ML082950351

Safety Audit Report Letter

ML082950351
Person / Time
Site:	Susquehanna
Issue date:	01/16/2009
From:	Gettys E Division of License Renewal
To:	Mckinney B Susquehanna
Gettys Evelyn, NRR/DLR/RLRA 415-4029
References
TAC MD3019, TAC MD3020
Download: ML082950351 (82)

Text

January 16, 2009 Mr. Britt T. McKinney Sr. Vice President and Chief Nuclear Officer PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 Berwick, PA 18603-0467

SUBJECT:

AUDIT REPORT REGARDING THE SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION

Dear Mr. McKinney:

By letter dated September 13, 2006, PPL Susquehanna, LLC submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating licenses for Susquehanna Steam Electric Station, Units 1 and 2, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). On May 9, 2008, the staff completed the onsite audit of Aging Management Programs. The audit report is enclosed.

If you have any questions, please contact me at 301-415-4029 or by e-mail at evelyn.gettys@nrc.gov.

Sincerely,

/RA/

Evelyn Gettys, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-387 and 50-388

Enclosure:

As stated cc w/encl: See next page

ML082950351 OFFICE LA:DLR PM:RPB1:DLR BC:RER1 DLR:RER2 BC: RPB1:DLR NAME EGettys JDozier RAuluck DPelton DATE 01/08/09 01/09/09 01/09/09 01/12/09 01/16/09 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION, DIVISION OF LICENSE RENEWAL Docket No: 50-387 and 50-388 License No: NPF-14 and NPF- 22 Licensee: PPL Susquehanna, LLC Facility: Susquehanna Steam Electric Station, Units 1 and 2 Location: 769 Salem Boulevard Berwick, Pennsylvania 18603-0467 Dates: May 5-9, 2008 Reviewers: E. Gettys, Project Manager, Division of License Renewal (DLR)

R. Auluck, Branch Chief, DLR J. Davis, Senior Materials Engineer, DLR J. Medoff, Senior Materials Engineer, DLR R. Sun, Mechanical Engineer, DLR O. Yee, Mechanical Engineer, DLR U. Baig, Mechanical Engineer, DLR D. Hoang, Structural Engineer, DLR B. Lehman, Structural Engineer, DLR R. Li, Electrical Engineer, DLR E. Patel, Consultant, Advanced Technologies & Laboratories (ATL)

W. Jackson, Consultant (ATL)

Approved By: Jerry Dozier, Chief Engineering Review Branch 1 Division of License Renewal Rajender Auluck, Chief Engineering Review Branch 2 Division of License Renewal

Introduction An audit was conducted by the Nuclear Regulatory Commission (NRC) at the Susquehanna Steam Electric Station (SSES) Units 1 and 2 in Berwick, PA on May 5 - 9, 2008. The purpose of this audit was to examine the PPL Susquehanna, LLC, (the applicant) Aging Management Programs (AMPs) and related documentation for SSES and to verify the applicants claim of consistency with the corresponding Generic Aging Lessons Learned (GALL) Report (NUREG-1801, Rev. 1) AMPs. Exceptions to the GALL Report AMP elements will be evaluated separately as part of the NRC staffs (or the staff) review of the SSES license renewal application (LRA) and documented in the staffs Safety Evaluation Report (SER).

The Standard Review Plan (SRP) for Review of License Renewal Applications for Nuclear Power Plants (NUREG-1800, Rev. 1) provides the staff guidance for reviewing an LRA. The SRP allows an applicant to reference in its LRA, the AMPs described in the GALL Report. By referencing the GALL Report 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 Report program, it is incumbent on the applicant to ensure that the plant program contains all of the elements of the referenced GALL Report program. The applicants determination should be documented in an auditable form and maintained onsite.

During this audit, the staff audited AMP elements 1-6, which includes: 1. scope of program; 2.

preventative actions; 3. parameters monitored or inspected; 4. detection of aging effects; 5.

monitoring and trending; and 6. acceptance criteria. Also included in the audit was AMP element 10, operating experience. These elements of the applicants AMPs were claimed to be consistent with the GALL Report and were audited against the related elements of the associated AMP described in the GALL Report, unless otherwise indicated in this Audit Report.

Elements 7-9 address corrective actions, confirmation process, and administrative controls, respectively, and were audited during the Scoping and Screening Methodology audit (ML071340121) conducted on December 11-15, 2006 and are evaluated separately. The staff 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 LRA, program bases documents and related references, interviewed various applicant representatives, and conducted walkdowns of several plant areas. In total, 41 AMPs were reviewed. This report documents the staffs activities during this audit.

LRA AMP B.2.1, Inservice Inspection (ISI) Program In the Susquehanna Steam Electric Station (SSES) LRA, the applicant stated that AMP B.2.1, Inservice Inspection (ISI) Program is an existing program that is entirely consistent with the program elements in the GALL Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, with an exception on using a risk-informed ISI methodology to select its ASME Code Class welds for examination.

During its audit, the staff reviewed the applicants onsite documentation to determine whether those program elements claimed to be consistent with the GALL Report in the applicants AMP are consistent with the program elements recommended in the GALL Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD. The staff auditor interviewed the applicants technical staff and reviewed the following onsite documents:

Document Identifier (Numbers) Title Revision / Date

1. LRPD-05 SSES License Renewal Rev. 3, 4/29/2008 Project Document, Aging Management Program Evaluation Results

2. LRPD-05 Attachment 1.9 Aging Management Binder Rev. 1, 4/27/2008 B.2.1, Inservice Inspection (ISI) Program

3. ISI Procedure ISI Program Plan, Third Rev. 2 09/19/2006 SUS04.G01 Ten-Year Inspection Interval, Susquehanna Units 1 and 2

4. PPL Susquehanna, LLC Inservice Inspection (ISI) - Rev. 10 06/01/2007 Procedure NDAP-QA-1608 defines ISI responsibilities for site ISI groups

5. PPL Susquehanna, LLC Reactor Coolant Systems Rev. 2 07/14/2007 Procedure NDAP-QA-1610 Materials Degradation Management Program

6. PPL Susquehanna, LLC Nuclear Design Rev. 4 08/19/2004 Procedure NEPM-QA- Engineering Inservice 1160 Inspection Program

7. CR #567886 ISI Rejectable Linear 04/03/2008 Indication on the N2J Nozzle to Safe-End Weld Under PCWO# 562906 As Identified Under ISI CNF#

ISI-04-016 (On N2J Recirc Outlet Nozzle Weld)

8. CR #561319 N1B Nozzle-Safe End 03/21/2008 Weld Indication (On N1B Recirc Inlet Nozzle Weld)

9. Owner Activity Report ISI Owners Activity Report 06/06/2007 No. OAR-1-22 - defines the ISI and augmented ISI examinations performed during 2RO13 In comparing the 7 elements in the applicants program to those in the GALL Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, the staff reviewer 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 the GALL Report AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, except for: (1) four program element areas that the staff felt needed additional clarification, and (2) the applicants exception taken against the scope of program program element in the GALL Report AMP XI.M1 for crediting a risk-informed methodology for particular ASME Code Class 1 and 2 weld examinations. The four areas needing additional clarification are discussed in the paragraphs below. The staff assesses the applicants exception taken to the scope of program program element in the GALL Report AMP XI.M1 in the SER.

The staff noted that the applicant had not identified the parameters or aging effect that the program manages in either the scope of program, parameters monitored/inspected, or detection of aging effects program elements for the AMP. The staff asked the applicant to clarify which parameters/aging effect or aging mechanisms are within the scope of and managed by the applicants Inservice Inspection (ISI) Program. The staffs evaluation will be documented in the SER.

The staff noted that the basis document for the ISI Program indicated that the criteria in particular NRC approved BWRVIP reports may be used in lieu of applicable ASME Code Section XI ISI requirements for ASME Code Class 1, 2, or 3 components. The staff noted however, that the applicant did not specify whether any proposals to use alternative BWRVIP guidelines criteria would be requested through the 10 CFR 50.55a(a)(3) alternative methodology relief request process. This issue is relevant with respect to the scope of program, detecting of aging effects, monitoring and trending, acceptance criteria, and corrective actions program elements for the AMP. The staff asked the applicant to clarify whether proposals to use NRC approved BWRVIP guideline criteria (in lieu of applicable ASME Code Section XI requirements) would be submitted for staff approval in accordance with the alternative method relief request process in 10 CFR 50.55a(a)(3). The staffs evaluation will be documented in the SER.

The staff noted that the corrective actions program element discussion in the basis document specified that that corrective actions for the Inservice Inspection Program would be implemented through implementation of the applicants 10 CFR Part 50, Appendix B Quality Assurance Program. The staff also noted that corrective actions for ASME Code Class components are required, through reference in 10 CFR 50.55a, to be implemented in accordance with applicable corrective actions in ASME Code Section XI Article IWB-3000, or its subarticles, paragraphs, or subparagraphs. The staff asked the applicant to clarify how the implementation of the applicants 10 CFR Part 50, Appendix B Quality Assurance Program would ensure that the corrective actions for ASME Code Class 1, 2, or 3 components would be implemented in accordance with applicable corrective actions in ASME Code Section XI Article IWB-3000, or its subarticles, paragraphs, or subparagraphs or in NRC approved ASME Code Cases that are endorsed for use in the latest NRC issued version of Regulatory Guide 1.1.47, as endorsed in 10 CFR 50.55a.

The staff noted that operating experience program element discussion in the basis document did not specify any SSES specific or generic operating experience (OE) that the applicant felt was relevant to either: (1) demonstration that the applicants implementation of the AMP would accomplish its intended functions, (2) demonstration that one or more of the program elements for the AMP would need to be augmented or enhanced in order to accomplish their intended purpose, or (3) demonstration that the program elements of the AMP would not be capable of achieving their intended purpose. The staff noted that the license renewal binder for the Inservice Inspection Program included two (2) condition reports on circumferential cracking detected in the SSES Unit 1 N2J recirculation outlet nozzle safe end weld and in the SSES Unit N1B recirculation inlet nozzle safe end weld but that the applicant had not indicated this as relevant operating experience for the operating experience program element for the AMP.

The staff will issue an RAI to request that the LRA be amended to list these circumferential crack safe end nozzle events as relevant OE for the applicants Inservice Inspection (ISI)

Program. The staff asked the applicant to identify the weld overlay methodology that was used for the repairs of these safe end nozzle indications, and to inquire whether the overlay methodology required a flaw tolerance evaluation of the flaw indications, and if so, whether the analysis is a TLAA for the application. 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 the GALL Report 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.2.2, BWR Water Chemistry Program In the LRA, the applicant stated that AMP B.2.2 is an existing program that is consistent with the GALL Report AMP XI.M2, Water Chemistry. The applicant did not identify any exceptions to the GALL Report, nor enhancements required in the existing program.

During the audit, the staff reviewed the applicants onsite documentation to determine whether those program elements claimed to be consistent with the GALL Report in the applicants AMP are consistent with the program elements recommended in the GALL Report AMP XI.M2. The staff auditor interviewed the applicants technical staff and reviewed the following onsite documents.

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Results Revision 3 4/29/2008

2. LRPD-05, Aging Management Program Evaluation Results - Revision 1 Attachment 2.3a BWR Water Chemistry Program 7/28/2006

3. LRPD-04 Operating Experience Review Results and Summary Revision 2 11/11/2006

4. SCM Susquehanna Chemistry Manual, Chapter 2 - Revision 4 Reactor Water System 5/8/2002

5. SCM Susquehanna Chemistry Manual, Chapter 4 - Revision 3 Decay Heat Removal and Accident Mitigation Systems 12/19/1997

6. NDAP-QA-0630 Conduct of Chemistry Revision 6 06/05/2007

7. CR 580537 Condition Report # 580537 and Associated Evaluation Level 05/24/2003 Evaluation Report

8. CR 473077 Condition Report # 473077 and Associated 09/16/2003 Root Cause Analysis Level Evaluation Report

9. CR 470164 Condition Report # 470164 and Associated Evaluation Level 12/31/2004 Evaluation Report In comparing the 7 elements in the applicants AMP with the descriptions of each element in the GALL Report AMP XI.M2, the staff noted the following differences related to the applicants implementation of EPRI TR-103515, BWR Water Chemistry Guidelines:

1) EPRI TR-103515 recommends continuous monitoring of local electrochemical corrosion potential (ECP) during reactor power operation (>10% rated power). However, in lieu of monitoring for ECP, the applicant currently relies on monitoring of dissolved oxygen for indication of relevant conditions for corrosion.

2) EPRI TR-103515 recommends weekly monitoring of conductivity, chlorides, and sulfates in the Condensate Storage Tank (CST). However, the applicant currently measures conductivity, chlorides, and sulfates in the CST on a monthly basis.

The staff will prepare an RAI asking the applicant to justify that these deviations from recommendation in the GALL Report, through its reference to EPRI TR-103515, are technically acceptable and why they are not considered to be exceptions to the GALL Reports recommendations for program element Parameters Monitored or Inspected and program element Monitoring and Trending. The staffs evaluation will be documented in the SER.

The staff also reviewed the applicants 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 reviewing corrective action condition reports (CRs), the staff noted that SSES has a history of CRs related to high sulfate levels in reactor water following outages. The applicant stated that there have been no component failures attributed to the transient elevation of sulfates following a refueling outage. The staff will issue an RAI asking the applicant to provide additional information with regard to the current status and what has been done to eliminate or mitigate this issue of elevated sulfates. The staff noted that the most recent CR included in the SSES operating experience report had a resolution date of 12/31/2004. The staff will prepare an RAI asking the applicant to perform a review of more recent CRs and provide additional information about recent CRs related to the BWR Water Chemistry Program. 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 the GALL Report AMP XI.M2, except for the issues addressed in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.3, Reactor Head Closure Studs In the LRA, the applicant stated that AMP B.2.3 is an existing program that is consistent with the GALL Report AMP XI.M3, Reactor Head Closure Studs.

During its audit, the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 SSES License Renewal Project Document, Attachment 1.10, Rev. 1, 07/27/2006 Attachment 1.10 Reactor Head Closure Studs Program

2. SUS04.G01 ISI Program Plan, Third Ten-Year Inspection Interval Rev. 0, 07/2003

3. ME-ORF-059 , Reactor Vessel Head Stud Tensioning Rev. 9, 03/08/20000 superseded by ME-1RF-101 or ME-2RF-101

4. ME-ORF-058, Reactor Vessel Head Installation Rev. 5, 09/29/1997 Superseded by ME-1RF-101 or ME-2RF-101

5. ME-1RF-101 Unit 1 Reactor Vessel Reassembly Rev. 4, 10/21/2007

6. CR651077 ISI Visual Exam of containment head studs noted mechanical 030/2/2005 damage on one stud In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in the AMP B.2.3 are consistent with the GALL Report AMP XI.M3 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL Report AMP XI.M3. The staff also verified that the applicant provided an adequate summary description of the program.

The applicant confirmed that they conform to the requirements of the ASME Code,Section XI, Subsection IWB (1998 edition), and not the 2001 edition as recommended by the GALL Report.

This issue will be handled generically for SSES, and does not require an AMP specific exception. Additionally, the applicant confirmed that the maximum reported ultimate tensile strength is 163.5 ksi which is less than the 170 ksi cited in the GALL Report.

The staff also reviewed the operating experience reports to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience.

