ML082140838

License Renewal Application Audit Report

ML082140838
Person / Time
Site:	Beaver Valley
Issue date:	11/05/2008
From:	Kent Howard License Renewal Projects Branch 2
To:	Sena P FirstEnergy Nuclear Generation Corp
Howard K, NRR/DLR/RLRB, 415-2989
References
Download: ML082140838 (62)

Text

November 5, 2008 Peter P. Sena III Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB-1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

AUDIT REPORT REGARDING THE BEAVER VALLEY POWER STATION, UNIT 1 AND 2, LICENSE RENEWAL APPLICATION

Dear Mr. Sena:

By letter dated August 27, 2007, FirstEnergy Nuclear Operating Company, Units 1 and 2, submitted an application pursuant to 10 Code of Federal Regulations Part 54 (10 CFR Part 54),

to renew the operating license for Beaver Valley Power Station for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). On March 7, 2008, the NRC audit team completed the on-site audit of aging management programs. The audit report is enclosed.

If you have any questions, please contact me at 301-415-2989 or by e-mail at Kent.Howard@nrc.gov.

\RA\

Kent Howard, Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulations Docket Nos. 50-334 and 50-412

Enclosure:

As stated cc w/encl: See next page

November 5, 2008 Peter P. Sena III Site Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-SEB-1 P.O. Box 4, Route 168 Shippingport, PA 15077

SUBJECT:

AUDIT REPORT REGARDING THE BEAVER VALLEY POWER STATION, UNIT 1 AND 2, LICENSE RENEWAL APPLICATION

Dear Mr. Sena:

By letter dated August 27, 2007, Beaver Valley Power Station, submitted an application pursuant to 10 Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating license for Beaver Valley Power Station for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). On March 7, 2008, the NRC audit team completed the on-site audit of aging management programs. The audit report is enclosed.

If you have any questions, please contact me at 301-415-2989 or by e-mail at Kent.Howard@nrc.gov.

\RA\

Kent Howard, Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulations Docket Nos. 50-334 and 50-412

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION: See next page ADAMS Accession Number: ML082140838 OFFCIE LA:DLR PM:RPB2:DLR BC:RPB1:DLR BC:RER2:DLR BC:RPB2 NAME IKing KHoward JDozier RAuluck RFranovich (DWrona for)

DATE 08/08/08 11/05/08 08/10/08 08/19/08 11/05/08 OFFICIAL RECORD COPY

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION - DIVISION OF LICENSE RENEWAL Docket No: 050-00334 and 050-00412 License No: DPR-66 and NPF-73 Licensee: FirstEnergy Nuclear Operating Company Facility: Beaver Valley Power Station, Units 1 and 2 Location: Mailstop A-BV-SEB-1 Route 168 Shippingport, PA 15077 Dates: March 3-7, 2008 Reviewers: K. Howard, Project Manager, Division of License Renewal (DLR)

K. Chang, Branch Chief, DLR J. Medoff, Sr. Mechanical Engineer, DLR J. Davis, Sr. Materials Engineer, DLR R. Sun, Mechanical Engineer, DLR D. Hoang, Structural Engineer, DLR Z. Xi, Structural Engineer, DLR D. Nguyen, Electrical Engineer, DLR R. Li, Electrical Engineer, DLR E. Patel, Consultant (ISL)

C. Marks, Consultant (ISL)

Approved By: Rajender Auluck, Chief Engineering Review Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Jerry Dozier, Chief Engineering Review Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation ENCLOSURE

Introduction A five-day audit was conducted by the NRC project team at the plant in Shippingport, PA on March 3-7, 2008. The purpose of this audit was to examine the applicants Aging Management Programs (AMPs) documentation for Beaver Valley Power Station (BVPS) Units 1 & 2 and to verify the applicants claim of consistency with the corresponding GALL AMPs. Exceptions to the GALL AMP elements will be evaluated separately as part of the NRC staffs (the staff) review of BVPS license renewal application (LRA) and documented in the staffs Safety Evaluation Report (SER).

The Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800) provides the staff guidance for reviewing a license renewal application (LRA). The Standard Review Plan allows an applicant to reference in its LRA the AMPs described in NUREG-1801, Generic Aging Lessons Learned (GALL) Report. By referencing the GALL AMPs, the applicant concludes that its AMPs correspond to those AMPs which are reviewed and approved in the GALL Report, and that no further staff review is required. If an applicant credits an AMP for being consistent with a GALL program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL program. The applicants determination should be documented in an auditable form and maintained on-site.

During this audit, the staff audited program elements 1-6, and program element 10, (operating experience), of the applicants AMPs claimed to be consistent with the GALL report against the related elements of the associated AMP described in the GALL Report, unless otherwise indicated in this Audit Report. Elements 7-9 which address corrective actions, confirmation process, and administrative controls were audited by another NRC project team during the Scoping and Screening Methodology audit and are evaluated separately. The NRC project team audited all AMPs that the applicant stated were consistent with the GALL report AMPs.

During this audit, if an applicant took credit for a program in the GALL Report, the staff verified that the plant program contains all the elements of the referenced GALL Report program. In addition, the staff verified the conditions at the plant were bounded by the conditions for which the GALL Report program was evaluated.

In performing this audit, the staff examined the applicants program bases documents and related references for these AMPs. The NRC project team also interviewed Beaver Valley representatives to obtain additional clarification related to the BVPS AMPs. This report documents the staff activities during this audit.

LRA AMP B.2.1, 10 CFR Part 50, Appendix J In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.1 is an existing program that is consistent with GALL AMP XI.S4, 10 CFR Part 50, Appendix J.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the AMP elements are consistent with the elements in the GALL AMP XI.S4. The staff interviewed the applicant's technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.S4 10 CFR Part 50, Appendix J Rev. 2, 06/28/07 LRVB-OE-001 Operating Experience Review Report Rev. 3, 01/16/08 1BVT 1.47.1 Unit 1 Containment Structural Integrity Test Rev. 9, 03/30/06 2BVT 1.47.1 Containment Structural Integrity Test Rev. 7, 09/08/06 CR 06-02024 1R17 Containment Exterior Concrete 03/15/06 Deficiencies Identified By 1BVT 1.47.1 Unit 1 Containment Type A Leak Test Results 04/15/06 Report Unit 2 Containment Type A Leak Test Results 11/10/93 Report In comparing the elements in the applicants program to those in GALL AMP XI.S4, the staff found that BVPS chose Option B of Appendix J, the performance based approach, for meeting the GALL Reports monitoring and trending element. However, the staff identified two issues where additional clarifications were needed to complete the review. The first issue noted by the staff was the risk impact evaluation. Since BVPS uses option B, the performance-based approach, the relaxation of Option B Integrated Leak rate test (ILRT) frequency for 15 years is based on the risk impact assessment. The second issue was that the applicant did not address how to incorporate the abovementioned liner degradation to the ILRT pretest procedure. The staff will consider issuing RAIs to address these issues, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. The review indicated the most recent Unit 1 Type A test, conducted on April 14, 2006, showed a leakage rate (including the Type B and Type C Penalty Additions and Tank Change Volume Corrections) of 0.00324 %wt/day, which was below the Acceptance Criteria of 0.075 %wt/day. The most recent Unit 2 Type A test, conducted on November 10, 1993, showed a leakage rate of 0.04011

%wt/day, which was below the Acceptance Criteria of 0.075 %wt/day.

The 3 program elements, corrective actions, confirmation process, and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.S4, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.2, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program In the Beaver Valley Power Station LRA, the applicant stated that AMP B.2.2 is an existing program that is entirely consistent with the program elements in GALL AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, with an exception on the Code edition that is recommended for aging management in the scope of program, parameters monitored or inspected, detection of aging effects, monitoring and trending, and acceptance criteria, and program elements of GALL AMP XI.M1. The applicants ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program is credited to manage the effects of aging in ASME Code Class 1, 2, and 3 systems and components. The applicant also credits this AMP to manage the effects of aging that are applicable to the ASME Code Class 1, 2, and 3 component supports.

During its audit, the staff audited the applicants on-site documentation to determine whether those program elements claimed to be consistent with GALL in the applicants AMP are consistent with the program elements recommended in GALL AMP XI.M1. The staff interviewed the applicants technical staff and audited the following additional on-site documents and NRC-issued documents listed below:

DOCUMENT TITLE REVISION /DATE FENOC Program Evaluation ASME Section XI Inservice Inspection, Rev. 3, 1/17/08 Document LRBV-PED-XI.M1 Subsection IWB, IWC, and IWD.

FENOC Program Evaluation Operating Experience Review Report Rev. 3, 1/16/08 Document LRBV-OE-001 FENOC Program Evaluation Industry Operating Experience Review Rev. 2, 11/30/08 Document LRBV-OE-002 and Licensee Events FENOC Procedure No. 1/2- Beaver Valley Power Station Unit 1/2, Rev. 4, 07/13/06 ADM-2039 BVPS ISI Ten-Year Plans FENOC Procedure No. 1/2- ASME Section XI Repair/Replacement Rev. 5, 09/06/06 ADM-0801 Program NRC Safety Evaluation Beaver Valley Power Station, Unit 04/09/04 Nos. 1 and 2 (BVPS-1 and 2), Risk-Informed Inservice Inspection (RI-ISI)

Program (TAC Nos. MB5687 and MB5688)

BVPS Letter l-02-066 Beaver Valley Power Station, Unit No. 07/24/02 1 and No. 2, BV-1 Docket No. 50-334, License No. DPR-66, BV-2 Docket No.

50-412, License No. NPF-73, Risk-Informed Inservice Inspection Program Plans. ISI (Inservice Inspection)

Program Relief Request FENOC Corporate Nuclear Corrective Action Program Rev.15, 02/28/08 Operating Procedure NOP-LP-2001

Specifically, the staff audited the program element descriptions for the scope of program, preventative actions, parameters monitored/detected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, and operating experience, program elements in the applicants program against the corresponding program element descriptions that are defined and described in GALL AMP XI.M1.

The staffs audit of the confirmation process, and administrative controls program elements were performed as part of the staffs audit of the quality assurance program for the LRA.

In comparing the stated 8 program elements of the applicants program to those in GALL AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, the staff noted that the program elements in the applicants AMP claimed to be consistent with the GALL Report were consistent with the corresponding program element criteria recommended in the program elements of GALL AMP XI.M1 except for two (2) topics which the staff felt were in need of additional clarification. The staff will consider issuing RAIs to address these issues, and the staffs evaluation will be documented in the SER.

In the first topic needing additional clarification, the staff noted that the applicant had credited its current risk-informed inservice inspection (RI-ISI) program for the period of extended operation.

The staff noted that that the staffs approval of this RI-ISI program was limited only to the current 10-Year inservice inspection (ISI) intervals for the BVPS units and that RI-ISI had yet to be requested or approved for the period of extended operation. The staffs basis for considering issuing this RAI is discussed in the SER section for this AMP.

