE section of the code was mandated in 1996. This edition of the (c) Specify the current code did not require inspection of Class MC inspection program and supports. However, as a conservative describe the current inspection measure, PNPS included a sample of 25% of details for the MC supports the torus saddle supports, 25% of the that are identified in (b) above. earthquake ties, and 25% of the upper drywell stabilizers.

(d) Confirm that, all MC The current IWE Program at PNPS was supports will be included in the developed in accordance with the 1998 edition scope of this inspection with 2000 addenda of ASME XL. This code program for the extended edition requires that 100% of the Class MC period of operation. supports be examined during the ten year interval. Accordingly, all torus supports, earthquake ties and upper drywell stabilizer supports are currently scheduled for examination during the PNPS 4th ten-year inspection interval. The first examinations under the 4th interval IWE program will occur immediately prior to and during RFO1 6 in 2007.

The torus saddle supports and earthquake ties are accessible to inspection as they are located on the torus floor. Inspection of the upper drywell stabilizers requires the removal of bolted access hatches to perform the required visual inspections. These hatches constitute a portion of the primary containment pressure boundary and are tested in accordance with Appendix J requirements after each opening.

d. These are currently included in the 4Th interval ISI program which expires in June 2015.

The next interval will be updated and maintained as required by 10 CFR 50.55(a) and ASME Section requirements.

All torus supports, earthquake ties and upper drywell stabilizer supports continue to be examined in accordance with the PNPS IWE Program during the period of extended operation.

Thursday, June 1, 2006 Page 32 of 82

Number Status Request Response NRC Auditor PNPS Lead 190 Closed [B.1.16.1-H-02, CIlI] The condition discovered in 1999 involved two Hoang, Dan Pardee, Rich torus saddle support tie-down nuts. The anchor

2. The applicant is requested bolts themselves were not loose.

to identify and provide the Inspection frequency against The loose condition of the two torus saddle the AMP B.1.16.1. What is the support tie-down nuts was, discovered during a cause for "Loose" torus anchor scheduled PNPS ]WE Program visual bolt found in 1999? Are there examination of containment supports in 1999.

any other "loose and/or Nonconformance Report NCR 99-19 and degraded" situations identified? Problem Report PR 99.9102 were generated to document and investigate the condition.

Corrective actions included re-torquing the two Are there any Preventive loose tie-down nuts to 80 ft-lb and checking the Action for the Torus shell wall tightness of a sample of the remaining tie down (thin wall)? Provide an nuts. No other loose bolting conditions were examination details, acceptance identified. The tightness of the support tie-down criteria, qualifications, nuts is unrelated to torus anchor bolt tension as and documentation. the upper tie-down bolting connects the torus saddle support to the free upper end of the anchor bolt, and is not used to tension the anchor bolt to the concrete floor.

The cause of the two loose tie-down nuts found in 1999 may be indeterminate given the information available at this point in time.

Inadequate initial preload during installation of the torus saddle supports during the Torus Mark Icontainment modifications in 1980 is considered to be an unlikely cause due to the high level of QA oversight on the project which included direct OC inspection of anchor bolt installation and torquing process.

The loose bolting condition is not significant because the safety function of the torus saddle support tie-down bolting is to prevent vertical movement of the torus from a hydrodynamic event occurring during accident conditions. The 80 ft-lb torque for these nuts is intended to ensure the nuts remain in a flush condition with the saddle support bearing surface. As long as no gap exists between the tie-down nuts and the torus saddle support bearing surface, the support will perform the intended safety function. No gaps existed between the two loose nuts found in 1999 and saddle support surfaces.

In addition, unrelated to the condition discussed above, a corrosion assessment of torus saddle tiedown concrete anchor bolt assemblies was performed in 1999 and documented in supplier design document review form SUDDS/RF99-134. The assessment determined that ground water intrusion through the torus floor had not significantly degraded the tensile strength of the rock anchor bolts based on chemical testing of the groundwater.

PNPS monitors torus wall thickness via the inclusion of augmented UT thickness examinations in the PNPS IWE Program. These thickness examinations are performed at 8 locations distributed around the torus. Half of the inspections are performed at the torus vapor/water interface of the torus shell while the other half are performed at a location approximately halfway between the waterline and the lowest point on the torus shell. Torus shell thickness examinations are performed Thursday, June 1, 2006 Page 33 of 82

Number Status Request Response NRC Auditor PNPS Lead during each 40 month period (i.e. every other outage) while the plant is on-line. Comparison of UT results from 1999 and 2003 reveal no measurable change in wall thickness. These examinations will continue to be performed during the period of extended operation. The examinations are performed by qualified NDE technicians who are code certified to at least Level II in ultrasonic thickness measurement 191 Closed [B.1.16.1-H-03, Cll] Results of the IWE General Visual Walkdown Hoang, Dan Pardee, Rich performed during RFO14 are evaluated and

3. The applicant is requested dispositioned in Condition Report to address the results of the CR-PNP-2003-01618. Newly reported corrosion CII general walkdown of around the CRD penetrations at the 270 degree primary containment during azimuth at approximately 35 feet elevation in April 2003 (RFO 14) and found the drywell was re-checked visually by the IWE some surface corrosion in the Responsible/Design Engineer and found CRD penetration areas. What acceptable. This was characterized as surface were your corrective and corrosion that was not considered significant by preventive action? Did a Root the Responsible/Design Engineer. Since the Cause Analysis was determination was that the corrosion was performed? Please provide acceptable, no root cause analysis was your acceptance criteria, performed and no corrective or preventive qualification? And/or any other actions were required. Acceptance criteria for means to support your the General Visual Walkdown are detailed in conclusion? procedure PNPS 2.1.8.7 and Entergy Engineering Standard ENN-EP-S-001, Section 5.

Conditions listed as requiring evaluation include, in part, peeling, flaking, blistering, cracking, checking, absence of coating, and rusting of the containment coating.

Thursday, June 1, 2006 Page 34 of 82

Number Status Request Response NRC Auditor PNPS Lead 192 Closed [B.1.16.1-H-04, CII] PNPS performs desludging, inspection and Hoang, Dan Pardee, Rich coating repairs every other outage as part of the

4. The applicant is requested torus desludge project on torus below-water to address and discussion the surfaces in accordance with a Preventive Operating Experience in detail Maintenance (PM) task scheduled using the plant found in 1999, the below-water Master Surveillance Tracking Program (MSTP).

regions of all 16 torus bays as This task was performed most recently in the well as the drywell to torus vent 1999 and 2003 outages. During the 1999 outage areas. Did your scope (RFO1 2), [WE visual examinations were also expansion was required due to performed by certified divers in accordance with unacceptable found? Do you the PNPS IWE Program.

have any Preventive Actions to prevent it from further The 1999 [WE underwater visual examinations damaged and/or recur? If yes, revealed the approximately 80% of the surfaces why it's not including into this to be in fair good condition with sporadic coating program? defects (localized corrosion with pitting) identified in the remaining areas. Corrosion of the torus underwater surfaces is attributed to local zinc depletion in the zinc-rich protective coating. Pit depth measurements were taken and documented in the SG Pinney report and Problem Report PR 99.1345. All areas with pit depths measured at 0.032" and greater were recoated with a qualified coating. One pit exceeded the maximum allowable depth of 0.066 inches. This was determined to be a preservice gouge in the torus shell plate and was subsequently accepted by evaluation. None of the 1999 inspection results of torus underwater surfaces were considered significant (Ref. PR 99.1345 response). The current general corrosion rates determined from inspection data collected since 1991 will not result in pitting corrosion that would cause violating the general minimum wall thickness values for the torus shell by the end of the period of extended operation.

Preventive actions to prevent recurrence of pitting consists of coating repairs with qualified coatings and periodic inspections associated with the torus desludge project every other outage. The IWE VT-3 visual examination of submerged surfaces is also performed every 10 years in accordance with the PNPS IWE Program.

Augmented IWE visual examinations of selected portions of the drywell to torus vent system in 1999 revealed localized pitting due to degradation of the coating aggravated by standing water in the downcomer vent bowls (vent bowl drains had been cut and capped in a previousmodification for seismic considerations). The scope of the examinations was expanded to include all 8 vents. All pitting was evaluated and found to be acceptable. The surfaces were prepped and recoated with a qualified coating to prevent recurrence of the corrosion.

Thursday, June 1, 2006 Page 35 of 82

Number Status Request Response NRC Auditor PNPS Lead 193 Closed [B.1.16.1-H-05, CII] The drywell coolers are a continuous operating Hoang, Dan Ahrabli, Reza online system. Functional tests are not required

5. "The drywell coolers, because the system is constantly running and including the fans, with their the drywell temperature is maintained below the power and control system were tech spec limits:

tested during the pre-operational tests...". When LIMITING CONDITIONS FOR OPERATION was the last time this system 3.2 PROTECTIVE INSTRUMENTATION underwent a functional test? A H. Drywell Temperature justification for an additional 20 1. The drywell temperature shall be years is needed for the staff maintained within the following limits to review. when the reactor coolant temperature is above 212'F.

Above elevation 40' <=1 94°F Equal to or Below elevation 40' <=150°F SURVEILLANCE REQUIREMENTS 4.2 PROTECTIVE INSTRUMENTATION H. Drywell Temperature

1. When reactor coolant temperature is above 212°F, the drywell air temperature limits will be determined by reading the instruments listed in Table 3.2.H. These instruments shall be logged once per shift, and each reading compared to the limits of Section 3.2.H.1.

The drywell coolers are not required during an accident, and have no mission time or required temperature to meet and have no auto start functions.

Preventative maintenance is preformed during each refueling outages and coil cleaning is performed as required.

Thursday, June 1, 2006 Page 36 of 82

Number Status Request Response NRC Auditor PNPS Lead 194 Closed [B.1.16.2-J-01, SI] The following table lists exceptions or Jackson, Wilbur Pardee, Rich alternatives related to inservice inspection at the

1. The LRA states that PNPS' Pilgrim Nuclear Power Station during the fourth AMP B.1.16.2 (Inservice ten-year interval, which expires on June 30, Inspection) ISI Program is a 2015. Technical justifications for these plant-specific program exceptions and alternatives is included in encompassing ASME Section PNPS-RPT-05-001, which is available for on-site X1, Subsections IWA, IWB, review.

IWC, IWD and IWF requirements. The LRA states PRR-2 Alternate Criteria for Class 1 Pressure that the ASME code edition and Tests of Piping, Pumps, and Valves (Category addenda used for the fourth B-P, Item Nos. B15.10, B15.50, B15.60, interval is the 1998 edition with B15.70).

2000 addenda. The LRA states that PNPS entered its fourth PRR-4 Relief from leakage testing of 1" and

[ten-year] ISI interval on July less vent and drain lines and valves. Category 1,2005. B-P, Items B15.50 and B15.70 require the system leakage test to include all ASME Code QUESTIONS: Class 1 components within the system boundary.

Clarify whether PNPS' AMP B.1.16.2 includes any PRR-5 (Approved - NRC SER issued) Relief exceptions or alternatives to from Supplement 10 for examination of the requirements of ASME Category B-F dissimilar metal (DSM) welds. The Section XI, 1998 edition with Final Rule, 64 FR 51370, dated 09/22/1999, 2000 addenda, granted oi required Pilgrim to implement a program to imposed under the provisions comply with Supplement 10 by 11/22/2002.

of' 10 CFR 50.55a. Supplement 10 contains the qualification requirements for procedures, equipment, and personnel involved with examining DSM welds using ultrasonic techniques.

PRR-9 (Approved - NRC SER issued) Relief from ASME Code Section XI, Mandatory Appendix VIII, Supplement 11 for pressure retaining piping weld overlay examination.

PRR-10 Risk-Informed ISI (RI-ISI): Relief from Category B-F & B-J weld examinations.

The following exceptions or alternatives relate to components covered by BWRVIP programs.

PRR-11 (Approved - NRC. SER issued) Relief from code RPV shell-to-flange weld UT exam requirements conducted in accordance with Article 4 of ASME Section V, supplemented by the requirements of Table 1-2000-1.

PRR-15 Alternative Contingency Repair Plan for RPV nozzle safe-end and dissimilar metal piping welds using ASME Code Cases N-638 and N-504-2 with exceptions.

Previously approved 3rd interval exceptions or alternatives applicable to the 4th interval (expiration date 6/8/2012):

PRR-28 Alternative to exam requirements of RPV circumferential shell welds (Item B1.10 of Exam Category B-A).

PRR-39 Full structural weld overlay contingency repairs for the welds associated with austenitic RPV nozzle safe-end and dissimilar metal piping welds.

Thursday, June 1, 2006 Page 37 of 82

Number Status Request Response NRC Auditor PNPS Lead 195 Closed [B.1.16.2-J-02, ISI] LRA Table 3.1.2-3 identifies reactor recirculation Jackson, Wilbur Potts, Lori pump casings and covers and valve bodies >=4"

2. The PNPS LRA, Appendix NPS made of CASS as subject to the aging B. 1.16.2 (Inservice Inspection), effect of reduction of fracture toughness. The under Scope of Program, aging management program is Inservice states, "The ISI Program Inspection. As stated in NUREG-1 801, the manages cracking, loss of ASME Section Xl inspection requirements are material, and reduction of sufficient for managing the effects of loss of fracture toughness of reactor fracture toughness due to thermal aging coolant system piping, embrittlement of CASS pump casings and valve components, and supports. bodies. The Inservice Inspection Program uses NDE techniques specified in ASME Section XI LRA Table 3.2.1-3 identifies to monitor for the presence and extent of reactor recirculation pump cracking which provides indication of reduction casings and covers, main in fracture toughness for these CASS steamline flow restrictors and components.

valve bodies (>= 4" NPS and <

4"NPS) made of CASS as LRA Table 3.1.2-3 identifies main steamline flow subject to the aging effect of restrictors and valve bodies < 4"NPS made of reduction of fracture CASS as subject to the aging effect of toughness. The aging reduction of fracture toughness. The aging management program is either management program is One-Time Inspection.

Inservice Inspection or The One-Time Inspection Program uses NDE One-Time Inspection. techniques consistent with those specified in ASME Section XI to monitor for the presence The SRP-LRA (NUREG-1800, and extent of cracking which provides indication Rev.1), Appendix A.1.2.3.4 of reduction in fracture toughness for these (Detection of Aging Effects), CASS components.

states that the applicant should "Provide information that links Since the One-Time Inspection Program is a new the parameters to be monitored program, the list of valves subject.to the aging or inspected to the aging effect of reduction of fracture toughness has effect being managed." not yet been compiled. However, the One-Time Inspection program (described in LRA section QUESTIONS: B.1.23) will inspect a representative sample of CASS components exposed to treated water Discuss how the parameters to >482 degrees F with emphasis on the most be monitored by the ISI susceptible components.

Program or One-Time Inspection are linked to the aging effect of reduction in fracture toughness?

Which valves are subject to the aging effect of reduction in fracture toughness? (Please provide either valve numbers and drawing references or a functional description of the valves.)

Thursday, June 1, 2006 Page 38 of 82

Number Status Request Response NRC Auditor PNPS Lead 196 Accepted [B.1.16.2-J-03, ISI] The parameter(s) or indicator(s) being trended Jackson, Wilbur Potts, Lori and the methodology for analyzing the

3. The SRP-LRA inspection or test results are in accordance with (NUREG-1800, Rev.1), the requirements of ASME Section XI. As Appendix A.1.2.3.5 (Monitoring described in LRA Section B.1.16.2, the Inservice and Trending), Paragraph 2, Inspection Program uses nondestructive states: .The parameter or examination (NDE) techniques to detect and indicator trended should be characterize surface and subsurface flaws.

described. The methodology Therefore, the parameter being trended is the for analyzirng the inspection or presence of a flaw indication.

test results against the acceptance criteria should be Results are compared, as appropriate, to described. baseline data and other previous test results.