However, none of the SSES operating experience reviewed revealed any reactor head closure stud cracking or loss of material, or any other problems with the RPV head studs, nuts, or washers.

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 the GALL Report AMP XI.M3, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.4, BWR Vessel ID Attachment Welds Program In the LRA, the applicant stated that AMP B.2.4, BWR Vessel ID Attachment Welds Program is an existing program that is consistent with the program elements in the GALL Report AMP XI.M4, BWR Vessel ID Attachment Welds. The staff verified that the applicants BWR Vessel ID Attachment Welds Program is an existing program that is credited to manage cracking that may occur in reactor vessel (RV) ID attachment welds.

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

Document Identifier (Numbers) Title Revision / Date

1. LRPD-05 SSES License Renewal Rev. 3, 04/29/2008 Project Document, Aging Management Program Evaluation Results

2. LRPD-05 Attachment 1.6 SSES License Renewal Rev. 1 08/08/2006 Project, Aging Management Program Evaluation Results, BWR Vessel ID Attachment Weld Program

3. SSES Letter No. Susquehanna Steam 07/16/2004 PLA-5775 Electric Station, Unit 1 Thirteenth Refueling and Inspection Outage, ISI Summary Report

4. SSES Letter No. Susquehanna Steam 07/18/2003 PLA-5649 Electric Station, Unit 2 Eleventh Refueling and Inspection Outage, ISI Summary Report In comparing the 7 elements in the applicants program to those in the GALL Report AMP XI.M4, BWR Vessel ID Attachment Welds the staff reviewer noted that the program elements for the applicants AMP were consistent with the program element criteria recommended in the GALL Report AMP XI.M4. Specifically, the staff reviewer noted that, consistent with the program element criteria in the GALL Report AMP XI.M4, the program elements in the applicants BWR Vessel ID Attachment Welds Program are based on the required inservice inspection examinations mandated in Section XI for these welds and on the augmented inspections that are recommended for these welds in accordance with the inspection and flaw evaluation guidelines in Topical Report BWRVIP-48-A. The staff verified that its endorsement of the inspection and flaw evaluation guidelines in BWRVIP-48 was provided in a safety evaluation (SE) to the BWRVIP dated January 17, 2001 (ML010180493). The safety evaluation includes the staffs license renewal applicant action items on BWRVIP-48. The staff verified that the applicant provided its responses to these license renewal applicant action items in Appendix C of the LRA. The staffs evaluation will be documented in the SER.

The staff also reviewed the operating experience discussion that the applicant provided in LRA AMP B.2.10 and the operating experience basis document binder for this AMP. The staff noted that the applicant did not identify any relevant specific operating experience or NRC issued or industry issued generic operating experience relative to the program elements for this AMP.

However, the staff did verify that the applicant had provided the Outage ISI summary reports for Unit 1 refueling and inspection outage 1RIO13 and Unit 2 refueling and inspection outage 2RIO11 in the license renewal binder B.2.4 for this AMP and that these outage summaries did not identify the presence of any recordable flaw indications in the RV interior attachment welds for SSES Unit 1 or Unit 2. Based on this review, the staff verified that the applicant has been implementing the required inspections of these attachment welds in accordance with the ASME Code Section XI and the recommended augmented inspection criteria for these welds as given in BWRVIP-48-A, as implemented through augmented inspections performed under the applicants Inservice Inspection Program. The staff also verified that there are not yet any SSES specific operating experience flaw indications in these interior attachment welds. The staffs SER evaluation of the operating experience program element for this AMP will be given in the SER and will reference this operating experience review summary.

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.M4, except for the issues addressed by the aforementioned RAIs in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.5, BWR Feedwater Nozzle Program In the LRA, the applicant stated that B.2.5, BWR Feedwater Nozzle Program is an existing program that is consistent with the program elements in the GALL Report AMP XI.M5, BWR Feedwater Nozzles. The staff verified that the applicants BWR Feedwater Nozzles Program is credited as an existing program that is used to manage cracking that may occur in the reactor vessel (RV) feedwater nozzles.

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

Document Identifier (Numbers) Title Revision / Date

1. LRPD-05 SSES License Renewal Rev. 3, 04/29/2008 Project Document, Aging Management Program Evaluation Results

2. LRPD-05 Attachment 1.3 SSES License Renewal Rev. 1 07/27/2006 Project, Aging Management Program Evaluation Results, BWR Feedwater Nozzle Program

3. SSES Letter No. PLA- Susquehanna Steam Electric 06/11, 1981 807 Station, SER Outstanding Issue 20

4. SSES Letter No. PLA- Susquehanna Steam Electric 11/02/2000 5253 Station, Licenses NPF-14 and NPF-22: Alternate Feedwater Nozzle Inspection Requirements

5. SSES Letter No. PLA- Susquehanna Steam Electric 05/03/1982 1075 Station, Preservice/Inservice Examination - NUREG 0619

6. SSES Letter No. PLA- Susquehanna Steam Electric 06/21/2006 6078 Station Unit 1 Fourteenth Refueling Outage Owners Activity Report

7. GE Nuclear Energy UT Project Susquehanna Unit 1 03/03/2006 Examination Summary - R&IO14, Weld ID No. N4A Sheet No. 1-B3.90.0017 (NoZ-SC3), Reactor Pressure Vessel Weld

8. SSES Letter No. PLA- Susquehanna Steam Electric 06/29/2007 6228 Station Unit 2 Thirteenth Refueling Outage Owners Activity Report

9. GE Examination Susquehanna Unit 2, Summary Sheet No. VE- Component ID N4A-Bore,07-006 Outage U213RIO, FW Nozzle Bore As part of its audit of the BWR Feedwater Nozzle Program, the staff reviewed the license renewal basis document for the applicants BWR Feedwater Nozzle Program and compared the scope of program, preventative actions, parameters monitored/detected, detection of aging effects, monitoring and trending, acceptance criteria, and operating experience program element descriptions for the AMP, as discussed in the basis document, to the corresponding program element criteria that are recommended in the GALL Report AMP XI.M5, BWR Feedwater Nozzle. The staffs review of the corrective actions, administrative controls, and confirmatory controls program elements for the Inservice Inspection Program was performed as part of the staffs review of the applicants Quality Assurance Program for the LRA.

In comparing the 7 elements in the applicants program to those in the GALL Report AMP XI.M5, BWR Feedwater Nozzles the staff reviewer noted that the program elements for the applicants AMP were consistent with the program element criteria recommended in the GALL Report AMP XI.M5, with the exception of three (3) aspects of the applicants program that the staff felt were in need of further resolution and for which the staff issued RAIs to the applicant.

Specifically, the staff reviewer noted that, consistent with the program element criteria in the GALL Report AMP XI.M5, the program elements in the applicants BWR Feedwater Nozzles Program are based on the augmented ultrasonic testing (UT) methodology and criteria for BWR feedwater nozzles, proposed in General Electric (GE) Topical Report No. GENE-523-A71-0594, and implemented in accordance with the applicant Inservice Inspection Program (LRA AMP B.2.1). The staff verified that this is consistent with the GALL Report because the staff endorses use of GEs augmented UT methodology for aging management of the SSES feedwater nozzles in the GALL Report AMP XI.M5.

The staff noted that three (3) aspects of the applicants program were in need of further clarification. In the first area needing clarification, the staff noted that applicants acceptance criteria program element for the BWR Feedwater Nozzle Program indicated that the applicant may use acceptance criteria in NRC approved BWRVIP guideline documents as an alternative to the acceptance criteria for the FW nozzles that are required by the ASME Code Section XI, Subsection IWB. The staff will issue an RAI on AMP B.2.1, Inservice Inspection (ISI) Program, to inquire about the validity of using alternative BWRVIP recommendation criteria as alternatives to ASME Code Section XI requirements. This RAI is also applicable to the acceptance criteria program element for this AMP. The staffs evaluation will be documented in the SER.

In the second area needing clarification, the staff noted that in the operating experience program element for the AMP B.2.5, BWR Feedwater Nozzles, the applicant specifically discussed the specific operating experience for its feedwater nozzle examinations and provided a statement that the plant-specific UT experience for the FW nozzles is bounded by that identified and discussed in NRC Generic Letter (GL) 81-11 and in NUREG-0619. However, the staff also noted the license renewal binder for this AMP did provide some operating experience events resulting from augmented examinations performed on the FW nozzles during the last refueling and inspection outage for SSES Unit 1 (i.e., RIO #U114RIO), as provided in SSES Letter No. PLA-6078, Susquehanna Steam Electric Station Unit 1 Fourteenth Refueling Outage Owners Activity Report, dated June 21, 2006 and GE Nuclear Energy UT Examination Summary Sheet No. 1-B3.90.0017, Project Susquehanna Unit 1 - R&IO14, Weld ID No. N4A (NoZ-SC3), Reactor Pressure Vessel Weld, dated March 3, 2006.

Specifically, the staff noted that the augmented UT examinations of SSES Unit 1 FW nozzle N4A indicated the presence of eight (8) recordable flaw indications that were dispositioned as being acceptable for further service in accordance with ASME Code Section XI IWB-3000 provisions. The staff noted however, that the applicant did not cite these flaw indications as relevant operating experience for this AMP. The staff will issue an RAI to request the operating experience program element discussion for LRA Section B.2.5 be amended to include this experience as relevant operating experience for the AMP and to provide additional information on the augmented UT reinspection frequency that would be used for the Unit 1 FW nozzle N4A in the future. The staff evaluates the applicants operating experience program element for the BWR Feedwater Nozzle Program and the resolution of the RAI will be documented in the SER.

With respect to the corresponding outage documents for Unit 2 (during refueling and inspection outage #U213RIO), the staff reviewed SSES Letter No. PLA-6228, Susquehanna Steam Electric Station Unit 2 Thirteenth Refueling Outage Owners Activity Report, dated June 29, 2007 and GE Examination Summary Sheet Nos. VE-07-007 and VE-07-018, Susquehanna Unit 2, Component IDs N4A-IR and N4E-IR, Outage U2R&IO13, NOZ-IR, both dated March 22, 2007, and noted that the applicant had performed augmented UT examinations of the Unit 2 N4A and N4E FW nozzle bores. The staff verified that the applicant did not identify any recordable indications in SSES Unit 2 FW nozzles N4A and N4E as a result of implementing these augmented inspections.

With respect to the third area needing clarification, the staff verified that the applicant provided its FSAR Supplement summary description for the BWR Feedwater Nozzle Program in LRA Section A.1.2.6 and that the FSAR Supplement includes Commitment No. 5. However, the staff noted a discrepancy in the application, in that the program description for the BWR Feedwater Nozzle Program states that the AMP is implemented in accordance with the augmented UT methodology and criteria in GE Topical Report GENE-523-A71-0594, whereas the FSAR Supplement summary description for the AMP indicates that the augmented UT methodology would be implemented in accordance with the recommendations in applicable BWRVIP guidelines. The staff asked the applicant to resolve this discrepancy. The staff will evaluate the FSAR Supplement A.1.2.6 for the BWR Feedwater Nozzle Program and LRA Commitment No.

5 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 the GALL Report AMP XI.M5, except for the issues addressed by the aforementioned RAIs in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.7, BWR Stress Corrosion Cracking Program In the LRA, the applicant stated that AMP B.2.7, BWR Stress Corrosion Cracking Program is an existing program that is consistent with the program elements in the GALL Report AMP XI.M7, BWR Stress Corrosion Cracking, without any exceptions to the GALL Report AMP and without the need for enhancement of the program. The staff verified that the applicants BWR Stress Corrosion Cracking Program is an existing program that is credited to manage cracking/stress corrosion cracking that may occur in the ASME Code Class 1 stainless steel piping, valves, flow instruments, and pump casings.

During its audit, the staff reviewed the applicants onsite documentation to determine whether the program elements in the applicants AMP are consistent with the elements in the GALL Report program. The staff auditor interviewed the applicants technical staff and reviewed the following additional onsite documents and NRC issued documents listed below:

Document Identifier (Numbers) Title Revision / Date

1. LRPD-05 SSES License Renewal Rev. 3, 04/29/2008 Project Document, Aging Management Program Evaluation Results

2. LRPD-05 Attachment 1.5 SSES License Renewal Rev. 1 07/27/2006 Project, BWR Stress Corrosion Cracking Program

3. PPL Susquehanna, LLC Inservice Inspection (ISI) - Rev. 10 06/01/2007 Procedure NDAP-QA-1608 defines ISI responsibilities for site ISI groups

4. CR #567886 ISI Rejectable Linear 04/03/2008 Indication on the N2J Nozzle to Safe-End Weld Under PCWO# 562906 As Identified Under ISI CNF#

ISI-04-016

5. CR #561319 N1B Nozzle-Safe End 03/21/2008 Weld Indication

6. CR #3 391355 Recirc B Pump Small Pipe Cracking On Eleven Recirc Loop B Class 1 small bore piping welds found cracked as a result of vibrational fatigue-all welds repaired or replaced

7. PPL Susquehanna, LLC ISI BWRVIP Inspection Rev. 1 09/28/2006 Procedure NEIM-00-1180 Implementation In comparing the 7 elements in the applicants program to those in the GALL Report AMP XI.M7, BWR Stress Corrosion Cracking, the staff reviewer 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 the GALL Report AMP XI.M7, BWR Stress Corrosion Cracking, except for two aspects of the AMPs program element areas that the staff felt were in need of additional clarification.

In regard to the first program element aspect needing clarification (on preventative actions),

the staff noted that applicants preventative actions program element for the BWR Stress Corrosion Cracking Program indicated that two welds scheduled for stress relief had not received a post-weld heat treatment consistent with the NRC Generic Letter (GL) 88-01/NUREG-0313 recommendations and were unacceptable for stress relief credit by the NRC.

The staff noted that the applicant had identified that the plant had initiated hydrogen water chemistry control as a basis for reducing the electro-chemical potentials of the Class 1 stainless steel welds below the potential associated with the onset of stress corrosion cracking (SCC).

The staff asked the applicant to clarify whether there was any established link between the findings identified in the NRCs safety evaluation on the applicants response to GL 88-01 and the two recirculation nozzle safe-end welds in which the applicant had reported indications of SCC-induced flaws (i.e., the Unit 1 N2J recirculation outlet nozzle safe-end weld and the Unit 1 N1B recirculation inlet nozzle safe-end weld). Specifically, the staff asked the applicant to identify whether these safe end nozzle welds were among the Class 1 stainless steel piping welds that were scheduled induction heating stress relief treatments and whether the N2J and N1B nozzle safe end welds were the welds that had not received the recommended post weld heat treatments that are part of this stress relief process. The staff asked the applicant to identify the dates of hydrogen water chemistry control at SSES Unit 1 and SSES Unit 2. The staff assesses the applicants response to this RAI in the SER.