In the second topic needing additional clarification, the staff noted that the applicant had not credited the edition of the ASME Code Section XI that is recommended for use in GALL AMP XI.M1. The staffs basis for considering issuing this RAI is discussed in the SER section for this AMP.

The staff audited the applicants operating experience and selected reports associated with Inservice Inspection, Subsections IWB, IWC, and IWD. The staff also interviewed the applicantss technicial staff to confirm that plant-specific operating experience did not reveal any degradation outside the bounds of industry experience.

The 2 program elements, confirmation process, and administrative controls, were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 8 program elements in the applicants program and verified that these 8 elements for the AMP were consistent with those specified in GALL AMP XI.M1, not including any exceptions identified by the applicant in the LRA for this AMP, which will be evaluated separately in the SER, and the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.3, ASME Section XI, Subsection IWE In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.3 is an existing program that is consistent with GALL AMP XI.S1, ASME Section XI, Subsection IWE with exception.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the AMP elements are consistent with the elements in the GALL AMP XI.S1. The staff interviewed the applicant's technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.S1 ASME Section XI, Subsection IWE Rev. 2, 06/25/07 LRVB-OE-001 Operating Experience Review Report Rev. 3, 01/16/08 IWE-L BVPS Unit 1 and Unit 2, Primary Rev. 0, 12/13/99 Containment Inservice Inspection Program Plan, 1BVT 1.47.1 Unit 1Containment Structural Integrity Rev. 9, 03/30/06 Test 2BVT 1.47.1 Containment Structural Integrity Test Rev. 7, 09/08/06 CR 06-01122 1R17 Containment Exterior Concrete 3/15/06 Deficiencies Identified By 1BVT 1.47.1 In comparing the elements in the applicants program to those in GALL AMP XI.S1, the staff found that an exception due to the use of ASME Section XI edition for 6 GALL elements scope of program, parameters monitored or inspection, detection of aging effects, monitoring and trending, acceptance criteria, and corrective actions. A generic RAI will be considered to be issued to the applicant for clarifying which Edition of the ASME Code Section XI will be credited for those AMPs that credit the ASME Code Section XI during the period of extended operation.

The staff also audited the operating experience reports, including some condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. The audit indicated that during refueling outage 1R17 in 2006, the temporary construction opening for Unit 1 steam generators and the reactor vessel head replacement revealed three areas of significant corrosion on the containment liner plate on the side in contact with the concrete. However, the applicant could not identify a root-cause of the corrosion. Therefore, the staff identified three issues where additional clarifications were needed to complete the review. The first issue was the possibility and severity of the similar corrosion at other locations in Unit 1 and Unit 2. The second issue was the effectiveness of the modified test procedure after refueling outage 1R17 for detecting the similar corrosion found during refueling outage 1R17. The last issue was whether the refueling outage 1R17 liner corrosion finding had led to an augmented inspection under the BVPS IWE Program. The staff will consider issuing RAIs to address these issues, and the staffs evaluation will be documented in the SER.

The 2 program elements, confirmation process, and administrative controls, were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 8 program elements in the applicants program

and verified that these 8 elements for the AMP were consistent with those specified in GALL AMP XI.S1, not including any exceptions identified by the applicant in the LRA for this AMP, which will be evaluated separately in the SER, and the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.4, ASME Section XI, Subsection IWF In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.4 is an existing program that is consistent with GALL AMP XI.S3, ASME Section XI, Subsection IWF with exception.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the AMP elements are consistent with the elements in the GALL AMP XI.S3. The staff interviewed the applicant's technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.S3 BVPS ASME Section XI, Subsection Rev. 3, 07/30/07 IWF Program LRVB-OE-001 Operating Experience Review Report Rev. 3, 01/16/08 1/2-ADM-2039 BVPS ISI Ten-Year Plans Rev. 4, 07/13/06 2R10 90 Day ISI Unit 2 ISI examinations for Class 1, 2, Fall 2003 Report 3 and MC components 1R17 90 Day ISI Unit 1 ISI examinations for Class 1, 2, Spring 2006 Report 3 and MC components In comparing the elements in the applicants program to those in GALL AMP XI.S3, the staff found that an exception due to the use of ASME Section XI edition for 6 GALL elements Scope of Program, Parameters Monitored or Inspection, Detection of Aging Effects, Monitoring and Trending, Acceptance Criteria, and Corrective Actions. A generic RAI will be considered to be issued to the applicant to clarify which Edition of the ASME Code Section XI will be credited for those AMPs that credit the ASME Code Section XI during the period of extended operation.

The staff also found that the BVPS chose alternate rules for examination, ASME Code Case N-491, for meeting the GALL Report Program Description. However, in the Operating Experience element, an IWF table of ASME Section XI, Subsection IWF, 1989 edition was used. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience reports, including some condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. The condition reports documented instances of pipe support degradation. The applicant determined the causes included supports being exposed to standing water, and being exposed to moisture via pipe leaks or pipe condensation. The applicants identification and resolution of these issues provides reasonable assurance that the program effectively manages aging for component supports. During refueling outage 1R17 in 2006, the applicant performed Unit 1 ISI examinations on Class 1, 2, 3 and MC components. Class 1 exams (VT-3 visual exams for pipe and vessel supports), Class 2 exams (supports-visual), and visual exams of Class 3 supports were performed as part of this inspection. There were no recorded ISI non-destructive examination deficiencies in refueling outage 1R17. During the 2R10 refueling outage in 2003, the applicant performed Unit 2 ISI examinations on Class 1, 2, and MC components. Class 2 exams were also performed. The applicant found no ISI non-destructive examination deficiencies in refueling outage 2R10.

The 2 program elements, corrective action, confirmation process, and administrative controls, were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 8 program elements in the applicants program and verified that these 8 elements for the AMP were consistent with those specified in GALL AMP XI.S3, not including any exceptions identified by the applicant in the LRA for this AMP, which will be evaluated separately in the SER, and the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.5, ASME Section XI, Subsection IWL In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.5 is an existing program that is consistent with GALL AMP XI.S2, ASME Section XI, Subsection IWL.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the AMP elements are consistent with the elements in the GALL AMP XI.S2. The staff interviewed the applicant's technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.S2 ASME Section XI, Subsection IWL Rev. 5, 01/16/08 LRVB-OE-001 Operating Experience Review Report Rev. 3, 01/16/08 1/2-ADM-0801 ASME Section XI, Rev. 5, 09/06/06 Repair/Replacement Program LRBV-CAMR-101 Equipment Hatch Platform and Rev. 2, 07/17/07 Reactor Containment Building, Unit 1 LRBV-CAMR-201 Equipment Hatch Platform and Rev. 2, 07/17/07 Reactor Containment Building, Unit 2 NDE-VT-512 Visual Examination of Concrete Rev. 3, 09/21/07 Containment Buildings CRs: 06-8067, 01-06842, 01- IWL Summary report 1R17 & 2R10 2006 04646, and 01-4645 In comparing the elements in the applicants program, the staff verified that the program elements contained in Beaver Valley AMP B.2.5 are consistent with GALL AMP XI.S2 program elements.

The staff also audited the operating experience reports, including some condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. The applicant performed its most recent containment structure IWL inspections during refueling outages 1R17 and 2R10 in 2006. The applicants inspection results confirmed the physical condition of the concrete for Unit 1 and Unit 2 containment structures was satisfactory. The applicant identified no non-conformities, unusual wear, or damage observed in the exterior concrete at either unit.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.S2.

LRA AMP B.2.6, Bolting Integrity In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.6 is an existing program that is consistent with GALL AMP XI.M18, Bolting Integrity.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION / DATE LRBV-PED-XI.M18 Beaver Valley Power Station (BVPS) Rev. 2, 7/5/07 Bolting Integrity Program PROPOSED 1/2- Bolting Integrity Program Proposed ADM-[XI.M18]

PIPS M08.3 Category I, II, III and F bolting Program Rev. 3, 12/29/98 LRBV-AMPB-001 Aging Management Program Common Rev. 1, 7/9/07 Information EPRI-1002950 Aging Effects for Structures and Structural Rev. 1, 8/03 Components (Structural Tools), Rev 1 LRBV-OE-001 Operating Experience Review Report Rev. 3, 1/16/08 In comparing the elements in the applicants program to those in GALL AMP XI.M18, the staff found that the GALL Report monitoring and trending program element recommending leak rate to be monitored on a particularly defined schedule was not properly documented in the applicants bolting integrity program. Additionally, the staff found that although the BVPS LRA claimed that the B.2.6 Bolting Integrity AMP was consistent with the GALL AMP, in the applicants basis documents there appeared to be an exception to the GALL Report parameters monitored/inspected program element related to crack monitoring of high strength bolts (actual yield strength 150 ksi) used in Nuclear Steam Supply System (NSSS) component supports. The staff will consider issuing RAIs to address these issues, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. A condition report indicated that in 2002, during a VT-1 visual inspection of reactor coolant pump flange bolts, the condition of a bolt was determined to be unsatisfactory. The specific condition the applicant observed was blistering of the bolt coating in the mid-shank area between the head and threads. The threads were also noted to be lightly rusted, and the bolt was replaced. Upon further staff questioning of the BVPS staff and review of the CR, it was learned that the applicant performed additional investigation to verify the integrity of the remaining flange bolts.

As a result, 3 bolts were replaced in total, and proper corrective actions were demonstrated.

The 3 program elements, corrective actions, confirmation process, and administrative controls, were audited as part of the Scoping and Screening Methodology audit.

During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M18, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.7, Boric Acid Corrosion Program In the LRA, the applicant stated that AMP B.2.7 is an existing program that is consistent with GALL AMP XI.M10, Boric Acid Corrosion.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.M10 Boric Acid Corrosion Program Rev. 5, 01/18/08 Evaluation document NOP-ER-2001 Boric Acid Corrosion Control Rev. 6, 02/02/07 Program CR 03-09455 Valve encrusted with dry boric acid 09/14/03 CR 06-04426 Boric acid identified during walk 07/24/06 down of primary system L-03-138 Applicant response NRC Bulletin 09/19/03 2003-02 L-02-095 Applicant response NRC Bulletin 09/11/02 2002-02 In comparing the elements in the applicants AMP to those in GALL AMP XI.M10, the staff found that the applicant did not identify whether all the components, including all Class 1 nickel alloy locations as per the NRC Order EA-03-009, Bulletins 2003-02 and 2004-01 were included in the scope of this program. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M10, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.8, Buried Piping and Tanks Inspection In the BVPS LRA, the applicant stated that LRA AMP B.2.8 is a new program that is consistent with GALL AMP XI.M34, Buried Piping and Tanks Inspection.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL report. The staff interviewed the applicants technical staff and audited the following on-site documents listed.