Indications are evaluated in accordance with PNPS LRA Appendix B.1.16.2 ASME Section Xl. If the component is qualified (Inservice Inspection), Section as acceptable for continued service, the area 5 (Monitoring and Trending), containing the indication is reexamined during does not describe the subsequent inspection periods. Examinations parameter(s) or indicator(s) that reveal indications that exceed the being trended nor the acceptance standards are extended to include methodology for analyzing the additional examinations in accordance with inspection or test results, either ASME Section Xl.

explicitly or by reference to specific standards tables. LRA Section B.1.16.2, attribute 5, Monitoring and Trending will be amended to include this QUESTONS: clarification.

For PNPS plant-specific AMP B.1.16.2, please provide a description of the parameter(s) or indicator(s) being trended and of the methodology for analyzing the inspection or test 197 Closed [B.1.17-P-01, Instrument Air Tubing and valve bodies are managed in the Pavinich, Wayne Ivy, Ted Quality] standby gas treatment system.

Piping, tanks, tubing, and valve bodies are

1. Provide a list of components managed in the instrument air system.

or systems that are subject to the Instrument Air Quality Program.

198 Closed [B.1.17-P-02, Instrument Air The responses to GL 88-14 are included in initial Pavinich, Wayne Ivy, Ted Quality)) response letter BECo letter 89-010, Response to Generic Letter 88-14: Instrument Air Supply

2. General questions. What system Problems Affecting Safety Related commitments were made as a Equipment, dated February 3, 1989, Docket result of the PNPS response to 50-293 and supplementary response letter BECo NRC GL 88-14? What letter 89-071, dated May 30, 1989 which outline industry standards are used for commitments and applicable industry preventative actions and standards. A copy of this information is detection of aging effects?

199 Closed [B.1.17-P-03, Instrument Air Deteriorating air quality is detected by trending Pavinich, Wayne Ivy, Ted Quality] of air quality test results, by procedure PNPS 7.1.69, System Air Quality Sampling in Section

3. Provide details describing 8. A copy of this procedure is available for the methods that determine deteriorating air quality.

200 Closed [B.1.17-P-04, Instrument Air The instrument air systems are sampled and Pavinich, Wayne Ivy, Ted Quality] tested to the requirements of ANSI/ISA 7.3 per procedure PNPS 7.1.69, System Air Quality

4. Provide the basis for the Sampling. A copy of this procedure is available acceptance criteria for dew for review.

point, oil mist and particulate including any industry standards invoked.

Thursday, June 1, 2006 Page 39 of 82

Number Status Request Response NRC Auditor PNPS Lead 201 Accepted [B.1.17-P-05, Instrument Air As stated in the letter submitting the license Pavinich, Wayne Ivy, Ted Quality] renewal application (letter number 2.06.003, dated 1/25/06), PNPS is committed to the

5. NUREG-1800, SRPfor programs listed in Appendix B, Section B.1 of Ilicense renewal, section the license renewal application. Enhancements

• 3.X.3.4, FSAR Supplement, to programs that are described in Appendix B of states the following: the LRA are, therefore, commitments. To facilitate tracking of the enhancements through As noted in Table 3.X-2, an the NRC review process and facilitate applicant need not incorporate implementation once the renewed license is the implementation schedule received, a list of specific commitments for into its FSAR. However, the license renewal has been developed. This list reviewer should confirm that will be sent to the Staff under oath and the applicant has identified and affirmation and will be supplemented as committed in the license necessary during the NRC review process.

renewal application to any Both Appendix B of the LRA and the list of future aging management commitments for license renewal include activities, including commitments to implement new programs and enhancements and commitments to enhance existing programs commitments to be completed before the period of extended operation.

before entering the period of extended operation. The staff Item 13 on the list of commitments for license expects to impose a license renewal is the commitment to enhance the condition on any renewed Instrument Air Quality Program to include a license to ensure that the sample point in the standby gas treatment and applicant will complete these torus vacuum breaker instrument air subsystem activities no later than the in addition to the instrument air header sample committed date. points described in LRA Section B.1.1 The enhancements identified in See Item #320 for closure for this item.

the B.1.17 write-up are not included in the FSAR Supplement Appendix A.2.1.19.

They should be in the UFSAR Supplement in order to address these commitments.

Thursday, June 1, 2006 Page 40 of 82

Number Status Request Response NRC Auditor PNPS Lead 203 Accepted [B.1.18-N-01, Metal Enclosed Since MEB bolted connections are covered with Nguyen, Duc Stroud, Mike Bus Inspection] heat shrink tape or insulating boots per manufacturer's recommendations, a sample of

1. PNPS AMP B.1.18, under accessible bolted connections will be visually Detection of Aging Affects, inspected for insulation material surface you have states that PNPS anomalies. Internal portions of the MEBs will be takes an exception to GALL inspected for cracks, corrosion, foreign debris, XI.E4 by visual inspection of excessive dust buildup, and evidence of water metal enclosed bus (MEB) intrusion. Bus insulation will be inspected for bolted connections every 10 signs of embrittlement, cracking, melting, years. GALL XI.E4 under the swelling, or discoloration, which may indicate same element states that as an overheating or aging degradation. Internal bus alternate to thermography or supports will be inspected for structural integrity measuring connection and signs of cracks.

resistance of bolted connections, for the accessible An inspection will occur before the end of the bolted connections that are initial 40-year license term and every 5 years covered with heat shrink tape, thereafter.

sleeving, insulated boots, etc.

(emphasis added), the applicant If degradation is found in the metal-enclosed may use visual inspection of bus materials, an engineering evaluation will be insulation material to detect performed when the inspection acceptance surface anomalies, such as criteria are not met in order to ensure that the discoloration, cracking, chipping intended functions of the metal-enclosed bus or surface contamination. can be maintained consistent with the current When this alternate visual licensing basis. This evaluation is performed in inspection is used to check accordance with the Entergy corrective action bolted connections, the first process per procedure EN-LI-102. This inspection will be completed procedure provides the stated elements to before the period of extended consider including the extent of the concern, the operation and every five years potential root causes for not meeting the test thereafter. NUREG-1833, acceptance criteria, the corrective actions Table IV, Justification for required, and likelihood of recurrence.

Changes in Aging Management Programs, states that since the This engineering evaluation will determine the visual inspection is less frequency of the next inspection, which will not effective than testing, this exceed 5 years inspection (visual) is to be performed once every five LRA Appendix A.2.1.20 will be revised to "5 years instead of once every 10 years".

years.

LRA Appendix B.1.18 will be revised to remove

a. Are all bolted connections the exception to 5 years.

covered with heat shrink tape, sleeving, or insulated boots? If This requires an amendment to the LRA.

they are, justify the 10 years frequency vs. the five years as recomnmended by NUREG-180.1.

b. If they are not, justify the visual inspection vs GALL's recommended thermography and/or resistance connections.

Thursday, June 1, 2006 Page 41 of 82

Number Status Request Response NRC Auditor PNPS Lead 204 Accepted [B.1.18-N-02, Metal Enclosed The PNPS metal-enclosed bus program will Nguyen, Duc Stroud, Mike Bus Inspection] visually inspect the enclosure assemblies for evidence of loss of material and enclosure

2. In LRA, Section B.1.18 you assembly elastomers will be visually inspected have states that the program and manually flexed.

attribute of the Metal-Enclosed Bus (MEB) Inspection program Revise LRPD-02 to read as follows: (Section at PNPS will be consistent with 3.3.B.6.b - Acceptance Criteria - add after first the program attribute described paragraph) The acceptance criteria for in NUREG-1801,Section XI.E4, enclosure assemblies will be no loss of material Metal Enclosed Bus Aging due to general corrosion. The acceptance Management Program with an criteria for elastomers will be no hardening and exception. The exception is to loss of strength due to degradation.

inspect MEB enclosure assemblies in addition to internal surfaces using the MEB Inspection Program. GALL XI.E4 referred structures monitoring program for inspecting the metal enclosure bus assemblies. In addition to inspecting the enclosure assemblies for loss of material due to general corrosion, GALL's structure monitoring program also requires inspecting the enclosure seals for hardening and loss of strength due elastomers degradation. Are these enclosure seals included in the scope of MEB inspection program? What is the acceptance criteria for inspecting the enclosure assemblies?

205 Closed [B.1.18-N-03, Metal Enclosed Operating Experience at PNPS is controlled by Nguyen, Duc Stroud, Mike Bus Inspection] procedure EN-OP-100, Operating Experience Program. The program includes the following

3. In LRA, Section B.1.18, components:

under Operating Experience, you have stated that the Metal Operating Experience - Information received Enclosed Bus Inspection from various industry sources that describe Program at PNPS is a new events, issues, equipment failures, that may program for which there is no represent opportunities to apply lessons learned operating experience. to avoid negative consequences or to recreate NUREG-1800, Rev. 1, positive experiences as applicable.

Appendix A, Branch Technical Position RLSB-1 states that an Internal Operating Experience - Operating applicant may have to commit experience that originates as a condition report to providing operating or request from plant personnel which warrants experience in the future for new consideration for possible Entergy-wide program to confirm their distribution. Internal OE can originate from any effectiveness. Describe how Entergy plant or headquarters.

operating experience will be captured to confirm the Impact Evaluation - Analysis of an OE event or program effectiveness or to be problem that requires additional information and used to adjust the program as research to determine impact or potential needed. impact, as it relates to plant condition and/or configuration. Impact evaluations are typically documented with a condition report.

Condition report action items and corrective actions are used to confirm program effectiveness and to modify the program as needed.

Thursday, June 1, 2006 Page 42 of 82

Number Status Request Response NRC Auditor PNPS Lead 206 Accepted [B.1.19-N-01, Non-EQ PNPS inspection for water accumulation in Nguyen, Duc Stroud, Mike Inaccessible Medium Voltage manholes is conducted by plant inspection. An Cable Program] engineering evaluation will be performed per EN-LI-102.

1. GALL XI.E3 under Detection of Aging Effects recommends To clarify that the PNPS AMP is consistent with that the inspection for water the GALL recommendation, LRPD-02 will be collection should be performed revised as follows: [Section 3.4.B.4.b -

based on actual plant Detection of Aging Effects - replace 2nd experience with water paragraph] The inspection will be based on accumulation in the manhole. actual plant experience with water accumulation However, the inspection in the manholes and the frequency of inspection frequency should be at least will be adjusted based on the results of the once every two years. evaluation, but the frequency will be at least LRPD-02, Rev. 1, Section 3.4, once every two years.

under the same attribute, states that inspection for water in collection in manholes and conduit occur at least once very two years. Explain how operating experience is considered in manhole inspection frequency.

207 Closed [B.1.19-N-02, Non-EQ Operating Experience at PNPS is controlled by Nguyen, Duc Stroud, Mike Inaccessible Medium Voltage procedure EN-OP-100, Operating Experience Cable Program] Program. The program includes the following components:

2. In AMP B1.19 under Operating Experience element, Operating Experience - Information received you have stated that the from various industry sources that describe Non-EQ Inaccessible events, issues, equipment failures, that may Medium-Voltage Cable Program represent opportunities to apply lessons learned at PNPS is a new program for to avoid negative consequences or to recreate which there is no operating positive experiences as applicable.

experience. NUREG-1800, Rev. 1, Appendix A, Branch Internal Operating Experience - Operating Technical Position RLSB-1 experience that originates as a condition report states that an applicant may or request from plant personnel which warrants have to commit to provide consideration for possible Entergy-wide operating experience in the distribution. Internal OE can originate from any future for new program to Entergy plant or headquarters.

confirm their effectiveness.

Describe how operating Impact Evaluation - Analysis of an OE event or experience is captured to problem that requires additional information and confirm the program research to determine impact or potential effectiveness or to be used to impact, as it relates to plant condition and/or adjust the program as needed. configuration. Impact evaluations are typically documented with a condition report.

Condition report action items and corrective actions are used to confirm program effectiveness and to modify the program as needed.

Thursday, June 1, 2006 Page 43 of 82

Number Status Request Response NRC Auditor PNPS Lead 208 Accepted [B.1.20-N-01, Non-EQ To clarify that the PNPS AMP is consistent with Nguyen, Duc Stroud, Mike Instrumentation Circuits Test the GALL recommendation, LRPD-02 will be Review Program] revised as follows: [Section 3.5.A - Program Description - add after 2nd sentence] The first

1. In LRA, Section A.2.1.22, test of neutron monitoring system cables that you have stated that for are disconnected during instrument calibrations neutron flux monitoring system shall be completed before the period of cables that are disconnected extended operation and subsequent tests will during instrument calibration, occur at least every 10 years. In accordance testing is performed at least with the corrective action program, an once every 10 years. GALL engineering evaluation will be performed when XI.E2 recommends that the test test acceptance criteria are not met and frequency shall be determined corrective actions, including modified inspection by the applicant based on frequency, will be implemented to ensure that engineering evaluation, but the the intended functions of the cables can be test frequency shall be at least maintained consistent with the current licensing once every ten years. Explain basis for the period of extended operation.

how engineering evaluation is considered in the test frequency.

209 Closed [B.1.20-N-02, Non-EQ Yes, the B.1.20 program includes both cables Nguyen, Duc Stroud, Mike Instrumentation Circuits Test and connections for the instrument circuits that Review Program] are in scope for license renewal.

2. Confirm that the test include both cables and 210 Closed [B.1.20-N-03, Non-EQ Operating Experience at PNPS is controlled by Nguyen, Duc Stroud, Mike Instrumentation Circuits Test procedure EN-OP-100, Operating Experience Review Program] Program. The program includes the following components:

3. PNPS AMP B1.20 under Operating Experience element Operating Experience - Information received states that the Non-EQ from various industry sources that describe Instrumentation Circuit Tests events, issues, equipment failures, that may Review Program at PNPS is a represent opportunities to apply lessons learned new program for which there is to avoid negative consequences or to recreate no operating experience. positive experiences as applicable.

Explain how operating experience is captured to Internal Operating Experience - Operating confirm the program experience that originates as a condition report effectiveness or to be used to or request from plant personnel which warrants adjust the program as needed. consideration for possible Entergy-wide distribution. Internal OE can originate from any Entergy plant or headquarters.

Impact Evaluation - Analysis of an OE event or problem that requires additional information and researchto determine impact or potential impact, as it relates to plant condition and/or configuration. Impact evaluations are typically documented with a condition report.

Condition report action items and corrective actions are used to confirm program effectiveness and to modify the program as needed.

Thursday, June 1, 2006 Page 44 of 82

Number Status Request Response NRC Auditor PNPS Lead 211 Accepted [B.1.21-N-01, Non-EQ Insulated a. A ball park percentage of accessible Nguyen, Duc Stroud, Mike ,

Cables and Connections in-scope cables and connections would be 80 to Program] 85%.

1. GALL XI.E1 under program b. LRA Appendix B.1.21 will be revised to read description states that the as follows.

program described herein is This program addresses cables and connections written specifically to address at plants whose configuration is such that most cables and connections at cables and connections installed in adverse plants whose configuration is localized environments are accessible: This such that most (if not all) program can be thought of as a sampling cables and connections program. Selected cables and connections from installed in adverse localized accessible areas will be inspected and represent, environments are accessible. with reasonable assurance, all cables and This program, as described, connections in the adverse localized can be thought of as a environments. If an unacceptable condition or sampling program. Selected situation is identified for a cable or connection in cables and connections from the inspection sample, a determination will be accessible areas (the made as to whether the same condition or inspection sample) are situation is applicable to other accessible cables inspected and represent, with or connections. The sample size will be reasonable assurance, all increased based on an evaluation per EN-LI-102 cables and connections in the - Corrective Action Process.

adverse localized environment.