In regard to the second program element aspect needing clarification (on detection of aging effects and acceptance criteria), the staff noted that the NRC approved guidelines in BWRVIP Topical Report #BWRVIP-75A provide the latest recommendations for augmented stress corrosion cracking inservice inspections. However, the staff noted that the applicant had only credited the BWRVIP-75A criteria for expansion of the sample size upon detection of a relevant SCC-induced flaw indication and that the applicant was continuing to use the recommended augmented ISI criteria in GL 88-01 and NUREG-0313 to perform the augmented ISI examinations (i.e., augment UT examinations) of these stainless steel Class 1 pipe welds. The staff, in an RAI will ask the applicant to clarify whether the updated NRC approved guidelines in Topical Report BWRVIP-75A would be used as an option for performing the updated augmented ISI examinations for these ASME Code Class 1 stainless steel pipe welds. The staff asked the applicant to clarify whether the flaw acceptance criteria in NRC-approved Topical Report BWRVIP-75A or in NRC- approved Topical Report BWRVIP-14 would be used for the acceptance criteria for any crack indications that might be detected in these ASME Code Class 1 stainless steel pipe welds. The staff will assess the applicants response to this RAI in the SER.

The staff also reviewed the operating experience program element discussion for this AMP.

The staff noted that the applicant had identified the circumferential crack indications in the SSES Unit 1 N2J recirculation nozzle outlet safe-end weld and the SSES Unit 1 N1B recirculation inlet nozzle safe-end weld as relevant operating experience for this AMP. The staff verified that the applicant included the conditions reports (CRs) for these indications in the license renewal binder for this AMP.

The staff also noted that the applicant had also listed a CR on flaw indications in 12 small bore Class 1 piping components as relevant operating experience for this AMP. The staff reviewed these CRs as part of its onsite review of the AMP. The staff verified that the CRs demonstrated that the detection of these flaw indications were the result of the non-destructive test examinations that were implemented through an augmentation of the applicants Inservice Inspection Program, and that the CRs indicated that the applicant had performed appropriate Code repairs of the flaw indications in the small bore nozzle welds.

The staffs evaluation of these condition reports and the applicants operating experience program element for the BWR Stress Corrosion Cracking Program will be provided 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 the GALL Report AMP XI.M7, except for the issues addressed by RAIs in which the staff needs additional clarification.

LRA AMP B.2.8, BWR Penetrations Program In the LRA, the applicant stated that AMP B.2.8, BWR Penetrations Program is an existing program that is consistent with the program elements in the GALL Report AMP XI.M8, BWR Penetrations, with an exception taken on the scope of program program element in the GALL Report AMP XI.M8 to include the vessel flange leakoff penetration nozzle, vessel drain penetration nozzle, control rod drive penetration nozzles, and incore flux monitor penetration nozzles as additional components that are within the scope of the AMP (i.e. in addition to the standby liquid control nozzles and instrument penetration nozzles). The staff verified that the applicants BWR Penetrations Program is a new program that is credited to manage cracking that may occur in reactor vessel (RV) penetration nozzles and their safe-end nozzle welds.

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

Document Identifier (Numbers) Title Revision / Date SSES License Renewal Project Document, Aging Management Program

1. LRPD-05 Evaluation Results Rev. 3, 04/29/2008 SSES License Renewal Project, Aging Management Program Evaluation Results,

2. LRPD-05 Attachment 1.6 BWR Penetrations Program Rev. 1, 07/22/2006 Susquehanna Steam Electric Station, Unit 1 Thirteenth Refueling and Inspection

3. SSES Letter # PLA-5775 Outage, ISI Summary Report 07/16/2004 Susquehanna Steam Electric Station, Unit 1 Eleventh Refueling and Inspection

4. SSES Letter # PLA-5649 Outage, ISI Summary Report 07/18/2003 In comparing the 7 elements in the applicants program to those in AMP XI.M4, BWR Vessel ID Attachment Welds the staff auditor noted that the program elements for the applicants AMP were consistent with the program element criteria recommended in the GALL Report AMP XI.M4, except for the additional penetration nozzles that were brought into the scope of the AMP. Review of LRPD-05, Attachment 1.4, the staff verified that the additional nozzles referred to in the LRA were the RV flange leakoff penetration nozzle, RV drain penetration nozzle, control rod drive penetration nozzles, and the incore flux monitor penetration nozzles. The staff verified that the applicant had included the addition of these penetration nozzles as an exception to the scope of program program element for the AMP. The staff considers the inclusion of these additional penetrations to be a conservative augmentation of the AMP instead of an exception to the scope of program program element. The staff verified that the applicants program uses the existing ASME Section XI inspection requirements for these penetrations as its bases for inspecting the penetrations in accordance with the AMP, and that the applicant implements these examinations through the implementation of the applicants Inservice Inspection (ISI) Program. This information forms the staffs basis for its evaluation of the exception taken to the scope of program program element in the GALL Report AMP XI.M8.

This exception will be evaluated in the SER.

The staff also reviewed the SSES operating experience discussion provided in LRA AMP B.2.8 and the operating experience basis document for this AMP. The staff noted operating experience program element in LR basis document LRPD-05, Attachment 1.4, indicated that the applicant had reviewed the last five Inservice Inspection Outage Summary Reports for SSES Units 1 and 2 and that the inservice inspections (ISI) or augmented ISI inspections performed on the penetration nozzles did identify any relevant flaw indications in the penetration nozzles that were inspected as part of the applicants ISI Program on behalf of this AMP. The staff verified that, although the applicant has not yet identified any relevant indications for the penetrations in the scope of this AMP, the applicant has recorded indications and initiated appropriate condition report/action requests on flaw indications that the applicant has identified in some of the RV internal components, as part of its in-vessel visual inspections (IVVI) that are performed on its BWR reactor vessel internals (RVIs). The staffs verification of the process that the applicant uses to implement the BWRVIP-based augmented inspections of its RV penetration nozzles and RVI components demonstrates that the applicants BWRVIP-based augmented inspections of its RV penetration nozzles and RVI components are effective. The staff evaluates the operating experience program elements for both the BWR Penetrations Program and the BWR Vessel Internals Program in the applicable subsections of 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 the GALL Report AMP XI.M8, 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.2.9 BWR Vessel Internals Program In the LRA, the applicant stated that AMP B.2.9 BWR Vessel Internals Program is an existing program that is consistent with the program elements in the GALL Report AMP XI.M9, BWR Vessel Internals, with an enhancement taken on the scope of program program element in the GALL Report AMP XI.M9 to include augmented inspections of the top guide grid beam and beam-to-beam crevice slot locations. The staff verified that the applicants BWR Vessel Internals Welds Program is an existing program that is credited to manage cracking, reduction of fracture, and loss of material that may occur in the SSES reactor vessel internal (RVI) components.

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

Document Identifier (Numbers) Title Revision / Date

1. LRPD-05 SSES License Renewal Rev. 3, 04/29/2008 Project Document, Aging Management Program Evaluation Results

2. LRPD-05 Attachment 1.7 SSES License Renewal Rev. 2 10/12/2006 Project, Aging Management Program Evaluation Results, BWR Vessel Internals Program

3. Condition Report 97- Core Spray Sparger 03/27/1997 0965 Support Cracking

4. Condition Report 98- Four Ultrasonic Indications 03/22/1998 1815 Identified On Core Shroud Weld H4

5. Condition Reports No Title - Subject Matter is 04/18/2001 326415 and 324469 On Recommendation for Use As-Is for Indications in Jet Pump Assembly Restrainer, Wedge, and Rod Subcomponents

6. BWRVIP Topical Reports Referenced in GALL AMP XI.M9

7. Staffs Safety Evaluations on BWRVIP Topical Reports Referenced in GALL AMP XI.M9 In comparing the 7 elements in the applicants program to those in the GALL Report AMP XI.M9, BWR Vessel Internals the staff auditor noted that the program elements for the applicants AMP were consistent with the program element criteria recommended in the GALL Report AMP XI.M9, except for two (2) program element aspects of the AMP that the staff felt were in need of additional clarification and for which the staff issued an RAI.

With respect to the first program element aspect needing clarification, the staff noted that the applicant has enhanced the AMP to credit augmented inspections of the top guide grid beam and beam-to-beam crevice slot locations. The staff will ask the applicant in an RAI to clarify whether SSES has performed any inspections of these locations to date, and if so whether there has been any SSES specific experience with top guide cracking in these locations. The staff will evaluate this enhancement and the RAI in the SER.

With respect to the second program element aspect needing clarification, the staff reviewed the operating experience discussion provided in LRA AMP B.2.8 and in the license renewal basis document for this AMP. The staff noted that the applicant did not identify any relevant SSES specific operating experience or NRC issued or industry issued generic operating experience relative to the program elements for this AMP. The staff also noted that the applicant had included some relevant condition reports (CRs) for the SSES RVI components in the program basis document. The staff reviewed a number of CRs for the BWR RVI components and noted that, in these CRs, the applicant reported the detection of recordable flaw indications in some of the core spray sparger brackets, core shroud circumferential welds and jet pump assembly components (i.e., jet pump restrainers, wedges, and rods). The staff noted that the applicant had dispositioned these flaw indications as acceptable As-Is for further service without the need at this point for repair or replacement. The staff will ask the applicant in an RAI to justify why the flaw indications in the core spray sparger brackets, core shroud welds, and jet pump assembly components had not been identified as relevant operating experience for the AMP and to provide its basis for leaving the flaws in these components in service. The staff will assess the applicants operating experience program element for the applicants BWR Vessel Internals Program and the RAI 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 the GALL Report AMP XI.M9, except for the issues to be addressed by the RAIs in which the staff needed additional clarification might be warranted as described above.

LRA AMP B.2.10, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program In the LRA, the applicant stated that the AMP B.2.10 is a new program that will be consistent with the program elements in the GALL Report AMP XI.M13, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS). The staff verified that 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 reviewed the applicants onsite documentation to determine whether the program elements in the applicants AMP are consistent with the elements in the GALL Report program. The staff auditor interviewed the applicants technical staff and reviewed the following additional onsite documents and NRC-issued documents listed below:

Document Identifier (Numbers) Title Revision / Date SSES License Renewal Project Document, Aging Management Program

1. LRPD-05 Evaluation Results Rev. 3, 04/29/2008 Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic

2. LRPD-05 Attachment 1.8 Stainless Steel (CASS) Program Rev. 2 10/09/2006

3. PPL Susquehanna, LLC Procedure NDAP-QA-1608 Inservice Inspection (IS) Rev. 8 10/22/2004 Reactor Coolant Systems

4. PPL Susquehanna, Materials LLC Procedure Degradation Management NDAP-QA-1610 Program Rev. 2 07/14/2007

5. PPL Susquehanna, LLC Procedure Nuclear Design Engineering NEPM-QA-1160 Inservice Inspection Program Rev. 4 08/19/2004 In comparing the 7 elements in the applicants program to those in the GALL Report AMP XI.M13, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS), the staff auditor noted that the program elements for the applicants AMP were consistent with the program element criteria recommended in the GALL Report AMP, except for:

(1) five program element aspects that the staff felt were in need of additional clarification, and in which RAIs were issued, and (2) issuance of a sixth RAI requesting a commitment on future operating experience in order to make the operating experience program element for the AMP consistent with the staffs guidance in SRP-LR Branch Position RSLB-1, Section A.1.2.3.10. (i.e.

in Section A.1.2.3.10 of Appendix A to NUREG-1800, Revision 1). The basis for asking for these clarifications is discussed in the paragraphs below:

In regard to the first program element aspect needing clarification, the staff noted that the scope of program program element for the AMP did not establish which NRC approved guideline or basis document would be used to screen the CASS RVI components for susceptibility to the phenomenon of thermal aging embrittlement. The staff will ask the applicant in an RAI to clarify which NRC approved guideline or basis document would be used to screen the CASS RVI components for susceptibility to the phenomenon of thermal aging embrittlement.

The evaluation will be documented in the SER.

In regard to the second program element aspect needing clarification, the staff noted that there was an inconsistency between the scope of program element description and the parameters monitored/inspected element description on the parameters that would be used to screen the CASS components for susceptibility to reduction of fracture toughness. The staff noted that in the scope of program program element, the applicant indicated that it would use casting method, molybdenum content, and ferrite content as its basis for screening loss of fracture toughness by either thermal aging embrittlement or by neutron irradiation embrittlement. In contrast, the staff noted that the parameters monitored/inspected program element description indicated that the screening for reduction of fracture toughness would be based on both neutron fluence levels and component material properties (including alloying content criteria). The staff will ask the applicant in an RAI to resolve this discrepancy between the scope of program and the parameters monitored/inspected program element descriptions in the LR basis document for the AMP, and to identify which specific parameter criteria would be used to screen the CASS RVI component for reduction of fracture toughness by thermal aging embrittlement and which specific parameter criteria would be used to screen the CASS RVI components for reduction of fracture toughness by neutron irradiation embrittlement. The staff will evaluate the applicants responses to the RAIs in the SER.

With regard to the third program element aspect needing clarification, the staff noted that the detection of aging effects program element indicated that the applicant may use ultrasonic testing (UT) as one of the inspection techniques that are used to detect for cracking in these CASS components. The current state of the art UT inspection methods have not yet been qualified as being capable of detecting cracks in CASS materials. The staff will ask the applicant in an RAI to clarify whether the state of the art UT techniques are capable of detecting cracks in CASS materials, and if not, to clarify which inspection technique/method would be implemented to monitor for cracking if condition monitoring was chosen as the process for aging management of fracture toughness.

The staff asked the applicant to justify why the detection of aging effects or monitoring or trending program elements for the AMP did not credit a supplemental flaw tolerance analysis as an alternative basis for managing reduction of fracture toughness in these CASS RVI components. The staff will evaluate the applicants responses to the RAIs in the SER.

With regard to the fifth program element aspect needing clarification, the staff noted that the scope of program program element description in the basis document for the applicants BWR Vessel Internals Program indicated the applicant might use applicable NRC approved BWRVIP guidelines as the basis for managing reduction of fracture toughness in the CASS RVI internals, through implementation of the applicants BWR Vessel Internals Program and Inservice Inspection Program. However, the staff noted that the applicant did not identify this as an exception to either the scope of program or detection of aging effects program elements for the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program. The staff will ask the applicant in an RAI to amend the LRA to identify this aspect as an exception to the scope of program and detection of aging effects program elements for AMP B.2.10, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program, and to amend the scope of program program element for LRA Section B.2.9, BWR Vessel Internals Program, to identify the BWRVIP guideline documents that would be used to manage both reduction of fracture toughness due to thermal aging of CASS and neutron irradiation embrittlement in the CASS RVI components.

The staff will evaluate the impact of the applicants response to this RAI in the SER.

With respect to the staffs review of the operating experience program element for this AMP, the staff noted that the applicant has identified the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program as a new program for SSES Units 1 and 2, and did not report any operating experience events on reduction of fracture toughness in CASS RVI components as being relevant to the operating experience program element for the AMP. The staff noted that LR Section A.1.2.3.10, Item 2 (i.e., in Appendix A of NUREG-1800, Revision 1), establishes the NRCs position that applicants crediting new programs for aging management may want to provide a commitment on the LRA to submit any future operating experience for these programs to the NRC. In order to be consistent with Section A.1.2.310, Item 2 in SRP-LR Branch Position RLSB-1, the staff will issue an RAI and request that, consistent with the recommended criterion in Section A.1.2.3.10 in Branch Position RLSB-1 (i.e. in Appendix A of NUREG-1800, Revision 1), the applicant provide a commitment on the application to submit future operating experience to verify the effectiveness of their new programs, including the Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS) Program. The staff will evaluate the applicants response to this RAI 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 the GALL Report AMP XI.M13, except for the issues addressed by the RAIs in which the staff needed additional clarification.