DOCUMENT NUMBER TITLE REVISION/DATE LRBV-MAMR-022 Aging Management Review of the Vol. 1 & 2, Rev. 5, Condensate System 06/22/07 LRBV-MAMR-24B Aging Management Review of the Rev. 6, 08/03/07 Feedwater System LRBV-MAMR-030-1 Aging Management Review of the Rev 5, 06/22/07 River Water System LRBV-MAMR-030-2 Aging Management Review of the Rev 5, 06/22/07 Service Water System LRBV-MAMR-032 Aging Management Review of the Vol. 1 & 2, Rev. 5, Water Treating System 08/03/07 LRBV-MAMR-033 Aging Management Review of the Fire Rev 5, 06/22/07 Protection System LRBV-MAMR-36A Aging Management Review of the Rev 6, 07/20/07 Diesel Generator System LRBV-MAMR-45F Aging Management Review of the Rev 5, 06/22/07 Security Diesel Generator System LRBV-PED-XI.M34 Buried Piping and Tanks Inspection Vol. Rev. 7, 08/09/07 1

LRBV-PED-XI.M34 Buried Piping and Tanks Inspection Vol. Rev. 7, 08/09/07 2

In comparing the elements in the applicants program to those in GALL AMP XI.M34, the staff found that the applicant had addressed all elements in a satisfactory manner. In addition, the elements were consistent with the GALL Report.

The staff also audited the operating experience, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. In the application, the applicant stated that there is no operating experience with the effectiveness of the program because it is a new program. In order to be consistent with the staffs recommendations in Section A.1.2.3.10, item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), the staff will consider issuing an RAI requesting that the applicant provide a commitment in the application to submit future operating experience on this AMP to the staff in order to confirm the effectiveness of this program. This RAI will also consider requesting the applicant to discuss and submit any observed material degradation found during the implementation of other existing activities that relate to the aging effects that will be managed by the new program. This RAI will be evaluated and documented in the SER.

The 3 program elements, corrective actions, confirmation process, and administrative controls, were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M34, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.9, Closed-Cycle Cooling Water System In the LRA, the applicant stated that AMP B.2.9 is an existing program that, following enhancements, will be consistent with GALL AMP XI.M21, Closed-Cycle Cooling Water System.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.M21 Beaver Valley Power Station Closed- Rev. 4, 07/30/07 Cycle Cooling Water Program (Unit 1 and Unit 2)

Enhanced 1/2-ADM- Closed Loop and River Water Rev. 2, 09/20/06 1738 System Monitoring Program LRBV-OE-001 CR 06-02674/Biofouling Rev. 3, 01/16/08 LRBV-OE-001 CR 05-07400/Component cooling Rev. 3, 01/16/08 water chemistry out of tolerance In comparing the elements in the applicants AMP to those in GALL AMP XI.M21, the staff found that the applicant has taken enhancements as follows:

1. Added components (diesel-driven fire pump Unit 1 only and diesel-driven standby air compressor Unit 2 only) to the Closed-Cycle Cooling Water System Program under the Scope of Program. The staff noticed that the systems crediting the Closed-Cycle Cooling Water System identified by the applicant were not complete as compared with the AMR Tables. Therefore, the staff will consider issuing a RAI to address this issue.

2. Added detail to procedures providing direction in the performance of visual inspections of system components and performance testing of heat exchangers and pumps under Parameters Monitored/Inspected. The staff noticed that although the diesel-driven fire pump and diesel-driven standby air compressor were added to the Closed-Cycle Cooling Water System Program, no instrumentation exists for performance testing. Therefore, the staff will consider issuing a RAI to address this issue.

3. Added parameters to Detection of Aging Effects specifying parameters that will be trended to determine whether heat exchanger tube fouling or corrosion product buildup exists.

4. Added requirements to specify visual inspection test frequency to Monitor and Trending.

The Operating Experience explains that EDG Jacket Water system bolting for the temperature control valves may be subject to unexpected corrosion; however, there are no AMR lines for bolting credited with this program. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M21, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.11, Electrical Cable and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.11 is a new program that is consistent with GALL AMP XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

During its audit, the staff audited the applicants claim of consistency with the GALL AMP.

Specifically, the staff interviewed the applicant's technical staff and audited the following documents:

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.E1 Electrical Cables and Connections Not Subject Rev. 3, 07/23/07 to 10 CFR 50.49 Environmental Qualification Requirements Program Evaluation Document LRBV-PED-XI.E1 Electrical Cables and Connections Not Subject Rev. 3, 07/23/07 to 10 CFR 50.49 Environmental Qualification Requirements References LRBV-EAMR-001 BVPS License Renewal Project Document Rev. 5, 11/30/07 In comparing the elements in the applicants program, the staff verified that the program elements contained in Beaver Valley AMP B.2.11 are consistent with GALL AMP XI.E1 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP. The staff also verified that the applicant provided an adequate summary description of the program.

The staff audited the LRV-EAMR-001, Revision 5, where the threshold temperature and radiation level for localize environment is defined. The applicant representative clarified the sample process for inspecting cables and connections located in adverse localized environments. The staff verified the technical information and guidance identified in GALL AMP XI.E1 were presented in Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements References LRBV-PED-XI.E1. The LRA states that AMP B.2.11 is a new program for which there is no plant-specific program operating experience.

In order to be consistent with the staffs recommendations in Section A.1.2.3.10, item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), the staff will consider issuing an RAI requesting that the applicant provide a commitment in the application to submit future operating experience on this AMP to the staff in order to confirm the effectiveness of this program. This RAI will also consider requesting the applicant to discuss and submit any observed material degradation found during the implementation of other existing activities that relate to the aging effects that will be managed by the new program. This RAI will be evaluated and documented in the SER.

The 3 program elements, corrective actions, confirmation process, and administrative controls, were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.E1, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.12, Electrical Cable and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.12 is a new program that is consistent with GALL AMP XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.

During its audit, the staff audited the applicants claim of consistency with the GALL AMP.

Specifically, the staff interviewed the applicant's technical staff and audited the following documents:

DOCUMENT TITLE REVISION / DATE LRBV-PED-XI.E2 Electrical Cables and Connections Not Rev. 4, 01/31/08 Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuit Program Evaluation Document LRBV-PED-XI.E2 Electrical Cables and Connections Not Rev. 4, 01/31/08 Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuit References LRBV-EAMR-001 BVPS License Renewal Project Document Rev. 5, 11/30/07 The staff verified the program elements contained in Beaver Valley AMP B.2.12 are consistent with GALL AMP XI.E2 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP. The staff also verified that the applicant provided an adequate summary description of the program.

Beaver Valley AMP B.2.12, Electrical Cable and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits, states that this program includes high-range radiation monitors and excore nuclear instrumentation circuits.

GALL AMP XI.E2 applies to high-range radiation monitors and neutron flux monitoring instrumentation cables. The staff audited BVPS License Renewal Project Document, LRBV-EAMR-001 and verified that excore nuclear instrumentation (source range, intermediate range, and power range) are the same as neutron flux monitoring instrumentation cable.

The LRA states that AMP B.2.12 is a new program for which there is no plant-specific program operating experience. In order to be consistent with the staffs recommendations in Section A.1.2.3.10, item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), the staff will consider issuing an RAI requesting that the applicant provide a commitment in the application to submit future operating experience on this AMP to the staff in order to confirm the effectiveness of this program. This RAI will also consider requesting the applicant to discuss and submit any observed material degradation found during the implementation of other existing activities that relate to the aging effects that will be managed by the new program. This RAI will be evaluated and documented in the SER.

The 3 program elements, corrective actions, confirmation process, and administrative controls, were audited as part of the Scoping and Screening Methodology audit. During the Aging

Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.E2, not including any exceptions identified by the applicant in the LRA for this AMP, which will be evaluated separately in the SER, and the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.14, Environmental Qualification of Electric Component Program In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.14 is an existing program that is consistent with GALL AMP X.E1, Environmental Qualification of Electric Components.

During its audit, the staff audited the applicants claim of consistency with the GALL AMP.

Specifically, the staff interviewed the applicant's technical staff and audited the following documents:

DOCUMENT TITLE REVISION /DATE LRBV-PED-X.E1 Environmental Qualification of Electrical Rev. 3, Vol. 1 Component Program (Unit 1 and Unit 2) 07/30/07 LRBV-PED-X.E1 Environmental Qualification of Electrical Rev. 3, Vol. 2 Component Program References 07/30/07 In comparing the elements in the applicants program, the staff verified that the program elements contained in BVPS AMP B.2.14 are consistent with GALL AMP X.E1 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP. The staff also verified that the applicant provided an adequate summary description of the program.

The technical information and guidance identified in GALL AMP X.E1 were presented in Environmental Qualification of Electrical Component Program LRBV-PED-X.E1 and references.

Based on its audit, the staff found that the applicant did not include reanalysis attributes in the program description of BVPS AMP B.2.14 and FSAR supplement. Section 4.4 of the LRA indicates that the aging effects of the EQ of electrical equipment identified as TLAAs will be managed during the period of extended operation under 10 CFR 54.21(c)(iii). However, no information is provided in the applicants program and FSAR supplement regarding reanalysis attributes to extend the qualified life of EQ components. Important attributes for the reanalysis of an aging evaluation include analytical methods, data collection and reduction methods, underlying assumptions, acceptance criteria, and corrective actions (if acceptance criteria are not met). The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The applicant stated in its LRBV-PED-X.E1, Volume 1, that the Detection of Aging Affects and Monitoring and Trending program sub-element is consistent with GALL AMP X.E1 and the applicant referred to procedure 1/2-ADM-2014, Section 7.9 and 7.10. However, the staff audited this reference and found that it did not specifically address monitoring or inspection of certain environments to ensure that components are within the bounds of their qualification bases. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. The applicant performed a self-assessment in 2006 based upon industry operating experience that identified discrepancies in the information contained within the preventive maintenance (PM) database and the associated EQ program documentation. The self-assessment found that one of the 94

EQ Maintenance Assessment Packages was deficient in the PM database and would have caused the equipment to be relied upon beyond its qualified life value. A corrective action program report was generated by the applicant to correct the requirement frequency from 22 years to 20 years. This demonstrates that the current EQ program is effectively identifying problems and implementing corrective actions.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP X.E1, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.15, External Surface Monitoring Program In the LRA, the applicant stated that AMP B.2.15 is a new program that when implemented will be consistent with GALL AMP XI.M36, External Surface Monitoring.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.M36 External Surfaces Monitoring Rev. 4, 07/20/07 Program Evaluation Document SPEAP-2.1 Performance of System Walk downs Rev. 5, 05/30/01 In comparing the elements in the applicants AMP to those in GALL AMP XI.M36, the staff found that the applicant has expanded the scope of the External Surfaces Monitoring Program beyond what the GALL AMP addresses. The GALL AMP XI.M36 is credited for managing the aging effect of loss of material due to general, pitting and crevice corrosion for steel components. The applicant states its program is consistent with the GALL AMP, however, it also manages hardening, loss of strength and cracking of elastomers; reduction of heat transfer of Emergency Response Facility diesel generator jacket water radiator fins; and loss of material for aluminum, Cast Austenitic Stainless Steel, stainless steel, copper alloy and nickel alloy components. The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The operating experience element states that the External Surface Monitoring Program is a new program and there is no plant-specific program operating experience. However, during performance of surveillance tests or preventive maintenance or during system walk-downs, any degradation of exterior surfaces that was observed would have been documented. In order to be consistent with the staffs recommendations in Section A.1.2.3.10, item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), the staff will consider issuing an RAI requesting that the applicant provide a commitment in the application to submit future operating experience on this AMP to the staff in order to confirm the effectiveness of this program. This RAI will also consider requesting the applicant to discuss and submit any observed material degradation found during the implementation of other existing activities that relate to the aging effects that will be managed by the new program. This RAI will be evaluated and documented in the SER.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M36, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.16, Fire Protection Program In the LRA, the applicant stated that AMP B.2.16 is an existing program that, following enhancement, will be consistent with GALL AMP XI.M26, Fire Protection, with an exception.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.M26 Fire Protection Program Evaluation Rev. 4, 02/22/08 document 1/2-ADM-1900 Fire Protection Program Rev. 14, 12/29/06 CR 03-08988 Degraded fire wrap material on 09/15/04 ductwork CR 06-04450 Degraded fire seal found 07/24/06 In comparing the elements in the applicants AMP, the staff found that the applicant has taken enhancements as follows:

1. Add into the scope of program element the fire protection systems that are within the scope of license renewal. The systems will also be included in the detection of aging effects, monitoring and trending, and acceptance criteria elements.

