ML091900449

AMP Audit Report Regarding the Kewaunee Power Station, License Renewal Application

ML091900449
Person / Time
Site:	Kewaunee
Issue date:	08/12/2009
From:	Hernandez-Quinones S License Renewal Projects Branch 1
To:	Heacock D Dominion Energy Kewaunee
Hernandez S, NRR/DLR/REBB, 415-4049
References
TAC MD9408
Download: ML091900449 (76)

Text

August 12, 2009 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.

Innsbrook Technical Center - 2SW 5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT:

AMP AUDIT REPORT REGARDING THE KEWAUNEE POWER STATION, LICENSE RENEWAL APPLICATION (TAC NO. MD9408)

Dear Mr. Heacock:

By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc. (Dominion), submitted an application pursuant to 10 Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating license for Kewaunee Power Station (KPS) for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). On June 12, 2009, the NRC audit team completed the on-site audit of aging management programs. The audit report is enclosed.

If you have any questions, please contact Samuel Hernandez at 301-415-4049 or by e-mail at samuel.hernandez@nrc.gov.

/RA/

Samuel Hernandez, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulations Docket No. 50-305

Enclosure:

As stated cc w/encl: See next page

August 12, 2009 Mr. David A. Heacock President and Chief Nuclear Officer Dominion Energy Kewaunee, Inc.

Innsbrook Technical Center - 2SW 5000 Dominion Blvd.

Glen Allen, VA 23060-6711

SUBJECT:

AMP AUDIT REPORT REGARDING THE KEWAUNEE POWER STATION, LICENSE RENEWAL APPLICATION (TAC NO. MD9408)

Dear Mr. Heacock:

By letter dated August 12, 2008, Dominion Energy Kewaunee, Inc. (Dominion), submitted an application pursuant to 10 Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating license for Kewaunee Power Station (KPS) for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). On June 12, 2009, the NRC audit team completed the on-site audit of aging management programs. The audit report is enclosed.

If you have any questions, please contact Samuel Hernandez at 301-415-4049 or by e-mail at samuel.hernandez@nrc.gov.

/RA/

Samuel Hernandez, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulations Docket No. 50-305

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION: See next page ADAMS Accession Number: ML091900449 OFFICE LA:DLR PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR D. Pelton S. Hernandez NAME S. Figueroa S. Hernandez (E. Keegan for) (Signature)

DATE 08/11/09 08/11/09 08/12/09 08/12/09 OFFICIAL RECORD COPY

Letter to D. Heacock from S. Hernandez, dated August 12, 2009 DISTRIBUTION:

SUBJECT:

AMP AUDIT REPORT REGARDING THE KEWAUNEE POWER STATION, LICENSE RENEWAL APPLICATION (TAC NO. MD9408)

HARD COPY DLR RF E-MAIL:

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S. Hernandez S. Lopas B. Rogers P. Tam M. Kunowski S. Burton P. Higgins V. Mitlyng I. Couret S. Uttal, OGC K. Barclay V. Perin

Kewaunee Power Station cc:

Resident Inspectors Office Mr. Paul C. Aitken U.S. Nuclear Regulatory Commission Supervisor - License Renewal Project N490 Hwy 42 Innsbrook Technical Center - 3NE Kewaunee, WI 54216-9510 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Mr. Chris L. Funderburk Director, Nuclear Licensing and Mr. David A. Sommers Operations Support Supervisor - Nuclear Engineering Dominion Resources Services, Inc. Innsbrook Technical Center - 2SE Innsbrook Technical Center - 2SE 5000 Dominion Boulevard 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Glen Allen, VA 23060-6711 Ms. Lillian M. Cuoco, Esq.

Mr. Thomas L. Breene Senior Counsel Dominon Energy Kewaunee, Inc. Dominion Resources Services, Inc.

Kewaunee Power Station 120 Tredegar Street N490 Highway 42 Riverside 2 Kewaunee, WI 54216 Richmond, VA 23219 Mr. Michael J. Wilson, Director Mr. Stephen E. Scace Nuclear Safety & Licensing Site Vice President Dominion Energy Kewaunee, Inc. Dominion Energy Kewaunee, Inc.

Kewaunee Power Station Kewaunee Power Station N490 Highway 42 N490 Highway 42 Kewaunee, WI 54216 Kewaunee, WI 54216 Mr. William R. Matthews Mr. David R. Lewis Senior Vice President - Nuclear Pillsbury Winthrop Shaw Operations Pittman, LLP Innsbrook Technical Center - 2SE 2300 N Street, N.W.

5000 Dominion Boulevard Washington, DC 20037-1122 Glen Allen, VA 23060-6711 Mr. Ken Paplham Mr. Alan J. Price E 4095 Sandy Bay Rd.

Vice President - Nuclear Engineering Kewaunee, WI 54216 Innsbrook Technical Center - 2SE 5000 Dominion Boulevard Mr. Jeff Kitsembel, P.E.

Glen Allen, VA 23060-6711 Public Service Commission of Wisconsin Mr. William D. Corbin P.O. Box 7854 Director - Nuclear Engineering Madison, WI 53707-7854 Innsbrook Technical Center - 3NE 5000 Dominion Boulevard Glen Allen, VA 23060-6711

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION - DIVISION OF LICENSE RENEWAL Docket No: 050-305 License No: DPR-43 Licensee: Dominion Energy Kewaunee, Inc.

Facility: Kewaunee Power Station Location: Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216 Dates: June 9-12, 2009 Reviewers: S. Hernandez, Project Manager, Division of License Renewal (DLR)

A. Hiser, Senior Level Service, DLR J. Dozier, Branch Chief, DLR R. Auluck, Branch Chief, DLR D. Brittner, Reactor Engineer, DLR J. Shea, Sr. Reactor Engineer, DLR K. Karwoski. Senior Level Service, DCI D. Nguyen, Electrical Engineer, DLR C. Doutt, Sr. Electrical Engineer, DLR J. Davis, Sr. Materials Engineer, DLR J. Gavula, Mechanical Engineer, DLR W. Smith, Sr. Materials Engineer, DLR D. Alley, Materials Engineer, DLR D. Lamb, Student Engineer, DLR V. Perin, Project Manager, DLR A. Prinaris, Sr. Materials Engineer, DLR S. Min, Materials Engineer, DLR B. Lehman, Structural Engineer, DLR M. Sircar, Structural Engineer, DLR A. Sheik, Sr. Structural Engineer, DLR C. Yang, Sr. Mechanical Engineer, DLR A. Wong, Sr. Mechanical Engineer, DLR R. Vaucher, Mechanical Engineer, DLR O. Yee, Mechanical Engineer, DLR B. Fu, Materials Engineer, DLR D. Diercks, Sr. Mechanical Engineer O. Chopra, Sr. Metallurgist D. Naus, Sr. Structural Engineer ENCLOSURE

Approved By:

Jerry Dozier, Chief Engineering Review Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Rajender Auluck, Chief Engineering Review Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation David Pelton, Chief Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation

Introduction A four day audit was conducted by the NRC project team at the plant in Kewaunee, WI on June 9-12, 2009. The purpose of this audit was to examine the applicants Aging Management Programs (AMPs) documentation for the Kewaunee Power Station (KPS) and to verify the applicants claim of consistency with the corresponding Generic Aging Lessons Learned (GALL)

AMPs. Exceptions to the GALL AMP elements will be evaluated separately as part of the NRC staffs (the staffs) review of KPS license renewal application (LRA) and documented in the staffs Safety Evaluation Report (SER).

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

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

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

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

LRA AMP B2.1.2, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD In the KPS LRA, the applicant stated that AMP B2.1.2 is an existing program that is consistent with the program elements in GALL AMP XI.M1, ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, with exceptions. The exceptions are related to the use of a different version of ASME Sec. XI Code. [currently in 4th Ten-Year ISI interval, commenced in 2004]. The enhancements are related to aging management of reactor vessel internals, and aging management of thermal aging and neutron irradiation embrittlement of cast stainless steel.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date ASME Section XI Inservice Inspection AMP

1. KLR-1309 07/22/2008 Technical Report & Reference Information Fourth 10-year Inservice Inspection (ISI) Program 2004-

2. Rev. 1 2014, Revision 1.

Rev.1

3. NMC-01-342 Risk Informed Inservice Inspection Program Plan 09/30/2005 Nuclear Engineering Procedure - Visual Examination for

4. NEP-15.05 05/26/2005 Inservice Inspection

5. ER-AA-NE-VT-601 VT-1 Visual Examination Procedure 01/18/2008

6. ISI Indication evaluation record F103, VT of HX bolting 05/24/2000 ISI Indication evaluation record F113, Vessel Head

7. 04/20/2003 Conoseal bolting ISI Indication evaluation record F114 (unacceptable

8. 04/13/2003 indication on socket weld)

ISI Indication evaluation record F118, PT of nozzle to safe

9. 11/22/2004 end butt weld.

th

10. CAP031925 Correction in ISI 4 Ten Year Interval relief request 03/10/2006

11. CAP038736 Boric residue on RC-42 10/23/2006 In comparing the 7 program elements in the applicants program, the staff found that some of the program elements contained in AMP B2.1.2 are consistent with GALL AMP XI.M1 program elements and some are not. In reviewing elements Scope of Program and Parameter Monitored/Inspected, the staff found that they are not consistent with elements specified in GALL AMP XI.M1. NUREG-1800 recommends a stand-alone program to address inspections of class 1 small bore piping up to NPS 4 inch. The program is specified in GALL AMP XI.M35, One-Time Inspection of ASME Code Class 1 Small Bore Piping. However, the applicant does not have a program consistent with GALL AMP XI.M35. In addition, AMP B2.1.2 does not address all issues as recommended in GALL AMP XI.M35. The staff discussed this issue and will consider issuing RAIs related to small bore piping.

The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP except for the areas that the applicant took

exceptions to GALL AMP XI.M1. The staff also verified that the applicant provided an adequate summary description of the program In the application, the applicant proposed an exception to GALL program elements Scope of Program, and Parameters Monitored/Inspected, that would use a different version of the ASME code. The staff will review the exception and may consider issuing an RAI that requests the applicant provide additional information.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database search for operating experience relevant to AMP B2.1.2. A search with keywords: Class 1, weld, examination, inspection, ISI, indication, crack and flaw resulted in a review of Class 1 weld examination. The staff screened these results for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for 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 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in the GALL AMP XI.M1, not including any exceptions identified by the applicant in the LRA for this AMP, which will be evaluated separately in the SER, and the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.1.3, ASME Section XI, Subsection IWE In the KPS LRA, the applicant stated that AMP B2.1.3 is an existing program that is consistent with the program elements in GALL AMP XI.S1, ASME Section XI, Subsection IWE.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. KLR-1338 ASME Section XI, Subsection IWE Revision 1 07/22/ 2008

2. Kewaunee Power Station Second 10-Year Inservice Revision 2 Inspection Class MC (ISI) Program 2006-2016

3. ER-AA-NDE-VT-605 IWE Visual Examination Procedure Revision 0 09/10/2007

Document Title Revision / Date

4. GNP-01.05.02 KPS General Nuclear Procedure, Reactor Building Revision D Containment Vessel Indication Evaluation for Inservice 10/31/2006 Inspection

5. PCR014213 Revise IWE Program 10/31/2003 st rd

6. KNPP 2004 Examination Summary, 1 Interval, 3 st Period, 1 Outage st rd

7. KNPP 2004 Examination Summary, 1 Interval, 3 nd Period, 2 Outage

8. CR097856 White Deposits Within Biological Shield Wall 05/05/2008

9. CAP033062 Inservice Inspection Mentoring Engineering Support 04/18/2006 Guide Procedures In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.3 are consistent with GALL AMP XI.S1 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP XI.S1. The staff also verified that the applicant provided an adequate summary description of the program.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.3. A search with keywords: containment, corrosion, rust, and leakage resulted in over 70 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

During the audit, the staff noted that the applicants AMP is based on the 2001 Edition, 2003 Addenda of the ASME code while the ten elements of the GALL Report use excerpts of the 1995 Edition. The applicant compared the elements of their program against the 2001 Edition of the ASME code, which is referenced in the GALL Report Program description. The staff finds this acceptable because it compares the applicants AMP to their current code edition approved under 10 CFR 50.55a and captures the intent of the GALL Report. The staff asked the applicant about the possibility of refueling cavity leakage contacting the containment vessel.

The applicant provided information on the historic flow rates and path of the leakage. The staff also asked the applicant to discuss areas of the containment vessel that may require augmented examinations, specifically the concrete/vessel interface. The applicant explained that they believe there are currently no areas at KPS which require augmented examinations.

The staff also asked the applicant to discuss how aging of containment coatings is handled at KPS. The applicant explained that coatings are not credited for aging management and that their containment safety systems are protected from coating failure based on their response to GSI-191. The staff will consider issuing RAIs to address these issues, and the staffs evaluation will be documented in the SER.

The 3 program elements, corrective actions, confirmation process and administrative controls were reviewed as part of the Scoping and Screening Methodology audit. During the AMP audit, the staff reviewed 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in the GALL AMP XI.S1, not including those areas in which the staff felt additional clarification might be warranted as discussed above.

LRA AMP B2.1.4, ASME Section XI, Subsection IWF In the KPS LRA, the applicant stated that AMP B2.1.4 is an existing program that is consistent with the program elements in GALL AMP XI.S3, ASME Section XI, Subsection IWF with an exception. The exception is related to the ASME Section XI Code edition utilized.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. KLR-1339 ASME Section XI, Subsection IWF, Aging Management Revision 1 Program 07/22/2008 Nuclear Fleet Nondestructive Examination Procedure, VT- Revision 1

2. ER-AA-NDE-VT-603 3 Visual Examination Procedure 01/18/2008 Kewaunee Power Station Fourth 10-Year Interval Revision 1

3. Inservice Inspection (ISI) Program June 16, 2004 - June 16, 2014 Nuclear Fleet Nondestructive Examination Procedure, Revision 1

4. ER-AA-NDE-VT-123 Dominion Written Practice for Certification of Visual 03/13/2008 Examination Personnel.

Revision 6

5. GNP-01.05.01 Indication Evaluation for Inservice Inspection 05/22/2008 Revision 15

6. SP-55-085 Ten Year Inservice Inspection Requirements 01/29/2008

7. CAP000835 Feedwater Hanger FDW-H122 has a damaged saddle 11/06/2001 AC-H2 has gap between bearing plates and therefore non-

8. CAP007813 10/24/2001 functional In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.4 are consistent with GALL AMP XI.S3 program elements, with the exception that the scope of program program element contained in AMP B2.1.4 is not consistent with the GALL AMP XI.S3 program element. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP XI.S3 except for the areas that the applicant took exceptions to GALL AMP and the areas the staff identified. The staff also verified that the applicant provided an adequate summary description of the program.

In the application, the applicant proposed an exception to GALL program element scope of program because their program is based on a different ASME Code Edition than specified in

the GALL Report. The staff will review the exception and may consider issuing an RAI that requests the applicant provide additional information concerning the technical differences between code editions.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.4. A search with keywords: spring, hanger, and Subsection IWF resulted in over 75 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

During the audit, the staff noted that the AMP basis document discussion of the element scope of program mentioned an augmented program for Class 1, Class 2 and Class 3 supports and hangers. The staff asked the applicant how this augmented program was implemented and how it related to code required additional inspections. The applicant stated that additional examination requirements are described in Dominion Procedure SP-55-085. The staff reviewed the procedure and determined that additional clarification may be required on this issue.

Therefore, 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 AMP audit, the staff reviewed 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in the GALL AMP B2.1.4, not including the exception 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 B2.1.5, Bolting Integrity In the KPS LRA, the applicant stated that KPS AMP B2.1.5 is an existing program that is consistent with GALL AMP XI.M18, Bolting Integrity, with an enhancement and no exceptions.

The enhancement is related to further incorporating applicable EPRI and industry bolting guidance which include; proper joint assembly, torque values, gasket types, use of lubricants, and other bolting fundamentals.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision/Date

1. KPS General Maintenance Primary Manway Removal and Installation for Rev. 25 Procedure GMP-115 Steam Generator. 06/12/2007

2. KPS General Maintenance "Secondary Manway and Handhole Cover Removal Rev. V Procedure GMP-114 and Installation for Steam Generator." 08/24/2006

3. KPS General Maintenance Rev. H "Pressurizer Manway Removal and Installation."

Procedure GMP-117 10/23/2003

4. KPS General Maintenance Rev. 17 "General Bolting Procedure."

Procedure GMP-211 09/06/2007

5. PS Engineering Specification Specification for Fasteners - Mechanical, Rev. 1 ES-0100 Electrical, Instrument and Structural Systems. 04/20/2004

6. KPS Engineering Specification Rev. 5 Specification for Pipe and Fittings."

ES-2001, 01/11/2005

7. KPS Supply Group Procedure Rev. B "Receipt Inspection and Documentation Review."

SGP-021, 06/30/2006

8. KPS Lesson Plan M-MD- Rev. B "Bolting Practices."

LP2.1.3, 01/13/2003

9. KPS Lesson Plan MM-07-LP- Rev. A "Bolted Joints."

004 08/10/2007

10. Nuclear Fleet Guidance and "Leakage Management." Rev. 3 Reference Document MA-AA-No Date 1002 Rev. 0

11. CR096475 KEWA- missing bolt from support stand 04/17/2008 Rev. 0

12. KLR-1318 LRP/AMP KPS Bolting Integrity Program.

07/22/2008 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in KPS AMP B2.1.5 are consistent with GALL 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 AMP. The staff also verified that the applicant provided an adequate summary description of the program.