LRA AMP B2.11, Flow-Accelerated Corrosion Program In the LRA, the applicant stated that AMP B2.18 is an existing program that is consistent with the GALL Report AMP XI.M17, Flow-Accelerated Corrosion.

During its audit, the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Rev. 3, 04/29/2008 Results

2. LRPD-05, Att. 2.8 Aging Management Program Evaluation Rev. 1, 07/25/2006 Results - Flow Accelerated Corrosion

3. M-1414 Inspection of ASME Class 1,2,3 and B31.1 Rev. 10, 02/27/2004 piping for moisture erosion/corrosion

4. NEPM-QA-1172 Guidelines for Flow-Accelerated Corrosion Rev. 1, 10/31/2006 Program Activities

5. NDAP-QA-1106 Flow-Accelerated Corrosion Program Rev. 1, 10/31/2006

6. NEPM-QA-0221-1 FAC System Susceptibility Evaluation Rev. 0, 01/28/2005 th

7. Summary Report for the 12 Refueling and Winter 2005 Inspection Outage In LRA Table 3.4.2-4, Condenser and Air Removal System, the Flow-Accelerated Corrosion (FAC) Program is credited to manage loss of material for carbon steel condensers (shell) in a treated water environment. In Table 3.4.2-7, Main Turbine System, the Flow-Accelerated Corrosion (FAC) Program is credited to manage loss of material for carbon steel turbine casings (high pressure) in a treated water environment. The staff will issue an RAI requesting the applicant to confirm that these components are included in the scope of the existing FAC Program, and the staffs evaluation will be documented in the SER.

It was not clear what criterion the applicant used to increase sample size. The staff will consider issuing an RAI requesting the applicant to provide information on how SSES expands sample size, and the staffs evaluation will be documented in the SER.

The staff also reviewed 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 the GALL Report AMP XI.M17, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.12, Bolting Integrity In the LRA, the applicant stated that the AMP B.2.12 is an existing program that is consistent with the GALL Report AMP XI.M18, Bolting Integrity with exceptions and an enhancement.

The exceptions primarily address aging management of structural bolting, which is accomplished under the ISI Program and Structures Monitoring Program, and affects the GALL Report program elements 1-6. The enhancement includes a specific precaution against using certain compounds as lubricants to protect against stress corrosion cracking.

During its audit, the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents.

Document Title Revision / Date

1. LRPD-05 Attachment 2.16 Bolting Integrity Program Rev 2, 4/22/08

2. Procedure MT-GM-015 Torquing Guidelines Rev 16, 10/01/04

3. Procedure NDAP-QA- Inservice Inspection Rev 8, 10/22/04 1608

4. Procedure NEPM-QA- Design Engineering Programs Inservice Inspection Rev 4, 8/19/04 1160

5. Procedure NEIM-00-1162 ISI Data Review and Approval Rev 3, 10/04/05

6. LRPD-04 Operating Experience Review Results and Rev 2, 11/11/06 Summary In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in SSES AMP B.2.12 are consistent with the GALL Report AMP XI.M18 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL Report AMP except for the areas that the applicant took exceptions to the GALL Report AMP XI.M18. The staff also verified that the applicant provided an adequate summary description of the program.

The staff found that the GALL Report monitoring and trending program element requiring leak rate to be monitored on a particularly defined schedule was not properly documented in their bolting integrity program. Additionally, it was found that although the LRA claimed that the B.2.12 Bolting Integrity AMP was consistent with the GALL Report Corrective Actions program element, an exception to this program element exists in their use of EPRI NP-5067 and TR-104213 instead of EPRI NP-5769 as recommended by the GALL Report. The staff will consider issuing RAIs to address these issues, and the staffs evaluation will be documented in the SER.

The staff also reviewed 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 2002 condition report describes the degraded condition of a total of 26 corroded bolts on the A1 and A2 diesel generator intercoolers. Upon further questioning and review of the condition report, it was discovered that additional investigation was done to determine the root cause to be moisture and warm conditions. As a result, all 26 bolts were replaced, 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 the GALL Report AMP XI.M18, 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 B2.13, Piping Corrosion In the LRA, the applicant stated that AMP B2.23 is an existing program that will be consistent with the GALL Report AMP XI.M20, Open Cycle Cooling Water System with exceptions.

During its audit the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Rev. 3, 04/29/2008 Results

2. LRPD-05, Att. 2.11 Aging Management Program Evaluation Rev. 2, 12/12/2007 Results - Piping Corrosion Program

3. M-1548 SSES Heat Exchangers Performance Rev. 0, 06/23/1999 Monitoring Program

4. H-1019 Piping Corrosion and Degradation Inspection Rev. 2, 02/08/1999 Program

5. H-1004 Heat Exchanger/Condenser Inspection and Rev. 6, 12/12/2002 Condition Assessment

6. CR-603759 Clams found during inspection 09/08/2004

7. CR-693852 Asiatic clams found in ESSW spray pond 07/20/2005 In the LRA Section B.2.13, the applicant stated an exception in the monitoring and trending element that inspection frequencies are based on operating conditions and past history; flow rates, water quality, lay-up and heat exchanger design. The GALL Report AMP XI.M20 recommends that testing and inspections be performed annually and during refueling outages.

The staff will consider issuing an RAI to request the applicant confirm these frequencies are in accordance with the information provided in GL 89-13 concerning a routine inspection and maintenance program and Section D, frequency of testing and maintenance, in GL 89-13, Supplement 1, and the staffs evaluation will be documented in the SER.

In Table 3.2.2-7, Standby Gas Treatment System (SGTS), the Piping Corrosion Program is credited for managing the aging effect of loss of material for loop seal piping and valve bodies.

However, a review of the AMP evaluation results document, LRPD-05, Attachment 2.11, Section 2.1.b, indicates that SGTS is not included in the scope of the Piping Corrosion Program.

The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff noted that the current scope of program program element, as described in the LRA, does not include commitments for two GL 89-13 guidelines incorporated in the GALL Report AMP XI.M20. The specific components of the GL 89-13 program missing from the Piping Corrosion Program are a system walkdown inspection to ensure compliance with the CLB and a review of maintenance, operating, and training practices and procedures. The staff will consider issuing an RAI requesting the applicant to justify why this not an exception to the GALL Report AMP, and the staffs evaluation will be documented in the SER.

In a response to GL 89-13, SSES took an exception to heat transfer capability testing. The GALL Report AMP XI.M20, in the parameters monitored/inspected element, recommends testing to ensure heat transfer capabilities. In the LRA Section B.2.13, SSES has not taken an exception to this program element. The staff will consider issuing an 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 the operating experience element of Section B.2.13, the LRA states that SSES has programs in place with operating experience to demonstrate that the effects of aging on the service water systems, and on the safety-related heat exchangers that they serve, will be effectively managed during the period of extended operation. The staff will consider issuing an RAI requesting the applicant to provide some specific examples of issues that were found in the condition reports, 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 the GALL Report AMP XI.M20, 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.

SSES AMP B.2.14, Closed- Cycle Cooling Water Chemistry Program In the LRA, the applicant states that SESS AMP B.2.14 is an existing program and is consistent with the GALL Report AMP XI.M21, Closed-Cycle Cooling with exceptions. The exceptions to the GALL Report AMP XI.M21 were not reviewed during this audit, but a review of the exceptions will be performed at NRC Headquarters.

During the onsite audit, the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Results Rev. 2, 11/30/2007

2. MRA-819761 Action Fact Sheets 07/17/2007

3. NSEI-AD-420 Susquehanna Chemistry Manual (Chapter 7) Rev. 3, 12/16/1997 Closed Cooling Oil Systems

4. NDAP-QA-0630 Conduct of Chemistry Rev. 6, 6/5/2007

5. NDAP-QA-1195 Chemistry Program Rev. 4, 3/16/2007 During the review of the operating experience program element of AMP B.2.14, Closed Cooling Water Chemistry Program states, the staff noted that SSES had some operating experience in relation to diesel jacket water corrosion/microbiological control. The staff also noted that certain corrective actions were taken by SSES as described in LRA Section B.2.14. However the staff felt that SSES needed to clarify the specifics of the corrective actions that were taken with respect to the addition of biocide control compounds or corrosion inhibitors and if any supplemental inspections will be performed to confirm the effectiveness of addition of biocide control compounds or corrosion inhibitors. The staff will consider issuing an RAI to address this discrepancy, and the staffs evaluation will be documented in the SER. The staff also reviewed 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.

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 the GALL Report AMP XI.M21, except for the areas that the applicant took exceptions to the GALL Report AMP XI.M21 and the areas in which the staff felt additional clarification was warranted as described above.

LRA AMP B.2.15, Crane Inspection Program In the LRA, the applicant stated that SSES AMP B.2.15 is an existing program that is consistent with the GALL Report AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems.

During its audit, the staff reviewed the applicants onsite documentation to support its conclusion that the AMP elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Crane Inspection Program Rev. 1, 07/24/2006 Attachment 3.2

2. PPL Proc NDAP- Crane, Hoist and Rigging Program Rev. 9, 02/26/2008 QA-0505

3. PPL Proc MT-GM- Crane and Installed Hoist Mechanical Inspection Rev. 9, 06/05/2007 013

4. PPL Proc MT-181- Refueling Platform Mechanical Inspection and Testing Rev. 6, 07/13/2006 003 (Pre Outage)

5. PPL Proc MT-281- Refueling Platform Mechanical Inspection and Testing Rev. 3, 08/29/2003 003 (Pre Outage)

6. PPL Proc ON-000- Natural Phenomena Rev.18, 02/22/2008 002

7. U1 and U2 TRO SSES Technical Requirements Manual, Units 1 and 2, 02/05/1999 3.12.1, 3.12.2, and Section 3.12 Loads Control Program 3.12.3 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in SSES AMP B.2.15 are consistent with the GALL Report AMP XI.M23 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL Report AMP XI.M23.

The staff also verified that the applicant provided an adequate summary description of the program.

The staff found that SSES did not explicitly identify the effects of wear on the rails in the rail system in their basis document for the GALL Report program element, Scope of Program.

The lack of identification in their basis document brings into question whether this item should have been identified as an exception. Additionally, the staff found that SSES did not explicitly identify wear in their basis document for the GALL Report program element, Acceptance Criteria. The lack of identification in their basis document brings into question whether this item should have been identified as an exception. The staff will consider issuing RAIs to address these issues, and the staffs evaluation will be documented in the SER.

The staff also reviewed 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 2007, a crack was found in a structural, load bearing weld. This incident was not reported in the LRA operating experience summary. More information is needed to assess the severity of the incident. 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 the GALL Report AMP XI.M23, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.16, Fire Protection Program In the LRA, the applicant stated that AMP B2.16 is an existing program that is consistent with GALL AMP XI.M26, Fire Protection, with an exception.

During its audit the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05, Att. 2.7.a AMP Evaluation Results - Fire Protection Rev.1, 08/30/2007 Program

2. TRM/3.7.3.3 Technical Requirements Manual, Fire 08/02/1999 Protection - CO2 System

3. TRM/3.7.3.4 Technical Requirements Manual, Fire 03/31/2006 Protection - Halon System

4. CR 1015794 Fire door will not close 04/14/2008

5. CR 990573 Fire door closure mechanism issue 03/11/2008

6. SE-013-006 18-month CO2 system functional test Rev. 10

7. SE 113/213-006 24-month inspection of Unit 1/2 fire rated Rev. 4 penetration seals The applicant took an exception that the Halon/carbon dioxide (CO2) suppression systems and the fuel oil supply line for the diesel-driven fire pump, inspections and tests included in the Fire Protection Program (and addressed in the Technical Requirements Manual) are not credited with aging management but do provide for periodic observation of the related components.

While Halon/CO2 and fuel supply line internal conditions are not directly inspected or evaluated during these tests and inspections, they do provide indirect confirmation of whether degradation has occurred, prior to a loss of function.

The staff will consider issuing an RAI requesting the applicant to justify why these tests and inspections, if required, are not credited for license renewal, 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 the GALL Report 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 B2.17, Fire Water System Program In the LRA, the applicant stated that AMP B2.17 is an existing program that, following enhancements, will be consistent with the GALL Report AMP XI.M27, Fire Water System.

During its audit the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Rev. 3, 04/29/2008 Results

2. LRPD-05, Att. 2.7b Aging Management Program Evaluation Rev. 2, 02/21/2008 Results - Fire Water System Program

3. TRM, Section 3.7.3 Technical Requirements Manual, - Fire Protection

4. CR 912388 12 FP pipe is leaking 10/20/2007

5. CR 657958 14 FP pipe is leaking 03/17/2005

6. CR 592368 16 FP pipe is leaking 07/12/2004

7. CR 233774 Through wall leak in piping header 06/14/2000 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 detection of aging effects, monitoring and trending, and acceptance criteria to require testing or replacement of sprinkler heads in service for 50 years.

2) Added a program requirement in the parameters monitored or inspected and detection of aging effects element to perform ultrasonic testing of representative portions of above ground fire protection piping that are exposed to water but do not normally experience flow.

The LRA credits the Fire Water System Program for managing loss of material for valve bodies (deluge) in the Standby Gas Treatment System. However, the STGS is not included in the list of systems in the scope of this program, as identified in the Aging Management Program Evaluation Results for this program. The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

LRA Table 3.3.2-13 credits the Fire Water System program to manage reduction in heat transfer for heat exchanger tubes. However, the LRA Section B.2.17 states that this program is consistent with the GALL Report AMP XI.M27, which focuses on managing the aging effect of loss of material and not reduction in heat transfer. The staff will consider issuing an RAI requesting the applicant to justify how this program will manage reduction in heat transfer, 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 the operating experience element of LRA Section B.2.17, the LRA states that a search of condition reports was performed for the Fire Protection System. When conditions were found that required correction they were repaired in accordance with the site corrective action program. The staff will consider issuing an RAI requesting the applicant provide some specific examples of issues that were found in the condition reports, and the staffs evaluation will be documented in the SER.

The staff reviewed some condition reports as part of the operating experience review and found that several CRs were written to address through wall leaks in fire water headers in the Circ water pumphouse area. Stagnant water in low drainage locations inside the pump was determined to be the cause. 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 the GALL Report AMP XI.M27, except for the areas in which the staff needed additional clarification as described above.

SSES AMP B.2.19, Condensate and Refueling Water Storage Tanks Inspection In the LRA, the applicant states that the AMP B.2.19 is a new program and is consistent with the GALL Report AMP XI.M29, Aboveground Steel Tanks in conjunction with the System Walkdown Program.

During the onsite audit, the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP in conjunction with the System Walkdown Program. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Number Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Results Rev. 3

2. LRPD-05 Attachment Aging Management Program Evaluation Results - Rev. 1 2.4 Condensate and Refueling Water Storage Tanks Inspection

3. LRPD-05 Attachment Aging Management Program Evaluation Results - System Rev. 2 2.15 Walkdown Program

4. Specifications - C-27 Technical Specification for Field Erected Steel Tanks Rev. 5

5. Specifications - A-48 Technical Specification for Subcontract for Protective Rev. 6 Coatings for Field Erected Steel Tanks

6. Condensate and Refueling Water Storage Tanks 01/11/2008 Inspection Outline In comparing the elements in the applicants program to the GALL Report program, the staff noted that several program elements (program element #1, 3, 4, 5 and 6) refer to the Systems Walkdown Program (B.2.32), in order to claim that the Condensate and Refueling Water Storage Tanks Inspection is consistent with the GALL Report. The staff confirmed that the boundary conditions of the plant program envelopes the boundary conditions described in the GALL Report AMP. The staff also verified that the applicant provided an adequate summary description of the program. In comparing the elements in the applicants program, the staff verified that the program elements contained in SSES AMP B.2.19 are consistent with the GALL Report AMP XI.M29 program elements except for the areas that the staff needed additional information as discussed below.