2. Enhance the inspection guidance to include details about fire barrier degradation The applicant took an exception to the frequency of Halon and carbon dioxide system functional test. The GALL Report AMP recommends a frequency of once every six months whereas the applicant is using once every eighteen months. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

As part of the exception, the applicant stated that it will change the frequency of Halon and carbon dioxide system inspections to once every 6 months compared to once every eighteen months during the period of extended operation. However, the applicant did not include an enhancement or a commitment in the LRA. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M26, not including any exceptions identified by the applicant in the LRA for this AMP, which will be evaluated separately in the SER, and the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.17, Fire Water System Program In the LRA, the applicant stated that AMP B.2.17 is an existing program that, following enhancements, will be consistent with GALL AMP XI.M27, Fire Water System.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.M27 Fire Water System Program Rev. 3, 08/08/07 Evaluation Document 1/2-ADM-1900 Fire Protection Program Rev. 14, 12/29/06 CR 05-3940 Fire protection piping through wall 05/24/05 leak CR 06-05051 Fire protection piping through wall 08/27/06 leak CR 07-13290 Fire protection leak 01/24/07 In comparing the elements in the applicants AMP, the staff found that the applicant has taken enhancements as follows:

1. Added a program requirement in the parameters monitored/inspected element to perform flow test or inspection of all accessible fire water headers

2. Added program requirements in the detection of aging effects element to identify locations if visual inspections are to be performed; allow test of inspection results from accessible sections of pipe to be extrapolated for inaccessible pipe; require flow testing of all accessible headers and piping; and require testing or replacement of sprinkler heads in service for 50 years.

3. The applicant also included an enhancement in the detection of aging effects element that states that the program enhancement described under the scope of program element is necessary. However, there is no enhancement identified in the scope of program element. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

In the fire water system program document, for evaluation of consistency with the GALL AMP, the applicant stated that Unit 1 fire hydrant gasket inspection is performed every 18 months, compared to the GALL AMP recommendation of 12 months. However, the applicant did not include this as an exception in the LRA because gaskets were considered consumables and will be replaced as necessary. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

In the fire water system program document, for evaluation of consistency with the GALL AMP, the applicant stated that fire hydrant hose hydraulic tests are performed at various frequencies different than the GALL AMP recommended frequency of once every 12 months. However, the applicant did not include this as an exception in the LRA because hoses were considered

consumables and will be replaced as necessary. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. However, the staff noticed that several CRs were generated to address pinhole leaks in fire protection piping.

The applicant attributed the cause of the leaks as loss of material due to microbiologically induced corrosion (MIC). In CR 05-3940, it was determined that the chemical treatment of the piping did not eliminate MICs already established in the piping. UT inspections by the applicant confirmed areas in the piping system having a wall thickness loss of 50% or more. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M27, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.18, Flow-Accelerated Corrosion Program In the LRA, the applicant stated that AMP B.2.18 is an existing program that is consistent with GALL AMP XI.M17, Flow-Accelerated Corrosion.

During its audit, the staff audited the applicants on-site documentation to support its conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.M18 Flow Accelerated Corrosion Program Rev. 4, 01/17/08 Evaluation document 1/2-ADM-2205 Flow Accelerated Corrosion Program Rev. 1, 10/02/06 CR 06-01195 Feedwater elbow minimum wall 02/22/06 concern NSAC-202L-R2 Recommendation for an effective April 1999 flow-accelerated program ATR 98113-TR-01 Altran Technical Report for FAC July 1998 Program system susceptibility screening for Beaver Valley The staff reviewed the flow-accelerated corrosion program document and the ALTRAN Technical Report to confirm that appropriate susceptibility screening of systems was performed.

The applicant uses CHECKWORKS as a predictive code. The staff also reviewed some inspection results to confirm the correlation between the predicted wall thickness and the actual measured wall thickness.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. The staff reviewed the results of the last two refueling outages and the corrective actions taken by the applicant.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 remaining program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those recommended in GALL AMP XI.M17.

LRA AMP B.2.19, Flux Thimble Tube Inspection In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.19 is an existing program that is consistent with GALL AMP XI.M37 Flux Thimble Tube Inspection with an enhancement.

The enhancement included corrective actions which would require removal of a thimble tube from service if it cannot be inspected over the tube length.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION / DATE LRBV-PED- BVPS Flux Thimble Tube Inspection Program (Unit 1 Rev. 3, 6/19/07 XI.M37 and Unit 2)

ISIE-ECP-3 Flux Thimble Tube Examination Program Rev. 5, 8/22/05 Letter BVPS Response to NRC Bulletin 88-09 (Unit 1 flux 11/03/88 thimble tube inspection)

Letter BVPS follow-up response to NRC Bulletin 88-09 04/24/89 (Unit 2 flux thimble tube inspection)

Letter NRC Acknowledgement of BVPS Response to 08/01/89 Bulletin 88-09 WCAP-12866 Bottom Mounted Instrumentation Flux Thimble 01/91 Wear LRBV-OE- Operating Experience Review Report Rev. 3, 01/16/08 001 In comparing the elements in the applicants program, the staff found that the GALL Report parameters monitored/ inspected and detection of aging effects program elements which require a wear limit, were stated to be satisfied by BVPS through its response to NRC Bulletin 88-09 in letter BVPS Response to NRC Bulletin 88-09 (Unit 1 flux thimble tube inspection) dated November 3, 1988 and BVPS follow-up response to NRC Bulletin 88-09 (Unit 2 flux thimble tube inspection), dated April 24, 1989. The NRC acknowledged these responses in a letter dated August 1, 1989. However, since then the BVPS flux thimble tube wear limit has changed to a less conservative value. Documentation of approval of this change was not readily available for examination. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience reports and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. The reports indicated that in 2003, during refueling outage 1R15, several flux thimble tubes which were replaced during refueling outage 1R13 displayed elevated wall thinning. Of those with significant wall thinning, only two tubes were projected to exceed the BVPS 70% threshold for wall thinning. When questioned about the elevated wall thinning, the applicant stated that this initial elevated wear was explained as an initial wear in period, after which wear rates would significantly slow down. However, the applicant could not readily supply the specific wall thicknesses measured or how they used industry experience to come to its conclusion that it is acceptable. The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M37, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.20, Fuel Oil Chemistry In the LRA, the applicant stated that AMP B2.20 is an existing program that, following enhancement, will be consistent with GALL AMP XI.M30, Fuel Oil Chemistry System.

During its audit the staff audited the applicants on-site documentation to support its conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

Document Number Title Revision and/or Date

1. LRBV-PED-XI.M30 Beaver Valley Power Station Fuel Oil Rev. 4, 02/01/08 Chemistry Program (Unit 1 and Unit 2)

2. Proposed 1/2-ADM- Fuel Oil Chemistry Program Rev. 0

[XI.M30]

3. LRBV-OE-001 CR 02-02591/Particulates Rev. 3, 1/16/08

4. LRBV-OE-001 CR 05-01616/Water in Fuel Oil Rev. 3, 1/16/08

5. LRBV-OE-001 CR 02-11357/Problems in EDG FO Rev. 3, 1/16/08 In comparing the elements in the applicants AMP, the staff found that the applicant has taken enhancements as follows:

1. Add into the Parameters Monitored/Inspected element, revised procedures for sampling and testing the diesel-driven fire pump fuel oil storage tank (Unit 1) which includes a particulate and accumulated water test. Additionally, a new implementing procedure will be issued that describes sampling and testing the security diesel generator fuel oil day tank (Common) for accumulated water, particulate contamination, and sediment/water.

2. The Detection of Aging Effects describe that the enhancements under Parameters Monitored/Inspected element bring the Fuel Oil Chemistry Program into consistency with the GALL AMP.

3. The Detection of Aging Effects describe that implementing procedures will be revised to perform UT thickness measurements of accessible above-ground fuel oil tank bottoms at the same frequency as tank cleaning and inspections to ensure that significant degradation is not occurring.

The staff reviewed the enhancements and compared the changes with the GALL AMP XI.M30 recommendations for the enhanced elements. The staff determined that implementation of these enhancements will make the applicants Fuel Oil Chemistry program consistent with the GALL AMP XI.M30. On this basis, the staff finds the enhancements acceptable.

The Operating Experience reports including a sample of condition reports, and interviews with the applicants technical staff confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. Condition Report 02-11357, Problem (in fuel oil) following the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run of the 2-2 Emergency Diesel Generator, and Corrective Actions #21 & #39 Condition Report 02-02591, EE-TK-6 Total Particulate Contamination Exceeds Limits, Corrective Action #2, were reviewed. These CRs identified out of specification particulates in fuel oil. The corrective actions were documented the report that included filtering and sampling the fuel oil to restore parameters to specifications.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M30, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.21, Inaccessible Medium-Voltage Cables Not Subject To 10 CFR 50.49 Environmental Qualification Requirements In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.21 is a new program that is consistent with GALL AMP XI.E3, Inaccessible Medium-Voltage Cables not Subject to 10 CFR 50.49 Environmental Qualification Requirement.

During its audit, the staff audited the applicants claim of consistency with the GALL AMP.

Specifically, the staff interviewed the applicant's technical staff and audited the following documents:

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.E3 Inaccessible Medium-Voltage Cables not Rev. 3, Subject to 10CFR50.49 Environmental 07/23/07 Qualification Requirements LRBV-PED-XI.E3 Inaccessible Medium-Voltage Cables not Rev. 3, Subject to 10CFR50.49 Environmental 07/23/07 Qualification Requirements References LRBV-EAMR-001 BVPS License Renewal Project Document Rev. 5, 11/30/07 LRBV-OE-01 Operating Experience Rev. 3 In comparing the elements in the applicants program, the staff verified that the program elements contained in Beaver Valley AMP B.2.21 are consistent with GALL AMP XI.E3 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP. The staff also verified that the applicant provided an adequate summary description of the program.