The staff found that the enhancements described in the LRA AMP B2.1.5 Bolting Integrity Program, would need additional clarification explaining which specific EPRI document it is referencing as well as the details of the specific changes which will be made. The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff also found that KPS has a rigorous Bolting Integrity Training Program that is pertinent to proper bolting procedures. However, the applicant did not state the frequency of such training. The applicant is not clear in whether or not their training frequency for proper bolting procedures related to bolting integrity would be on-going to assure a well trained maintenance staff. 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 operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP XI.M18. The search resulted in a review of 89 records through the use of keywords: Bolt, Nut, Preload, Torque, and Leak. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff identified an instance where a particular condition report, CR-096475, appeared to be significant in nature. The report indicated a missing bolt from a support stand to a Steam Generator B flow instrument tubing. The problem was treated as a structural integrity problem but not a possible foreign object damage problem. However, upon further staff evaluation, it was realized that this was not a 10 CFR Part 54 issue, rather a Part 50, current licensing issue. The incident was then re-evaluated by the staff as being properly handled as per 10 CFR Part 54. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for 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 AMP 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 AMP XI.M18, not including the areas for which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.1.6, Boric Acid Corrosion In the KPS LRA, the applicant stated that AMP B2.1.6 is an existing program that is consistent with the program elements in GALL AMP XI.M10, Boric Acid Corrosion.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. Technical Report License Renewal Project Aging Management, Boric Revision 1 KLR-1313 Acid Corrosion 07/22/2008

2. Program Description Boric Acid Corrosion Control Program Revision 0 ER-AP-BAC-10

3. Admin Procedure Boric Acid Corrosion Control Program Inspections Revision 0 ER-AP-BAC-101

4. Admin Procedure Boric Acid Corrosion Control Program Evaluations Revision 0 ER-AP-BAC-102

4. Guidance and KPS Site Specific Boric Acid Corrosion Control Program Reference Document Revision 0 Inspection and Evaluation Requirements ER-KW-BAC-101-1001

5. CAP022956 QRT Improvements for Boric Acid Evaluation 09/30/2004

Document Title Revision / Date

6. CAP024969 Boric Acid Residue on CVC-301 01/14/2005

7. CAP025692 Dry Boric Acid discovered under insulation for SI-304B 02/23/2005 Dry rust colored boric acid from packing leak on

8. CAP025694 02/23/2005 CV-21072-2

9. CAP025985 Valve RC-VREL-1 has Boric Acid on it 03/07/2005 Increase Management involvement in Boric Acid

10. CR012888 06/01/2007 Control Program Improvements needed in screening boric acid leaks for 11.CR021990 10/08/2007 repair

12. CAP016963 Boric acid corrosion improvements needed 06/18/2003 CVC-440 packing leak is high risk leak in accordance

13. CAP021581 06/16/2004 with GNP-08.06.01 for boric acid leakage Packing leak on RC-100B, boric acid is on the valve

14. CAP030233 11/22/2005 and pipe support Boric acid leakage from A RHR pump seal casing

15. CAP030959 01/18/2006 bolting

16. CAP019618 1B RHR Seal leakage 01/21/2004 Dry boric acid was found on the 30-inch flange of the

17. CAP019746 01/28/2004 letdown heat exchanger

18. CAP020969 Boric acid residue on FPC-4A body to bonnet 04/26/2004 Dry boric acid at ICS-7B valve stem, bonnet, and in

19. CR013058 06/04/2007 contact with stud White substance on wall and ceiling of waste drumming

20. CR027873 12/28/2007 room

21. CR090284 BA leak on CVC-101C top body flange 02/01/2008

22. CR090470 RHR-202 has dry boric buildup around packing gland. 02/05/2008 Moderate dry white boric acid identified at valve stem

23. CR094131 03/29/2008 for SI-15B In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.6 are consistent with GALL AMP XI.M10 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP XI.M10. The staff also verified that the applicant provided an adequate summary description of the program.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP XI.M10. A search with keywords: boric acid corrosion resulted in 120 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

The 3 program elements, corrective actions, confirmation process and administrative controls were reviewed as part of the Scoping and Screening Methodology audit. During the AMP audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M10.

The program basis document noted that Generic Letter 88-05, EPRI 1000975, "Boric Acid Corrosion Guidebook, Revision 1," November 2001, EPRI 1010087, " Materials Reliability Program (MRP): Primary System Piping Butt Weld Inspection and Evaluation Guideline (MRP-139)," 2005, and WCAP 15988, Revision 1, Generic Guidance for an Effective Boric Acid are used as reference documents for providing guidance for evaluating the severity of boric acid leakage and for determining the appropriate corrective actions. These references were cited in program elements scope of program, detection of aging effects, and acceptance criteria.

In addition, the program basis document noted that preventive actions included revising the valve packing program to improve packing techniques, performance of pre-outage walkdowns to identify those components that may require corrective maintenance, and monitoring of locations where potential leakage could occur.

The program basis document noted that for the detection of aging effects, the boric acid corrosion AMP credits the inspection opportunities afforded by other programs, including operator rounds, engineering walkdowns, inservice inspection pressure tests and inspections, operations reactor coolant system leakage monitoring, reactor containment vessel inspections, and others.

LRA AMP B2.1.7, Buried Piping and Tanks Inspection In the KPS LRA, the applicant stated that AMP B2.1.7 is an existing program that is consistent with the program elements in GALL AMP XI.M34, Buried Piping and Tanks Inspection, with an enhancement. The enhancement is related to the inspection of a representative sample of in-scope buried material/protective measure combinations through the use of opportunistic and deliberate inspections during the 10 years preceding and the 10 years following the beginning of the period of extended operation.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date Rev 1

1. KLR1327 Buried Piping and Tanks Inspection 07/22/2008

2. KO5559 Project Specification, Fuel Oils Storage Tank 03/18/1980 Rev 16

3. ES 2003 Specification for Piping Design 05/21/2007

4. WM-AA-100 Work Management Rev 0

5. CR095855 Turbine Building Sump Pump Discharge Degradation 04/17/2008

6. CR018992 INPO Performance Deficiency Cathodic Protection 08/24/2007

Document Title Revision / Date

7. CR102729 Propane Tanks Pose Hazard to ISFSI 07/08/2008

8. CR120378 Corrosion on Flanges of 10 Fire Protection Pipe 12/10/2008

9. CR145165 Containment Sump B Epoxy Coating 11/05/2004 10 ER-AA-AMP-102 Buried Piping Inspections Rev 0 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.7 are consistent with GALL AMP XI.M34 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP. The staff also verified that the applicant provided an adequate summary description of the program.

The applicant has committed to implement an enhancement affecting the parameters monitored or inspected program element. The applicant states that implementing the opportunistic and deliberate inspections to which they have committed will ensure that in scope buried components are inspected as recommended by the GALL Report. The applicant has also committed to enhance the detection of aging effects program element to require opportunistic or deliberate inspections of in scope buried components prior to a loss of their intended function. The applicant stated that the enhancements are consistent with current implementation practices, and the enhancements formally incorporate these practices into applicable implementing procedures.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.7. A search with keywords: buried piping, buried tanks, tanks and soil, piping and soil, coated piping, and coated tanks resulted in 50 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

During its audit, the staff identified three issues which required further explanation. These issues are described in the paragraphs below.

Section 1 of the AMP recommended by the GALL Report states that the program includes buried steel piping. The proposed AMP includes both steel and stainless steel piping. Written information provided by the applicant indicated that the stainless steel piping was coated or wrapped. Verbal information provided by the applicant indicated that the stainless steel piping was not coated. The staff will consider issuing an RAI to address this issue. The staffs evaluation will be documented in the SER.

Section 3 of the AMP recommended by the GALL Report states that all piping and tanks should be coated or wrapped. The proposed AMP indicates that buried uncoated steel components

are included in the AMP. The staff will consider issuing an RAI to address this issue. The staffs evaluation will be documented in the SER.

Operating experience indicates that a tritium leak has occurred at the plant. This leak has been traced to degraded epoxy joints in the drain system. This drain system is at least partially buried. The drain system is not, however, in scope for license renewal. Despite the fact that this leak occurred in buried piping, it does not constitute operating experience which can or should be applied to the in-scope buried piping system as the buried piping system does not contain epoxy joints. No RAI will be issued on this subject.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the AMP 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 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 B2.1.8, Closed-Cycle Cooling Water System In the LRA, the applicant states that AMP B2.1.8 is an existing program that is consistent with GALL AMP XI.M21, Closed-Cycle Cooling Water System, with five exceptions to preventive actions and parameters monitored or inspected. Exception 1 stated that corrosion inhibitors are not used in the Control Room Air Conditioning System because this system interconnects with the Service Water System, and periodic testing would release any inhibitors to the environment. Exception 2 stated that the applicants program used an updated revision of the EPRI Report TR-107396 recommended in GALL. Exception 3 stated that differential pressure is not monitored as part of the thermal performance testing of the component cooling heat exchangers as recommended by GALL XI.M21. Exception 4 stated that thermal performance testing is not performed for the heat exchangers included in the Component Cooling Water System cooling loop that are part of the Emergency Generator cooling water subsystem heat exchangers and lube oil coolers. Finally, exception 5 stated that air handling units and pumps in the Control Room Air Conditioning System are not performance tested as recommended in GALL XI.M21.

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

Document Title Revision/Date License Renewal AMP Basis Document - Rev. 1,

1. KLR-1321 Closed-Cycle Cooling Water System Program 08/11/2008 Rev. 7,

2. NID-01.013 Generic Letter 89-13 Program Document 02/14/2008 Rev. G,

3. NAD-01.43 Kewaunee Auxiliary Cooling Water Chemistry Program 03/22/2007

Document Title Revision/Date

4. CY-AA-AUX-301 Closed Cooling Water Chemistry Rev. 0, undated Emergency Diesel Generators Cooling Water Chemistry Rev. D,

5. CHEM-45.001 Specifications and Sampling 08/04/2005 Component Cooling Chemistry Specifications and Rev. E,

6. CHEM-46.002 Sampling 02/13/2007

7. ER-AA-HTX-10 Heat Exchanger Program Rev. 0, undated

8. ER-AA-HTX-1002 Heat Exchanger Program Visual and Leak Testing Rev. 0, undated Rev. 3,

9. NAD-01.32 Heat Exchanger Performance Monitoring 01/31/2008 Rev. B,

10. NAD-01.52 Heat Exchanger Eddy Current Program 05/27/2004 Component Cooling Heat Exchanger 1A Performance

11. SP-31-340A Orig., 08/01/2006 Monitoring Rev.15,

12. SP-31-1680A Train A Component Cooling Pump and Valve Test - IST 04/29/2008

13. MA-KW-MPM- Preventive Maintenance of Emergency Diesel Generator Rev. 3, DGM-006 Cooling System 04/20/2008 ACC - Control Room Air Conditioning Mechanical Rev. 4,

14. PMP-25-09 Inspection and Maintenance 07/19/2007 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in KPS AMP B2.1.8 are consistent with GALL AMP XI.M21 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP except for the areas that the applicant took exceptions to GALL AMP XI.M21. The staff also verified that the applicant provided an adequate summary description of the program.

The applicant took two exceptions to the preventive actions program element: (a) corrosion inhibitors are not used in the Control Room Air Conditioning Systems as recommended by the GALL AMP, and (b) the applicant implements the guidance in EPRI TR-107396, Revision 1, Closed Cooling Water Chemistry Guidelines, April 2004, in lieu of EPRI TR-107396, Revision 0, Closed Cooling Water Chemistry Guidelines, October 1997. The applicant also took three exceptions to the parameters monitored/inspected program element: (a) differential pressure is not monitored as part of the thermal performance testing of component cooling heat exchangers as recommended in the GALL AMP, (b) thermal performance testing is not performed for the heat exchangers included in the Component Cooling System cooling loop that are part of other systems or the Emergency Diesel Generator cooling water subsystem heat exchangers and lube oil coolers, and (c) the air handling units and pumps in the Control Room Air Conditioning System are not performance tested as recommended in the GALL AMP. The staff issued four RAIs requesting the applicant for additional information to justify the exceptions, and the staffs evaluation will be documented in the SER.

The staff reviewed the applicants procedure related to monitoring and control of corrosion inhibitors, comparing the applicants monitoring frequencies and limits against those recommended in the EPRI guidelines used by the applicant. The staff noted no differences between recommendations in the EPRI guidelines and the applicants procedure, except that the nitrate levels are not being monitored on a periodic basis in the component cooling water

system as specified in the EPRI document. The staff issued an RAI, and the staffs evaluation will be documented in the SER.

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

The staff also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.8. The search resulted in a review of 65 records through the use of keywords: chemistry, corrosion, cracking, stress corrosion cracking, pitting, crevice corrosion, wastage, general corrosion and cooling water. The staff screened these records, and reviewed them for relevance to the AMP in evaluating the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for 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 AMP audit, the staff compared the other 7 program elements in the applicants program and verified that these 7 elements for the AMP are consistent with those recommended in GALL AMP XI.M21, 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 B2.1.9, Compressed Air Monitoring In the KPS LRA, the applicant stated that AMP B2.1.9 is an existing program that is consistent with the program elements in GALL AMP XI.M24, Compressed Air Monitoring Program, with an exception and an enhancement. The exception is related to lack of leak testing for the station and instrument air system distribution network and the enhancement is related to the incorporation of compressed air system testing and maintenance recommendations from ASME OM-S/G-1998, Part 17, and EPRI TR-108147.

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

Document Title Revision / Date Compressed Air Monitoring, I. AMP Report: including the Revision 1

1. KLR-1324 Attachments 08/11/2008 Revision B

2. CHEM-44.001 Instrument Air and Diesel Air Start Air Quality Specification 03/22/2007

3. A Letter to NRC: Response to Generic Letter 88-14, Instrument Air Supply Revision N/A Docket No. 50-305 System Problems Affecting Safety-Related Equipment 05/22/2007

Document Title Revision / Date AS - Diesel Generator Startup Air Compressor Inspection Revision T

4. PMP-01-01 (QA-1) 05/23/2006 Revision N/A

5. CAP028456 Air Compressor G Tripped on High HP Outlet Temperature 07/19/2005 Revision N/A

6. CAP040925 Potential degradation of both station air compressors 01/23/2007 F air compressor intercooler, aftercooler and oil cooler Revision N/A

7. CR020964 excessive fouling 09/26/2007 Pinhole leak on tygon house inside of G air compressor Revision: N/A

8. CR017604 housing: to be reviewed 08/09/2007 Revision: N/A

9. CR336049 Excessive leakage on B DG startup air receivers 05/26/2009 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.9 are consistent with GALL AMP XI.M24 program elements and the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP except for the area that the applicant took an exception to GALL AMP XI.M24 and the areas that the staff may consider issuing RAIs as described below. The staff also verified that the applicant provided an adequate summary description of the program.

In the application, the applicant proposed an exception to GALL program element, Detection of Aging Effects, that would allow lack of leak testing for the station and instrument air system distribution network. The staff will review the exception and may consider issuing an RAI that requests the applicant provide additional information concerning lack of the leak testing.

The applicant has committed to implement an enhancement affecting the Detection of Aging Effect program element. The enhancement is to incorporate the compressed air system testing and maintenance recommendations from ASME OM-S/G-1998, Part 17, and EPRI TR-108147 and to identify these documents as part of the program basis. The applicant has also committed to enhance the Corrective Actions program element to require the implementation of the documents as part of the program basis. The applicant stated that the enhancement is consistent with current implementation practices, and the enhancements formally incorporate these practices into applicable implementing procedures. The staff may consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.9. A search with keywords: instrument, air or startup resulted in 367 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The

staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

The staff may consider issuing RAIs to address the following issues and the staffs evaluations will be documented in the SER:

• The technical basis references of the applicants program do not include NRC Information Notices (IN) 81-38, IN 87-28, IN 87-28 Supplement 1 or Institute of Nuclear Power Operations Significant Operating Experience Report (INPO SOER) 88-01.

• In the applicants chemistry procedure for air quality control, CHEM-44.001 Rev. B, Instrument Air and Diesel Air Start Air Quality Specification, dated March 22, 2007, the inspection frequency for dew point is once a year as described in Section 5.3 of the chemistry procedure. In contrast, the ANSI/ISA-7.0.01-1996, which is one of the applicants technical references, recommends shift monitoring for pressure dew point if a monitored alarm is not available. In addition, Section 5.3 of the applicants procedure does not specify any Action Level for hydrocarbon content or particulate size, while the Action Level for the dew point is 22 °F.

• The element, Parameters Monitored/Inspected, of the GALL Report program recommends that inservice inspection and testing be performed to confirm that maintenance practices, emergency procedures and training are adequate to ensure that the intended function of the air system is maintained. However, the reference section of the applicants program document did not clearly refer to relevant references for emergency procedures, training or training schedules.

• The exception regarding lack of leak testing for the station and instrument air system distribution network is in apparent conflict with the technical basis references cited for the enhancement of the program as the technical basis references recommend leak tests.

• The staff found that the applicants program documents do not clearly indicate whether the applicants program established acceptance criteria for some parameters of the compressed air systems such as compressor load and unload times, minimal operational time for backup accumulators upon loss of the main air system, and Inlet and outlet coolant temperatures of the coolant in the compressor intercoolers and aftercoolers.