The staff verified that the refueling water and condensate transfer and storage systems are in the scope of the Systems Walkdown Program. The GALL Report recommends visual inspections of paints/coatings and sealants/caulking for the external surfaces of the tanks for which the applicant credits the Systems Walkdown Program for these visual inspections. While comparing the GALL Report program element #1, the staff noted that paints/coatings and sealants/caulkings were not included as part of the scope for visual inspections in the Systems Walkdown Program. The staff will consider issuing an RAI to address this discrepancy, and the staffs evaluation will be documented in the SER. While comparing element #6, the staff found that the GALL Report states that any degradation must be reported and further evaluated. But the applicants program states that corrective actions are taken when there is an unacceptable loss of material. It is unclear what the criteria or threshold is for the component when there is an unacceptable loss of material. The staff will consider issuing an RAI to address this discrepancy, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience for this program. The applicant stated that operating experience specific to this program is not available because it is a new program. A generic RAI will be issued concerning a commitment to submit the operating experience for the program when it becomes available. However the applicant did review their condition report database from ~2000 to mid-2007. The staff did not identify any condition reports that revealed instances of degradation of the Condensate Storage and Refueling Water Storage tank bottoms. The staff audited the operating experience from the Systems Walkdown Program (B.2.32) for any condition reports related to the degradation of the protective coating or the tank bottoms of the Condensate and Refueling Water Storage Tanks. The staff did not identify any condition reports related to the Condensate Storage and Refueling Water Storage Tanks.

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 the GALL Report AMP XI.M29, except for the areas in which the staff felt additional clarification was warranted as described above.

LRA AMP B.2.20, Fuel Oil Chemistry Program In the LRA, the applicant stated that AMP B.2.20 is an existing SSES program that is consistent with the GALL Report AMP XI.M30, Fuel Oil Chemistry, with exceptions as described below.

During its audit, the staff reviewed the applicants onsite documentation to determine whether those program elements claimed to be consistent with the GALL Report in the applicants AMP are consistent with the program elements recommended in the GALL Report AMP XI.M30. The staff auditor interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Results Revision 3 04/29/2008

2. LRPD-05, Aging Management Program Evaluation Results - Revision 2 Attachment 2.3c Fuel Oil Chemistry Program 09/29/2006

3. LRPD-04 Operating Experience Review Results and Summary Revision 2 11/11/2006

4. NAPD-QA-0630 Conduct of Chemistry Revision 6 06/05/2007

5. NAPD-QA-0633 Diesel Fuel Oil Testing Program Revision 0 06/18/2000

6. CH-CC-046 Water and Sediment in Oil Revision 9 03/23/1999

7. CH-CC-062 Determination of Microorganisms in Oil Revision 4 11/20/2002

8. CH-CC-077 Clear and Bright Test for Diesel Fuel Oil Revision 1 03/14/2007

9. CH-CC-088 Diesel Fuel Oil Particulate Contaminant Test Revision 1 03/12/1999

10. CH-SY-012 Diesel Fuel Oil Biocide Addition Revision 5 05/30/2007

11. CH-TP-025 Diesel Fuel Oil Sampling Revision 9 04/21/2005

12. SA # A83521 Completed Surveillance - 10 Year Diesel Fuel Oil Storage Completion Date Cleaning 12/28/1998

13. PCWO 227843 Completed Preventive Maintenance -- E Diesel Fuel Oil Day Completion Date CR 207132 Tank Cleaning 10/11/2000

14. SC-013-001 Quarterly Fire Pump Diesel Fuel Oil Storage Tank - Revision 6 Viscosity, Water, and Sediment 05/13/2004

15. Spec. H-1015 Procurement of Diesel Fuel Oil for Emergency Diesel Revision 3 Generators 08/20/1998 In the LRA the applicant identified the following exceptions to the Fuel Oil Chemistry AMP as described in the GALL Report,Section XI.M30:

Scope of Program: Although largely focused on fuel oil tanks, the SSES Fuel Oil Chemistry Program is also applicable to other components exposed to fuel oil, including the fuel oil supply components for the diesel engine-driven fire pumps.

Parameters Monitored/Inspected: With respect to modified ASTM D2276 for particulate determinations, 0.8 micron membrane filters recommended for aviation fuels are used at SSES, but the required volume is decreased in order to increase the range of accuracy.

Monitoring and Trending: An annual frequency for sampling of fuel for biological activity is used for SSES, along with monthly or quarterly sampling for other contaminants.

In comparing the 7 elements in the applicants program to those in the GALL Report AMP XI.M30, the staff reviewer noted that the program elements claimed to be consistent with the GALL Report in the applicants AMP are consistent with the corresponding program element criteria recommended in the GALL Report AMP XI.M30, except for the exceptions taken against the scope of program, the parameters monitored/inspected, and the monitoring and trending elements as described above. The staff, requested the applicant provide additional information further explaining or justifying the exception to the monitoring and trending program element of the GALL Report program. The staffs evaluation will be documented in the SER.

In the operating experience element of LRA Section B.2.20, the applicant states that review of SSES operating experience did not reveal a loss of component function or fouling of subject components that contain fuel oil which could be attributed to an inadequacy of the Fuel Oil Chemistry Program. The applicant states that fuel oil delivered to the site is sampled and analyzed prior to addition to fuel oil storage tanks and periodically thereafter and that water and sediment is removed, particulates are filtered, and biological activity is controlled. The staff reviewed selected procedures and completed work packages related to periodic fuel oil chemistry testing and preventive maintenance on components in the fuel oil storage system.

The staff noted that the onsite documentation supports the applicants statements with regard to operating experience for the Fuel Oil Chemistry Program and that the applicants operating experience does not reveal any aging related degradation not bounded by industry experience.

The staffs review of the applicants onsite documentation did not identify any differences between the program described in the onsite documents and the applicants claim of consistency with the GALL Report AMP XI.M30, with the exceptions as identified in the LRA.

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 the GALL Report AMP XI.M30, 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.2.22, Chemistry Program Effectiveness Inspection In the LRA, the applicant stated that AMP B.2.22 is a new one-time inspection that will be consistent with the GALL Report AMP XI.M32, One-Time Inspection. The applicant did not identify any exceptions to the GALL Report nor enhancements required in an existing program.

During its audit, the staff reviewed the applicants onsite documentation to determine whether those program elements claimed as consistent with the GALL Report in the applicants AMP are consistent with the program elements recommended in the GALL Report AMP XI.M32. The staff auditor interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Results Revision 3 04/29/2008

2. LRPD-05, Aging Management Program Evaluation Results - Revision 2 Attachment 2.3d Chemistry Program Effectiveness Inspection 12/12/2007

3. LRPD-04 Operating Experience Review Results and Summary Revision 2 11/11/2006

4. Aging Management Program Outline for Chemistry Program 12/12/2007 Effectiveness Inspection In comparing the 7 elements in the applicants program with the description of each element in the GALL Report AMP XI.M32, the staff noted that the applicants descriptions of this new program, as presented in the LRA and in onsite documentation, are consistent with the elements of the AMP as described in the GALL Report. The staff also noted that the applicants program documentation makes reference to future engineering evaluations to determine location and sample sizes of components selected for inspection. The staff will prepare an RAI asking the applicant to provide a more detailed description of the methodology to be used for determining sample sizes and locations of components selected for one-time inspection. The staffs evaluation will be documented in the SER.

In the acceptance criteria program element of LRA Section B.2.22, the applicant states that the acceptance criteria will be no unacceptable loss of material or cracking of stainless steel exposed to temperatures above 140 F that could result in a loss of component intended function during the period of extended operation, as determined by engineering evaluation. The staff will prepare an RAI asking the applicant to explain why the acceptance criterion in AMP B.2.22 is different from the GALL Reports recommendation and to clarify what no unacceptable loss of material or cracking means. The staffs evaluation will be documented in the SER.

In the operating experience program element of LRA Section B.2.22, the applicant states that the Chemistry Program Effectiveness Inspection program is a new one-time inspection activity for which there is no operating experience and inspection methods are to be consistent with accepted industry practices. The staff will issue a generic RAI asking the applicant to commit to providing an operating experience summary in the future for each new program to confirm the programs effectiveness.

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 the GALL Report AMP XI.M22, except for the issues addressed by the RAIs in which the staff needs additional clarification.

LRA AMP B2.23, Cooling Unit Inspection In the LRA, the applicant stated that AMP B2.23 is a new one-time inspection that will be consistent with the GALL Report AMP XI.M32, One-Time Inspection.

During its audit the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date Rev. 3,

1. LRPD-05 Aging Management Program Evaluation Results 04/29/2008 Aging Management Program Evaluation Results - Cooling Units Rev. 1,

2. LRPD-05, Att. 2.5 Inspection 07/26/2006

3. Aging Management Program Outline for Cooling Units Inspection 12/19/2007 In the scope of program element, the LRA states that this program detects loss of material due to crevice and pitting corrosion and selective leaching of the copper alloy cooler channel in the CS HVAC system. Selective leaching generally does not cause changes in dimensions and is difficult to detect. The examination techniques used by this program to detect degradation is visual and/or volumetric. Neither one of these techniques by itself will detect selective leaching.

The staff will consider issuing an RAI requesting the applicant justify how this program will manage selective leaching and explain why these components are not included in LRA Section B.2.29, Selective Leaching Program, and the staffs evaluation will be documented in the SER.

In the GALL Report AMP XI.M32, in the detection of aging effects element, different inspection methods are identified for monitoring specific aging mechanisms such as crevice corrosion, galvanic corrosion, etc. However, the LRA states generally that the program uses a combination of established volumetric or visual examination techniques. The staff will consider issuing an RAI requesting the applicant clarify which techniques will be used to detect the various aging mechanisms, and the staffs evaluation will be documented in the SER.

In the monitoring and trending element, the LRA states that no actions are taken as part of this program, since it is a one-time inspection activity. The staff will consider issuing an RAI to request the applicant confirm if the corrective action program will increase the sample size in the event aging effects are detected, and the staffs evaluation will be documented in the SER.

In the acceptance criteria element, the GALL Report AMP XI.M32 states that any indication or relevant conditions of degradation detected are evaluated. LRA Section B.2.23 states that no unacceptable loss of material (or wall thinning) or fouling of heat exchanger tubes and fins that could result in a loss of component intended function during the period of extended operation, as determined by engineering evaluation. The staff will consider issuing an RAI to request that the applicant explain why the acceptance criteria for B.2.23 differ from the recommendations of the GALL Report and clarify what no unacceptable loss of material (or wall thinning) or fouling means, and the staffs evaluation will be documented in the SER.

The operating experience element states that the Cooling Unit Inspection is a new program and there is no plant-specific program operating experience. Several condition reports have been generated during walkdowns, surveillance and maintenance activities on the cooling units that are included in the scope of this program. The staff will consider issuing an RAI to request the applicant identify any age related degradation documented for these cooling units, 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 the GALL Report AMP XI.M32, except for the areas described above, in which the staff needs additional clarification.

LRA AMP B2.24, Heat Exchanger Inspection In the LRA, the applicant stated that AMP B2.24 is a new one-time inspection that will be consistent with the GALL Report AMP XI.M32, One-Time Inspection.

During its audit the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date Rev. 3,

1. LRPD-05 Aging Management Program Evaluation Results 04/29/2008

2. LRPD-05, Att. Aging Management Program Evaluation Results - Heat Rev. 1, 2.9 Exchanger Inspection 07/26/2006 Aging Management Program Outline for Heat Exchanger

3. Inspection 12/12/2007 The operating experience element states that the Heat Exchanger Inspection is a new program and there is no plant-specific program operating experience. However, during performance of surveillance tests or preventive maintenance any degradation of tubes observed would have been documented. The staff will consider issuing an RAI requesting the applicant identify examples of issues that may have been documented to address age-related degradation of the heat exchanger tubes within the scope of this program, 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 the GALL Report AMP XI.M32, except for the areas described above, in which the staff needs additional clarification.

LRA AMP B.2.25, Lubrication Oil Inspection In the LRA, the applicant states that the AMP B.2.25 is a new program and is consistent with the GALL Report AMP XI.M32, One-Time Inspection.

During the onsite audit, the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Result Rev. 2, 01/09/2008

2. MRA-819764 Action Fact Sheets 01/02/2008

3. Journal Search Utility

4. Aging Management Program (AMP) Outline For 12/12/2007 Lubricating Oil Inspection

5. NIMS WMX-ARCRFS Condition Report Fact Sheets 01/02/2008 In comparing the elements in the applicants program, the staff verified that the program elements contained in the AMP B.2.25 are consistent with the GALL Report AMP XI.M32 program elements except for the areas that the staff needed additional information as discussed below. The staff confirmed that the boundary conditions of the plant program envelopes the boundary conditions described in the GALL Report AMP. The staff also verified that the applicant provided an adequate summary description of the program. During the audit, the staff noted that SSES credits AMP B2.25 Lubricating Oil Inspection and AMP B 2.33 Lubricating Oil Analysis Program as two of the AMPs for managing the aging effects in plant systems that are exposed to lubricating oil, including components in the Emergency Diesel Generator System, Control Structures Chilled Water System, Residual Closed Cooling Water System, and High Pressure Coolant Injection System. The staff asked SSES to identify whether there are any other systems that are within the scope of license renewal and are exposed to lubricating oil. The staff will consider issuing an RAI to address this discrepancy, and the staffs evaluation will be documented in the SER.

The staff also audited the operating experience for this program. The applicant stated that operating experience specific to this program is not available because it is a new program. A generic RAI will be issued concerning a commitment to submit the operating experience for the program when it becomes available.

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 the GALL Report AMP XI.M32, except for the areas described above in which the staff needs additional clarification.

LRA AMP B2.26, Main Steam Flow Restrictor Inspection In the LRA, the applicant stated that AMP B2.26 is a new one-time inspection that will be consistent with the GALL Report AMP XI.M32, One-Time Inspection.

During its audit the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date Rev. 3,

1. LRPD-05 Aging Management Program Evaluation Results 04/29/2008

2. LRPD-05, Att. Aging Management Program Evaluation Results - Main Steam Rev. 1, 1.13 Flow Restrictor Inspection 07/31/2006 Aging Management Program Outline for Main Steam Flow

3. Restrictor Inspection 01/16/2008 In GALL Report AMP XI.M32 detection of aging effects element, several inspection methods are identified for monitoring specific aging mechanisms such as crevice corrosion, galvanic corrosion, etc. However, the LRA states generally that the program uses established visual examination techniques. The staff will consider issuing an RAI requesting the applicant clarify which visual technique will be used to detect reduction of fracture toughness as evidenced by cracking, and the staffs evaluation will be documented in the SER.