The technical information and guidance identified in GALL AMP XI.E3 were presented in Inaccessible Medium-Voltage Cable Not Subject to 10 CFR 50.49 Environmental Qualification Requirement LRBV-PED-XI.E3 and references. In comparing the elements in the applicants program, the staff found that the applicant did not define significant moisture and significant voltage in the scope of AMP B.2.21. The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

GALL AMP XI.E3 identified NUREG/CR-5643, IEEE Std. P1205, SAND96-0344, EPRI TR-109619, and EPRI TR-103834-P1-2 as the technical basis and guidance in GALL XI.E3. The applicant states that Beaver Valley B.2.21 is consistent with GALL AMP XI.E3 but it did not identify these documents as the basis for its AMP. The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff audited operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. In LRA Section B.2.21, under operating experience, the applicant states that it currently has a manhole inspection program which identified and evaluated water collection in the manholes. The applicant stated that this prevention program has been effective in monitoring and evaluating the exposure of water to cable and cable supports located in manholes.

The staff audited operating experience LRBV-OE-01, Revision 3, and noted that in Corrective Report (CR) 04-03545 the applicant discovered that the Manhole 1EMH-19A Duct 944 had 34 inches of water in it during performance of a manhole inspection for water induced damage in 2004. The water was removed; however, the lower cable tray was severely deteriorated to the point where one of the ladder rungs of the tray had fallen out and the tray support brackets were also badly rusted. The BVPS manhole inspection was last performed by the applicant in September 2006. The findings from that inspection included missing seals, cracked walls, corroded supports, and water intrusion, but no cable damage was found. In reviewing the CR, the staff noted that certain manholes had chronic flooding problems. These manholes, numbered 1EMH-8A, 8B, and 15, are located below grade near the intake structure and repeatedly had water levels of 10 to 15 feet. Manholes 1EMH - 8A&8B contain safety related cables from both Units 1 and 2. The staff questioned the adequacy of the applicants corrective actions and periodic inspection for water collection in the manholes. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.E3, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.22, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components Program In the LRA, the applicant stated that AMP B.2.22 is a new program that when implemented will be consistent with GALL AMP XI.M38, Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION /DATE LRBV-PED-XI.M38 Inspection of Internal Surfaces in Rev. 3, 07/26/07 Miscellaneous Piping and Ducting Components Program Evaluation Document Proposed 1/2-ADM- Inspection of Internal Surfaces in Draft

[XI.M38] Miscellaneous Piping and Ducting Components Program CR 02-09358 Spray nozzle corrosion 10/19/02 CR 06-8110 Service water system valve loss of 10/16/06 material In comparing the elements in the applicants AMP, the staff found that the acceptance criteria element states that the program will inspect for indications of material degradation such as corrosion, cracking, fouling, etc. and that inspection results not meeting the acceptance criteria will be processed in accordance with the corrective action program. However, the acceptance criteria are not defined. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M38, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.23 is an existing program that is consistent with GALL AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, with an enhancement. The enhancement includes guidance in licensee procedures to inspect for loss of material due to corrosion on certain crane components.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the AMP elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION / DATE LRBV-PED- BVPS Inspection of Overhead Heavy Load and Rev. 2, 7/3/07 XI.M23 Light Load (Related to refueling) Handling Systems Program - Program Evaluation Document 1/2-ADM-0800 Site Load Handling & Rigging Program Rev. 3, 1/24/06 1/2 -ADM-0819 Handling of NUREG 0612 Heavy Loads Rev. 5, 3/24/06 CR 03-01127 RFA-Engineering Investigate 10 CFR21 2/1/03 Notification - Whiting Corporation LRBV-OE-001 Operating Experience Review Report Rev. 3, 1/16/08 In comparing the elements in the applicants program to those in GALL AMP XI.M23, the staff found that BVPS credited its Maintenance Rule Program for meeting the GALL Report parameters monitored/ inspected program element by evaluating the effectiveness of the crane maintenance monitoring program and the effects of past and future usage on the structural reliability of cranes and hoists. However, no reference to the Maintenance Rule Program was found in LRBV-PED-XI.M23. Therefore, the staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. The applicants reports indicate that, in 2003, an event occurred in the Waste Handling Building when programmatic deficiencies and degraded crane material conditions related to a lift of a high integrity container grapple necessitated a stop work order for radiological lifts. However, additional details were not readily apparent regarding the event, most notably the resulting enhancements that were driven by this event. A lack of response by its monitoring program would bring into question the applicants ability to meet the GALL Report detection of aging effects program element. Therefore, the staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M23, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.24, Lubricating Oil Analysis Program In the LRA, the applicant stated that AMP B.2.24 is an existing program that is consistent with GALL AMP XI.M39, Lubricating Oil Analysis Program.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT TITLE REVISION / DATE LRBV-PED-XI.M39 Beaver Valley Power Station Rev. 2, 06/21/2007 Lubricating Oil Analysis Program (Unit 1 and Unit 2) 1/2-ADM-2104 Lubricating Oil Analysis Program Rev.2, 06/21/2007 LRBV-AMPB-001 Aging Management Programs 8/06/2007 Common Information The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M39.

LRA AMP B.2.25, Masonry Wall Program In the LRA, the applicant stated that AMP B.2.25 is an existing program that is consistent with GALL AMP XI.S5.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT NUMBER TITLE REVISION /DATE LRBV-PED-XI.S5 Masonry Wall Program Evaluation Rev. 3, document 01/16/2008 LVBV-OE-001 Operation Experience Review Report Rev.3, 01/16/2008 1/2 -ADM-2016 General Area Structural Inspections Rev.1, 12/09/2006 8700-DSS-0083 Inspection Specification for Concrete Rev.1, Block Walls 12/15/1992 The staff audited the Masonry Wall Program by comparing the 7 elements in the applicants program for which the applicant claims consistency with GALL AMP XI.S5. The staff noted that the Masonry Wall Program includes the guidance and lessons learned from Office of Inspection and Enforcement Bulletin 80-11 and Information Notice 87-67. During the audit, the staff asked for the visual examination frequency for the program and its technical basis. In its response, the applicant stated that the inspection is implemented by the Structures Monitoring Program and consist of visual inspection for cracking in joints, deterioration of penetrations, missing or broken blocks, missing mortar, and general mechanical soundness of steel supports. Visual inspections are at least every five years to ensure no loss of intended function between inspections. The absence of operating experience with significantly degraded masonry walls indicates that this frequency is appropriate.

The staff also audited the operating experience reports including a sample of condition reports and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.S5.

LRA AMP B.2.26, Metal Enclosed Bus (Unit 2 Only)

In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.26 is a new program that is consistent with GALL AMP XI.E4, Metal Enclosed Bus.

During its audit, the staff audited the applicants claim of consistency with the GALL AMP.

Specifically, the staff interviewed the applicant's technical staff and audited the following documents:

DOCUMENT NUMBER TITLE REVISION /DATE LRBV-PED-XI.E4 Metal Enclosed Bus Rev.3, 07/23/2007 LRBV-PED-XI.E4 Metal Enclosed Bus References Rev.3, 07/23/2007 LRBV-EAMR-001 BVPS License Renewal Project Document Rev.5, 11/30/2007 In comparing the elements in the applicants program, the staff verified that the program elements contained in Beaver Valley AMP B.2.26 are consistent with GALL AMP XI.E4 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP. The staff also verified that the applicant provided an adequate summary description of the program.

The technical information and guidance identified in GALL AMP X1.E4 were presented in Metal Enclosed Bus LRBV-PED-X1.E4 and references. Based on its audit, the staff identified an issue where additional clarifications were needed to complete the audit. The applicant did not identify iso-phase bus within the scope of Metal Enclosed Bus Program. The staff will consider issuing a RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. In BVPS AMP B.2.26, the applicant stated that the Metal Enclosed Bus Program is a new aging management program for which there is no plant-specific operating experience for program effectiveness. In order to be consistent with the staffs recommendations in Section A.1.2.3.10, item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), the staff will consider issuing an RAI requesting that the applicant provide a commitment in the application to submit future operating experience on this AMP to the staff in order to confirm the effectiveness of this program. This RAI will also consider requesting the applicant to discuss and submit any observed material degradation found during the implementation of other existing activities that relate to the aging effects that will be managed by the new program. This RAI will be evaluated and documented in the SER.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.E4, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.27, Metal Fatigue of Reactor Coolant Pressure Boundary In the BVPS LRA, the applicant stated that BVPS AMP B.2.27 is an existing program that is consistent with GALL AMP X.M1.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL report. The staff interviewed the applicants technical staff and audited the following on-site documents listed.

DOCUMENT NUMBER TITLE REVISION/DATE LRBV-PED-X.M1 Metal Fatigue of Reactor Coolant Rev. 2, 07/24/07 Pressure Boundary Program (Unit 1 and Unit 2)

LRBV-OE-001 Operating Experience Review Report 1/2 -ADM-2115 Fatigue Cycle Monitoring Program Rev. 1, 04/30/07 1/2 DBD-M-001 Fatigue Analysis Rev. 0, 07/19/07 WCAP-16173-P Beaver Valley Units 1 and 2 Design Rev. 0, 03/2004, Basis Transient Evaluation for including Errata License Renewal dated 08/11/2004 In comparing the 7 elements in the applicants program to those in GALL AMP X.M1, the staff found the LRA section B. 2.27 does not provide sufficient detail to determine whether Metal Fatigue of Reactor Coolant Pressure Boundary Program is adequate for the period of extended operation. Therefore, the staff will consider issuing an RAI requesting the applicant to provide sufficient detail under the program description on the scope of the program, methodology for monitoring the critical and thermal transients periodic updates of fatigue usage calculation, and how it will address environmentally assisted fatigue (EAF).

In addition, staff will consider issuing an RAI requesting the applicant to provide sufficient detail on supplemental transients, which was identified in the LRA and as scope of the program.

These include the major components affected, the update of related fatigue analysis, consistency between supplemental transients and design transients, and monitoring information for these transients.

The staff will also consider issuing an RAI requesting the basis for the applicants selection of critical transients. In addition, the staff will consider issuing another RAI on triggering point and its follow-up corrective actions, including the process incorporated into the plant procedure.

These RAIs pertain to the program element, parameters monitored.

The staff audited the basis documents supplied by the applicant that support the LRA, and discussed its review with the applicant. Two RAIs will be considered to be issued on the discrepancy between the LRA and the basis documents. The first will request the applicant to justify the discrepancy on the 60-year projected cycles, and the second will request the applicant to justify any difference between the LRA and the basis documents for the design transients.