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 AMP XI.M24, not including the exception 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 B2.1.10, External Surfaces Monitoring In the Kewaunee LRA, the applicant stated that AMP B.2.1.10 is an existing program that is consistent with the program elements in GALL AMP XI.M36, External Surfaces Monitoring, with two enhancements. The applicant, through this program, will monitor corrosion also of non-carbon steel metals and degradation of elastomers. The applicant takes no exception from deviating the program from GALL. The program has two enhancemets. The first enhancement addresses the inspection of infrequently accessed areas of the KPS, the second deals with specific to AMP training of the inspection personnel.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date Revision 1

1. KLR-1334 External Surface Monitoring AMP Technical Report 07/22/2008 Dominion Nuclear Fleet Guidance and Reference Revision 6

2. OP-AA-100 Document, "Conduct of Operations" Latest Issue Dominion Nuclear Fleet Guidance and Reference Revision 1

3. ER-AA-SYS-1002 Document, "System Engineering Walkdowns" Latest Issue Dominion Nuclear Fleet Guidance and Reference Revision 1

4. ER-AA-SYS-1004 Document, "System Engineering Handbook" Latest Issue Dominion Nuclear Fleet Technical Procedure, Radiation Revision 0

5. RP-AA-222 Protection, Radiation Surveys Latest Issue Dominion Nuclear Fleet Guidance and Reference Revision 2

6. MA-AA-1002 Document, "Leakage Management" Latest Issue Revision 2

7. KLR-1101 Material Aging Effects Technical Report (MAER) 08/06/2008 Final Report

8. 1007933 Aging Assessment Field Guide, Altran Corp. and EPRI 12/2003

9. KEWA-CR021676 Iso-phase PT fuses have corrosion on ferrells 10/05/2007

10. KEWA- Copper air line by valve IA-870 touching/rubbing all-thread 04/17/2008 CR096094 hanger

11. KEWA-Found instrument air line w/corrosion at the clamping points 04/20/2007 CR160656

12. KEWA-Corrosion found during the rebuild of FW-7a and FW-7B 04/14/2003 CR137164

13. KEWA- Stainless Steel piping is in contact with carbon steel 07/24/2007 CR016587 support

14. KEWA- Corrosion on steel surfaces on the Shield Building 04/08/2008 CR094995 equipment hatch blocks

15. KEWA- Corrosion and coating issues for the column and 10/27/2008 CR116142 anchorages at column line 1A

16. KEWA- Service water piping on turbine generator cooler needs 02/17/2009 CR324557 painting

17. KEWA- Request to clean and coat corroded surfaces on 12/16/2008 CR317109 penetration collars 18.CAP-000209 Penetration 478, CC Pump B Room, is degraded 01/15/2002

Document Title Revision / Date

19. KEWA- TSC HVAC Return Air Fan has a degraded ventilation 07/19/2007 CR016288 connection boot Coating on A MB Denim, peeled away and fallen

20. CAP-034745 06/24/2006 downside of demin

21. KEWA-License Renewal Changes to GNP-03.30.02 09/11/2006 CR155897 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.10 are consistent with GALL AMP XI.M36 program elements not including the program elements in which the staff felt additional clarification might be warranted as discussed below. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL. The staff also verified that the applicant provided an adequate summary description of the program.

In the application, the applicant proposed to use this AMP and inspect carbon steel, other metallic materials (stainless steels, copper, aluminum), and elastomers. The applicant identified only a small number of elastomers to be monitored under this AMP. These are limited to the following elastomer materials/systems, structures, and components combinations:

• Flexible connections-ventilation ducting

• Flexible hoses in liquid waste processing and discharge

• Shield building penetration seals The applicant stated that the addition of the aforementioned materials (other than carbon steel) to the program is not something new. The applicant has used this approach long before it became an AMP. The applicant instead considers the addition of these materials as a benefit to the overall External Surface Monitoring program. The applicant further stated that it does not plan to have the program credited for managing the aging of the internal surfaces of systems or components.

The staff verified through an interview all listed material commodities in B2.1.10, related to piping, piping components, ducting, and other components and relevant to systems, structures, and components (SSCs), will only be visually inspected. The applicant will perform no other supplementary testing or other forms of inspection. The applicant will repair or replace the SSCs, when their intended functions are diminished or lost.

The applicant proposes two enhancements to the program. The first enhancement, affects the scope of the program and parameters monitored or inspected of infrequently accessed areas. The applicant intends to fulfill program element 1 by visually inspecting the infrequently accessed areas (e.g., due to elevated or residual radiation) for corroded surfaces of in-scope components, piping, supports, structural members, and identified structural commodities. The applicant identified these areas to be the Auxiliary Building and Turbine Building emergency oil sump. Inspection in these areas will be in accordance with program element 3, Parameters Monitored/Inspected, of the XI.M36 AMP External Surface Monitoring program. The applicant verified that this inspection commitment will be administered prior to license renewal, at which time the applicant will determine whether this needs to be a reoccurring inspection.

The applicant suggests a second enhancement to the External Surfaces Monitoring program.

This program enhancement deals with element 5, Monitoring and Trending. To ascertain efficient management of aging related to the corrosion of external surfaces, the applicant intends to train the inspectors who are tasked with this AMP. The staff verified that this inspection commitment will be honored prior to extended operation. The applicant will offer the training to the inspecting personnel as necessary, without requiring further certification. The training will help inspectors to uniformly track and identify potential corrosion of relevant SSC material commodities before the assets loose their ability to perform their intended functions.

The applicant plans to use reference 8 to supplement the training curriculum.

The staff also conducted an independent search of the applicants condition report database and reviewed applicant supplied corrective action reports for operating experience relevant to AMP B.2.1.10. Word searches for: (i) keywords: leak, corrosion, degradation, rust, penetration and (ii) word combinations: stainless steel crack, steel corrosion, loss of material, surface corrosion and (iii) for commodities: aluminum, copper, elastomers yielded numerous hits.

Interestingly copper was the most prevalent commodity to yield results. By contrast aluminum and SS yielded the least hits. This confirmed staffs concerns that corrosion in these commodities is hard to visually track and identify.

The search verified the high awareness of the applicant to manage the External Surface Monitoring AMP. It also showed that although the applicant tracks and monitors SSCs and commodities for corrosion, and defines the need for corrective actions, depending on their significance, repairs/replacements may be delayed. The applicant by en large, performs repairs/replacements of the ailing SSCs/commodities before they stop being functional. Some work orders, however, are completed at the outset of corrosion inhibition based on cost/benefit analyses. In case of an imminent danger, however, the applicant takes immediate actions to assure safety of the plant (see audited reference 18) is maintained.

The staff considers issuing three RAIs. The first two RAIs will address program element 1, Scope of the Program. The first RAI affirms to the applicant the approach of adding metallics, other than steel, and elastomers to this AMP constitutes an exception to the GALL. The focus of the first RAI is to determine how the applicant expects to supplement this visual inspection program with techniques identifying difficult to visualize critically oxidized other than steel metallic commodities, as for example, aluminum, stainless steels, and waxy elastomers. The RAI will request the applicant to provide additional information concerning alternative detection techniques and justification for using these techniques. Any proposed alternative detection techniques, which may be used instead of, or in addition to the visual inspection will then be reviewed.

The second RAI, focuses on the use of the language by the applicant stating that the aging effects of change in material properties, cracking, delamination, loss of material, and hardening and loss of strength in SSCs will be accomplished through visual inspections. The staff noted the LRA used phraseology on material properties demands the applicant to perform hands-on testing. On this basis, the staff requests the applicant to provide information of how they plan to obtain change[s] in material properties, through visual walkdown inspections.

The third RAI spotlights program element 4, Detection of Aging Effects. The applicant uses an areas/sampling approach to define how they are going to inspect KNPP SSCs for

rust/corrosion. The staff noted to the applicant the XI.M36 program is not a sampling program.

Since sampling is allowed, however, by GALL, the staff requests the applicant to provide the basis for sampling. The staff will review all of the applicant's responses. The staffs decisions as to the acceptability of the responses 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 AMP 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 AMP XI.M36, not including any exceptions or enhancements 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 B2.1.11, Fire Protection In the KPS LRA, the applicant stated that AMP B.2.1.11 is an existing program that is consistent with the GALL AMP XI. M26, Fire Protection and XI.M27 Fire Water System program elements, with one exception and three enhancements. The exception is to functionally test the Halon system annually with a supplemental level measurement on a 6-month cycle. In addition, two of the CO2 fire suppression sub-systems are inspected / tested every 18 months during refueling outage. The rest of the CO2 fire suppression system is inspected and tested semiannually. The enhancements are related to testing and/or replacement of the sprinkler heads per NFPA 25, incorporating the elastomer Shield Building fire boots into the fire barrier penetration seal inspections, and including inspection the reactor coolant pump oil collection system receiver for corrosion, and performing a one-time inspection of the internal surfaces of the reactor coolant pump oil collection tank.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date License Renewal Project Aging Management Revision 2

1. Technical Report: KLR-1325 Program - Fire Protection 05/26/2009

2. KPS Chemistry Procedure Revision D CHEM-43.0111 Fire Protection System Chemical Treatment 09/25/2005

3. KPS Mechanical Preventive 1 Safeguards Alley Preaction Sprinkler System Revision 0 Maintenance Procedure MA-KW-Testing MPM-FP-001

4. KPS Mechanical Preventive Main Auxiliary Transformer Deluge Fire System Revision 0 Maintenance Procedure MA-KW-Wet Test MPM-FP-006A 1

KPS is in the process of transitioning from designating the procedure with an effective date and revision number to a system with only revision number and no effective date. This is the reason why some procedures have both effective date and revision number while others only carry a revision number.

Document Title Revision / Date

5. KPS Mechanical Preventive Main Auxiliary Transformer Deluge Fire System Revision 0 Maintenance Procedure MA-KW-Dry Test MPM-FP-008A

6. KPS Mechanical Preventive Revision 1 Maintenance Procedure MA-KW- Hose House and Hydrant Inspection MPM-FP-002

7. KPS Mechanical Preventive Revision 0 Maintenance Procedure MA-KW- Fire Hydrant Flow Test MPM-FP-003

8. KPS Mechanical Preventive Inspection and Flush of Plant Hose Stations Revision 0 Maintenance Procedure MA-KW-and Inspection of Floor Drains MPM-FP-005

9. KPS Preventive Maintenance FP - Sprinkler System Inspection and Alarm Revision R Procedure PMP-08-10 Test 04/19/2007

10. KPS Mechanical Preventive Containment Purge Exhaust Fan Charcoal Revision 11 Maintenance Procedure MA-KW-Filter Heat Detector Test 04/09/2009 MPM-FP-025

11. KPS Preventive Maintenance Revision 4 FP - Fire Pump A Flow Test Procedure PMP-08-31A 08/07/2008

12. KPS Surveillance Procedure Revision 35 Fire Pump Test SP-08-081 04/28/2009

13. KPS General Nuclear Service Water and Fire Inspection Program Revision 5 Procedure GNP-01.09.01 Coordination 05/05/2009

14. KPS General Nuclear Service Water and Fire Protection System Revision 1 Procedure GNP-01.09.02 Through Wall Leakage Integrity Program 04/21/2009

15. Nuclear Fleet Guidance and Revision 8 Reference Document WM-KW- Work Management Process 100-1001

16. KPS Mechanical Preventive CO2 System (Cardox) Dry Test for Records Revision 1 Maintenance Procedure MA-KW-Storage Room MPM-FP-009A

17. KPS Mechanical Preventive Inspection and Dry Test of CO2 System for Revision 1 Maintenance Procedure MA-KW-Diesel Generator Room 1A MPM-FP-030A Revision 14

18. KPS Preventive Maintenance FP - Halon System Inspection and Testing 08/18/2008 Procedure PMP-08-23 Revision 14

19. KPS Preventive Maintenance FP - Penetration Fire Barrier Inspection 07/01/2008 Procedure PMP-08-33 Revision 17

20. KPS Preventive Maintenance FP - Inspection of Plant and Fire Doors 02/08/2008 Procedure PMP-08-19 Revision 9

21. KPS Fire Plan Procedure FPP-Appendix R Fire Wrap Inspection 04/07/2009 08-15 Revision 21

22. KPS Preventive Maintenance RC - Reactor Coolant Pump Motor Electrical 01/15/2008 Procedure PMP-36-02 Maintenance (QA-1)

Appendix A Fire Penetration Barrier Inspection

23. CR104438 07/24/2008 Deficiencies

Document Title Revision / Date Unqualified Appendix R Penetration Seal -

24. CR025823 11/29/2007 PEN752

25. CR135294 Degraded Appendix R Penetration 12/05/2002

26. CR136631 Appendix R Barrier Degraded 03/14/2003

27. CR108085 Fire Barrier Inspection 09/03/2008

28. CR108387 Fire Penetration Barrier Inspection 09/05/2008

29. CR155269 2006 Summer Zebra Mussel Treatment Results 08/03/2006

30. CR167725 2006 Post Outage Zebra Mussel Treatment 10/19/2006

31. CR018574 2007 Summer Zebra Mussel Treatment Results 08/24/2007 2007 End of Season Zebra Mussel Treatment

32. CR022607 10/17/2007 Results for Service Water System

33. CR101957 Improving Control of Zebra Mussel Population 06/11/2008

34. CR105901 2008 Summer Zebra Mussel Treatment Results 08/13/2008 2008 End of Season Zebra Mussel Treatment

35. CR116629 11/29/2008 Results for Service Water System CO2 Hose Reel #1Had Degraded or Damaged

36. CR107160 08/26/2008 Outer Jacking FP - CO2 System (Cardox) Dry Test on Relay

37. CR144666 10/17/2004 Room Equipment Failures No PM for Halon Fire Protection System in the

38. CR163810S 08/31/2005 Substation Control House Substation Control House Fire Detection

39. CR142523 05/13/2004 Failure Fire Suppression System Found to Be

40. CR146146 01/19/2005 Ineffective during PPCS Replacement Project Radiography Determines Pitting Occurring in

41. CR140252 11/11/2003 SW Supply to DG Hxs Turbine Building Standpipe and nearby Piping

42. CR147339 03/10/2005 Severely Degraded Corrosion on Flanges of 10 Fire Protection

43. CR120378 11/26/2008 Pipe In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B.2.1.11 are consistent with GALL AMPs XI.M26 and XI.M27, program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP except for the areas that the applicant took exceptions to GALL AMPs XI.M26 and XI.M27. The staff also verified that the applicant provided an adequate summary description of the program.

The GALL Report recommends the diesel-driven fire pump be periodically tested to ensure the fuel supply line can perform the intended function. Kewaunee does not have a diesel-driven fire pump. Hence, this recommendation is not applicable to the KPS LRA. The GALL Report recommends approximately 10% of the penetration seals be visually examined at least once every refueling outage. The applicant visually inspects 100% of the penetration seals at the present time. However, going forward, the applicant stated that they plan to examine only 20%

of the seals that fulfill the 10 CFR Part 50 Appendix A function every 18 months. The penetration seals that fulfill the Appendix R requirements will still be inspected 100% every 18 months. The penetration seals and other fire barriers (e.g., doors, fire wraps, walls, ceilings,

etc.) are inspected per plant procedures (References 19 - 21.) Although fire wrap is not specifically included in the GALL AMP XI.M26, the applicant nevertheless visually inspects the fire wraps as a part of the fire barrier inspections.

The GALL Report recommends periodic flushing and inspection of the water-based fire protection system to ensure no significant corrosion, MIC, or bio-fouling. The applicant injects a non-oxidizing biocide to the fire water system to minimize the growth of micro- and macro-organisms (Ref: Document 2). KPS visually inspects the internals of the water-based fire protection system during maintenance activities when the system is opened. Further non-destructive examinations may be necessary if the initial visual inspections indicate causes of concern (Ref: Documents 13 and 14).

In the application, the applicant proposed an exception to the GALL program element Monitoring and Trending. Under this exception, the applicant plans to functionally test its relay room and turbine bearing CO2 fire suppression systems every 18 months during the refueling outage; other CO2 systems are tested semi-annually. The Halon systems are functionally tested annually. The GALL Report recommends a 6-month inspection and testing frequency for both the Halon and CO2 fire suppression systems. The staff will review this exception and will consider issuing an RAI to explain why the extended interval of functional testing is justified based on the plant operating experience.

The applicant also committed to implement three enhancements to the Fire Protection and Fire Water System AMPs. The first enhancement is to replace or test a representative sample of the sprinklers after 50 years of service in accordance with the National Fire Protection Association (NFPA) 25 the Inspection, Testing, and Maintenance of Water-Based Fire Protection Systems (2002), Section 5.3.1.1.1. This enhancement affects program element 4 detection of aging management. Staff reviewed this enhancement and concluded it was acceptable because it will make the applicants program consistent with the GALL AMP XI.M27 recommendation.

Under the second enhancement, the applicant stated that it planned to include some elastomer Shield Building fire boots to the fire barrier penetration seal inspection program. According to the applicant, these silicone-impregnated neoprene fire boots are being inspected. However, they are not specifically called out in the procedure (Ref: Document 19.) This enhancement affects program element 3 parameters monitored/inspected, and element 4 detection of aging effects. Visual inspection of penetration seals is an integral part of the fire barrier inspection in the GALL XI.M26 Fire Protection AMP. The implementation of this enhancement should improve the overall effectiveness of the fire barrier inspection. Thus, the staff finds the applicants enhancement acceptable because it will make the applicants program consistent with GALL XI.M26 Fire Protection AMP.

The applicant stated that the third enhancement pertained to (i) adding one more criterion (inspecting for corrosion) to the current reactor coolant pump oil collection system receiver inspection program (Ref: Document 1, pp 40 - 41), and (ii) performing a one-time inspection of the internal surfaces of the oil collection tank. The applicant stated that the one-time inspection was not the XI.M32 One-Time Inspection. The reactor coolant pump oil collection system is required under the 10 CFR Part 50, Appendix R. The GALL Report XI.M26 does not have any specific recommendation regarding the reactor coolant pump oil collection system. However, the GALL Report recommends the XI.M39 Lubricating Oil Analysis, and XI.M32, One-Time

Inspection AMPs (Ref: VII-G-26 and VII-G-27 on p. VII G-8 of the GALL Report, volume 2) for the material (steel) and environment (lubricating oil) combination. The staff will review this enhancement and consider issuing an RAI requesting why this enhancement is not in alignment with the GALL Report recommendation.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to XI.M26 and XI.M27 AMPs. A search with key words; pipe thinning, corrosion, MIC, zebra mussels, fire barriers, penetration seals, Halon, and CO2, resulted in approximately 180 hits. The staff screened these results for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review.