Acceptance criteria states that no cracking that could result in a loss of component intended function(s) during the period of extended operation be present, as determined by engineering evaluation. The staff will consider issuing an RAI requesting the applicant confirm if the CASS main stream flow restrictors were screened for thermal aging and whether they are susceptible, and the staffs evaluation will be documented in the SER.

In the detection of aging effects element, the LRA states that the Steam Flow Restrictor Inspection will be applied to all eight (four per unit) main steam flow restrictors at SSES. The staff will consider issuing an RAI requesting the applicant clarify if this means that all eight flow restrictors will be inspected, and the staffs evaluation will be documented in the SER.

The operating experience element states that the Main Steam Flow Restrictor Inspection is a new program and there is no plant-specific program operating experience. However, the applicant did perform a search of their operating experience and did not identify any operating experience relating to reduction of heat transfer in the CASS portions of the main steam line flow restrictors.

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 the GALL Report AMP XI.M32, except for the areas described above in which the staff needs additional clarification.

LRA AMP B2.27, Monitoring and Collection System Inspection In the LRA, the applicant stated that AMP B2.27 is a new one-time inspection that will be consistent with the GALL Report AMP XI.M32, One-Time Inspection.

During its audit, the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Results Rev. 3, 04/29/2008

2. LRPD-05, Att. Aging Management Program Evaluation Results - Monitoring 2.10 and Collection System Inspection Rev. 1, 07/26/2006 Aging Management Program Outline for Monitoring and

3. collection System Inspection 01/09/2008 The GALL Report AMP XI.M32, in the detection of aging effects element, different inspection methods are identified for monitoring specific aging mechanisms such as crevice corrosion, general corrosion, etc. However, the LRA states generally that the program uses a combination of established volumetric or visual examination techniques. The staff will consider issuing an RAI requesting the applicant clarify which techniques will be used to detect the various aging mechanisms, and the staffs evaluation will be documented in the SER.

In the monitoring and trending element, the LRA states that no actions are taken as part of this program since it is a one-time inspection activity. The staff will consider issuing an RAI to request the applicant to confirm if the corrective action program will increase the sample size in the event aging effects are detected, and the staffs evaluation will be documented in the SER.

In the acceptance criteria element, the GALL Report AMP XI.M32 states that any indication or relevant conditions of degradation detected are evaluated. The LRA Section B.2.27 states that no unacceptable loss of material (or wall thinning) that could result in a loss of component intended function during the period of extended operation be present, as determined by engineering evaluation. The staff will consider issuing an RAI to request the applicant explain why the acceptance criteria for B.2.27 differ from the recommendations of the GALL Report and clarify what no unacceptable loss of material (or wall thinning) or fouling means, and the staffs evaluation will be documented in the SER.

The operating experience element states that the Heat Exchanger Inspection is a new program and there is no plant-specific program operating experience. However, the applicant performed a search of the plant operating experience database for any age related degradation in the liquid radwaste system and did not find any entries.

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 the GALL Report AMP XI.M32, except for the areas described above in which the staff needs additional clarification.

LRA AMP B2.28, Supplementary Piping/Tank Inspection In the LRA, the applicant stated that AMP B2.28 is a new one-time inspection that will be consistent with the GALL Report AMP XI.M32, One-Time Inspection.

During its audit the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date Rev. 3,

1. LRPD-05 Aging Management Program Evaluation Results 04/29/2008

2. LRPD-05, Att. Aging Management Program Evaluation Results - Supplemental Rev. 0, 2.14 Piping/Tanks Inspection 02/10/2006 Aging Management Program Outline for Supplemental Piping/Tank

3. Inspection 12/12/2007 In Table 3.2.2-9, diesel generator starting air system, the Supplemental Piping/Tank Inspection Program is credited for managing the aging effect of loss of material for stainless steel drain trap bodies and carbon steel moisture separators. However, a review of the AMP Evaluation Results Document indicates that diesel generator starting air system is not included in the scope of the Supplemental Piping/Tank Inspection Program. The staff will consider issuing an RAI requesting the applicant justify why it is not included, and the staffs evaluation will be documented in the SER.

The GALL Report AMP XI.M32, in the detection of aging effects element, different inspection methods are identified for monitoring specific aging mechanisms such as crevice corrosion, galvanic corrosion, etc. However, the LRA states generally that the program uses a combination of established volumetric or visual examination techniques. The staff will consider issuing an RAI requesting the applicant clarify which techniques will be used to detect the various aging mechanisms, and the staffs evaluation will be documented in the SER.

In the monitoring and trending element, the LRA states that no actions are taken as part of this program, since it is a one-time inspection activity. The staff will consider issuing an RAI to request the applicant confirm if the corrective action program will increase the sample size in the event aging effects are detected, and the staffs evaluation will be documented in the SER.

In the acceptance criteria element, the GALL Report AMP XI.M32 states that any indication or relevant conditions of detected degradation be evaluated. The LRA Section B.2.28 states that no unacceptable loss of material (or wall thinning) that could result in a loss of component intended function during the period of extended operation be present, as determined by engineering evaluation. The staff will consider issuing an RAI to request the applicant explain why the acceptance criteria for B.2.23 differ from the recommendations of the GALL Report and clarify what no unacceptable loss of material (or wall thinning) or fouling means, and the staffs evaluation will be documented in the SER.

The operating experience element states that the Supplementary Piping/Tank Inspection is a new program and there is no plant-specific program operating experience. However, the applicant has reviewed the SSES condition reports and could identify no instances of loss of material due to alternate wetting and drying at SSES over the last seven years.

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 the GALL Report AMP XI.M32, except for the areas described above in which the staff needs additional clarification.

LRA AMP B.2.29, Selective Leaching Inspection Program In the LRA, the applicant stated that AMP B.2.29 is a new program that, when implemented, will be consistent with the GALL Report AMP XI.M33, Selective Leaching of Materials.

During the audit the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Aging Management Program Revision 3 04/29/2008 Evaluation Results

2. MRA 819474 License Renewal Commitment - 01/14/2007 Selective Leaching Inspection For the operating experience element, the applicant states that the Selective Leaching Inspection Program is a new one-time inspection activity for which there is no operating experience that indicates the need for an aging management program. The applicant stated that because of plant design considerations, there is potential for degradation of installed components through the application of materials suitable for the expected operation environments. The applicant conducted a search for operating experience using the keywords leaching or leached and did not identify any degradation due to selective leaching in the 5 year period searched.

The SRP-LR states in A.1.2.3.10, Operating experience, paragraph 2. An applicant may have to commit to providing operating experience in the future for new programs to confirm their effectiveness. The staff is preparing a generic RAI for all of the new AMPs to address this issue of whether the applicant is going to commit to providing operating experience in the future for new programs including this one.

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 the GALL Report AMP XI.M33, except for the issues addressed by the aforementioned RAIs in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.30, Buried Piping and Tank Inspections In the LRA, the applicant stated that AMPB.2.30 is a new program that when implemented, will be consistent with the GALL Report AMP XI.M34, Buried Piping and Tanks Inspection, with exceptions as follows:

Scope - In addition to steel (as well as cast iron) piping components and steel tanks, the scope of the program includes stainless steel piping components.

Preventive Actions - The buried fire protection piping components and the buried stainless steel piping components in the Condensate Transfer and Storage System are not provided with any special coatings or wrappings in accordance with plant design specifications and consistent with plant operating experience.

Document Title Revision /

Date

1. SSES Specification H-1019 Nuclear Engineering Specification for the Inspection Revision 2 Program for Pipe Corrosion and Degradation

2. SSES Specification N-199 Piping Class Sheets. Line Index and Standards for Revision 66 the SSES Units 1 & 2

3. SSES FSAR Section 9.2.5 ESW System Revision 61

4. SSES FSAR Section 9.2.6 RHR Service Water System Revision 61

5. SSES FSAR Section 9.5.4 Diesel Generator Fuel Oil Storage and Revision 61 Transfer System

6. SSES Specification M-208 External Surface Treatment of Underground Revision 2 Steel Pipe

7. SSES Specification M1001 External Surface Treatment of Underground Revision 1 Steel Pipe

8. SSES Drawing C-38 Underground Yard Piping FPS Steel Pipe, Revision 20 sheet 1

9. SSES Drawing C-38 Underground Yard Piping, FPS sheet 2 Revision 4

10. SSES Specification C-31 Furnishing and Delivery of Utility Pipe and Revision 1 Fittings

11. Calculation EC-054-1021 Study to Determine NDE Methods Best Revision 0 Suited for Inspection of Buried Underground Piping Systems, Primarily ESW

12. SSES Fire Protection Report (FPRR) Revision 15

13. SSES Design Basis Document DBD013, Diesel Revision 3 Generators and Auxiliaries

14. SSES Specification C-1034 Structural Excavation Revision 3

15. SSES Procedure Structural Excavation Reviews Revision 0 NSEI-AD-415

16. NFPA-24 Standard for the Installation of Private Fire 2002 Edition Service Mains and their Appurtenances The condensate transfer and storage system contains stainless steel piping coming from the condensate storage tank (20 HCB-1) into the Reactor Building. The Fire Protection System contains ductile iron piping (cement-lined yard loop), cast iron piping (fire hydrant barrels) and grey cast iron valve bodies.

Diesel fuel oil storage tanks are located in concrete vaults that are sealed and filled with structural backfill consisting of a mixture of sand, cement, and fly ash. The applicant considers the environment to be controlled with respect to groundwater intrusion and soil conditions.

Buried piping in the Fire Protection System is constructed using cast iron and ductile iron. It is not coated per the plant design specifications. The staff is not convinced that there is a solid basis for not coating this buried pipe and has prepared an RAI to investigate this staff concern.

The LRA states that the Fire Protection System piping will be inspected as part of the Selective Leaching Inspection Program. However, the Buried Piping and Tanks Inspection Program includes no mention of this. The evaluation of this RAI will be provided in the SER.

The operating experience element states that the Buried Piping and Tanks Inspection Program is a new program and there is no plant-specific program operating experience. The applicant reviewed plant-specific operating experience and did not find any records of leakage due to degradation of the exterior surfaces of buried components.

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 the GALL Report 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.2.31, Small Bore Class 1 Piping Inspection In the LRA, the applicant stated that AMP B.2.31 is a new one-time inspection that will be consistent with the GALL Report AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping. The applicant did not identify any exceptions to the GALL Report nor enhancements required in an existing program.

During its audit, the staff reviewed the applicants onsite documentation to determine whether those program elements claimed to be consistent with the GALL Report in the applicants AMP are consistent with the program elements recommended in the GALL Report AMP XI.M35. The staff interviewed the applicants technical staff and reviewed the following onsite documents.

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Results Revision 3 04/29/2008

2. LRPD-05, Aging Management Program Evaluation Results - Revision 2 Attachment 1.12 Small Bore Class 1 Piping Inspection 04/23/2008

3. LRPD-04 Operating Experience Review Results and Summary Revision 2 11/11/2006

4. Aging Management Program Outline for Small Bore Class 1 04/30/2008 Piping Inspection

5. NEPM-QA-1160 Nuclear Design Engineering Inservice Inspection Program Revision 5 10/24/2006

6. NDAP-QA-1608 Inservice Inspection (ISI) Revision 10 06/01/2007

7. CR 659286 Condition Report 659286 - Leakage for HV243F031B as a 03/20/2005 Result of Vessel Leak Check

8. CRA 595279 Condition Assessment Report 595279 Fact Sheet: Assessment Date:

Assessment of Socket Weld Fatigue Life Initiatives 05/19/2006

9. EWR 778401 U2-13RIO/U1-15RIO AUG 8 - 05/15/2006 -

Augmented Socket Weld Inspections 06/01/2006

10. CRA 595330 Small Pipe Socket Weld Indications in Drywell during the U1- 09/17/2004 13RIO In comparing the 7 elements in the applicants program with the description of each element in the GALL Report AMP XI.M35, the staff noted that both the applicants description of its program in the LRA and the applicants onsite documentation support a conclusion that the applicants proposed program includes the recommendations of the GALL Report AMP XI.M35.

However, the applicants proposed program also includes additional features that are not encompassed by the program elements of AMP XI.M35 as described in the GALL Report.

Further review by the staff determined that the applicants proposed AMP for ASME Code Class 1 Small Bore Piping combines elements of the GALL Report AMP XI.M35 for managing the aging effect of cracking and with elements of the GALL Report AMP XI.M32, One-Time Inspection, for managing the aging effect of loss of material in ASME Class 1 Small Bore Piping and related components. The staff prepared two RAIs asking the applicant to provide additional information about its proposed program. The staff will ask the applicant in an RAI to explain or clarify its basis for classifying its proposed program as consistent with the GALL Report AMP XI.M35. The staff will ask the applicant in an RAI to clarify the selection process to be used to ensure that appropriate locations are selected and monitored for both aging effects (cracking and loss of material) managed by its proposed program. The staff noted in the description of program element monitoring and trending, that the applicant states that information in NRC Information Notice (IN) 97-46, Unisolable Crack in High Pressure Injection Piping, will be a basis for selecting inspection locations. Since IN 97-46 is more directly applicable to PWRs than to BWRs, the staff prepared an RAI asking the applicant to clarify how IN 97-46 will be used as a basis to select appropriate locations for ASME Class 1 small bore piping inspections. The staffs evaluation will be documented in the SER.

In the operating experience program element of LRA Section B.2.31 the applicant states that the Small Bore Class 1 Piping Inspection is a new program for which there is no plant-specific operating experience. However, in its review of onsite documentation provided by the applicant, the staff noted that the applicant has found cracking in several small-bore ASME Class 1 pipe socket welds associated with the recirculation system. The staff asked the applicant why the small-bore piping failures and related assessment activities and corrective actions are not considered to be applicable operating experience relevant to the GALL Report AMP XI.M35. In response to this question, the applicant stated that the small bore piping failures at SSES were related to piping vibrations and high-cycle fatigue, rather than to the more slow-acting aging effects of cracking due to stress corrosion or thermal and mechanical loading that are the focuses of the GALL Report AMP XI.M35. The staff prepared an RAI asking the applicant to provide an enhanced discussion of its small-bore piping failures, assessment activities and corrective actions taken. 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 the GALL Report AMP XI.M35, except for the issues described above in which the staff needs additional clarification.

SSES AMP B.2.32, System Walk down Program In the LRA, the applicant states that AMP B.2.32 is an existing program and is consistent with the GALL Report AMP XI.M36, External Surfaces Monitoring with enhancements.

During the onsite audit, the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Results Rev 2, 11/19/2007

2. MRA-81978 Action Fact Sheets

3. NSEP-AD-0002 Station Health Reporting Process Rev 2, 11/19/2007

4. LRBV-MAMR-014A Listing of CRs for Years 2000-2007

5. Form NTP-QA-65.9B Task Qualification Card, Perform System, Program Rev 0 09/2003 and Component Monitoring In comparing the elements in the applicants program, the staff verified that the program elements contained in the AMP B.2.32 are consistent with the GALL Report AMP XI.M36 program elements except for the areas that the staff needed additional information as discussed below. The staff confirmed that the boundary conditions of the plant program envelopes the boundary conditions described in the GALL Report AMP. The staff also verified that the applicant provided an adequate summary description of the program. During its review, the staff noted that SSES may change the frequency of inspections and the staff needed additional clarification. The staff asked SSES to identify the systems that are within the scope of the Systems Walkdown Program and that are subject to the change in inspection frequency. The staff also asked SSES to clarify the current inspection frequency for systems in the scope of the program and SSESs basis and process for changing the inspection frequency. The staff will consider issuing an RAI to address this discrepancy, and the staffs evaluation will be documented in the SER.