The staff also noted in its review of the basis documents that the applicant does not require monitoring of the design transient, RHR actuation, of BVPS Unit 1. Therefore, an RAI will be considered to be issued on the basis of the monitoring for the transient during the period of extended operation.

The staff requested the applicant to explain the on-line fatigue monitoring system during the on-site discussion. The staff will consider issuing an RAI requesting the applicants benchmarking results, including the purpose of the system, in order to determine the adequacy of the model incorporated in the system.

The staff also noted that LRA section B.2.27 should provide a supporting description if specific TLAAs have been dispositioned in accordance with 10 CFR 54.21(c)(1)(iii) in the LRA Section 4.3 as aging management program. Thus, the staff will consider issuing an RAI requesting information on the method used by the applicant to monitor the transients with several BVPS unit 2 auxiliary heat exchangers.

The staff audited the operating experience and selected condition reports associated with this AMP, and interviewed the applicants technical staff to confirm that the effects of aging will be managed adequately during the period of extended operation. The staff noted that the LRA indicated a re-analysis of the charging piping was required to account for the appropriate transients for a 60-year plant life. The staff will consider issuing an RAI requesting information on the basis for the determination with no further evaluation of the letdown or excess letdown piping and the status of re-analysis for the charging piping and its EAF evaluation.

The staffs evaluation of the RAIs will be documented in the SER.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP X.M1, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.29, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Head Program In the Beaver Valley Power Station LRA, the applicant states that AMP B.2.29 is an existing program that is consistent with the program elements in GALL AMP XI.M11, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Head. The applicants program is credited to manage cracking due to primary water stress corrosion cracking (PWSCC) that could potentially occur in the Nickel-alloy penetration nozzles that are welded to the applicants reactor vessel closure heads (RVCHs) or their associated J-groove welds. The applicant also credits the AMP to manage loss of material due to boric acid-induced wastage in the upper RVCHs.

During its audit, the staff audited the applicants on-site documentation to determine whether the program elements in the applicants AMP are consistent with the elements in the GALL report program. The staff interviewed the applicants technical staff and audited the following additional on-site documents and NRC-issued documents listed below:

DOCUMENT TITLE REVISION/

NUMBER DATE LRBV-PED- Beaver Valley Power Station (BVPS) Nickel-Alloy Penetration Rev.3, XI.M11A Nozzle Welded to the Upper Reactor Vessel Closure Head 01/17/08 Program NOP-ER-2003 Alloy 600/690 Management Program Rev.1 /

February 28, 2007 1/2-ADM-2096 Alloy 600/690 Management Program Rev.4 /

February 28, 2007 1/2-ADM-0801 ASME Section XI Repair/Replacement Program Rev.5 /

Septembe r 6, 2006 LRBV-AMP-001 Aging Management Program Common Information Rev.1 /

August 6, 2007 NRC First Revised Establishing Interim Inspection Requirements for Reactor February Order No. EA Pressure Vessel Heads at Pressurized Water Reactors 20, 2004 009 L-04-030 Beaver Valley Power Station, Unit No. 1 and No. 2, BV-1 March 5, Docket No. 50-334, License No. DPR-66, BV-2 Docket No. 2004 50-412, License No. NPF-73, Response to First Revised Order (EA-03-009),

Order EA 03-009 Issuance of Order Establishing Interim Inspection February Requirements for Reactor Pressure Vessel Heads at 11, 2003 Pressurized Water Reactors L-03-035 Beaver Valley Power Station, Unit No. 1 and No. 2, BV-1 March 3, Docket No. 50-334, License No. DPR-66, BV-2 Docket No. 2003 50-412, License No. NPF-73, Order Establishing Interim Inspection Requirements for RPV Heads

Specifically, the staff audited the program element descriptions for the scope of program, preventative actions, parameters monitored/detected, detection of aging effects, monitoring and trending, acceptance criteria, and operating experience, program elements in the applicant program against the corresponding program element descriptions that are defined and described in GALL AMP XI.M11.

The staffs reviews of the corrective actions, confirmatory actions, and administrative controls program elements for the applicants program were performed as part of the staffs review of the applicants quality assurance program, which is provided in LRA Section B.1.3.

In comparing the 7 elements in the applicants program to those in GALL AMP XI.M11, Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Head, the staff noted that the program elements for the applicants AMP were consistent with the program element criteria recommended in the GALL AMP and that the applicant had addressed the relevant BVPS Unit 1 and 2 operating experience for its upper RVCH and RVCH nozzle examinations.

The staff did not have any issues with respect to the program elements for the applicants Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Head Program, and therefore did not issue any requests for additional information relative to the applicants Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Head Program.

The staff audited the applicants operating experience and selected reports associated with Nickel-Alloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Head Program.

The staff also interviewed the applicants technical staff to confirm that plant-specific operating experience did not reveal any degradation outside the bounds of industry experience.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M11.

LRA AMP B.2.30, One-Time Inspection Program In the LRA, the applicant stated that AMP B.2.30 is a new program that when implemented will be consistent with GALL AMP XI.M32, One-Time Inspection.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT NUMBER TITLE REVISION/DATE LRBV-PED-XI.M32 Beaver Valley Power Station One-Time Rev. 5, Inspection Program (Unit 1 and Unit 2) 1/17/2008 Proposed 1/2-ADM- One-Time Inspection Program Rev. 0

[XI.M32]

The operating experience element states that the One-Time Inspection Program is a new program and there is no plant-specific program operating experience. In order to be consistent with the staffs recommendations in Section A.1.2.3.10, item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), the staff will consider issuing an RAI requesting that the applicant provide a commitment in the application to submit future operating experience on this AMP to the staff in order to confirm the effectiveness of this program. This RAI will also consider requesting the applicant to discuss and submit any observed material degradation found during the implementation of other existing activities that relate to the aging effects that will be managed by the new program. This RAI will be evaluated and documented in the SER.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M32.

LRA AMP B.2.31, One-Time Inspection of ASME Code Class 1 Small Bore Piping In the BVPS LRA, the applicant stated that BVPS AMP B.2.31 is a new program that is consistent with GALL AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small Bore Piping.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL report. The staff interviewed the applicants technical staff and audited the following on-site documents listed.

DOCUMENT NUMBER TITLE REVISION/DATE Proposed 1/2 -ADM-[XI.M35 Beaver Valley Power Station One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program MRP-24, EPRI 1000701 Interim Thermal Fatigue Management 1/2001 Guideline NRC Bulletin 88-08 Thermal Stresses in Piping Connected to Reactor Coolant Systems including Supplements 1, 2, and 3 LRBV-MAMR-006 Reactor Coolant System Rev. 9, 1/8/08 LRBV-PED-XI.M35 One-Time Inspection of ASME Code Rev. 4, 8/16/07 Class 1 Small Bore Piping Vol. 1 LRBV-PED-XI.M35 One-Time Inspection of ASME Code Rev. 4, 8/16/07 Class 1 Small Bore Piping Vol. 2 The staff audited operating experience and selected condition reports and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. In the application, the applicant stated that there is no operating experience for the effectiveness of the program because it is a new program. In order to be consistent with the staffs recommendations in Section A.1.2.3.10, item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), the staff will consider issuing an RAI requesting that the applicant provide a commitment in the application to submit future operating experience on this AMP to the staff in order to confirm the effectiveness of this program. This RAI will also consider requesting the applicant to discuss and submit any observed material degradation found during the implementation of other existing activities that relate to the aging effects that will be managed by the new program. This RAI will be evaluated and documented in the SER.

The 3 program elements, corrective actions, confirmation process, and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M35.

LRA AMP B2.32, Open-Cycle Cooling Water System Program In the LRA, the applicant stated that AMP B2.32 is an existing program that, following enhancements, will be consistent with GALL AMP XI.M20, Open-Cycle Cooling Water System.

The applicant stated that the GALL programs scope is a prevention, performance monitoring, and condition monitoring program that manages the effects of aging on the systems, structures, component types, and commodity groups. The applicant summarized that the following systems have their aging management review reports (including materials, environments, and corresponding aging effects requiring management) addressed by this aging management program:

• Reactor Plant Component and Neutron Shieled Tank Cooling Water System

• Primary Plant Component and Neutron Shieled Tank Cooling Water System

• Chemical and Volume Control System, Charging Pump Lube Oil Coolers

• Emergency Diesel Generator and Support System, Cooling Water Heat Exchangers

• Containment Depressurization System, Recirculation Spray Heat Exchangers

• Area Ventilation Systems - Control Area A/C Condensing Unit Heat Exchangers

• River Water System, Control Room Redundant Cooling Coils

• River Water System, Auxiliary River Water Pump Motor Oil Coolers

• Service Water System, Control Room Backup Air Conditioning Units

• Area Ventilation Systems, Control Room Refrigeration Unit Condensers

• Ventilation Systems, Alternate S/D Panel Air Conditioning Unit Condensers

• Ventilation Systems, MCC Cubicle Cooling Coils

• Ventilation Systems, Safeguards Area Air Conditioning Units

• Service Water System, Standby Service Water Pump Motor Oil Coolers

• Service Water System, Pump Motor Oil Coolers

• Radiation Monitoring System, Recirculation Spray Heat Exchanger Rad Monitor Coolers

• Post Accident Sample System, Sample Cooler

• Auxiliary Feed Water System, Emergency Supply Water Valves The applicant stated that the Open-Cycle Cooling Water System Program implements the site commitments to NRC Generic 89-13, Service Water System Problems Affecting Safety-Related Equipment, including Supplement 1. The applicant explained that this program manages the aging effects on the open-cycle cooling water systems such that the systems will be able to fulfill their intended functions during the period of extended operation. The applicant also stated that the program includes surveillance and control techniques to manage aging effects caused by biofouling, corrosion, erosion, protective coating failures, and silting in the River Water and Service Water Systems or structures and components serviced by the systems.

During its audit the staff audited the applicants on-site documentation to support its conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

Document Number Title Revision and/or Date

1. LRBV-PED-XI.M20 Beaver Valley Power Station Open- Rev.5, 02/14/2008 Cycle Cooling Water Program (Unit 1 and Unit 2)

2. LRBV-AMPB-001 Aging Management Programs Rev.1, 08/06/2007 Common Information

3. LRBV-OE-001 Beaver Valley Power Station Operating Rev. 3, 01/16/2008 Experience Review Report Ltr 1-29-1990 Beaver Valley Response to Generic 01/29/1990 Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment Ltr 6-27-1991 Beaver Valley Second Response to 06/27/1991 Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipment As a result of the staffs IP-71002 inspections that occurred during the weeks of June 23 and July 14, 2008, the applicant identified necessary revisions to the LRA which includes new program enhancements. The applicant provided the program changes in letter L-08-262 dated, September 9, 2008 which includes LRA Amendment No. 23. The following is the staffs evaluation of the Amendment. Therefore, the applicant identified the following enhancements to their current Open-Cycle Cooling Water Program:

The Scope of Program will be expanded to include a Unit 1 Post Accident Sample System heat exchanger (PAS-E-1) credited with a leakage boundary function.