The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for the AMPs.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the AMP 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 AMP XI.M26 and XI.M27, 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 B2.1.12, Flow-Accelerated Corrosion In the KPS LRA, the applicant stated that AMP B2.1.12 is an existing program that is consistent with the program elements in GALL AMP XI.M17, Flow-Accelerated Corrosion, with an exception. The exception is related to using revision 3 of the EPRI guidance document as opposed to using revision 2, as recommended in the GALL Report.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. Technical Report License Renewal Project Aging Management Program Revision 1 KLR-1317 Flow-Accelerated Corrosion Program 07/22/2008

2. Program Description Flow-Accelerated Corrosion Program Rev 0 ER-AA-FAC-10

3. Guidance and Flow-Accelerated Corrosion Susceptibility Analysis &

Reference Document Rev 0 Modeling ER-AA-FAC-1001

Document Title Revision / Date

4. Guidance and Flow-Accelerated Corrosion Inspection and Evaluation Reference Document Rev 1 Activities ER-AA-FAC-1002

5. Guidance and Flow-Accelerated Corrosion Operational Experience Reference Document Rev 1 Reviews ER-AA-FAC-1003

6. Guidance and Reference Document Crossover/Crossunder Inspection & Evaluation Activities Rev 0 ER-AA-FAC-1004 OEA 99-063 Callaway 6-inch drain line from D moisture st

7. CAP008707 separator reheater 1 stage drain tank to 6B HP 05/21/2001 feedwater heater Wall thinning in 20-inch condensate piping below Code

8. CAP023687 10/29/2004 minimum.

Wall thinning in 16-inch CD line from C14B to 14B GW

9. CAP 037145 09/13/2006 heater.

10. CAP037450 Shell thinning identified in FW heaters 14A &14B. 09/20/2006

11. CAP020926 Pipe thinning calculations and configuration control. 04/22/2004 Wall Thinning on 20-inch Condensate Supply to FW

12. CAP023508 10/23/2004 pumps.

1987 Commitments re: FAC piping inspection

13. CAP026916 04/19/2005 frequencies. Programmatic issues SW pipe thinning 1/2-inch lines for SW coolers C & D 14 CAP033709 05/10/2006 bypass lines.

Wall thinning found in SG Blowdown Heat Exchanger

15. CAP036791 09/06/2006 1A1 Condensate return line.

Wall thinning found in piping components in A & B FW

16. CAP 037051 09/11/2006 Pump recirculation lines.

17. FAC 2008RO Kewaunee, 2008 Refueling Outage Results of Flow 12/03/2008 Outage Report Accelerated Inspection Program Discrepancies in CHECWORKS, flow accelerated

18. CAP031121 01/27/2006 corrosion program predictive model No new CAPs were generated upon completion of FAC

19. CAP031127 01/27/2006 program GAP analysis in December 2005 Duplicate and out of date procedures in effect for the

20. CAP031123 01/27/2006 FAC program Incomplete status of evaluation/review of FAC

21. CAP031124 02/08/2006 component inspections In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.12 are consistent with GALL AMP XI.M17 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP except for the areas that the applicant took exceptions to GALL AMP XI.M17. The staff also verified that the applicant provided an adequate summary description of the program.

In the application, the applicant proposed an exception to GALL program elements scope of program and detection of aging effects by using EPRI NSAC-202L, Revision 3, Recommendations for an Effective Flow-Accelerated Corrosion Program. This is in contrast to

GALL AMP XI.M17, which recommends using revision 2 of EPRI NSAC-202L. The applicant justified this exception by noting that revision 3 contains recommendations updated with recent experience, and developments in detection, modeling and mitigation technology. The applicant also stated that these recommendations refine and enhance the recommendations from earlier versions without contradiction, to ensure continuity of existing FAC programs.

According to the applicants program basis document, some basic differences between revision 3 and revision 2 of NSAC-202L are:

• Revision 3 augmented Revision 2 by applying safety factors in ranking risks,

• Revision 3 enhanced sample selection for modeled lines by providing more clarification and details,

• Revision 3 added guidance for using plant and industry experience in selecting inspection locations and location of re-inspections,

• Revision 3 clarified the inspection techniques for ultrasonic testing and radiographic testing,

• Revision 3 enhanced the guidance for inspection of vessels, tanks, valves, orifices and equipment nozzles,

• Revision 3 added sections for use of radiographic testing to inspect large-bore piping, inspection of turbine cross-around piping and inspection of valves.

Based on the above information, the applicant concluded that the use of EPRI NSAC-202L, Revision 3, is equivalent to NSAC-202L, Revision 2 and meets the intent of NUREG-1801,Section XI.M17. The staff will review the exception and may consider issuing an RAI that requests the applicant provide additional information concerning the use of EPRI NSAC-202L, Revision 3.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.12. A search with keywords: flow-accelerated corrosion resulted in 70 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for 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 AMP 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 AMP XI.M17, not including the exception identified by the applicant in the LRA for this AMP, which will be evaluated separately in the SER.

LRA AMP B2.1.13, Flux Thimble Tube inspection In the KPS LRA, the applicant stated that AMP B2.1.13 is an existing program that is consistent with the program elements in GALL AMP XI.M37, Flux Thimble Tube Inspection Program.

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

Document Title Revision / Date

1. KLR-1335 Revision 1 Flux Thimble Tube Inspection, I. AMP Report 06/22/2008 Revision N/A

2. WCAP-12866 Bottom Mounted Instrumentation Flux Thimble Wear 01/1991

3. WO# 03-011955 / Eddy Current Incore Thimbles per COMTRAK 92-110: Revision N/A PM50-032 Thimble Tube Eddy Current Inspection 10/29/2003 Eddy Current Incore Thimbles per COMTRAK 92-110:

4. Preventive Work Revision N/A Including Thimble Tube Inspection Evaluation Report Order 03-011955-000 11/21/2004 (11/26/2004)

CAPADMIN Revision N/A

5. CAP001444 (Note: Evaluation of COMTRAK 92-110 for requirement to 09/25/2001 perform PM50-032 during 1R25 outage)

Revision N/A

6. CAP022869 Thimble Tube Eddy Current Inspections 09/24/2004 Incore Flux Thimble Tube Eddy Current Inspection Results Revision N/A

7. CAP024164

- R27 11/22/2004 RF-04.08, Incore Flux Thimble Tube Insertion Procedure Revision N/A

8. CR137558 Weakness 04/29/2003 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.13 are consistent with GALL AMP XI.M37 program elements and the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP except the areas that the staff may consider issuing RAIs as described below. The staff also verified that the applicant provided an adequate summary description of the program.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.13. A search with keywords: flux, thimble and tube. resulted in 72 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff

verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP except for the areas described below.

The staff may consider issuing RAIs to address the following issues and the staffs evaluations will be documented in the SER:

• The LRA and related on-site program documentation did not clearly address how the program manages discrepancies between projected wear rates and measured wear rates.

• The LRA did not clearly indicate that the results of the inspections performed in 2000 and 2004 demonstrate the adequacy of the program-defined inspection frequency and wear projection methodology.

• The section for the program element, Acceptance Criteria, in the on-site technical report, KLR-1335, Revision 1 indicated that the acceptance criterion of 80% through-wall wear requires the repositioning and isolation of the thimble tube. The report also stated that the 80% criterion was first used in 2004 and differs from the 60% limit discussed in the applicants response to Bulletin 88-09. The new acceptance criteria related with 80

% wall wear need to be justified.

• In the applicants response to NRC Bulletin 88-09, dated November 7, 1988, the applicant stated that the examination frequency after 1998 will be dependent on the results of the previous two tests. However, it is not clear whether the applicants approach to define the exponent for wear rate projections considers plant-specific inspection results. The staff also found a need to clarify whether the program adequately manages the potential effect of hardware and flow rate changes on the thimble tube wear rates.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the AMP 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 AMP B.2.1.13, not including the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.1.14, Fuel Oil Chemistry In the KPS LRA, the applicant stated that AMP B2.1.14 is an existing program that is consistent with the program elements in GALL AMP XI.M30, Fuel Oil Chemistry, with exceptions. The exception is related to sampling methods of fuel oil, the use of one ASTM standard in-lieu of another, not using fuel oil additives and to the use of Standard Technical Specifications.

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

AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. Technical Report License Renewal Project Aging Management Program: Revision 1 KLR-1329 Fuel Oil Chemistry 07/22/2008 Standard Test Method for Free Water and Particulate

2. ASTM D4176-04 Contamination in Distillate Fuels (Visual Inspection N/A Procedures)

Nuclear Fleet: Administrative Procedure: Diesel Fuel Oil

3. CY-AA-AUX-310 Revision 0 Sampling and Testing Revision 23

4. SP-10-225 Surveillance Procedure: Diesel Fuel Oil Sampling 02/12/2008 Preventative Maintenance Procedure: DGM - Fluid Revision 15

5. PMP-10-02 Samples 01/27/2009 Preventative Maintenance Procedure: DGM - DGM TSC Revision 3

6. PMP-10-13 Diesel - Fluid Samples 02/26/2009 Revision A

7. CHEM-15.001 Chemistry Procedure: Diesel Fuel Oil Flash Point 03/25/03 Revision A

8. CHEM-15.002 Chemistry Procedure: Diesel Fuel Oil Density 03/25/03 Revision A

9. CHEM-15.003 Chemistry Procedure: Diesel Fuel Oil Water and Sediment 03/25/03 NRC IN 2009-02, Biodiesel in Fuel Oil Could Adversely

10. CR327396 03/18/2009 Impact Engine Perf Investigate and determine the feasibility of purchasing and

11. CA135102 03/18/2009 using test equipment - (this is in relation to IN 2009-02)

Review NRC IN 2009-02, Biodiesel in Fuel Oil Could

12. CA131564 03/18/2009 Adversely Impact Engine Perf

13. Product Info Wilks Enterprise Inc. Biofuels Analyzers N/A

14. CAP041525 KPS Delivery of Ultra Low Sulfur Diesel (ULSD) fuel 02/07/2007

15. CA032296 Ultra Low Sulfur Diesel (ULSD) fuel chemistry issues 06/07/2007

16. CA032303 Evaluate ULSD for use with TSC Diesel 06/08/2007

17. Attachment to Ultra Low Sulfur Diesel Evaluation CA032303 (TSC DG) 06/10/2007 CA032303 PMP 10-02 does not cover TSC Diesel Generator day tank

18. CAP000378 12/13/2001 fuel oil inspections

19. CAP000727 Chemistry, Emergency diesel generator fuel oil 11/21/2001

20. CAP006299 Diesel fuel oil out of specification 11/24/1997 Diesel Fuel Oil Testing Program Vendor Laboratory

21. CAP043134 contract needs revision (ULSD, biological activity, timely 03/21/2007 report of results)

22. CAP039321 Documented Sediment found when sampling B EDG Fuel 11/12/2006 Apparent Cause Evaluation: Documented Sediment found

23. ACE003345 11/15/2006 when sampling B EDG Fuel Enhancement of cleanliness of EDG B fuel oil tank sample

24. CAP040574 01/12/2007 access flange

25. CAP044152 Foreign material found in 1A diesel generator fuel sample 04/24/2007

Document Title Revision / Date

26. Attachment to Ultra Low Sulfur Diesel Evaluation CA029658 (EDG) 08/21/2007 CA029658

27. Laboratory Herguth Laboratories, Inc. Certificate of Analysis - New 10/2008 through Results Fuel Shipment Results 02/2009 Herguth Laboratories, Inc. Certificate of Analysis -

28. Laboratory 08/2008 through Quarterly Lab Results from August 2008 to April 2009 for Results 04/2009 A and B EDG storage tank and TSC storage tank 07/31/2003 02/12/2002

29. PMP-10-02 Diesel Generator A Fluid Sample Data Sheet 01/08/2002 02/11/2001 08/26/2004

30. PMP-10-02 Diesel Generator B Fluid Sample Data Sheet 02/14/2002 04/14/2004

31. PMP-10-13 TSC Diesel Generator Fluid Sample Data Sheet 11/22/2002 Work Order - Remove the in service fuel strainer and filter

32. KW07-000198 02/08/2007 on 1B EDG (related to CAP040574)

Work Order - Remove accumulated corrosion products

33. KW07-000171 from the fill flange - 1B EDG fuel oil storage tank (related 07/23/2008 to CAP040574)

In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.14 are consistent with GALL AMP XI.M30 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP except for the areas that the applicant took exceptions to GALL AMP XI.M30. The staff also verified that the applicant provided an adequate summary description of the program.

In the application, the applicant proposed exceptions to GALL program elements Scope of Program, Preventative Actions, Parameters Monitored/Inspected, Detection of Aging Effects and Acceptance Criteria. The applicants exceptions consisted of performing fuel oil purity activities as part of plant-specific procedures, not utilizing fuel oil additives, utilizing one ASTM standard in-lieu of another and not performing multi-level sampling for diesel fuel oil day tanks only. The staff will review the exceptions and may consider issuing RAIs that request the applicant provide additional information and justification for taking these exceptions to the recommendations of GALL AMP XI.M30.

The staff reviewed laboratory results of fuel oil samples from the diesel fuel oil storage tanks, from August 2008 to April 2009. The results of the laboratory tests indicate that particulate contamination and water and sediment were within acceptable limits of 10mg/L for particulates and < 0.05% for water and sediment. The results also indicated that the acceptance criteria of all other parameters specified in the applicants procedures were met. The staff also reviewed laboratory results of samples taken from the new fuel oil shipments, and these results also indicated that the fuel met all applicable acceptance criteria. Furthermore several results from the monthly samples taken from the bottom of the EDG and TSC DG day tanks were reviewed, which indicated no visual indication of water or sediment.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.14. A search of keywords: fuel oil, sulfur and biodiesel resulted in a review of over 100 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

During this search, the staff found a condition report (CR327369) that was initiated by the applicant to address Information Notice (IN) 2009-02, Biodiesel in Fuel Oil Could Adversely Impact Diesel Engine Performance. The staff reviewed this condition report and interviewed the applicants technical staff which indicated that this issue is currently being addressed and a possible solution would be a portable device that can detect if the fuel oil is bio-diesel during new fuel shipments. The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The applicant investigated a September 2006 fuel oil shipment that contained ~14000 gallons of Ultra Low Sulfur Diesel (ULSD). The applicant entered this into their corrective actions program and as part of the resolution evaluations were performed to determine the acceptable use of ULSD in the EDG and TSC DG. This condition report directed that the long-term issues (compatibility with lube oil, elastomers, storage tank interior surfaces and long-term fuel storage) and short-term issues (heat content and lubricity) be evaluated. The staff reviewed the applicants evaluation and noted that the conclusion was made that ULSD is acceptable for use in the EDG and TSC DG after consideration of the long-term and short-term issues with using ULSD.

The staff noted that in July 2008 the applicant completed its cleaning activities of removing corrosion products from the fill flange on the 1B EDG fuel oil storage tank as part of Work Order KW07-000171. This work order was performed to address the evaluation in CAP040574. This operating experience was documented in the LRA, and the staff confirmed during its audit that the applicant completed its corrective actions to remove the corrosion products and to minimize corrosion products falling into the tank during cleaning activities.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the AMP 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 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 B2.1.15, Fuel Oil Tanks Inspections In the KPS LRA, the applicant stated that AMP B2.1.15 is an existing program that is consistent with the program elements in GALL AMP XI.M30, Fuel Oil Chemistry, with an enhancement.

The enhancement is related to formalizing procedures of current preventative maintenance work orders to inspect the internals of the fuel oil storage tanks.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. Technical Report License Renewal Project Aging Management Program: Fuel Revision 1 KLR-1326 Oil Tank Inspections 07/22/2008

2. Specification Project Specification - Technical Support Center Fuel Oil 03/18/1980 K05559 Storage Tank D/G Fuel Oil Storage Tank A, Insp and Clean (Preventative

3. PM10-050 N/A Maintenance Work Order)

D/G Fuel Oil Storage Tank B, Insp and Clean (Preventative

4. PM10-052 N/A Maintenance Work Order)

Inspect/Clean Tank (TSC) (Preventative Maintenance Work

5. PM10-664 N/A Order)

(Tank Inspection Report for A and B EDG Storage Tanks)

6. 10/2001 Fuel Maintenance, L.L.C., Petrocon AQI/PCR Division Evaluation of Gouges in Shell of Diesel Generator

7. Calc/Eval: Revision 0 Underground Fuel Oil Storage Tank - Stevenson &

01Q0273-C-001 11/20/2001 Associates Tank Cleaning and Inspection Report TSC DFO Tank, Fuel 8.

Maintenance, L.L.C., 07/21/2002

9. CAP001280 A DG Fuel Tank Wall Damage 10/08/2001 10.CAP000210 TSC Fuel Oil Tank Cleaning 01/15/2002 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.15 are consistent with GALL AMP XI.M30 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP. The staff also verified that the applicant provided an adequate summary description of the program. However the staff noted one concern related to the scope of program element. The staff noted that the fuel oil day tanks were not in scope of this program, but rather they were in scope of the applicants Work Control Process. The staff was unable to establish the type of activities that are performed for the fuel oil day tanks. The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER.

The applicant has committed to implement an enhancement affecting the preventative actions and detection of aging effects program elements. The staff noted that this enhancement will provide guidance for periodic draining, cleaning and inspection activities. The staff noted that the applicant currently cleans and inspects the fuel oil storage tanks based on a preventative

maintenance work order, so currently there are no formal procedures. The staff noted that the enhancement is consistent with the work orders, and the enhancement will formally incorporate these practices into procedures. The staff further noted that these activities are consistent with recommendations provided in GALL AMP XI.M30.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.15. A search of keywords: fuel oil, storage tanks and tank inspection resulted in a review of over 100 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

The staff noted that in October 2001 the applicant performed a cleaning and inspection of the EDG fuel oil storage tanks. The staff reviewed the results of these inspections and noted that the A EDG fuel oil storage tank had 7 gouge locations on the shell and 8 gouge locations on the shell of the B EDG fuel oil storage tank. The applicant entered the discovery of these gouges in its corrective actions program. The results of the inspection noted that these gouges were made during original construction. The applicant evaluated the gouges in the shell of the EDG fuel oil storage tanks and it was concluded that maximum increased stress from the gouges does not exceed the allowable stress limit; therefore these tanks are capable for continued operation. The staff noted that the applicant initiated appropriate corrective actions and determined that these tanks were suitable for continued use.