During its review, the staff noted that paints, coatings, sealants, and caulking were not included in the scope of materials to be monitored by the System Walkdown Program as stated in LRA Section B.2.19. The staff asked SSES to clarify whether these materials are in the scope of AMP B.2.32 and to clarify the inspection techniques that will be credited as monitoring for degradation of these materials. The staff will consider issuing an RAI to address this discrepancy, and the staffs evaluation will be documented in the SER.

In the program description, SSES credits this program to manage cracking and change in material properties for elastomers and polymers that are exposed to indoor air or ventilation environments. However this is not consistent with the recommendations in the GALL Report AMP XI.M36, External Surfaces Monitoring. The staff asked SSES to justify its basis for crediting this program with adequately managing the above aging effects that may occur in the external surfaces of in-scope components that are fabricated from elastomeric and/or polymeric materials. The staff further asked SSES to clarify how a visual examination of the external surfaces is capable of detecting the following aging effects: (1) a tightly configured crack that penetrates the external surface of the component, (2) a subsurface crack or a crack that only penetrates the internal surface of the materials, and (3) a change in a material property, such as a potential change in the hardness property or strength property for the elastomer or polymer material used to fabricate the component. The staff will consider issuing an RAI to address this discrepancy, and the staffs evaluation will be documented in the SER.

The staff also audited the 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. The staff noted that in LRA Section B.2.32 it states that a review of operating experience revealed that component leakage, damage, and/or degradation are routinely identified by the system walk downs, and that subsequent timely corrective actions were taken to correct these problems. The staff felt additional information was needed, and asked SSES to identify the plant systems that have had problems with age related degradation in the past, and identify the specific age-related degradation problems that have occurred in these systems. The staff further asked SSES to clarify if these age-related degradation issues have had any impact on the ability of the AMP to manage aging and whether the program will need to be augmented to ensure adequate management of aging in these systems and to identify the corrective actions that SSES has taken with respect to the issues identified by SSES. The staff will consider issuing an RAI to address this discrepancy, 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 the GALL Report AMP XI.M36, except for the areas described above in which the staff needs additional clarification.

SSES AMP B.2.33, Lubricating Oil Analysis Program In the LRA, the applicant states that the AMP B.2.33 is an existing program which is consistent with the GALL Report AMP XI.M39, Lubricating Oil Analysis with exceptions and enhancements. The exceptions to the GALL Report AMP XI.M39 were not reviewed during this audit, but will be reviewed at NRC Headquarters.

During the onsite audit, the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Results Rev. 2, 11/14/2007

2. MRA-819761 Action Fact Sheets

3. NSEI-AD-420 Predictive Maintenance (PdM) Process Rev. 0, 09/11/2003

4. Condition Reports

5. MPR-1399 Cooper Bessemer Model KSV Emergency Diesel Rev. 4 Generator Lube Oil, Jacket Water, Fuel Oil and Governor Oil Analyses Guidelines In comparing the elements in the applicants program, the staff verified that the program elements contained in the AMP B.2.33 are consistent with the GALL Report AMP XI.M39 program elements except for the areas that the staff needed additional information as discussed below. The staff confirmed that the boundary conditions of the plant program envelopes the boundary conditions described in the GALL Report AMP. The staff also verified that the applicant provided an adequate summary description of the program. The staff audited the enhancement provided in the LRA Section B.2.33 and did not feel additional information was needed. However, the staff is considering issuing an RAI to identify whether there were any additional plant systems that needed to be added within the scope of this program.

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.

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 the GALL Report AMP XI.M39, except for the areas that the applicant took exceptions to the GALL Report AMP XI.M39 and the areas in which the staff felt additional clarification was warranted as described above.

LRA AMP B.2.34, Inservice Inspection Program - IWE In the LRA, the applicant stated that the AMP B.2.34 is an existing program that is consistent with the GALL Report AMP XI.S1, ASME Section XI, Subsection IWE.

During its audit, the staff reviewed the applicants onsite documentation to support its conclusion that the AMP elements are consistent with the elements in the GALL Report AMP XI.S1. The staff interviewed the applicant's technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 -A3 License Renewal Evaluation of Civil/Structural Aging Rev. 1 (Attachment 3.3) Management Program

2. LRPD-05 Aging Management Program Evaluation Results Rev. 3

3. NDE-VT-003 PPL Procedure Visual Examination VT-3 Rev. 6

4. C1109 PPL Specification Containment Suppression Rev. 5 Chamber Inspections

5. CR 649369 Unit 2 Drywell Personnel Access Hatch has Moisture and Rust on Outer Door Seal Area

6. CR 97-1150 Pitting Found in Sealing Area of Reactor Cavity Ventilation Return, One Hatch Appears to be Out of Round by 1/8in In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in the AMP B.2.34 are consistent with the GALL Report AMP XI.S1 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL Report AMP XI.S1. The staff also verified that the applicant provided an adequate summary description of the program.

The staff also reviewed operating experience reports, including 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 LRA states that the inspection program has identified light to heavy pitting and corrosion. Applicant procedure NDT-VT-003 classifies levels of corrosion. After reviewing the document, the staff was satisfied with the classification of degradation and the applicants response to findings. The documents reviewed verify that the program is capturing degradation and correcting it in accordance with ASME Section XI.

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 B.2.34 were consistent with those specified in the GALL Report AMP XI.S1.

LRA AMP B.2.35, Inservice Inspection Program - IWL In the LRA, the applicant stated that the AMP B.2.35 is an existing program that is consistent with the GALL Report AMP XI.S2, ASME Section XI, Subsection IWL.

During its audit, the staff reviewed the applicants onsite documentation to support its conclusion that the AMP elements are consistent with the elements in the GALL Report AMP XI.S2. The staff interviewed the applicant's technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 -A3 License Renewal Evaluation of Civil/Structural Aging Rev. 1 (Attachment 3.5) Management Program

2. LRPD-05 Aging Management Program Evaluation Results Rev. 3

3. C-1118 PPL Specification, Specification for Inservice Inspection, Rev. 0 Evaluation and Repairs of Reinforced Concrete Primary Containment Structures.

In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in SSES AMP B.2.35 are consistent with the GALL Report AMP XI.S2 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL Report AMP XI.S2. The staff also verified that the applicant provided an adequate summary description of the program.

The staff also reviewed the operating experience reports, including inspection data and summaries, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience.

Visual examinations in 2000 revealed surface cracking on the containment exterior. The licensee provided documentation showing the cracking to be less than the allowable values per ACI 224R, Table 4.1, and acceptable per their appropriate plant specification. No recent condition reports have been generated for this program because no degradation has been found which meets the necessary threshold. The reviewed documents verify that the program is capturing degradation and evaluating it appropriately in accordance with ASME Section XI.

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 B.2.35 were consistent with those specified in the GALL Report AMP XI.S2.

LRA AMP B.2.36, Inservice Inspection Program - IWF In the LRA, the applicant stated that the AMP B.2.36 is an existing program that is consistent with the GALL Report AMP XI.S3, ASME Section XI, Subsection IWF.

During its audit, the staff reviewed the applicants onsite documentation to support its conclusion that the AMP elements are consistent with the elements in the GALL Report AMP XI.S3. The staff interviewed the applicant's technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 -A3 License Renewal Evaluation of Civil/Structural Aging Rev. 1 (Attachment 3.4) Management Program

2. LRPD-05 Aging Management Program Evaluation Results Rev. 3

3. NDAP-QA-1608 PPL Procedure, Inservice Inspection (ISI) Rev. 10

4. CR 555543 HRC 17(1)-H8 Visual Exam Revealed Bent Vertical Spring Can Rods In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in the AMP B.2.36 are consistent with the GALL Report AMP XI.S3 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL Report AMP XI.S3. The staff also verified that the applicant provided an adequate summary description of the program.

The staff also reviewed the operating experience reports, including 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 asked the applicant to provide more information about the bent spring can supports described in the LRA operating experience. In response the applicant provided the condition report which detailed the finding and the resolution. The reviewed documents verify that the program is capturing degradation and correcting it in accordance with ASME Section XI.

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 B.2.36 were consistent with those specified in the GALL Report AMP XI.S3.

LRA AMP B.2.37, Containment Leak Rate Test Program In the LRA, the applicant stated that the AMP B.2.37 is an existing program that is consistent with the GALL Report AMP XI.S4, 10 CFR 50, Appendix J.

During its audit, the staff reviewed the applicants onsite documentation to support its conclusion that the AMP elements are consistent with the elements in the GALL Report AMP XI.S4. The staff interviewed the applicant's technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 -A3 License Renewal Evaluation of Civil/Structural Aging Rev. 1 (Attachment 3.1) Management Program

2. NDAP-QA-0412 PPL Procedure, Leakage Rate Test Program Rev. 10

3. LRPD-05 Aging Management Program Evaluation Results Rev. 3

4. CR 649369 Unit 2 Drywell Personnel Access Hatch has Moisture and Rust on Outer Door Seal Area In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in the AMP B.2.37 are consistent with the GALL Report AMP XI.S4 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL Report AMP XI.S4. The staff also verified that the applicant provided an adequate summary description of the program.

The staff reviewed the operating experience reports, including condition reports and test results, 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 most recent containment structure Integrated Leak Rate Tests were performed in April 2006 and 2007 for Units 1 and 2 respectively. The results were below the plant limits found in the technical specifications, and demonstrate that the containments are leak tight. The reviewed documents verify that the program is capturing degradation and properly evaluating it.

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 B.2.37 were consistent with those specified in the GALL Report AMP XI.S4.

LRA AMP B.2.38, Masonry Wall Program In the LRA, the applicant stated that the AMP B.2.38 is an existing program that, following enhancement, will be consistent with the GALL Report AMP XI.S5, Masonry Wall Program.

During its audit, the staff reviewed the applicants onsite documentation to support its conclusion that the program elements are consistent with the elements in the GALL Report program. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05-A3 License Renewal Evaluation of Civil/Structural Aging Rev. 1 Management Programs/Activities (Att. 3.6.a)

2. SSES FSAR Final Safety Analysis Report Rev. 61

3. PPL NDAP-QA- Structural Monitoring Program Rev. 2 1163

4. NUREG 1801 Generic Aging Lessons Learned (GALL) Report Rev. 1

5. LRPD-05 Aging Management Program Evaluation Results Rev. 3 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in the AMP B.2.38 are consistent with the GALL Report AMP XI.S5 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL Report AMP XI.S5. The staff also verified that the applicant provided an adequate summary description of the program.

In comparing the elements in the applicants program, 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 consists of visual inspection of external surfaces prior to the loss of the structures or the components intended functions (e.g., cracking, broken blocks, missing mortar, and general mechanical soundness of steel supports). Visual inspections are performed 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 inspection frequency is appropriate.

In comparing the elements in the applicants AMP to those in the GALL Report AMP XI.S5, the staff found that the applicant has taken an enhancement as follows:

Add to Acceptance Criteria. The applicant indicated that the Masonry Wall Program is implemented by the Structures Monitoring Program, and the Structures Monitoring Program procedure will be enhanced to specify that for each masonry wall, the extent of observed masonry cracking and/or degradation of steel edge supports/bracing which is evaluated to ensure that the current evaluation basis is still valid.

The staff also reviewed 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 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 were consistent with those specified in the GALL Report AMP XI.S5.

LRA AMP B.2.39, Structures Monitoring Program In the LRA, the applicant stated that the AMP B.2.39 is an existing program that, following enhancements, will be consistent with the GALL Report AMP XI.S6 Structures Monitoring Program.

During its audit, the staff reviewed the applicants onsite documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05-A3 License Renewal Evaluation of Civil/Structural Aging Rev. 1 Management Programs/Activities (Att. 3.6.)

2. PPL NDAP- Structures Monitoring Program Rev. 2 QA-1163

3. GDS-011 Design Standard for Life Assessments of Structures Rev. 1

4. GDS-012 Design Standard for Condition Surveys of Structures Rev. 1

5. PPL SE- Ground Water Monitoring Rev. 9 OOO-016

6. LRPD-05 Aging Management Program Evaluation Results Rev. 3

7. CR 231987 Turbine building roof leaking on 762 elevation adjacent to the cable tray

8. CR 320511 Corrosion on steel legs of platforms submerged in cooling tower basins

9. CR 581824 Evaluate/repair damaged concrete on ESW valve vault

10. CR 718328 Corrosion on cable supports in Electrical manhole

11. CR 744866 General corrosion on pipe through penetrations (still open)

12. CR 757782 Loose nut for beam connection in MS tunnel

13. CR 767559 Several chunks of concrete were found on the floor in Rx # 1, elev. 670 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in the AMP B.2.39 are consistent with the GALL Report AMP XI.S6 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL Report AMP XI.S6. The staff also verified that the applicant provided an adequate summary description of the program.

The staff reviewed those portions of the Structures Monitoring Program for which the applicant claims consistency with the GALL Report AMP XI.S6 with enhancements. The staff finds the applicant omitted the Acceptance Criteria enhancement for Water Control Structures (program element 6). The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff conducted a field walkdown with the applicants technical staff to the turbine building, diesel generator building, reactor building, ESSW pumphouse, yard, etc. Overall, the staff noticed that the structures and structure components of the above areas appeared to be in good general shape and normal operating condition.

The staff also audited the operating experience provided in the License Renewal Basis Documents as included in the above table, 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 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 were consistent with those specified in the GALL Report 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, RG 1.127 Water Control Structures Inspection In the LRA, the applicant stated that the AMP B.2.40 is an existing program that, following enhancement, will be consistent with the GALL Report AMP XI.S7 RG 1.127 Water Control Structures Inspection.

During its audit, the staff interviewed the applicants technical staff and reviewed the following onsite documents related to the RG 1.127 Water Control Structures Inspection:

Document Title Revision /

Date

1. LRPD-05-A3 License Renewal Evaluation of Civil/Structural Aging Management Rev. 1 Programs/Activities (Att. 3.6.b)

2. PPL NDAP-QA- Structural Monitoring Program Rev. 2 1163

3. PPL NSEI-AD-411 ESSW Pump House Structural Monitoring Rev. 1

4. PPL SE-OOO-016 Ground Water Monitoring Rev. 9

5. LRPD-05 Aging Management Program Evaluation Results Rev. 3

6. PPL TP-OOO-015 Settlement Monitoring of ESSW Pumphouse Rev. 0

7. CR-871298 Damage to concrete in several areas around pond retention walls as well as damage noted to the expansion joint caulking material

8. CR-982864 Concrete cracking found along Spray pond apron

9. CR-905178 Small sink hole in road that encircles spray pond In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in the AMP B.2.40 are consistent with the GALL Report AMP XI.S7 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL Report AMP XI.S7. The staff also verified that the applicant provided an adequate summary description of the program.