If an acceptable condition or This requires an amendment to the LRA.

situation is identified for a cable or connection in the inspection sample, a determination is made as to whether the same condition or situation is applicable to other accessible or inaccessible cables or connections. As such, this program does not apply to plants in which most cables are inaccessible.

a. Provide a ball part percentage of in-scope cable and connections population installed in adverse localized environments that are accessible.

b. In LRA, Section B.1.21 you have stated that the a representative sample of accessible insulated cables and connections within the scope of license renewal will be visually inspected for cable and connection jacket surface anomalies such as embrittlement, discoloration, cracking or surface contamination. Explain the technical basis for cable sampling.

Thursday, June 1, 2006 Page 45 of 82

Number Status Request Response NRC Auditor PNPS Lead 212 Closed [B.1.21-N-02, Non-EQ Insulated Operating Experience at PNPS is controlled by Nguyen, Duc Stroud, Mike Cables and Connections procedure EN-OP-100, Operating Experience Program] Program. The program includes the following components:

2. In LRA, Section B.1.21 under Operating Experience Operating Experience - Information received element, you have stated that from various industry sources that describe the Non-EQ Insulated Cables events, issues, equipment failures, that may and Connection Program at represent opportunities to apply lessons learned PNPS is a new program for to avoid negative consequences or to recreate which there is no operating positive experiences as applicable.

experience. Describe how operating experience will be Internal Operating Experience - Operating captured to confirm the experience that originates as a condition report program effectiveness or to be. or request from plant personnel which warrants used to adjust the program as consideration for possible Entergy-wide needed. distribution. Internal OE can originate from any Entergy plant or headquarters.

Impact Evaluation - Analysis of an OE event or problem that requires additional information and research to determine impact or potential impact, as it relates to plant condition and/or configuration. Impact evaluations are typically documented with a condition report.

Condition report action items and corrective actions are used to confirm program effectiveness and to modify the program as needed.

213 Accepted [B.1.22-P-01, Oil Analysis 1. As stated in LRA Section B.1.22, exception Pavinich, Wayne Potts, Lori Program] note 1, flash point is not determined for sampled oil because analysis of filter residue or particle

1. Provide justification for not count, viscosity, total acid/base (neutralization monitoring the flashpoint of oil number), water content, and metals content that is not regularly changed. provide sufficient information to verify the oil does not contain water or contaminants that would permit the onset of aging effects. PNPS

2. Provide the document that monitors the % fuel dilution in diesel engine oils establishes the frequency of which is a more accurate method than flash monitoring for and the point for identifying fuel leaks and oil dilution.

acceptance criteria for the allowable % dilution. 2. Provided a copy of procedure 3.M.3-61.3, Emergency Diesel Generator Quarterly Preventive Maintenance, showing that quarterly lube oil samples are sent to the laboratory.

Provided laboratory test results showing that %

dilution is measured in accordance with ASTM standards. Acceptance criterion is < 3 %Wt and is based on ALCO diesel engine owners' group chemistry guidelines.

The following will be added to LRA Section B.1.22 exception note. PNPS measures the %

fuel dilution in diesel engine oils which is a more accurate method than flash point for identifying fuel leaks and oil dilution. Acceptance criterion is < 3% Wt based on ALCO diesel engine owners' group chemistry guidelines.

This requires an amendment to the LRA.

Thursday, June 1; 2006 Page 46 of 82

Number Status Request Response NRC Auditor PNPS Lead 214 Closed [B.1.22-P-02, Oil Analysis As stated in the Aging Management Program Pavinich, Wayne Potts, Lori Program] Evaluation Report (AMPER), acceptance criteria resulting in re-sampling and increased sampling

2. Provide acceptance criteria frequency include:

for water and particulate contamination and viscosity -- particulates - large ferrous or non-ferrous and the basis of the limits. contamination or trend increasing levels viscosity - increase of 15% from viscosity grade

-- viscosity - decrease of 15% from viscosity grade

-- water content - > 2000 ppm (0.2% by volume)

The acceptance criteria are based on manufacturer's recommendations and industry 215 Accepted [B.1.22-P-03, Oil Analysis As stated in the letter submitting the license Pavinich, Wayne Potts, Lori Program] renewal application (letter number 2.06.003, dated 1/25/06), PNPS is committed to the

3. NUREG-1800, SRP for programs listed in Appendix B, Section B.1 of license renewal, section the license renewal application. Enhancements 3.X.3.4, FSAR Supplement, to programs that are described in Appendix B of states the following: the LRA are, therefore, commitments. To facilitate tracking of the enhancements through As noted in Table 3.X-2, an the NRC review process and facilitate applicant need not incorporate implementation once the renewed license is the implementation schedule received, a list of specific commitments for into its FSAR. However, the license renewal has been developed. This list reviewer should confirm that will be sent to the Staff under oath and the applicant has identified and affirmation and will be supplemented as committed in the license necessary during the NRC review process.

renewal application to any Both Appendix B of the LRA and the list of future aging management commitments for license renewal include activities, including commitments to implement new programs and enhancements and commitments to enhance existing programs commitments to be completed before the period of extended operation.

before entering the period of extended operation. The staff Items 18 and 19 on the list of commitments for expects to impose a license license renewal are the commitments to condition on any renewed implement the enhancements described in LRA license to ensure that the Section B.1.22.

applicant will complete these activities no later than the See Item #320 for closure for this Item.

committed date.

The enhancements identified in the B.1.22 write-up are not included in the FSAR Supplement Appendix A.2.1.24.

They should be in the UFSAR Supplement in order to address these commitments.

Thursday, June 1, 2006 Page 47 of 82

Number Status Request Response NRC Auditor PNPS Lead 217 Closed [B.1.23-P-01, One Time As described in LRA Section B.1.23, the Patel, Erach Potts, Lori Inspection] One-Time Inspection Program includes several activities. The activities to confirmh the absence

1. Provide a list of systems in of aging effects identify the systems to which element of "Scope of they apply. For instance, the activity for Activity", where One-Time inspection of "Internal surfaces of buried carbon Inspection will be performed. steel pipe on the standby gas treatment system discharge to the stack" inspects components in the standby gas treatment system.

The activity to verify effectiveness of the water chemistry control programs is applicable to many systems. The systems are not listed in LRA Section B.1.23. However, they may be found in the tables in LRA Section 3.0, Aging Management Review Results. In these tables, systems with line items containing one of the water chemistry control programs, (Water Chemistry Control - Auxiliary Systems, Water Chemistry Control - BWR, or Water Chemistry Control - Closed Cooling Water), have components included in the sample population for this one-time inspection activity.

218 Closed [B.1.23-P-02, One Time As described in the Aging Management Program Patel, Erach Potts, Lori Inspection] Evaluation Report (AMPER), the One-Time Inspection Program activity for inspection of

2. Identify how the sample of small-bore piping in the reactor coolant system small piping welds, 4" and and associated systems that form the reactor smaller will be picked for coolant pressure boundary will inspect a performing NDE inspection. statistically significant sample of welds of each material and environment combination in Class I piping less than or equal to 4" NPS. The initial population will include all Class I small-bore piping and actual inspection locations will be selected based on physical location, exposure levels, NDE techniques, and locations identified in Information Notice 97-46, Un-isolable Crack in High-Pressure Injection Piping.

219 Closed [B.1.23-P-03, One Time As indicated in plant procedures, during the 4th Patel, Erach Potts, Lori Inspection] ISI Interval, PNPS plans to.perform both VT-2 and PT examinations, at a minimum, of socket

3. How will.PNPS handle the welds in accordance with the PNPS 4th Interval aging of socket welds? ISI Program Plan. The One-Time Inspection of small-bore piping does not exclude locations based upon geometry. Therefore, Class I small-bore piping socket welds will be selected for one-time inspection based on physical location and exposure levels.

Thursday, June 1, 2006 Page 48 of 82

Number Status Request Response NRC Auditor PNPS Lead 220 Accepted [B.1.23-P-04, One Time As stated in the letter submitting the license Patel, Erach Potts, Lori Inspection] renewal application (letter number 2.06.003, dated 1/25/06), PNPS is committed to the

4. NUREG-1800, SRP for programs listed in Appendix B, Section B.1 of license renewal, section the license renewal application. Therefore, 3.X.3.4, FSAR Supplement, programs that are described in Appendix B of states the following: the LRA are commitments. To facilitate tracking through the NRC review process and facilitate As noted in Table 3.X 2, an implementation once the renewed license is applicant need not incorporate received, a list of specific commitments for the implementation schedule license renewal has been developed. This list into its FSAR. However, the will be sent to the Staff under oath and reviewer should confirm that affirmation and will be supplemented as the applicant has identified and necessary during the NRC review process.

committed in the license Both Appendix B of the LRA and the list of renewal application to any commitments for license renewal include future aging management commitments to implement new programs and activities, including commitments to enhance existing programs enhancements and before the period of extended operation.

commitments to be completed before entering the period of Item 20 on the list of commitments for license extended operation. The staff renewal is the commitment to implement the expects to impose a license One-Time Inspection Program as described in condition on any renewed LRA Section B.1.2.

license to ensure that the applicant will complete these See Item #320 -for closure for this Item.

activities no later than the committed date.

The One-Time Inspection program is a new program that will be implemented prior to period of extended operation.

Justify why this commitment is not included in the FSAR Supplement write-up in Appendix A. 1.25.

222 Closed [B.1.24-P-01, Periodic As indicated in LRA Section B.1.24, many of the Pavinich, Wayne Potts, Lori Surveillance and Preventative Periodic Surveillance and Preventive Maintenance] Maintenance activities include visual or other non-destructive examinations of structures,

1. Provide any codes and systems and components. These examinations standards used for detection of are performed in accordance with approved aging effects. procedures that are consistent with ASME Section XI and 10 CFR 50 Appendix B.

Thursday, June 1, 2006 Page 49 of 82

Number Status Request Response NRC Auditor PNPS Lead 223 Accepted [B.1.24-P-02, Periodic As stated in the letter submitting the license Pavinich, Wayne Potts, Lori Surveillance and Preventative renewal application (letter number 2.06.003, Maintenance] dated 1/25/06), PNPS is committed to the programs listed in Appendix B, Section B.1 of

2. NUREG-1800, SRP for the license renewal application. Enhancements license renewal, section to programs that are described in Appendix B of 3.X.3.4, FSAR Supplement, the LRA are, therefore, PNPS commitments. A states the following: list of specific commitments for license renewal will be developed to facilitate tracking and As noted in Table 3.X-2, an implementation of the enhancements through applicant need not incorporate the NRC review process upon receipt of the the implementation schedule renewed license. This list will be sent to the into its FSAR. However, the Staff under oath and affirmation and will be reviewer should confirm that supplemented as necessary during the NRC the applicant has identified and review process. Both Appendix B of the LRA committed in the license and the list of commitments for license renewal renewal application to any include commitments to implement new future aging management programs and commitments to enhance existing activities, including programs before the period of extended enhancements and operation.

commitments to be completed before entering the period of Item 21 on the list of commitments for license extended operation. The staff renewal is the commitment to implement the expects to impose a license enhancements described in LRA Section B.1.24.

condition on any renewed license to ensure that the applicant will complete these activities no later than the committed date.

The enhancements identified in the B.1.24write-up are not included in the FSAR Supplement Appendix A.2.1.26.

They should be in the UFSAR Supplement in order to address these commitments.

225 Closed [B.1.24-P-04, Periodic Inspection and testing intervals are established Pavinich, Wayne Potts, Lori Surveillance and Preventative such that they provide for timely detection of Maintenance] structures, systems and components degradation. Inspection and testing intervals are

4. Provide trending methods. dependent on the material and environment and take into consideration industry and plant-specific operating experience and manufacturers' recommendations. Trending of degraded components occurs within the Corrective Action Program.

Thursday, June 1, 2006 Page 50 of 82

Number Status Request Response NRC Auditor PNPS Lead 226 Closed [B.1.25-J-01, Reactor Head Approved lubricants for RPV studs are Jackson, Wilbur Finnin, Ron Closure Studs] Neo-Lube or equivalent. (Ref. Procedure 3.M.4-48)

1. The PNPS AMP B.1.25 (Reactor Head Closure Studs) The use of appropriate materials means that any states gives as examples of replacement studs would be specified to be preventive measures to made from material that met all the mitigate cracking "rust requirements at the time of specification, and inhibitors, stable lubricants, encompassed all the available operating appropriate materials." experience. For example, no metal sheathed studs would be ordered and tensile strength QUESTIONS: would be specified.

At PNPS what rust inhibitors and lubricants are approved for used on the reactor head closure studs, nuts, washers, and bushings?

What is encompassed by the words "appropriate materials"?:

227 ' Closed [B.1.25-J-02, Reactor Head There are 56 reactor head studs, so a sample of Jackson, Wilbur Finnin, Ron Closure Studs] 18 is 1/3 of the studs (19, 19, 18).

2. The PNPS LRA, AMP B.1.25 Yes, all studs/nuts/washers are examined (Reactor Head Closure Studs), every 10 year interval.

Operating Experience states that volumetric examination of The studs/nuts/washers currently installed at 18 reactor head closure studs PNPS are original equipment.

and visual examination of 18 nuts and 18 washers was performed during RF015 (April, 2005).

QUESTIONS:

What is the fraction of total reactor head closure studs represented by the 18 studs examinde during RVO15?

Are all studs, nuts and washers examined during each 10-year ISI interval?

Are the studs, nuts and washers examined during RF015 original equipment that has been in use since initial startup of the plant? If not, what is the approximate average length of time that these items have been in used in operation.

Thursday, June 1, 2006 Page 51 of 82

Number Status Request Response NRC Auditor PNPS Lead 228 Closed [B.1.25-J-03, Reactor Head PNPS has not detected any recordable Jackson, Wilbur Pardee, Rich Closure Studs] indications in any of the 56 RPV closure head studs.

3. The PNPS LRA, AMP B.1.25 (Reactor Head Closure Studs),

Operating Experience states that no new recordable indications were found for the studs, nuts and washers examined during RFO15.

QUESTIONS:

What is the examination history related to earlier refueling outages? Have indications been found in previous examinations?

If indications were found, what corrective actions were taken?

229 Closed [B.1.25-J-.04, Reactor Head Since RFO15 (2005), PNPS has adopted the Jackson, Wilbur Pardee, Rich Closure Studs] 1998 edition with 2000 addenda of ASME XI which requires either a surface exam or

4. RG 1.65 (Materials and volumetric exam of RPV studs that are Inspections for Reactor Vessel removed. PNPS elected to perform a Closure Studs), which is volumetric examination on these four studs in referenced in and is a basis for RFO15 in the tensioned condition prior to their GALL Program XI.M3 (Reactor removal. No indications were detected in the Head Closure Studs), states four removed studs in 2005. The four studs that "visual and surface adjacent to the fuel transfer chute are removed examinations may fail to reveal each refueling outage; these are the only studs unacceptable defects, that have been removed from the PNPS vessel.

especially ifthe studs are examined in an untensioned condition." It also states that PNPS currently performs ultrasonic examination "a [volumetric examination] of RPV studs from the top surface of the stud.

technique has been developed In the past, PNPS had performed this in which a transducer is lowered examination using a specially fabricated stud into the stud bolt center hole radial UT probe inserted into the stud's heater and an ultrasonic radial scan is hole located on the stud's central axis. The used for the ultrasonic technique currently in use utilizing the flat examination." surface at the top of the stud is considered superior in the detection of flaws in RPV studs QUESTIONS: when compared to UT exams performed from the heater hole.