The staff noted that the applicant also performed a tank inspection of the TSC diesel fuel oil storage tank. The results of this inspection concluded that the tank was in excellent condition and that it was suitable for continued operation. The staff noted that the applicant will perform a tank inspection of the EDG and TSC DG fuel oil storage tanks on a 10-year frequency, consistent with RG 1.137.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the AMP 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 AMP XI.M30, including the applicants enhancement to formalize procedures for periodic draining, cleaning and inspection activities of fuel oil storage tanks, and not including the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.1.16, Inspection of Overhead Heavy Load and Refueling Handling Systems In the KPS LRA, the applicant stated that AMP B2.1.16 is an existing program that is consistent with the program elements in GALL AMP XI.M23, Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems, with an enhancement. The enhancement

is related to clarifying the requirements of visual inspection of structural members, including structural bolting, of the in-scope heavy load cranes, fuel handling cranes and associated equipment.

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

Document Title Revision / Date

1. Technical Report: Aging Management Program: Inspection of Overhead Heavy Revision 1 KLR-1323 Load and Refueling Handling Systems KPS 07/02/22008

2. Technical Report: Revision 1 Crane Load Cycle TLAA KLR-1208 01/17/2008

3. Letter (NRC From C. W. Geisler to D. G. Eisenhut, "Control of Heavy 12/23/1982 223) Loads - Six Month Response"

4. Letter (NRC From C. W. Giesler to D. G. Eisenhut, "Control of Heavy 03/09/1983

52) Loads - Nine-Month Response" From C. W. Giesler to S.A. Varga, "Response to Open Items

5. Letter (NRC Identified inTechnical Evaluation Report on Control of Heavy 07/27/1983 144)

Loads, NUREG 0612"

6. Letter (NRC From C. W. Giesler to S. A. Varga, "Clarification of 11/14/1983 203) Commitment made in Response to Nureg-0612"

7. Guidance and Reference Revision 0 "Overhead Cranes/Hoists" Document MA-AA- No Date 101-1004 KPS General Nuclear Procedure GNP-08.12.02, "Controls 03/28/2008

8. Procedure for Use of Cranes Within the Protected Area" Revision 15 KPS Preventive Maintenance Procedure PMP-57-26, "C - Revision 2

9. Procedure Reactor Building Polar Crane Mechanical Maintenance" 04/05/2008

10. Guidance and Reference Revision 2 Operating Experience Program Document No Date PI-AA-100-1007 KPS Nuclear Engineering Procedures (General) Revision 14

11. Procedure NEP-14.13, Operating Experience Procedure No Date

12. Directive NAD- Revision 21 Directive Implementing Document and Procedure Control 03.01 02/19/2009 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.16 are consistent with GALL 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 AMP XI.M23. The staff also verified that the applicant provided an adequate summary description of the program.

The applicant has committed to implement an enhancement affecting the parameters monitored or inspected program element. The enhancement will clarify the requirements of visual inspection of structural members, including structural bolting of the in-scope heavy load

and refueling handling cranes and associated equipment. The applicant stated that the enhancement is consistent with current implementation practices, and the enhancement formally incorporates these practices into applicable implementing procedures. The staff will consider issuing an RAI to address these issues, and the staffs evaluation will be documented in the SER.

The staff audited the operating experience reports and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. The documents audited by the staff and discussions between the staff and the applicants technical staff indicate that the operating experience program is adequately documented and followed.

The staff also met with the Resident Inspector on Tuesday and with members of the Region III Inspection Team on Wednesday. The discussed weld-cracking on the rail located in the Aux Building is a design issue being covered by the RIII Inspection Team.

During the breakup session with the applicant, the staff discussed potential RAIs that were identified as corrective actions. Corrective actions are not covered under AMPs. The staff also discussed the proposed enhancement on inspection criteria. The enhancement is also covered by the corrective actions program. The staff will consider issuing an RAI to address AMP Program Element 7, Corrective Actions, 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 AMP 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 AMP XI.M23 not including the areas in which the staff felt additional clarification might be warranted as described above which will be evaluated separately in the SER.

LRA AMP B2.1.17, Lubricating Oil Analysis In the KPS LRA, the applicant stated that AMP B2.1.17 is an existing program that is consistent with the program elements in GALL AMP XI.M39, Lubricating Oil Analysis.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. Technical Report License Renewal Project Aging Management Program: Revision 1 KLR-1337 Lubricating Oil Analysis 07/22/2008 Revision C

2. NID-01.05.02 Predictive Maintenance Oil Analysis Program 04/11/2006

Document Title Revision / Date Hydraulic fluid power - Determination of particulate First Edition

3. ISO 11500 contamination by automatic counting using the light extinction 09/01/1997 principle TSC Diesel Generator Lube oil approaching warning limit on

4. CAP014826 02/19/2003

% fuel oil content 1B diesel generator lube oil sample high zinc content

5. CAP017846 08/28/2003 indication Evaluate Feasibility of acceptance criteria for Lube Oil 6.CAP021571 06/15/2004 Analysis Results Oil was darker than normal on 1A & 1B Condensate Motor

7. CAP023820 11/04/204 Lwr Brg B Circ. Pump contamination and Chemistry oil levels trend

8. CAP025113 01/23/2005 into the alarm range

9. CAP000042 HD pump thrust stand bearing has water in oil 06/26/2001

10. ACE000004 Apparent Cause Evaluation for CAP000042 06/26/2001 Water is present in the B Heater Drain pump thrust stand oil

11. CAP028851 08/15/2005 reservoir

12. CE016302 Condition Evaluation of CAP028851 08/17/2005

13. CAP021529 Metal Wear Particles found in Turb. Driven AFW turbine oil 06/11/2004

14. RCE000652 Root Cause Evaluation for CAP021529 06/15/2004 Condition Evaluation - TDAFW Pump Terry Turbine bearing

15. CE015040 11/19/2004 temperature probe exerting force on bearing

16. CAP027923 Wear debris in B circulating water pump bearing oil 06/10/2005

17. CAP040532 TSC DG lube oil adverse trend 01/11/2007

18. CE019625 Condition Evaluation for CAP040532 01/16/2007 Oil Sample of 1B Control Room A/C Chiller Pump has

19. CR336440 05/29/2009 suspended particles

20. CA137670 Review oil analysis results - related to CR336440 05/29/2009

21. Laboratory Insight Services - Analysis Report - Excessive Particle Count 06/02/2009 Results

22. Laboratory Supreta - Technical Service Laboratory - Fluid Analysis 12/06/2005 Results Report

23. Laboratory Herguth Laboratories -Sample A - Mobil Sovarex 08/10/2005 Results

24. Laboratory Analysts, Inc. - Bearing Assembly / Sump 10/14/2006 Results

25. Laboratory Analysts, Inc. - 1A Diesel Generator - Mobil Mobilgard 450 11/10/2005 Results

26. CR094705 Moderate Fuel Dilution in TSC Diesel 04/04/2008

24. Laboratory Analysts, Inc. - Diesel Engine - TSC 05/04/2009 Results In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.17 are consistent with GALL AMP XI.M39 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP XI.M39. The staff also verified that the applicant provided an adequate summary description of the program.

The staff noted in the applicants acceptance criteria, program element, that the applicant is utilizing the industry standard ISO 11500. The staff noted that this standard incorporates the ISO 4406, which is a standard that GALL AMP XI.M39 recommends.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.17. 0A search with keywords: lube oil, contamination and particles resulted in over 220 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

In June 2001 the applicant noted based on an oil analysis that the 1B Heater Drain pump thrust stand bearing as having water in the lube oil. The applicant noted that the level of water in the lube oil was 1588 ppm, which was still below the allowable concentration of <2000 ppm of water. The applicant identified a desiccant breather on the heater drain pump thrust stand designed to prevent recurrence. During its evaluation the applicant noted that moisture from the air or moisture from packing leak off spilling to the hot pump casing and flashing to steam may have entered the lube oil reservoir through the air breather. The applicant took appropriate corrective actions to prevent recurrence, however in August 2005; there was excess water in the lube oil again. The applicant evaluated further and determined that the water in the lube oil was a result of a packing gland leakage. The applicant took appropriate corrective actions to remove the water in the lube oil reservoir and the packing gland leakage was corrected. The applicant removed the source of water to the thrust stand oil reservoir. The staff noted that the applicant took appropriate corrective actions in both instances to prevent recurrence, and ultimately determined the root cause for the water contamination and corrected the packing gland leakage.

During its review of the applicants conditions reports, the staff noted in January 2007 the applicant identified an adverse trend of sodium and boron in the TSC Diesel Generator lube oil.

The applicant determined the baseline for sodium and boron in the lube oil from historical results and noted that there was large increase in this sample compared to previous results.

Based on its review, the applicant determined that there were no unusual operating parameters and the lube oil laboratory results indicated that the oil was acceptable for continued use. The staff noted that the applicant determined the cause of the elevated sodium and boron was a result of coolant leaking into the lubricating oil. The applicant located the leak to be between an injector tube and cylinder head. The applicant took corrective actions to replace the cylinder head and then the TSC DG was returned to service. The staff noted that the applicant took appropriate corrective actions to identify the cause of the adverse trend and then replace the cylinder head to prevent recurrence.

During a May 2009 inspection, the applicant noted the oil sample from the 1B Control Room A/C Chiller Pump contained suspended particles. The applicant noted that the particles were reddish in color, non-metallic and of low-density, which appears to be some type of sealant.

After the oil was sampled, the applicant flushed the bearing bracket with new oil to remove additional debris that remained. The applicant sent this oil sample to Insight Services to perform a laboratory analysis to determine the composition of the suspended particles and to determine the quality of the oil. The results were obtained in June 2009 and the applicant noted that results indicated the oil was normal and within acceptance criteria. It was concluded that the suspended particles are believed to be sealant tape from the pipe plug. The staff noted that the applicant was able to determine contaminants in the oil sample, took actions to remove any remaining debris and obtain laboratory results to ensure the composition of the particles and evaluate the need for further actions. The staff noted that the applicant will continue to obtain samples on the normal frequency and monitor for adverse trends.

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

LRA AMP B2.1.18, Metal Enclosed Bus In the KPS LRA, the applicant stated that AMP B2.1.18 is an existing program that is consistent with the program elements in GALL AMP XI.E4, Metal Enclosed Bus, with an enhancement.

The applicant stated that the enhancement includes additional periodical internal visual inspections of the metal enclosed bus and corrective actions for any observed aging degradation.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. NUREG 1801 Generic Lessons Learned (GALL) Report Chapter XI, Aging Vol. 2, Management Programs (AMPS), AMP XI.E4, Metal Revision 1 Enclosed Bus. 09/2005

2. KLR-1306 License Renewal Metal Enclosed Bus AMP Report Binder Revision 1 07/22/2008

3. MA-KW-EPM- Reserve Auxiliary Transformer Non-Segregated Bus 1 Rev. 2 EHV-036 Through 6 Electrical Maintenance

4. PMP 39-36 4160 V Supply and Distribution Reserve Auxiliary Bus 05/28/1979 Maintenance

5. MA-KW-EPM- Electrical Preventive Maintenance Revision 2 EHV-036 Date: N/A In comparing the 7 program elements in the applicants program, the staff verified that with the enhancements, the program elements contained in AMP B2.1.18 are consistent with GALL AMP XI.E4 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP XI.E4. The staff also verified that the applicant provided an adequate summary description of the program.

The applicant has committed to implement an enhancement affecting the parameters monitored or inspected, detection of aging effects, acceptance criteria, and corrective actions program elements. The applicant stated that the enhancement includes augmented periodical visual inspections of the metal enclosed bus internal surfaces, bus supports, bus insulation, taped joints and boots for signs of degradation or aging. The applicant also stated that enhancement provides additional corrective actions that will be initiated for any observed aging degradation. The applicant stated that the enhancements are consistent with current implementation practices, and the enhancements will formally incorporate these practices into applicable implementing procedures. The enhancement to LRA AMP B2.1.18 is identified as license renewal commitment 13 in Appendix A, Table A6.0-1.

In the LRA Sections B2.1.18 and A2.1.18, the AMP states that the program performs visual inspection, using a sampling methodology, of sections of the in-scope MEBs. GALL AMP XI.E4 program description states that, The purpose of the AMP is to provide an inspection of MEBs.

GALL AMP XI.E4 recommends inspecting all internal portions of MEBs but limits the application of sampling methods to accessible MEB bolted connections only. The staff will consider issuing an RAI to address MEB visual inspection based on sampling and the staffs evaluation will be documented in the SER.

The applicants MEB bolted connection sampling methodology is referenced in plant basis document KLR-1306 which states that a sample of MEB bus connections will be inspected.

Further, Procedure MA-KW-EPM-EHV-036, Electrical Preventive Maintenance, and Attachment A, RX Joint History Data Sheet, implement the MEB bolted connection sampling methodology based on a joint selection matrix that uses completed inspection information to determine the next set of connections for inspection.

In LRA Section B2.1.18, under the program description, the applicant states that the metal enclosed bus program is supported by the structures monitoring program which performs visual inspection of portions of the MEB enclosure assemblies. The staff reviewed the applicants structural monitoring program and noted that it does not address the visual inspection of MEBs.

The staff will consider issuing an RAI to confirm that the structure monitoring program visually inspects the exterior portions of the MEB consistent with GALL Report Table VI, Item VI.A-12 and VI.A-13.

In LRA Section B2.1.18, the applicant states that the existing inspection program is designed to maintain the tightness of metal-enclosed bus joints and joints were torque checked for proper tightness. The staff noted that re-torquing is not recommended in EPRI document TR-104213 (See Sections 7.2.1 and Section 8.2) for electrical bolted connection maintenance. The EPRI document states that the bolts should not be re-torqued unless the joint requires service or the bolts are clearly loose. Verifying the torque is not recommended. The torque required to turn the fastener in the tightening direction (restart torque) is not a good indicator of the preload once the fastener is in service. Due to relaxation of the parts of the joint, the final loads are likely to be lower than the installed loads. The staff will consider issuing an RAI to address this issue.

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

In LRA Section B2.1.18 under operating experience, the applicant states that instances of MEB failures due to degradation of bus insulation and accumulation of dust and debris occurred in the late 1980s. As a result of these failures, the program inspection requirements were enhanced to perform bus cleaning and visual inspection of the bus insulation as well as bus joint connections. The applicant also states that program inspection requirements were enhanced to inspect the MEB enclosures for foreign objects, such as tools and equipment used during the performance of maintenance, prior to closure of the MEB covers to ensure these items were removed. The applicant also states that its inspection program recognized the discussion in NRC Information Notices 89-64, 98-36, and 2000-14 for failures of MEBs due to age degradation of bus insulation and accumulation of moisture and debris, and has included these items as part of the MEB inspection program. The applicant further stated that no age-related MEB faults have occurred since the program was revised to include bus cleaning and enhanced visual inspections.

The staff also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.18. A search with keywords: non-segregated, bus duct, connection, elastomer, boot, bolted resulted in 21 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

The 3 program elements, corrective actions, confirmation process and administrative controls were reviewed as part of the Scoping and Screening Methodology audit. During the AMP audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.E4, not including any areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.1.19, Non-EQ Electrical Cables and Connections In the KPS LRA, the applicant stated that AMP B2.1.19 is a new program that is consistent with the program elements in GALL 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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. Technical Report License Renewal Project Aging Management Program Revision 1 KLR-1303 Non-EQ Electrical Cables and Connections Kewaunee 07/22/2008 Power Station

2. Topical Report Revision 6 Nuclear Facility Assurance Program DOM-QA-1

3. PI-KW-200 Corrective Action Revision 7

4. NAD-03.01 Directive, Implementing Document, and Procedure Control Revision 21,

Document Title Revision / Date 02/19/2009 Revision 14,

5. NEP-14.13 Operating Experience Procedure 02/28/2008 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.19 are consistent with GALL AMP XI.E1 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP XI.E1. The staff also verified that the applicant provided an adequate summary description of the program.

The staff 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 as provided in the GALL report. As stated in the LRA, the applicant performed a review of the corrective action program for representative examples of internal operating experience related to this program and did not identify any cases of reduced insulation resistance and electrical failure of accessible non-EQ electrical cables and connections within the scope of license renewal subject to an adverse localized environment. The applicant also stated that they will use the operating experience to adjust this program as needed.

The staff also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.19. A search with keywords: cable, connection, cracking, melting, discoloration, embrittlement, and surface contamination resulted in 25 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience in the applicant basis document adequately addressed the plant-specific experience for this AMP.

In the application, the applicant stated that AMP B2.1.19 is a new program and therefore there is no operating experience for the effectiveness of the program. In order to be consistent with the staffs recommendations in Section A.1.2.3.10, Item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), an applicant may have to commit to providing operating experience in the future for new programs to confirm their effectiveness.

The staff may request, consistent with the statement in the SRP-LR, that the applicant make a commitment to provide future operating experience to the staff for those new AMPS to confirm effectiveness for the period of extended operation.

The staff also reviewed the applicants method for identifying an adverse localize environment.

The applicant stated in Technical Report KLR-1303 that an adverse localized environment is a condition in a limited plant area that is significantly more severe than the specified service condition for the cable and connections. Should an adverse localized environment be observed, a representation sample of electrical cables and connection installed within that environment will be visually inspected for aging. However, the applicant did not address the criteria of how the adverse localized environment is identified. The staff will consider issuing a RAI to address this issue.