The Detection of Aging Effects describe that the internal condition of buried piping will be assessed by opportunistic inspections of header piping internals during removal of expansion joints and inline valves in the headers. Evaluation of inspection results will be documented and trended.

The staffs review of the applicants on-site documentation did not identify any differences between the program described in site documents and the applicants claim of consistency with the FALL Report AMP XI.M20. The staff does not anticipate issuing any RAIs related to the applicants claims of consistency for those program elements where the applicant claims consistency with the GALL Reports program elements.

The staff verified that the LRA includes LRA Section A.4 and A.5 (i.e., UFSAR Supplement Section A.1.31 and A.1.32 for Unit 1 and Unit 2, respectively), which provides the applicants UFSAR Supplement summary description for the Open-Cycle Cooling Water System Program.

The staff verified that LRA Commitments No. 30 for Unit 1 and Commitment 31 for Unit 2 credits this existing program for aging management and that the commitment has been aligned with the UFSAR Supplement Sections A.1.31 and A.1.32 for Unit 2. This commitment also includes a statement that the applicants program will be enhanced to include in the program scope for Unit 1, the Post Accident Sample System heat exchanger credited with a leakage boundary function and to assess the internal condition of buried piping by opportunistic inspections of header piping internals during removal of expansion joints and inline valves in the headers and that the evaluation of such inspection results will be documented and trended. This commitment also includes a statement that the applicants program will be enhanced to include in the program

scope for Unit 2, to assess the internal condition of buried piping by opportunistic inspections of header piping internals during removal of expansion joints and inline valves in the headers and that the evaluation of such inspections will be documented and trended. The staff will evaluate the UFSAR Supplement Section A.1.31 and A.1.32 and LRA Commitments No. 30 and 31 in the SER.

The staff audited the applicants operating experience and selected reports associated with the Open-Cycle Cooling Water System Program. The staff also interviewed the applicants technical staff to confirm that plant-specific operating experience did not reveal any degradation outside the bounds of industry experience.

The 3 program elements, corrective actions, confirmation process, and administrative controls were reviewed as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP, are consistent with those specified in GALL AMP XI.M20 in the areas where the applicant claimed consistency with the GALL Report.

LRA AMP B.2.34, Reactor Head Closure Studs In the Beaver Valley LRA, the applicant stated that BVPS AMP B.2.34 is an existing program that is consistent with GALL AMP XI.M3, Reactor Head Closure Studs with an exception. The exception is an ASME code edition change. Beaver Valley uses the 1989 edition.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff audited the following on-site documents.

DOCUMENT TITLE REVISION /DATE NUMBER LRBV-PED- Reactor Head Closure Studs Rev. 2, 1/17/08 XI.M3 1/2-ADM-0801 ASME Section XI Repair/Replacement Program Rev. 5, 9/6/06 1/2-ADM-2039 BVPS Ten Year Plans Rev. 5, 1/26/07 1/2-ADM-2045 Inservice Inspection Rev. 0 1RP-2.6 Remove Reactor Vessel Studs/Clean Rev. 4, 1/26/04 2RP-2.6 Refueling Procedure- Remove reactor vessel Rev. 4, 1/20/04 studs/clean 1/2RP-2.7 Reactor Vessel Head Removal Head Rev. 9, 3/6/07 Removal/Lift Rig Checkout LRBV-OE-001 Operating Experience Review Report Rev. 3, 1/16/08 The staff compared the elements in the applicants program with the GALL Report program elements. The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. The reports indicated that in 2006, the refueling outages 1R17 and 2R12 included reactor head studs ultrasonic testing examinations which both resulted in no undesirable indications. The reports further indicated there is no history of reactor vessel studs, nuts, and washers being found with cracks, or anything more significant than minor nicks and scratches.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M3, not including any exceptions identified by the applicant in the LRA for this AMP, which will be evaluated separately in the SER.

LRA AMP B.2.36, Selective Leaching of Materials In the BVPS LRA, the applicant stated that B.2.36 is a new program that is consistent with GALL AMP XI.M34, Selective Leaching of Materials with an exception.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL report. The staff interviewed the applicants technical staff and audited the following on-site documents listed.

DOCUMENT NUMBER TITLE REVISION/DATE LRBV-MAMR-008 Aging Management Review of the Boron Rev 5, 6/22/07 Recovery and Primary Grade Water System LRBV-MAMR-009 Aging Management Review of the Reactor Rev. 6, 7/26/07 Plant Vents and Drains Systems LRBV-MAMR-012 Aging Management Review of the Rev 5, 6/22/07 Containment Vacuum and Leakage Monitoring System LRBV-MAMR-014A Aging Management Review of the Reactor Rev 5, 6/22/07 Plant Sample System LRBV-MAMR-015 Aging Management Review of the Primary Rev 5, 6/22/07 Component and Neutron Shield Tank System LRBV-MAMR-017 Aging Management Review of the Liquid Rev 5, 6/22/07 Waste Disposal System LRBV-MAMR-018 Aging Management Review of the Solid Waste Rev 5, 6/22/07 Disposal System LRBV-MAMR-022 Aging Management Review of the Vol. 1 & 2, Rev Demineralization Water System 5, 6/22/07 LRBV-MAMR-24B Aging Management Review of the Auxiliary Rev 6, 8/3/07 Feedwater System LRBV-MAMR-026 Aging Management Review of the Main Rev 5, 6/22/07 Turbine and Condenser System LRBV-MAMR-027 Aging Management Review of the Auxiliary Rev 5, 6/22/07 Steam System LRBV-MAMR-029 Aging Management Review of the Chilled Rev 5, 6/22/07 Water System LRBV-MAMR-30-1 Aging Management Review of the River Water Rev 5, 8/3/07 System LRBV-MAMR-30-2 Aging Management Review of the Service Rev 5, 6/22/07 Water System LRBV-MAMR-032 Aging Management Review of the Water Rev 5, 6/22/07 Treating System LRBV-MAMR-033 Aging Management Review of the Fire Rev 5, 6/22/07 Protection System LRBV-MAMR-034 Aging Management Review of the Rev 5, 6/22/07 Compressed Air System LRBV-MAMR-36A Aging Management Review of the Emergency Rev. 6, 7/20/07 Diesel Generator System

Document Number Title Revision/Date LRBV-MAMR-41A Aging Management Review of the Building Rev 4, 6/22/07 Services Hot Water Heating System LRBV-MAMR-41B Aging Management Review of the Building Rev 4, 6/22/07 Services Glycol Heating System LRBV-MAMR-41C Aging Management Review of the Domestic Rev 4, 6/22/07 Water System LRBV-MAMR-41D Aging Management Review of the Building and Rev. 7, 1/8/08 Yard Drains System LRBV-MAMR-44A Aging Management Review of the Control Rev. 6 7/2/07 Area Ventilation System LRBV-MAMR-45F Aging Management Review of the Security Rev 5, 6/22/07 Diesel Generator System LRBV-MAMR-58E Aging Management Review of the EFR Diesel Rev. 6, 1/8/08 Generator System LRBV-MAMR-VENT Aging Management Review of the Area Rev. 6, Ventilation Systems 10/25/07 CR Number Multiple Ruptures of the Fire Header, 01/10/2001 01- 0108 01/10/2001 CR Number Containment Instrument Air Check Valve 00- 3147 Internals LRBV-PED-XI.M33 Selective Leaching of Materials Inspection Vol. Rev. 5, 1/17/08 1

LRBV-PED-XI.M33 Selective Leaching of Materials Inspection Vol. Rev. 5, 1/17/08 2

The staff also audited operating experience and selected condition reports and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. In the application, the applicant stated that there is no operating experience for the effectiveness of the program because it is a new program. In order to be consistent with the staffs recommendations in Section A.1.2.3.10, item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), the staff will consider issuing an RAI requesting that the applicant provide a commitment in the application to submit future operating experience on this AMP to the staff in order to confirm the effectiveness of this program. This RAI will also consider requesting the applicant to discuss and submit any observed material degradation found during the implementation of other existing activities that relate to the aging effects that will be managed by the new program. This RAI will be evaluated and documented in the SER.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M34, not including any exceptions identified by the applicant in the LRA for this AMP, which will be evaluated separately in the SER, and the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.38, Steam Generator Tube Integrity Program In the LRA, the applicant stated that AMP B.2.38 is an existing program that is consistent with GALL AMP XI.M19, Steam Generator Tube Integrity.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT NUMBER TITLE REVISION /DATE LRBV-PED-XI.M19 Beaver Valley Power Station Steam Rev.3, Generator Tube Integrity Program (Unit 01/24/2008 1 and Unit 2)

LRBV-AMPB-001 Aging Management Programs Rev.1, Common Information 08/06/2007 LRBV-OE-001 Beaver Valley Power Station Operating Rev. 3, Experience Review Report 01/16/2008 In comparing the AMP element, scope of program to GALL AMP XI.M19, the staff found that the applicant has included the component types feedrings and J-Nozzles within its bounds. The staff noted however, that GALL AMP XI.M19 does not include the component types, feedrings and J-Nozzles within its scope to manage their aging effects. Additionally, the staff audited LRA Table item 3.1.1-76 which states that feedrings and J-Nozzles are managed, in part (in combination with Water Chemistry, B.2.42), by the Steam Generator Tube Integrity Program.

The staff will consider issuing an RAI to address why this is not a program enhancement. The staffs evaluation will be documented in the SER.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M19, except the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.39, Structures Monitoring Program In the BVPS LRA, the applicant stated that BVPS AMP B.2.39 is an existing program that is consistent with GALL AMP XI.S6, Structures Monitoring Program.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT NUMBER TITLE REVISION /DATE LRBV-PED-XI.S6 Structures Monitoring Program Rev. 3, Evaluation Document 01/16/2008 LVBV-OE-001 Operation Experience Review Report Rev.5, 01/16/2008 1/2 -ADM-2114 MR program Admins. Procedure Rev.3, 05/19/2006 1/2-ADM-2016 General Area Structural Inspections Rev.3 In comparing the elements in the applicants program, the staff noted that failure of coatings could result in aging effects for steel shell in containment. The failure of coatings could also result in the failure of safety systems to perform their intended functions. The staff will consider issuing an RAI requesting the applicant to justify not having an aging management program for coatings. In addition, it is not clear to the staff how the applicant satisfies the GALL Report parameters monitored/inspected program element. Specifically, the GALL Report program element suggested ACI 349.3R-96 and ANSI/ASCE 11-90 for an acceptable basis for selection of parameters to be monitored. Because the applicant does not include the frequency of periodic sampling of ground water for pH, chloride, and sulfate concentration, the staff will consider issuing an RAI requesting the applicant to provide the time frame for the periodic sampling, and for the results of the last two samplings of groundwater. The staffs evaluation of these RAIs will be documented in the SER.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.S6, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.40, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)

In the Beaver Valley Power Station LRA, the applicant stated that AMP B.2.40 is a new program that will be consistent with the program elements in GALL AMP XI.M13, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS). The applicants Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)

Program is a new program that is credited to manage reduction of fracture toughness that may occur in CASS reactor vessel internal (RVI) components as a result of thermal aging embrittlement or neutron irradiation embrittlement.