With regard to reactor head closure studs that are removed RPV studs at PNPS are examined utilizing a for examination, does PNPS straight beam ultrasonic testing (UT) technique.

perform the surface This method has been demonstrated and examination with the studs in a qualified by the Performance Demonstration tensioned or untensioned Initiative (PDI) at the Electric Power Research condition? Institute (EPRI) Nondestructive examination (NDE) Center. Examiners utilizing this qualified Has PNPS performed any technique are also qualified by the PDI to radial ultrasonic scans of its perform this examination. This straight beam reactor vessel closure studs? examination has been demonstrated by PDI to be capable of detecting a flaw of critical size.

All 56 RPV studs at PNPS are examined once per interval using this technique.

Thursday, June 1, 2006 Page'52 of 82

Number Status Request Response NRC Auditor PNPS Lead 230 Accepted [B.1.27-W-01, Selective Yes it is included. Item 23 of the commitment Wen, Peter Ivy, Ted Leaching Program] list states "Implement the Selective Leaching Program in accordance with the program as

1. PNPS states in LRA described in LRA Section B.1.27".

B.1.27,Selective Leaching Program, that this AMP is a new program, and it will be initiated prior to the period of extended operation. Will the implementation of this AMP be included in the commitment list?

231 Closed [B.1.27-W-02, Selective As described in section B.1.27, the selective Wen, Peter Ivy, Ted Leaching] leaching program will be consistent with NUREG-1801,Section XI.M33, Selection

2. Provide a status of the Leaching of Materials. Scope, parameters implementation of this AMP, inspected/measured, and acceptance criteria including scope of work, along with other program attributes are available (planned) implementing for your review in the Aging Management procedures, parameters to be Program Evaluation Report LRPD-02, section inspected and measured, and 3.8.

acceptance criteria.

Because this is a new program, the implementing procedures have not yet been developed, but will be in place prior to the period 232 Closed [B. 1.28-H-01, Service Water Piping Pavinich, Wayne Gaedtke, Joe Integrity]

- The Salt Service Water Supply buried piping

1. Identify applications where and sections of the supply and return wall components are not coated or penetration piping spools are constructed of lined and the materials of Titanium, ASTM B381 GR. F2. These spools are construction. not lined internally.

• Salt Service Water Small bore pipe (=2") Vents and Drain piping are constructed of ASTM B-466, 90-10 CUNI. These spools are not lined internally. These spools are bolted onto large bore Carbon Steel rubber lined pipe.

Valves

- Salt Service Water Pump Discharge 12" Check Valves are not lined internally. They are constructed of; (3) ASTM B-61 bodies, (2) are ASTM A-494 Gr. M35-1 bodies.

- Salt service Water Small bore (=2") Vent and Drain Valves are not lined internally. They are constructed of ASTM B-61 or ASTM B-62.

Pumps

- Salt Service Water Pumps are not lined internally. Their Column are constructed of; ASTM B-1 48-88 C95800 or ASTM B271-89 Alloy C95800.

Heat Exchangers

• The Closed Cooling Water (RBCCW &

TBCCW) Heat Exchangers, Salt Service Water side are not lined internally. They are constructed of ASTM SB-171-C70600, 90/10 CuNi.

Thursday, June 1, 2006 Page 53 of 82

Number Status Request Response NRC Auditor PNPS Lead 233 Closed [B. 1.29.1 -H-01, Masonry Wall] 1. No additional masonry walls have been Hoang, Dan Ahrabli, Reza identified to be added to the scope of Pilgrim current masonry wall program as result of the

1. The program description for LR scoping and screening process [Ref. Aging AMP B.1.29.1 in the Pilgrim management program evaluation report LRA indicates that the scope of LRPD-02, section 4.21.2].

this program includes all masonry walls that perform an 2. Not applicable since no additional masonry intended function in accordance walls have been added to the scope of Pilgrim with 10 CFR 54.4. The current masonry wall program as result of the applicant is requested to LR scoping and screening process [Ref. item (1) provide the following above].

information related to the scope of this program: 3. Not applicable since no additional masonry walls have been added to the scope of Pilgrim (1) Identify whether any current masonry wall program as result of the additional masonry walls have LR scoping and screening process [Ref. item (1) been added to the scope of the above].

current Pilgrim program as a result of the LR scoping and screening process, particularly in light of the requirement to consider regulated events in the LR assessment.

(2) If additional masonry walls have been added to the scope, explain how the requirements of I. E. Bulletin 80-11 have been applied to these walls, and describe any physical modifications that have/will be implemented to establish the evaluation bases.

(3) If additional masonry walls have been added to the scope, explain why this is not considered an enhancement to the current Pilgrim program.

Thursday, June 1, 2006 Page 54 of 82

Number Status Request Response NRC Auditor PNPS Lead 234 Closed [B.1.29.1-H-02, Masonry Wall] Pilgrim masonry wall program which is Hoang, Dan Ahrabli, Reza consistent with the program described in NUREG-1 801,Section XI.S5, Masonry Wall

2. The program description for Program, includes the guidance and lessons AMP B.1.29.1 in the Pilgrim learned from NRC Bulletin 80-1 land Information LRA does not indicates that Notice 87-67. As indicated in Aging this program includes all of the Management Program Evaluation Report guidances provided in I.E. LRPD-02, section 4.21.2, Operating experience Bulletin 80-11, "Masonry Wall shows that this program has been effective in Design", and Information managing aging effects with consideration for Notice 87-67, "Lessons learned recommendations and lessons learned from from Regional Inspections of Bulletin 80-11 and Information Notice 87-67.

Licensee Actions in Response Masonry walls are visually examined at to I.E. 80-11 ". Also, what is frequency selected (at least once every 10 your Visual examined years) to ensure there is no loss of intended frequency? The applicant is function between inspections. (Ref. Pilgrim requested to provide and procedure NE8.02, section 5, and Aging confirm to the above Management Program Evaluation Report information related to this LRPD-02, section 4.21.2) program.

PNPS Engineering Design Standards Manual MCSB03.104 defines the procedure to maintain the qualification of safety-related masonry block walls in accordance with the provisions of NRC Bulletin 80-11, Masonry Wall Design".

PNPS procedure NE8.02, "Structure Inspection and Condition Monitoring", Section 5.0 (last sentence, pg. 8) states "The inspection intervals are once every three years for accessible areas, once every ten years for normally inaccessible areas.

235 Closed [B.1.29.2-H-01, Structures PNPS AMP B1.29.2 Structures Monitoring, Hoang, Dan Ahrabli, Reza Monitoring Program] Program Description states "Since protective coatings are not relied upon to manage the

1. Since the program coatings effects of aging for structures included in the are not relied upon to manage Structures Monitoring Program, the program the effects of aging for does not address protective coating monitoring structures included in the and maintenance."

Structures Monitoring Program (AMP B.1.29.2). Please provide the following information related to this enhancement:

(a) What is your criteria and How are you going to qualify and monitor it under AMP B.1.29.2.

Thursday, June 1, 2006 Page 55 of 82

Number Status Request Response NRC Auditor PNPS Lead 236 Closed [B.1.29.2-H-02, Structures The following plant documents, were available Hoang, Dan Kalb, Jeff Monitoring Program] for review: PDF Files: Item 236 (part 1), Item 236 (part 2), Item 236 (part 3), Item 236 (part 4),

2. In the discussion of and operating experience, four noteworthy incidences of CR-PNP-2000-09246 degradation are noted: cracks, CR-PNP-2000-09435 gaps, corrosion, and flaking CR-PNP-2000-09448 coating. CR-PNP-2001-09145 CR-PNP-2001-09700 For each of the first three CR-PNP-2004-03373 incidences of degradation, CR-PNP-2004-03981 please provide the plant documentation that describes Cracks, gaps and corrosion will be monitored as the degradation, the stated in LRPD-02 and Attachment 4-assessment performed, the Structures Monitoring Program General Criteria acceptance criteria applied, (pg. 279). For Concrete, structures monitoring future monitoring manages loss of material, cracking, and change recommendations, and any in material properties, as identified in LRA tables corrective action taken. Also 3.5.2-1 thru 3.5.2-6.The acceptance criteria is describe the monitoring the absence of the following: cracks, excessive activities that are or will be rust bleeding, staining or discoloration, abrasion, conducted under the Structures erosion, cavitation, spalling, scaling, !eaching, Monitoring Program for each of excessive settlement, corrosion of reinforcing, the three regions. degraded waterproof membranes. For Steel, structures monitoring program manages the loss of material, as identified in LRA tables 3.5.2-1 thru 3.5.2-6. The acceptance criteria is the absence of the following: Pitting, beam/column deflection, cracks, flaking coatings, excessive rust, loose/missing bolts, peeling paint, wide spread corrosion. (also see commitment numbers 25 and 26 regarding this program) For Elastomers the aging effect managed is cracking,' change in material properties. The acceptance criteria will include the absence of cracks and gaps.

Thursday, June 1, 2006 Page 56 of 82

Number Status Request Response NRC Auditor PNPS Lead 237 Closed [B. 1.29.2-H-03, Structures The Dresden/Quad Cities License Renewal Hoang, Dan Ahrabli, Reza Monitoring Program] Application (LRA) and Safety Evaluation Report (SER) provide a description of the

3. The Dresden/Quad Cities Dresden/Quad Cities operating experience with BWR units have a history of their stainless steel bellows. The Dresden/Quad problems with containment Cities review determined a total of 120 bellows penetration bellows, and the were within the scope of license renewal. Of licensee has a long-term these 120 bellows, 24 bellows were identified as replacement program that will being degraded. The root cause was identified as continue into the LR period. stress corrosion cracking (SCC). From 1990 to The applicant is requested to 2003 Dresden/Quad Cities replaced or removed address this industry operating the degraded bellows from service. The SER experience and submit a states that several of the replaced bellows specific technical basis why received metallurgical analysis. Analysis the Pilgrim containment results from a couple of examples determined penetration bellows are not the presence of corrosive products, such as subject to the aging effects "magnesium salts", chlorides, fluorides, and and aging mechanisms sulfides. Also, these corrosive species are not observed at Dresden/Quad typical of containment operating conditions. As Cities. a result, the SER concludes the corrosive species, leading to the site specific degradation of the bellows, were most probably introduced and contaminated during plant construction.

(Reference Dresden/Quad Cities SER pages 3-403 to 3-408)

Cracking due to SCC for the PNPS containment bellows is not an aging affect requiring management. There are no PNPS site specific operating experiences similar to that of Dresden/Quad Cities. In summary, the presence of corrosive products is necessary for SCC to exist. The normal environment for the PNPS drywell is dry and there has been no indication of contamination of the bellows during construction at PNPS. In addition, containment bellows for PNPS are not exposed to a corrosive environment. As such, SCC is not applicable to PNPS stainless steel bellows. (Ref. LRA paragraph 3.5.2.2.1.7)

Thursday, June 1, 2006 Page 57 of 82

Number Status Request Response NRC Auditor PNPS Lead 238 Accepted [B.1.29.2-H-04, Structures a. On October 27, 2005, groundwater samples Hoang, Dan Kalb, Jeff Monitoring Program] were taken from a well located -3 feet from the foundation of the Pilgrim Station turbine building

4. More information is needed near the truck lock at the south side of the about aging management of building. This well was installed in the late 90s to inaccessible concrete areas. monitor for total petroleum hydrocarbons as a The applicant is requested to result of a transformer oil spill. The bottom of submit the dates and complete the well is -25 feet below ground surface and at results (at specific the time the sample was taken, the depth to locations/not averages or water was -16 feet. The sample was analyzed ranges) of all past groundwater for chlorides, total phosphate, sulfate and pH.

monitoring tests. Discuss why The results were as follows:

the groundwater is non-aggressive, and/or "Chlorides: 420 ppm aggressive, if applicable.

• Total phosphate: 0.26 ppm Confirm that the Pilgrim SMP

• Sulfate: 16 ppm credited for LR will inspect all

• pH: 6.2 inaccessible areas that may be exposed by excavation for The sampling was performed by SAIC any reason, whether the Engineering, Inc. and the analysis was environment is considered performed by R. I. Analytical Laboratories, Inc.

aggressive or not, and also will inspect any inaccessible area where observed conditions in The recent test data shows PNPS ground water accessible areas, which are has remained non-aggressive (chloride <

exposed to the same 500ppm, Sulfate < 1500 ppm and pH > 5.5).

environment, show that significant concrete degradation b. Although it is expected that inaccessible is occurring. areas are inspected when exposed by excavation for any reason, Pilgrim site procedure for "Structures Inspection and condition monitoring" will. be revised to require opportunistic inspections of inaccessible concrete areas when they become accessible (commitment 25). Expanding inspection to other areas (accessible or non- accessible) where significant concrete degradation is observed in the accessible area will continue to be part of corrective action program 8.0.3.

This requires an amendment to the LRA.

Thursday, June 1, 2006 Page 58 of 82

Number Status Request Response NRC Auditor PNPS Lead 239 Closed [B.1.29.2-H-05, Structures The discussion in the operating experience Hoang, Dan Kalb, Jeff Monitoring Program] section (LPDR-05, pg. 41) of Pilgrim's LRA came from the System 56, Structures

5. The applicant is requested Maintenance Rule fourth quarter 2004 System to address and discussion of Health Report. These items were however operating experience in detail of identified during System 56 walkdowns as part pipe supports and cable trays of the periodic inspections performed in found degradation in November accordance with PNPS procedure NE8.03, 2004. Did your scope Structure Inspection and Condition Monitoring.

expansion was required due to unacceptable found? When degraded conditions were observed a WRT/MR was written to correct the condition.

Provide the following information related to this MR # 04117586 recent operating experience: MR # 04117332 (a) Identify the system(s), MR # 04117319 ASME Code Class, the initial MR # 04117320 sample size, and the MR # 04117318 percentage found to be MR # 04117334 unacceptable. MR # 04117333 MR # 04117590 (b) Identify whether loss of MR # 04117591 material due to corrosion, loss MR # 04117313 of mechanical function, or both MR # 04117279 aging effects were observed. MR # 04117272 Did the as-found unacceptable MR # 04116777 conditions compromise any MR # 04116773 intended functions? MR # 04116774 MR # 04116775 (c) Identify the final sample MR # 04116776 size, after scope expansion, and the percentage found to be (a) The affected systems vary with each unacceptable. component identified. All of the degraded conditions found occurred on non safety related (d) Identify the number of conduits or pipe supports. None of the piping supports returned to service supports were ASME supports. There was no based solely on evaluation and sample size since the various portions of the the number of supports process buildings were walked down and returned to service after repair. inspected room by room.

(b) Some of the degraded conditions were due to corrosion and some were due to conditions (e) Describe the root cause other than aging effects, such as, bent rods.

evaluation and the corrective See attached MRs. No as found conditions actions taken to prevent compromised any intended design function.

recurrence.

(c) There was no sample size and there was no (f) Identify any additional scope expansion.

inspections scheduled for the next inspection period. (d) The supports in question were evaluated and determined all needed repair or maintenance before returning back to service. Approximately 50% of the supports, on different systems, have been repaired and returned to service. The remaining will be returned to service when the repairs are complete. As noted in the response to part (a), the degraded supports were found on nonsafety-related conduits or piping.

(e) There was no root cause analyses performed and no additional corrective actions taken to prevent recurrence.

(f) No additional inspections have been identified for the next inspection period.