The 3 program elements, corrective actions, confirmation process and administrative controls were reviewed as part of the Scoping and Screening Methodology audit. During the AMP audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.E1 not including any areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.1.20, Non-EQ Electrical Cable Connections In the KPS LRA, the applicant stated that AMP B2.1.20 is a new program that is consistent with the program elements in GALL 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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date Generic Lessons Learned (GALL) Report Chapter XI, Aging Vol. 2,

1. NUREG 1801 Management Programs (AMPS), AMP XI.E6, Electrical Revision 1 Cable Connections Not Subject to 10 CFR 50.49 09/2005 Environmental Qualification Requirements.

Revision 1

2. KLR-1308 Non-EQ Electrical Cable Connections 07/22/2008

3. Nuclear Fleet Administrative Revision 7 Procedure PI-KW- Corrective Action Date: N/A 200, Corrective Action.

4. Nuclear Fleet Guidance and Revision 14 Reference Operating Experience Program 02/28/2008 Document PI-AA-100-1007 Changes to Generic Lesson Learned (GALL) Report Aging Issued for Management Program (AMP) XI.E6, Electrical Cable

5. LR-ISG-2007-02 Comment; Connections Not Subject to 10 CFR 50.49 Environmental 08/29/2007 Qualification Requirements In comparing the 7 program elements in the applicants program, the staff noted that the applicant stated that B2.1.20 is a new program consistent with GALL but the program elements contained in AMP B2.1.20 are not consistent with GALL AMP XI.E6 program elements. The staff noted that the applicant elected to incorporate a one-time test, limit the voltage level testing criteria and other changes. However, the staff noted that these changes are consistent with ISG LR-ISG-2007-02 but the applicant did not reference the ISG or provide justification for its use in LRA Section B2.1.20. The staff will consider issuing an RAI to resolve this issue. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP XI.E6. The staff also noted that the applicants summary

description of the program was inconsistent with GALL AMP XI.E6. The staff will consider issuing an RAI to request the applicant to reconcile the summary description with GALL AMP XI.E6.

The staff audited operating experience prepared by the applicant and interviewed the applicants technical staff to confirm that plant-specific operating experience did not reveal any degradation outside the bounds of industry experience. The applicants review of its corrective action program (CAP) did not reveal any specific CAP examples of loose bolt connections attributable to the aging mechanisms applicable to LRA Section B2.1.20 and GALL AMP XI.E6.

The staff also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.20. A search with keywords: cable, connection, bolted, thermography, resistance, loose, electrical, and corrosion resulted in over 52 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

In the LRA, the applicant stated that the Non-EQ Electrical Cable Connections is a new program and therefore there is no operating experience to evaluate the effectiveness of this specific program. However, as indicated above, the applicant did perform a review of the corrective action program and stated that although cases of loose bolted connections were identified, no failures were noted that were due to aging mechanisms associated with thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion and oxidation. The licensee further stated that as operating experience is obtained, lessons learned will be used to adjust this program as needed. In order to be consistent with the staffs recommendations in Section A.1.2.3.10, Item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), an applicant may have to commit to providing operating experience in the future for new programs to confirm their effectiveness. The staff may request, consistent with the statement in the SRP-LR, that the applicant make a commitment to provide future operating experience to the staff for those new AMPS to confirm effectiveness for the period of extended operation.

The 3 program elements, corrective actions, confirmation process and administrative controls were reviewed as part of the Scoping and Screening Methodology audit. During the AMP 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.E6 not including any areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.1.21, Non-EQ Inaccessible Medium-Voltage Cables In the KPS LRA, the applicant stated that AMP B2.1.21 is a new program that is consistent with the program elements in GALL AMP XI.E3, Inaccessible Medium-Voltage Cables 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

AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date Generic Lessons Learned (GALL) Report Chapter XI, Aging Management Programs (AMPS), AMP XI.E3, Vol. 2,

1. NUREG 1801 Inaccessible Medum-Voltage Cables not Subject to Revision 1 10 CFR 50.49 Environmental Qualification 09/2005 Requirements.

License Renewal Project Aging Management

2. Technical Report : Revision 1 Program - Non-EQ Inaccessible Medium Voltage KLR-1305 07/27/2008 Cables Kewaunee power Station

3. Technical Report:

License Renewal Project Position Paper 08/08/2008 KLR-1401 Plan Plant Site - Underground Conduit and Cable

4. Dwg. E-350 05/25/2007 Routes Plan and Sections - Underground Conduit - Trans

5. Dwg. E-351 11/04/2003 Area

6. Nuclear Fleet Administrative Revision 7 Corrective Action Procedure PI-KW- Date: N/A 200

7. Nuclear Fleet Guidance and Revision 14 Reference Operating Experience Program 02/28/2008 Document PI-AA-100-1007 Inaccessible or Underground Power Cables Failures

8. GL 2007-01 that Disable Accident Mitigation Systems or Cause 02/07/2007 Plant Transients In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.21 are consistent with GALL AMP XI.E3 program elements with the exception of AMP B2.1.21 program element 4 Detection of Aging Effects, and Element 7 Corrective Actions. For Program Element 4, the applicant states that inspection for water collection should be performed prior to the period of extended operation and every two years thereafter. GALL AMP XI.E3 states that the inspection for water collection should be based on actual plant experience with water accumulation in the manhole with an inspection frequency of at least every two years. The staff is concerned that the applicant did not provide plant-specific operating experience to justify the fixed two year inspection frequency.

In addition, the staff is concerned that the applicants program does not provide for adjustment of the two year inspection frequency based on the possibility of subsequent significant water accumulation resulting in cable submergence. The staff is considering issuing an RAI to address this issue. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP XI.E3. The staff also verified that the applicant provided an adequate summary description of the program.

The staff audited operating experience prepared by the applicant and interviewed the applicants technical staff to confirm that plant-specific operating experience did not reveal any degradation outside the bounds of industry experience. The applicants review of its CAP did

not reveal any specific CAP examples attributable to the aging mechanisms applicable to LRA AMP B2.1.21 and GALL AMP XI.E3. The applicants response to NRC generic letter GL-2007-01 did not identify any failures of cables in-scope of GL-2007-01 or license renewal. In addition, the applicants inspection of the in-scope manhole east of the tertiary auxiliary transformer did not identify water collection that would cause in-scope cables to be exposed to significant moisture. As part of the audit, the staff also walked down the in-scope manhole and confirmed the applicants findings. Therefore, the applicants plant-specific operating experience did not reveal any degradation outside the bounds of industry experience.

The staff also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.21. A search with keywords: electrical, manhole, submergence, duct bank, water, bus, medium voltage, and cable resulted in over 16 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

In the application, the applicant stated that the Non-EQ Inaccessible Medium-Voltage Cables is a new program and therefore there is no operating experience for the effectiveness of the program. However, as indicated above, the applicant did perform a review of the corrective action program and stated that no failures of in-scope cables were identified. The licensee further stated that as operating experience is obtained, lessons learned will be used to adjust this program as needed. In order to be consistent with the staffs recommendations in Section A.1.2.3.10, Item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), an applicant may have to commit to providing operating experience in the future for new programs to confirm their effectiveness. The staff may request, consistent with the statement in the SRP-LR, that the applicant make a commitment to provide future operating experience to the staff for those new AMPS to confirm effectiveness for the period of extended operation.

The 3 program elements, corrective actions, confirmation process and administrative controls were reviewed as part of the Scoping and Screening Methodology audit. During the AMP audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.E3 not including any areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.1.22, Non-EQ Instrumentation Circuits Subject to Sensitive, High Voltage, Low-Level Signals In the KPS LRA, the applicant stated that AMP B2.1.22 is a new program that is consistent with the program elements in GALL AMP XI.E2, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits.

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

Document Title Revision / Date Non-EQ Instrumentation Circuits Subject to Sensitive, High- Revision 1

1. KLR-1304 Voltage Low-Level Signals 07/22/2008 RMS Channel R-11 Containment Particulate Radiation Rev. 18

2. SP-45-050.11 Monitor Calibration 11/29/2007 RMS Channel R-21 Containment Particulate Radiation Rev. 11

3. SP-45-050.21 Monitor Calibration 02/07/2008 Aging Management Guidelines for Commercial Nuclear

4. SAND96-0344 09/1996 Power Plants - Electrical Cable and Terminations In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.22 are consistent with GALL AMP XI.E2 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP XI.E2. The staff also verified that the applicant provided an adequate summary description of the program.

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

The staff also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.22. A search with keywords: instrumentation, circuits, discoloration resulted in 37 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP. In the application, the applicant stated that Non-EQ Instrumentation Circuits Subject to Sensitive, High-Voltage, Low-Level Signals is a new program and therefore there is no operating experience for the effectiveness of the program. In order to be consistent with the staffs recommendations in Section A.1.2.3.10, Item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), an applicant may have to commit to providing operating experience in the future for new programs to confirm their effectiveness. The staff may request, consistent with the statement in the SRP-LR, that the applicant make a commitment to provide future operating experience to the staff for those new AMPS to confirm effectiveness for the period of extended operation.

In the basis document KLR-1304, the applicant states that the scope of program applies to electrical cables and connections used in the power range monitor nuclear instrumentation circuits and radiation monitoring circuits. The staff noted that the scope of the program does not include the source and intermediate range nuclear instrumentation. During the meeting with the applicants personnel, the staff asked the applicant why source range and intermediate range nuclear instrumentation were not included in the scope of AMP B2.1.22. The applicant

indicated and the staff verified that the source and intermediate range instrumentation are in the EQ master list and therefore, they are not required to be in the scope of AMP B2.1.22.

The 3 program elements, corrective actions, confirmation process and administrative controls were reviewed as part of the Scoping and Screening Methodology audit. During the AMP audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.E2.

LRA AMP B2.1.23, Open-Cycle Cooling Water System In the KPS LRA, the applicant stated that AMP B2.1.23 is an existing program that is consistent with the program elements in GALL AMP XI.M20, Open Cycle Cooling Water System, with an enhancement and an exception. The exception is related to thermal performance testing of containment coil fan units and heat exchangers in the emergency diesel generator subsystem and the enhancement is related to adding applicable aging effects, such as the detection of silt buildup and zebra mussels to the inspection criteria for the circulating water system intake.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. KLR 1320 Rev 2 Open Cycle Cooling Water System 05/26/2009

2. USAR Section Rev 18 Service Water System 9.6.2 11/01/2003 Rev 8

3. NID-01.01 Generic Letter 89-13 Program Document 10/09/2008

4. CY-KW-043-006 Chemistry Procedure Rev 0

5. ESR 91-16 Slime and Silting Control in the Service Water System 05/04/1993 Rev 7

6. Chem-43.007 Service Water Dead Leg Chemical Treatment 01/10/2008

7. ER-AA-HTX-1003 Heat Exchanger Monitoring and Assessment Rev 2 Requirements for Heat Exchanger Eddy Current Program Rev 10

8. GNP-01.52.01 Implementation 08/05/2008

9. CAP 018869 Radiography determines silting 11/10/2003

10. CAP 023815 Unexpected degradation in component cooling heat exch. 11/04/2004

11. CAP 004023 Piping corrosion 04/29/2002

12. CAP 012296 SI Pump Oil Cooler Pluggage 07/18/2002 Evaluations and procedures put in place for loss of heatsink

13. CR132044 07/17/2000 due to loss of AF

14. CR167725 Post Outage Zebra Mussel Treatment 10/19/2006

15. CR154602 Turbine building Basement Cooling Water Duplex Strainer 06/27/2006

16. CR155269 Summer Zebra Mussel Treatment Results 08/03/2006

17. CR161406 Live Zebra Mussels 05/17/2007

Document Title Revision / Date Min or leakage identified on TSC Diesel Jacket Water

18. CR149302 07/13/2005 System

19. CR144739 Concern in SW Pipes Embedded in Concrete 10/20/2004

20. CR138744 Service Water System Operability Concerns 07/23/2003 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.23 are consistent with GALL AMP XI.M20 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP except for the areas that the applicant took exceptions to GALL AMP XI.M20. The staff also verified that the applicant provided an adequate summary description of the program.

In the application, the applicant proposed an exception to GALL program element detection of aging effects that would allow for the use of periodic maintenance and inspection in place of performance testing. Generic Letter 89-13 proposes periodic maintenance and inspection in place of performance testing when reliable performance data cannot be obtained due to the characteristics of the heat exchangers being tested. The staff will review the exception and may consider issuing an RAI that requests the applicant provide additional information.

The applicant has committed to implement an enhancement affecting the parameters monitored or inspected program element. The enhancement is related to adding detection of applicable aging effects, such as silt buildup and zebra mussels to the inspection criteria for the circulating water system intake. The applicant stated that the enhancements are consistent with current implementation practices, and the enhancements formally incorporate these practices into applicable implementing procedures. The staff will consider issuing an RAI to address these issues, and the staffs evaluation will be documented in the SER.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.23. A search with keywords: service water piping, service water corrosion, zebra mussels, chlorination, service water fouling resulted in 100 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

During its audit, the staff identified three issues which required further explanation. These issues are described in the paragraphs below.

Section 2 of the GALL AMP states that all service water piping should be lined. The LRA AMP states that much of the service water piping is unlined. Corrosion of unlined piping may be much higher than in lined piping. Consistency with the GALL AMP, when unlined piping is used,

may not adequately manage corrosion in the period of extended operation. The staff will consider issuing an RAI to address this issue. The staffs evaluation will be documented in the SER.

Section 2 of the GALL AMP recommends chemical treatment for the control of biofouling.

Operating experience indicates a significant number of reports indicating failure of the chemical injection system and presence of zebra mussels in the service water system. The combination of these observations could indicate a weakness in the LRA AMP related to chemical treatment.

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

During its review of operating experience, the staff noted a number of reports indicating loss of function of service water components. Some, but not all of these reports, indicated that the information gathered from these reports was applied to other components with similar material/environment combinations. The number of reports in which the staff could not confirm that the information gathered had been applied to other components, especially those dealing with fouling in low flow heat exchangers was sufficient for the staff to question whether lessons learned were universally applied to other, similar, components. The staff will consider issuing an RAI to address this issue. 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 AMP 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 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.

LRA AMP B2.1.24, Primary Water Chemistry In the Kewaunee Nuclear Station LRA, the applicant stated that AMP B2.1.24 is an existing program that is consistent with the program elements in GALL AMP XI.M2, Water Chemistry.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. KLR-1310 License Renewal Project Aging Management Program, Revision 2 Primary Water Chemistry, Kewaunee Nuclear Station 05/21/2009 Revision D

2. NAD-01.44 Kewaunee Primary Water Chemistry Program 08/01/2006 Revision 2

3. CY-KW-040-001 Primary Chemistry Sample Specifications (undated)

Revision 2

4. CY-KW-040-007 Hydrogen Peroxide Addition to the Reactor Coolant (undated)

Document Title Revision / Date Revision 0

5. CY-KW-040-008 Chemical Degasification of the Reactor Coolant System (undated)

Sample Container Rinsing and Miscellaneous Purge Revision 0

6. CY-KW-009-002 Volumes (undated)

Revision 0

7. CY-KW-049-004 Chemistry Control Guidelines for Plant Shutdown (undated)

Revision F

8. CHEM-40.005 Chemistry Control Guidelines for Plant Startup 10/04/2006 Revision A

9. CHEM-40.009 RCS Lithium Management 03/25/2003 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.24 are consistent with GALL AMP XI.M2 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP XI.M2. The staff also verified that the applicant provided an adequate summary description of the program.

The staff noted that the applicant had apparently misidentified the most recent revision of the EPRI report that forms the basis for GALL AMP XI.M2 and for the applicants Primary Water Chemistry AMP. The staff also noted that the applicant provided apparently conflicting information on action level limits for primary water dissolved oxygen under reactor critical conditions and on the concentration limit for reactive silica in the boric acid storage tanks. The staff will consider issuing RAIs to address these issues, and the staffs evaluation will be documented in the SER.

The staff further noted that the applicants LRA lists a number of structures and components for which the operating environment is primary water and for which aging is managed by GALL AMP XI.M2. GALL states that no further aging management review (AMR) is necessary for these components if the applicant provides certain component-specific commitments in the FSAR Supplement. The applicants USAR for this AMP does not appear to include these commitments. The staff will consider issuing an RAI to address these issues, and the staffs evaluation will be documented in the SER.

The staff further noted that element 4 of GALL AMP XI.M2 states that inspection of select components is to be undertaken to verify the effectiveness of the chemistry control program and to ensure that significant degradation is not occurring and the component intended function will be maintained during the extended period of operation. GALL recommends that this verification be accomplished using an in-service inspection program such as AMP XI.M32 (One-Time Inspection). The applicant proposes to replace this AMP with its own plant-specific Work Control Process AMP B2.1.32. The staff has determined that applicants Primary Water Chemistry Program therefore conforms to GALL XI.M2 with respect to element 4 (Detection of Aging Effects) only if its Work Control Process Program is determined to be an acceptable alternative to GALL XI.M32. The staff will consider issuing an RAI to address these issues, and the staffs evaluation will be documented in the SER.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 did not identify any issues where additional clarifications were needed related to the operating experience in the LRA.