During its audit, the staff audited the applicants on-site documentation to determine whether the program elements in the applicants AMP are consistent with the elements in the GALL report program. The staff interviewed the applicants technical staff and audited the following additional on-site documents and NRC-issued documents listed below:

DOCUMENT NUMBER TITLE REVISION

/DATE LRBV-PED-XI.M13 Thermal Aging and Neutron Irradiation Rev.2 / July Embrittlement of Cast Austenitic 26, 2007 Stainless Steel (CASS)

NRC Letter of May 19, License Renewal Issue No., 98-0030, 2000 from C Grimes(NRC) Thermal Aging Embrittlement of Cast to D. J. Walter (NEI) Austenitic Stainless Steel Component NUREG/CR-4513 Estimation of Fracture Toughness of Rev. 1 / May Cast Stainless Steels During Thermal 1994 Aging in LWR Systems LRBV-AMPB-001 Aging Management Common August 6, Information 2007 Specifically, the staff audited the program element descriptions for the scope of program, preventative actions, parameters monitored/detected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, and operating experience, program elements in the applicant program against the corresponding program element descriptions that are defined and described in GALL AMP XI.M13.

The staffs review of the confirmatory actions, and administrative controls program elements were performed as part of the staffs review of the quality assurance program for the LRA.

The staff felt that the following three (3) topics required additional clarification and in which requests for additional information (RAI) will be considered to be issued. The staffs evaluation will be documented in the Safety Evaluation Report (SER).

In the first topic needing additional clarification, the staff was aware that the current state-of-the-art ultrasonic testing (UT) methods in the industry are incapable of distinguishing between UT indication signals that arise from relevant flaw indications in CASS components and those that arise as background noise signals as a result of the complexity in the CASS grain structure (i.e,,

CASS microstructure). The staff sought clarification from the applicant on the alternative inspection methods that would be used if the current state-of-the-art UT methods remained

inadequate for CASS materials, and will consider issuing an RAI to resolve this issue. The staffs basis for issuing and resolving this RAI will be discussed in the SER section for this AMP.

In the second topic needing additional clarification, the staff noted that the applicant had indicated that it may use the industry initiatives of the Electric Power Research Institute Materials Reliability Program Task Group on PWR RVI components as an alternative to using the program to manage reduction of fracture toughness in the CASS RVI components. The staff believes that this basis should have been identified as an exception to the scope of program, program element of the applicants Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program. The staff will consider issuing an RAI to resolve this issue. The staffs basis for issuing and resolving this RAI will be discussed in the SER section for this AMP.

In the third topic needing additional clarification, the staff noted that the applicants Thermal Aging and Neutron Irradiation Embrittlement of CASS Program is a new program that has yet to be implemented at the plant. Since this is a new program, the staff did not have any relevant operating experience events to review on reduction of fracture toughness of the CASS RVI components as a result of thermal aging embrittlement or neutron irradiation embrittlement of the RVI components. However, in order to be consistent with the staffs recommendations in Section A.1.2.3.10, item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), the staff will consider issuing an RAI requesting that the applicant provide a commitment in the application to submit future operating experience on this AMP to the staff in order to confirm the effectiveness of this program. This RAI will also consider requesting the applicant to discuss and submit any observed material degradation found during the implementation of other existing activities that relate to the aging effects that will be managed by the new program.

The 2 program elements, confirmation process, corrective actions, and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 8 program elements in the applicants program and verified that these 8 elements for the AMP were consistent with those specified in GALL AMP XI.M13, except the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.41, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS)

In the Beaver Valley Power Station LRA, the applicant stated that AMP B.2.41 is a new program that will be consistent with the program elements in GALL AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS). The applicants program is credited to manage reduction of fracture toughness that may occur in CASS piping, piping components (including CASS valve bodies and pump casings), and piping elements in the reactor coolant pressure boundary (RCPB) as a result of thermal aging embrittlement.

During its audit, the staff audited the applicants on-site documentation to determine whether the program elements in the applicants AMP are consistent with the elements in the GALL report program. The staff interviewed the applicants technical staff and audited the following additional on-site documents and NRC-issued documents listed below:

DOCUMENT NUMBER TITLE REVISION /DATE LRBV-PED-XI.M12 Thermal Aging and Neutron Irradiation Rev.3 / July 26, Embrittlement of Cast Austenitic Stainless 2007 Steel (CASS)

NRC Letter of May 19, License Renewal Issue No., 98-0030, 2000 from C Thermal Aging Embrittlement of Cast Grimes(NRC) to D. J. Austenitic Stainless Steel Component Walter (NEI)

NUREG/CR-4513 Estimation of Fracture Toughness of Cast Rev. 1 / May Stainless Steels During Thermal Aging in 1994 LWR Systems LRBV-AMPB-001 Aging Management Common Information August 6, 2007 Specifically, the staff audited the program element descriptions for the scope of program, preventative actions, parameters monitored/detected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions, and operating experience, program elements in the applicant program against the corresponding program element descriptions that are defined and described in GALL AMP XI.M12, Thermal Aging Embrittlement of Cast Austenitic Stainless Steel (CASS).

The staffs review of the confirmatory actions, and administrative controls program elements were performed as part of the staffs review of the quality assurance program for the LRA.

The staff felt that the following two (2) topics required additional clarification and in which requests for additional information (RAI) will be considered to be issued. The staffs evaluation will be documented in the SER.

In the first topic needing additional clarification, the staff was aware that the current state-of-the-art ultrasonic testing (UT) methods in the industry are incapable of distinguishing between UT indication signals that arise from relevant flaw indications in CASS components and those that arise as background noise signals as a result of the complexity in the CASS grain structure (i.e,,

CASS microstructure). The staff sought clarification from the applicant on the alternative inspection methods that would be used if the current state-of-the-art UT methods remained inadequate for CASS materials, and decided to consider issuing an RAI to resolve this issue.

The staffs basis for issuing and resolving this RAI will be discussed in the SER section for this AMP.

In the second topic needing additional clarification, the staff noted that the applicants Thermal Aging and Neutron Irradiation Embrittlement of CASS Program is a new program that has yet to be implemented at the plant. Since this is a new program, the staff did not have any relevant operating experience events to review on reduction of fracture toughness of the CASS RVI components as a result of thermal aging embrittlement or neutron irradiation embrittlement of the RVI components. However, in order to be consistent with the staffs recommendations in Section A.1.2.3.10, item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), the staff will consider issuing an RAI requesting that the applicant provide a commitment in the application to submit future operating experience on this AMP to the staff in order to confirm the effectiveness of this program. This RAI will also consider requesting the applicant to discuss and submit any observed material degradation found during the implementation of other existing activities that relate to the aging effects that will be managed by the new program.

The 2 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 8 program elements in the applicants program and verified that these 8 elements for the AMP were consistent with those specified in GALL AMP XI.M12, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.42, Water Chemistry Program In the LRA, the applicant stated that AMP B.2.42 is an existing program that, following enhancement, will be consistent with GALL AMP XI.M2, Water Chemistry.

During its audit, the staff audited the applicants on-site documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL AMP. The staff interviewed the applicants technical staff and audited the following on-site documents.

DOCUMENT NUMBER TITLE REVISION /DATE LRBV-PED-XI.M2 Beaver Valley Power Station Water Rev. 3, 2/01/08 Chemistry Program (Unit 1 and Unit 2) 1/2-ADM-1710 Sample Retention Rev. 0 1/2-ADM-1711 Secondary Water Chemistry Monitoring Rev. 7, 9/20/06 Program 1/2-ADM-1712 Primary Systems Chemistry Monitoring Rev. 4, 9/20/06 Program 1/2-ADM-1730 Laboratory Quality Assurance And Rev. 8, 10/25/06 Quality Control Program 1/2-ADM-1732 Corrective Actions Rev. 0 In comparing the elements in the applicants AMP to those in GALL AMP XI.M2, the staff found that the applicant has taken an enhancement as follows:

Add into the Monitoring and Trending element, revised procedures for sampling frequency for reactor coolant silica monitoring to comply with EPRI guidelines.

The staff finds that this enhancement brings the BVPS Water Chemistry AMP B.2.42 into consistency because it specifies the latest EPRI guidelines for sampling RCS silica which is now 1/week for Modes 1 and 1/day during heatup in Modes 3 and 4.

The staff also audited the operating experience reports, including a sample of condition reports, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the Aging Management Program audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M2.

Letter to P. Sena III from K. Howard, dated November 05, 2008 DISTRIBUTION:

SUBJECT:

AUDIT REPORT REGARDING THE BEAVER VALLEY POWER STATION, UNIT 1 AND 2, LICENSE RENEWAL APPLICATION HARD COPY:

DLR RF E-MAIL:

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KHoward ESayoc NMorgan MModes, RI PCataldo, RI DWerkheiser, RI

Beaver Valley Power Station, Units 1 and 2 cc:

Joseph J. Hagan Manager, Fleet Licensing President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 Mail Stop A-GO-19 76 South Main Street 76 South Main Street Akron, OH 44308 Akron, OH 44308 Director, Fleet Regulatory Affairs James H. Lash FirstEnergy Nuclear Operating Company Senior Vice President of Operations Mail Stop A-GO-2 and Chief Operating Officer 76 South Main Street FirstEnergy Nuclear Operating Company Akron, OH 44308 Mail Stop A-GO-14 76 South Main Street Manager, Site Regulatory Compliance Akron, OH 44308 FirstEnergy Nuclear Operating Company Beaver Valley Power Station Danny L. Pace Mail Stop A-BV-A Senior Vice President, Fleet Engineering P.O. Box 4, Route 168 FirstEnergy Nuclear Operating Company Shippingport, PA 15077 Mail Stop A-GO-14 76 South Main Street Regional Administrator, Region I Akron, OH 44308 U.S. Nuclear Regulatory Commission 475 Allendale Road Jeannie M. Rinckel King of Prussia, PA 19406 Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Resident Inspector Mail Stop A-GO-14 U.S. Nuclear Regulatory Commission 76 South Main Street P.O. Box 298 Akron, OH 44308 Shippingport, PA 15077 Paul A. Harden Cliff Custer Vice President, Nuclear Support FirstEnergy Nuclear Operating Company FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-GO-14 P.O. Box 4, Route 168 76 South Main Street Shippingport, PA 15077 Akron, OH 44308 Steve Dort David W. Jenkins, Attorney FirstEnergy Nuclear Operating Company FirstEnergy Corporation Beaver Valley Power Station Mail Stop A-GO-15 P.O. Box 4, Route 168 76 South Main Street Shippingport, PA 15077 Akron, OH 44308 Mike Banko FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077