Thursday, June 1, 2006 Page 59 of 82

Number Status Request Response NRC Auditor PNPS Lead 240 Accepted [B.1.29.2-H-06, Structures Since 6 years remain before PNPS enters the Hoang, Dan Ahrabli, Reza Monitoring Program] period of extended operation, implementing procedures required for new AMPs, and

6. Considering the relatively procedure revisions for enhancements to short time period remaining existing AMPs have not yet been developed.

before Pilgrim enters the Items 25 and 26 on the list of commitments for license renewal period, the license renewal are the commitment to staff expects that considerable implement the enhancements to the Structures progress has already been Monitoring Program described in LRA Section made in developing and B.1.29.2. .

formally documenting the implementing procedures To facilitate tracking of enhancements through required for new AMPs, and for the NRC review process and facilitate significant enhancements to implementation, a list of specific commitments existing AMPs. In light of this, for license renewal has been developed. This please address each of the list will be sent to the Staff under oath and following questions regarding affirmation and will be supplemented as the current status of necessary during the NRC review process.

implementing procedures for Both Appendix B of the LRA and the list of this AMP: commitments for license renewal include commitments to implement new programs and (a) Provide the status of the commitments to enhance existing programs implementing procedures for before the period of extended operation.

each enhancement to the existing Structures Monitoring Program.

(b) Provide the schedule for initiating each of the enhancements to the existing Structures Monitoring Program.

(c) Provide a sample of an implementing procedure for one enhancement to the existing Structures Monitoring Program.

(d) Provide the results of any enhanced inspections that have 241 Closed [B.1.29.2-H-07, Structures PNPS AMP B1.29.2 Structures Monitoring, Hoang, Dan Kalb, Jeff Monitoring Program] Program Description states "Since protective coatings are not relied upon to manage the

7. Discuss PNPS use of Level effects of aging for structures included in the III coatings and identify Structures Monitoring Program, the program whether any Service Level III does not address protective coating monitoring coatings are credited for and maintenance."

corrosion protection for license Thursday, June 1, 2006 Page 60 of 82

Number Status Request Response NRC Auditor PNPS Lead 242 Closed [B.1.29.2-H-08, Structures (a) The Structures Monitoring Program at PNPS Hoang, Dan Ahrabli, Reza Monitoring Program] is comparable to the program described in NUREG-1801,Section XI.S6, Structures

8. The scope of the Monitoring Program (SMP). The Structures enhancements listed for AMP Monitoring Program will be enhanced to clarify B.1.29.2 are quite significant, that the discharge structure, security diesel and encompass several generator building, trenches, valve pits, elements that would be manholes, duct banks, underground fuel oil tank expected to be part of an foundations, manway seals and gaskets, hatch existing Structures Monitoring seals and gaskets, underwater concrete in the Program. Notable examples intake structure, and crane rails and girders are are the inclusion of anchors included in the program (commitment numbers and the addition of loss of 25 and 26). The structures, structural material due to corrosion of components and their aging effects requiring steel components to the current management under scope of SMP are included inspection criteria. in LRA Tables 3.5.2-1 thru 3.5.2-6. Visual Consequently, the applicant is inspections of accessible plant structures are requested to: performed at three-year intervals and inspections of normally inaccessible (insulated (a) describe the scope of AMP or high radiation zone) areas are performed at B.1.29.2, including the ten-year intervals. Visual inspections of buried structures and components in plant structures are performed when the scope of AMP B.1.129.2; opportunistic excavation occurs. However, the aging effects that are more frequent inspections may be performed monitored; the inspection based on past inspection results, industry methods employed; and the experience, or exposure to a significant event inspection frequency; and (e.g. tornado, earthquake, fire, chemical spill).

(Ref. Aging Management Program Evaluation (b) for the structures and Report LRPD-02, section 4.21.1) components that will be added to the Structures Monitoring (b) Currently there are no aging management Program scope for license activities being implemented for structures and renewal, describe the aging components that will be added to the Structures management activities that are Monitoring Program for license renewal.

currently being implemented.

243 Closed [B.1.29.2-H-09, Structures Aging management of drywell shell is provided Hoang, Dan Ahrabli, Reza Monitoring Program] by aging management program (AMP) B.16.1, "Containment Inservice Inspection (CII)". The

9. The applicant has not inspections of buried plant structures and addressed aging management structural components (e.g., portion of drywell of the portion of the drywell embedded in drywell concrete floor) are shell embedded in the drywell performed when they become accessible, concrete floor. This area is inspection results of similar component show inaccessible for inspection, but significant degradation, or operating experience is potentially subject to wetting warrants such inspections. (Ref. Aging on both the inside and outside Management Program Evaluation Report surfaces. Are they any LRPD-02, section 4.14.2) inspections planned prior to the extended period of operation for this portion of the drywell shell?

Thursday, June 1, 2006 Page 61 of.82

Number Status- Request Response NRC Auditor PNPS Lead 244 Closed [B. 1.29.3-H-01, Water Control Aggressive environment is environment with pH Hoang, Dan Ahrabli, Reza Structures Monitoring Program] less than 5.5 or chloride solution greater than 500 ppm, or sulfate solution greater than 1500 ppm (Ref. LRA section 3.5.2.2.2.4).

1. Describe the "aggressive 'Water-flowing" is considered flowing water at environment" and greater than 3 fps. (Ref. LRA section "water-flowing" environments 3.5.2.2.2.4 and EPRI report 1002950 "Aging for Reinforced Concrete Effects for Structures and Structural Foundation, Slabs, and Components (Structural Tools), section 3.3.1.4)

Reinforced Concrete Walls.

What is the plant-specific program to manage potential For concrete, structures monitoring manages degradation? loss of material, cracking, and change in material properties, as identified in LRA Tables 3.5.2-1 thru 3.5:2-6. The acceptance criteria is the absence of the following: cracks, excessive rust bleeding, staining or discoloration, abrasion, erosion, cavitation, spalling, scaling, leaching, excessive settlement, corrosion of reinforcing, degraded waterproof membranes.

245 Accepted [B.1.29.3-H-02, Water Control Since 6 years remain before PNPS enters the Hoang, Dan Ahrabli, Reza Structures Monitoring Program] period of extended operation, implementing procedures required for new AMPs, and procedure revisions for enhancements to

2. Considering the relatively existing AMPs have not yet been developed.

short time period remaining before Pilgrim enters the To facilitate tracking of enhancements through license renewal period, the the NRC review process and facilitate staff expects that considerable implementation, a list of specific commitments progress has already been for license renewal has been developed. Items made in developing and 25 and 26 on the list of commitments for license formally documenting the renewal are the commitment to implement the implementing procedures enhancements to the Structures Monitoring required for new AMPs, and for Program described in LRA Section B.1.29.2.

significant enhancements to This list will be sent to the Staff under oath and existing AMPs. In light of this, affirmation and will be supplemented as please address each of the necessary during the NRC review process.

following questions regarding Both Appendix B of the LRA and the list of the current status of commitments for license renewal include implementing procedures for commitments to implement new programs and.

this AMP: commitments to enhance existing programs before the period of extended operation.

(a) Provide the status of the implementing procedures for See item #320 for closure of this item.

each enhancement to the existing RG 1.127, Inspection of Water-Control Structures program.

(b) Provide the schedule for initiating each of the enhancements to the existing RG 1.127, Inspection of Water-Control Structures program.

(c) Provide a sample of an implementing procedure for one enhancement to the existing RG 1.127, Inspection of Water-Control Structures program.

(d) Provide the results of any enhanced inspections that may have already been completed.

Thursday, June 1, 2006 Page 62 of 82

Number Status Request Response NRC Auditor PNPS Lead 246 Accepted [B.1.29.3-H-03, Water Control The Water Control Structures Monitoring Hoang, Dan . Ahrabli, Reza Structures Monitoring Program] Program at PNPS is comparable, to the program described in NUREG-1801,Section XI.S7, RG 1.127, Inspection of Water-Control Structures

3. LRA Appendix B, Section Associated with Nuclear Power Plants. The B.O.5 identifies AMP B.1.29.3 program includes visual inspections to manage as an existing program. The loss of material and loss of form for Program Description states that water-control structures (breakwaters, jetties, this AMP is part of the and revetments). The water-control structures Structures Monitoring Program, are of rubble mound construction with the outer and further states the program layer protected by heavy capstone.

will be used to manage aging Parameters monitored include settlement of water-control structures. (vertical displacement) and rock displacement.

The scope of the These parameters are consistent with those enhancements listed for AMP described in RG 1.127. Inspections are B.1.29.3 encompass many of performed on water-control structures every 5 the elements that normally years and following major storms. Program would be part of an existing scope will be enhanced to include the east inspection program for breakwater, jetties, and onshore revetments in water-control structures. addition to the main breakwater (commitment Consequently, the applicant is number 27). These added items as requested to describe the enhancements are not currently monitored under scope of AMP B.1.29.3, the existing program.

including the structures and components in the scope of This requires an amendment to the LRA.

AMP B.1.29.3; the aging effects that are monitored; the inspection methods employed; and the inspection frequency.

247 Closed [B.1.29.3-H-04, Water Control The trash racks are in scope of license renewal, Hoang, Dan Ahrabli, Reza Structures Monitoring Program] but they are not subject to aging management review. The trash racks are intended to protect the traveling screens from large debris. The

4. The applicant is requested failure of the trash racks will not affect any to identify the document(s) that license renewal function. (Ref. AMRC-03 "Aging includes the evaluation of the Management Review of the Intake Structure" Pilgrim program against the table 2.1-2). Accordingly, structures monitoring monitoring of trash racks. Does program is not credited for aging management the Structures Monitoring of trash racks:

Program is credited for aging management of trash racks?

248 Closed [B.1.29.3-H-05, Water Control Inspections are performed on water-control Hoang, Dan Ahrabli, Reza Structures Monitoring Program] structures at least every 5 years and following major storms. [Ref. Aging Management Program Evaluation Report LRPD-02, section 4.21.3.4(b)]

5. The applicant is requested to identify and provide the inspection frequency against the GALL AMP XI.S7. If greater.

than 5 years. Please explain why the inspection frequency is NOT identified as an exception to the GALL AMP.

Also provide the technical basis for concluding that Pilgrim frequency is sufficient for submerged portions of structures.

Thursday, June 1, 2006 Page 63 of 82

Number Status Request Response NRC Auditor PNPS Lead 249 Closed [B.1.29.3-H-06, Water Control The corrective action has been completed. The Hoang, Dan Ahrabli, Reza Structures Monitoring Program] Main Breakwater was repaired in October of 2005. The Main Breakwater was repaired, assessment performed, and condition resolved

6. Per the Operating in accordance with the requirements of PNPS Experience discussion for Specification C20-ER-Q-EO, Main Breakwater B.1.29.3, Pilgrim has Repair. (Ref. MR # 04118760). The degradation experienced degradation of the of the Main Breakwater is documented in main breakwater Structure had Condition Reports CR-PNP-2004-03933, Rock displacement in 2004. CR-PNP-2005-00093, CR-PNP-2005-00450 and Has the corrective action been CR-PNP-2005-03018.

completed? Ifnot, why? If yes, provide the plant The Main Breakwater is monitored at PNPS using documentation that describes procedure PNPS 3.M.5-3, Main Breakwater the degradation, the Monitoring and Repair Procedure. The procedure assessment performed, the provides methods for initiating and assessing acceptance criteria applied, the results for main breakwater surveys and future monitoring repair of the main breakwater. In addition to recommendations, and any scheduled walkdown inspections and detailed preventive and/or corrective surveys, the wind speeds are monitored for determining the need for additional inspections.

The wind speeds at two separate met towers are monitored routinely. If any wind sensor indicates speed in excess of 50 MPH for two consecutive hours, a walkdown inspection of the breakwater is performed to assess any damage and repair as needed. Additional walkdown inspections are performed at the discretion of the design engineer for any suspicion of damage, regardless of wind speed.

250 Accepted [B.1.29.3-H-07, Water Control a. Program scope will be enhanced to include the Hoang, Dan Ahrabli, Reza Structures Monitoring Program] east breakwater, jetties, and onshore revetments in addition to the main breakwater The applicant is requested to (commitment number 27). No underwater confirm that Pilgrim AMP supports are identified to be added to scope of B.1.29.3 identifies an this program for license renewal period. (Ref.

inspection of underwater Aging Management Program Evaluation Report supports for loss of material LRPD-02, section 4.21.3.B.1.b).

due to corrosion and loss of mechanical function. Provide b. The Water Control Structures Monitoring the following information related Program at PNPS is comparable to the program to this request: described in NUREG-1801,Section XI.S7, RG 1.127, Inspection of Water-Control Structures (a) Identify the specific Associated with Nuclear Power Plants. The underwater supports that will be program includes visual inspections to manage added to the scope of the loss of material and loss of form for inspection program for the water-control structures (breakwaters, jetties, license renewal period, including and revetments). The water-control structures the system name and ASME are of rubble mound construction with the outer Code Class. layer protected by heavy capstone.

Parameters monitored include settlement (b) Specify the current (vertical displacement) and rock displacement.

inspection program and These parameters are consistent with those describe the current inspection described in RG 1.127. There are no underwater details for the underwater supports identified in scope of this program.

supports that are identified in (Ref. Aging Management Program Evaluation (a) above. Report LRPD-02, section 4,21.3.A)

(c) Confirm that, all ASME c. No underwater supports are identified to be Code Class underwater added to scope of this program for the license supports will be included in the renewal period. (Ref. Aging Management scope of the inspection program Program Evaluation Report LRPD-02, section for the license renewal period. 4.21.3.B.1 .b).

Thursday, June 1, 2006 Page 64 of 82

Number Status Request Response NRC Auditor PNPS Lead 251 Closed [B.1.30-W-01, System As stated in LRA Section B.1.30, the system Wen, Peter Potts, Lori Walkdown] Walkdown Program is consistent with the program described in NUREG-1801, Section

1. PNPS states in LRA XI.M36, External Surfaces Monitoring. The A.2.1.34, System Walkdown frequency of inspection and the acceptance Program, that "Surfaces are criteria are consistent with those described in inspected at frequencies to NUREG-1801,Section XI.M36. Further provide reasonable assurance information is provided in Section 4.22 of the that effect of aging will be PNPS License Renewal Project Aging managed such that applicable Management Program Evaluation Report, components will perform their LRPD-02, "Aging Management Program intended function during the Evaluation Report." A copy of this section of period of extended operation." the report is available for on-site review.

However, there is only limited information provided in the LRA System Walkdowns are performed in B.1.30, "System Walkdown." accordance with Entergy Procedure EN-DC-178, What is the frequency of "System Walkdowns." A copy of this inspection, and what are the procedure was available for on-site review.

inspection criteria for the current program? System inspections are conducted at least once per refueling cycle. This frequency is acceptable since aging effects are typically caused by long-term degradation mechanisms such as corrosion. Surfaces that are inaccessible or not readily visible during plant operations and refueling outages are inspected at such intervals that would ensure the components intended function is maintained.

The intervals of inspections may be adjusted as necessary based on plant-specific inspection results and industry experience. In addition, all plant personnel are required to identify adverse conditions via the corrective action process.

Since adverse conditions include those which the system walkdowns are intended to manage, aging effects may be identified through routine operations and maintenance activities.

System walkdown attributes are based on EPRI Technical Reports 1011223, "Aging Identification and Assessment Checklist - Electrical Components," January 2005, and 101124, "Aging Identification and Assessment Checklist - Civil and Structural Components," January 2005, and are consistent with NUREG-1801,Section XI.M36. Examples of Walkdown Attributes include:

• Liquid on floor/components leaking

• Concrete or grout cracks

• Paint and preservation adequate

• Fasteners in place, in good condition, proper thread engagement Evidence of moisture entry on/in panels, conduits, or other components Hangers (loose, broken, improper fasteners, indications of improper motion, displacement)

In addition, System Engineers have received training on EPRI Technical Report 1007933, "Aging Assessment Field Guide," December 2003, and use the Guide during performance of their System Walkdowns.