The staff also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.24. The search resulted in a review of 65 records through the use of keywords: chemistry, corrosion, cracking, stress corrosion cracking, pitting, crevice corrosion, wastage, general corrosion and cooling water. The staff screened these records, and reviewed them for relevance to the AMP in evaluating the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

The 3 program elements, corrective actions, confirmation process, and administrative controls, were reviewed as part of the Scoping and Screening Methodology audit. During the AMP audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M2, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.1.25, Reactor Containment Leakage Testing 10 CFR 50, Appendix J In the KPS LRA, the applicant stated that AMP B2.1.25 is an existing program that is consistent with the program elements in GALL AMP XI.S4, 10 CFR Part 50, Appendix J.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. KLR-1340 Reactor Containment Leakage Testing 10 CFR 50 Appendix J, Revision 1 Aging Management Program 07/22/2008 Revision C

2. KPS Containment Leak Rate Testing Program 07/31/2007 KPS Surveillance Procedure Containment Building Integrated Revision 11

3. SP-56A-088 Leak Rate Test 04/14/ 2009 KPS Surveillance Procedure Containment Local Leak Rate Type Revision 15

4. SP-56A-090 B & C Test 08/21/2007

5. CAP015541 Failure of Station Air Valves During SP-56A-090 04/06/2003

6. CAP015960 Proposed Design Change for Penetration 19 04/21/2003 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.25 are consistent with the GALL 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 AMP. The staff also verified that the applicant provided an adequate summary description of the program.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.25. A search with keywords: ILRT and Appendix J resulted in approximately 150 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review.

The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

In the IWE and Appendix J basis documents, it appeared that IWE examinations conducted in prior outages were credited for the visual inspection required by Appendix J prior to an Appendix J Type A Integrated Leak Rate Test (ILRT). The staff asked the applicant to explain this discrepancy, which they did by providing KPS Surveillance Procedure SP-56A-088 Section 6.8 which clearly says a complete visual inspection must be done of the accessible containment vessel prior to initiating an ILRT.

The 3 program elements, corrective actions, confirmation process and administrative controls were reviewed as part of the Scoping and Screening Methodology audit. During the AMP audit, the staff reviewed 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.S4.

LRA AMP B2.1.26, Reactor Head Closure Studs In the KPS LRA, the applicant stated that KPS AMP B2.1.26 is an existing program that is consistent with GALL AMP XI.M3, Reactor Head Closure Studs with an exception to the scope of the program program element in that the program is implemented using the guidance of ASME Section XI 1998 Code Edition through 2000 Addenda instead of the ASME Section XI 2001 Code Edition through 2003 Addenda recommended by the GALL Report. The program consists of preventive measures identified in NRC Regulatory Guide 1.65 to mitigate cracking and loss of material, and visual or volumetric examinations to monitor this degradation.

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

Document Title Revision / Date License Renewal AMP Basis Document - Rev. 1,

1. KLR-1312 Reactor Head Closure Studs Program 07/22/2008 Rev. 1,

2. #676413 Equipment Specifications- Reactor Vessel 10/25/1967

Document Title Revision / Date Rev. 1,

3. ER-AA-NDE-VT-601 VT-1 Visual Examination Procedure 01/18/2008 Rev. A,

4. NEP-15.07 Magnetic Particle Examination for Inservice inspection 06/17/2004 Ultrasonic Examination of Bolts and Studs for Inservice Rev. A,

5. NEP-15.15 inspection 06/17/2004 Ultrasonic Examination of Reactor Vessel Threads in Rev. A,

6. NEP-15.19 Flange for Inservice inspection 06/17/2004 ASME Boiler and Pressure Vessel Code Class 1 System Rev. Q,

7. SP-36-267 Pressure Testing 01/17/2006 Rev. 15,

8. SP-55-085 Ten Year Inservice Inspection Requirement 01/29/2008 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.26 are consistent with GALL 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 AMP except for the areas that the applicant took exceptions to GALL AMP XI.M3. The staff also verified that the applicant provided an adequate summary description of the program.

In the application, the applicant proposed an exception to GALL program element scope of program in that the program is implemented using the guidance of ASME Section XI 1998 Code Edition through 2000 Addenda, which allowed surface or volumetric examinations of the reactor head closure studs when the studs were removed, instead of the 2001 Code Edition through 2003 Addenda recommended in the GALL Report, which requires a volumetric examination when the studs are in place or removed. In its review, the staff noted that the applicant was committed to volumetric examination of the studs when they are removed during refueling outages. Consequently, the applicants AMP is consistent with the requirements of the ASME Section XI 2001 Code Edition through 2003 Addenda, and therefore acceptable.

In its review, the staff also noted that the detection of aging effects program element of GALL AMP XI.M3 Reactor Head Closure Studs was not consistent with ASME Section XI 2001 Code Edition through 2003 Addenda. The second and third paragraphs of program element 4 of GALL AMP XI.M3 describe the requirements of the Section XI 1995 Code Edition through 1997 ADDENDA. These paragraphs should be revised to be consistent with the requirements of the 2001 Code Edition. The staff may consider issuing an RAI that requests the applicant provide additional information The staff verified consistency with the GALL Report preventive actions program element recommending the use of acceptable surface treatments and stable lubricants. The staff reviewed the material specification sheet for the lubricant used, and verified that the lubricant did not include any unstable compounds identified in RG 1.65.

The staff also reviewed the operating experience reports and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. The applicant stated that a review of the Kewaunee condition reports did not identify any reported cracking or loss of material for the

closure studs. A review of the Kewaunee Corrective Action Program (CAP) items indicated two minor incidences: exceeding elongation limit of one stud by 0.001 inch (2003) and removal of a stud blemish (2006).

The staff also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.26. The search resulted in a review of 15 records.

The staff screened these records, and reviewed them for relevance to the AMP in evaluating the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

The 3 program elements, corrective actions, confirmation process and administrative controls were reviewed as part of the Scoping and Screening Methodology audit. During AMP 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 AMP XI.M3, not including any exceptions identified by the applicant in the LRA for this AMP, which will be evaluated separately in the SER, and the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.1.28, Secondary Water Chemistry In the Kewaunee Nuclear Station LRA, the applicant stated that AMP B2.1.28 is an existing program that is consistent with the program elements in GALL AMP XI.M2, Water Chemistry.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. KLR-1311 License Renewal Project Aging Management Program, Revision 2 Secondary Water Chemistry, Kewaunee Nuclear Station 05/21/2009 Revision F

2. NAD-01.45 Kewaunee Secondary Water Chemistry Program 07/12/2005 Revision 0

3. CY-AP-SEC-200 Secondary Water Chemistry (undated)

Revision 0

4. CY-KW-041-001 Secondary Chemistry Sample Specifications (undated)

Revision 0

5. CY-KW-041-005 Secondary Hideout Return Sampling (undated)

Revision 0

6. CY-KW-041-010 Secondary ChemistryEquivalent Inleakage Rate (undated)

Revision 8

7. CHEM-41.002 Secondary Chemistry Corrective Actions 09/27/2007 Control of Steam Generator Chemistry During Periods of Revision C

8. CHEM-41.003 Cold Shutdown 10/07/2004 Revision C

9. CHEM-41.005 Secondary Hideout Return Sampling 02/13/2007

Document Title Revision / Date Secondary Chemistry Sample Locations and Sample Revision 8

10. CHEM-41.006 Purging 02/19/2008 Sample Container Rinsing and Miscellaneous Purge Revision 0

11. CY-KW-009-002 Volumes (undated)

Secondary Chemistry Sample Conditioning and Flow Control Revision 0

12. CY-KW-041-013 for Inline Analyzers (undated)

In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B2.1.28 are consistent with GALL AMP XI.M2 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP XI.M2. The staff also verified that the applicant provided an adequate summary description of the program.

The staff noted that element 4 of GALL AMP XI.M2 states that inspection of select components is to be undertaken to verify the effectiveness of the chemistry control program and to ensure that significant degradation is not occurring and the component intended function will be maintained during the extended period of operation. GALL recommends that this verification be accomplished using an in-service inspection program such as AMP XI.M32 (One-Time Inspection). The applicant proposes to replace this AMP with its own plant-specific Work Control Process AMP B2.1.32. The staff has determined that applicants Primary Water Chemistry Program therefore conforms to GALL XI.M2 with respect to element 4 (Detection of Aging Effects) only if its Work Control Process Program is determined to be an acceptable alternative to GALL XI.M32. The staff will consider issuing an RAI to address these issues, and the staffs evaluation will be documented in the SER.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 did not identify any issues where additional clarifications were needed related to the operating experience in the LRA.

The staff also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.28. The search resulted in a review of 65 records through the use of keywords: chemistry, corrosion, cracking, stress corrosion cracking, pitting, crevice corrosion, wastage, general corrosion and cooling water. The staff screened these records, and reviewed them for relevance to the AMP in evaluating the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

The 3 program elements, corrective actions, confirmation process, and administrative controls, were reviewed as part of the Scoping and Screening Methodology audit. During the AMP audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP XI.M2, except for the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B2.1.29, Selective Leaching of Materials In the KPS LRA, the applicant stated that AMP B2.1.29 is a new program that is consistent with the program elements described in the GALL Report AMP XI.M33, Selective Leaching of Materials.

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 document:

Document Title Revision / Date

1. Technical Report License Renewal Project Aging Management Program Revision 1 KLR-1332 Selective Leaching of Materials 7/22/08 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in KPS AMP B.1.29 are consistent with the GALL Report AMP XI.M33 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.M33.

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

The staff conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1.29. A search with keywords: gray cast iron, copper alloy, selective leaching, dealloying, dezincification, and dealuminumification, resulted in three records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the KPS operating experience from the independent search did not indicate age-related degradation by selective leaching that would be applicable to this program. The applicant did identify instances of applicable operating industry experience at four other plants, and entered them into the KPS condition report system, and referenced them in the AMP technical report.

In the application, the applicant stated that the Selective Leaching of Materials program is a new program and that it had identified no operating experience at KPS with which to evaluate the effectiveness of the program. In order to be consistent with the staffs recommendations in Section A.1.2.3.10, Item 2 of SRP-LR Branch Position RLSB-1 (i.e. Branch Position RLSB-1 of Appendix A to NUREG-1800), an applicant may have to commit to providing operating experience in the future for new programs to confirm their effectiveness. The staff may request, consistent with the statement in the SRP-LR, that the applicant make a commitment to provide future operating experience to the staff for those new AMPs to confirm effectiveness for the period of extended operation.

The 3 program elements, corrective actions, confirmation process and administrative controls were reviewed as part of the Scoping and Screening Methodology audit. During the AMP 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.M33.

LRA AMP B2.1.30, Steam Generator Tube Integrity In the Kewaunee LRA, the applicant stated that AMP B2.1.30 is an existing program that is consistent with the program elements in GALL AMP XI.M19, Steam Generator Tube Integrity with an exception. The exception is related to using a later revision of an NEI Guideline for implementing the Steam Generator Tube Integrity Program (NEI 97-06, Revision 2, "Steam Generator Program Guidelines) than the one recommended in the GALL report,Section XI.M19 (NEI 97-06, Revision 1, "Steam Generator Program Guidelines).

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date Requirements for Steam Generator Primary Side Revision 1

1. GNP -01.21.01 Activities 04/03/2007 Requirements for Steam Generator Secondary Side Revision G

2. GNP -01.21.02 Activities 01/30/2007 Revision O

3. SP 084 Steam Generator Tube Inspection 08/17/2006

4. KNPP - SGR Project -

Replacement Lower Assemblies and Steam Dome Revision 3 Physical Change - DCR No.

Modifications 12/12/2001 2858

5. WCAP-15324 Volume 1 Section 3 Geometry and Material Properties Vertical Steam Generator Instructions for Operations

6. Westinghouse Technical Revision 0 and Maintenance - Wisconsin Public Service Manual No. TM 1440-C384 05/2000 Corporation Kewaunee

7. Dominion Nuclear Fleet Revision 1 Program Description ER- Steam Generator Program Description 4/09/2009 AP-SGP-10

8. Dominion Nuclear Fleet Revision 2 Administrative Procedure Steam Generator Program 02/19/2009 ER-AP-SGP-101

9. Dominion Nuclear Fleet Revision 0 Administrative Procedure Steam Generator Degradation Assessment 01/29/2009 ER-AP-SGP-102

10. Dominion Nuclear Fleet Steam Generator Condition Monitoring and Revision 0 Administrative Procedure Operational Assessments 01/29/2009 ER-AP-SGP-103

11. Technical Report KLR-1319 License Renewal Steam Generator Tube Integrity - Kewaunee Power Revision 1 Project - Aging Station 07/22/2008 Management Program Revision E

12. GNP-01.21.04 Primary-to-Secondary Leak Monitoring Program 02/07/2006 Revisions 0 Calculation of Allowable Tube Degradation (RG

13. WCAP 15325 (2000) and 1 1.121)/Steam Generator Tube Plugging Limits (2002)

Document Title Revision / Date

14. Dominion Energy Kewaunee Power Station, Steam Generator Revision 1 Kewaunee, Inc. Secondary Side Integrity Plan 04/10/2007

15. SAR-000485 Steam Generator Program Self-Assessment 12/12/2008 The staff compared the applicants program contained in AMP B2.1.30 to GALL AMP X1.M19.

For some of the 7 program elements that were reviewed, the staff was not able to verify consistency between the applicants program and GALL AMP X1.M19. As a result, the staff developed several RAIs, which highlight potential inconsistencies between the applicants program and the GALL AMP X1.M19.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B2.1-30. A search with keywords: steam generator tube, eddy current, primary secondary leak resulted in 300 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for 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 evaluated 7 program elements in the applicants program and was not able to confirm that all aspects of some of the 7 elements for the AMP were consistent with those specified in the GALL AMP X1.M19, not including any exceptions identified by the applicant in the LRA for this AMP, which will be evaluated separately in the SER.

LRA AMP B2.1.31, Structures Monitoring Program In the KPS LRA, the applicant stated that AMP B2.1.31 is an existing program that is consistent with the program elements in GALL AMP XI.S5, Masonry Wall Program, XI.S6, Structures Monitoring Program, and XI.S7, RG 1.127, Inspection of Water-Control Structures Association with Nuclear Power Plants. with three enhancements. The enhancements are related to (1)

Define In-Scope Structural Elements: The Structural Monitoring Program will be enhanced to clarify define structures, structural elements, and miscellaneous structural commodities that are in scope. (2) Groundwater Monitoring: The Structures Monitoring Program will be enhanced to monitor groundwater quality and verify that it remains non-aggressive to below grade concrete.

(3) Underwater Inspections: The Structures Monitoring Program will be enhanced to improve criteria for detection of aging effects for the underwater visual inspections of the in-scope structures.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date

1. KLR-1341 Structures Monitoring program Revision 1 07/22/2008

2. NEP-08.04 KPS Nuclear Engineering Procedure - Maintenance Rule Revision 3 Inspection Guideline for Buildings and Structures. 09/18/2007

3. PMP-04-01 KPS Preventive Maintenance Procedure - CW Inlet Revision L Structure Inspection 03/07/2006

4. PMP-04-14 KPS Preventive Maintenance Procedure - CW Pump Revision G Suction Vault and Discharge Piping Zebra Mussel and 04/24/2007 Organic Macro Fouling Inspection

5. PMP-89A-01 KPS Preventive Maintenance Procedure - Building Revision G Settlement Detection Reading 06/03/2003

6. PI-AA-100-1007 Nuclear Fleet - Operating Experience Program Revision 2 11/18/2008

7. NEP-14.13 Operating Experience Procedure Revision 14 02/28/2008

8. CR027873 White Substance on Wall and Ceiling of Waste Drumming 12/28/2007 Room under Spent Fuel Pool.

9. CAP 15107 Column 1-A is Corroding at Base March 2003

10. CAP 15975 Containment Refueling Pool Outer Face Cracking and April 2003 Leaching

11. CAP 15099 Screen House East Wall Degradations March 2003

12. CR095754 Apparent High Chloride and Sulfates in Groundwater April 2008 In comparing the 7 program elements in the applicants program, the staff observed that the references for implementation of the GALL Report are not clearly included. The applicant verbally confirmed that they are meeting the GALL References. The staff will issue an RAI to address this issue. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP.

The applicant has committed to implement an enhancement affecting the Scope of Program program element. This enhancement will define structures, structural elements, and miscellaneous structural commodities that are in scope. In this regard, the applicant provided DMR-712 which presents the list of structures, structural elements and components. The applicant has also committed to enhance Groundwater Monitoring. This enhancement will improve periodic groundwater monitoring. Groundwater quality impacts the potential for below-grade concrete degradation. It will ensure timely detection and assessment for a ground water change to an aggressive state. The applicant has also committed to enhance the Parameters Monitored or Inspected, Monitoring and Trending, and Acceptance Criteria, program elements. These enhancements will be put into action by performing underwater (circulating water intake crib/discharge pipe and Screenhouse forebay/pumpbay) visual inspections for aging effects consistent with the affected program elements. The applicant stated that the enhancements are consistent with current implementation practices, and the enhancements formally incorporate these practices into applicable implementing procedures.

The staff audited the operating experience reports, including a sample of condition reports prepared by the applicant, 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 also conducted an independent search of the applicants condition report database for operating experience relevant to AMP XI.S6, XI.S5, and XI.S7. A search of keywords: masonry wall, groundwater ,leaching, underwater structures, resulted in about 300 records. The staff screened these records for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP. Also, the staff identified CR 027873 where it was reported about white substance that was observed on the wall and ceiling of the waste drumming room. The staff will consider issuing an RAI to address this issue, and the staffs evaluation will be documented in the SER. Also, CR095754 was identified for apparent high chlorides and sulfates in groundwater. This issue was discussed with the applicant. 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 AMP audit, the staff compared 7 program elements in the applicants program and an RAI will be issued to verify implementation of all the references specified in the GALL AMP XI.S6, XI.S5, and XI.S7.

The areas in which the staff felt additional clarification might be warranted as described above will be evaluated separately in the SER.

LRA AMP B3.2, Metal Fatigue of Reactor Coolant Pressure Boundary In the KPS LRA, the applicant stated that AMP B3.2 is an existing program that is consistent with the program elements in GALL AMP X.M1, Metal Fatigue of Reactor Coolant Pressure Boundary with an enhancement. The enhancement is related to routinely updating the status of transient cycle counts and fatigue usage.