The staff reviewed those portions of the applicants RG 1.127 Water Control Structures Inspection, for which the applicant claims consistency with the GALL Report AMP XI.S7, with enhancements to the Structures Monitoring Program procedure. The staff noticed that the RG 1.127 Water Control Structures Inspection is implemented as part of the Structures Monitoring Program. The staff also reviewed the Structures Monitoring Program and found that the applicant omitted the Acceptance Criteria enhancement for Water Control Structures (program element 6). The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also reviewed the operating experience provided in the License Renewal Basis Documents as included in the above table, 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 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 were consistent with those specified in the GALL Report AMP XI.S7, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.41, Non-EQ Electrical Cable & Connections Visual Inspection Program In the LRA, the applicant stated that the AMP B.2.41 is a new program that is consistent with the GALL Report AMP XI.E1, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

During its audit, the staff reviewed the applicants onsite documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents.

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Results Rev. 2, 02/06/2008 attachment 4.1

2. CR 759242 Found degraded cables in high voltage cabinet Rev. 1, 05/05/2006

3. NREG/CR-5643 Insights Gained from Aging Research 03/1992

4. EPRI TR-109619 Guideline for the Management of Adverse Localized 06/1999 Environments

5. SAND96-0344 Aging Management Guideline for Commercial Nuclear 09/1996 Power Plants - Electrical Cables and Terminations

6. EPRI 1003057 License Renewal Electrical Handbook 12/2001

7. LRPD-04 Operating Experience Review Rev. 2, 10/31/2006 In comparing the 7 elements in the applicants program to those in the GALL Report AMP XI.E1, the staff verified that the program elements contained in Susquehanna AMP B.2.41 are consistent with the GALL Report AMP XI.E1 program elements. The staff confirmed that the boundary conditions of the plant programs are enveloped by the boundary conditions described in the GALL Report AMP. The staff did not find adequate definition for adverse localize environment, which should be based on the most limiting service environment of a cable design.

The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also reviewed 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 2006, while performing a work order, plant staff found high-voltage cables (4KV) in the high-voltage transition cabinet had been degraded from corona (cracked, brittle, and crispy). The safety assessment concluded no adverse plant safety consequence. Corrective action was taken to address the issue.

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 the remaining 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in the GALL Report AMP XI.E1, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.42, Non-EQ Electrical Cable & Connections in Low-Current Instrumentation Circuits Program In the LRA, the applicant stated that the AMP B.2.42 is a new program that is consistent with the GALL Report 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 reviewed the applicants onsite documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 attachment Aging Management Program Evaluation Results Rev. 2, 02/06/2008 4.2

2. CR 97-1098 IRM cables under the vessel are very brittle 04/06/1997 CR 97-1111 04/07/1997

3. NUREG/CR-5643 Insights Gained from Aging Research 03/1992

4. EPRI TR-109619 Guideline for the Management of Adverse Localized 06/1999 Environments

5. SAND 96-0344 Aging Management Guideline for Commercial Nuclear 09/1996 Power Plants - Electrical Cables and Terminations

6. IEEE Standard 1205- IEEE Guide for Assessing, Monitoring, and Mitigating N/A 2000 Effects on Class 1E Equipment Used in Nuclear Power Generating Stations

7. NRC Information Environmental Qualification Deficiency for Cables and 07/ 1997 (and Notice 97-45 Containment Penetration Pigtails Supplement 1, 02/1998

8. EPRI 1003057 License Renewal Electrical Handbook 12/ 2001

9. PPL Calculation EC- Review of Acceptability Criteria of Under-Vessel LPRM 04/1998 078-1008 Cables Insulation Resistance Testing In comparing the 7 elements in the applicants program to those in the GALL Report AMP XI.E2, the staff verified that the program elements contained in Susquehanna AMP B.2.42 are consistent with the GALL Report AMP XI.E2 program elements. The staff confirmed that the boundary conditions of the plant programs are enveloped by the boundary conditions described in the GALL Report AMP. The staff did not find adequate description of the method to be used to test the degradation of insulation in low-current instrumentation circuits. The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also reviewed 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 April 1997, while repairing LPRM connectors under the Unit 2 reactor vessel, the outer jackets for four LPRM detector cables were observed to have heat related damaged. The damage was localized, showing exposure of the cable braid, and indicative of the cable coming into contact with a hot item (e.g., CRD flange, etc.). Testing results and monitoring indicates that no adverse trends exist with respect to LPRM performance. Corrective action was taken to address the issue.

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 the remaining 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in the GALL Report AMP XI.E2, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.43, Non-EQ Inaccessible Medium-Voltage Cables Program In the LRA, the applicant stated that the AMP B.2.43 is a new program that is consistent with the GALL Report AMP XI.E3, Non-EQ Inaccessible Medium-Voltage Cables Program.

During its audit, the staff reviewed the applicants onsite documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 attachment Aging Management Program Evaluation Results Rev. 2, 02/06/2008 4.3

2. PCWO 701105 Support Engineering by Pumping Down Various 08/17/2005 Manholes

3. NUREG/CR-5643 Insights Gained from Aging Research 03/1992

4. EPRI TR-109619 Guideline for the Management of Adverse Localized 06/1999 Environments

5. SAND96-0344 Aging Management Guideline for Commercial Nuclear 09/1996 Power Plants - Electrical Cables and Terminations

6. EPRI 1003057 License Renewal Electrical Handbook 12/2001

7. EPRI TR-1033834- Effects of Moisture on the Life of Power Plant Cables 08/1994 P1-2

8. PPL Drawing E-1, Susquehanna S.E.S Unit 1&2 - Single-Line Diagram Rev. 30 Sheet 1 Station In comparing the 7 elements in the applicants program to those in the GALL Report AMP XI.E3, the staff verified that the program elements contained in the AMP B.2.43 are consistent with the GALL Report AMP XI.E3 program elements. The staff confirmed that the boundary conditions of the plant programs are enveloped by the boundary conditions described in the GALL Report AMP. The staff did not find adequate description of the corrective action in place if adverse conditions are determined. The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER. The staff audited the condition of manholes

1. 2 and #16 and observed all cables were submerged under water inside manhole #2 while manhole #16 had one foot of water. The staff questioned the adequacy of the applicants corrective actions and periodic inspection for water collection in the manholes. Subsequently, corrective action was taken by the applicant to address the issue. The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also reviewed 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 August 2005, a work order was generated to measure and record water level and pump standing water from various manholes inside the plant. Water was found in a sample of those manholes inspected and continuous corrective action was taken to address the issue for 8 months afterward.

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 the remaining 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in the GALL Report AMP XI.E3, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B.2.44, Metal-Enclosed Bus Inspection Program In the LRA, the applicant stated that the AMP B.2.44 is a new program that is consistent with the GALL Report AMP XI.E4, Metal-Enclosed Bus.

During its audit, the staff reviewed the applicants onsite documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 attachment Aging Management Program Evaluation Results Rev. 2, 02/06/2008 4.4

2. INPO SER 4-04 Isophase bus Ground Faults 08/17/2005

3. NUREG/CR-5643 Insights Gained from Aging Research 03/1992

4. EPRI TR-109619 Guideline for the Management of Adverse Localized 06/1999 Environments

5. SAND96-0344 Aging Management Guideline for Commercial Nuclear 09/1996 Power Plants - Electrical Cables and Terminations

6. EPRI 1003057 License Renewal Electrical Handbook 12/2001

7. IEEE Standard 1205- IEEE Guide for Assessing, Monitoring, and mitigating 03/30/2000 2000 Effects on Class1E Equipment Used in Nuclear Power Generating Stations

8. NRC Information Electrical Bus Bar Failures 09/07/1989 Notice 89-64

9. NRC Information Non-Vital Bus Fault Leads to Fire and Loss of Offsite 09/27/2000 Notice 2000-14 Power

10. LRAMER-E01 Aging Management Review of Electrical Component Rev. 3, 02/28/2007 Commodity Groups

11. SSES Procedure MI- Thermographic Inspection Program Rev. 2, 10/29/1999 PD-002

12. PPL Drawing E-1, Susquehanna S.E.S Unit 1&2 - Single-Line Diagram Rev. 30 Sheet 1 Station

13. PPL Drawing E-4, Single-Line Meter & Relay Diagram -13.8kV Start-Up Aux. Rev. 36 Sheet 2 Power System In comparing the elements in the applicants program to those in the GALL Report AMP XI.E4, the staff verified that the program elements contained in the AMP B.2.44 are consistent with the GALL Report AMP XI.E4 program elements. The staff confirmed that the boundary conditions of the plant programs are enveloped by the boundary conditions described in the GALL Report AMP. The staff observed pictures taken of various metal enclosed buses during a work order and the buses appear to be in acceptable condition. The staff also reviewed industry guidance with relevance to this AMP.

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 the remaining 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in the GALL Report AMP XI.E4.

LRA AMP B.2.45, Non-EQ Electrical Cable Connections Program In the LRA, the applicant stated that the AMP B.2.45 is a new program that is consistent with the GALL Report AMP XI.E6, Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements.

During its audit, the staff reviewed the applicants onsite documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-05 Aging Management Program Evaluation Results Rev. 2, 2/6/2008 attachment 4.5

2. NREG/CR-5643 Insights Gained from Aging Research 03/1992

3. SAND96-0344 Aging Management Guideline for Commercial Nuclear 09/1996 Power Plants - Electrical Cables and Terminations

4. EPRI 1003057 License Renewal Electrical Handbook 12/2001

5. LRAMER-E01 Aging Management Review of Electrical Component Rev. 3, 02/28/2007 Commodity Groups

6. SSES Procedure Thermographic Inspection Program Rev. 2, 10/29/1999 MI-PD-002

7. CR 97-0713 In Battery Charger 2D613 Found Hot Spot on DC Output 3/19/97 Cable Lugs In comparing the 7 elements in the applicants program to those in the GALL Report AMP XI.E6 the staff verified that the program elements contained in the AMP B.2.44 are consistent with the GALL Report AMP XI.E6 program elements. The staff confirmed that the boundary conditions of the plant programs are enveloped by the boundary conditions described in the GALL Report AMP.

The staff also reviewed 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.

On March 19, 1997, while performing PMWA #P60762 on battery charger 2D613 the applicant found a hot spot on DC output cable lugs with the use of thermography performed by Predictive Maintenance. Corrective action was taken to replace lugs on DC output cable.

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 the remaining 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in the GALL Report AMP XI.E6.

LRA AMP B.3.2, Environmental Qualification (EQ) Program In the LRA, the applicant stated that the AMP B.3.2 is a new program that is consistent with the GALL Report AMP X.E1, Environmental Qualification (EQ) of Electric components.

During its audit, the staff reviewed the applicants onsite documentation supporting the applicants conclusion that the program elements are consistent with the elements in the GALL Report AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. LRPD-02 TLAA and Exemption Evaluation Results Rev. 1, 02/16/2006

2. CR 191057 The EQ Program has not Addressed the Thermal Effects 07/20/1999 on Continuously Energized AC solenoids Resulting from System Voltages that Typically Exceed the Equipments 120 VAC Rating.

3. EQAR-114 Susquehanna Steam Electric Station Environmental Rev. 4, 07/25/2007 Qualification Assessment Report Summary Page for NLI-Supplied Motor Control Centers

4. EC-RNEW-1001 SSES Nuclear Engineering Calculation, Evaluation of Rev. 1 Environmental Qualification Assessment Reports (EQAR) to Determine Which Are License Renewal Time-Limited Aging Analyses (TLAA)

5. NRC RIS 2003-09 Environmental Qualification of Low-Voltage 05/02/2003 Instrumentation and Control Cables

6. NUREG-0588 Interim Staff Position on Environmental Qualification of Rev. 1, 12/1979 Safety-Related Electrical Equipment

7. DBD011 Design Basis Document for Environmental Qualification Rev. 2, 04/03/2003

8. Reg Guide 1.89 Environmental Qualification of Certain Electrical Rev. 1, 6/1984 Equipment Important to Safety for Nuclear Power Plants,

9. DOR Guidelines Guidelines for Evaluating Environmental Qualification of 1979 Class 1E Electrical Equipment in Operating Reactors In comparing the 7 elements in the applicants program to those in the GALL Report AMP X.E1, the staff verified that the program elements contained in the AMP B.3.2 are consistent with the GALL Report AMP X.E1 program elements. The staff confirmed that the boundary conditions of the plant programs are enveloped by the boundary conditions described in the GALL Report AMP. The staff reviewed the EQ master list and verified all information is within the boundary conditions.

The staff also reviewed 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.

CR # 191057 states that the issue of higher than rated voltage effects on solenoid life was raised at an industry meeting. While performing investigation of SSES equipment, conclusion was drawn that terminal voltages typically exceed the 120 VAC rating of SOVs in the EQ program. The study concludes an establishment of the maximum end device voltages for U1 Class 1E 120V panels, and on the average 10 and T20 bus voltage over the last year. A review of effected EQARs has determined that temperature rise due to self-heat at voltages above 120 VAC has not been factored into qualified life determinations. Corrective action was taken to address the issue.

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 the remaining 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in the GALL Report AMP X.E1.

Letter to B. McKinney from E. Gettys, dated January 16, 2009 DISTRIBUTION:

SUBJECT:

AUDIT REPORT REGARDING THE SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION HARD COPY:

DLR RF E-MAIL:

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Susquehanna Steam Electric Station, Units 1 and 2 cc:

Joseph J. Scopelliti Cornelius J. Gannon Community Relations Manager, Vice President - Nuclear Operations Susquehanna PPL Susquehanna, LLC PPL Susquehanna, LLC 769 Salem Blvd., NUCSB3 634 Salem Blvd., SSO Berwick, PA 18603-0467 Berwick, PA 18603-0467 Robert M. Paley Bryan A. Snapp, Esq.

General Manager - Plant Support Associate General Counsel PPL Susquehanna, LLC PPL Services Corporation 769 Salem Blvd., NUCSB2 Two North Ninth Street, GENTW3 Berwick, PA 18603-0467 Allentown, PA 18101-1179 Rocco R. Sgarro Document Control Services Manager - Nuclear Regulatory Affairs PPL Susquehanna, LLC PPL Susquehanna, LLC Two North Ninth Street, GENPL4 Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Allentown, PA 18101-1179 Richard W. Osborne Supervisor - Nuclear Regulatory Affairs Allegheny Electric Cooperative, Inc.

PPL Susquehanna, LLC 212 Locust Street 769 Salem Blvd., NUCSA4 P.O. Box 1266 Berwick, PA 18603-0467 Harrisburg, PA 17108-1266 Michael H. Crowthers Director, Bureau of Radiation Protection Supervisor - Nuclear Regulatory Affairs Pennsylvania Department of PPL Susquehanna, LLC Environmental Protection Two North Ninth Street, GENPL4 Rachel Carson State Office Building Allentown, PA 18101-1179 P.O. Box 8469 Harrisburg, PA 17105-8469 Ronald E. Smith General Manager - Site Preparedness Senior Resident Inspector and Services U.S. Nuclear Regulatory Commission PPL Susquehanna, LLC P.O. Box 35, NUCSA4 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0035 Berwick, PA 18603-0467 Regional Administrator, Region 1 Michael H. Rose U.S. Nuclear Regulatory Commission Manager - Quality Assurance 475 Allendale Road PPL Susquehanna, LLC King of Prussia, PA 19406 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467

Susquehanna Steam Electric Station, Units 1 and 2 cc:

Board of Supervisors Salem Township P.O. Box 405 Berwick, PA 18603-0035 Dr. Judith Johnsrud National Energy Committee Sierra Club 443 Orlando Avenue State College, PA 16803