Thursday, June 1, 2006 Page 65 of 82

Number Status Request Response . NRC Auditor PNPS Lead 252 Closed [B.1.30-W-02, System Surfaces that are inaccessible or not readily Wen, Peter Trask, Tim Walkdown] visible during plant operations are inspected during refueling outages. Surfaces that are

2. PNPS states in LRA B.1.30 inaccessible or not readily visible during both

, 'System Walkdown," that this plant operations and refueling outages are AMP is consistent with the inspected at such intervals that would provide program described in GALL reasonable assurance that the effects of aging Report Section XL.M36, will be managed such that applicable "External Surfaces Monitoring." components will perform their intended function The GALL Report XIM36 during the period of extended operation.

indicates that this AMP manages aging effects through Surfaces that are insulated are inspected when visual inspection and the external surface is exposed (i.e.,

monitoring of external surfaces maintenance) at such intervals that would for loss of material and provide reasonable assurance that the effects leakage. The GALL Report of aging will be managed such that applicable further states in the Detection components will perform their intended function of Aging Effects program during the period of extended operation.

element, that Corrosion of piping under insulation will be "Surfaces that are inaccessible associated with discoloration of the external or not readily visible during insulation or with visible degradation of the plant operations and refueling insulation which provided the pathway for the outages are inspected at such fluid to reach the piping. Consistent with intervals that would ensure the NUREG-1801,Section XI.M36, staining on

• components intended function thermal insulation is a monitored parameter.

is maintained."

Discuss how PNPS plans to inspect inaccessible surfaces of components that are within the scope of license renewal.

253 Closed [B.1.30-W-03, System As stated in LRA Section B.1.30, system Wen, Peter Trask, Tim Walkdown] walkdowns between 1998 and 2004 identified evidence of aging effects, including corrosion

3. Provide some examples of and leakage. Examples include fire water actual plant-specific operating storage tank and diesel fire pump fuel oil day experience of how the problems tank leakage, through-wall leakage on SSW were identified and appropriate piping, signs of corrosion in fan room and actions taken to demonstrate auxiliary bays, and through-wall leakage without and ensure the effectiveness loss of function on a drain line to the aux bay of the existing System sump. Corrective actions were accomplished in Walkdown Program. accordance with the site Corrective Action Program. Related condition reports are available for on-site review.

254 Closed [B.1.31-W-01, Thermal Aging The PNPS CASS program has not yet been Wen, Peter Finnin, Ron and Neutron Irradiation developed. However, to ensure consistency Embrittlement of CASS] with NUREG-1801, the screening criteria (casting method, molybdenum content, and

1. What are the screening ferrite content) given in Section XI.M13, Scope criteria used by PNPS to of the Program, would be used by PNPS to determine the susceptibility of determine susceptibility to thermal aging.

CASS components to thermal aging and neutron irradiation Components exposed to more that 1017 n/cm2 embrittlement? (E>1 MeV) over the life of the plant will be included in the program as susceptible to neutron irradiation embrittlement.

Thursday, June 1, 2006 Page 66 of 82

Number Status Request Response NRC Auditor PNPS Lead 255 Closed [B.1.31-W-02, Thermal Aging The CASS program comparable to NUREG-1801 Wen, Peter Finnin, Ron and Neutron Irradiation Section XI.M13 is applicable only to the reactor Embrittlement of CASS] vessel internals. The identified CASS components of the internals (guide tube, fuel

2. As indicated in Table 3.1.2-2 support pieces, and pieces of the jet pump of the LRA, PNPS identified assemblies) are not subject to ISI, so there are three components: CRD Guide no ISI results to date.

Tubes, Fuel Support Pieces and Jet Pump Assemblies are Outside the reactor vessel, the only CASS subject to the aging effect of components are valve bodies, pump casings, loss of fracture toughness due and the main steam flow restrictors. PNPS has to thermal aging and neutron no CASS piping. The main steam flow irradiation embrittlement. Are restrictors are not pressure boundary parts, and any other CASS components in hence they are not examined by ISI either.

primary pressure boundary and reactor vessel internal Reduction of fracture toughness for CASS subject to this aging effect? valves and pump casings are managed by ISI, Discuss the recent ISI not by a CASS program, as discussed in inspection findings for those NUREG-1801 Section XI.M1 components that PNPS has identified to be subject to this aging effect.

256 Closed [B.1.31-W-03, Thermal Aging For those components that require inspection, Wen, Peter Finnin, Ron and Neutron Irradiation PNPS will inspect them using enhanced visual Embrittlement of CASS] examinations (EVT-1) capable of detecting 0.0005 inch resolution.

3. As indicated in the description of LRA AMP PNPS will perform either component specific B. 1.31, PNPS claims that its evaluations or examinations of those B.1.31 AMP will be consistent components that are not eliminated by the with the GALL Report Section screening criteria discussed in Question 254.

XI.M13 AMP. The GALL Report Component-specific evaluations may include states that for each mechanical loading analyses. Component "potentially susceptible" examinations will be enhanced visual component, an applicant can examinations (EVT-1). Evaluations/inspections implement either (a) a will be performed by the first refueling outage in supplemental examination of the period of extended operation.

the affected component as part of a 10-year ISI program Acceptance criteria for any flaws detected during the license renewal term, during these examinations will be evaluated in or (b) a component-specific accordance with the applicable procedures of evaluation to determine the IWB-3500, and may include flaw evaluations component's susceptibility to performed according to the principles associated loss of fracture toughness. with IWB-3640 procedures for submerged arc Describe what kind of welds (SAW), disregarding the Code restriction supplemental inspection will be of 20% ferrite in IWB-3641(b)(1).

used in PNPS for detecting the critical flaw size with adequate margin.

257 Accepted [B.1.31-W-04, Thermal Aging Yes, all new programs are included in the Wen, Peter Finnin, Ron and Neutron Irradiation commitment list. Implementation of the Thermal Embrittlement of CASS] Aging and Neutron Embrittlement of Cast Austenitic Stainless Steel Program is

4. PNPS states in LRA B.1.31, commitment #29.

that this AMP is a new program, and it will be initiated prior to the period of extended operation. Will the implementation of this AMP be included in the commitment list?

Thursday, June 1, 2006 Page 67 of 82

r Number Status Request Response NRC Auditor PNPS Lead 258 Closed [B.1.32.1-P-01, Water Stator cooling water conductivity is monitored Patel, Erach Smalley, Paul Chemistry Control - Auxiliary continuously using three conductivity elements Systems] with remote readouts and alarms. Dissolved oxygen is measured using a portable oxygen

1. Per SRP Appendix Al, meter with a continuous local display. The section A1.2.3.4, the frequency oxygen meter is read weekly and the value is of sampling water chemistry recorded. If the oxygen meter is out-of-service, should be identified. PNPS a weekly grab sample is obtained and a Appendix B.1.32-1, element 4 chemical analysis is performed. Monthly copper does not identify the analyses are performed to monitor for frequency. Identify the corrosion.

frequency.

1. There are three installed plant conductivity elements (P&ID M275). They read out remotely and are alarmed for Operations. In addition, there is one portable conductivity meter kept in Sample Panel C-3006. The portable conductivity meter only has a local readout.

Normally, the portable meter satisfies procedure PNPS 7.8.1 grab sample requirement.

However, we are considering removing the portable meter from the sample panel and just use the installed conductivity elements. With three conductivity elements, there is more than enough monitoring.

2. The only oxygen meter is portable and located in Sample Panel C-3006. It only has a local readout. The oxygen meter continuously displays locally, but has no readout or alarms.

The oxygen meter is read weekly and the value is recorded. If the oxygen meter is out-of-service, a weekly grab sample is obtained and a chemical analysis is performed.

3. PNPS does not do corrosion products analyses. Only copper analyses are performed.

260 Accepted [B.1.32.3-P-01, Water The exception in LRA Section B.1.32.3, which Patel, Erach Smalley, Paul Chemistry Control - Closed was applied to the detection of aging effects Cooling Water] attribute (element 4) is equally applicable to the parameters monitored/trended attribute (element

1. The exception taken for 3). The exception was discussed under Element element 4 about the 4 since it is more directly related to detection of performance and functional aging effects.

testing should also apply to element 3 for the same reason LRA Section B.1.32.3 will be amended to that it applies to element 4. indicate that the exception is applicable to both Justify why this exception attribute 3, Parameters Monitored/Trended and does not apply to element 3. attribute 4, Detection of Aging Effects.

This requires an amendment to the LRA.

Thursday, June 1, 2006 Page 68 of 82

Number Status Request Response NRC Auditor PNPS Lead 261 Closed [Generic-J-01, Appendix B SRP Section A.1.2.3.10 states, "Operating Jackson, Wilbur Cox, Alan Aging Management Program] experience with existing programs should be discussed." To identify operating experience for

1. In the PNPS LRA Operating license renewal, Entergy focused on operating Experience section for several experience with the existing programs rather AMPs (e.g. B.1.5; B.1.6; B.1.7; than operating experience from the program that B.1.8; B.1.25) describes only existed 10 to 15 years ago. Entergy did not the results of relatively recent own the plant 10 years ago. Entergy focused inspection during RFO14 (April on operating experience from the existing 2003) and RFO15 (April 2005). programs rather than operating experience from In most cases, inspection the program that existed 10 to 15 years ago, results for these refueling because results of the earlier inspections do not outage are negative (no provide information regarding existing program recordable indications). Then effectiveness. In addition, BWRVIP programs the LRA makes a statement incorporate industry operating experience from such as "Absence of recordable the entire BWR fleet. The PNPS programs are indications on the vessel based on NUREG-1 801 programs which are also attachment welds provides based on industry experience.

evidence that the program is effective for managing aging of the component during the period of extended operation."

LR-SRP (NUREG-1800, Rev.

1) in Appendix A, Section A.1.2.3.10 (Branch Technical Position RLSB-1, Operating Experience) states that "the operating experience of aging management programs, including past corrective actions resulting in program enhancements or additional programs, should be considered ..... This information can show where an existing program has succeeded and where it has failed (if at all) in intercepting aging degradation in a timely manner."

QUESTION:

For those AMPs where only the negative inspection results of RFO14 and RFO15 inspections are presented in the LRA, please provide additional discussion of inspection results from earlier refueling outages (approximately 10-15 years of history). If historical inspection results have found indications at some times in the past, provide additional discussion of what corrective actions have been taken.

Thursday, June 1, 2006 Page 69 of 82

Number Status Request Response NRC Auditor PNPS Lead 262 Accepted [Generic-J-02, Appendix B The intent of saying that enhancements will be Jackson, Wilbur Cox, Alan Aging Management Program] initiated prior to the period of extended operation is that the enhancements will be fully

2. The Standard Review Plan implemented prior to the period of extended for License Renewal operation.

(NUREG-1800, Rev. 1),

Section 3.0.1, states that This clarification will be provided in an "Enhancements are revisions or amendment to the LRA.

additions to existing aging management programs that the applicant commits to implement prior to the period of extended operation."

In describing enhancements, the PNPS LRA typically says,

'The following enhancement will be initiated prior to the period of extended operation."

In describing an enhancement as something to be "initiated",

rather than "implemented", prior to the period of extended operation, the LRA wording appears is ambiguous with regard to whether the enhancement will be fully implemented prior to the period of extended operation.

QUESTION:

Clarify or resolve this ambiguity in the LRA description of enhancements.

298 Closed B. 1.16.2-J-04 See below for the number of B-F and B-J weld Jackson, Wilbur Potts, Lori inspections before and after risk informed ISI Please provide a comparison of (RISI) implementation:

the number of category B-F weld inspections and category Code Category B-F B-J weld inspections before and after implementation of There are a total of 40 B-F welds in the ISI risk-informed ISI. program. Before RISI implementation there were 40 weld exams and after RISI there are now 11 welds examined.

Code Category B-J There are a total of 598 B-J welds in the ISI program. Before RISI implementation there were 156 weld exams and after RISI there are now 60 welds examined.

In addition to ISI program welds, there are augmented IGSCC BWRVIP-75A program welds examined. For the IGSCC category B thru G welds examined per BWRVIP-75A there are 16 category B-F welds and 18 category B-J welds.

Thursday, June 1, 2006 Page 70 of 82

Number Status Request Response NRC Auditor PNPS Lead 299 Closed Generic - N - 01 Power to the New England Grid is provided via Nguyen, Duc Das, Swapan the Main Transformer and the 345kV switchyard.

Provide brief description of all The six 4.16kV busses are powered via the Unit AC power sources and Auxiliary Transformer (UAT).

sequence of power transfer: Upon a unit trip, the 4.16kV buses are automatically fast transferred to the Start up transformer, the preferred source (SUT). On loss of SUT, the 4.16kV safety busses A5 and A6 are transferred to Emergency Diesel Generators (EDG) automatically after approximately 10 seconds. Loss of an EDG will result in a transfer of its respective 4.16kV bus automatically in approximately 12 seconds to the Shutdown Transformer (SDT) source. Upon loss of all AC power at PNPS, the Station Blackout Diesel (SBODG) is started manually from the Control Room in 10 minutes and manually loaded to the safety 4.16kV busses A5 or A6 as needed by Operations.

300 Closed Generic - N - 02 The secondary AC power, the Shutdown Nguyen, Duc Das, Swapan What is the capability of 23kV Transformer (SDT) is capable of supplying all Shut down Transformer (SDT) require loads of one emergency AC 4.16kV bus Source? A5 or A6 for the safe shutdown of reactor for postulated accidents per PNPS analysis. The SDT is capable of supplying both safety busses A5 and A6 loadings per PNPS analysis for normal shutdown.

Thursday, June 1, 2006 Page 71 of 82

Number Status Request Response NRC Auditor PNPS Lead 302 Closed B.1.12-P-01 The effects of the reactor coolant environment Patel, Erach Finnin, Ron are not considered in the current fatigue Review of AMPER 4.11 - monitoring program at PNPS. The CUFs given element 2, Preventive Actions in Table 4.3-1 of the LRA are the basis for the (page 137) current fatigue monitoring program, and these were calculated without considering In the comparison statement, environmental effects.

PNPS states that PNPS preventive actions are not Section 4.3.3 of the LRA presents a consistent with GALL Report conservative estimate of the effects of the and that the program only reactor coolant environment on fatigue for involves tracking of cycles, PNPS. The results (the CUFs in Table 4.3-3 of and does not include the LRA) show that severallocations exceed 1.0 assessment of environmental when the resulting Fen are applied. As stated in fatigue. However, LRA Section 4.3.3:

environmental fatigue is addressed by TLAA section "Prior to entering the period of extended 4.3.3, and therefore, PNPS is operation, for each location that may exceed a consistent with GALL Report. CUF of 1.0 when considering environmental Please clarify if PNPS is effects, PNPS will implement one or more of the consistent with GALL for this following:

element. (1) further refinement of the fatigue analyses to lower the predicted CUFs to less than 1.0; (2) management of fatigue at the affected location by an inspection program that has been reviewed and accepted by the NRC (e.g.

periodic non-destructive examination of the affected locations at inspection intervals to be determined by a method acceptable to the NRC);

(3) repair or replacement of the affected locations."

Once this commitment is implemented (commitment #31), the allowable number of transient cycles will be inputs to the fatigue analyses that include consideration of the effects of the reactor coolant environment.