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 AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Document Title Revision / Date Metal Fatigue of Reactor Coolant Pressure Rev. 1, 7/22/2008 KLR-1302 Boundary KLR-0101 Personnel Qualification and Training Rev. 1, 8/01/2008 KLR-0801 Time Limited Aging Analysis Evaluations Rev. 1, 8/08/2008 KLR-0902 Operating Experience Review Rev. 2, 4/23/09 KLR-1216 60-year Cycle Projection Rev. 1, 8/20/08

Document Title Revision / Date SP-55-226 1/08/2009 Surveillance Transient or Operational Cycles Procedure Transient or Operational Cycles SP-55-226 Surveillance (Data sheets from November 16, 1998 through Procedure data sheets November 28, 2006)

Rev. 0, CR166111 RCHL Sample Line Thermal Cycling 7/24/2006 Pressurizer Bubble Formation Impact on Fatigue Rev. 0, CR169516 Usage 10/20/2006 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B3.2 are consistent with GALL AMP X.M1 program elements. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in the GALL AMP. KPS Metal Fatigue of Reactor Coolant Pressure Boundary (MFRCPB) program claims no exceptions, only one enhancement. The staff also verified that the applicant provided an adequate summary description of the program.

The applicant has committed to implement an enhancement. The applicant states that this enhancement will affect the Preventive Actions, Detection of Aging Effects, Acceptance Criteria, and Corrective Actions program elements. Based on its review, the staff found the applicants claim that the enhancement would affect the cited program elements reasonable because the enhancement will give the program the ability to update the status of the fatigue usage, initiate corrective action if necessary, and ensure the fatigue usage meet the acceptance criteria, i.e., keeping fatigue usage within the design limit.

The enhancement is to require a routine assessment of the transient cycle count totals and fatigue usage (CUF) status to be performed for the monitored locations. The enhancement also includes an action limit provision, which will initiate corrective action if the current cycle counts or CUF values exceed 80 percent of the design limits. The applicant indicates that with the enhancement the accrued current transient cycles and CUF will be compared against the projected 60-year values to confirm that the projections are accurate.

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

Onsite document KLR-0902, as identified in the above table, documents industry operating experience. Attachment 2 of this document contains a very large collection of NRC generic documents taken from GL, IEB, IN, RIS, GSI and ISG, over 2.5 years of generic communication.

The staff performed a search of reports relating to metal fatigue. However, the search generated none in the metal fatigue area.

The staff also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B3.2. A search with keywords: fatigue usage and dissolved oxygen resulted in 19 records. The staff screened these results for relevance to the

AMP and used them to evaluate the adequacy of the applicants operating experience review.

The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

The staff found that all 7 program elements audited are consistent with those described in GALL AMP X.M1. However, elements 3, 4, 5 and 7 involve utilizing non-conforming software, FatiguePro, to carry out the required functions identified in each of these elements. The staff will consider issuing RAI on this subject and the staffs evaluation will be documented in the SER.

During the audit, the staff interviewed the applicants technical staff on both the AMP and TLAA areas. These interviews focused on transient cycle tracking and stress analysis methods.

Since the applicant did not provide complete answers at the time of audit, the staff will consider issuing RAIs on these subjects, if appropriate, and the staffs evaluation will be documented in the SER.

In its review of the onsite document of the metal fatigue AMP (KLR-1302 Revision 1), the staff noticed a discrepancy in the transients between those listed in the onsite document Table 2-1 and those listed in LRA Table 4.3-1 and in the USAR. The onsite document listed significantly many more transients than the LRA did. The staff is concerned whether all transients listed in the onsite document Table 2-1 were considered in the fatigue evaluation for the license renewal application. During the onsite interview, the KPS technical staff asserted that license renewal is CLB based application and so it is not required to include those transients that are beyond those defined in the original design specifications. Pursuant to the regulatory requirements, the staff found the applicants argument acceptable.

During the audit, the staff verified that the KPS transient tracking system has been appropriately set up by reviewing the data sheets collected over the most recent 8 years of plant operation, November 1998 through November 2006. The records demonstrated that the thermal events were documented in accordance with KPS Surveillance Procedure SP-55-226, as required.

The cycles logged in the data sheets are consistent with those shown in LRA Table 4.3-1.

The 3 program elements, corrective actions, confirmation process and administrative controls were audited as part of the Scoping and Screening Methodology audit. During the AMP 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 AMP X.M1, not including the areas in which the staff felt additional clarification might be warranted as described above.

LRA AMP B3.1 Environmental Qualification (EQ) of Electrical Components In the KPS LRA, the applicant stated that AMP B3.1 is an existing program that is consistent with the program elements in GALL 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

AMP. The staff interviewed the applicants technical staff and reviewed the following onsite documents:

Revision /

Document Title Date Generic Lessons Learned (GALL) Report Chapter X, Time-Vol. 2, Limited Aging Analysis Evaluation of Aging Management

1. NUREG 1801 Revision 1 Programs Under 10 CFR 54.21(c)(1)(iii), AMP X.E1, 09/2005 Environmental Qualification of Electric Components.

2. Regulatory Environmental Qualification of Certain Electric Equipment Revision 1 Guide 1.89 Important to Safety for Nuclear Power Plants June 1984 EQ Related HELB Issues Identified as a Result the HELB

3. CAP025993 3/7/2005 EOC Walk down EQ H3 Evaluation for SVs 33289/33290 Doesnt Comply

4. CAP022755 9/17/2004 with EQ plan Criteria Environmental Qualification Evaluation and Review (EQER)

5. CAP000511 12/1/2001 Revisions EQ Evaluation Required to Ensure Qualification to Power

6. CAP013798 11/25/2002 Uprate Radiation Levels

5. SA023110 Kewaunee EQ Focused Self-Assessment 6/20/2006

6. Technical License Renewal Project Aging Management Program 4/21/2008 Report KLR-1301

7. KPS-SA-07-19 Informal Self-Assessment Plan/Report 4/24/2007

8. 2004-001-2-018 Nuclear Oversight Observation Report 4/8/2004 In comparing the 7 program elements in the applicants program, the staff verified that the program elements contained in AMP B3.1 are consistent with GALL AMP X.E1 program elements except for the specific reference to the use of ambient temperature monitoring to modify qualified life through reanalysis. Gall AMP X.E1 states that condition or performance monitoring programs is an acceptable basis to modify a qualified life through reanalysis (per Regulatory Guide 1.89, Rev. 1). However, the applicant did not describe how ambient temperature monitoring is performed and controlled under the EQ program consistent with GALL AMP X.E1 and will ensure that component qualified life remains bounded with respect to ambient temperature. The staff will consider issuing an RAI to address this issue. The staff confirmed that the boundary conditions of the plant program are enveloped by the boundary conditions described in GALL AMP B3.1. The staff also verified that the applicant provided an adequate summary description of the program.

The staff audited the operating experience reports, including a sample of representative corrective action program (CAP) and corrective action reports prepared by the applicant, and interviewed the applicants technical staff to confirm that the plant-specific operating experience did not reveal any degradation not bounded by industry experience. CAP examples included potential adverse environmental conditions not considered in the EQ program, electrical equipment EQ classification not in compliance with EQ classification criteria. Additionally, industry and applicant self assessments of the EQ program effectiveness and implementation were performed. Although improvements and backlog of EQ documentation updates were identified, the assessments found the applicants EQ program adequate. The applicant implemented a program to address areas of improvement and the EQ documentation backlog.

The staff also conducted an independent search of the applicants condition report database for operating experience relevant to AMP B3.1. A search with keywords: EQ, environmental qualification, electrical, EQ program, equipment qualification, components, and cable resulted in over 100 records. The staff screened these results for relevance to the AMP and used them to evaluate the adequacy of the applicants operating experience review. The staff verified that the operating experience described in the applicants basis document adequately addresses the plant-specific operating experience for this AMP.

The 3 program elements, corrective actions, confirmation process and administrative controls were reviewed as part of the Scoping and Screening Methodology audit. During the AMP audit, the staff compared 7 program elements in the applicants program and verified that these 7 elements for the AMP were consistent with those specified in GALL AMP X.E1, not including any areas in which the staff felt additional clarification might be warranted as described above.

Independent Operating Experience Review The purpose of this activity was to perform an Independent Search of an Applicants Operating Experience (OE) Database to determine the adequacy of the License Renewal Applicants use of OE to inform the AMPs for its extended period of operation.

Plant OE plays an important role in License Renewal and figures prominently in a LRA, as stated in the OIG report OIG-07-A-15 September 6, 2007. The NRCs Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants (Standard Review Plan) provides guidance to the NRC staff on assessing the 10 program elements for each AMP submitted in a LRA. OE is listed as one of these elements, and defined in brief in the GALL Report.

The on-site specific and industry OE is also an important part of two other AMP elements:

specifically, detection of aging effects and monitoring and trending. The Standard Review Plan also calls attention to the importance of the applicants specific OE in relation to scoping and screening, AMR, and time-limited aging analysis activities.

For the aging management audit of the KPS, two dedicated audit team members, with plant experience, conducted an independent search of the applicants plant-specific OE database in providing the staff team members with relevant and appropriate OE, and the associated corrective actions performed. The total amount of specific OE items searched and extracted from the applicants database was in excess of 2500 items. The use of key search words was required to search through the applicants condition reports, CAP, design basis, work orders, and licensing documents relevant to the applicants AMPs. These database searches were independent of the applicants input contained in the LRA, and allowed for deeper probes and verification of the applicants specified OE used to inform the AMPs.

The results were further screened by the staff while reviewing individual AMPs for relevance and adequacy and used to help in some cases develop further RAIs to obtain more information regarding particular AMP reviewed. Due to the applicants restricted use of their database, a dedicated plant staff member with experience in using the database computer system was available and assisted in the staffs review of the site OE data base.

The KPSs CAP database extends back to the year 1997 along with corrective action and condition reports. The staff in performing this independent review of acquiring, screening, verifying, and reviewing the applicants database documents resulted in an extensive OE review, and provides reasonable assurance that the applicant had used relevant OE for informing the proposed AMPs for use during the period of extended operation.

Material and Environment Random Sample Verification The purpose of this activity was to perform a verification of Materials and Environmental Entries in the AMR Tables contained in the License Renewal Application.

The applicant for the proposed KPS license renewal determined specific component material and environment(s) used for the AMPs by performing an integrated plant assessment (IPA) in accordance with requirements of 10 CFR 54.21(a). The IPA first involved: (1) identification of the plant systems, structures and components that are within scope, in accordance with 10 CFR 54.4, Scope, of license renewal and (2) determined which specific components require an AMR referred to as Screening. The screening process identified in-scope passive components subject to an AMR. Short-lived passive components, which could be excluded from an AMR on the basis of a qualified life or a specified replacement time period, were also identified and removed from any further aging evaluation considerations.

To validate the KPS plant-specific in-scope component material and environment(s) selected by the applicant subject to an AMR during the proposed extended operating period, the staff performed an independent on-site audit. Due to the extensive number of actual components subject to an AMR the staff developed a statistical method to sample the KPS material and environment combinations for the component information submitted by the applicant as part of the LRA. A random sample of thirty components and their environments were selected in advance for the on-site audit and these specific line items were provided to the applicant prior to the audit to ensure that references could be provided for inspection and validation.

The staff performed an on location material/environment verification by walkdowns and by review of KPS plant-specific reference documentation. These reference documents included the Kewaunee Updated Safety Evaluation Report (USAR), Plant System and Design Drawings, Plant Design Specifications, Plant System Descriptions, Component Vendor Manuals, Vendor Correspondence and Purchase Order information. The staff was able to visually inspect fourteen of the thirty items randomly selected for this audit. These items represented all components that could be readily accessed by walkdowns inside and outside of the physical plant. Examples of component walkdowns included; emergency diesel generator, screen-house, control room cooling coils, make-up and demin water supply; and various components in the administrative and auxiliary buildings.

During the staff review of the thirty selected items, twenty nine items were verified by the staff to be correct in the LRA application. The staff noted in its walkdowns and in subsequent document searches of the applicants references, drawings and material specifications that the diesel generator Filter Housings in LRA Table 3.3.2-19 was not correct in regards to material environment description regarding an as-found filter housing that was Aluminum and

contained lube oil as an internal environment. The applicant had only listed Steel with a lube oil environment in its table.

In follow up discussions with the applicant over a proposed RAI, the applicant staff had also concluded that the Aluminum filter housing was missed in its component material/environment KPS evaluation for an AMR. As a result of this discrepancy the applicant submitted a corrective action to change the description in Table 3.3.2-19 and add an appropriate AMP that included lube oil environment with the aluminum filter housing component group. With this corrective action taken the staff found that the draft RAI was not required. The following table depicts the detailed findings during the KPS Material Environment random sample verification.

Table: Material and Environment Random Sample Verification Material Environmental LRA 1 Source of System Subcomponent Material Environment Information Information is Table Verification is correct correct Penetration seals (flexible seals, (E) Borated water USAR, 3.5.2-2 Shield Building Steel Yes Yes bellows seals, leakage DWG M-381 plates seals)

Annulus sumps USAR, 3.5.2-2 Shield Building Concrete (E) Raw water Yes Yes and trenches DWG S-218 (I) Treated water-Primary Sample Heat 3.3.2-29 Steel closed cycle Yes Yes USAR Sampling Exchangers (Shell) cooling Control Room (I) Treated water Walkdown, Steam Humidifier 3.3.2-10 Air Stainless Steel and/or steam- Yes Yes Visual Sparger Conditioning secondary Examination Air outlet structure Walkdown, Administration (walls, slabs, 3.5.2-3 Concrete (E) Soil Yes Yes Visual Building louver housing, Examination and grating)

Chemical and (I) Treated water- Plant Design 3.3.2-9 Volume Pipe (Class 1) Stainless Steel Yes Yes primary Specification Control Liquid Waste Sludge Interceptor (E) Air-indoor Plant System 3.3.2-22 Processing Stainless Steel Yes Yes Tank uncontrolled Description and Discharge (I) Treated water-Secondary Plant System 3.4.2-12 Storage Tank Steel closed cycle Yes Yes Sampling Description cooling Walkdown, Diesel (E) Air-indoor 3.3.2-19 Pipe Steel Yes Yes Visual Generator uncontrolled Examination 1

Definitions for Service environments are described in Table 3.0-1 of the KPS LRA.

Material Environmental LRA 1 Source of System Subcomponent Material Environment Information Information is Table Verification is correct correct Main Walkdown, Generator Hydrogen Side 3.4.2-11 Steel (I) Lube oil Yes Yes Visual (Mechanical) Seal Oil Pump Examination and Auxiliaries Gaseous Waste Waste Gas Plant System 3.3.2-21 Steel (I) Raw water Yes Yes Processing Compressors Description and Discharge Primary (E) Air-indoor Plant Design 3.3.2-29 Bolting Steel Yes Yes Sampling uncontrolled Specification Safety (E) Borated water Plant Design 3.2.2-2 Bolting Steel Yes Yes Injection leakage Specification Walkdown, Administration Equipment (E) Air-indoor 3.5.2-3 Concrete Yes Yes Visual Building pads/grout uncontrolled Examination (I) Treated water Secondary Plant Design 3.4.2-12 Valves Stainless Steel and/or steam- Yes Yes Sampling Specification secondary Steam (I) Treated water Generator Plant Design 3.4.2-6 Tubing Copper Alloys and/or steam- Yes Yes Blowdown Specification secondary Treatment USAR and Reactor (I) Treated water-3.1.2-3 Tubing Stainless Steel Yes Yes Plant Design Coolant primary Specification Reactor Westinghouse (E) Treated 3.1.2-2 Vessel Baffle/former bolts Stainless Steel Yes Yes LTR ARIDA-water-primary Internals 08-63 Diesel Generator (E) Treated Walkdown, Diesel Cooling Water 3.3.2-19 Copper Alloys water-closed Yes Yes Visual Generator Heat Exchangers cycle cooling Examination (Tubesheet)

Material Environmental LRA 1 Source of System Subcomponent Material Environment Information Information is Table Verification is correct correct Miscellaneous Steel [embedded steel exposed surfaces (shapes, Walkdown, (E) Air-indoor 3.5.2-2 Shield Building plates, unistrut, Steel Yes Yes Visual uncontrolled etc.) ladders, Examination gratings, checkered plates, stairs, handrails]

Control Room Air Handling Units (I) Treated water-Vendor 3.3.2-10 Air (Cooling Copper Alloys closed cycle Yes Yes Manual Conditioning Coils/Fins) cooling Walkdown, Diesel 2 3.3.2-19 Filter Housings Steel (I) Lube oil No Yes Visual Generator Examination Auxiliary Walkdown, Flexible (I) Air-indoor 3.3.2-13 Building Elastomers Yes Yes Visual Connections uncontrolled Ventilation Examination Miscellaneous (E) Borated water Plant Design 3.3.2-27 Tubing Stainless Steel Yes Yes Gas leakage Specification (I) Treated water 3

3.4.2-3 Bleed Steam Restricting Orifices Steel and/or steam- No Yes NA secondary Walkdown, Water conduit 3.5.2-12 Screenhouse Concrete (E) Soil Yes Yes Visual inlets Examination Auxiliary Walkdown, (I) Air-indoor 3.3.2-11 Building Air Ductwork Steel Yes Yes Visual controlled Conditioning Examination 2

This was an error of omission. Applicant failed to recognize that there are filter housing Aluminum material for Lube Oil environment.

3 Applicant could not absolutely identify component so they used Engineering Judgment based on similar known material and environment.

Material Environmental LRA 1 Source of System Subcomponent Material Environment Information Information is Table Verification is correct correct Reactor Walkdown, Flexible (I) Air-indoor 3.3.2-14 Building Elastomers Yes Yes Visual Connections uncontrolled Ventilation Examination Makeup and Walkdown, (I) Treated water-3.3.2-24 Demineralized Strainer Housing Stainless Steel Yes Yes Visual primary Water Examination Heater and Walkdown, Moisture (E) Air-indoor 3.4.2-9 Level Glass Glass Yes Yes Visual Separator uncontrolled Examination Drains