Therefore, during the period of extended operation, the Fatigue Monitoring Program will 303 Accepted B.1.12-P-02 An exception was not identified for Attribute 6 in Patel, Erach Finnin, Ron the original Aging Management Program since Review of AMPER 4.11 - the exception addressed under Attribute 2 was element 6, Acceptance Criteria considered adequate. For clarification, the (page 137) Aging Management Program document, and the License Renewal Application will be revised as In the comparison to GALL follows to also show an exception for attribute 6.

element 6, PNPS states it is consistent with GALL.

However, the comparison AMPER 4.11 - element 6. The final sentence statement does not address will be changed to read "PNPS acceptance environmental fatigue. As criteria are not consistent with NUREG-1 801 written, this statement is because the PNPS Fatigue Monitoring Program inconsistent with GALL Report. does not consider environmental fatigue Please clarify how effects."

environmental fatigue is addressed by PNPS or justify LRA Section B.1.12 will be revised to add "6.

why as written, this element is Acceptance Criteria" under the Attributes consistent with GALL Report. Affected column for the first exception listed.

Thursday, June 1, 2006 Page 72 of 82

Number Status Request Response NRC Auditor PNPS Lead 304 Closed B.1.12-P-03 Lifetime projections, as used in Section 7.0 of Patel, Erach Finnin, Ron procedure PNPS 1.3.118, are projections based Review of AMPER 4.11 - on 40 years of operation. The procedure element 7, Corrective Actions extrapolates the actual transient cycles that (page 137) have occurred to date to 40 years and shows that the projected number of cycles remains In the comparison statement, below the number of cycles used to calculate PNPS states, "ifthe lifetime the CUrs for the vessel and appurtenances.

projection of CUE exceeds 1.0, Hence, the fatigue analyses that calculated the

.. ', please explain what CUrs remain valid. The procedure will be lifetime means. Is it 40 years revised to extrapolate transient cycles to 60 or 60 years? This references years, and we will adjust CUrs accordingly, PNPS procedure 1.3.118, when the renewed license is approved.

section 7.0, where the lifetime Projections of cycles to 60 years are provided is defined as 40 years. Will in Section 4.3.1 (Table 4.3-2) of the LRA.

the procedure be revised to reflect 60-year life?

305 Closed B. 1.27-W-03 Yes, PNPS took an aggressive approach to Wen, Peter Ivy, Ted Selective Leaching replace P-105A ("A" Circulating Sea Water Pump) in RFO1 5 (April 2005) as a result of OE

3. Industry operating from the Vendor (Flowserve) informing PNPS experience has identified - that a failure of a cast iron Circulating Water graphitization (removal of iron Pump occurred at the New Boston Fossil Station from cast iron) of submerged in 2004 due to graphitization. That pump was a pump components from similar design to PNPS with 6 additional years of long-term immersion in submergence/operation in salt water. Six core saltwater environments. PNPS samples of the pump casing were sent out to a indicates in LRPD-02, Section materials lab for analysis and the results 3.8, that this AMP is credited in confirmed graphitization. Currently, there are both Salt Service Water plans to replace P-105B in RFO17 based on the System and the Circulation core sample analysis obtained from P-105A Water System. Has any columns. PNPS has also purchased, and has pump, in these systems, been on-site the columns for P-105B replaced as a result of overhaul/replacement. The new pump columns selective leaching? If yes, are cast iron enhanced with the addition of 3-5%

please discuss how the problem Nickel to improve strength and resistance to was identified and the graphitization. The original columns were ASTM corrective action taken. A48 CL 35 with 1.75-2.25% Nickel.

The Salt Service Water pumps are not cast iron.

The cast iron valve bodies (lined with rubber and Ni-Resist cast iron discs) originally installed on the SSW System have been replaced with cast steel lined with rubber and monel discs such that there are no cast iron components in the SSW system.

306 Accepted B.1.18-N-04 Provide LRPD-02 will be revised as follows: (Section Nguyen, Duc Stroud, Mike acceptance criteria for 3.3.B.6.b - Acceptance Criteria - add after first inspecting enclosure paragraph) The acceptance criteria for assemblies or justify why enclosure assemblies will be no loss of material acceptance criteria for due to general corrosion. The acceptance enclosure assemblies is not criteria for elastomers will be no hardening and necessary. Revise AMP B1.18 loss of strength due to degradation.

as appropriate.

Thursday, June 1, 2006 Page 73 of 82

Number Status Request Response NRC Auditor PNPS Lead 307 Accepted B.1.19-N-03 GALL XI.E3, LRPD-02 will be revised as follows: (Section Nguyen, Duc Stroud, Mike under scope of program, 3.4.B.1.b - Scope of Program - replace first defines significant moisture as paragraph) This program applies to inaccessible periodic exposures to moisture (e.g. in conduit or direct buried) medium-voltage that last less than a few days cables within the scope of license renewal that (e.g., cable in standing water). are exposed to significant moisture Significant voltage exposure is simultaneously with significant voltage.

defined as being subjected to Significant moisture is defined as periodic system voltage for more than exposure to moisture that lasts more than a few twenty-five percent of the days (e.g., cable in standing water). Periodic time. PNPS LRPD-02, exposures to moisture that lasts less than a few Revision 1, under Scope of days'(i.e., normal rain and drain) are not Program states that this significant. Significant voltage exposure is program will include defined as being subjected to system voltage inaccessible (e.g., in conduit or for more than twenty-five percent of the time.

direct buried) medium-voltage cables within the scope of license renewal that are exposed to significant moisture simultaneously with applied voltage. AMRE-01, Revision 2, Section 3.4.1.5, Non-EQ Inaccessible Medium-Voltage Cable Screening, states that the cable that are susceptible to water treeing are those exposed to significant moisture (submerged for years).

Revise AMP B1.19, under the scope of program, to be consistent with GALL's definition or explain how inaccessible medium-voltage cables exposed moisture for more than few days and less than years is not susceptible to water tree.

Thursday, June 1, 2006 Page 74 of 82

Number Status Request Response NRCAuditor PNPSLead 308 Closed B.1.19-N-04 GALL XI.E3 under The intent of the PNPS AMP B.1.19 is to inspect Nguyen, Duc Stroud, Mike program description states, in for water in manholes and to test the in-scope part, that periodic actions such medium-voltage cables.

as inspecting for water collection in cable man holes, and draining water, as needed to prevent cable from being exposed to significant moisture. The above actions are not sufficient to assure water is not trapped elsewhere in the raceways. In addition to the above periodic actions, in-scope medium-voltage cables are tested to provide an indication of the condition of the conductor insulation. PNPS AMP B.1.19 under the same attribute states that periodic actions will be taken to prevent cables from being exposed to significant moisture, such as inspecting for water collection in cables manholes and conduit, and draining water, as needed. In scope medium-voltage cables exposed to significant moisture and voltage will be tested to provide an indication of the condition of the conductor insulation. It is clear to the team if periodic actions of manhole inspections are used to preclude cable testings.

Confirm that the intend of AMP B.1.19 is to inspect for water in manholes and to test all the in-scope medium-voltage 309 Accepted B.1.19-N-05 GALL XI.E3 under LRA Appendix B.1.19 will define medium voltage Nguyen, Duc Stroud, Mike program description defines cables as follows: For this program, medium medium-voltage is from 2 kV to voltage is from 2kV to 35kV.

35 kV. AMRE-01, Rev 2, Attachment 4 lists medium This requires an amendment to the LRA.

voltage cables from 2kV to 23 kV. Provide definition of medium voltage in the LRA to be consistent with GALL or provide a justification of why water tree phenomenon is not applicable for inaccessible medium-voltage cable greater than 23 kV.

Thursday, June 1, 2006 Page 75 of 82

Number Status Request Response NRC Auditor PNPS Lead 310 Accepted B. 1.1 9-N-06 GALL XI.E3 under LRPD-02 will be revised as follows: (Section Nguyen, Duc Stroud, Mike parameters 3.4.B.3.b - Parameters Monitored/Inspected monitored/inspected states that -replace 2nd sentence) This program will state the specific type of test that the specific type of test to be performed performed will be determined will be determined prior to the initial test and is to prior to the initial test and it to be a proven test for detecting deterioration of be a proven test for detecting the insulation system due to wetting as deterioration of the insulation described in EPRI TR-103834-P1-2, or other system due to wetting such as testing that is state-of-the-art at the time the power factor, partial discharge the test is performed.

test, or polarization index, as described in EPRI TR-103834-P1, or other testing that is state-of-the-art at the time the test is performed.

PNPS B.1.19 under the same attribute only states that the specific type of test performed will be determined prior to the initial test. Revise your AMP to be consistent with GALL or explain how you ensure that the test to be performed will be in accordance with industrial guideline or that is the state-of-the-art at the time the test is performed.

311 Accepted B.1.19-N-07 Do you currently Yes, though not a formal procedure, PNPS has Nguyen, Duc Stroud, Mike inspect water in the man holes. an existing repetitive task and job plan for Are there any existing inspecting manholes. An example is provided.

procedures for inspecting man holes. Provide a copy of these PNPS will develop a formal procedure to inspect procedures. manholes for in-scope medium voltage cable.

Also, LRPD-02, section 3.4.B.10 - Operating Experience will be revised to discuss the process for considering plant operating experience that will be used during implementation of the Non-EQ Medium-Voltage Cable Program.

312 Closed B.1.19-N-08 AMRE-01, Rev. 2, Since medium voltage cables are defined as Nguyen, Duc Stroud, Mike Page 71 of 87 provides a list 2kV to 35kV, the service water cables are not in of in-scope inaccessible scope because they run on a system voltage of medium-voltage cables that are 480 volts.

in scope of AMP B.1.19.

However, itdoes not include service water cables. Explain why service water cables are not in-scope of AMP B.1.19.

Thursday, June 1, 2006 Page 76 of 82

Number Status Request Response NRC Auditor PNPS Lead 313 Closed B.1.20-N-04 GALL Xl.E2 under The high-range radiation monitoring system Nguyen, Duc Stroud, Mike scope of program states that monitors radiation levels inside containment this program applies to (drywell and torus areas) during and following a electrical cables and design basis event. The monitors connections (cable system) (RE1001-606A/B and RE1001-607A/B) are used in circuits with sensitive, safety-related. The cables from the detectors high voltage, low-level signal to the cabinets in the control room are EQ (10 such as radiation monitoring CFR 50.49) and therefore, are replaced based and nuclear instrumentation on qualified life, so are not subject to aging that are subject to an AMR. management review.

PNPS AMP B.1.20 under the same attribute states that this program will include non-EQ electrical used in circuits with sensitive, high voltage, low-level signals, i.e., neutron flux monitoring instrumentation.

Explain why high range radiation monitor cables are not in scope of B.1.20.

314 Accepted B.1.20-N-05 GALL XI.E2 under a. LRPD-02 will be revised as follows: (Section Nguyen, Duc Stroud, Mike parameter monitored/inspected 3.5.B.3.b - Parameters Monitored/Inspected -

states that the parameter replace 2nd sentence) The parameters monitored are determined from monitored are determined from the specific the specific calibration, calibration, surveillances or testing performed surveillance or testing and are based on the specific instrumentation performed and are based on circuit under surveillance or being calibrated, as the specific instrumentation documented in plant procedures.

under surveillance or being calibrated, as documented in b. LRPD-02 will be revised to read as follows:

plant procedures. PNPS AMP (Section 3.5.B.3.b - Parameters B.1.20 under same attribute Monitored/Inspected - add to 2nd sentence) The states that results from the parameters monitored are determined from the calibrations or surveillance of specific calibration, surveillances or testing components within the scope of performed. The parameter for cable testing is license renewal will be determined from the plant procedures. Cable reviewed. The parameters testing is performed by plant procedures on reviewed will be based on the cables in-scope of license renewal that are specific instrumentation circuit disconnected during instrument calibration.

under surveillance or being calibrated, as document in the plant calibration or surveillance procedures.

a. Why does the review of calibration results belong to parameter monitored/inspected attribute?

b. The parameter monitored/inspected for cable testing was not mentioned.

What is the parameter for cable testing. Confirm that cable testing will be perform on cables in scope of XI.E2 that are disconnected during instrumentation calibration.

Thursday, June 1, 2006 Page 77 of 82

Number Status Request Response NRC Auditor PNPS Lead 315 Accepted B.1.21-N-03 GALL XI.E1 under "In a structure" means inside the plant, not Nguyen, Duc Stroud, Mike scope of program states that outside.

this inspection program applies to accessible electrical cables LRPD-02 will be revised to read as follows:

and connections within the (Section 3.6.B.1 .b - Scope of Program - add to scope of license renewal that scope) The program applies to accessible installed in adverse localized electrical cables and connections within the environments caused by heat scope of license renewal that are installed in or radiation in the presence of adverse localized environments caused by heat oxygen. PNPS B.1.21 under or radiation in the presence of oxygen.

the same element states that this program will include accessible insulated cables and connections installed in structures within the scope of license renewal and prone to adverse localized environments. What "in a structure" means? Why are structures included in the scope of non-EQ cables and connections AMP?

316 Accepted B.1.13.1-P-04 As indicated in the PNPS repetitive task Patel, Erach Potts, Lori database, functional testing of the cable

4. New question from site visit: spreading room Halon fire suppression system GALL report states that the is performed annually and inspection of the periodic function test and system is performed at least once every six inspection performed at least months. Therefore, LRA Section B.1.13.1 will be once every six months detects revised to include the following exception to the degradation of the halon/C02 Detection of Aging Effects Attribute.

fire suppression system before the loss of the component The NUREG-1801 program recommends that intended function. However, functional testing and inspection of the Halon per review of LRPD-02, Rev.1, fire suppression system occur at least once section 4.12.1.B.4.b, PNPS every six months. However, while PNPS performs this test once each performs inspections at least once every six operating cycle, which is months, functional testing is performed different than GALL report annually.

frequency. Please justify why this is not an exception to Exception note: The variation in functional test element 4, and if it is, please frequency is insignificant with relation to revise the LRA to include this detection of aging effects because functional exception. tests are designed to verify the operability of active system components. Since system inspections are performed at least once every six months, aging effects are identified prior to loss of passive component intended function.

This requires an amendment to the LRA.

317 Closed B.1.13.1-P-05 Loss of material for fire barrier walls, ceilings, Patel, Erach Potts, Lori and floors is addressed in procedure PNPS

5. New question from site visit: 8.B.29, Section 8.2 [1]. This procedure section In element 3, GALL states that describes how each fire barrier is to be visual inspection of the fire inspected. It directs inspectors to take note of barrier walls, ceilings, and any damaged portions of the barrier, and lists floors examines any sign of cracks/gaps/voids in walls as an example of degradation such as cracking, damage to be noted. It further states that if a spalling, and loss of material major defect exists in any barrier it will be caused by freeze-thaw, evaluated and entered into the corrective action chemical attack, and reaction action process.

with aggregates. Procedure 8.B.29 addresses cracking, spalling, etc., however LOM is not addressed. Where is LOM addressed?

Thursday, June 1, 2006 Page 78 of 82

Number Status Request Response NRC Auditor PNPS Lead 318 Accepted B.1.13.1-P-06 The exception in LRA Section B.1.13.1 will be Patel, Erach Potts, Lori revised to state: The NUREG-1801 program

6. New question from site visit: states that approximately 10% of each type of The GALL AMP XI.M26 penetration seal should be visually inspected at specifies approximately 10% of least once every refueling outage. The PNPS each type of seal should be program specifies inspection of approximately visually inspected at least once 20% of the seals, including at least one seal of every refueling outage (2 each type, each operating cycle, with all years). The exception taken in. accessible fire barrier penetration seals being the LRA states inspection of inspected at least once every five operating approximately 20% of seals cycles.

each operating cycle, with all accessible penetration seals This requires an amendment to the LRA.

being inspected at least once every five operating cycles (10 years). Please identify if each type of seal is included in this 20% sample.

319 Closed Please revise LRPD-02 pg 268, LRPD-02 pg 268, detection of aging effects for Patel, Erach Potts, Lori detection of aging effects for small bore piping inspection activity, will be small bore piping inspection revised to state: "Combinations of activity, to indicate that non-destructive examinations (including VT-1, volumetric examinations are enhanced VT-1, ultrasonic, and surface used to detect cracking in butt techniques) will be performed by qualified welds. Also revise LRPD-02 pg personnel following procedures that are 267, scope of program for consistent with Section XI of ASME B&PV Code water chemistry inspection and 10 CFR 50 Appendix B. Volumetric activity, to "A representative examinations are used to detect cracking in butt sample of susceptible welds. Actual inspection locations will be based components..." on physical accessibility, exposure levels, NDE techniques, and locations identified in NRC Information Notice 97-46".

LRPD-02 pg 267, scope of program.for water chemistry inspection activity, will be revised to state: "A representative sample of susceptible components of each material and environment crediting water chemistry control programs for aging management will be inspected."

320 Accepted Generic P-01 Program descriptions in Appendix A of the LRA Patel, Erach Cox, Alan will be revised, as applicable, to identify the Since Appendix A will be placed commitment number(s) associated with the in the FSAR immediately if program.

and when the license renewal application is approved, new The program descriptions in Appendix A for new programs should be presented or enhanced programs will be amended to in future tense, rather than include one of the following statements as present tense as currently applicable.

presented.

"License renewal commitment #

Also, SRP-LR states that all governs implementation of this program."

enhancements to programs should be listed in Appendix A, Or, UFSAR Supplement.

"License renewal commitment #

specifies enhancement to this program."

This requires an amendment to the LRA.

Thursday, June 1, 2006 Page 79 of 82

P Number Status Request Response NRC Auditor PNPS Lead 321 Accepted B.1.1-W-05 LRPD-02, Sections 4.1 .B.2.b and 4.1 .B.4.b will Wen, Peter Potts, Lori be revised to clarify that BADGER testing is an Please revise LRPD-02, areal density measurement.

Sections 4.1.B.2.b and 4.1 .B.4.b to clarify that Section 4.1.B.2.b will state:

BADGER testing is an areal density measurement. Silica levels in the spent fuel pool water are monitored monthly.

(Ref. Attachment 9, 7.8.1)

Gap formation is measured by blackness testing, areal density (BADGER) is periodically measured and the RACKLIFE predictive model is used.

(Ref. CR-PNP-2004-00285)

PNPS preventive actions are consistent with NUREG-1801.

Section 4.1.B.4.b will state:

The amount of boron carbide released from the Boraflex panels is determined through correlation of the silica levels in the spent fuel pool water using the RACKLIFE code. Detection of gaps through blackness testing and periodic verification of boron loss through areal density measurements (BADGER) identify loss of material and cracking of the Boraflex panels.

(Ref. Attachment 9, 7.8.1 and CR-PNP-2004-00285)

This program is credited with managing the following aging effects.

• change in material properties (reduction in neutron-absorbing capacity) for Boraflex neutron absorber panels (AMRM 21)

PNPS detection of aging effects is consistent with NUREG-1801.

322 Accepted B.1.1.11-N-03 10 CFR 50.49 does not require actions that Nguyen, Duc Stroud, Mike prevent aging effects.

Provide a description of preventive actions for the LRPD-02 will be revised to read as follows:

PNPS EQ Program. (Section 4.10.B.2.b - Preventive Actions - add to end of first sentence) The program actions that could be viewed as preventive actions are the identification of qualified life and specific maintenance/installation requirements.

323 Closed [B.1.32.2-P-02] Reactor water hydrogen peroxide Patel, Erach Loomis, Larry GALL AMP XI.M2, element 3, measurements, while they would be beneficial in Parameters determining the total oxidizing species affecting Monitored/Inspected, lists Stress Corrosion Cracking (SCC), are not monitoring of chlorides, practical. The results obtained through liquid sulfates, dissolved oxygen, sampling are inaccurate because of and hydrogen peroxide. decomposition of hydrogen peroxide in the However, LRPD-02, section sample lines. No practical method exists for a 4.23.2.B.3.b, which performs a BWR to obtain direct hydrogen peroxide comparison of element 3 with measurements.

the PNPS AMP, monitoring of hydrogen peroxide is not In accordance with BWRVIP-1 30, reactor water mentioned, and concludes that Electrochemical Corrosion Potential (ECP) and the PNPS AMP is consistent dissolved oxygen measurements are used at with this element. Please PNPS to determine whether oxidizing species clarify if hydrogen peroxide is including H202 have been reduced sufficiently not monitored, how is PNPS to minimize IGSCC.

consistent with this element?

Thursday, June 1, 2006 Page 80 of 82

Number' Status Request Response NRC Auditor PNPS Lead 324 Accepted [B.1.32.3-P-02] The last For clarity, LRA Section B.1.23.3, exception Patel, Erach Potts, Lori sentence of exception note 1 note 1 will be revised to state: "Passive states that "Passive intended intended functions of pumps, heat exchangers functions of pumps, heat and other components will be adequately exchangers and other managed by the closed cooling water chemistry components will be adequately and one-time inspection programs through managed by the closed cooling monitoring and control of water chemistry water chemistry program parameters and verification of the absence of through monitoring and control aging effects."

of water chemistry parameters." Isn't the one-time inspection program also used to verify effectiveness of the chemistry program? If so, should that be addressed as part of this exception note 1 justification?

325 Accepted [B.1.32.1-P-02] Element 6- Yes, this was a software conversion error. Patel, Erach Potts, Lori Acceptance Criteria states that Element 6 of LRA Section B.1.32.1 will be conductivity should be amended to correct the units of conductivity to maintained <0.3 S/cm. Is the pS/cm and delete the acceptance criteria for unit correct? Should it be corrosion products. Corrosion product (copper) pS/cm? (per LRPD-02, Rev. 1, sampling is used to determine the type of section 4.23.1.B.6) copper oxide layer formed. Thus it is a diagnostic parameter without an acceptance criterion.

326 Accepted [B.1.32.2-P-01] GALL Chapter Yes, the one-time inspection program described Patel, Erach Potts, Lori XI.M2 suggests that for in LRA Section B.1.23 includes inspections to "susceptible locations," a verify the effectiveness of the water chemistry one-time inspection verification control aging management programs by program may be appropriate. confirming that unacceptable cracking, loss of Do you intend to implement a material, and fouling is not occurring.

one-time inspection program for this water chemistry control LRA Section 3 Table l's discussions provide the program? link between the One-Time Inspection and Water Chemistry Control Program for Furthermore, will a one-time susceptible components. However, for clarity, inspection program be LRA Appendix A descriptions for the Water implemented for other water Chemistry Control - BWR, Closed Cooling chemistry control programs? If Water and Auxiliary Systems programs will be so, please explain why this is amended to provide a link to the One-Time not included in Appendix A for Inspection Program activities to confirm the each of these water chemistry effectiveness of these programs.

control programs.

This requires an amendment to the LRA.

Thursday, June 1, 2006 Page 81 of 82

Number Status Request Response NRC Auditor PNPS Lead 327 Accepted B.1.30-W-04 The enhancement in LRPD-02 was identified Wen, Peter Potts, Lori after the LRA was submitted to NRC for review.

LRPD-02 identifies an This enhancement will be added to LRA Section enhancement to the System B.1.30 as follows.

Walkdown Program that is not listed in the LRA. Please Enhancements Attribute Affected 1. Scope of Program Enhancement Enhance system walkdown guidance documents to clarify license .renewal commitment. The commitment for license renewal is for periodic system engineer inspections of systems in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(1) and (a)(3).

Inspections shall include areas surrounding the subject systems to identify hazards to those systems. Inspections of nearby systems that could impact the subject systems will include SSCs that are in scope and subject to aging management review for license renewal in accordance with 10 CFR 54.4(a)(2).

This requires an amendment to the LRA.

328 Accepted GALL XI.E1, XI.E2, XI.E3, and The programs will be updated to include the Nguyen; Duc Stroud, Mike XI.E4 indicates that operating following:

experience has shown that degradation of metal enclosed The XXX program is a new aging management bus, cables, and connections program. Industry operating experience that within the scope of El, E2, E3, forms the basis for the program is described in and E4 may exist. Provide a the operating experience element of the discussion of industry and NUREG-1801 program description. PNPS plant operating experience for plant-specific operating experience is consistent these programs. with the operating experience in the NUREG-1801 program description. Specifically, PNPS has experienced [insert PNPS component-specific OE similar to GALL OE].

Plant and industry operating experience with the methods planned for this program provides reasonable assurance that the program will be effective during the period of extended operation. The program is based on the program description in NUREG-1801, which in turn is based on relevant industry operating experience.

As such, operating experience indicates that implementation of the XXX program will provide reasonable assurance that effects of aging will be managed such that applicable components will continue to perform their intended functions consistent with the current licensing basis for the period of extended operation.

This requires an amendment to the LRA.

Thursday, June 1, 2006 Page 82 of 82

!K9ent+/-oward - Patch File .Page 1 From: Ram Subbaratnam To: James Davis Date: 6/5/2006 9:05:18 AM

Subject:

Patch File

,,J Nuclear power plants release varying amounts of tritium, depending on the amount of liquid waste discharged via normal and abnormal release discharge paths and the type of reactor. In the United States, there are two basic types of operating reactors, a pressurized water reactor (PWR) and a boiling water reactor (BWR). PWRs typically have higher tritium releases than BWRs. In 2003, the average PWR released about 700 curies of tritium in liquid effluents and the average BWR released about 30 curies of tritium in liquid effluents.

The NRC is proactive and taking action in investigating incidents reported by various licensees about radiological leaks and spills. For example, the NRC has established a lessons learned task force to address inadvertent, unmonitored liquid radioactive releases from U.S. commercial nuclear power plants. This task force will review previous incidents and identify lessons learned from these events and determine what, if any changes are needed to the regulatory program.

The NRC will enter the findings from the lessons learned task force into its formal agency lessons learned program.

The NRC licensing process for nuclear power plants includes a thorough review of all the plant's radioactive, gaseous, liquid, and solid waste systems, components, and programs to ensure that radioactive material is safely controlled in accordance with NRC regulations. The licensing process, evaluated the plant's ability to safely handle, store, monitor, and discharge radioactive effluents in accordance with NRC requirements. These requirements include safety limits on radiation dose to plant workers and members of the public. During operation of the plant, the NRC continuously inspects licensee performance through. the use of Resident Inspectors stationed at each plant and the use of technical specialist inspectors from the NRC Regional offices. If there is an abnormal situation at a plant, the Resident Inspector and Regional Specialists become involved to assess the licensee's response to the situation to ensure NRC requirements are met.

As with any industrial facility, a nuclear power plant may deviate from normal operation with a spill or leak of liquid material. However, the design of the plant and the NRC inspection program provides reasonable assurance that even in abnormal situations, safety limits are met.

Radiological health hazard and biological effects due to exposure to very small amounts of ionizing radiation is thought to minimally increase the risk of developing cancer, and the risk increases as exposure increases. Tritium is one of the least dangerous radionuclides because it emits very weak radiation and leaves the body relatively quick. Since tritium is almost always found as water, if ingested, it goes directly into soft tissues and organs. The dose to these tissues are generally uniform and dependent on the tissues' water content. Sr-90, if ingested, tends to mimic calcium when it is in the body and therefore becomes concentrated in calcified tissues such as bones and teeth. If ingested in quantities that produce very large doses (about a thousand times higher than what we all receive from natural radiation), Sr-90 is known to increase the risk of bone cancer and leukemia in animals, and is presumed to do so in people.

Below these doses, there is no evidence of excess cancer.

Radiological environmental monitoring and effluent monitoring at nuclear power plants is required by U.S. Nuclear Regulatory Commission regulations. The monitoring of radioactive effluents and the environment around the nuclear power plant is important both for normal operations, as well as in the event of an accident. During normal operations, environmental monitoring verifies the effectiveness of in-plant measures for controlling the release of radioactive materials, and makes sure that the levels of radioactive materials in the environment do not exceed those originally anticipated prior to licensing the plant. For accidents, it allows an additional means for estimating doses to members of the general public. The principal regulatory basis for requiring environmental monitoring and effluent monitoring at nuclear power plants is contained in General Design Criteria 60, 61, and 64 of Appendix A of Title 10 of the Code of Federal Regulations Part 50. The criteria require that a licensee control, monitor, perform radiological evaluations of all releases, document and report all radiological effluents discharged into the environment. We also have specific criteria that requires power reactor licensees to keep the public dose from radioactive effluents as low as it reasonably achievable (ALARA). The ALARA criteria is contained in Appendix I of 10 CFR Part 50. This criteria is very clear what the NRC expects of power reactors concerning their effluent discharges. The licensee shall establish an appropriate surveillance and monitoring program to:

1. Provide data on quantities of radioactive material released in liquid and gaseous effluents.

2. Provide data on measurable levels of radiation and radioactive materials in the environment to evaluate the relationship between quantities of radioactive material released in effluents and resultant radiation doses to individuals from principal pathways of exposure.

3. Identify changes in the use of unrestricted areas (e.g., for agricultural purposes) to permit modifications in monitoring programs for evaluating doses to individuals from principal pathways of exposure. Results from the environmental and effluent monitoring programs are reviewed by the NRC during routine inspections, and if the data indicate that the relationship between the quantities of effluents and the calculated doses to individuals is significantly different than that assumed in the licensing calculations, then the NRC may modify the allowable quantities in the Technical Specifications for the nuclear power plant. Prior to licensing a nuclear power plant, the NRC staff. review the applicant's proposed radiological environmental program. The applicant conducts a pre-operational program at least two years prior to initial criticality of the reactor. The pre-operational program documents the background levels of direct radiation and concentrations of radionuclides that exist in the environment. It also provides an opportunity for the licensee to train personnel, and to evaluate procedures, equipment, and techniques. A licensee's pre-operational environmental monitoring program is reviewed by NRC staff in regard to the criteria contained in the NRC's Radiological Assessment Branch Technical Position, Revision 1, November 1979, "An Acceptable Radiological Environmental Monitoring Program." The Branch Technical Position (BTP) contains an example of an acceptable minimum radiological monitoring program. Highlights of the BTP include:

monitoring of air at the offsite locations where the highest concentrations of radionuclides are expected; placement of dosimeters in two concentric rings around the plant; water samples (i.e., surface, ground, and drinking) upstream and downstream; milk samples at locations where the highest doses are expected; and various food samples. Lower limits of detection for the various types of samples and nuclides are specified. The operational radiological environmental monitoring program is essentially a continuation of the pre-operational program. The minimum requirements of the program are specified in the Radiological Effluent Technical Specifications (RETS) that are required pursuant to 10 CFR 50.36a. In addition, more detailed information about the program is contained in the licensee's Offsite Dose Calculational Manual, which is

referenced in the plant's RETS. The RETS also require that the licensee submit: (1) an annual radiological environmental monitoring report which is designed to assess the impact of radiological effluent releases into the environment; and (2) a Special Report within 30 days of discovery of the event if predetermined levels of radioactivity are exceeded. The NRC also requires that the licensee participate in an Interlaboratory Comparison Program to ensure the accuracy and precision of the licensee's data. The results of licensee's radiological environmental monitoring and effluent release programs are required to be reported annually to the NRC, and are available to the public. Radiation Dose Limits C:\temp\Nuclear power plants release varying amounts of tritium.wpd